CICO, K-REACH’s SIEF System Finally Opens

The highly anticipated K-REACH CICO (analogous to EU REACH’s substance information exchange forum -SIEF) finally opened on 7th October. Companies that want to complete joint-registration need to join CICO first. Enterprises willing to play the role of LR or AM in CICO, are advised to join as soon as possible to improve the outcome in the LR/AM election.

On 7^th October 2019, South Korea finally open the Chemical Substance Information Communicative Organization (CICO) ^[1] to the public. CICO is the SIEF system used in K-REACH and is a hugely important topic for stakeholders (Chemlinked News ^[2]). According to Article 10 of K-REACH, the existing chemical substances which are imported or manufactured over 1 ton per year shall complete pre-registration or late pre-registration to obtain a Grace Period for importation or production prior to formal registration. For enterprises that wish to register the same substance, it is necessary to join CICO first and then establish a "consortium" to prepare for joint registration during the grace period.

Like the SIEF system under EU REACH, the registration process under the CICO of K-REACH includes establishing CICO of the substance, electing the lead registrant, and preparing registration, etc. The prerequisites of joining CICO are:

Complete the pre-registration of the existing substance before 30^th June 2019; or
Have completed the late pre-registration of the existing substance.

Lead Registrant (LR), Active Member (AM) and Passive Member (PM) are the three roles in CICO. Among the three roles, LR and AM will occupy a dominant position in the joint-registration and shoulder certain responsibilities. Specifically, LR and AM will operate CICO together, including formulating cost-sharing rules, preparing registration dossiers, paying for early data testing fees, etc. For PMs, they will be passive during the joint-registration and may be charged a higher fee.

For enterprises willing to play an LR or AM role in CICO, we suggest you join CICO as soon as possible. Especially stakeholders dealing in existing substances with a volume over 1000 tons per year or CMR substances with a volume over 1 ton per year. Both substance categories will be subject to formal registration requirements starting on 31^st December 2021. Relevant enterprises are advised to complete the pre-registration and join CICO as soon as possible.

Here are some tips about CICO:

Only the domestic importers or manufacturers are qualified to join CICO. Overseas companies need to entrust a domestic OR.
Companies that will assume the role of LR or AM need to act immediately and are advised to complete registration as soon as possible and join CICO to obtain priority treatment in subsequent LR elections and CICO operation.
Stakeholders should choose whether to assume the role of LR when applying to join CICO.
A “coordinator” role is added in CICO, which is responsible to operate CICO before LR is determined. Generally, the first member who joins CICO and expresses willingness to assume LR status will become the coordinator. The coordinator can collect corresponding management fees.
CICO members will vote for the final LR, the election can be conducted as early as 30 days after the coordinator’s identity is confirmed.
The voting and election can be conducted online, within a specified time. Stakeholders may not opt-out of CICO during the voting period.

At last, it is worthy to mention that a user guide on the CICO system operation was released together with the notice. More information about CICO and K-REACH can be found on Chemlinked ^[3] (in English) and REACH24H ^[4] website (in Chinese). What’s more, please don’t forget that REACH24H Consulting Group is always ready to help you with the sign-up and participation work of CICO.