3-Line Summary
- If details of your factory registration (company name, representative, factory area, ancillary facility area, detailed business types, etc.) change, you must apply for amended registration within 2 months of the date the change occurred. Failure to do so will result in a fine.
- Even if you start using space previously occupied by a tenant, this constitutes an increase in factory area and requires amended registration. You need to ensure the documentation matches the usage rights for the new space, the building record purpose, and the actual equipment layout.
- Comparing the site with the documents before submission will reduce requests for supplementary information. General amendments are typically notified within 7 days of receipt, so submitting them on time allows you to coordinate schedules with your clients.
Table of Contents
- Counting Backwards from the Day of Passing the Prime Contractor’s Review
- A Wider Factory, But the Same Factory Registration Certificate
- 2 Months from the Date of Change, Only 16 Days Remaining
- A Warehouse Space Still Listed on the Building Record
- The Registration of the Departing Company Still in Place
- Adding Detailed Business Types and Redrawing the Manufacturing Process
- 7 Days After Submission, and Then a Re-Review by the Prime Contractor
- Contents of Administrative Agent (administrative scrivener) Office Work and Checklist
1. Counting Backwards from the Day of Passing the Prime Contractor’s Review
I am an administrative agent (administrative scrivener) based in Songdo, Incheon. I’d like to share an experience I had while handling corporate licensing documents, starting with the result.
In the third week of October, I received a short text message from the plant manager of a metal processing company. “We passed the prime contractor’s new product review. We’re starting mass production next month.” Attached was a newly issued factory registration certificate. The number in the factory building area section was different from the one a month earlier.
Just a month ago, this single number had caused the new product approval to be suspended. The factory had already been expanded, and the machinery was already in place. Only the documents remained the same.
Expanding a factory usually ends with construction and equipment. Amending the factory registration is something that follows, and it’s easy to overlook. This case was the same.
2. A Wider Factory, But the Same Factory Registration Certificate
The client company was a manufacturer of aluminum brackets for automotive parts, located on an individual factory site in Seo-gu, Incheon. They have 14 employees. The 50-year-old representative, who had worked as a lathe technician for over 20 years, founded the company, and the representative’s daughter has been serving as the plant manager for the past 3 years, handling prime contractor relations and paperwork.
They were leasing the first floor of a two-story building. The other half of the first floor was occupied by another company that assembled wooden furniture. In mid-August of this year, that company relocated to Gyeonggi Province, leaving the space vacant. The representative discussed it with the building owner and decided to use the space as well, and brought in two CNC machining centers and one parts washing machine that had been postponed.
The reason for increasing the equipment was clear. The primary client, a Tier 1 supplier, had offered a new bracket order for electric vehicles, and the existing equipment could not meet the delivery deadline. The new product order was of a scale that accounted for nearly 30% of the company’s annual revenue. The representative even planned to hire two more night shift workers if they secured this order.
During the third week of September, the prime contractor’s quality team visited the factory to review the new product approval. The factory registration certificate was included in the review documents. The quality team member looked at the certificate and asked, “The factory area on the certificate doesn’t match the production line I’m seeing today. Are you in the process of amending the registration?”
The plant manager couldn’t immediately answer that question. The prime contractor “requested that they submit the documents again after matching the factory registration details with the current status” and suspended the approval.
3. Changes Occurred Two Months Ago, 16 Days Remaining
The first communication was an email from the facility manager. It included attachments such as a certificate of factory registration, building floor plans, the existing lease agreement, and photos of the newly acquired machinery. As scheduled, the representative and facility manager arrived together on Tuesday afternoon.
First, we confirmed the dates. Article 16 of the 「Act on Promotion of Industrial Complexation and Establishment of Factories」 stipulates that amended registration is required when certain items of factory registration change. The amended registration targets specified in the Enforcement Decree include the company name, representative, factory site area and factory building area (including increases due to tenant departure), ancillary facility area, detailed business types, and entry type. The application deadline is within two months from the date the change occurred. Changing registered items without amended registration can result in a fine of up to 2 million won.
