What is South Korea EPR EEE

South Korea operates one of Asia's most established and rigorously enforced Extended Producer Responsibility systems for electrical and electronic equipment. The legal foundation is the Act on Resource Circulation of Electrical and Electronic Equipment and Vehicles (이하 "자원순환법"), commonly referred to as the EEEV Act or K-RoHS/WEEE Act. The act was originally passed in 2007 and entered into force on 1 July 2008. It functions as a unified domestic equivalent of three EU frameworks combined: the RoHS Directive (hazardous substance restrictions), the WEEE Directive (waste collection and recycling obligations), and the ELV Directive (end-of-life vehicles).

South Korea's national system for collecting and recycling waste electrical and electronic equipment has been built and operated based on the EPR system, which was first introduced in 2003, with the Ministry of Environment (MOE) including EEE as a specific target under EPR since the test-operation period that year.

The EEEV Act imposes two distinct but related obligations on producers:

1. Recycling/collection obligations — producers must collect and recycle a defined quantity of end-of-life products each year, either individually or through an accredited Producer Responsibility Organization (PRO).
2. Hazardous substance restrictions — products must not exceed prescribed concentration limits for ten restricted substances including lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates (DEHP, BBP, DBP, DIBP).

On 25 September 2024, the Ministry of Environment (MOE) announced draft revisions to the Enforcement Order and Enforcement Rules of the EEEV Act, with the primary revision being an expansion of the scope of RoHS and EPR rules from the current approximately 50 products to all electrical and electronic products.

The enforcement timeline for these expansions provides that mandatory collection and recycling obligations will apply from 2026, and hazardous substance restrictions will extend to all EEE from 2028, with the revised rules promulgated by end of 2024 and grace periods applied accordingly.

The Korea Environment Corporation (KECO), a semi-governmental body under the MOE, is the primary operational administrator for EPR compliance, maintaining the online registration portal and verifying performance data.

Does This Apply to E-Commerce & Online Sales

Yes. South Korea's EPR obligations under the EEEV Act apply based on the act of placing products on the Korean market, not on the physical location or sales channel of the seller. This means that:

1. Foreign companies selling EEE directly to Korean consumers through their own websites or cross-border e-commerce platforms are treated as importers under the law and bear full producer obligations.
2. Companies selling through Korean online marketplaces — such as Coupang, Naver Smart Store, or G-Market — may also be treated as producers if they are the entity importing and supplying the products.
3. Where a Korean marketplace operator imports goods on behalf of a foreign seller and takes legal title, the marketplace may assume producer status. However, where the foreign seller retains import responsibility, the obligation rests with the foreign seller.

There is no specific exemption for distance sales or cross-border digital commerce under the EEEV Act. Foreign producers must appoint a Korea-based representative — either an importer or a specialised compliance agent — to handle registration, reporting, and fee payment on their behalf.

Foreign companies selling into South Korea via third-party fulfilment networks, distributors, or trading companies should clarify in their contractual arrangements which entity will assume producer responsibility. If the Korean importer or distributor formally assumes producer status, they bear the compliance obligation. If no such arrangement is documented, the foreign company placing goods on the market remains responsible.

Who is the "Producer" Under South Korea EPR?

The EEEV Act defines the concept of a "producer" broadly. The following entities are considered obligated producers under the legislation:

1. Manufacturers — domestic companies that manufacture EEE in South Korea and place it on the market under their own brand or another brand.
2. Importers — entities that import EEE from abroad and supply it on the Korean market, regardless of whether they are the brand owner.
3. Private label owners — companies that commission EEE manufactured by a third party and sell it under their own brand name in Korea.
4. Authorised representatives — where a foreign manufacturer has no local establishment, the designated Korean representative assumes producer obligations on the foreign entity's behalf.

Manufacturers and distributors of electrical and electronic equipment are responsible for the future waste of the in-scope products they place on the Korean market, and to achieve their EPR duties, manufacturers engage with local Producer Compliance Schemes, which arrange the collection and treatment of their WEEE and must recycle the e-waste according to Ministry of Environment standards.

