How to register intermediates under K-REACH

▪ Intermediate means a substance that is manufactured for and consumed in or used for chemical processing in order to be transformed into another substance.

-          Non-isolated intermediate : an intermediate that is not intentionally removed from the equipment in which the synthesis takes place, during synthesis.

-          Isolated intermediate : other intermediate that is not falling in definition of Non-isolated intermediate.

▪ K-REACH compliance subject to Non-isolated intermediate

-          Exempted from the obligation of ‘Annual Reporting’

-          Exempted from the obligation of ‘Registration’, but prior confirmation of the registration exemption shall be required (just once at first time)

▪ K-REACH compliance subject to Isolated intermediate

-          Only “isolated intermediate which blocked from release or exposure by functional method” can be exempted from the obligation of ‘Registration’ but prior confirmation of the registration exemption shall be required (just once at first time)

-          Other isolated intermediates are subject to Registration. But, the submission of hazard data,  risk and exposure assessment, or safe use guidance could be exempted.

▪ According to consultation with the competent Korea Government, the authority is most likely to only consider ‘On-site, Isolated intermediate’ as ‘Isolated intermediate’ which defined under K-REACH. This means that in adverse ‘Transport, Isolated intermediate’ is considered as ‘Substance’. Therefore ‘Isolated intermediate’ imported into Korea should comply with K-REACH obligation as ‘Substance’, not as ‘Isolated intermediate’, even though the same substance is considered as ‘Isolated intermediate’ in the relevant regulations of other countries, like EU-REACH.