Obligations for Polymers under K-REACH

Do you export your polymer products to Korea?

Polymer compliance under K-REACH also took shape as the regulation is amended on January 1st, 2019. Depending on its molecular weight, and constituent, there are different ways to comply it. If you export your polymer 100 – 1 000 t/a, the 2024 Deadline, 31st December 2024, is getting closer.

What is a polymer under K-REACH?

Under paragraph 3 of article 2 of the K-REACH Enforcement decree, a polymer is defined as a substance meeting the following criteria:

• It shall be composed of molecules in which at least one type of monomer unit is continuously repeated.
• It shall show the characteristic distribution of molecular weights by repetitive numbers of monomer units in each molecule.
• Its molecules with at least three monomer units form a covalent bond with at least one monomer unit or other reactants shall be at least 50 %.
• Its molecules of the same molecular weight shall not exceed 50 % of the weight ratio.

Not all polymers need to be registered

If a polymer meets the criteria below, it is exempted from registration/notification:

• A polymer whose number average molecular weight is at least 10,000, in which the content of molecules whose weight is less than 1,000 is less than 5 %, and the content of molecules whose weight is less than 500 is less than 2 %;
• A polymer whose number average molecular weight is at least 1,000 but less than 10,000, in which the content of molecules whose weight is less than 1,000 is less than 25 % and the content of molecules whose weight is less than 500 is less than 10 %.

To be exempt, you should submit a confirmation of exemption from registration for your polymer with the above information to prove it.

Polymers requiring registration

The polymer should be registered if it does not meet the aforementioned criteria: the polymer is a cationic polymer or a polymer whose number average molecular weight is less than 10,000, in which an unreacted monomer, which is any of the following chemical substances, constitutes more than 0.1 % by weight:

a)       A hazardous chemical substance;

b)      A substance subject to intensive control;

c)       A non-phase-in substance (excluding any non-phase-in substance that is to be manufactured or imported in quantities of 1 ton or more per year and has undergone a hazard review under Article 18 of the Act)

Information proving you are registering a polymer

Unlike for non-polymeric substances, several tests are excluded from submission requirements. To prove that the substance you intend to register is a polymer, you should provide the following documents:

• Monomer information: substance name, CAS No., constituent
• Number average molecular weight report (GPC)
• Unreacted monomer content report
• Confirmation for Cationic polymer (Polymer structure)

REACHLaw in South Korea

REACHLaw is happy to support you with the complexities of the K-REACH (late) pre-registration and registration requirements as your Only Representative or as your service provider through our office in Seoul.

For more information and support, contact us at sales@reachlaw.fi  

Act now to secure your compliance and unlock your business opportunities in South Korea.

Remember, there are only 6 months left until the 2024 K-REACH registration deadline!