The revised K-REACH regulation has introduced pre-notification (similar to pre-registration under EU-REACH). The pre-notification window is from 1 January to 30 June 2019.
Pre-notification is required for all existing substances manufactured/imported ≥1 tonne/year. Only companies who have pre-notified will be able to take advantage of the extended K-REACH registration deadlines (listed below) for existing substances.
The K-REACH registration deadlines for existing substances are as follows:
- 31 December 2021 for 1000+ t/y and CMR substances ≥1 t/y
- 31 December 2024 for 100-1000 t/y
- 31 December 2027 for 10-100 t/y
- 31 December 2030 for 1-10 t/y
Note that pre-notification is not possible for new substances, as new substances must be notified (<0.1 t/y) or registered (≥0.1 t/y) prior to manufacture/import.
Do I need to pre-notify my substances?
You will have to pre-notify if your substance:
- Is an existing substance (i.e. is listed on the Korean Existing Chemical List)
- Has been manufactured/imported ≥1 t/y in at least one year between 2016 and 2018
Are there exemptions to pre-notification?
Some existing substances are exempt from the pre-notification requirements. For example:
- Substances controlled by other regulations (Radioactive substances, pharmaceutical products etc.)
- Substances designated as Priority Existing Chemicals (510 substances – these must be registered prior to manufacture/import)
- Substances exempt from Registration under K-REACH (e.g. substances used for R&D or for export only) (in some cases, companies must submit an application for “Confirmation of Exemption from Registration” prior to claiming the exemption)
- Substances announced as exempt by the Ministry of Environment due to their low hazard/risk potential
What are the data requirements?
From 1 January to 30 June 2019, manufacturers and importers must submit pre-notifications to Korea Environment Corp (Keco).
The data requirements are as follows:
- Legal entity information
- Substance identity
- Estimated manufacture/import tonnage band
- GHS Classification/Labelling
- Use category
- Only Representative Appointment letter (when a non-Korean manufacturer/formulator appoints an OR)
Is late pre-notification possible?
Late pre-notification is also possible for substances manufactured/imported ≥1 tonne/year for the first time after 30 June 2019.