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As of 12 May 2026, amendments to K-REACH have entered into force, introducing a formal framework for the transfer of compliance responsibilities when an overseas manufacturer or formulator appoints a new Only Representative (OR). These provisions ensure continuity of K-REACH regulatory obligations and minimize disruption during such transitions.

For overseas manufacturers and formulators relying on an OR to meet their K-REACH obligations in South Korea, this amendment provides greater legal certainty. Existing registrations, pre-registrations, notifications, exemptions, and other regulatory activities can now be maintained when changing an OR, provided that the succession process is properly completed.

This regulatory update is particularly relevant for companies that already hold K-REACH pre-registrations, registrations or other regulatory records in South Korea through an Only Representative (OR) and are planning to switch to a new OR.

OR Change: Key Considerations

For foreign manufacturers/formulators considering a change of OR for K-REACH compliance, two practical questions arise:

1. When should an OR change be considered?
2. What is required to complete the OR succession notification?

The amended K-REACH establishes a legal basis for the newly appointed OR to succeed to the regulatory activities previously carried out by the former OR. However, this succession must be notified to the Korea Environment Corporation (KECO) within the prescribed timeline and supported by appropriate documentation.

A successful transition requires a clear understanding of the former OR’s activities, including the substances covered, annual volumes, downstream users information, and the availability of supporting records.

What Has Changed?

Under amended Article 45-2 of K-REACH, when an overseas manufacturer or formulator changes its appointed OR under Article 38(1), the new OR inherits the regulatory effect of the former OR’s activities.

Key requirements include:

• Consent from the newly appointed OR.
• Submission of a succession notification within one month of appointment.

The detailed procedure is defined in the amended Enforcement Rule. Notifications must be submitted to KECO through the K-REACH IT system, along with documentation demonstrating the succession of activities.

In practice:

• The new OR submits manufacturer details, the reason for succession, and the former OR’s business registration number.
• The former OR inputs the substance-related information covered by succession.

This process requires coordination between the overseas manufacturer, the former OR, and the new OR prior to submission.

When Should an OR Change Be Considered?

OR succession is not only relevant for companies that have already decided to change their OR. It also provides an opportunity to assess whether the current OR arrangement remains suitable for long-term compliance.

K-REACH obligations require ongoing management rather than one-time submissions. Registrations, notifications, and exemptions must be actively maintained over time.

Overseas manufacturers/formulators should consider the following:

• Does the main contact point of your current OR change too frequently?
• Does your current OR proactively contact you about regulatory compliance plans and upcoming deadlines?
• When requesting data or documents, does your current OR clearly explain why the information is needed?
• After a registration, notification or exemption application has been submitted, does your current OR provide a clear explanation if the process takes longer than expected?
• Is there transparency when processes take longer than expected?

If several of these points raise concerns, it may be appropriate to reassess the current OR arrangement for K-REACH compliance.

Required Documentation for OR Succession

The Enforcement Rule requires documentation that demonstrates the succession of regulatory activities. These documents should reflect the actual compliance history of the substances involved.

Key elements include:

1. Appointment of the New OR
   Documentation must confirm that the overseas manufacturer/formulator has formally appointed the new OR for the relevant K-REACH scope.
2. Scope of Succession
   The documentation should clearly define which activities and substances are included. Substance identifiers such as CAS numbers, chemical names, and product names must align with existing records.
3. Previous Regulatory Records
   Relevant registration, notification, exemption numbers, and OR appointment records should be verified and consistent with the succession notification.
4. Lead Registrant Role (if applicable)
   If the succession involves the Lead Registrant role in a joint registration, additional documentation may be required. This can include confirmation that a majority of CICO (Chemical Substance Information Communicative Organization) members agree to the new OR assuming this role. This confirmation must be submitted to KECO alongside the succession documentation.

Final Remarks

The introduction of OR succession provisions is a significant step forward for K-REACH compliance. It enables foreign manufacturers and formulators to change their OR while preserving existing regulatory outcomes.

However, the success of the process depends on the quality and completeness of the supporting documentation. Authorities will assess not only the appointment of the new OR but also whether the transfer of K-REACH regulatory responsibilities is properly substantiated.

Need support with K-REACH related matters?

REACHLaw Korea offers comprehensive OR services for K-REACH compliance. We support overseas manufacturers and formulators throughout the K-REACH OR succession process, including review of existing registrations/notifications, preparation of documentation, submission through the K-REACH IT system, and communication with the authorities.

For support with K-REACH OR succession or other chemical regulatory matters in South Korea, please contact us at sales@reachlaw.fi