Newsletter
10–100 t/y Substance Registration Deadline & Expanded Public Disclosure of Registration and Notification Information
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10–100 t/y Existing Substance Registration Deadline & Expanded Public Disclosure of Registration and Notification Information | |||||||||
Two K-REACH developments warrant attention: the December 31, 2027 registration deadline for existing substances in the 10–100 t/y band and the phased expansion of public disclosure of registration and notification information. | |||||||||
Companies should review their annual volumes and joint-registration options. Special data protection requests for first-phase Priority Existing Chemicals (PECs) remain open until December 15, 2026. For the second phase, covering registrations and notifications from before August 7, 2025 other than the PECs covered by Phase 1, requests are being accepted from October 28, 2026 to April 27, 2027. | |||||||||
K-REACH: 10–100 t/y Existing Substance Registration Deadline | |||||||||
1. Key Information | |||||||||
Remaining Registration Grace Periods for Existing Substances
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The above deadlines apply to eligible pre-registered existing substances. Certain substances were subject to earlier registration deadlines. Companies planning to continue manufacturing or importing existing substances at 10–100 t/y beyond 2027 should review their expected annual volumes and begin registration preparations well in advance. Failure to complete registration by the applicable deadline may result in an interruption of manufacturing or imports. | |||||||||
2. Key Actions Before the Deadline | |||||||||
Check the CICO¹ registration status. | |||||||||
Confirm whether a lead registrant has been appointed, whether the lead registration is completed or in progress, and whether a Letter of Access (LoA) is available. Companies should also confirm the applicable data coverage, LoA costs, and time required to complete their own registration. | |||||||||
Identify potential registration obstacles. | |||||||||
Joint registration may not be readily available if no lead registrant has been appointed, the lead registration is delayed, or the existing registration does not adequately cover the required tonnage, substance identity, or data requirements. Depending on the circumstances, additional coordination with CICO members, additional data submissions, or alternative registration arrangements may be necessary. Early action is particularly important where the lead registration is not yet available. | |||||||||
Review the expected annual tonnage. | |||||||||
Where annual manufacturing or import volumes are genuinely expected to fall below 10 t/y, companies should assess the applicability of the 2030 registration deadline and update their pre-registration information as required. | |||||||||
3. Additional Considerations for Foreign Manufacturers Appointing an OR | |||||||||
Where an OR covers 10–100 t/y in total, but individual Korean importers each handle less than 10 t/y, an importer-based approach may offer two potential advantages: • Additional time for registration: Eligible pre-registration by individual importers may allow them to benefit from the registration grace period until December 31, 2030. • Lower registration tonnage: Registration by individual importers may allow a lower tonnage band to apply, based on each importer's annual import volume rather than the total volume covered by the OR. These options require case-by-case review of pre-registration eligibility, individual import volumes, and necessary changes to the existing OR coverage. | |||||||||
¹ CICO (Chemical Substance Information Communicative Organization): A K-REACH joint registration coordination forum, broadly corresponding to the former Substance Information Exchange Forum (SIEF) under EU REACH. | |||||||||
Expansion of K-REACH Registration and Notification Information Disclosure | |||||||||
1. Expanded Disclosure and Phased Application | |||||||||
K-REACH’s disclosure requirements expanded on August 7, 2025. Disclosure concerns information entered and submitted in the relevant fields of the Chemical Substance Information Processing System, and applies to earlier registrations and notifications in phases. Registration information is not necessarily disclosed immediately upon completion. Existing substance-level hazard review information should be distinguished from the disclosure of individual registration and notification records. | |||||||||
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Special Data Protection Requests for Earlier Records | |||||||||
Companies seeking to protect eligible trade-secret information in their earlier records should apply during the relevant request period. | |||||||||
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For Phase 2, eligibility is assessed against the registration completion date for registered substances and the notification application date for notified substances. [1, 4] | |||||||||
2. Disclosure Scope and Information Eligible for Protection | |||||||||
Disclosure scope and protection eligibility differ between registrations and notifications. | |||||||||
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Points to Note | |||||||||
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For registered substances, refer to the authorities’ checklist to assess eligibility for special data protection. A consolidated English reference is attached: Special_Data_Protection_Checklist_English_Translated.pdf | |||||||||
3. Review and Submission | |||||||||
Foreign manufacturers should work with their appointed ORs to review existing records and prepare any necessary protection request. | |||||||||
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For jointly submitted registration data, or data submitted with the data owner’s consent, the relevant lead registrant must request protection in consultation with the data owner. [4] | |||||||||
Applicable Deadlines Phase 1 PEC registrations: December 15, 2026 Phase 2 registrations and notifications: April 27, 2027 According to the official notice, information for which no data protection request is submitted within the applicable period is scheduled for public disclosure. Companies should confirm the applicable phase and begin reviewing their records and supporting evidence before the relevant deadline. | |||||||||
References [1] Article 42(1)(1) of K-REACH; supplementary provisions of Notice No. 2026-195; Phase 1 official notice on registration information disclosure and special data protection requests (September 2026). [2] Enforcement Rule of K-REACH, Article 51(2)(1)(a)–(g) and Article 51(3)(2). [3] Enforcement Decree of K-REACH, Article 30(2); Data Protection Requests Regulation, Article 11-2. [4] Phase 2 official notice on registration and notification information disclosure and special data protection requests; accompanying registration and notification procedure guides, request forms, and Special Data Protection Checklists. | |||||||||
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Figure 1. Example of currently disclosed hazard review information for Formaldehyde (CAS No. 50-00-0).