According to the requirement of “The Act on Registration and Evaluation of Chemicals of Korea”, i.e. “K-REACH”, all existing chemical substances manufactured or imported at ≥ 1 t/a in Korea shall submit pre-registration before Jun 30^th, 2019 to obtain the grace period for standard registration. And because many companies are rushing to submit pre-registration right before the deadline, there are quite a few error information submitted in the pre-registration system. That’s the reason why Korea MoE made this decision to re-open the system for another two weeks. However, the company which missed the pre-registration deadline can take this opportunity to submit its chemical information. The registration procedure is just like the original one.

Existing Chemical Inventory in China, as known as Inventory of Existing Chemical Substance in China (IECSC), was published by China authority to identify the new chemicals and existing chemicals. China has enforced new chemical pre-market approval system since the year 2003, requiring all new chemicals which are not listed in IECSC to complete registration before entering into China market. Since the market approval by China MEE can only be issued after full registration dossier been reviewed, the new chemical notification/registration is quite time-consuming.

The existing chemical scope is defined as ‘chemical substances legally produced or imported within the territory of PRC before Oct 15, 2003 ‘’ when IECSC was published. The current version is IECSC 2013, including 45,671 chemicals in total, which is a relatively small number comparing to China’s chemical industry scale. Although it’s stipulated in the new chemical regulations that the authority shall organize a national chemical substance survey every five years, and add the chemical substances found have been legally produced or imported within the territory of China before Oct 15, 2003 into the Inventory, there was no such chemical supplement initiated in last two surveys separately in 2014 and 2016.

And it has been eight years since China MEE last time accepted existing chemical supplementary application from industry, which is in the year 2011. The procedure of this round of supplement is also a bit different from the previous ones. This time the manufacturers, importers, chemical downstream users and relevant associations can be the applicants and submit proofs (both paper document and scanned copies) to the SCC-MEE (Solid Waste and Chemicals Management Center) directly before Sep 30th, 2019. The local environmental management bureau will not be involved in the application and review procedure this time.

However, it’s still the chemical substances that been produced or imported within the territory of China before Oct 15, 2003 applicable of this inventory supplement. The proof materials includes invoices, import and export customs declarations, industry statistics, chemical yearbooks, documents issued by the administrative department, publications, etc. Because 16 years is really a long time ago, and many chemical companies have been split and merged in recent years, it’s not easy to find the company internal trading proofs. The industry supporting and publication materials shall be considered as additional evidence.

The final version of the regulation specify 106 priority existing chemical substances (PECs) subject to Taiwan’s standard registration of existing chemical substances should complete the registration within 2 or 3 years and introduced annual report system, requires all chemicals submit the previous one year’s chemical manufacture/import tonnage for local authority strengthen the control of chemicals and risk management.

The main revision of the regulation as follows:

1. Revised regulation requires hazard assessment & exposure assessment report for new and existing chemical substances manufactured or imported at or over 10t/y. This is now in aligns with MoL’s regulation of new chemical substance registration under OHSA.
2. In order to reduce the administrative cost and reduce the burden of the registrant. Authority change the shall be approved by official documents Issue a login or completion code. (amendment articles 11 and 18)
3. For the first time manufacture or importation of an existing chemical substance with an annual quantity of more than 100 kg, the phase I registration is required by authority within 6 months after manufacturing or importation. If the phase I registration number is not obtained after 6 months, no further manufacturing or importation is allowed. If the annual quantity of manufactured or imported existing chemicals is less than 100 kg,  companies may apply for registration on their own initiative
4. Company can apply confidential business information for the existing chemical substance registration, and the new regulation adjust the number of years of information protection for the small quantity registration for PLC

The Regulation also introduced an “Annual report” system, that all registrants should submit annual manufacture/importation activity report including tonnage information to authority between April 1 and September 30. And EPA plans to strengthen post-market inspections.

Reference service link: https://www.accestra.com/services/chemical-regulatory-advisory/

• All New substances which are not listed in the KECI(Korea Existing Chemical Inventory) must be registered prior the manufacture or import activity.
• All existing chemical substances >=1t/y must be registered within given grace periods.

To benefit from the grace periods for existing substances, manufacturers and importers are obliged to pre-register with Korea authority for all existing chemical substances >=1t/ybefore 30 Jun 2019. For chemicals that are not pre-registered before 30 Jun 2019 cannot enjoy the grace period benefit, thus will not be allowed to export to Korea from 1 July 2019.

The “K-REACH” was enforced back to Jan.1, year 2015. Since then the South Korea’s Ministry of Environment have made several times amendments and the final version is significantly changed from the previous version which officially took effect on 1 Jan 2019. Manufactures and importers shall pay attention to the new requirements of compliance, as well as the following registration deadlines: