ILMA Compoundings October 2016 - 39

INTERNATIONAL INSIGHT

K-REACH PEC Registration
The joint registration process for Priority Existing Chemicals
(PECs) under K-REACH is well underway. But many in industry
are slow to participate. In fact, I find many exporters are unclear
of the need and seem unaware of the prospective market
interruption that is risked by late registration.
With that latter comment in mind, allow me to summarize.
PECs are existing chemical substances that are currently
freely permitted and placed on the South Korean market, and
that have been selected as requiring new registration under
K-REACH. A list comprised of 510 of these chemicals was
published by the Ministry of Environment at the end of July 2015.
The new registrations must be completed and approved by the
third anniversary of that publication in July 2018. The registration
process is quite similar to a European (EU) REACH joint
registration, including the need to become part of a Substance
Information Exchange Forum (SIEF) and share data development
costs with the lead registrant and other joint registrants.

But for substances that do not yet have a lead registrant,
more ground must be covered. A realistic assessment must
be made concerning the prospect of another lead registrant
candidate appearing. In some cases, an SIEF will still be in
the formation stage. If this represents your scenario, more
immediate preparatory steps include careful positioning with
other prospective registrants. In both situations, the calendar is
growing less friendly.

Taiwan REACH New Phase 1 Registrations
This past March, Taiwan EPA was inundated with Phase 1
registrations reflecting threshold volumes of existing substances
imported during calendar years 2015, 2014 and 2013 respectively.
Candidly, many late registrations are continuing to flow in, and
submitted registrations are still awaiting processing and approval.

The main focus of the above paragraph should be on
the deadline and its meaning. With EU REACH, the
acknowledgement by the European Chemicals Agency (ECHA)
of the dossier submittal and completeness and the payment
of the requisite filing fee opens market access. There is no
immediate approval condition upon which the access is based.
In effect, approval is presumed until such time as a subsequent
corrective action is required or restriction is imposed.
In stark contrast, K-REACH does not permit market access until
the registration is approved by the agency. For PECs, the existing
substances are permitted to enjoy continued market access
temporarily, during the 3-year "grace period" that begins with
the publication date of the related list. At the third anniversary,
the market closes for any importer in Korea of the affected
substance that is not covered by an approved joint registration.
Here's the second and sharper edge of that sword: it is likely that
with many PECs the importer is covered by competitor volumes
of that same substance. Translation: the exporter is the one that
loses the market while the importer simply shifts to a competitor
supply chain.
Given that we're into the second year of the grace period,
steps toward joint registration are strongly encouraged. For
those substances that already have a lead registrant appointed,
the steps needed for now are preliminary to filing the joint
registration. There are several items to cover, but the dossier
need not be prepared yet.

Prime Industries is a bottle manufacturer located
in Schulenburg, Texas. Our HDPE line of bottles
ranges from 4 oz. to 32 oz. in rounds, f-style
rectangles, additive and gear lube bottles.
Our customers have the flexibility to mix bottle sizes and bottle
colors to make up a truckload. We are strategically located at
Interstate 10 and Highway 77 between Houston and San Antonio.
We have access to all of the major truck lines and thus have the
capability of shipping coast-to-coast, and border-to-border.
At your request we can provide samples and quotes on our
products. Please do not hesitate to contact our sales team.
Joe Schindler
800-227-0539 ext. 106
jls@primellp.com

