K-REACH: how to register in 12 easy steps

In 2015, South Korea introduced legislation designed to protect human health and the environment from the impact of chemicals. With an estimated 44,000 chemicals in use in South Korea and about 300 new chemicals marketed annually, registrants and regulators will be kept busy assessing the risk posed to humans, animals and the environment by these chemicals. Effective Jan 1, 2019, this legislation has been revised to impose stricter controls on a broader range of substances.

12 Essential Steps On Preparing Your Substance Registration Under K-REACH

Chemical regulations are often complex and difficult to understand. Demonstrating regulatory compiance is getting more challenging. Use these 12 insightful steps for preparing your substance registration under the changing regulations of K‑REACH.

K-REACH Legislative Development and Goals

K-REACH is the Korean version of the EU regulation for the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH). K-REACH and REACH share the main goal of cataloging chemical hazard information in order to support improved risk management in their use.

Step 1: Start the registration process as early as possible.

Step 2: Check the latest regulatory requirements relevant to your substance. Identify which legislations are relevant and review your obligations under each legislation.

The two pieces of legislation introduced were the Act on the Registration and Evaluation of Chemicals (K-REACH), which mandates the registration of all new and existing chemicals marketed or imported into South Korea at ≥1 tonne per year, requiring detailed information on their likely hazard to human health and the environment; and the Chemicals Control Act (CCA), which focuses on chemical reporting and chemical accident prevention.

K-REACH and the CCA replaced the existing Toxic Chemical Control Act (TCCA) to provide enhanced protection against chemical hazards. The drive for enhanced legislation was triggered in response to an outbreak of toxic lung injuries related to inhalation of a disinfectant used to clean humidifiers.

Scope of K-REACH

As with REACH, K-REACH is confined to certain substances. Unlike REACH, where annual tonnage is calculated as a three-year rolling average and regular monitoring and updates are required, K-REACH annual tonnage is based on the maximum manufactured or imported volume in any given year from 2016 to 2018.

Step 3: Check if your substance is in scope and if it is on the Korean Existing Chemicals List (KECL); if not, your substance will be considered new.

K-REACH is a Multistage Process

Like REACH, K-REACH is a multistage process with different deadline and information requirements depending on the amount of the substance imported or manufactured. Under K‑REACH, foreign manufacturers without registered offices in South Korea need to appoint a South Korea-based only representative (OR) to submit pre-notification and registrations.

Step 4: Establish the pre-notification and registration requirements for your substance.

Step 5: Find and contract an OR if you need one.

Step 6: Calculate the maximum tonnage carefully to identify the information needs for that tonnage band.

Designated or Priority Existing Chemicals

K-REACH has similar information requirements to REACH, although the use of read-across and quantitative structure–activity relationship (QSAR) models for waiving some animal studies is not as widely accepted under K‑REACH.

Step 7: Identify all uses for your substance, as this will drive the exposure scenarios and risk assessment. You may need to consult downstream users.

Step 8: Conduct a data gap analysis to identify information you need to source, or the testing plans you need to carry out.

Planning Your Registration

Like REACH, K-REACH requires a single dossier to be submitted for each substance. This means that, as in Europe, companies producing chemicals containing the same substance must work together in a structure called a Chemical Substance Information Communicative Organization (CICO), which is similar to the EU Substance Information Exchange Forums (SIEFs). The CICO provides a framework, which enables the effective sharing of data and costs.

Step 9: Characterize your substance in detail.

Step 10: Find other registrants through the K-REACH IT system and consider how best to engage with them in the CICO. You may need to consider how important your substance is to you commercially and whether registrants will prioritize the substance in the same way.

Step 11: Decide who will act as lead registrant.

Step 12: Contract data access carefully, checking data quality (if possible) and being aware of usage limitations.

Summary

K-REACH is closely aligned with REACH regulation. The two have similar processes and evaluations. Although K-REACH relies more heavily on animal data. The pre-notification period for existing substances imported or manufactured at ≥1 tonne/year runs between January 1, and June 30, 2019. After this, submissions deadlines vary by tonnage band. Joint submissions are the norm, with registrants working together in CICOs.

It is likely that a number of substances requiring K-REACH registration will have already been registered in the EU through REACH. REACH dossiers can therefore be a data source, although a substantial amount of rework may be required to align any K-REACH submission with Korean regulations.

K-REACH Milestones in the Legislation

• Pre-notification for existing substances manufactured or imported at ≥1 tonne/year was required by June 30, 2019
   
• There are three tonnage bands for existing substances, which have different deadlines for registration
   
• Data requirements for registration increase with increasing tonnage
   
• The registration deadline of 510 priority existing chemicals was July 1, 2018
   
• Joint submission is mandated in most cases, with registrants working together as part of a CICO with a lead registrant
   
• Manufacturers or importers based outside Korea must appoint an OR to submit and manage substance registration

Getting your product through K-REACH requires long-term planning, regulatory insight and a constant focus on reaching your end goal.

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