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:
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.