In accordance with the latest requirements of the Occupational Safety and Health Act (OSHA) by the Ministry of Employment and Labor (MoEL), enterprises producing or importing classified hazardous chemicals in South Korea must not only ensure that each chemical is accompanied by a Korean-language MSDS (Material Safety Data Sheet) compliant with national standards but must also complete the submission of MSDS in a timely manner, as stipulated in the newly revised Article 110 of the OSHA regulations.
Domestic enterprises in South Korea (manufacturers, importers) can register and log into the MSDS system page on the KOSHA website to complete the online submission of Korean MSDS and obtain the officially assigned MSDS number. Enterprises outside South Korea cannot submit MSDS directly and may choose to appoint an Only Representative (OR) within South Korea to submit on their behalf.
In late November 2025, the Korea Occupational Safety and Health Agency (KOSHA) officially issued a notice stating that during the review of a large number of previously submitted MSDS, several critical issues were identified. The notice requires relevant enterprises to carry out corrections and resubmit as soon as possible. This move marks the entry of South Korea’s MSDS compliance supervision into a substantive review phase.
Key Deadlines and Current Status
Resubmission deadline: January 16, 2026
Current status: KOSHA currently recommends that enterprises proactively correct and resubmit MSDS documents. However, it is anticipated that after the grace period ends, this requirement will become mandatory.
Summary of Major Issues with MSDS Documents and Submissions
- Missing responsible party information: Failure to clearly indicate the responsible entity such as the manufacturer, importer, or supplier.
- Non-compliant language: Submission of MSDS in languages other than Korean, whereas the regulations require a Korean version.
- Incomplete toxicological information: Partial or complete absence of content in Section 11, "Toxicological Information."
- Inconsistent product names: Discrepancies between the product name in the MSDS and the registration information in the Korea Chemicals Management System (KMS).
- Lack of compliance supporting documents: Failure to submit a Letter of Compliance (LoC) for chemical verification.
Potential Risks and Response Strategies
Previously, efforts were primarily focused on completing MSDS submissions during the buffer period, resulting in a lack of systematic review mechanisms. With KOSHA strengthening its review efforts, defective MSDS may lead to subsequent legal and compliance risks, necessitating heightened attention.
Given the large number of MSDS documents requiring revision, a comprehensive one-time rectification is not feasible. Therefore, it is recommended to adopt a priority management approach, focusing on documents with severe deficiencies: for products with serious issues that are no longer sold, consider applying for deregistration; for products still in circulation, implement a step-by-step correction and resubmission strategy to ensure a compliant transition.
CIRS Group reminds chemical enterprises exporting to South Korea to further review previously submitted MSDS for compliance with the latest standards, promptly update problematic MSDS, and resubmit them before the deadline.
