Regulatory Update on K-REACH 2018 Revision
New Implementation Rules Have Been Released: Existing Substance Pre-Reporting deadline is 30 June 2019
28 August 2018
On May 30, South Korea's Ministry of Environment (MoE) published draft implementation rules for the amended Registration, Evaluation, and Authorization of Chemicals legislation in South Korea (K-REACH).
Are you a manufacturer or importer of 'existing' chemicals?
If so, it is important to understand the impact of the amendments to K-REACH on your business.
Companies that manufacture or import existing chemicals at ≥ 1 ton per year now have an obligation to pre-report (pre-register) such chemicals between 1 January 2019 and 30 June 2019, in order to continue to place them on the South Korean market up to the applicable registration deadline.
The amendments to K-REACH have also introduced changes for the registration of "new" chemicals (substances / polymers). From 1 January 2019, registration will only be required where manufacture or import exceeds 100 kg per year, unless such chemicals may cause significant damage to human health or the environment or where annual volume will exceed the tonnage specified in the Enforcement Decree, published by MoE. Additionally, the amendments to K-REACH have introduced a notification obligation whereby "new" chemicals manufactured or imported at < 100 kg per year will require reporting to the National Institute of Environmental Research (NIER). These changes will require careful interpretation by manufacturers and importers to ensure they remain compliant and where possible, gain commercial advantage from the changes.
It is anticipated that the revision of K-REACH will result in the registration of approximately 7,000 existing chemicals (those listed on the former Korean Existing Chemicals Inventory - KECI), over the next 12 years. With the pre-reporting deadline quickly approaching, you must:
- Check if your products are within the scope of K-REACH
- Identity your obligations under the amended K-REACH, including:
- pre-reporting existing substances;
- tonnage band registration deadlines;
- changes to simplified registration; and
- confidential business information (CBI) exemptions for manufacturers/importers.
You are required to pre-report existing substances, including information on classification & labelling and anticipated annual volumes being manufactured or imported by 30 June 2019. An online system of the Korea Environment Corporation (Keco), which is a MoE agency, will be utilized for pre-reporting. The MoE has stated that rules for this will be published in the near future.
By pre-reporting an existing substance, a company will be able to continue to manufacture or import up to the specified registration deadline. However, if a company does not do this, it will no longer be permitted to manufacture or import the existing substance from 1 July 2019.
We're here to help!
Intertek has longstanding experience of supporting compliance with K-REACH and the parallel Industrial Safety & Health Act (ISHA) and can provide a single-source solution for complying with the registration requirements of the amended K-REACH, including Only Representative services. Supported by our locations in over 100 countries, Intertek enables companies worldwide to achieve K-REACH regulatory compliance.
Today's expert blogger is Mr. Jeremy Ramsden, who has over 30 years' experience in manufacturing industry as a chemist and project manager. Jeremy's current role within Intertek - Health, Environmental & Regulatory Services embraces managing the UK business activities and leading global chemicals management projects for EU Clients, principally for substance / polymer notifications in those jurisdictions that have implemented chemicals registration schemes, e.g. China, South Korea, Philippines, Japan, Taiwan, USA, Canada, Australia, et al.