It’s time to take stock after 3 years of K-REACH
Nick Choi, team leader at consultancy Chemtopia, shared valuable insights on K-REACH registration at last year's Enforcement Summit Europe 2018.
Nick’s presentation was informed by his management of several joint registrations and negotiations with EU data holders.
Ahead of the Summit, he shared his thoughts on the event and a couple of pressing K-REACH issues.
Q) Do you think the international concerns that have been raised will lead to changes to the enforcement rules for the amended K-REACH?
Despite being in draft I don’t believe the K-REACH enforcement decree and enforcement rule will be significantly amended.
Q) The K-REACH enforcement rules say registration is required for non-hazardous polymers if unreacted monomers subject to registration persist at 0.1% or more of weight. What is your thinking on how to deal with this?
This may not be easy to deal with, although the obvious starting point for manufacturers and importers is to carefully review their monomers for hazardous or un-registered substances.
And, it should be noted that a condition for this rule to apply is that the polymer has a molecular weight under 10,000 – otherwise the old 2 per cent content rule still applies.
Q) What lessons were learned from the first K-REACH registration of the PECs?
I think the biggest lesson was that three years was not enough. And the staggered deadlines for different tonnage bands shows that this lesson has been taken on board.
Q) Why are you looking forward to speaking at (and attending) Enforcement Summit Europe?
I believe the event will provide a good opportunity to explain the enforcement of K-REACH as three years have passed since its implementation.
During this time, the Korean authority gave leniency programs to non-compliant companies, and it is currently setting up a system to manage and track the compliance with the Regulation.
It will be a good opportunity for me to share this information and I look forward to speaking at the event.
Q) What can delegates attending expect from your presentation, and from the rest of the event?
It is not really clear how the authority is going to track and verify the compliance with the Regulation. I will be able to offer insights into the intentions of the authority and how feasible it will be for the authority to systematically enforce the Regulation. It will be interesting to see how different countries manage and enforce regulations in their regions during the rest of the summit.