Effects to Industry
- Chemical business shall report the volume of manufacture or import of all new chemical and existing chemicals over 1 ton/year every year. However, the downstream users are exempted from the reporting obligation.
* Chemical business means the people who manufacture, import, use or sell chemicals for commercial purpose.
- As chemical business covers the person who manufacture, import, use or sell chemicals, this reporting requirements will lead big impact to all chemical industry.
To cope with this, chemical inventory work is essential
- All new chemical and priority substance over 1 ton/year are subject to registration. (In case the concern of hazard to human health or environment, less than 1 ton can be subject to registration)
- Registration exemption:
- -Imported chemical equipped in machinery
- -Imported chemicals with machinery or equipment for its trial run
- -The substance contained finished article but not released during its use
- -The substances manufactured or imported less than 10 ton/y solely for export
- In case of any change in amount, use after the registration, the change should be updated.
- As all new chemicals can be subject to registration, new chemical manufactured or imported as small quantity should be monitored and managed.
- As for exemption, application for exemption in prior to its manufacture or import and the approval from the authority is required.
- Even after registration, consistent management for information such as use is required.
- Risk assessment is required for substance over 100 ton/year and extended deadlines will be applied to substance of 10-100 ton/year
70 ton/year: 1 Jan 2017
50 ton/year: 1 Jan 2018
20 ton/year: 1 Jan 2019
10 ton/year: 1 Jan 2020
- As the tonnage band for risk assessment lowered, the industry need to make their internal staff trained for risk assessment or outsource external consultancy.
- In case of chemicals subject to authorization, application for authorization for specific use is required before its sunset date.
- Chemicals with property of CMR or PBT can be the candidate for authorization. In case of substance subject to authorization, the industry should be aware of substitution material etc.
5. Information exchange in supply chain
- The supplier for registered chemical or its mixture shall provide registration number, chemical name, hazard information, safe use information to his customer. Also this information should be shown in MSDS.
- The downstream users and sellers should provide his supplier use, exposure information, amount of use or sell, safe use information etc. only when requested by the supplier
- As information exchange in supply chain is mandatory, the supply chain management such as MSDS update is required.
- Product notification is required in case hazardous chemicals are present in a product over specific tonnage(>1 ton/year). The hazardous chemical name, content and hazard information, use in the product should be notified in advance. But the finished article with no release can be exempt from this notification.
- Product risk assessment is required for product with concern among following products which will be published by the MOE. This risk assessment will be performed by the specialized institution with experts appointed by the Ministry of Environment. After risk assessment, The ministry of Environment will issue the safety standard and labeling criteria.
- -Consumer product such as cleansing agent, air freshener, adhesive, polish, detergent, whitener, softener
- - Biocidal product
- The supply chain management for chemical product manufactured or imported is essential in order to make sure if any hazardous chemical contained.
- Although the final K-REACH addresses the government will perform product risk assessment, we expect the data required can be asked to the industry, if necessary. We need to wait for coming subordinate statutes for detailed information.
- A foreign manufacturer can appoint only representative for following task on behalf of him.
- - Reporting of manufacture etc. registration, notification etc.
*The eligibility of only representative will be addressed in subordinate statutes.
- To solve CBI protection, the appointment of only representative can be solution.
8.The transition time
- K-REACH will take effect on 1 Jan 2015. The transition time is given for risk assessment depending its tonnage band.
- K-REACH will be applied to new chemical registration from 1 Jan 2015. The transition time for priority existing substance will be determined in subordinate statutes.