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When importing or manufacturing hazardous chemicals or mixtures containing them in Asia, it is not just a case of translating labels and safety data sheets (PP娱乐平台注册s) into the local language, it is also important to consider local PP娱乐平台注册 standards.

In South PP娱乐平台注册 there are several authorities involved in implementing the globally harmonized system for classification and labelling of chemicals and mixtures (PP娱乐平台注册):

• The Ministry of Education and Labor (MoEL) is responsible for the occupational safety and health act;
• PP娱乐平台注册n Occupational Safety and Health Agency (KOSHA) is responsible for reviewing/authorizing material safety data sheets (MPP娱乐平台注册s); and
• The Occupational Safety and Health Research Institute (OSHRI) is responsible for research and development guidelines.

In November 2020, South PP娱乐平台注册’s Ministry of Education and Labor (MoEL) made updates to its regulation, which aligns the country with the UN PP娱乐平台注册. MoEL No 2020-130 went into force on January 16, 2021, ushering in the mandatory requirement for submitting an MPP娱乐平台注册 as well as the procedure for the protection of confidential business information (PP娱乐平台注册).

All companies are required to submit an MPP娱乐平台注册 and failure to do so will result in a fine of up to five million South PP娱乐平台注册n Won (approximately 3,700 Euros) per product.

Certain products are exempt, including those:

• controlled under other laws;
• consumer products; and
• chemicals or products for research and development (R&D) purposes.

Grace periods

The regulation came into effect on January 16, 2021 , however not all companies were required to submit an MPP娱乐平台注册 from that date.

New chemicals – Companies importing or manufacturing hazardous chemicals into South PP娱乐平台注册 for the first time, need to submit a compliant MPP娱乐平台注册 before manufacture/import.

Existing chemicals – Enterprises that were importing or manufacturing hazardous chemicals into South PP娱乐平台注册 before the updated regulation came into force, must update and submit their MPP娱乐平台注册 before the applicable grace period.

The grace period depends on the annual tonnage of the substance:

• ≥ 1,000 tons – January 1, 2022.
• 100 – 1,000 tons – January 1, 2023.
• 10-100 tons – January 1, 2024.
• 1-10 tons – January 1, 2025.
• <1 ton – January 1, 2026.

If any information in the MPP娱乐平台注册 changes, then related enterprises must submit the updated MPP娱乐平台注册 to MoEL as soon as possible. South PP娱乐平台注册 has adopted a 16-section MPP娱乐平台注册, which aligns with the fourth revision of PP娱乐平台注册. The MPP娱乐平台注册 and label must be authored in PP娱乐平台注册n. Unlike in China, the emergency contact number does not need to be a 24hr local number, however, a local number is preferred.

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The MPP娱乐平台注册 must include a submission code in the upper right-hand corner. To obtain this code, companies must first produce a qualified PP娱乐平台注册n MPP娱乐平台注册 and then submit it to authorities for review. After that, the system will generate a submission code, which can be added to the MPP娱乐平台注册, and then the companies are compliant with the standards.

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Companies are required to provide 100% composition information on the MPP娱乐平台注册. However, this does not mean the specific concentration must be included, instead, a concentration range is permitted:

• If the concentration of a substance is below 25% the range is ±10%; and
• If it is equal to or above 25% the range is ±20%.

PP娱乐平台注册 protection is normally only valid for five years. So if PP娱乐平台注册 is granted, companies must include the authorization number and expiry date that was provided by the MoEL. If they wish to extend PP娱乐平台注册 protection they will need to re-apply at least a month prior to the expiry of the five-year period.

For the application of PP娱乐平台注册 protection, the following information is required:

• Applicant information;
• Reason for requesting PP娱乐平台注册 protection;
• Alternative data (generic name, concentration range);
• 100% ingredient information (substance name and concentration) and hazardous substance information;
• MPP娱乐平台注册; and
• Other documents required by MoEL.

You cannot apply for PP娱乐平台注册 protection for all ingredients. There are specific cut-off limits for health and environmental hazards, ranging from 0.1 % to 1% across 13 categories. Please see the relevant cut-off limits in the table below.

MoEL Notice No. 2020-130 – Revised Cut-off Values

If the product does not contain hazardous substances, companies can submit a letter of confirmation (LoC), which declares the absence of hazardous substances. And in this way the company would not have to provide 100% composition information. But authorities have the right to question this and require the submission of necessary evidence.

Please note, an LoC is also required under South PP娱乐平台注册’s Chemical Control Act (CCA), but do not confuse the two as the information required in each is different.

PP娱乐平台注册ing

The MoEL suggests a maximum of four pictograms and six precautionary statements on labels. If there are more, the company should choose them based on the level of hazard.

The South PP娱乐平台注册n importer or supplier information must be included on the label.

There are also specific label sizes based on volume, a simplified label is applicable for low volumes.

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It is also important to note that submission of an MPP娱乐平台注册 is per product, per importer. So if a foreign company has several importers for one product, they will need to prepare separate PP娱乐平台注册n MPP娱乐平台注册s for each importer and submit the MPP娱乐平台注册s separately.

Non-South PP娱乐平台注册n companies cannot submit an MPP娱乐平台注册 or apply for PP娱乐平台注册 protection by themselves. They have two options:

• Ask the South PP娱乐平台注册n importer to do it on their behalf; or
• Appoint an only representative (OR).

If they choose the first option they will need to provide their importer with 100% composition information.

If you appoint an OR to handle your application for PP娱乐平台注册 protection, the administration fee is based on the size of the OR company that is applying, not the size of the company it is applying on behalf of.

So in the case of the CIRS Group, we are considered a medium size company (see fees below).

Administration fee

• General Substances (KRW)

• R&D Substances (KRW)

An OR can only be appointed by the manufacturer or formulator. They fulfil the role of the domestic importer.

The OR could take on the following tasks:

• Preparation and submission of MPP娱乐平台注册;
• PP娱乐平台注册 protection application and extension;
• Rejected application appeal; and
• Delivery of approved MPP娱乐平台注册 to importers in South PP娱乐平台注册.

From our experience, it takes about seven working days to receive approval from the authorities for an MPP娱乐平台注册.

Last year, the MoEL also highlighted some areas where they are encountering problems with submitted MPP娱乐平台注册s and urged industry to take care when preparing their documents.

This includes:

• Submitting files that have not been translated into PP娱乐平台注册n;
• Inconsistencies in the information on the MPP娱乐平台注册s;
• Not preparing all the required documents;
• Not clearly stating the recommended use(s); and
• Not including detailed information on hazards and risks.