Overview
As the amended K-REACH (Act on the Registration and Evaluation of Chemicals) continues to take effect, companies face new compliance questions regarding substance notification, registration, and post-submission management. Since the revised notification system for new substances took effect on January 1, 2025, many manufacturers and importers have been seeking clarity on the validity of past notifications, hazard classification requirements, and document update obligations.
Drawing on the latest Korean official policy releases and hands-on compliance experience, this article summarizes the key FAQs to Korea REACH registration and provides practical insights to help businesses maintain compliance and avoid trade disruptions.
1. Are previously notified new substances (<0.1 t/y) still valid after the 2025 reform?
Yes. Notifications already approved before January 1, 2025, remain valid. Each substance generally has fewer than two notifying companies, and the revised K-REACH framework does not alter requirements based on annual tonnage. Therefore, no additional action is required to continue manufacturing or importing under 1 ton per year for those substances.
2. Can companies use public hazard classification data such as ECHA CLP for K-REACH notification?
Yes. K-REACH accepts hazard information from a wide range of credible sources — including domestic and international evaluation reports, test data, publicly available classifications, and QSAR predictions — as valid supporting materials for registration.
3. Will substances registered or notified before the revision be labeled as “Unconfirmed Hazardous Substances”?
Not immediately. Although the authorities are discussing whether to designate such substances and publish their classification details, there will likely be a grace period before implementation. Applicants will be informed in advance and given time to review or update their submissions before any public disclosure.
4. Should MSDS specify if a substance is “Unconfirmed Hazardous”?
Yes. When submitting the Korean MSDS to the competent authority, the status of the substance — including whether it is classified as an Unconfirmed Hazardous Substance — must be clearly stated.
5. Updates to the Letter of Confirmation (LOC) under the Chemical Control Act (CCA)
The newest version of the LOC form under the CCA will take effect on August 7, 2025. The old formats are acceptable until December 31, 2025
6. Does the “Unconfirmed Hazardous Substance” designation apply only to newly notified substances?
Yes. From Aug 7, 2025, this classification applies only to new substances subject to notification.
7. How does the authority determine whether a substance is “Unconfirmed Hazardous”?
Applicants must submit all the available hazard classification data that they owned or searched. If any of the following parts are matching(related hazardous data are not submitted), the system automatically links to a page related to unconfirmed hazardous substances, and the applicants confirm this on their own.
Chemicals with unconfirmed acute oral toxicity. ( If the substance is a gas at room temperature or if the main exposure route is determined to be inhalation due to its use, it refers to a substance with unconfirmed acute inhalation toxicity.)
Chemicals with unconfirmed results from the bacterial reverse mutation test or the chromosome aberration test using cultured mammalian cells.
Chemicals with unconfirmed acute toxicity to fish / acute toxicity to daphnia/freshwater algae growth inhibition test results.
Chemicals with unconfirmed biodegradability.
If no relevant data exist, the notification can still proceed with a “no data” submission. Authorities issue a preliminary certificate once basic information is complete, then conduct their own hazard review using internal and international databases. The final hazard classification results are later published on the official K-REACH website.
If an applicant submits no hazard data, the substance will be self-classified as “Unconfirmed Hazardous.” Subsequent updates may be required if the authority later identifies relevant hazard data from other sources.
8. Can classification information based solely on a supplier’s SDS be accepted?
Only if the classification in the supplier’s SDS can be traced to reliable sources such as recognized databases, studies, or regulatory listings. Simple SDS statements without traceable data generally lack sufficient credibility for K-REACH purposes.
9. When will NICS publish updated hazard classifications?
The National Institute of Chemical Safety (NICS) continues to review and classify substances under K-REACH. Among the more than 2,200 registered substances, approximately one-quarter have completed hazard assessment. Due to high workload and limited staff capacity, progress has been gradual. However, a significant portion of updated classifications were released on August 7, 2025, on the registration website.
10. Can foreign manufacturers register under K-REACH?
Yes. Overseas manufacturers or producers may appoint a Korean Only Representative (OR) to complete K-REACH registration. Since the actual producer has the most comprehensive understanding of substance identity and manufacturing details, the authority can better assess compliance when the application originates from or is supported by the manufacturer’s OR.
Key Takeaways for Companies
The continuous refinement of K-REACH raises the bar for chemical management capabilities. Companies must proactively:
Maintain the validity of previously notified substances;
Ensure the completeness and reliability of hazard classification data;
Update LOC and MSDS documentation in line with the latest formats;
Monitor NICS publications for new hazard classifications.
REACH24H Consulting Group recommends that companies closely follow official announcements and work with professional compliance partners to prepare data, track procedural updates, and anticipate potential regulatory risks. This proactive approach ensures efficient K-REACH registration and smooth market access in Korea.
For more information and inquiries on K-REACH, please feel free to contact us at customer@reach24h.com.
