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Notice on Key Document Updates under Korea’s Revised Chemical Hazard Framework
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Notice on Key Document Updates under Korea’s Revised Chemical Hazard Framework
Following the End of the Relevant Transitional Period on 1 July 2026
On August 7, 2025, Korea replaced the former “Toxic Substances” framework with the new “Substances Hazardous to Human Health, etc.” framework. Under the revised system, the former Toxic Substances category was subdivided into Human Acute Hazardous Substances, Human Chronic Hazardous Substances, and Ecological Hazardous Substances. At the same time, the concept of “Substances with unidentified hazards” was introduced for certain new chemicals notified below one ton per year where hazard information has not been confirmed.
With the relevant transitional period having ended on July 1, 2026, companies should now ensure that the current regulatory status of their products and substances is properly reflected in key compliance documents, including K-REACH Form No. 25 / Form No. 26, CCA Chemical Confirmation and its supporting Letter of Confirmation (“LoC”), and Section 15 of the MSDS.
Chemtopia previously provided an overview of the key regulatory changes introduced by the partial amendment to the Chemicals Control Act (“CCA”) (Act No. 20231), the partial amendment to the Act on Registration and Evaluation of Chemical Substances (“K-REACH”) (Act No. 20232), and the NICS Notice on the Designation of Substances with Human Acute Hazards, Substances with Human Chronic Hazards, and Substances with Ecological Hazards (NICS Notice No. 2025-19) through our 2025 newsletter, “Revision of Hazardous Substance Classification and Related Regulatory Frameworks in Korea.” For further details on the legal background and regulatory framework, please refer to the previous newsletter.
Accordingly, this newsletter focuses on the practical review and updating of K-REACH Form No. 25 / Form No. 26, CCA Chemical Confirmation and supporting LoC documentation, and the K-OSHA MSDS. Other obligations, including labeling, import notification, handling requirements, business permits or notifications, Chemical Accident Prevention and Management Plans, and handling facility standards, should be reviewed separately under the applicable laws and transitional provisions. As part of this review, companies should also reconfirm, where applicable, whether information concerning Substances with unidentified hazards is properly reflected in previously provided information and the revised MSDS format.
Key Documents, Deadlines, and Review Points
Regulation | Document | Key review points | Grace period ended on |
|---|---|---|---|
K-REACH | Form No. 25 / Form No. 26 | Reflect changes in hazard categories and concentration thresholds; re-provide updated information to importers and downstream users where the chemical safety information has changed | July 1, 2026 |
CCA | Chemical Confirmation (supporting document: LoC) | Check whether a new designation or lower concentration threshold causes the product (mixture or single substance) to newly become subject to the hazardous substance framework. Submit or update Chemical Confirmation where required; no resubmission is needed for products already submitted as containing an existing Toxic Substance | July 1, 2026 |
K-OSHA | MSDS | Reflect the current regulatory status in Section 15 and ensure that the revised Section 15 format is applied as required | July 1, 2026 |
※ MSDS Section 15 has been revised to require regulatory information to be presented by individual legal framework.
Companies should review the following items for each product.
Status of Existing Toxic Substances After the Amendment Check which hazard category the existing Toxic Substance has been converted into, and whether the product’s regulatory status has changed due to changes in concentration thresholds. | New Designation of Previously Non-Toxic Substances Check whether any substance that was not previously designated as a Toxic Substance has newly been designated as a Human Acute Hazardous Substance, Human Chronic Hazardous Substance, or Ecological Hazardous Substance. | Review of Substances with Unidentified Hazards For new chemical substances notified below one ton per year on or after August 7, 2025, confirm whether the substance has been identified as a Substance with unidentified hazards. Because this status is specific to the relevant notifier and notification, the applicable status should be confirmed for each relevant supply chain. |
Case 1. Existing Toxic Substance Converted into a Substance with Human Health or Ecological Hazards
Required Actions
Situation | Form No. 25 / Form No. 26 | Chemical Confirmation / LoC | MSDS |
|---|---|---|---|
Regulatory status remains substantially the same | Reflect the revised hazard category and re-provide the updated information | Where Chemical Confirmation was previously submitted for the product, mixture, or single substance as containing an existing Toxic Substance, resubmission is not required. Update the supporting LoC if necessary | Reflect the revised regulatory information in Section 15 |
The product newly becomes regulated due to a lower concentration threshold | Reflect the revised threshold and hazard category and re-provide the updated information | Review whether the product newly falls within the scope of Chemical Confirmation and submit or update the relevant documentation as required | Review Section 15 and, where necessary, other affected parts of the MSDS |
Case 2. Substance Newly Designated or Applicable Concentration Threshold Lowered
Required Actions
Document | Action |
|---|---|
Form No. 25 / Form No. 26 | Review whether the new designation or lower concentration threshold changes the applicable chemical safety information; reflect the change and re-provide the updated information where necessary |
Chemical Confirmation / LoC | Where the product (mixture or single substance) newly becomes subject to the hazardous substance framework, submit or update Chemical Confirmation and supporting documentation as applicable. No resubmission is required for products already submitted as containing an existing Toxic Substance |
MSDS | Review whether the new designation or lower concentration threshold changes the regulatory status of the relevant substance, mixture, or product; update Section 15 and other affected sections where necessary |
Additional Review: Substances with Unidentified Hazards
As part of the current document review, companies should reconfirm whether the applicable unidentified-hazard status is correctly reflected in previously provided information and the revised MSDS format.
