On February 11, 2026, the Ministry of Environment (MOE) released a draft amendment to the Enforcement Rules of the Act on the Registration and Evaluation of Chemicals (K‑REACH).
The proposed revision aligns with the amended K-REACH Act scheduled to enter into force on May 12, 2026, and focuses on improving procedural clarity in several key compliance areas, including joint registration dispute handling, data submission flexibility, and Only Representative (OR) changes.
Companies manufacturing or importing chemicals into South Korea should closely monitor these developments, as the changes may directly affect compliance strategies and consortium management.
Joint Registration: Formal Dispute Resolution Mechanism
One of the most notable changes is the introduction of a formal mediation process for disputes arising during joint registration.
Under the draft amendment, companies participating in joint registration may request mediation from the Ministry of Environment if disagreements occur, particularly regarding data sharing arrangements or cost allocation.
If a mediation proposal is issued and no response is provided within 30 days, the proposal will be deemed accepted. This mechanism is expected to reduce prolonged disputes and bring greater structure to joint registration negotiations.
- Data Submission: Introduction of a Deferral System
The amendment also introduces a deferral option for data submission.
If a registrant cannot obtain access to required test data, such as during ongoing Letter of Access (LoA) negotiations, the company may request a temporary deferral of data submission.
Applications will be reviewed by the National Institute of Chemical Safety (NICS) within 30 days, and deferrals may be granted for up to one year, with the possibility of extension.
This provision provides companies with greater flexibility when addressing data gaps during the registration process.
- Only Representative (OR) Changes: Simplified Transfer Process
The amendment introduces a formal procedure for transferring Only Representative responsibilities.
When an OR is replaced, the existing rights and obligations associated with the registration may be transferred to the new OR through a notification process.
As a result, re-registration will no longer be required, significantly simplifying administrative procedures for foreign manufacturers relying on OR services in South Korea.
- Structural Improvements to Joint Registration
The amendment also revises and streamlines several provisions related to joint submission and consortium structures.
These changes aim to improve clarity, transparency, and consistency in the overall regulatory framework and help facilitate smoother coordination among lead registrants and consortium members.
- What This Means for Companies
The proposed changes may significantly influence how companies manage K-REACH compliance.
Key implications include:
- Greater transparency expectations in cost sharing within joint registration consortia
- Increased responsibility for Lead Registrants to justify data access and cost allocation
- Simplified transitions between Only Representatives, potentially increasing competition among OR service providers
- More flexibility in managing data access delays, particularly during LoA negotiations
Companies involved in joint registration or consortium participation should review these developments carefully and consider how the changes may affect registration strategy, cost management, and data-sharing negotiations.
The amendment is expected to take effect on May 12, 2026, in line with the revised K-REACH Act.
Further regulatory guidance may follow as the draft progresses through the legislative process.
