South Korea has officially launched a standardized Only Representative (OR) change procedure under the Act on Registration and Evaluation of Chemicals (K-REACH), significantly improving regulatory flexibility for foreign chemical manufacturers.
The new procedure follows revisions to the Enforcement Rule of K-REACH announced on October 15, 2025, with detailed operational guidance released by the National Institute of Chemical Safety (NICS) on December 17, 2025.
Regulatory Background: K-REACH and OR Obligations
K-REACH, which entered into force on January 1, 2015, regulates the registration and evaluation of chemical substances manufactured or imported into South Korea.
Under K-REACH:
- New substances, and
- Existing substances manufactured or imported at ≥1 tonne per year must be registered prior to market entry.
Foreign manufacturers without a legal presence in South Korea are required to appoint a local Only Representative (OR) to fulfil K-REACH registration and compliance obligations on their behalf.
Features of the New OR Change Procedure
The newly launched procedure allows registrants to change their Only Representative without cancelling existing registrations, addressing a long-standing compliance challenge.
Required Documentation
To initiate an OR change, the following documents must be submitted via the online system:
- Power of Attorney (POA) issued by the foreign manufacturer, clearly identifying the substances subject to transfer
- Business registration and corporate documents of the existing OR, including SME certification where applicable
Joint Registration Considerations
- If the existing OR acts as the Lead Registrant (LR) in a joint registration consortium (CICO), additional documentation is required to confirm:
- Transfer of lead registrant status, or
- Consent from the majority of consortium members
- If the existing OR is a non-lead registrant, no additional proof related to previously purchased Letters of Access (LOA) is required
Processing Timeline and Substance Eligibility
Once all required materials are submitted, authorities typically complete the OR change within 14 working days.
The OR change procedure applies to substances that have already completed:
- Pre-registration
- Full registration
- Registration exemption confirmation
Importantly, existing registration numbers remain unchanged after the OR transfer, including:
- Pre-registration numbers
- Full registration numbers
- Registration exemption confirmation numbers
Compliance Impact for Companies
The introduction of the OR change procedure represents a major efficiency gain for foreign manufacturers and registrants. Previously, changing an OR required cancelling registrations and re-registering substances, resulting in additional cost, administrative burden, and potential supply disruptions.
With the new process, companies can:
- Maintain regulatory continuity
- Reduce compliance costs
- Avoid duplication of registration efforts
- Improve long-term compliance planning under K-REACH
Important Dates briefly
- K-REACH effective date: January 1, 2015
- Enforcement Rule revision announced: October 15, 2025
- OR change procedure guidance issued: December 17, 2025
South Korea’s formal launch of the K-REACH OR change procedure marks a significant modernization of the country’s chemical regulatory framework. The change enhances regulatory transparency and provides much-needed flexibility for global chemical companies operating in the Korean market.
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