Recommendation about Pre-registration under K-REACH

In accordance with the amended K-REACH, if Korean manufacturers/ importers of existing substances have manufactured/ imported over 1t/a between 2016 and 2018, they need to submit pre-registration between 1 Jan. 2019 and 30 Jun. 2019. After submtting the pre-registration, Korean manufacturers/ importers can enjoy corresponding grace period based on the tonnage band and the hazardousness of the substance. However, some enterprises find it difficult to complete pre-registration in some special circumstances. #The Ministry Of Environment(MOE) has given the following recommendations:

1. UVCB Substances without KE Number

UVCB Substances refer to Substance of Unknown or Variable composition, Complex reaction products or Biological materials(for example: petro chemical,coal chemical, or natural extract and etc.)

Circumstance: Chemicals such as UVCB* substances manufactured or, imported and handled before 1991but not listed in KECL, or substances produced as intermediates in the process.

Required information under this circumstance:

  • In the case of UVCB substances, a description of the process, including manufacturing / synthesis methods
  • In the case of UVCB substances, information on major constituentsgreater than 10%(including name, contents, Classification and label and as much as possible)
  • In case the registrant possess the analysis data, recommended to submit
  • A declaration that confirms that the chemical substance was manufactured / imported / used before 1991.
  • Confirm whether substances is CMR substances / Classification & Labelling

Submission

Submit to the Korea Environment Corporation(KECO) by e-mail

  • E-mail address: kreach@keco.or.kr
  • Address: (04513)39, Sejong-daero, Jung-gu, Seoul, Republic of Korea

2. Substances whose product cannot be obtained

Chemicals which foreign manufacturer/or producer are not providing chemical information under Confidential Business Information (CBI) and are not planning to appoint OR. In this circumstance, Korean importers can make a declaration to MoE regarding they have required oversea manufacturers to provide necessary information and to complete pre-registration in dvance, yet the overseas manufacturers cannot respond to/handle/submit pre-registration in time.

Submission

In this circumstance, Korean importers must provide related information as much as possible, including:

  • Plan for procuring information (product name, amount, use category etc.)
  • Confirm whether substances is CMR(carcinogenic, mutagenic, or toxic for reproduction) substances / Classification & Labelling

The applicant must submit all the information obtained by him to the competent authority between 1 July and 30 September, and the competent authority will carry out evaluation based on the submitted substance. If the substance is regarded as an existing substance, then it can be pre-registered; but if the substance is a new substance, then the applicant must complete registration for the substance as soon as possible.

If you have any needs or questions, please contact us at service@cirs-reach.com.