K-REACH Joint Registration Pilot Project

To better identify potential joint registration problems, and develop supporting measures for the upcoming K-REACH implementation (especially the consortium issues), Korea MoE is conducting a pilot project, choosing seven substances included in the 1st priority list subject to existing chemical registration as the test substances. However, three of the seven substances have been replaced by another three priority substances.

K-REACH requires existing chemical registration for designated priority substances, which will be issued every three years in three batches. The 1st priority list involving about 500 substances is expected to be issued by the end of this month. Potential Registrants are waiting for the issuance of the list to see whether they should comply with K-REACH exiting chemical registration.

Each of the substances selected for the K-REACH joint registration pilot project, has a representative consulting company. The corresponding consulting company will be responsible for the establishment of consortium and for providing technical support for SMEs and assisting K-REACH implementation.

According to Mr. Yun Myoung-Jin, the team leader of KCMA’s Joint Registration Support Team the reasons for replacing three substances with another three are varied. For 4,4'-Methylenedianiline, the reason given by Mr. Yun is that due to extremely high registration costs, all potential registrants have withdrawn their registration application. For (butoxymethyl) oxirane, the potential registrants have pulled out as a viable alternative has been found to take its place. For the third substance registrants wanted to register diisocyanatomethylbenzene and its isomer 2,4-Diisocyanatotoluene together rather than doing registration separately, which caused disagreement with the authorities and finally resulted in the substance being dropped.

The original application period was from 28 Aug to 11 Sep 2014 and lasted 15 days. However, due to the replacement of three substances, the deadline is delayed accordingly. Potential registrants who at present (or in the future plan to) manufacture or import relevant substances over 1 ton annually are eligible to apply for pilot project participation. To jointly register these substances, potential registrants need to contact Korea Chemicals Management Association (KCMA) or Korea Institute of Industrial Technology by 17 Oct.

According to Mr. Yun, for some substances more than 10 companies have applied to participate while for others only two or three companies will join the pilot project. The tonnage bands are varied from 1-10 t/y to 1000 t/y plus. Some potential registrants raised concerns about the use of the IT tools for registration dossier submission, test data trading (something like SIEF) since they aren’t ready yet. Mr. Yun expects the preparation of submission data to be done by April or May of 2015, which leaves time for the issuance of the supporting IT tools. The pilot project is planned to take a whole year and should be due in Jul 2015 but based on present work rate is likely to be delayed.

Table 1. K-REACH Pilot Project Details