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K-REACH pre-notification window - What you need to know

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:

  1. Is an existing substance (i.e. is listed on the Korean Existing Chemical List)
  2. 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.