Sellers of EEE — that is, retailers who did not manufacture or import the product but sell it to end users — also carry a duty to collect waste equipment of the same category they sell, either independently or through a PRO. This obligation differs from but complements the producer's recycling duty.

Who Must Register for EPR EEE in South Korea

Any domestic manufacturer or importer of in-scope EEE that exceeds the applicable thresholds must register with the Korea Environment Corporation (KECO) through the EPR online registration portal (iepr.or.kr).

After registration, companies must regularly submit data regarding product sales, and authorities may conduct audits to verify reported information.

Foreign companies without a Korean legal entity cannot register directly. They must appoint a Korean-registered importer or a compliance service provider to register and fulfil obligations on their behalf. The designated representative acts as the point of contact for KECO and the MOE.

Registration is required before placing regulated products on the Korean market. Operating without registration while exceeding thresholds exposes companies and their Korean importers to penalties, product detention at customs, and potential market withdrawal orders.

The Ministry of Environment (MOE) retains ultimate regulatory authority over the EEEV Act, while KECO administers day-to-day compliance monitoring, data verification, and PRO accreditation.

South Korea EPR EEE Registration Threshold

Under the current framework, not all producers are subject to EPR obligations. The MOE has stated that small-sized manufacturers with annual sales of less than 1 billion Korean won (approximately USD 722,000) and small-sized importers with annual imports of less than 300 million Korean won (approximately USD 217,000) will continue to be exempt from the mandatory collection and recycling obligation.

Key threshold points to note:

1. The exemption thresholds are assessed on an annual basis using the preceding year's figures.
2. Importers and manufacturers are assessed on different thresholds — importers benefit from a lower absolute threshold than manufacturers.
3. Companies that fall below the threshold in one year but exceed it the following year must register and fulfil obligations from the year in which they exceed the limit.
4. There is no de minimis threshold based on product weight or unit volume for companies that exceed the turnover thresholds — the EPR obligation is universal for covered products once the financial threshold is crossed. Lovat Compliance
5. Producers of solar panels, regardless of turnover size, have been subject to EPR since the Solar Panel Waste Management Plan entered into force on 5 January 2023, pursuant to the EEEV Act.

Foreign companies should assess their threshold position based on the value of EEE imported into and sold on the Korean market each year, not on their global or home-country turnover.

EEE Categories Covered (and Excluded)

Currently covered products (pre-2026 expansion)

The established product list under the EEEV Act has included televisions, refrigerators, washing machines, air conditioners, PCs, audio equipment, mobile phones, printers, copiers, and fax machines as the core categories, with subsequent expansions adding electric water purifiers, electric ovens, microwave ovens, food processors, dishwashers, electric bidets, air purifiers, electric heaters, electric rice cookers, water softeners, humidifiers, electric irons, fans, mixers, vacuum cleaners, video players, dehumidifiers, navigation devices, scanners, beam projectors, routers, electric massagers, coffee makers, food dryers, treadmills, toasters, electric kettles, electric water heaters, electric frying pans, hair dryers, surveillance cameras, foot baths, sewing machines, video game machines, bread makers, fryers, steamers, and related equipment.

Post-2026 expanded scope

Under the proposed revisions, the scope of products subject to the obligation to collect and recycle is proposed to be expanded to all electrical and electronic products, with the MOE intending to exempt certain items such as industrial equipment and military equipment from mandatory collection and recycling.

In practical terms, the post-2026 open scope is expected to encompass the following categories (aligned broadly with international WEEE classification conventions):

1. Large household appliances (refrigerators, washing machines, air conditioners, dishwashers)
2. Small household appliances (irons, toasters, kettles, coffee makers, hair dryers, vacuum cleaners)
3. IT and telecommunications equipment (computers, monitors, printers, mobile phones, routers, scanners)
4. Consumer electronics (televisions, audio equipment, cameras, video game consoles)
5. Lighting equipment (fluorescent lamps are already covered under the separate Resource Recycling Act; LED and other EEE lighting expected under expanded scope)
6. Electrical and electronic tools (power drills, saws, and other motorised hand-held tools)
7. Toys, leisure, and sports equipment (electronic games, treadmills, fitness equipment)
8. Medical devices (certain categories; subject to ministerial designation)
9. Monitoring and control instruments (thermostats, alarm systems, surveillance cameras)
10. Automatic dispensers (vending machines with temperature exchange function)
11. Solar photovoltaic panels (covered since January 2023 under the EEEV Act)

