With K-REACH coming in effect from January 1, 2015, we have organized some checklists to help non-Community suppliers to be prepared for the new regime.
1. Make early-registration of new chemical substance using Korea’s existing law – the TCCA.
It is a good opportunity for foreign entities to make registrations for new chemical substances early under the existing law – toxic chemical control act (TCCA) while they still can. The new chemical substances registered under the TCCA will be accepted under the K-REACH.
2. Identify and join consortiums of priority existing chemicals.
Any person who intends to manufacture ∙ import any designated ∙ published existing chemical substances as prescribed by the Ministerial Decree (Ministry of Environment) at 1 ton or more per year will need to register the substance under K-REACH. Although the list of designated existing chemicals is still under revision, when the list is published, it will be vital for companies to check if their substances are included in the list and make preparations accordingly.
3. Start looking for a local representative to submit registrations under K-REACH.
It is required for foreign companies to appoint a local representative established in Korea who fulfils the requirement specified by the Ministerial Decree, and may have him perform the following tasks to fulfil the registration obligations of the importers. Tasks include: reporting of import volume and use, registration application, notification, other tasks specified by the Presidential Decree.
4. Prepare cost sharing plans within the supply chain.
Korean manufacturers and importers, local representatives appointed by a manufacturer, producer established outside Korea have the obligation to register a substance. Since one registration is required per substance in a supply chain, these actors can decide who will submit the registration dossier and prepare cost sharing plans
5. Secure supply chains and make early identifications of registration status within the chains.
Since only one registration number is required for a substance within a supply chain, companies should check beforehand if the substance has been registered somewhere along the chain.
6. Research alternative substances for authorized∙restricted∙prohibited chemical substances.
The Minister of Environment can revoke the designation of authorization listed substance that may no longer be used as an alternative substance or new technology is developed to substitute the authorization listed substance following deliberation of the Evaluation Committee.
For more information on regulations in Korea, please feel free to post your question or send an e-mail to ehcho@namandnam.com.
Thank you.
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