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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 packing 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 or products subject to recyclability obligation.

1. Data to be Submitted:


Data to submit

Producers obligated to recycle

(1) Records of delivered/imported quantity of the products and packing 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 packing 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 packing 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 packing 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



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


Paper packs, metal cans, synthetic resin materials

Foamed synthetic resin materials

Glass bottles




Less than 1 billion won (about 822 thousand dollars)

Delivery quantity

Less than 4 tons

Less than 0.8 tons

Less than 10 tons


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


Manufacturer or importer of the products subject to recyclability


3. Products and Packing Materials subject to Recyclability Obligation

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Tags : South Korea
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