This company’s change occurred on the date the neighboring business vacated and transferred their space. Checking the text messages exchanged with the building owner and matching the neighboring business’s moving date, it was around August 18th. The consultation date was October 2nd. There were 16 days remaining until the deadline.
The representative said, “I thought it was counted from the date the machinery was brought in.” Since the machinery arrived in early September, he thought there was more time. If we had planned based on a later date, we could have missed the deadline. I used the date of space acquisition as the starting point and worked backward to create the schedule. The target submission date was set as October 13th, five days before the deadline. This was to allow for some leeway in case a supplementary request came through.
4. A Single Warehouse Space Remaining on the Building Record
The next morning, we went to the factory to inspect it directly. Amending factory registration is not just about revising documents. The responsible department checks whether the application, business plan, manufacturing process, and machine list actually match the site. Inspecting the site beforehand significantly reduces the likelihood of supplementary requests.
We walked through the first floor with the building record in hand. Both the existing space and the newly acquired space were registered as factory use. However, a small section at the far end of the new space was designated as a warehouse. This was where the previous business had stored furniture materials.
The problem was that a parts washing machine was located in that warehouse space. They said it was placed there because it was convenient for piping work. The washing machine is a manufacturing facility included in the production process. There was a high probability that a supplementary request would be issued stating that the use did not match if a manufacturing facility was placed in a warehouse space and the area was applied as factory area.
There were two options. Change the use of the warehouse space or move the washing machine to a factory area. Changing the use would take more time and procedures and would be difficult to complete within 16 days. I recommended moving the washing machine to the factory area next to the CNC and keeping only raw materials in the warehouse space. Extending the piping work would take two days. The area of the warehouse space was divided and listed as ancillary facilities rather than manufacturing facilities.
With this arrangement, the areas to be written on the application became clear. We created a table dividing the factory site, manufacturing facilities, and ancillary facilities by floor and section. This is because the responsible person would not ask, “Is the entire building a factory?” but rather “How far does the area actually used for manufacturing facilities extend?”
5. The Registered Company Still Remains at the Old Address
In the afternoon of the day we visited the site, we made a preliminary inquiry to the factory registration department of the Yeonsu-gu office. While explaining the changes and confirming the necessary documents, the officer pointed out one thing: “Another company’s factory registration is still active at that address.”
The furniture company that had moved to Gyeonggi-do had moved without clearing up the factory registration at its old address. In the system, half of the first floor of the building was still registered as the factory area of that company. It is not possible to register the same space as the factory area of two companies simultaneously. If we had submitted the application in this state, it could have been stopped due to overlapping area.
This was something the client company could not do themselves. The application to clear the old registration had to be made directly by that company. The representative seemed troubled. They had a good relationship when they were neighbors, but there had been no contact since they moved.
I obtained the contact information of the company representative through the building owner, and the facility manager made the first call. I briefly summarized the points to request: ① the reason for clearing the factory registration at the old address, ② the relevant department at the Yeonsu-gu office and the necessary documents, and ③ the fact that if it wasn’t cleared, the other company would be left with a situation where the registration details and the actual situation do not match. It would be inconvenient for the company that wants to re-register its factory at the new factory to have the old registration still in place.
The company representative listened to the explanation and immediately took action. The application to clear the factory registration at the old address was received three days later. On the day he came to stamp the documents, he took two wooden chairs that he had been keeping in the corner of the warehouse and loaded them onto a truck. The facility manager said he had been using those chairs in the break room for two months. The chairs were gone, and new chairs were brought into the break room the next day.
6. Adding Detailed Business Categories and Redrawing the Manufacturing Process
Once the area issue was resolved, the next step was the business categories. The detailed business categories of the existing factory registration were only one: manufacturing of automotive parts. It’s easy to think that the new product is the same category because it’s also automotive parts. However, when we saw the specifications requested by the main client, this company plans to receive metal machining subcontracting orders from other companies in addition to automotive parts. This is to avoid letting the newly introduced CNC machining center sit idle.
According to the Korean Standard Industrial Classification (KSIC), the two categories are in different sub-categories. If subcontracting work is started and then the category is changed, it must be re-registered again at that time. It was better to add the detailed business categories together during this change. However, in order to add a business category, you must first check whether that category is eligible to be located on that land. We checked the zoning through the Land Use Plan Verification Certificate and also asked the relevant department during the preliminary inquiry about the possibility of adding the category.
