Little Pro on 2018-09-17
K-REACH pre-notification will start from 1 Jan 2019 and end on 30 June 2019. It is required for all >=1t/y existing chemical substances manufactured in or imported to Korea. Only those pre-notified existing substances can benefit from registration grace periods, during which one can manufacture or import those pre-notified substances without full registrations. In this article, we will summarize everything you need to know about the K-REACH pre-registration: scope, exemptions, who, when and info requirements.
K-REACH pre-notification is only required for >=1t/y existing chemical substances. New chemical substances do not require pre-notification and they must be registered prior to manufacture or import.
For mixtures, you need to know the identity of each substance in them and calculate the total volume of each substance in all mixtures. To find out if a substance is an existing substance or not, you shall search KECL first.
Many >=1t/y existing substances qualify pre-registration exemptions. Please refer to the table below.
|Exemption||Description and Examples|
|Substances controlled by other regulations||
|The first list of 510 PECS||
|Substances exempt from registration (confirmation not required)||
|Substances exempt from registration (application of confirmation on exemption required)||
|Substances annouced by MOE as exempt from registration due to their concerns||
Note: For >=1t/y existing substances which qualify for confirmation on exemptions, manufacturers or importers do not submit pre-notifications only if confirmation on exemption certificates have been obtained.
A Korean manufacturer or importer of >=1t/y existing substances shall submit pre-notifications to Korea Environment Corp (KECO). This should be done between 1 Jan 2019 and 30 Jun 2019. Foreign manufacturers or formulators can appoint Korea-based only representatives to submit pre-notifications. Downstream users and foreign traders cannot submit pre-notifications.
Late pre-notification is also possible for existing substances exceeding 1t/y for the first time after 30 June 2019.
It is based on the maximum manufacture or import volume in any given year from 2016 to 2018. It is not based on 3-year-average (like EU REACH).
The following info is required for K-REACH pre-notification:
It should be noted that one applicant shall update their pre-notifications within one month if there are changes with:
You shall firstly make an inventory of substances manufactured in or imported into Korea, determine if they are new substances or not and determine if they are exempt from K-REACH pre-notifications. Secondly, you shall make a final list of >=1t/y non-exempt exsting substances and gather their uses and classification & labelling. Finally, you shall submit pre-notifications on time. You can do it by yourself or use a consultant.
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