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Key Amendments to K-REACH Enforcement Decree! Joint Submission Disputes Now Mediable, OR Changes Hassle-Free

from CIRS by

On May 6, 2026, the South Korean government, following deliberation by the State Council, issued Presidential Decree No. 36304, officially promulgating a partial amendment to the Enforcement Decree of the Act on Registration and Evaluation of Chemical Substances (the K-REACH Enforcement Decree). This amendment aims to further refine the chemical substance registration and evaluation system in alignment with the Act on Registration and Evaluation of Chemical Substances (Act No. 21132), which was promulgated on November 11, 2025, and will take effect on May 12, 2026.

The new act introduces a mediation system to resolve disputes arising from the joint submission of data required for chemical substance registration applications. It also explicitly stipulates that when an overseas manufacturer changes its Only Representative (OR), the regulatory obligations between the former and new OR can be legally inherited.

This Enforcement Decree primarily specifies the detailed matters needed to implement the act. The main contents include:

  • Expansion of OR and Information System Scopes (effective from May 12, 2026)

Among the tasks that an OR appointed by an overseas manufacturer can perform and those that can be handled through the chemical substance information processing system, the following have been newly added: mediation services for disputes over joint submission of registration application data; and application services for extension of the deadline to submit registration application data.

  • Designation of Entrusted Agency Responsibilities (effective from May 12, 2026)

Fact-finding investigations into joint submission disputes and the receipt of notifications concerning the inheritance of regulatory obligations for ORs appointed by overseas manufacturers have been entrusted to the Korea Environment Corporation (K-ECO).

  • Expansion of SME Support Scope (effective from the date of promulgation)

Among the administrative, technical, and financial support that the Ministry of Climate and Environment can provide to small and medium enterprises (SMEs), a new item, “activities to reduce the use of highly hazardous chemical substances,” has been added to address deficiencies in the current system’s operation.

  • New Entrustment Provisions: Korea Environmental Preservation Agency and Others Authorized (effective from the date of promulgation)

The Ministry of Climate and Environment has entrusted the operation and deliberation support of the Information Provision Deliberation Committee to the Korea Environmental Preservation Agency, established under the Framework Act on Environmental Policy.

In addition, the Minister of Climate and Environment may entrust support tasks related to specific matters under the relevant act and enforcement decree to the Korea Environment Corporation, the Korea Environmental Preservation Agency, or the Korea Chemical Substances Management Association.

CIRS Reminder

This amendment has significant implications for enterprises that have completed or are in the process of conducting chemical substance registration in South Korea. Relevant companies should pay attention to the following:

  • New dispute mediation mechanism: If you encounter disputes with other companies in joint registration regarding the joint submission of data, the new regulation introduces a mediation system to seek a legal resolution. It is advisable to understand the mediation process and the receiving agency in advance.
  • Inheritance of regulatory obligations when changing an agent: When an overseas manufacturer changes its OR, the regulatory obligations of the new OR will legally inherit the relevant work of the former OR. However, a notification must still be submitted as required. Ensure a smooth transition.
  • Support resources – consult the newly designated agencies: For matters involving joint submission dispute investigations and notification of obligation inheritance, contact the Korea Environment Corporation. For matters involving the operation of the Information Provision Deliberation Committee and specific technical support, contact the Korea Environmental Preservation Agency.

CIRS Group will continue to track the latest developments in the K-REACH regulation and provide compliance support to enterprises.

About the CIRS Group

Established in China in 2007, the CIRS Group is a global product safety and regulatory consultancy with a strong presence across the UK, EU, Asia, and the United States.

CIRS provides end-to-end regulatory compliance solutions for the chemical industry, including UK/EU REACH, GB/EU CLP, global GHS compliance, SDS authoring, and chemical risk management. Our multidisciplinary services also include laboratory testing, regulatory strategy, product stewardship, R&D support, and global market access consulting.

With extensive expertise in both Europe and Asia-Pacific regulatory systems, CIRS helps businesses reduce compliance risk, improve operational efficiency, and accelerate access to international markets across chemical, biocides, cosmetics, food, and consumer goods.

 

Our Services

  • K-REACH Only Representative
  • K-REACH Pre-registration
  • K-REACH Registration
  • K-REACH Registration Exemption Application
  • Risk Assessment Report
  • Regulatory Consulting and Training Services
  • New Substance Inquiry for Korea
  • Test Monitoring and Review & Translation of Study Reports
  • Korean SDS and Label Preparation
  • K-REACH Regulation Tracking
  • KOSHA New Substance Registration
  • Commissioning of Tests to Designated or GLP Laboratories in Korea

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further information

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