South Korea K-REACH registration you ask me a question

Release time:

2021-04-21 16:15

Recently, the South Korea Chemical Registration and Evaluation K-REACH Amendment Act added penalties for downstream users and sellers, China's export South Korea chemicals compliance will receive more and more attention. The following South Korea K-REACH laws and regulations small knowledge for small partners reference.

For existing chemicals that are re-notified in 2020, the pre-announcement period (June 30, 2019) has passed, do we need to register immediately?

Note: Prior to manufacture or import, registration may be made after reporting in accordance with Article 10 (3) of the Chemical Substances Registration and Evaluation Act (hereinafter referred to as the "Chemical Assessment Act") until the grace period for registration. However, if the grace period for registration based on annual production and imports has been exceeded, registration must be made before manufacturing or importing.

How to certify the exemption of chemical substances according to Ministry of the Environment Circular No. 2018-234?

Note: Manufacturers/importers with information on a substance must conduct a comprehensive review of the function, purpose and use of the substance to confirm whether an exemption is possible.

If the classification label is changed due to the hazard inspection after the registration of an existing chemical substance, is it necessary to make a change registration? In addition, what standards should be used for information transmission and MSDS revision?

Note: Even if the classification and labeling information entered in the registration application data is different from the results of the hazard check, there is no obligation to make changes. After receiving the registration notice, the manufacturing and import information delivery and MSDS will follow the classification and labeling matters specified in the registration application data, but after the notification of the hazard test results, the classification and labeling results based on the hazard test will be reflected. Information transmission and MSDS should be revised.

When doing polymer registration, if the data of the polymer is different from the protocol member, what data should be submitted as joint registration data?

Note: Each registered company must submit its own data. For the characteristics of high-molecular compounds, data on the manufacture or import of substances must be submitted for each registered company. However, test data such as acid-base stability can be submitted by grouping them with substances of similar molecular weight.

If the classification label is changed according to the residual monomer content of the polymer compound, can it be submitted jointly? For example, the classification and label of the polymer substance containing 0.2% formamide and the polymer substance containing 0.05% formamide are different, how to submit the registration document?

Description: Joint submission is possible. If the classification label of the substance to be registered is different due to the difference in the residual monomer content, please check the reason for the omission according to the difference in the classification label, and explain the registration data with a different classification label for each member. However, due to the different classification and labeling of the same substance, different registrations can be submitted, but the same company cannot be registered multiple times with different councils.

When preparing to register 1000 tons or more of polymer compounds, if the residual monomer of carcinogens is 0.1%, can the data submission be ignored?

Note: Because it is a carcinogen, data of 10-100 tons should be submitted instead of 1-10 tons. For polymer substances of 1,000 tons or more, data of 1-10 tons can only be submitted if they belong to Class ① (substances classified as Environmental Hazard Category 3 or 4).

"Classification result" is the criterion for omitting the submission of data. Does it refer to the classification submitted at the time of prior notification?

Explanation: No. In the process of preparing for registration, it refers to the result of classification based on information that the registrant can reasonably know or must know. That is, ① classifications that already have a clear basis outside the South Korea, ② classifications that are based on data generated for registration or data collected through sufficient effort (e. g. public data).

Even if there is evidence of classification different from the classification submitted at the time of pre-registration, does this constitute an omission of the submitted data?

Description: Yes. However, first, it is different from pre-registration, so it is limited to the case of change registration; second, it is necessary to attach supporting data and description of classification differences.

If a new classification is discovered during the collection of registration data, even though the data was not submitted during the pre-registration phase, what should I do?

Note: The new classification must be followed. Therefore, make full use of the public information and materials provided during the initial registration preparation phase. If the new classification is known, the report must be changed.

If the decision not to submit data is based on the classification of the person or environment, is there a problem with the classification or labeling of the person as a physical hazard?

Explanation: No problem. Physical hazards are not related to the results of the classification of human or environmental hazards and the omission of data submission.

If there is a classification in the MSDS provided by the Labor and Occupational Safety Health Bureau, is it certain that the submitted data will be ignored according to the classification?

Note: The MSDS information provided by the Labor and Occupational Safety Health Bureau is for reference only. Therefore, in addition to determining whether to simplify the registration application data based on this content, reliable evidence is also required to ensure the accuracy of the information.

Even if there is evidence that its classification is different from the harmonized classification disclosed by the European Environment Agency (CLP classification), can the submitted data be ignored?

Description: Yes. However, more reliable evidence than CLP classification should be provided.

List of penalties for South Korea MSDS violations

K-REACH Evening Pre-registration and South Korea Environment Ministry Announcement No. 2021-97 Introduction

List of penalties for South Korea MSDS violations

K-REACH Evening Pre-registration and South Korea Environment Ministry Announcement No. 2021-97 Introduction

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