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South Korea’s Act on Registration and Evaluation, etc. of Chemicals (K-REACH) was overhauled in 2018 and fully implemented as of January 1, 2019. Leaving only half a year before the first registration deadline of December 31, 2021, the Ministry of Environment (MoE) proposed draft amendments to the K-REACH Enforcement Rules[1] by MoE Notice No. 2021-421 to clarify some issues so as to ease compliance burden and streamline the review work. Comments are welcome before July 13, 2021.
The followings are the major proposed amendments worth the attention of enterprises:
Exemptions for the submission of Chemical Safety Report (CSR) for low tonnage polymers
The registration of polymers manufactured or imported below 1,000 tons per year is exempt from CSR submission. Under the current regulations, some experimental data for polymer registration can be exempted based on the tonnage band, whereas the CSR does not apply for the exemption. In actual registration, it is difficult to produce a complete CSR due to the partial exemption of experimental data. Thus, the draft amendments were proposed to exempt polymers under 1,000 tons from submitting CSR, which will relieve stakeholders’ concern about registration difficulties and costs.
Exemptions for duplicate submissions under K-BPR and K-REACH
As proposed, the same data already submitted under K-BPR for registration of biocidal active substances can be exempt from submission for registration under other regulations, such as K-REACH. The current registration requirements of K-BPR and other Korean regulations have overlapping parts, and some data requirements under K-BPR are even higher than those of other regulations. The proposed amendments are to ease the industry compliance burden and relieve the authority from duplicate review work.
Establishment of a system for appeal of hazard evaluation results
Enterprises that disagree with the hazard evaluation results are allowed to submit an appeal to the National Institute of Environmental Research (NIER) within 20 days of receiving the notification of the evaluation results. The manner and specific process for making an appeal will be further stipulated.
