The Korean Ministry of Environment (MoE) deemed necessary to complete the existing instructions for pre-registration with new instructions. They affect cases that were not covered by the regulation. This update was also prompted by the emergence of cases where companies did not have access to all the required data.
Specifically, UVCB susbtances - because they are, by definition, complex – are problematic. For this category of substances, the MoE added that, when possible, the dossiers should include:
- basic information on the substance (name, classification, etc.)
- proof that these substances were manufactured or imported before 1991
- a technical document detailing the manufacturing process
The other question which prompted the MoE to update its guidelines, was that of companies whose suppliers did not provide enough information. Some companies indeed consider some of the data as CBI (Confidential Business Information). Moreover, some foreign companies did not always appoint an Only Representative.
In both cases, the MoE confirmed that pre-registration is still required. If companies requested the information to their suppliers and they did not answer, they should still submit their dossier before 30th June with the available information. The proof that the company did try to get all the data should be included to the submission.
Reminder on the deadlines
The Korean REACH Regulation was amended to include a pre-registration period. This process only affects existing substances, is mandatory and allows companies to benefit from a grace period before having to fully register their substances. The pre-registration period in South Korea started in January and ends on 30th June 2019, with no additional delay.
Definitive registrations must be submitted before the following deadlines:
- 31st December 2021 for 1000+ t/year and CMR substances ≥1 t/y
- 31st December 2024 for 100-1000 t/y
- 31st December 2027 for 10-100 t/y
- 31st December 2030 for 1-10 t/y
Companies should therefore be reactive and start their pre-registration as soon as possible, when necessary, to stay compliant in South Korea. If you need details on K-REACH requirements, do not hesitate to contact us or download our free white paper.
Wish to know more about K-REACH?
For more information, do not hesitate to contact our expert Renaud Germain-Thomas by phone: +33 1 83 64 20 54 for Europe or +1 (778) 234 1607 for North America or even by mail at [email protected].
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