Robert Herbrich
800-227-0539 ext. 109
robert@primellp.com

Debbie Fojtik
800-227-0539 ext. 100
debbie@primellp.com

www.PrimeLLP.com

Compoundings October 2016 * 39 * Vol. 66 No. 10


http://www.PrimeLLP.com

ILMA Compoundings October 2016

Table of Contents for the Digital Edition of ILMA Compoundings October 2016

FROM THE PRESIDENT
FROM THE CEO
ILMA THANKS
VOICES & VIEWS: Today's Most Powerful Marketing Tool
VOICES & VIEWS: As the Market Turns: Preparing for the Next Upswing in Carrier Rates
VOICES & VIEWS: Technology Trends for Lubricants Companies: The Benefits of Working with Millennials
SCHOLARSHIP PROGRAM
NOTES FROM API
NOTES FROM STLE
THE ICIS VIEW
INFINEUM: THE EVOLUTION OF PC-11 AND GF-6
MILITARY MATTERS
INTERNATIONAL INSIGHT
FOCUS ON ETHICS
REGULATORY SPOTLIGHT
FAMILY BUSINESS
FINANCIAL FREEDOM
RULES & REGS
POWER PLAY
LEGAL EASE
THE WHITE PAPER
THE HEART OF ILMA
Happy Trails: ILMA Sends Best Wishes to Retiring Members
Etna Hosts Congressional Dialogue with Rep. David Joyce
ILMA Compoundings October 2016 - 1
ILMA Compoundings October 2016 - 2
ILMA Compoundings October 2016 - 3
ILMA Compoundings October 2016 - 4
ILMA Compoundings October 2016 - 5
ILMA Compoundings October 2016 - 6
ILMA Compoundings October 2016 - FROM THE PRESIDENT
ILMA Compoundings October 2016 - 8
ILMA Compoundings October 2016 - ILMA THANKS
ILMA Compoundings October 2016 - 10
ILMA Compoundings October 2016 - 11
ILMA Compoundings October 2016 - VOICES & VIEWS: Today's Most Powerful Marketing Tool
ILMA Compoundings October 2016 - 13
ILMA Compoundings October 2016 - 14
ILMA Compoundings October 2016 - VOICES & VIEWS: As the Market Turns: Preparing for the Next Upswing in Carrier Rates
ILMA Compoundings October 2016 - 16
ILMA Compoundings October 2016 - VOICES & VIEWS: Technology Trends for Lubricants Companies: The Benefits of Working with Millennials
ILMA Compoundings October 2016 - 18
ILMA Compoundings October 2016 - 19
ILMA Compoundings October 2016 - SCHOLARSHIP PROGRAM
ILMA Compoundings October 2016 - 21
ILMA Compoundings October 2016 - 22
ILMA Compoundings October 2016 - 23
ILMA Compoundings October 2016 - 24
ILMA Compoundings October 2016 - NOTES FROM API
ILMA Compoundings October 2016 - 26
ILMA Compoundings October 2016 - 27
ILMA Compoundings October 2016 - NOTES FROM STLE
ILMA Compoundings October 2016 - 29
ILMA Compoundings October 2016 - 30
ILMA Compoundings October 2016 - THE ICIS VIEW
ILMA Compoundings October 2016 - 32
ILMA Compoundings October 2016 - 33
ILMA Compoundings October 2016 - INFINEUM: THE EVOLUTION OF PC-11 AND GF-6
ILMA Compoundings October 2016 - 35
ILMA Compoundings October 2016 - MILITARY MATTERS
ILMA Compoundings October 2016 - 37
ILMA Compoundings October 2016 - INTERNATIONAL INSIGHT
ILMA Compoundings October 2016 - 39
ILMA Compoundings October 2016 - 40
ILMA Compoundings October 2016 - 41
ILMA Compoundings October 2016 - FOCUS ON ETHICS
ILMA Compoundings October 2016 - 43
ILMA Compoundings October 2016 - REGULATORY SPOTLIGHT
ILMA Compoundings October 2016 - 45
ILMA Compoundings October 2016 - 46
ILMA Compoundings October 2016 - FAMILY BUSINESS
ILMA Compoundings October 2016 - 48
ILMA Compoundings October 2016 - 49
ILMA Compoundings October 2016 - 50
ILMA Compoundings October 2016 - FINANCIAL FREEDOM
ILMA Compoundings October 2016 - 52
ILMA Compoundings October 2016 - 53
ILMA Compoundings October 2016 - RULES & REGS
ILMA Compoundings October 2016 - 55
ILMA Compoundings October 2016 - 56
ILMA Compoundings October 2016 - POWER PLAY
ILMA Compoundings October 2016 - 58
ILMA Compoundings October 2016 - LEGAL EASE
ILMA Compoundings October 2016 - 60
ILMA Compoundings October 2016 - 61
ILMA Compoundings October 2016 - THE WHITE PAPER
ILMA Compoundings October 2016 - 63
ILMA Compoundings October 2016 - 64
ILMA Compoundings October 2016 - THE HEART OF ILMA
ILMA Compoundings October 2016 - Happy Trails: ILMA Sends Best Wishes to Retiring Members
ILMA Compoundings October 2016 - Etna Hosts Congressional Dialogue with Rep. David Joyce
ILMA Compoundings October 2016 - 68
ILMA Compoundings October 2016 - 69
ILMA Compoundings October 2016 - 70
ILMA Compoundings October 2016 - 71
ILMA Compoundings October 2016 - 72
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