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South Korea Packaging Materials Requirement (Part 2): Methods of Evaluating and Labeling Recyclability

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).

* In Part 1, a comprehensive introduction of the requirements on packaging material evaluation, was stated along with the list of materials subject to evaluation. Part 2 will illuminate the evaluation procedure, detailing methods for conducting the self-assessment, submitting an application for official confirmation, and labeling the recyclability grade.

Chapter 3. Packaging Material Recyclability Evaluation and Labeling

3.1. Evaluation Procedure

Figure 1. Evaluation Procedure.png

(Figure 1. Evaluation Procedure)

The manufacturer or importer of the packaging materials subject to evaluation, also known as the “producer obligated to recycle," is required to conduct a self-assessment on the materials’recyclability and submit the result to Korea Environment Corporation (KEC) for further confirmation. KEC will review the received documents and issue packaging material evaluation results within ten days.

After obtaining the confirmation result from KEC, the producer obligated to recycle should mark the materials or products with the recyclability grade labels (best/good/normal/difficult to recycle) within six months. Additionally, a dossier, including the information of the packaging materials and a list of products using such materials, must be submitted to KEC by April 15 of the following year

If "a producer obligated to recycle" dissents from the evaluation result, “the producer” can raise an objection with documents supporting the grounds of the objection within 30 days. Under this situation, KEC will review the objection's content and notify the result within ten days. 

3.2 Evaluation Application

Step 1. Self-Assessment

The “producers obligated to recycle” shall assess the recyclability of the package body, label, stopper, and other material components and analyze each component's impact on recycling. The producer can use the methods of “visual determination," or "instrumental analysis," as stated in the Packing Material Recyclability Rating Standard [4]. The assessment result shall be recorded for the follow-up official confirmation.

Assessment Methods

1. Visual determination

Visual determination applies to cases where evaluation for a rating is possible based on products' status without conducting a separate instrumental analysis or testing. The quality and structure rating can be determined visually, such as the color, which can be conducted without conducting an instrumental analysis.

 

2. Instrumental analysis

Instrumental analysis is a method to analyze quality and structure for rating when evaluation for the rating with visual determination is difficult. If the result of instrumental analysis differs from that of visual determination, the determination shall be made based on the instrumental analysis.

(Source: Attached Table 2 of Packing Material Recyclability Rating Standard [4])

The Guideline on Packaging Materials Evaluation [6] gives an example of a self-assessment result :

figure-2-pet-bottles-for-self-assessment.jpg

(Figure 2. PET bottles for self-assessment)

< Example of the Self-Assessment Result >

Packaging Material Components

Result Record

Body

▪ Colorless single materials

Label

▪ Structures that can be easily separated by customers;

Synthetic resin materials with a specific gravity less than 1;

Cut lines or edges to which adhesive is not applied.

 

▪ The thermal alkaline adhesive is applied to less than 20% of the PET bottle area and less than 60% of the label area.

Stopper

▪ Synthetic resin materials with a specific gravity less than 1.

Regardless of the contents, design, size, or color of the products, as shown in Figure 2, if the body, label, stopper, or other components of these products are of the same material the enterprise can conduct the self-assessment only once.  

Step 2. Application for KEC Confirmation

The “producer obligated to recycle” needs to submit an evaluation application letter in addition to the following documents to KEC after the self-assessment in Step 1:

  1. The result of the self-assessment of packing material quality and structure;

  2. Supporting documents about the result of the self-assessment of packing material quality and structure.

The application can be filed both offline and online. To submit online, the applicant should log in to KEO portal of www.iepr.or.kr and click “포장재재질구조개선 (Promotion of Packaging Material Quality and Structure)” to enter the submission page.

figure-3-portal-to-file-online-application.jpg(Figure 3. Portal to file online application)

Entering the application page, the business entity's information such as the company name, address, contact information, etc. shall be filed first. 

Regarding the next part of the application process, there are options for the applicant to select. Take the PET bottles in Figure 2 for instance, the applicant could choose the "PET bottles" in the options bar instead of typing the material type:

Figure 4. Demonstration of filing in application online I..png

 (Figure 4. Demonstration of filing in application online I. 

Double click to zoom in.)

The applicant is required to upload a picture of the relevant packing material. When there are several products that have the same packaging material, only one picture is necessary to represent them all.

Figure 5. Demonstration of filing in application online II..png (Figure 5. Demonstration of filing in application online II.)

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