By Little Pro on 2015-12-31 Views: Update:2017-01-18
K-REACH not only regulates chemical substances but also regulates chemical consumer products. Product containing hazardous chemical substances may require notification while product of risk concern needs to comply with additional safety and labelling standards. The picture below is an overview of product management under K-REACH.
In April 2015, the Ministry of Environment (MoE) in South Korea issued its Notice No. 2015-41 setting safety and labelling standards for 8 types of products designated as products of risk concern: cleaning agents, synthetic detergents, bleaching agents, fabric softeners, coatings, adhesives (including glues), fragrances, and deodorants. Manufacturers and importers of those household chemicals are required to comply with the new standards from 1 Oct 2015.
In this article, we will help you understand how those safety and labelling standards work and how to comply with them. We will also talk about other K-REACH requirements for chemical consumer products in Korea.
Under K-REACH, a product is defined a mixture or an article used by an end user or a component of the mixture or the article that may expose consumers to chemical substances. It mainly refers to chemical products for consumer use. A big majority of articles (for example, electronics) do not contain substances intended to be released, do not directly cause consumer exposure and thus cannot be regarded as "product" under K-REACH.
Product of risk concern means any of chemical products announced by the Minister of Environment (MoE) as products that are likely to cause risk to human health or the environment. When products of risk concern are announced, their safety and labelling standards will also be published. The first list of announced products of risk concern includes 8 types of products: cleaning agents, synthetic detergents, bleaching agents, fabric softeners, coatings, adhesives, fragrances, and deodorants.
The safety and labelling standards for each product type usually consist of 4 parts:
The table below is an example of how the MOE Notice No. 2015-41 sets the safety and labeling standards for cleaning agents for consumer use.
Chemicals used for cleaning oven, stove hood, bathroom, plates, carpets, building floor, shoes, furniture, automotive, air conditioners, musical instrument, mildew remover, stain remover, etc.
General labelling requirements:
Additional labelling requirements: If a product contains the following substances, it shall be labelled "toxic" along with the name, feature and content of the substances regardless of the content.
Child protection package are required for a liquid product containing any one or more of the following substances or powder product containing more than 2% or more sodium hydroxide/potassium hydroxide.
The MOE Notice No. 2015-41 requires suppliers of chemical consumer products to conduct product testing in qualified labs very three years to verify compliance and keep testing reports for inspections. In addition to that, the Notice has given detailed labelling instructions for each type of chemical consumer product.
Manufacturers and importers of chemical consumer products need to act quickly to determine their compliance status by testing their products against the new safety criteria. Labels must also be reviewed and updated if necessary.
It shall be noted that compliance with the new safety and labelling standards does not mean K-REACH compliance. Chemical consumer products may be subject to more K-REACH requirements such as annual report, registration, product notification and supply chain communication.
According to the article 8 of K-REACH, any person who manufactures, imports or sells a new chemical substance or at least one ton per year of an existing chemical substance shall report the uses, quantity, etc. of the chemical substance annually to the MoE.
Most of chemical consumer products are preparations. The quantity and use of one ingredient will need to be reported if it is a new substance or if its volume exceeds 1t/y. It shall be noted that 40 substances (for example, water, carbon dioxide) are exempt from annual reporting.
Any person who intends to manufacture or import a new chemical substance or at least one ton per year of a designated existing chemical substance subject to registration shall register the chemical substance before he/she manufactures or imports. The first batch of 518 existing substances subject to registration (draft version) has already been published.
Suppliers of chemical consumer products shall check their ingredients to determine if any registration is required for any ingredient.
A product requires notification only if it meets the following two criteria:
"Hazardous chemical substance" means any of the published toxic substances, substances subject to permission, restricted substances, and prohibited substances that can be searched on NIER's website. It currently includes thousands of substances.
Any person who transfers a product containing a hazardous chemical substance reported shall prepare and provide information such as the name, uses and conditions of the chemical substance in the product, to a person who acquires the product.
The person who transfers the product is also obligated to provide information on the safe uses of the product upon consumers' request.
K-REACH compliance for chemical consumer products is not easy. For the 8 types of products of risk concern, compliance with K-REACH safety and labelling standards requires some testing and label review. In the meantime, suppliers of chemical consumer products shall check if other K-REACH obligations including annual report, registration, and product notification apply.