South Korea’s REACH (K-REACH), officially known as the Act on Registration and Evaluation of Chemicals, came into effect on January 1, 2015. This act adopts registration, evaluation, authorization, and restriction requirements similar to the EU REACH regulation, governing new chemical substances, existing chemical substances, and downstream products. According to K-REACH requirements, new chemical substances and existing chemical substances with an annual volume exceeding 1 ton per year (t/a) must be registered before they can enter the South Korean market. Overseas companies can complete registration by appointing a local Only Representative (OR) within South Korea.
Pursuant to partial revisions of the Enforcement Rule of the Act on Registration and Evaluation of Chemicals (K-REACH) announced on October 15, 2025, the National Institute of Chemical Safety (NICS) released a notice on December 17 regarding the procedure for changing the registration entity, specifically the OR change process, within its system.
According to the current OR change operational procedure, the existing OR is required to submit the following information through the system:
- A Power of Attorney (POA) from the foreign manufacturer appointing the new OR, including the list of substances to be transferred.
- The existing OR’s corporate registration information, business license documents, and SME certification materials, etc.
- If the existing OR is the Lead Registrant (LR) for a joint registration (CICO), a confirmation document is required, proving that the new OR has joined the consortium and the Lead Registrant role has been transferred to the new OR, or that the new OR has been appointed as the Lead Registrant with the agreement of the majority of CICO members.
- If the existing OR is an ordinary registrant (non-LR) in a joint registration (CICO), no document is required to prove that the Letter of Access (LOA) was previously purchased by the original OR.
Current Processing Timeline for OR Change:
After submission through the system, the process is typically completed by the authority within 14 business days.
Substances Eligible for OR Change:
Substances that have completed pre-registration, full registration, or received a registration exemption confirmation can undergo a change of registration entity through the OR transfer procedure. After the transfer, the previously obtained pre-registration number, full registration number, or registration exemption confirmation number will remain unchanged.
The successful implementation of the OR change procedure under K-REACH is a significant update of great interest to many registrants. Previously, transferring an OR under K-REACH could only be done by canceling the existing (pre-) registration under the original OR and having a new OR conduct a new (pre-) registration, which undoubtedly added unnecessary time and economic costs for enterprises. The updated OR transfer process now facilitates easier compliance with K-REACH regulations for companies.
