Dear precious client :

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1 Dear precious client : Last year, Chemtopia received 1 st Korea joint registration No. and the certificate of registration result for HBr joint registration. This newsletter analyzes and shares the important aspects to be considered from this outcome. Furthermore, we would like to provide you the key aspects on the legislation of Household Chemical Products and Biocides Safety Management Act, which was pre-announced on 28 th December 2016, and the amendment of Act on the Registration and Evaluation, etc. of Chemical Substances. Its impact on relevant industries and regulatory compliance strategy are to be addressed here as well. Now Chemtopia has been involved in legislation of Household Chemical Products and Biocides Safety Management Act as expert group. <ISSUE AND FOCUS> 1. Implication of the first Korea joint registration (HBr) 2. Key aspects on amendment of following laws and its impact on industries -Ministry of Environment, Act on the Registration and Evaluation, etc. of Chemical Substances -Ministry of Environment, Chemicals Control Act -Ministry of Employment and Labor, Enforcement decree of the Occupational Safety and Health Act 3. Pre-announcement of legislation on Household Chemical Products and Biocides Safety Management Act and its impact on industries

2 1. Implication of the first Korea joint registration (HBr) - For Hydrogen Bromide (CAS No ), which is a PEC substance having its volume band above 1,000 tones and subject to CSR submission, waiving statements had been submitted for test items, physical property (ex. its boiling point) and human toxicity (ex. its acute oral toxicity and eye damage) as corrosive gas property. Especially, the toxicity data was submitted with Read-across of its analogous substances. - The evaluation by NIER during process from dossier submission to issue of registration No. is more likely completeness check to see whether all required test items are submitted. - The certificate of registration result includes registration number, tonnage band, use classification, detailed use description, use advised against, etc. Also, it indicates that additional data can be requested while NIER examines hazardous property. This means NIER can carry out a peer review for a year on waiving for Read-across of analogous substance and exposure characteristics. - IT system generates token number to co-registrants after lead registrant submits his dossier. When a co-registrant enters the toke number in the IT system, the token number proves the relationship between co-registrant and lead registrant, and also makes sure that the information in joint registration dossier are to shared with co-registrants. <Impact on industry and countermeasures> - Registration HBr started from MOE s national project and it had taken approximately 2 years for entire process from forming consortium to getting the certificate of registration. As deadline (~June, 2018) for joint registration comes close, we recommend the relevant industry to hasten to complete registration before its deadline. - Especially, it is necessary to check whether all required documents are included for completeness check by NIER. If a test is impracticable or can be waived, do not empty the column in IT system and must state clearly about reason.

3 2. Key aspects on amendment of following laws and its impact on industries (1) Act on the Registration and Evaluation, etc. of Chemical Substances : Key contents on amendment and its impact on industries. Annual report to be abolished - The abolition of annual report that is annually reporting use and volume of new chemical regardless of its volume and existing chemical exceeding 1ton/year. Registration of existing chemicals to be expanded to all existing chemicals exceeding 1ton/year (total ~7,000 substances are expected) - PEC will no longer exist, instead all existing chemicals exceeding 1ton/year are to be registered. Among them, CMR substance and substances exceeding 1,000ton are firstly targeted to be registered by For this, pre-registration system will be running like EU-REACH, and chemical name, expected registration date, registration volume, etc. are to be included in pre-registration. Notification of risk concerned substance contained in product - Previously known as product notification that is required when hazardous chemicals (toxic/authorized/restricted/prohibited substance) is present in a product exceeding 0.1% and 1ton, is modified to notify risk concerned substances*. *Risk concerned substances are CMR(Carcinogenic, Mutagenic, Reprotoxic), PBT (Persistent, Bioaccumulative, Toxic) and endocrine disrupting chemical, and therefore approximately 2,000 substances will be notified through MOE s public notice. Reinforcement of communication in supply chain - As extending range of informational exchange for registered chemical and the mixture cont aining it, a person who hands over hazardous substance or the mixture containing it, and re gistered chemicals, needs to transfer registration number, chemical name, hazardous/risk in formation and safety handling information, regardless of its contents, to downstream users. Reinforcement of penalty - If an overseas manufacturer or a producer appoints OR to comply with K-REACH, importer will be defined as downstream user, and in case of his violation, the penalty will be imposed to OR. - In case that unregistered chemical substance has been manufactured, imported, and sold, the partial amount of sales (under 10 billion Korean won) will be imposed as fines.

4 Schedule for amendment - Collecting opinion from relevant ministries and pre-announcement of legislation (~Jan or Feb of 2017) - Submission to National Assembly (~Apr of 2017) - Promulgation of law (~Mid of 2017) - Enforcement (~1 year after promulgation ~Mid of 2018) <Impact on industry and countermeasures> - Though annual reporting system is to be abolished, K-REACH amendment will be enforced 1 year after confirmation of the draft and promulgation of law. Therefore, annual reporting in 2017 is still required. For this annual report, this, inventory set-up for chemical and its product and its volume tracking are still necessary. - As expanding of PEC registration to all existing chemicals exceeding 1ton/year, cost increase for registration process is inevitable. Especially, CMR and massive production substance should be prioritized to correspond, and pre-registration should be done during pre-registration period for all registration expected substances to get registration grace period. - The number of risk concerned substance subject to notification is expected to expand over 2,000 and therefore, set-up of chemical inventory and monitoring of detailed chemical component, content and its volume contained in product are essential. - It is important to check whether registration is already completed when a chemical or its mixture are supplied from vender (compliance check). Also, a supplier who sells a chemical or its mixture needs to check whether his product contains hazardous chemicals and should provide MSDS and the additional information about risk and safety handling information to downstream users. (2) Chemical Control Act : Key contents on amendment and its impact on industries Preparation of chemical emission reduction plan report to be mandatory - According to amendment of the act being released on December 30 th of 2016, preparation of chemical emission reduction plan will be mandatory for those who handle Toxic Release Inventory (TRI) chemicals, because there is lack of efforts by business site to reduce use and discharge of toxic chemical such as carcinogen.

