- Existing chemical substances imported at 10 tonnes a year or more must be registered under K-REACH by 31 December 2027, and at 1 tonne or more by 31 December 2030.
- Since 1 January 2025 new substances need full registration only from 1 tonne a year; below that, a notification.
- The Chemicals Control Act replaced ‘toxic substances’ with three hazard classes on 7 August 2025; labels, MSDS and import declarations must follow by mid-2026, with further stages to 2030.
- Biocidal products without approved active substances may not be sold since 1 July 2026; approvals for product groups 3 and 4 are due by the end of 2027 and 2029.
- Importers of packaged goods above KRW 300 million or 1 tonne a year carry packaging EPR; since 1 January 2026 every category of electrical and electronic equipment is in EPR.
- Foreign manufacturers can keep control of their Korean filings through an Only Representative or their own Korean importer.
Why environmental rules land on foreign companies
Korean environmental law places most product obligations on the person who manufactures or imports in Korea. For a foreign manufacturer that sells through a distributor, that is the distributor: it registers the chemicals, reports the packaging, pays the recycling contributions — and holds the filings, the data and, in practice, the market access. When the relationship ends, the foreign company finds its products registered in someone else’s name. When the distributor gets it wrong, customs holds the shipment and the foreign brand takes the reputational hit. The alternatives are to appoint a Korean Only Representative (유일한 대리인, yuilhan daeriin) for chemical and biocide filings, or to import through the foreign company’s own Korean subsidiary.
The regulator has also changed. The Ministry of Environment has been reorganised as the Ministry of Climate, Energy and Environment (기후에너지환경부, gihu eneoji hwangyeongbu), with the National Institute of Environmental Research, the Korea Environment Corporation (K-eco) and the Korea Environmental Industry and Technology Institute handling registrations, EPR and product safety. Enforcement has tightened: in 2025 K-eco ran a campaign against unregistered high-tonnage substances, looking back at imports since 2018, with a voluntary self-reporting window that closed on 27 October 2025. See importing into Korea for the trade side and KC certification for product safety.
K-REACH: registering chemicals
The Act on the Registration and Evaluation of Chemicals — K-REACH — requires manufacturers and importers of chemical substances to register them, with data on hazards and uses, before placing them on the Korean market. It applies to substances on their own and in mixtures, and its unit is the substance, per manufacturer or importer, per year. For existing substances (기존화학물질, gijon hwahangmuljil) — those on the Korean inventory — the 2018 amendment gave phased deadlines by tonnage, provided the substance was pre-registered in the window that closed on 30 June 2019:
| Annual volume per importer | Registration deadline | Status |
|---|---|---|
| 1,000 t or more, and CMR substances 1 t or more | 31 December 2021 | Passed |
| 100 t or more | 31 December 2024 | Passed |
| 10 t or more | 31 December 2027 | Upcoming |
| 1 t or more | 31 December 2030 | Upcoming |
Since 1 July 2019 a substance at 1 tonne or more cannot be manufactured or imported without pre-registration or registration.
New substances — not on the inventory — need registration before import. Since 1 January 2025 the threshold for full registration has been 1 tonne a year rather than 100 kilograms; below 1 tonne a notification (신고, singo) is enough, and a substance notified without core hazard data is listed as a substance with unidentified hazards. Registrants of the same substance share data through consortia, and registration costs depend heavily on whether a consortium exists and how much of its dossier must be bought.
K-REACH also requires an annual report (연간 보고, yeongan bogo) of volumes: by 30 June each year, manufacturers and importers report the previous year’s quantities of new substances and of existing substances at 1 tonne or more, through the K-REACH IT system. Penalties for manufacturing or importing without registration reach five years’ imprisonment or a KRW 100 million fine, and the 2025 enforcement campaign added the threat of customs holds and surcharges. A foreign supplier whose importer missed a registration usually finds out when its customer’s shipment is stopped.
