Background: Stringent K-REACH Enforcement

The Korea Environment Corporation (KECO) is intensifying investigations into chemical substances with (post-)pre-registered volumes exceeding 100 t/a that have not completed full registration. Authorities are tracing export volumes from 2018 to 2025.

Under K-REACH, companies exporting unregistered substances risk severe penalties, including:

· Up to 5 years imprisonment

· Fines of up to 100 million KRW

· Additional penalty of 5% of turnover

· Potential trade bans with South Korea

Voluntary Self-Reporting: Applicable Scenarios

If no exports to Korea in 2025:

· Self-reporting is not required

· Adjust (post-)pre-registered tonnage to 10–100 t/a or 1–10 t/a

· Overseas enterprises may terminate their Only Representative (OR) appointment

If exporting to Korea in 2025:

· Export volume <100 tons: Reduce registration to 10–100 tons and submit voluntary self-report

· Export volume ≥100 tons: Complete full registration immediately and submit voluntary self-report

Required documents:

1. Explanation of the compliance violation

2. Production/import records

3. Standardized Self-Reporting Form (if CIRS KR is the OR, the company must provide export tonnage data from 2018–Feb 27, 2025)

4. Exemption basis (if applicable)

Deadline: October 27, 2025

Corporate Risk Warning

Consequences of Non-Compliance:

· Goods detained by Korean Customs

· Retroactive fines (from 2018 onward)

· Blacklisting under K-REACH, affecting all chemical trade with South Korea

Benefits of Self-Reporting:

· Exemption from criminal liability (avoid imprisonment)

· Reduction or waiver of economic penalties (fines and turnover-based penalties)

· Lower enforcement risk after the grace period

Recommended Actions

1. Screen Immediately

a. Identify substances >100 t/a without full registration

b. Verify chemicals exported to South Korea

c. Compile annual export tonnage data (2018–2025)

2. Handle by Case:

a. ≥100 tons/year (continuing exports): Begin full registration + self-report urgently

b. <100 tons/year or halting exports: Reduce tonnage & self-report, or terminate OR appointment

Final Reminder

The countdown to strict K-REACH enforcement has begun.KECO is expected to intensify inspections in Q4 2025. Chemical manufacturers exporting to South Korea should immediately review export records (2018–2025) and coordinate with their Only Representative or importer to complete voluntary self-reporting.

This is the last opportunity for non-compliant enterprises to remediate. Missing the deadline will result in direct trade losses.

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