The South-Korean OR certificate
K-REACH, contrary to its European counterpart, chose to submit the role of Only Representative (OR) to a certification from the Korean government. This certificate gives a kind of accreditation to its holder and allows them to access the equivalent of the REACH-IT tool for South Korea. EcoMundo can therefore become your OR and help you ensure compliance in anticipation of the export of your substances in South Korea.
Are you affected?
Substances subject to pre-Registration are those considered as already existing and imported or manufactured at more than 1 tonne per year. More specifically, the list of already existing substances (KECL: Korea Existing Chemicals List) is available here.
If your substance has exceeded at least once the 1 tonne import or manufacture volume between 2016 and 2018, then you are affected by this pre-Registration.
Why should you pre-register?
K-REACH opened its pre-Registration window on 1st January and it will last until 30th June 2019. In concrete terms, pre-Registration allows companies to benefit from a grace period for their substances’ registrations.
If companies choose not to pre-register their substances when they should, they will not be able to legally sell their substances for more than a tonne per year in South Korea from 1st July 2019 onwards. If they do not comply with this regulation, they risk a fine up to 100 000 000 KRW and an imprisonment up to 5 years for the Responsible Person.
If they do comply, companies will have the following deadlines for their definitive registrations:
- 31/12/2021 for substances exceeding 1000 T/year ; and CMR substances exceeding 1 T/year,
- 31/12/2024 for substances between 100 and 1000 T/year,
- 31/12/2027 for substances between 10 and 100 T/year,
- 31/12/2030 for substances entre 1 and 10 T/year.
How can you proceed?
To be able to pre-register your substances in South Korea before 30th June 2019, you must first appoint an OR approved by the Korean government. If you choose EcoMundo, we will ask you to fill out an information sheet on your company and your substances, as well as an OR Agreement provided by the Korean government, so as to facilitate the process.
Try and anticipate the process as much as possible, it is rather time-consuming.
Wish to know more about K-REACH pre-Registration?
For more information on K-REACH, do not hesitate to contact our expert, Renaud Germain-Thomas, by phone at : +33 1 83 64 20 54 for Europe, or +1 (778) 234 1607 for North America or even send him an email at [email protected].
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