Products excluded from EEE EPR obligations

• Military and defence equipment
• Large-scale fixed installations (infrastructure-grade equipment not intended for end-user markets)
• Space equipment
• Industrial equipment as designated by the MOE, which has indicated it intends to exempt this category from the mandatory collection and recycling expansion
• Products covered by other specialised frameworks (e.g., end-of-life vehicles regulated separately under the vehicles component of the EEEV Act)

Producer Responsibility Organization (PRO)

South Korea operates a PRO-based collective fulfilment model, which is the primary mechanism through which most producers — including foreign companies acting through their local representatives — discharge their recycling obligations.

The Korea Environment Corporation (KECO) oversees EPR implementation, monitoring compliance through an online portal where producers and importers must report their sales, imports, and recycling data. Producers must either collect and recycle their end-of-life products themselves or pay recycling fees to Producer Responsibility Organisations (PROs), which are accredited by KECO and manage the recycling process, with fees covering 70–90% of recycling costs and 1–5% allocated for public awareness campaigns.

The main accredited PROs for EEE in South Korea include:

1. Korea Electronics Recycling Cooperative (KERC) — the principal EEE PRO, covering the majority of consumer electronics and appliances categories.
2. Korea Packaging Recycling Cooperative (KPRC) — primarily for packaging but relevant where EEE products include regulated packaging components.

When a producer joins a PRO, the PRO assumes operational responsibility for collection logistics, transportation to licensed recyclers, and reporting to KECO. However, the legal obligation for compliance — and the legal exposure for non-compliance — remains with the registered producer.

Producer Compliance Schemes arrange the collection and treatment of WEEE and must recycle the e-waste according to Ministry of Environment standards, and in the case of WEEE violation, the Minister of Environment can fine manufacturers, distributors, or producer compliance schemes, depending on the offence.

Alternatively, producers may choose to fulfil their obligations independently by contracting directly with KECO-licensed collection and recycling companies, submitting their own recycling plan, and reporting performance directly to KECO.

EPR Registration in South Korea

The registration process for EEE EPR in South Korea involves the following steps:

1. Determine obligation status — confirm whether your products fall within in-scope EEE categories and whether your annual turnover/import value exceeds the applicable threshold.
2. Appoint a Korean representative (for foreign companies without a Korean legal entity) — engage a Korean-registered importer, trading company, or specialist compliance agent authorised to act on your behalf before KECO and the MOE.
3. Create an account on the KECO EPR portal (iepr.or.kr) — registration is completed through KECO's online system. Foreign companies register through their designated Korean representative's account.
4. Submit product and sales data — provide details of EEE product categories, quantities placed on the market (by weight and unit), and brand names under which products are sold in Korea.
5. Select a compliance pathway — choose to join an accredited PRO (most common for foreign companies) or declare an intention to fulfil obligations independently.
6. Execute a PRO membership agreement (if joining a PRO) — this establishes the producer's recycling obligation share and the fee structure for the year.
7. Receive registration confirmation from KECO — once registration is complete and accepted, the producer is formally enrolled in the EPR system and may place regulated products on the Korean market.
8. Submit annual recycling plan — by 31 October each year, producers must submit their collection target plan for the following year.

Authorized Representative

Foreign companies without a place of business established in South Korea cannot register directly with KECO or hold direct legal responsibility under the EEEV Act in their own name. The EEEV Act requires that a Korea-based authorized representative be designated to act on the foreign producer's behalf.

Foreign producers must designate a Korea-based authorized representative to manage EEE data, reporting, and liaison with the MOE and recyclers.

