South Korea Packaging Materials Requirement (Part 1): Materials Subject to Recyclability Grade Evaluation

This two-part article will give an A to Z introduction of Korea’s new packaging materials requirement. Part 1 introduces the new provisions on a general level, including the relevant regulations and materials subject to evaluation (Chapter 1 and 2). Part 2 specifies the detailed instructions on conducting the evaluation and labeling of the packaging material recyclability grade (Chapter 3).

Under the ever-increasing threat from environmental pollution, many countries took steps to control resource waste and plastic pollution. South Korea is one of the pioneers of this effort. On December 25, 2019, the Ministry of Environment (MOE) enacted the Act on the Promotion of Saving and Recycling of Resources (hereinafter referred as the Resources Recycling Act) ^[1] which banned the use of PVC materials and colored PET bottles as well as requiring enterprises to evaluate the packaging material grade.

As the grace period for evaluating packaging material grade ends on September 24, 2020, many enterprises are in dire need of detailed instructions on how to conduct this evaluation correctly. This article will give an A to Z introduction of the new packaging materials requirement to help enterprises have a better understanding of the Resources Recycling Act ^[1].

Chapter 1. Overview of the New Packaging Materials Evaluation Scheme

Following the Resources Recycling Act ^[1], manufacturers or importers are required to evaluate and grade the recyclability of specific packaging materials into four levels: “best to recycle," "good to recycle," "normal to recycle," and "difficult to recycle." A penalty up to three million KRW (about 2,600 UDS) would be charged to those who sell packaging materials or uses such materials as products packs without the recyclability grade label.

In addition to the Resources Recycling Act ^[1], MOE has unveiled a series of general supporting rules to optimize the management on packaging materials:

Main Act

Resources Recycling Act ^[1]

Supporting Regulations

Enforcement Decree of Resources Recycling Act^[2^]

Enforcement Rule of Resources Recycling Act ^[3]

Packing Material Recyclability Rating Standard ^[4]

Standards of Labeling Quality and Structure of Packaging Material Grade ^[5]

Chapter 2. Packaging Materials Subject to Evaluation

The manufactured and imported packaging materials designated in Article 18 of the Enforcement Decree of Resources Recycling Act ^[2]or products using the materials thereof shall undergo an evaluation. Following the Guideline on Packaging Materials Evaluation ^[6] released by Korea Environment Corporation (KEC), the materials subject to evaluation can be summarized as below:

Packaging Materials	Products	Examples
Paper packs	Beverages Agricultural/Aquatic/Livestock Products Detergents Cosmetics Shampoo and Conditioner for Pets Medicine and Quasi Drugs Butane gas Clothes Sanitary paper products Rubber gloves Antifreeze, Brake fluid, and Lubricant (applicable to packaging materials using synthetic resin only) Other products using packaging material of the synthetic resin
Glass bottles
Cans
Plastics
	Film/Sheet packaging materials and Foamed synthetic resin buffer material
	Disposable bags and shopping bags

The evaluation can be exempted under certain situations, such as when the annual import value of beverages, cosmetics, etc. using packages made of paper packs is less than 300 million KRW (about 253 thousand USD). One can find the detailed exemptions in the Attached Table 4 of Enforcement Decree of Resources Recycling Act ^[7] (in Korean). (Contact ChemLinked cosmetics team for translation services).

The competent authority has granted a nine-month grace period until September 24, 2020. The enterprises manufactured or imported packaging materials subject to evaluation from December 25, 2019, to September 24, 2020, shall submit the application prior to September 24, 2020.

* Please refer to Part 2 for the interpretation of evaluation procedure, evaluation method, submission of application for official confirmation, and labeling method.