ChemCon Asia preview
CW Briefing, / South Korea
With South Korea’s so-called “K-REACH” legislation only recently adopted by the country’s National Assembly, ChemCon Asia 2013, taking place in Seoul this September, will be taking a close look at the latest developments with ministry officials, as well as examining the host of other compliance challenges raised by the fast developing global regulatory scene.
David Nelissen of Accenture, a member of ChemCon’s six-strong programme advisory committee, agrees that at first glance, K-REACH looks very similar to the EU REACH Regulation. “K-REACH has indeed much in common with EU REACH, with its “no data, no market” principle, only representatives and joint registration mechanism. This is good news for the global industry and demonstrates the willingness of the Korean authorities not to reinvent the wheel and to build on the significant efforts made for REACH.”
But there are also, he says, important differences, such as the fact there will be no pre-registration, volume reporting will now be on a yearly base, the threshold for registration will be below one tonne in certain conditions, the grace period for existing chemicals and different rules on reporting exemptions. He also points out that the way the GHS system is being introduced in South Korea is less connected with the K-REACH timeline than it was with the EU Regulation on classification, labelling and packaging (CLP). But K-REACH “remains in the vein of REACH and its implementation should not bring new surprises to the industry”.
Those companies which have already experienced registration under REACH “will definitely find themselves in a familiar situation with K-REACH, as the processes are similar and therefore the experience capitalised will be at profit,” says Mr Nelissen, who will be moving to Accenture’s Singapore office, this summer. “But not all of the companies that import or manufacture chemicals in South Korea were exposed to REACH and these need to catch up quickly.”
Regarding access to data that was included in REACH registration dossiers, and whether there will be any benefits under the Korean regime, “it all depends on the level of access a company acquired at the time it bought its REACH letters of access,” he says. “Indeed, many consortia and Sief agreements state that the data access is only granted for REACH compliance, and only for 12 years – whereas K-REACH has a 15-year timespan. Some companies will, therefore, need to renegotiate their participation in consortia to take account of their K-REACH obligations.”
Accenture has also observed that, even in cases where substance data was acquired at the Sief or REACH consortium level, the data inventories are still at a draft stage and available data is not yet fully or clearly identified. This, says Mr Nelissen, was experienced last year with registration in Turkey and again this year in relation to several regulations in Asia. But the real cost and learning to be leveraged from REACH compliance are not connected to registration, he says, but to the implementation of the Regulation’s demanding requirements for ongoing communication along whole value and supply chains.
Companies already have enough information to start preparing for K-REACH, says Mr Nelissen. “But the details due in the forthcoming enforcement decree and associated guidance, plus outputs from the stakeholders forum and the outcomes of the pilot projects, will be important pieces of additional information – as well as the expected amount of the fees, of course.”
An important question, he says, is what sort of tools will be provided to help companies complete the registrations. “When looking at the REACH and Iuclid IT tools story, we clearly remember the fast pace of software releases for Iuclid 5 and REACH-IT , creating extra stress (only the dossiers created with the most recent Iuclid version were accepted by REACH-IT), an extra burden on the IT departments and significant extra costs for data input details.
If the South Korean Ministry of Environment was able to announce the dedicated tools and format to be used soon, “it would be appreciated”, says Mr Nelissen. And if the tools and formats could be compatible with Iuclid 5, “industry would love it”. This would also be a “logical move “, he says, as Iuclid 5 was developed under the auspices of the OECD, and South Korea has been an OECD member country since 1996. But Iuclid 5 still lacks an interface in Korean, and this needs to be resolved.
In addition to an in-depth seminar on South Korea, the conference will include a seminar looking into the lists of regulated chemicals under various legislation in the EU, Asia and North America. As always, the main programme will have the latest news, including sessions on key countries such as China, Russia and Brazil, REACH authorisation, TSCA reform, biocides, cosmetics and nanomaterials.
Chemical Watch is Media Associate for ChemCon Asia 2013. We provide reports before and after the event and daily reports for delegates during the event in conjunction with the conference organisers and presenters.
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