The Blog

Companies manufacturing and importing chemicals in Korea must comply with K-REACH, cooperate with statistical surveys under the Chemical substance Control Act (CCA), and obtain notifications or permits as necessary. Statistical surveys must be conducted for all chemicals, and certain chemicals belonging to hazardous chemical groups require permits for manufacturing, importing, and selling.

Recent revisions to the CCA impose differentiated compliance obligations based on handling volume and hazard level. Furthermore, the compliance obligation has been improved to allow overseas manufacturers to appoint agents to protect their trade secrets and to comply with regulations on behalf of importers.

The Korean government recently reorganized its organization, changing its name from the Ministry of Environment (MoE) to the Ministry of Climate, Energy, and Environment (MCEE), expanding its responsibilities and scope. This shift suggests that while necessary regulations will be rationally improved, additional regulations may be created.

K-CCA brief overview

MCEE enacted the CCA to prevent damage to public health and the environment caused by chemical substances, properly manage chemicals, and respond quickly in the event of chemical-related accidents to protect the lives, property, and environment of the public. The Enactment of the Toxic Chemical Control Act, enacted in 1990 and implemented from 1991, was comprehensively revised in June 2013 as the CCA, which has been in effect since 2015. Through annual revisions, the regulations were adjusted to better suit their purposes, and major revisions were made in 2024, having taken effect this year.

Key obligations:

• Statistical survey and information disclosure of chemical substances
• Safety management of hazardous chemicals
• Hazardous chemical substance business operator
• Chemical Accident Preparedness and Response

Statistical survey results and corporate risk management plans for chemical accidents are disclosed in the IT system.

• Basic workplace information: name, address, phone number
• Hazardous chemical information: name, hazard information, accident risk
• Information on accident response: impacted area, status of containment equipment, alert delivery method, action guidelines
• Emergency contact information and phone number

Key amendments effective 2025

By distinguishing between business permits/business reports/permits and reporting requirements based on hazardous chemical risk and handling volume, unnecessary administrative procedures have been eliminated for handling small quantities. This means that handling hazardous chemicals below a certain quantity does not require reporting or permits. Furthermore, a new volume range for handling after reporting has been established, reducing the burden on companies.

Companies manufacturing and using hazardous chemicals were previously required to undergo regular inspections every one to two years, depending on their operating license status. Furthermore, safety inspections were required every three, eight, or twelve years, depending on the risk level in their chemical accident prevention and management plan. Even if these inspections occurred in the same year, companies had to undergo separate inspections, which was a significant burden. The revised regulations allow for regular inspections up to four years, depending on the hazardous chemical risk level and handling volume. Safety inspections have been significantly improved, requiring inspections to be completed at the fourth inspection interval. Provisions have also been made to extend the regular inspection cycle by applying incentives to workplaces with excellent safety management, thereby providing incentives to workplaces that voluntarily and faithfully comply. Manufacturing and importing of banned or restricted substances that are fully exported are now permitted.

Non-Korean manufacturers can appoint a CCA Representative

While previously only domestic importers were permitted to apply for business approval, the revision allows overseas manufacturers to appoint a representative in Korea to obtain approval, protecting their trade secrets. Therefore, businesses exporting chemicals to Korea can now do business without having to disclose all the ingredients to Korean importers.

However, if an agent is appointed, the fact of appointment, the work assigned and the results of the performance, the permit number related to the import and use of the permitted substance, and other information must be provided to the domestic importer to share matters related to regulatory compliance.

Appointing a domestic agent to handle permits and reporting processes facilitates market entry by allowing the Korean agent to process business approvals independently of negotiations with importers. Even if the importer changes, the agent’s business registration certificate and registration number will help ensure a stable supply of products to the Korean market. However, as this is tied to safety-related laws, such as the Act on the Punishment of Serious Accidents, it is important to clearly define the scope and limits of the agent’s responsibilities.

Should you need support with K-REACH or K-CCA related matters, our REACHLaw Korea team is happy to assist you. You can contact us at sales@reachlaw.fi or KREACH@reachlaw.fi