Registration of new chemical substance ; K-REACH vs KOSHA

▪ For the new chemical substance, which is defined as not-listed substance onto Korea Inventory of Existing Chemical Substance, it should comply with registration under both K-REACH and KOSHA, since K-REACH has come into enforcement as of January 1 2015.

▪ With the tonnage band of ‘over 1t/y’ before beginning of 2020, the dossier for K-REACH registration can be also submitted to MoEL for KOSHA registration without further hazard data development.

▪ However, be noted that there is conflict in the required hazard data for registration between K-REACH and KOSHA, only regarding registration with tonnage band of ‘0.1 to 1t/y’

▪ please refer to the comparison in the table for the details

Before 2020	K-REACH (MoE)		KOSHA (MoEL)
Tonnage	< 0.1t/y	01t/y~1t/y	< 0.1t/y	0.1t/y <
Required Data	Basic Information Only “No Hazard Data”		Exempted from registration		Basic Information + “Hazard Data1” Required

▪ Unlike K-REACH, because KOSHA does not have the legal definition of ‘Representative’(similar concept to Only Representative in EU REACH), the registration under KOSHA should be conducted by the name of Korea importer. Nevertheless KOSHA registration could be completed via the authorized 3^rd Party by the overseas manufacturer, without risk to disclose the worthy information of the substance(CBI) to Korea importers.