Updates on Korea and Trade Issues

Chemical Regulations Updates in 2020

K-REACH

K-REACH requires registration for all existing chemicals manufactured and imported to South Korea in quantities exceeding 1 ton per year. Joint registration is mandatory under K-REACH unless the MoE authorizes a business for individual registration. Joint registration refers to forming a consortium consisted of several potential registrants to submit all necessary dossier for chemical substance registration under K-REACH. 

The first registration deadline under K-REACH is by 31 December 2021, which applies to those who manufacture and import existing chemical substances exceeding 1,000 tons per year, or carcinogenic, mutagenic, or reproductive toxins (CMR) more than 1 ton per year.

Over 17,045 substances were pre-registered by the end of January 2021, according to the Ministry of Environment (MoE) in South Korea. After the pre-registration, the next step is to join a Chemical Information Communicative Organization (CICO, corresponding to SIEF in EU-REACH) of a pre-registered substance and prepare registration dossier.

On 2 November, the MoE in South Korea announced the revised K-REACH rules. The reason is to ensure effective implementation of the K-REACH regulation. First, registrants can enjoy an extended deadline for change registration. The deadline is extended up to 1 year, and the authority's confirmation is required. Chemical Classification and Labeling standards between different ministries will be harmonized to enhance consistency. Finally, the government's registration fees will be exempted for SMEs manufacturing and importing 1-10 t/y, if they register their substances before 2022.

K-BPR

K-BPR, also known as the Consumer Chemical Products and Biocide Safety Management Law, regulates safe consumer products and biocidal products. Essential requirements for these regulations consist of chemical risk assessment and authorization. It took into force on 1 January 2019 and its recent amendment in 2020 which has been enforced since 1 January 2021.

The amendment includes that non-Korean manufacturer can appoint an Only Representative to register biocidal active substance. Dossier submission will be exempted once submitted for K-REACH compliance, and the MoE will disclose the chemical ingredients list in the detergents, air fresheners and disinfectants.

Trade status

According to UN Comtrade's analytics[1], India is the 8th largest chemical supplier to South Korea, indicating a continuous increase in export since 2013. To India, South Korea remains 6th largest chemical supplier following China, USA, Germany, Japan and Netherlands. DGCI analytics[2] shows that Organic chemicals are India's 3rd largest commodity exported to South Korea in recent years. 

Table 1. India's Exports of Chemical Products to South Korea[3]

Summary

Given trade statistics in recent years, it can be expected that chemicals will continue to be one of the crucial commodities in the trade between India and South Korea. As South Korea has tightened chemical regulations for safe chemical use, it might become a potential barrier for Indian chemical exporters. The Indian exporters shall appoint the Only Representative with a legal entity in South Korea to prevent non-compliance and meet regulatory requirements. In order to comply with the relevant regulations, it is necessary to proactively inform Indian exporters the recent regulatory updates. Also, collecting industry opinions about challenges and recommendations would be helpful for regulatory improvement.

Last update: 2021-02-12

[1] https://comtrade.un.org/labs/data-explorer

[2] http://www.dgcisanalytics.in/dgcis/EXIM-Analytics

[3] https://www.trademap.org/Index.aspx?AspxAutoDetectCookieSupport=1