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South Korea Addresses Concerns over Two Special Cases for K-REACH Pre-registration

The amended K-REACH requires all existing substances that are manufactured or imported in quantities at or above one tonne per year to be registered. Existing chemical substances pre-registered before Jun 30th, 2019 will be granted a grace period to complete full registration. The authority now calls on potential registrants facing the two special situations detailed below to submit application in time to obtain a registration grace period as well.

Situation 1

For UVCB substances (Substances of Unknown or Variable composition, Complex reaction products or Biological Materials) and intermediates, etc. that have been manufactured, imported or used before 1991 (legally for listing on South Korea’s Existing Chemicals Inventory) while omitted from the inventory, they still can apply to the Korea Environment Corporation (KECO) for pre-registration before Jun 30th, 2019. However, the registrants will be required to provide proof of their circulation in South Korea before 1991.

The updated KECI contains 44,478 existing substances (CL news), including:

  • Annex 1 of 37,088 chemical substances domestically circulated in Korea prior to Feb 2nd, 1991; and

  • Annex 2 of 7,390 chemical substances published by MoE after hazard evaluation under TCCA after Feb 2th, 1991.

Please click here to download the Annex1 and click here to download the Annex 2. The corresponding hydrates are also regarded as existing chemical substances.

Situation 2

To relieve Korean importers’ anxiety facing a situation where their pre-registration deadline is approaching but their overseas suppliers haven’t responded to (1) disclose substances information to importers for pre-registration, or (2) designate an only representative (OR) to complete pre-registration, the authority announced it will accept applications for such cases before Jun 30th and then will grant importers a registration grace period as well.

A Korean importer should submit as much chemical information as available to KECO for application. Evidence that the importer has tried their best to obtain information from the overseas supplier or require pre-registration through appointed OR should be attached with the application.

This step is important as chemical information is a basis for finding co-registrants of identical substance to complete the phase-in registration. Although the importer can obtain a grace period, it will still be a struggle to obtain the chemical information and complete pre-registration as normal. Otherwise, changing supplier or leaving the market are the only options available.

For the above situation 1 and situation 2, it should be indicated if the concerned products contain CMRs then phase-in registration must be completed before 2021.

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