I. Main issue on tracking and management system of chemical records

I.  Main issue on tracking and management system of chemical records

1. Problems of current system

- Chemicals or chemical products to be imported into Korea for the first time must be verified and written on Letter of Confirmation (LoC) if it contains any regulated substances such as PECs, toxic substances, etc. and this LoC shall be submitted to the Korea Chemical Management Association (KCMA). According to the MoE’s investigation, non-submission and/or false report of it are over 40%, which means it is necessary to revise current chemical confirmation system. 

2. Improvement of current Chemical Confirmation system

- Accordingly, the government is going to assign a chemical identification number (i.e. chemical confirmation number) to identify chemicals based on its physical status, hazard and risk information and use that are submitted by manufacturers and importers, and those information is registered/managed/disclosed on chemical information system, thus chemical circulation can be periodically monitored.   

- Frequency of Chemical Confirmation for same product is going to be changed from once for the first time to every five years.

-For foreign manufacturers, a representative (OR) can be appointed to fulfill importer’s duty, but chemical component and its content can be protect as Confidential Business Information(CBI) via OR. In addition, the OR is punished for false reporting of hazard information and so on.

3. Delivery of Information 

- When providing chemicals to downstream users, chemical identification number, presence of hazardous chemical, hazard/risk information must be written and provided. However, when providing MSDS according to Article 41 of the Occupation Safety and Health Act, such information can be included and provided to material safety data (SDS). 

- Any person, who is required to report a chemical confirmation, shall not report or provide false information to downstream users.

4. Implementation of the amendment

- The revised regulations are to be enforced two years after the public announcement. After regular session of the National Assembly in September 2019, it will be implemented at the end of 2020 at the earliest.

II. Countermeasures of Industry

II. Industry's countermeasure

- Submit industry’s opinions to the MoE by 13 June.

- Since all chemicals and products distributed/circulated in the market regardless of its volume are ultimately subject to this new confirmation system and a chemical identification number is given after the notification of all chemical components, CBI for disclosing component may be a crucial issue. 

- As delivery of chemical identification numbers within the supply chain is mandatory, supply chain management systems will have to be established while CBI is protected.

- For foreign manufacturer, information protection can be done by OR, but it is very important to select a reliable OR and to consider relevant cost.

Chemtopia Co., Ltd. provides corresponding services to comply with amended and legislated regulations :

· Chemical registration service including Pre-registration, OR service, Read-across or QSAR approach, CSR preparation, Data sharing and negotiation
· Chemical inventory for regulatory tracking
· Support of regulatory monitoring and volume tracking with chemical management system
· Provision of domestic and foreign chemical regulatory database
· MSDS and label authoring system
· Test arranging & its monitoring with domestic and foreign test institutes

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