On February 27, 2025, South Korea’s Ministry of Environment (MoE) and Ministry of Justice (MoJ) jointly announced the launch of a K-REACH Compliance Grace Period from February 28 to October 27, 2025, during which non-compliant companies may voluntarily declare past violations. Enterprises that proactively admit failures to register, amend registrations, or submit pre-registrations before February 27, 2025, and rectify these gaps, will be exempt from criminal penalties (imprisonment of up to 5 years), fines (up to KRW 100 million), and additional penalties (5% of annual turnover).
Who Must Declare? Key Scenarios
Case 1: Importing Without Pre-registration/Registration (Before February 27, 2025)
Background: A foreign manufacturer exported chemicals to Korea without any K-REACH pre-registration or registration by either the manufacturer or the Korean importer.
Requirements: Submit a voluntary declaration during the grace period (Feb 28 – Oct 27, 2025), detailing the violation and providing export/import records and standardized forms. Simultaneously initiate registration/pre-registration.
Declaring Entity: Korean importer or foreign manufacturer’s designated Only Representative (OR) in Korea.
Case 2: Exceeding Registered Tonnage (Before February 27, 2025)
Background: A foreign manufacturer or Korean importer completed registration/pre-registration but exported/imported volumes exceeding their approved tonnage limit.
Requirements: Submit voluntary declaration within the grace period (February 28, 2025 – October 27, 2025), provide proof of excess volume, and update pre-registration/registration promptly.
Declaring Entity: Foreign manufacturer’s OR in Korea or Korean importer.
Official Note: Submitting complete compliance documents is mandatory for rectification. The entity handling registration/pre-registration updates must file the declaration.
Critical Reminder: This voluntary declaration only covers violations occurring before February 27, 2025. If rectified, submit proof (e.g., registration number). If registration is ongoing, declare the estimated completion date (within one year after the grace period).
Benefits of Voluntary Declaration
Exemption from criminal liability (up to 5 years imprisonment)
Waiver of fines (up to KRW 100 million + 5% of annual turnover)
Reduced enforcement risk: Post-grace period, non-declared violators face strict penalties.
The MoE will conduct onsite inspections with local authorities after October 27, 2025, targeting non-compliant enterprises. Violators discovered post-deadline will face full penalties without leniency. The CIRS Group reminds all enterprises exporting to South Korea to carefully check their accounts and confirm whether there were any non-compliant exports before February 27, 2025. If so, timely confirmation with the South Korean importer about the self-declaration entity is necessary. After submitting a self-declaration, the declarant needs to promptly undertake related (pre-) registration work.