The Chemicals Control Act after August 2025
The Chemicals Control Act governs how hazardous chemicals are handled, stored, transported and imported. Its 2024 amendment, in force on 7 August 2025, replaced the single category of “toxic substances” with three classes — acute human hazard, chronic human hazard and environmental hazard (인체급성·인체만성·생태유해성물질, inche geupseong, inche manseong, saengtae yuhaeseong) — each with its own concentration thresholds for mixtures. About 1,250 substances were reclassified and some, such as ethyl acetate, dropped out. A separate category of accident-preparedness substances covers chemicals with a history of serious incidents.
The changes are phased. Letters of confirmation in the old format were accepted to the end of 2025; by mid-2026 confirmations, hazard labels, import declarations and safety data sheets had to reflect the new classes; new operating standards for handling apply from 1 January 2027; accident-prevention plans and permit applications under the new system from 1 January 2028; and facility standards from 1 January 2030. Mixtures with low benzene content have two extra years. Importers of hazardous chemicals file an import declaration (유해화학물질 수입신고, yuhae hwahangmuljil suip singo) before import, and before any substance is imported the chemical confirmation (화학물질 확인, hwahangmuljil hwagin) under Article 9 must be filed, by either the foreign manufacturer or the Korean importer. Businesses handling hazardous chemicals above set quantities need a permit or must file a declaration, and a draft overhaul of the business rules was consulted on in spring 2026.
Biocides and consumer chemical products
The Consumer Chemical Products and Biocides Safety Act — Korea’s equivalent of the EU Biocidal Products Regulation — requires approval of active substances and of biocidal products, with grace periods for existing active substances by product group: disinfectants, insecticides, repellents and rodenticides by the end of 2022; a second group by the end of 2024; product, film and fibre preservatives by 31 December 2027; and construction-material preservatives and antifouling products by 31 December 2029. The sell-off of non-compliant stock ended on 30 June 2026: since 1 July 2026 biocidal products without approval may not be sold, apart from products whose applications were filed in time, which may be sold until the end of 2026. Claims such as antibacterial or disinfecting on products that are not approved biocides are being policed.
The same Act covers safety-confirmation consumer chemical products (안전확인대상생활화학제품, anjeon hwagin daesang saenghwal hwahak jepum) — cleaners, deodorisers, adhesives, coatings and similar — which need testing against Korean standards and a declaration, renewed periodically, before sale; some, such as tattoo inks, need prior approval. Foreign manufacturers may appoint an Only Representative under this Act too.
Extended producer responsibility: packaging
Under the Act on the Promotion of Saving and Recycling of Resources, manufacturers and importers of products in packaging made of paper, glass, metal and plastics — and of certain products such as tyres, lubricants, batteries and fluorescent lamps — must ensure a set share is recycled each year, in practice by joining the producer responsibility organisation (재활용사업공제조합, jaehwaryong saeop gongje johap) and paying contributions. Importers are exempt below KRW 300 million of annual imports or 1 tonne of packaging (0.3 tonnes for foamed resin, 3 tonnes for glass); manufacturers below KRW 1 billion of sales or 4 tonnes.
The yearly cycle runs: recycling plan by 31 January; shipment and import data to K-eco by 15 April; recycling performance report by 30 April; and, where the obligation was not met, a charge of the recycling cost plus 30%, notified by 31 July and payable by 31 August. Packaging must also carry a recyclability grade (재활용 용이성 등급, jaehwaryong yongiseong deunggeup) assessment, and packaging graded hard to recycle pays a higher contribution — a surcharge planned to rise from up to 20% to up to 30%. Users of 5,000 tonnes or more of PET bottles a year must use 10% recycled content from 1 January 2026, rising to 30% by 2030, with the threshold falling to 1,000 tonnes in 2028.
The obligation sits with the importer of record. A foreign brand that imports through its own Korean company registers that company with K-eco and the producer organisation; one that sells through distributors should check that each distributor reports and pays for its packaging, and that contracts allocate the cost.
