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[Chemtopia Newsletter] Implementation of the K-REACH Leniency Program and Compliance Strategy

Update on ESH & Smart ESHRegistration date :2025.04.29


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Implementation of the K-REACH

Leniency Program and Compliance Strategy





The Ministry of Environment (MoE) and the Ministry of Justice of Korea have jointly announced a self-reporting period (February 28 ~ October 27, 2025, 8 months in total) under leniency program for companies that may have violated the Act on Registration and Evaluation of Chemical Substances (K-REACH). This initiative is intended to help companies come into compliance with the law by self-reporting any non-compliance.


Companies that self-report during this period will be exempt from administrative disposition and penalties. Ongoing investigations or prosecutions may be subject to leniency. However, after the self-reporting period ends (October 27, 2025~) enforcement will be strengthened, and any violations identified will be subject to strict penalties and administrative dispositions. The current self-reporting period provides a critical window for companies to comply with their obligations related to the registration and notification of chemical substances.


As a result, it is strongly recommended that companies review the relevant obligations and take appropriate action within the given timeframe.

  1. Key Information

[Who Should Self-Report]

Companies that had failed to fulfill the following obligations before, or that had manufactured or imported substances in a manner inconsistent with the obligations under the Act:

  • Chemical substance registration (Article 10(1))

  • Pre-registration of existing chemical substances (Article 10(3))

  • Updating registration (Article 12(1)) – change in the volume or use

 

 

[Reporting Period]

  • February 28th ~ October 27th, 2025 (For 8 months)

 

[Reporting Method and Relevant Authority]

  • Online application available: K-REACH IT system

  • Registration or Registration updates: National Institute of Chemical Safety (NICS) (Chemical Registration & Evaluation Team)

  • Pre-registration: Korea Environment Corporation (KECO) (Chemical Safety Support Division)

 

[Benefits to Self-Reporting]

  • Exemption from penalties and administrative dispositions

  • Leniency for ongoing investigations or pending prosecutions

 

[Consequences of Not Self-Reporting]

  • Any violations identified after the self-reporting period, strict penalties and administrative dispositions will be imposed.

  • Penalty: Up to 5 years imprisonment and a fine up to KRW 100 million (approximately USD 75,000), or administrative fines up to 5% of annual sales of company

  1. Notes to Foreign Companies Appointing OR

(1) Domestic importers must self-report their violations, even if the compliance action (e.g., registration, notification) will be carried out by their foreign supplier’s OR (Only Representative).

  • In such cases, the OR must attach an official letter in the dossier confirming that their compliance action corresponds to the importer’s self-report.

 

(2) The OR’s compliance covers only covers substances and volumes imported through the foreign companies (or supplier) that appointed the OR. Any violations committed outside this OR's scope must be addressed by the importer independently or in coordination with the relevant suppliers.

 

(3) ORs may also be subject to self-reporting for violations such as exceeding the notified the tonnage band without an update or failing to update for an unlisted use.

  1. Industry Advice

1) Conduct a thorough review of the registration and dossier status with OR

  • Periodically check the total volume of substance imported into Korea to ensure that it does not exceed the tonnage band registered or notified under K-REACH.

  • Review whether the current list of importers on each dossier is missing any importer with OR.

  • Ensure that the importers and their downstream users use the substance in the registered use scope.

2) Identify any non-compliance, and self-report

  • If there are any unfulfilled obligations related to registration, pre-registration, or updating registration, inform your OR or importers to self-report within the designated period.

  • Prepare required documentation as requested by the competent authority (NICS, KECO).

  • If necessary, contracts for testing or Letter of Access (LoA) may need to be arranged or submitted.

 

3) Strengthen internal monitoring systems


    • Implement internal monitoring procedures for chemical regulation compliance

    • Improve tracking systems for import volumes, importer list and conduct employee training if necessary.

For more information, please contact us:

☎ Inquiry: +82-(0)2-826-9100 (Main line), chemtopia@chemtopia.net