Substances of Priority Control and Product Notification under K-REACH
Little Pro on 2019-01-08
K-REACH not only requires the registration of new substances and >=1t/y existing substances, but also requires that producers and importers of products containing a priority control substance report the name, amount, hazard information, data on exposure and purpose of the priority control substance contained in the product to the Minister of Environment before manufacture or importation. In this article, we will help you understand this product reporting requirements.
Definition of Product under K-REACH
'Product' is a unique concept under K-REACH. A product means a mixture or an article used by consumers or a component of the mixture or the article that may expose consumers to chemical substances. A product includes both chemical preparations and solid articles. Typical products include cleaning products, air refreshers and toys.
If your product is only for industrial use, you can skip the rest of this article. If you are selling a consumer chemical product, you not only need to comply with K-REACH, but also need to comply with
Substances of Priority Control
“Priority control substances” mean risk-posing chemical substances which fall under any of the following and which are announced by the Minister of Environment (MOE).
- CMR substances and substances with endocrine disrupting properties (EDC)
- Bio-accumulative and persistent substances (vPvB or PBT)
- Substances which may damage organs such as lungs, kidneys after repeated exposure (STOT)
- Other substances which may give the same level of concern
on 28 Dec 2018, the MoE announced 2 lists of priority control substances.
- List 1: 204 substances: formaldehyde, benzene, etc
- List 2: 468 substances. furan, lead acetate, etc
The first list comes into force on 1 July 2019. The second list comes into force on 1 July 2021. Please contact us should you need this list.
Reporting of Products Containing Substances of Priority Control (Article 32)
A producer or an importer of products containing a priority control substance shall report, the name, amount, hazard information, data on exposure and purpose of the priority control substance contained in the product to the Minister of Environment before manufacture or importation when:
- The amount of priority control substance per product exceeds 0.1% of the total amount; and
- The total annually accrued amount of priority control substance contained in each product exceeds one ton.
When reporting a product, companies need to submit standard reporting form (Form No. 28) along with product labels and instruction manuals.
Products Exempt from Reporting
A product containing a priority control substance may be produced or without reporting if:
- The exposure of priority control substance to people or the environment can be blocked when the product is used according to ordinary use conditions
- The priority control substance has already been registered
- The priority control substance can be manufactured or imported without registration or reporting (i.e, <1t/y existing substances)
Provision of Information for Product Containing Hazardous Substances (Article 35)
Any person who transfers a product containing a priority control substance reported shall provide safety info about the contained priority control substance in the product, to a person who acquires the product. The safety info includes:
- Product name
- Name and content of the contained priority control substance
- Intended use and restricted product use
- Method of proper use and service condition of the product
- Precautions in handling the relevant products
If any consumers request provision of such information, such information shall be provided free of charge within 45 days from the date of such request.
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Tags: Topics - Korea, REACH-like Regulation and Registration