Electrical and electronic equipment
Korea’s Act on Resource Circulation of Electrical and Electronic Equipment and Vehicles combines take-back and recycling obligations with limits on hazardous substances similar to the EU’s RoHS. A decree of 22 April 2025 extended EPR to all categories of electrical and electronic equipment from 1 January 2026, so manufacturers and importers of products previously outside the list — many small appliances, IT accessories, tools and toys with electronics — now carry recycling obligations, report volumes and must meet substance limits. Batteries in products are already covered by packaging and product EPR; a dedicated EPR for electric-vehicle batteries is on the government’s roadmap. For product approvals, see KC certification.
Delivery packaging for online sellers
Rules introduced in April 2024 limit packaging for parcels delivered to consumers: empty space may not exceed 50% of the package, and only one layer of packaging is allowed. They apply to sellers and platforms with annual sales of KRW 50 billion or more, exempt packages of 50 cm or less in total dimensions, and were enforced from April 2026 after a two-year grace period. The 2026 rules eased several points — a 60 cm exemption for automated packing lines, a 60% ratio for packaging with at least 20% recycled plastic, 70% for paper cushioning, and exemptions for fragile goods — and an amendment of June 2026 created a monitoring centre at K-eco. Foreign e-commerce sellers fulfilling from Korean warehouses should audit their box sizes now; see e-commerce in Korea.
Climate: emissions trading and disclosure
Large emitters are covered by the Korea Emissions Trading Scheme (배출권거래제, baechulgwon georaeje). Phase 4, covering 2026 to 2030, was approved in November 2025 with a cap of 2,537 million tonnes of CO2-equivalent, rising auctioning in the power sector to 50% by 2030, 15% auctioning for other sectors, full free allocation for sectors at risk of carbon leakage, tighter benchmarks and a market stability reserve. Foreign-owned manufacturers with large Korean plants are participants like any other.
Sustainability disclosure is arriving in stages. Under the Financial Services Commission’s roadmap of July 2026, mandatory sustainability reports start in 2028, for the 2027 financial year, for KOSPI companies with assets of KRW 10 trillion or more, extending to those with KRW 5 trillion or more in 2029, with assurance from 2030 and Scope 3 emissions from 2031–33. Foreign subsidiaries are not directly covered unless listed, but Korean customers in scope will ask their suppliers for emissions and supply-chain data.
Factories, land and acquisitions
A foreign company building or buying a plant meets a further layer: environmental impact assessment for larger developments, permits for air and water emissions, waste-handling rules and soil contamination. Under the Soil Environment Conservation Act, liability for contaminated land can follow the owner and operator, which makes a soil survey a standard part of due diligence when acquiring a Korean site or company; see acquiring a Korean business. Leases of industrial premises should allocate remediation responsibility explicitly; see commercial leases.
What to do now
- Inventory what you place on the Korean market: substances and their annual tonnage per importer, mixtures, biocidal claims, packaging by material and weight, electrical products.
- Decide who holds the filings. An Only Representative for K-REACH and biocides, or your own Korean company as importer, keeps registrations with you rather than with a distributor.
- Check K-REACH status against 2027 and 2030: pre-registration, consortium membership, registration budget, annual report by 30 June.
- Update hazard classification: confirmations, labels, MSDS and import declarations under the 2025 Chemicals Control Act classes.
- Register for EPR if your Korean company imports packaged goods or any electrical product, and diarise 31 January, 15 April and 30 April.
- Write it into contracts: distribution agreements should state who registers, reports and pays, and what happens to registrations if the agreement ends.
- Keep a single calendar alongside tax and corporate deadlines; see the compliance calendar.