5 - Therefore, submission of chemical emission reduction plan report should be required every two years and a company shall be required to submit necessary documents for relevant public officials to understand the status and also required to allow them access to business site to investigate. Schedule for amendment - Two years after promulgation of amendment <Impact on industry and countermeasures> - The results of survey of TRI are now open to public. But the newly amended law makes submission and implementation of chemical emission reduction plan to be mandatory, so business site should strive for reliable survey. - In addition, it is necessary to secure a budget for technical investment in order to reduce emitted chemical volume such as reduction of non-point emission source. (3) Enforcement decree of the Occupational Safety and Health Act : Key contents on amendment and its impact on industries. According to the amendment being released on January 20 th of 2017, current small amount of fine is to be reinforced to imprisonment or a large fine for securing safety and health of workers in workplace. - Violation of prohibition of in-house-contract for harmful work, manufacture / import / transfer /provision / use of prohibited substance and use of permitted substance without permission, etc. are to be imposed of penalty that is not exceeding 10/100 times of amount of obtained profit from such violation. - Exceeding the level of exposure of harmful agents over permitted level, violation of providing Material Safety Data Sheet and, violation of work environment monitoring obligation, failure in duty of health examination for workers, etc. are to be imposed of penalty that is imprisonment for less than one year or a fine not exceeding 1000 million won, instead of paying small amount of penalty. - Violation of preparing a proper Material Safety Data Sheet that should not have any missing part and violation of submission of hazardous and risk prevention plan, and violation of submission of Material Safety Data Sheet are to be imposed of penalty that is imprisonment for less than six month or a fine not exceeding 500 million won, instead of paying small amount of penalty.

6 <Impact on industry and countermeasures> - It is necessary to confirm whether a substance in business site is corresponding to prohibited/permitted substance or meets permitted standard for its compliance with Occupational Safety and Health Act. - MSDS maintenance is required to provide a reliable MSDS and a hazardous and risk prevention plan. 3. Pre-announcement of legislation on Household Chemical Products and Biocides Safety Management Act and its impact on industries The purpose of this legislation is to improve safety management of household chemical products and biocidal product Covering risk concerned product being currently managed under K-REACH - Changing the name of risk concerned product to household chemical product subject to suitability check - Performing risk assessment for currently market circulating household chemical product which is subject to suitability check and notifying safety and labeling standard. - The manufacturer importer of household chemical product subject to suitability check needs to request a testing institute of suitability check on safety and labeling standard every 3 years. Approval system for biocide substance - Those who manufacture/import/sell/distribute a biocide substance should get an approval by submission of safety and efficacy documents. Evaluation of existing biocide substance - Currently circulating biocide substance needs to notify within a certain period to confirm existing biocide substance and also needs to submit required test report within 10 years of grace period to get the approval. Authorization of biocidal product - For biocidal product containing biocide substance, its effect, efficacy, use, exposure, toxicity and indication of label and package information must be submitted for authorization. * The following biocidal product controlled by other regulations are excluded : Pesticide, quasi-medicine, cosmetic, food additives, water treating chemical for drinking

7 water, and treating substance for ballast water. - Name of all biocide substance, concentration, approval number, use, adverse-effect and first aid method need to be indicated in order to get approval. Treated article - Only approved biocide substance can be used for treated article and name and function of all biocide substance should be displayed in label. Labeling for household product and biocidal product - Commercial phrase such as non-toxic, harmless, safe, environmental friendly, etc. cannot be used because those phrase can make consumer misunderstand. <Impact on industry and countermeasures> - The requiring documents for approval of biocide substance and authorization of biocidal product containing biocide substance will be a lot, due to requirement of efficacy and toxicological data, therefore the increase of expense is inevitable. Especially, authorization of biocidal product is required for each product, so it can impact on the increase of expense. - In particular, when producing a biocidal product by mixing biocide substances supplied from other, it must be confirmed whether those substances have been approved before using them. In addition, for biocide treated article such as anti-bacterial textile, it is also necessary to confirm whether this biocidal product has been approved. - Be aware of label of household chemical products and biocidal products Chemtopia is delighted to invited you to take part in a free EU-REACH & Asia-Pacific regulations seminar. This free-seminar will offer you a great source of information on the latest chemical regulatory developments in the Asia-Pacific region, but also will give you a good understanding on how to comply and manage REACH requirements in order to successfully submit your EU-REACH in 2018 as lead registrant and co-registrant. * More information about the event can be found in the attachment.

8 Chemtopia Co., Ltd. provides corresponding services to comply with amended and legislated regulations : Establishment of chemical inventory for manufactured/imported/sold chemicals and its product used in workplace Support of regulatory monitoring, volume tracking, and annual reporting with chemical management system Provision of domestic and foreign chemical regulatory database MSDS and label authoring system Chemical registration service including Pre-registration, OR service, Read-across analysis, CSR preparation, Data sharing and negotiation Test arranging & its monitoring with domestic and foreign test institutes TRI (Toxic Release Inventory) service and preparation of chemical emission reduction plan <This newsletter is available in Korean, English and Japanese> If you have any inquiries, please contact us via : phone : +82-(0) , chemtopia@chemtopia.net 1203~1206 Daerung Post Tower 7th, 48, Digital-ro No. 33, Guro-gu, Seoul, Korea Zip: 08377, TEL : , FAX : COPYRIGHT(C)2017 Chemtopia Co.,Ltd. ALL RIGHTS RESERVED.