The authorised representative may be:

1. A Korean importer or distributor that imports the foreign company's products under a formal distribution agreement — this is the most common arrangement for companies with established Korean distribution networks.
2. A specialist EPR compliance service provider registered in South Korea — appropriate for companies selling directly to Korean consumers without a local distributor, or where the distributor does not wish to assume compliance liability.

The authorised representative must be capable of:

• Registering the foreign company's products on the KECO portal
• Submitting annual recycling plans and performance reports
• Paying PRO fees or managing recycling arrangements
• Responding to KECO audits and information requests

It is strongly advisable to formalise the representative arrangement in a written agreement that clearly allocates compliance responsibilities, costs, and liability between the foreign company and the Korean representative. A change of representative must be notified to KECO.

What Data Must Be Reported

Registered producers in South Korea are required to report the following data to KECO on an annual basis:

1. Product categories — the specific EEE categories of products placed on the Korean market, using KECO's product classification codes.
2. Quantities placed on market — the total volume of EEE released for sale in Korea during the reporting year, expressed by both unit count and weight (kilograms or tonnes per product category).
3. Import volumes — for importers, the quantity and value of EEE imported, broken down by product type.
4. Brand names — all brand names under which the products are marketed in Korea.
5. Recycling performance data — actual volumes of waste EEE collected and recycled during the year, either through the producer's PRO membership or independently arranged recycling contracts.
6. PRO contributions — confirmation of fees paid to the accredited PRO and the PRO's recycling certificates covering the producer's obligation share.

The annual report covers tonnes placed on market, recycled volumes, and PRO contributions.

Producers must maintain documentary evidence supporting all reported data, including sales records, import customs documentation, recycling certificates from licensed recycling companies, and PRO membership invoices. KECO may request these documents during verification or audit.

First Reporting Period & EPR Reporting Deadlines

For companies newly crossing the registration threshold or entering the Korean market, the obligation to register arises before products are first placed on the market in South Korea. There is no phased introduction period — obligations begin from the first year in which thresholds are exceeded.

Key reporting and compliance deadlines under the EEEV Act are:

1. Annual recycling plan submission — by 31 October each year, producers must submit their planned collection and recycling targets for the forthcoming year to KECO. PRO members typically fulfil this through the PRO's collective submission.
2. Performance report submission — by 30 June of the following year, producers must submit their actual recycling performance report to KECO, confirming that annual recycling targets were met.
3. Annual data report — by 31 March, covering tonnes placed on market during the previous year, recycled volumes, and PRO contributions.
4. PRO fee payments — timing is governed by the individual PRO membership agreement, but fees are generally assessed and invoiced on a quarterly or annual basis following submission of sales data.

Companies that miss the recycling plan submission deadline risk being assessed for recycling charges by the MOE on a default basis, which is typically more expensive than PRO fees. Missing the performance report deadline may trigger enforcement action.

Labels & Marketing Claims

The EEEV Act and related ministerial regulations impose specific labelling requirements on EEE placed on the Korean market.

Mandatory labelling requirements include:

1. Crossed-out wheeled bin symbol — in-scope EEE sold in South Korea must bear the internationally recognised WEEE symbol (crossed-out wheeled bin), indicating that the product must not be discarded as general waste and must be collected separately for recycling. This requirement applies to all products covered by the EEEV Act.
2. Hazardous substance content marking — products must carry information about the restricted substances present in the product, in accordance with the EEEV Act's RoHS provisions. This typically takes the form of a hazardous substance table on the product, packaging, or accompanying documentation, disclosing the presence or absence of each of the ten restricted substances in each major component.
3. Recycling obligation fulfilment mark — producers that have fulfilled their EPR recycling obligations may apply for authorisation from KECO to display the Recycling Obligation Fulfilling Mark on their products. Enterprises intending to use the Recycling Obligation Fulfilling Mark must apply for a confirmation of EPR obligation fulfilment, and the validity period for the mark is two years.
4. KC mark — while not an EPR-specific label, products sold in South Korea must carry the KC (Korea Certification) mark under the Electrical Appliances and Consumer Products Safety Control Act where applicable. KC certification is a prerequisite for market access and must not be conflated with EPR compliance.
5. Separate discharge marks (for packaging) — where EEE is sold in packaging subject to the separate packaging EPR regime, packing materials subject to recycling obligations must bear separate discharge marks, which can be downloaded from the websites of the Korea Environment Corporation (keco.or.kr) or the EPR portal (iepr.or.kr).

