Non-Korean Enterprises Must Accept Two Manual Checks for K-REACH Pre-registration

The K-REACH pre-registration will be manually checked twice and the manual check usually takes about 15-20 working days.

Compared with EU REACH, K-REACH pre-registration takes longer time. In terms of K-REACH Pre-registration, non-Korean enterprises must accept two manual checks: OR Check and Authority Check.

1. OR Check

K-REACH Regulation requires only representative (OR) to submit OR confirmation to Korean authority online. After the confirmation is checked and approved by the authority, the OR is able to carry out pre-registration. In addition, OR needs to submit OR confirmation for each entrusted substance.

OR Check mainly focuses on:

• Information of enterprise that entrusting an OR (Oversea enterprise);
• Substance information;
• Importer information; and
• Power of Attorney (POA).

Note:

Information of the oversea enterprise includes: enterprise name, legal representative, address, telephone No., etc.

Importers are also required to provide detailed information, which includes: enterprise name, legal representative, business license No., address, etc.

Substance information includes: substance name, CAS No., etc.

OR check normally lasts for about 10 working days. Once the OR review is approved by the Korean authority, OR can formally submit pre-registration.

2. Authority Check

After the pre-registration is submitted by related enterprises, Korean authority will manually check the materials for pre-registration.

The authority check mainly focuses on:

• Information of enterprise that entrusting an OR (Oversea enterprise);
• Substance information;
• Tonnage;
• Substance classification;
• Usage; and
• Importer information.

Compared with OR Check, Authority Check requires more information, including substance classification, tonnage and the usage. In addition, related enterprise must give a detailed description of the substance usage. If the description is too simple, application for pre-registration may be returned.

The Authority Review usually takes 10 working days as well.

CIRS estimates that the number of pre-registration will reach a peak in May, which may result in the prolonging of pre-registration period. To complete K-REACH pre-registration in time, related enterprises must submit pre-registration in advance. If an enterprise intends to entrust an OR for K-REACH pre-registration in June, the enterprise may miss the pre-registration deadline. As the Korean authority has not introduced late pre-registration so far, if the enterprise misses the pre-registration deadline, it cannot enjoy the grace period. Instead, the enterprise must complete registration before exporting to Korea, which largely increases the cost in a short term. CIRS warmly reminds that related enterprises must make decisions as soon as possible so as to smoothly address K-REACH regulatory compliance requirements.

CIRS mainly devotes itself to providing global chemical regulation consultancy services, including K-REACH compliance. So far, CIRS has assisted various enterprises in completing K-REACH Pre-registration.

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