To ensure the compliant circulation of chemical substances in the Korean market, overseas manufacturers/producers must accurately convey the (pre-)registration numbers to importers after completion under K-REACH. Recently, many companies have been uncertain about which (pre-)registration number to convey following updates in information such as changes in importers, tonnage, or usage. CIRS provides the following analysis and explanation:
Basic Rule: Any Valid Number is Acceptable
Regardless of the type of update (including changes in importer, tonnage, or usage), conveying any (pre-)registration number obtained after an update and currently valid to the importer is in principle acceptable.
Official Recommendation: Use the Initial Number
The core purpose of providing the (pre-)registration number to importers is to inform them that the substance has completed the relevant registration process. The authorities can query and verify any valid number through their system. Therefore, the official recommendation is to prioritize sharing the initial (pre-)registration number with importers or downstream users.
As the only representative, CIRS records the (pre-)registration numbers obtained after dossier updates in our RCUM system, and the completion notices also reflect the list of (pre-)registration number updates. However, to simplify the process, avoid confusion, and ensure consistency of information, CIRS recommends that the initial (pre-)registration number should still be conveyed to the importer after each update.
