10 FAQs are selected to address some problems in submitting MSDS in South Korea, and 5 FAQs on the application for CBI protection. New FAQs will be updated on this website. Please stay tuned.

According to the revised Occupational Safety and Health Act, MSDS submission and CBI non-disclosure approval in South Korea through the IT system is mandatory before manufacturing or import of chemicals since January 16, 2021. The detailed requirements are stipulated in the revised Standards for Classification and Labeling of Chemical Substances and Material Safety Data Sheet (MOEL Public Notice 2020-130).

However, during the implementation in practice, a lot of problems were encountered. South Korea’s Ministry of Employment and Labor thus initiated a nationwide campaign on MSDS self-check on April 8, 2022 (news). A self-checklist was distributed to Korean manufacturers and importers to fulfill the MSDS self-inspection. The Basin/Regional Departments of Employment and Labor will conduct spot checks from July 2022 on unit compliance and rectify uncovered issues.

To address the problems, REACH24H held two webinars themed on Korea GHS compliance strategy in June and July:

[Resource Available] Spotlight on Korea GHS Regulatory Compliance Strategy

• Webinar I: Overview and Key Compliance Points
• Webinar II: MSDS Submission and CBI Non-disclosure Application

Below are some of the FAQs collected in these two webinars to facilitate your understanding of the compliance with the CBI Non-disclosure Application set forth by K-OSHA.

5 FAQs on CBI Non-disclosure Application

1. a) For different products can we appoint different ORs to apply for CBI protection separately? Can different ORs be appointed for CBI application and MSDS submission for the same product?

🅰: Different products can have different ORs to apply for CBI protection separately. However, for the same product, only one OR can be appointed to apply for CBI protection, prepare and submit MSDS, LoC, etc.

2. Can the alternative name and content range we used for CBI application be directly indicated on the MSDS before getting approval for CBI claims?

🅰: No, you need to update the MSDS after the CBI application is approved with the alternative name, content range, CBI approval number and validity period, and then submit it.

3. For an ingredient without hazard, if we want to indicate it in Section 3 of the MSDS and at the same time to preserve trade secrets, can we use an alternative name and not disclose CAS number?

🅰: Ingredients that are not categorized as hazardous factors cannot apply for CBI protection. If you insist on indicating it in Section 3 of the MSDS and keep it confidential, you can use alternative name in accordance with the MoE\’s Regulations on the Preparation of Data Protection Applications and the Methods for Managing Data Protection, etc., and use content range according to Article 17 of the MoEL Notification 2020-130. There is no need to apply to the MoEL for CBI protection.

4. We are an overseas supplier of mixed products to be exported to South Korea. But our upstream did not disclose all the ingredients to us. They kept confidential the names and CAS numbers of some ingredients. What should we do?

🅰: There are three ways: Read More

5. When the CBI extension application expires, can I apply for another extension?

🅰: Read More

Reference Links

• 10 FAQs on MSDS submission under Korea OSHA

• South Korea Initiates MSDS Self-check Campaign, Followed by Official Inspection

Contact Us

If you have any questions about Korean MSDS Submission & CBI Application Service, please feel free to contact us.

Tel: +86 (0)571-87007555

Email: customer@reach24h.com