Sustainability and environmental marketing claims made in relation to recycled content, recyclability, or eco-design must be substantiated with verifiable data and must not be misleading under South Korea's consumer protection and advertising regulations.

EPR Eco Fees & Eco-Modulation

South Korea's EEE EPR system uses a recycling obligation rate model rather than a simple flat fee per unit or per kilogram. The recycling obligation is calculated as a proportion of the total volume of products placed on the market during the year.

How the obligation is calculated:

The recycling amount for products is calculated by multiplying the quantity of products manufactured or imported in the current year (obligation fulfilment year) by the recycling obligation rate. The MOE establishes long-term recycling targets every five years and sets the annual recycling obligation rate to facilitate the collection and recycling of products.

The annual recycling target is set on a per capita basis: the 2024 annual recycling target was 8.38 kg per person, with a total population of 51,751 thousand, resulting in a total quantity to be recycled of approximately 1,088,264 tonnes when calculated against the previous year's volumes placed on market. The 2024 reflection coefficient was 0.3.

PRO fee structure:

When a producer joins an accredited PRO, the PRO calculates the producer's individual obligation share based on their reported market share within each product category. PRO fees are structured to cover 70–90% of recycling costs, with 1–5% allocated for public awareness campaigns.

Non-compliance surcharge:

Non-compliance results in fines of up to a 30% surcharge on the calculated recycling charge, though smaller producers and importers are exempt from these obligations.

Eco-modulation:

While South Korea does not yet operate a formally codified eco-modulation system comparable to some European frameworks, the EEEV Act includes provisions encouraging eco-design. The Eco-Assurance System (Eco-AS) was introduced in 2008 to improve eco-friendly design of EEE products, increase recycling rates for WEEE, and strengthen criteria for restricting the use of harmful materials in EEE at the manufacturing stage. Products designed for easier disassembly and higher recyclability may attract more favourable terms from PROs and benefit from reduced recycling cost assessments. Formal eco-modulation based on repairability scores or recyclability grades is expected to develop further as the regulatory framework matures through 2026–2028. ScienceDirect

Risks, Penalties & Common Mistakes

Penalties for non-compliance

In the case of WEEE violation, the Minister of Environment can fine manufacturers, distributors, or producer compliance schemes, depending on the offence. Specific enforcement measures include:

1. Administrative fines for failure to register, late registration, or failure to submit required data.
2. A recycling charge surcharge of up to 30% above the standard recycling fee for producers that fail to meet their recycling targets.
3. Mandatory corrective action orders requiring producers to remedy compliance deficiencies within a set period.
4. Product detention or market withdrawal orders where unregistered products are identified at the border or in the market.
5. Public disclosure of violators — South Korea's regulatory framework allows for public naming of non-compliant companies, creating significant reputational exposure.
6. Penalties against the Korean importer or authorised representative acting on behalf of a non-compliant foreign producer.

Common compliance mistakes for foreign companies

1. Assuming the Korean distributor automatically handles EPR — many distributors accept delivery obligations but do not formally register as the producer under the EEEV Act. The split of responsibility must be explicitly agreed and documented.
2. Failing to monitor threshold crossings — companies that grow their Korean sales gradually may breach turnover thresholds without recognising the trigger point for mandatory registration.
3. Incorrect product categorisation — assigning products to the wrong KECO category results in the wrong recycling rate being applied, leading to under-fulfilment of obligations.
4. Missing the recycling plan deadline (31 October) — this is the single most commonly missed deadline and results in the producer being assessed for default recycling charges.
5. Non-compliant labelling — shipping products to Korea without the crossed-out wheeled bin symbol or with incomplete hazardous substance disclosures can result in customs clearance delays or market enforcement actions.
6. Relying on EU RoHS compliance documentation alone — while South Korea's restricted substance list largely mirrors the EU RoHS list, the documentation formats, testing standards, and disclosure requirements differ. Korean-specific substance declaration formats should be prepared separately.
7. Failing to account for expanded scope obligations from 2026 — companies currently outside the 50-product list should begin compliance planning now in advance of the expanded EPR scope taking effect.

