Background (Stringent Policy Posture)
The Korea Environment Corporation (KECO) is strictly investigating chemical substances with (post-)pre-registered tonnages exceeding 100 t/a that have not completed full registration, focusing on tracing annual export volumes from 2018 to 2025. According to K-REACH, enterprises that continue to export unregistered substances may face severe penalties, including up to 5 years imprisonment, fines of up to 100 million KRW, additional penalties of 5% of turnover, and even a ban on trade with South Korea.
Applicable Scenarios for Voluntary Self-Reporting
- No export to Korea in 2025：Self-Reporting is NOT required.
- (Post-)pre-registered tonnage must be reduced to 10-100 t/a or even 1-10 t/a.
- Overseas enterprises can terminate their appointment with the Only Representative (OR).
- Enterprises exporting to Korea in 2025:
- 2025 export volume < 100 tons: Need to reduce the (post-)pre-registration to 10-100 tons and submit a voluntary self-report
- 2025 export volume ≥ 100 tons: Need to complete the full registration ASAP and submit a voluntary self-report.
- Documents required for self-reporting: 1) Explanation of the compliance violation; 2) Proof of production/import records; 3) Standardized Self-Reporting form (If CIRS KR acts as the OR, the company mainly needs to provide annual export tonnage data from 2018 to Feb 27, 2025).
- If the substance qualifies for an exemption, the basis for exemption must be provided.
- Self-reporting deadline: October 27, 2025
Corporate Risk Warning
- Consequences of continued non-compliance:
- Goods being detained by Korean Customs; historical fines (retroactive to 2018);
- Enterprises will be blacklisted under K-REACH, affecting trade for all chemical substances with South Korea.
- Benefits of self-reporting:
- Exemption from criminal liability: Avoid up to 5 years imprisonment.
- Reduction/waiver of economic penalties: Exemption from the 100 million KRW fine and the additional penalty of 5% of turnover.
- Reduced enforcement risk: After the grace period, Korea will strictly enforce inspections; companies that fail to Self-Report will face severe penalties.
Recommended Actions
Screen immediately: Identify substances with pre-registered tonnages >100 t/a that lack full registration. Confirm the list of chemicals exported to South Korea and compile annual export tonnage data from 2018-2025.
Handle by case:
- ≥100 tons/year and continuing exports in 2025: Urgently initiate full registration and voluntary self-report
- <100 tons/year OR pausing exports：Reduce pre-registered tonnage and submit voluntary self-report or Terminate OR appointment.
The countdown to 2025 K-REACH enforcement is on! According to industry sources in Korea, KECO will comprehensively strengthen supervision in the fourth quarter of 2025. CIRS Group reminds chemical manufacturers exporting to South Korea to promptly review their export records from 2018-2025 and, if necessary, quickly contact their Only Representative or Korean importer to initiate Voluntary Self-Reporting. This self-reporting is the final remediation for non-compliant enterprises. Missing it will directly lead to trade losses!
