Current K-REACH

Amendment (Draft)

Notification of existing chemicals subjects to registration every 3 years. (1st batch 510 substances: Register until June 30th of 2018) 

Different registration timeline is applied depending on volume band of existing chemicals exceeding 1 ton. 

Registration of all new chemicals regardless of their volume.

Registration of new chemical exceeding 100 kg/year still exists, but a simple notification system is applied for new chemical below 100 kg/year.  

No pre-registration.   

Pre-registration system is adapted in order to identify co-registrants. (i.e. notification of chemical name, expected manufactured or imported tonnage band, and other simple information)

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Notification of CMR component and its content are required when a CMR substance is present in a product exceeding 0.1% and 1 ton. 

Information communication in supply chain (Both manufacturer and importer are required to provide downstream users about chemical information for registered chemical substance and product containing of this substance).

Expanding of information communication (It is applied not only for registered substance, but only hazardous substance*)  

*Definition of hazardous substance : Toxic, authorized and restricted & banded chemicals)

Penalty for manufacture/import without registration is less than 5 years of imprisonment or less than USD $88,000 fine.

Penalty for manufacture/import without registration is proportionally applied on sales profit. (less than 5 % of sales profit is imposed as fine, but 2.5 % is imposed for a small sized enterprise having a single business unit)

Group A - Classified as hazardous according to GHS

: Sequential registration depending on tonnage band by 2030 with preparing data

Requirement. 

Group B – Classified as non-hazardous according to GHS

: Requiring a simple data (approx. 15 data) regardless of substance’s volume.

K-BPR

Application for grace period is required for approval of active ingredients being circulated before enforcement data, January 1st, 2019.

Step-wise approval for active ingredient that is already applied for grace period.

For a product containing active ingredient, authorization is required based on its safety, effect & efficacy information.  

After changing name of “Risk concerned product” under K-REACH to “Household chemical product subject to suitability check” in K-BPR, corresponding product includes not only products used in household, but also products used in office and in multi-use facilities.

à Requires suitability check on safety standard every 3 years.  

It is banded for advertisement using a phrase such as “Safe”, “Eco-friendly”, etc. that may lead misunderstanding to consumer. 

[Impact on industry and its countermeasure]

- Since there is no change in registration deadline for 510 pecs, completion of joint registration on time (~June 30th of 2018) is inevitable. 

- Pre-registration period is expected for 6 months from the enforcement date of amended K-REACH, which is July 1st, 2018, therefore, chemical inventory work for each company to identify relevant substance is recommended to avoid missing pre-registration.

- Especially for overseas manufacturers/exporters, it is important to appoint Only Representative for relevant substances, before the enforcement date of amended K-REACH.