Korea Cosmetics Packaging Recycling

On December 24, 2018, Korea issued the Promotion of Saving and Recycling of Resources Act (Recycling Act). The Recycling Act provides guidelines on the recyclability of packaging materials for the design and for packaging materials that are difficult to recycle. The Recycling Act bans the usage of plastic materials that are difficult to recycle such as PVC and colored PET bottles.

The Recycling Act is applicable to and impacts all products available in South Korea, including local and imported cosmetics products. The Recycling Act, implemented by Korean Ministry of Environment in December 2019, classifies nine packaging materials, such as:

· paper packaging,

· glass bottles,

· steel cans,

· aluminum cans,

· ordinary foamed synthetic resin – single/composite material packaging materials,

· polystyrene paper (PSP),

· PET bottles,

· synthetic resin single material container/tray, and

· composite material container/tray and single/composite material film/sheet packaging materials.

The Recycling Act requires packaging evaluation, gradation, and labeling with respect to recyclability and classifies packaging materials into four recycling grades: excellent, good, normal, and difficult.

The classification for packaging materials depends on the form by which they are sent for recycling. For instance, glass bottles, which are mainly used in toner/lotion cosmetics, are divided into body, label, and stopper/miscellaneous part. If the body color is colorless, brown, or green, it is considered good for recycling, but other colors are difficult to recycle. Difficulties in recycling include surface coating and painting used on the glass body. Labels are graded good for recycling when unused or paper materials or non-adhesive synthetic resin with perforated lines are used. Recycling becomes difficult when a synthetic resin material or metal mixed material is used or printed directly on the body of the bottle. As for the stopper/ miscellaneous materials, the integrated structure of the lid and frame, and the stopper that can be separated from the body is classified as recycling grade. Synthetic resin covered metal caps, lid and frame separable structures, cork materials, and metallic materials are difficult to recycle. The result of the self-assessment of each component of the packaging material is aggregated and the final overall grade of the packaging material must be indicated on the labels. Products that are graded as “difficult to recycle” are obligated to indicate the recyclability class on their labels.

Pump-type containers used for shampoos were initially expected to receive a “difficult to recycle” rating due to the iron springs attached in those containers. The personal care Industry provided comments on the proposed regulations and the final guidelines reflect the comments. Synthetic resin single material or composite material pump-type containers are evaluated to “normal” if pumps can be separated. However, PET bottle materials are considered “difficult to recycle” regardless of pump separation.

Time Period: The Recycling Act includes a nine-month grace period from December 25, 2019-September 24, 2020, for grading and evaluation. While the labeling grace period extends until March 24, 2021. The Recycling Act allows for a maximum of a 9-month grace period for labeling until December 24, 2021, but requires approval from the of Korea Environment Corporation. If a product does not meet the requirements of the Recycling Act, manufacturers/importers are given an improvement period of one year to comply, or up to three years if there are changes to the manufacturing process. If a product does not meet the requirements of the Recycling Act following the grace and improvement periods, suspension on manufacturing, importation, sales, or a maximum penalty of KRW 1 bn (around USD 850) may be imposed.

For questions, contact the U.S. Commercial Service Korea at the U.S. Embassy in Seoul: office.seoul@trade.gov