What we can do for you
Environmental filings follow the importer, so the first question is structural: whose name are your products in? We set up and run the Korean company that acts as your importer of record, so that registrations, EPR membership and reports belong to your group rather than a distributor. Through that company we handle the recurring EPR registration and annual reports, keep the environmental deadlines on the same calendar as tax, payroll and registry filings, and review distribution agreements so that responsibilities and costs are allocated clearly. For substance registration dossiers, biocide approvals and testing we coordinate with Korean chemical regulatory specialists and accredited laboratories, so you deal with one point of contact in English.
A worked example
A German maker of industrial adhesives sells into Korea through two distributors. Its products contain six substances on the Korean inventory, two of which reach 30 tonnes a year across both distributors combined — but only 15 tonnes each, so each distributor pre-registered separately and planned to register before the end of 2027. The products ship in plastic pails, and one product line was reclassified under the new chronic-hazard class in 2025.
The company appoints an Only Representative so that one registration covers both distributors, joins the existing consortium for the two substances and budgets for the dossiers before the 2027 deadline. It updates labels and MSDS to the new classes and has the distributors file the revised import declarations. When it later opens its own Korean company to import directly, the subsidiary registers with K-eco for packaging EPR and reports the pails each April. Two years on, when one distributor relationship ends, the registrations stay with the group.
Mistakes we see
- Leaving registrations with the distributor, then losing them when the contract ends.
- Counting tonnage per shipment instead of per importer per year.
- Missing the 30 June annual report under K-REACH.
- Old-format labels and MSDS after the 2025 reclassification.
- Antibacterial claims on products that are not approved biocides.
- Assuming EPR is the distributor’s problem after switching to your own importer.
- Electronics accessories outside the old EPR list, now covered since January 2026.
- Buying a Korean site without a soil survey.
Korean terms you will meet
Questions readers ask
When must existing chemicals be registered under K-REACH?
By 31 December 2027 for substances imported at 10 tonnes a year or more per importer, and by 31 December 2030 for 1 tonne or more, provided they were pre-registered.
Can a foreign manufacturer register chemicals in Korea itself?
Through a Korean-resident Only Representative, which registers and reports on its behalf so that its importers rely on one registration.
What changed in the Chemicals Control Act in 2025?
From 7 August 2025 toxic substances were replaced by three hazard classes, with labels, MSDS and import declarations updated by mid-2026 and further stages in 2027, 2028 and 2030.
Do foreign brands pay packaging EPR in Korea?
The importer of record does, if its imports exceed KRW 300 million or 1 tonne of packaging a year. If your own Korean company imports, it registers and reports.
Are all electronics covered by Korean EPR?
Yes. Since 1 January 2026 every category of electrical and electronic equipment is in the EPR scheme.
When do Korean sustainability disclosure rules start?
Mandatory reports start in 2028, for the 2027 financial year, for KOSPI companies with assets of KRW 10 trillion or more, extending to KRW 5 trillion in 2029.
- ChemRadar — K-REACH registration requirements
- 3E — Korea’s 2025 chemical regulatory overhaul
- REACH24H — K-REACH and Chemicals Control Act amendments 2025
- ChemRadar — Korea Biocides Act guide
- ERIA — Extended producer responsibility in Korea
- Shin & Kim — Resource circulation policy changes
- Enviliance — EEE EPR expansion to all categories
- Packaging Insights — Korea courier packaging rules
- ICAP — Korea approves Phase 4 K-ETS allocation plan
- FSC — Sustainability disclosure roadmap (July 2026)
- CIRS — K-REACH enforcement campaign and self-reporting
Alexander Baranov
Founder of the BCA Group · cross-border corporate and tax adviser since 2008
Alexander advises foreign founders and groups on company formation, tax structuring and corporate law in more than 40 jurisdictions across Europe, the Gulf, Asia and Latin America. He is the author of nine books on international business and tax and writes regularly for professional finance and tax journals. He works in English, German, Spanish and Russian.
This guide is based on the Korean statutes cited in the text and on our own filings. It is reviewed when the law or official rates change.