What are the risks if you do not pre-register your substances under K-REACH?

Published 
May 29, 2019

More time to register

The pre-registration deadline for existing substances under the K-REACH regulation, in South Korea, is set to 30th June 2019, in a month. The pre-registration period started on 1st January. Pre-registering substances allows companies to enjoy a grace period before having to complete a full and definitive registration. The grace period is as follow:

  • 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

Risks related to non-compliance with pre-registration

A company which does not register the existing substances it produces, imports or exports in South Korea for more than 1 tonne per year will not be legally able to continue its activities without directly registering these substances. Companies choosing to still keep their activities going will face two risks:

  • A fine up to 100 000 000 KRW
  • A prison sentence up to 5 years

About K-REACH

K-REACH is a regulation aiming at supervising the registration, evaluation, etc. of chemical substances in South Korea. Implemented in 2015 and amended in 2018, the regulation is based on the European counterpart, REACH, with some changes such as the requirement to register polymers.

To carry out pre-registrations, foreign companies are required to appoint a Korean OR (Only Representative). With an office based in Seoul, EcoMundo can take on this role and carry out your pre-registrations. Korean companies may also appoint an OR if they want to avoid a heavy administrative burden.

The OR confirmation by the Korean government for a pre-registration can take up to 2 weeks. Consequently, you should anticipate as much as possible the process so as not to get caught unprepared.

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