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South Korea Requires Submission for Recyclability Data of Packaging Materials before April 15

MOE issues a notice on submission of delivery and import records of products and packaging materials. Enterprises subject to recyclability shall report the delivery and import data to MOE before April 15, 2022. ChemLinked concludes the critical points of the notice, including the data to submit, exemption situations, products and packing materials subject to recyclability obligation, and submission method.

On March 29, 2022, the Ministry of Environment (MOE) published a notice to require the relevant enterprise to submit the delivery and import data1 of the products and packing materials before April 15, 2022.

Background information

 

As per Article 22 under the Enforcement Decree of the Act on the Promotion of Saving and Recycling of Resources2, the “producer obligated to recycle” shall submit to MOE the data about the quantity of products and packaging materials that are delivered/imported in the previous year by no later than April 15 each year.

The “producer obligated to recycle” is either a manufacturer or an importer of the packaging materials subject to evaluation.

1. Data to be Submitted:


Enterprises

Data to submit

Producers obligated to recycle

(1) Records of delivered/imported quantity of the products and packaging materials subject to recyclability.

(2) Attached documents:

  1. A copy of the business license;

  2. A statement of final accounts or other documents that can prove the quantity of the delivered or imported products;

  3. Data for calculating the products’ and packaging materials’ weight and capacity as well as the data of the quality and structure;

  4. Application for reducing the delivery amount and documents proving the delivered packaging materials have been used in other enterprises' products. (Applicable to the situation where the enterprise intends to reduce the delivery amount);

  5. Application letter for installment payment of recycling dues (Applicable to the situation where the enterprise intends to pay the recycling dues by installment)

Enterprises eligible for exemption from data submission

(1) Confirmation Form of the Exception from Recyclability Obligation

(2) Attached Documents:

  1. Documents proving the sales amount or import amount (applicable to enterprises eligible for exemptions based on sales amount or import amount);

  2. Documents proving the delivery or import quantity (including the basic data for calculating the product and packaging material’s weight and capacity) (applicable to enterprises eligible for exemptions based on delivery quantity or import quantity).

2. Situations of Exemptions from Data Submission

Category

Entity

Exemption Situations

Packing Materials

[including the five kinds of films (except the PVC film)]

Manufacturer or importer of the products whose packaging materials are subject to recyclability or the five kinds of films

Types

Paper packs, metal cans, synthetic resin materials

Foamed synthetic resin materials

Glass bottles

Manufacturer

Sales 

amount

Less than 1 billion won (about 822 thousand dollars)

Delivery quantity

Less than 4 tons

Less than 0.8 tons

Less than 10 tons

Importer

Import amount

Less than 300 million won (about 247 thousand dollars)

Delivery quantity

Less than 1 ton

Less than 0.3 tons

Less than 3 tons

Products

Manufacturer or importer of the products subject to recyclability

-

3. Products and Packaging Materials subject to Recyclability Obligation

Category

Products and Packaging Materials subject to Recyclability Obligation

Products

Batteries

  1. Mercury batteries;

  2. Oxidized silver batteries;

  3. Nickel-cadmium batteries;

  4. Lithium batteries (limited to primary batteries);

  5. Manganese batteries and alkaline manganese batteries;

  6. Nickel-hydrogen batteries;

Tires

  1. Tires used for the motor vehicles defined in subparagraph 1 of Article 2 of the Motor Vehicle Management Act3;

  2. Tires used for the vehicles subject to the Act on the Management of Military Supplies4;

  3. Tires used for construction equipment defined in Article 2 (1) 1 of the Construction Machinery Management Act5;

  4. Tires used for agricultural equipment defined in subparagraph 1 of Article 2 of the Agricultural Mechanization Promotion Act6.

Lubricating oil

  1. Lubricating oil used for Motor vehicles defined in subparagraph 1 of Article 2 of the Motor Vehicle Management Act3;

  2. Lubricating oil used for vehicles subject to the Act on the Management of Military Supplies4;

  3. Lubricating oil used for construction equipment defined in Article 2 (1) 1 of the Construction Machinery Management Act5;

  4. Lubricating oil used for agricultural equipment defined in subparagraph 1 of Article 2 of the Agricultural Mechanization Promotion Act6;

  5. Lubricating oil used for Korean ships (excluding deep-sea vessels) defined in Article 2 of the Ship Act7;

  6. Lubricating oil used for fishing vessels (excluding deep-sea fishing vessels) defined in Article 2 (1) of the Fishing Vessels Act8;

Fluorescent lamps

Fluorescent lamps (including half-finished lamps for manufacturing fluorescent lamps containing mercury)

Buoys for farming marine products

Buoys for farming marine products (referring to buoys for farming marine products specified in the Korean Industrial Standards publicly notified under Article 11 of the Industrial Standardization Act9);

Sheet film for baled silage

Sheet film (referring to plastics made of synthetic resin used for compressing and binding forage crops, rice straws, etc.) for baled silage;

Racks of synthetic resin mats

Racks of synthetic resin mats (referring to racks used to dry laver among marine products defined in subparagraph 7 of Article 3 of the Framework Act on Fisheries and Fishing Villages Development10);

Products made of Synthetic resin

  1. Industrial films

  2. Replacement Water Filters

Films made of synthetic resin except for PVC

  1. Air-filled films used for shock-absorbing packaging or insulation;

  2. Films used for the washing and dry-cleaning services to protect fur products, clothes, fabric products, etc.;

  3. Plastic bags (excluding pay-as-you-go waste bags);

  4. Disposable vinyl gloves;

  5. Wrap films for food packaging;

Packaging materials

Paper packs

Packaging materials of:

Beverages, Agricultural/Aquatic/Livestock Products, Detergents,Cosmetics, Medicine and Quasi Drugs, Butane gas products, Insecticide and Sterilizer, Clothes, Sanitary paper products, Rubber gloves, etc.

(In cases of paper packs, limited to paper packaging to which the synthetic resin foil or aluminum foil is attached.)

Glass bottles

Metal cans

Synthetic resin packaging materials

Packaging materials of the final product (except the insecticides and toxic products contained in a plastic container)

※Antifreeze, brake liquids, and lubricating oil referred to in subparagraph 6 (limited to packaging materials made of synthetic resin)

Packaging materials of the Electrical machinery, etc.

Packaging materials in forms of film and sheet and shock-absorbing materials made of synthetic resin foam

Disposable bags and shopping bags

Disposable bags and shopping bags made of synthetic resin (excluding pay-as-you-go waste bags);

4. Data Submission Method

Enterprises can submit the required data online via MOE's IEPR system11


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