Document | Review Point |
|---|---|
Form No. 25 / Form No. 26 | Where Form No. 25 or Form No. 26 has previously been provided, review whether the relevant unidentified-hazard information is appropriately reflected and update and re-provide the information where necessary |
MSDS | Confirm that the relevant unidentified-hazard information and applicable safe-handling precautions are appropriately reflected in Section 15 in line with the revised MSDS format |
※ The applicable status should be confirmed against the relevant notifier and notification.
Establish an ongoing regulatory monitoring and supply chain management system.
Regulatory compliance should not be managed solely through one-time document updates. A product’s regulatory status may change when hazard categories are revised, substances are newly designated, concentration thresholds are amended, or unidentified-hazard status varies according to the relevant notifier and notification. Companies are therefore advised to establish a system that connects regulatory monitoring with product-level compliance review, document updates, and supply-chain communication.
At a minimum, the monitoring and management system should enable companies to identify affected products, assess whether regulatory status has changed, update connected compliance documents, and ensure that revised information is communicated consistently through the relevant supply chain. Key management elements should include:
Up-to-date product composition and substance inventory, including applicable concentration ranges and relevant substance identifiers
Monitoring of changes in regulatory status, including revised hazard categories, newly designated substances, and changes in concentration thresholds
Tracking of Substances with unidentified hazards by relevant notifier and notification, including the applicable notification status and affected supply chain
Linked management of Form No. 25 / Form No. 26, Chemical Confirmation and supporting LoC documentation, and MSDS, so that changes in product regulatory status are reflected consistently across connected documents
Version control and distribution records, including identification of the latest document versions and records of recipients to whom revised information has been provided
Defined internal responsibilities and review triggers, so that relevant regulatory changes are assessed and implemented in a timely and consistent manner
Form No. 25 / Form No. 26, Chemical Confirmation and supporting LoC documentation, and MSDS should not be managed as isolated documents. Where a regulatory change affects a substance or product, the impact should be assessed across all connected documents and communicated consistently to relevant importers, downstream users, and other supply-chain actors. For Substances with unidentified hazards, this process should additionally account for the status being specific to the relevant notifier and notification.
Legal References
Partial amendment to the Chemicals Control Act (“CCA”) (Act No. 20231)
Partial amendment to the Act on Registration and Evaluation of Chemical Substances (“K-REACH”) (Act No. 20232)
NICS Notice on the Designation of Substances with Human Acute Hazards, Substances with Human Chronic Hazards, and Substances with Ecological Hazards (NICS Notice No. 2025-19, as amended by NICS Notice No. 2026-5)
Ministry of Employment and Labor Notice on the Standards for Classification and Labeling of Chemical Substances and Material Safety Data Sheets (MoEL Notice No. 2025-50)
Chemtopia Support Chemtopia can support the following services. Product and substance inventory review · Preparation and revision of K-REACH Form No. 25 / Form No. 26 · Review of Letters of Confirmation and LoCs · Review and Preparation of MSDS under K-OSHA · Only Representative services | Contact |
Chemtopia Co., Ltd. · chemtopia@chemtopia.net