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April 16, 2019

Reminder on the Upcoming June 30, 2019, Registration Deadline for Existing Chemical Substances in South Korea

Bergeson & Campbell, P.C.

The South Korea amendment to the Act on Registration and Evaluation, etc of Chemical Substances (K-REACH) came into effect on January 1, 2019.  All existing chemical substances (i.e., substances that are listed on the existing chemical inventory in South Korea) manufactured in or imported to South Korea at greater than or equal to one ton per year are now subject to registration.
 
Existing chemical substances must be pre-registered by the fast-approaching deadline of June 30, 2019.  Pre-registered substances benefit from registration grace periods that allow existing chemical substances to be imported without full registrations.
 

Substance TypeRegistration Deadline
>1000 t/y existing substances
>1 t/y CMR substances
December 31, 2021
100-1000 t/y existing substancesDecember 31, 2024
10-100 t/y existing substancesDecember 31, 2027
1-10 t/y existing substancesDecember 31, 2030


Who needs to pre-register?
 
Any person manufacturing or importing existing chemical substances greater than or equal to one ton per year.  Foreign manufacturers/producers who export existing chemicals to South Korea may appoint an Only Representative, as the legal entity, to pre-register chemical substances on their behalf.
 
How do you determine if you have an existing chemical substance?
 
Substance status can be determined by searching the Korea Existing Chemicals List (KECL).  Substances that are not listed on the Korea Existing Chemicals Inventory (KECI), substances that are designated priority existing chemicals (PEC), or substances considered exempt are not eligible for pre-registration.
 
What happens if pre-registration is not complete by the June 30, 2019, deadline?
 
If a substance is not pre-registered by the June 30, 2019, deadline, the registration grace period is inapplicable.  Substances not pre-registered will require registration before manufacture or import.  Substances that are not pre-registered or registered are subject to suspension of manufacture/import/use/sales.
 
What information is needed to pre-register?
 
To pre-register an existing chemical, the following information is necessary:

  • The name of the chemical substance; 
  • Expected annual manufacture/import quantity;
  • Classification and labels of the substance;
  • Use details;
  • Name/contact information of the manufacturer or importer; and
  • Any other information specified under the Ordinance of the Ministry of Environment.

For more information on important issues in the international chemical space, please consult Karin F. Baron, kbaron@actagroup.com, of The Acta Group (Acta®), Bergeson & Campbell, P.C.’s (B&C®) consulting affiliate.