South Korea

Recycling Act amendments

On 9 September 2019, the Korean Ministry of Environment notified the WTO TBT Committee (G/TBT/N/KOR/857) of several proposed amendments to the Act on the Promotion of Saving and Recycling of Resources.  The amendment proposes elements of mandatory recycling labelling including a system for “grading” ease of recyclability of packaging materials and recycling levies. The amendment is notified as entering into force on 25 December 2019 and allows a grace period of two years for industry compliance. WTO comments are due 60 days from the date of the notification.

We understand that all packaging material including alcoholic beverages must be evaluated according to its ease or difficulty in its recyclability, and that there will be four grades: excellent, good, normal and difficult. If a product has several parts, it will be assessed against its most difficult part. E.g. for wine bottles the assessment would include the glass, the cap or cork and the label. The criteria being used to grade ease of recyclability (see below) would appear to imply that certain wine packaging elements might be graded as “difficult”. 

The potential implications for imported wine include:

1. Labelling
If one of the components is “difficult” to recycle, the whole product is graded as difficult, and must be labelled as such. The image below shows the current recycling label (left) and the revised label (right), with the additional text at the bottom clarifying “good” “difficult” etc. However, only “difficult” grade must be labelled, and other grades may voluntarily apply the recycling logo, but are not required to do so.

2. Recycling Levy
All products that are graded as “difficult” will be charged an additional recycling levy. The levy is expected to be increased by up to 30% under the new regime however, details are not yet clear.

If producers/importers want to claim the product/material is better than “difficult”, this has to be verified by a public research center approved by the Ministry of Environment. Producers will have 9 months from 25 December 2019 to have this endorsed.