South Korea to Tighten Management of Cosmetic Packaging Materials

Terms:
PVC: Poly Vinyl Chloride
PET: Polyethylene terephthalate
HDPE: High-density polyethylene
PP: Polypropylene

Main Amendments to the Act

1. Prohibition of use of packaging & container that makes recycling difficult, including:

• PVC material;

• Coloured PET bottles;

• General adhesives for labels.

Source: Internet

Impact on the Cosmetic Industry
1) The cosmetics with PVC material will be prohibited from Dec. 25, 2019.

• Prohibition of shrink film made of PVC material for products such as perfume

• Prohibition of PVC material for cosmetic set packaging (tray, etc.)

2) PET bottles should be colorless, and labels should be made of a material or structure that can be easily removed during recycling.

In case of violation, the first time penalty is an improvement order, and the second time penalty is the suspension of sale.

2. Evaluation of packaging material structure (grace period: Sep. 24, 2020)

The Act classifies packaging materials into four grades, which are best, excellent, good, and difficult (to recycle). According to Cosmetic Consulting, cosmetic manufacturers and importers must submit a packaging grade evaluation report to the Korea Environment Corporation (KEC), receive the confirmation of the grade from KEC, and mark it on Korean label within six months after receiving the confirmation of the grade from KEC. If it is difficult to do so within six months, it can be extended for one time only (an additional nine months).

Recycling grade must be evaluated within the grace period (Dec. 25, 2019, to Sep. 24, 2020).

Enterprises shall be ordered to cease manufacturing, importing, or selling in the event of failure to comply or breach any improvement order.

Example of Grade Mark on Korean Label

Cosmetic Packaging Grade Evaluation
1) In the case of cosmetics, lipsticks, palettes, and colored glass bottles are likely to be marked as "difficult to recycle." Bottles with a label that is not easily separated with water are likely to be marked as "difficult to recycle."

2) In the case of tubes, if the body is HDPE and the lid is PP, it is rated "good recyclable."

3) PET bottles that use non-adhesive labels (that can be easily separated with water) will be given a “best" grade, and incentives will be given to the enterprise.

4) In the case of the "best," "excellent," and "good" grades other than the "difficult to recycle," the self-assessment report must be submitted to the Korea Environment Corporation for evaluation confirmation.

Self-assessment Procedure for Cosmetic Importer
Since the self-assessment report is difficult to prepare in reality, it will be submitted with the test report issued by the test institute.

Challenges Facing the Cosmetics Industry

According to BeautyNury, although the South Korean cosmetic industry supports the use of environmentally friendly packaging materials, they have raised concerns about the implementation of the Act.

1. Grace Period is Too Short
The Act requires to label the grade mark on the packaging, but the 9-month grace period is too short. Cosmetic enterprises will be under severe pressure.

2. Loss of Packaging Creativity
The reason why K-Beauty is popular is that the visual part conforms to the latest fashion trend. Use of creative containers or packaging materials will be more challenging due to this Act.

3. Cost Increase
Small enterprises that produce multi-category products must attach grade marks on every product. The manufacturer or importer must all bear any expenses associated with testing by KEC to obtain the grade evaluation results. This is likely to translate to a price increase on affected products.