What E-Commerce Sellers Should Do Now

Foreign e-commerce companies selling EEE to Korean consumers or planning to enter the Korean market should take the following steps:

1. Audit your product portfolio against the current EEEV Act product list and the forthcoming expanded scope, confirming which products are in scope for EPR obligations in 2025 and which will be captured from 2026.
2. Calculate your Korean market sales value for the previous year to determine whether you exceed the importer threshold of 300 million KRW (approx. USD 217,000) or the manufacturer threshold of 1 billion KRW (approx. USD 722,000).
3. Identify your compliance pathway — determine whether your Korean distributor or importer is formally registered as the producer, or whether you need to appoint a specialist authorised representative.
4. Appoint a Korea-based authorised representative if you sell directly to Korean consumers or if your Korean distributor has not assumed producer responsibility in writing.
5. Register on the KECO EPR portal (iepr.or.kr) through your authorised representative, and submit your initial product and sales data.
6. Join an accredited PRO — for most foreign companies, membership of the Korea Electronics Recycling Cooperative or another KECO-accredited PRO is the most efficient way to fulfil recycling obligations.
7. Submit your annual recycling plan by 31 October and your performance report by 30 June of the following year.
8. Review product labelling — ensure all in-scope products carry the crossed-out wheeled bin symbol and compliant hazardous substance disclosure tables before shipping to Korea.
9. Align RoHS documentation with Korean-specific requirements, including the ten-substance restriction list and the Korean-format material declaration.
10. Monitor the 2026 and 2028 regulatory expansions — begin internal compliance planning for the broadened product scope and the extended hazardous substance restriction requirements before they take effect.

FAQ

• Is EPR registration for EEE mandatory in South Korea?

Yes. Registration with KECO is legally mandatory for all manufacturers and importers of in-scope EEE that exceed the applicable thresholds under the EEEV Act. Operating without registration while above the threshold exposes the company and its Korean representative to administrative fines, product detention, and market withdrawal orders.

• Do the EPR obligations apply to foreign sellers without a Korean legal entity?

Yes. Foreign companies selling EEE on the Korean market — whether through a local distributor, a Korean marketplace, or directly via cross-border e-commerce — are subject to EPR obligations. They must appoint a Korea-based authorised representative (a registered Korean importer or compliance service provider) to register, report, and fulfil recycling obligations on their behalf. The foreign company cannot register directly.

• What is the threshold for EPR registration in South Korea?

Small manufacturers with annual Korean sales below 1 billion KRW (approx. USD 722,000) and small importers with annual Korean imports below 300 million KRW (approx. USD 217,000) are currently exempt from mandatory recycling obligations. These thresholds are assessed against the prior year's figures. Companies crossing the threshold must register before placing further products on the market.

• What labelling is required on EEE products sold in South Korea?

All in-scope EEE must bear the crossed-out wheeled bin symbol indicating separate waste collection, and must include a hazardous substance disclosure table covering the ten restricted substances under the EEEV Act. Products sold by producers that have fulfilled their EPR obligations may also carry the Recycling Obligation Fulfilling Mark issued by KECO. The separate KC certification mark is also required for market access under product safety regulations, independently of EPR.

• Do online marketplace platforms have EPR obligations in South Korea?

Korean marketplace platforms that act as importers — taking legal title to goods before reselling them — may be considered producers under the EEEV Act and bear direct EPR obligations. Where the foreign seller remains the importer of record, the marketplace does not typically assume producer status. However, foreign sellers using Korean marketplaces as their primary sales channel should confirm in writing with the platform whether the platform is registered as the producer, or whether the seller must appoint a separate authorised representative to fulfil those obligations.

Packaging EPR law in South Korea: None enacted

South Korea is not among the countries with enacted textile EPR legislation.