SME Sector Says "Burden of Registering Small-Quantity Chemicals Is High... Mitigation Measures Needed"
Korea Federation of SMEs Releases Results of Survey on Corporate Perceptions of Small-Quantity Existing Chemical Registration
According to a survey by the small and medium-sized business community, registering small-quantity chemicals under the Act on the Registration and Evaluation of Chemical Substances (ARECS) imposes a significant burden, highlighting the need for mitigation measures.
The Korea Federation of SMEs announced on April 5 the results of its "Corporate Perception Survey on Registration of Small-Quantity Existing Chemicals," which was conducted among 500 SMEs to assess the burden level related to registration of existing chemicals under ARECS. According to current ARECS regulations, those who intend to manufacture or import more than 1 ton of existing chemical substances annually must pre-notify the authorities and then register the notified substances in stages within a grace period, based on the quantity.
Among these, the 1–10 ton annual range that must be registered by 2030 has relatively low usage, but a high registration cost relative to corporate sales per company. The SME sector has continuously called for measures to alleviate this burden. This survey was conducted to identify the difficulties experienced by companies using small quantities (1–10 tons) of existing chemicals during the registration process.
The results show that 71% of responding companies handle existing chemicals in the 1–10 ton annual range, and each company uses an average of 17.59 chemical substances. Notably, workplaces employing between 10 and 30 people handled an average of 24.55 substances, making them the group dealing with the largest number of small-quantity existing chemicals.
The overall level of securing data necessary for chemical registration—such as physical and chemical properties, human toxicity, and environmental hazards—was found to be low. Regarding physical and chemical properties, most responses indicated lack of preparation, with 21.3% saying they have "secured almost none" and 52.5% saying they "have secured only some" of the required data.
For human toxicity data, less than 20% of workplaces with fewer than 30 employees responded that "most data is secured," and this figure was only 7.7% among companies with 5 to 10 employees. The proportion of workplaces responding that "most data is secured" was even lower for environmental hazard data, with only 4.3% in the chemical product manufacturing sector, indicating that many companies are unprepared for registration.
When asked about burdens and difficulties in the process of registering small-quantity existing chemicals, "lack of internal personnel and expertise" was the highest burden factor (68.38 points), followed by "cost of purchasing reference rights" (67.25 points) and "administrative and procedural complexity" (65.77 points), which were at similar levels.
The main difficulties experienced during participation in the joint registration consortium were "lack of information on the scope and adequacy of data" (46.4%) and "delays in negotiations and decision-making within the consortium" (46.4%). "Lack of transparency and fairness in reference right pricing and cost-sharing" (38.2%) followed. In particular, when asked about understanding the criteria for reference right pricing, the combined percentage for "do not understand at all" (17.3%) and "partially understand" (44.5%) was 61.8%, with an average score of only 33.18 out of 100, indicating significant difficulties in understanding reference right pricing.
When asked about anticipated difficulties if small-quantity existing chemicals are not registered, "production disruptions and risk of product discontinuation" (62.2%) was the most common response, followed by "additional costs due to switching to alternative substances or domestic purchases" (60.8%). Among workplaces with fewer than 10 employees, "business suspension or withdrawal due to deteriorating profitability" was higher than in other company groups, indicating that chemical registration has a direct impact on business management.
Regarding the effectiveness of introducing measures to alleviate registration burdens, "cost vouchers and support programs" (67.55 points) were rated highest, followed by "extension of registration grace periods" (67.40 points), and "simplification of administrative forms and submission items for small-quantity categories" (67.15 points). In micro-enterprises with fewer than five employees, immediate support measures such as "cost vouchers" (69.54 points) and "extension of grace periods" (69.83 points) were preferred to reduce management burdens.
Across the overall ARECS implementation process, the biggest burden, regardless of the number of employees or annual sales, was "economic cost" (63.4%). The most demanded policy was also "financial support" such as subsidies and vouchers (62.6%).
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Yang Chanhoe, head of the Innovation Growth Headquarters at the Korea Federation of SMEs, said, "Although the annual usage in the 1–10 ton range is relatively low, there are a large number of substances and a wide variety of uses, so many SMEs without specialized personnel feel a heavy burden regarding registration." He added, "After the registration of the 10–100 ton range is completed at the end of 2027, the registration of the 1–10 ton range is expected to begin in earnest. By identifying the difficulties SMEs face during the implementation process and rationally improving the system and providing appropriate support measures, we can increase the compliance rate with the system."
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