We also redrew the manufacturing process flow. The existing process flow was raw material receipt, cutting, lathe machining, inspection, and packaging. The actual line included CNC machining and cleaning processes, and the cleaning machine had even changed location. I walked along the line with the factory manager, confirmed the order of the processes, and compared the model names and quantities of the machines listed with the nameplates one by one. One lathe on the first floor was out of order and scheduled for sale, so it was removed from the list. If the machines listed on the application are not working in the field, the on-site verification explanation will be lengthy.
We also confirmed the disposal of waste liquid from the cleaning machine. All the cleaning liquid was being taken away by a collection company, and there was a contract for entrusted disposal. We separately inquired with the relevant environmental department to confirm whether it was subject to environmental reporting, and wrote a single line about the answer in the business plan.
7. Within 7 Days of Submission, and Re-review by the Main Contractor
The submitted documents were prepared as follows:
- Factory Registration Change Application Form: Details of area and detailed business type changes were recorded.
- Business Plan: Included additional equipment, production items, and waste liquid disposal methods.
- Manufacturing Process Flow and List of Machinery and Equipment: The most up-to-date version, after on-site comparison.
- Factory Layout (Floor Plan): Showing the divisions and area of manufacturing and supporting facilities.
- Revised Lease Agreement: Specifying the area and period, including the new space.
- Building Information Record: For confirmation of the purpose of each division.
The lease agreement also needed to be revised. The representative and the building owner had only verbally agreed to the use of the new space, and the existing contract’s area remained unchanged. If the right to use the new space was not confirmed in writing, it would be difficult to have that area recognized as the factory area. We requested a revised contract from the building owner, reflecting the area and rent, and received it within two days.
The submission was completed a day earlier than planned, on October 12th. In general, the result of a standard registration change is supposed to be notified within 7 days of receiving the application. If there are related approvals being processed simultaneously, it could take until the 20th. This case did not have any such related approvals.
The relevant department came for an on-site inspection. They compared the layout with the actual location, the list of machinery with the nameplates, and confirmed that the warehouse area only contained raw materials. There were no requests for additional information. The registration change was processed 5 days after submission, and the management team leader issued a new factory registration certificate and sent it to the main contractor.
The main contractor’s re-review was completed simply by checking the documents. The message I introduced in Chapter 1 arrived that day.
8. Services Provided by the Administrative Agent’s Office and Checklist
Factory registration changes are procedures that quietly follow major events such as equipment investment or relocation. For companies, the focus is often on construction and deadlines, so these procedures are easily pushed back. It is common for companies to only discover that the documents and the actual site do not match when they need to submit a factory registration certificate for main contractor review, policy funding applications, or procurement registration.
If this is the situation, please check the following:
- Has the factory area increased or decreased? Even if you have expanded the space by taking over from a previous tenant, this requires registration changes. The deadline is 2 months from the date the reason for the change occurred, such as the date you took over the space.
- Has the company name or representative changed? Even if you have updated the corporate registry, a separate factory registration change is required.
- Have you confirmed the building information record purpose for the new space? If manufacturing facilities are located in warehouse or neighborhood living facility areas, a request for additional information may arise.
- Is there an old company’s factory registration still remaining at the same address? Checking this during a preliminary inquiry can prevent processing from stopping after submission.
- Have you included all future business types? If you plan to add detailed business types, it is more efficient to check the feasibility of the location and apply for this change at the same time.
Hwang Yunsang Administrative Agent’s Office drafts and submits factory establishment approval, factory registration, and registration change applications, as well as business plans and manufacturing process flows. Before submission, we compare the building information record, machinery list, and layout with the actual factory to organize any necessary revisions, and we also handle preliminary inquiries to the relevant department and responses to requests for additional information. Requirements and processing methods vary by region and case, so individual verification is necessary.
A single factory area number held back a new contract for a month. During the first week of November, that factory hired two new employees for the night shift.
This is a story constructed to aid understanding.
