Amendment of Packing Material Recyclability Rating Standards

As the deadline for reporting last year’s import data, April 15, is approaching, producers obligated to recycle (PORs) may busy gathering information about the packaging materials. (Regarding who becomes the POR, you can refer to my previous post at https://koreacertifiedcustomsattorneysj.blogspot.com/2023/04/sudden-burden-for-importer-who-has-just.html)

Since every packaging type must be referenced in the Notice of Evaluation Result on Quality and Structure of Packing Materials, if a new packaging type was used in last year’s imported goods, self-assessment of quality, structure, and recyclability of packing materials must be completed before reporting for the new packaging type.

 

In addition, the Ministry of Environment Notification, PACKING MATERIAL RECYCLABILITY RATING STANDARDS (포장재 재활용 용이성 등급평가 기준) was amended and entered into force as of April 14, 2023 [ME Notification No. 2023-73]. If the recyclability rating changes under the amended standard, the self-assessment must be performed again, and the proper Notice of Evaluation Result on Quality and Structure of Packing Materials must be obtained before filing last year’s import volume of packaging materials.

 

Amended standards are:

[Appendix 1] Standards for the Quality, Structure, and Recyclability of Packing Materials

Before April 14, 2023	From April 14, 2023
□ Definition of Terms A.     The term "inseparable (cannot be separated)" means the cases where it is difficult for consumers to separate labels, caps and other components without using a tool, or the cases where some parts of the labels, caps, and other components remain on the body even if they are separated. However, the following cases are not considered " inseparable (cannot be separated)": 1.      Where a product cannot be used without separating labels, caps, and other components from the body. 2.      Where it is necessary to be inseparable for compliance with the safety standards for child-resistant packaging under the "Consumer Chemical Products And Biocides Safety Control Act," special packaging under the "Regulations on Safety Containers and Packaging for Medicines and Dosage Dispenser" (Notification of the Ministry of Food and Drug Safety), and safety containers and packaging under the "Cosmetics Act."	□ Definition of Terms A.     The term "inseparable (cannot be separated)" means the cases where it is difficult for consumers to separate labels, caps and other components without using a tool, or the cases where some parts of the labels, caps, and other components remain on the body even if they are separated. However, the case where a product cannot be used without separating labels, caps, and other components from the body is not considered "inseparable (cannot be separated)".
.	□ Evaluation standard E.      In the case where it is necessary to be inseparable for compliance with the safety standards for child-resistant packaging under the ‘Consumer Chemical Products And Biocides Safety Control Act,’ special packaging under the ‘Regulations on Safety Containers and Packaging for Medicines and Dosage Dispenser’ (Notification of the Ministry of Food and Drug Safety), and safety containers  and packaging under the ‘Cosmetics Act,’ “quality and structure with limited recycling capability (normal for recycling)” is given.
□ Details of the standard for quality and structure by packing material 7. PET bottle packing materials Classification Quality and structure that can be easily recycled Quality and structure that are difficult to recycle Label Ÿ Structure that enables consumers to separate the label easily1) Ÿ  Synthetic resin material with specific gravity less than 1 Ÿ If adhesive is used, use of separable thermal alkaline adhesive that can be separated during recycling process2) Best: non-adhesive or any equivalent label3), non-use of label4) Excellent: minimized5) area ‧ amount where adhesive is applied Ÿ Synthetic resin material with specific gravity not less than 1 and without structure that enables consumers to separate the label easily6) Ÿ Use of an adhesive that does not allow thermal alkaline separation Ÿ Directly printed on the body (except for marking expiration date and production date) 7) PVC-type material, material other than synthetic resin, and metal-included material   1)   Cut lines or edges to which adhesive is not applied [including a state where the adhesive force has been removed], excluding the cases where it would be technically impossible to apply the PE stretch label, etc. 2)   Separable thermal alkaline adhesive refers to an adhesive that is reacted to sodium hydroxide (2%) at a certain temperature (80℃) and separated during a recycling process. 3)    Where separable thermal alkaline adhesive is applied to an area less than 0.5% of the total label area. 4)   If only the bottle cap attaching label is used, ‘best for recycling’.  (In this case, the criteria of specific gravity and structure that enables consumers to separate the label easily don’t have to be met.) 5)   Where the area to which separable thermal alkaline adhesive is applied (excluding the area where the adhesive force has been removed) is 20% or less of the PET bottle’s entire area (based on the surface area except for the cap) and 60% or less of the label’s area. 6)   If there are cut lines making the label separable, ‘normal for recycling’.  7)   In the case of drinking spring water, etc., exclude the mandatory labeling matters stipulated in Article 14, subparagraph 1 of the Standard, Specifications, and Labeling Requirements for Drinking Spring Water.	□ Details of the standard for quality and structure by packing material 7. PET bottle packing materials Classification Quality and structure that can be easily recycled Quality and structure that are difficult to recycle Label Ÿ Non-use of label1) Ÿ Synthetic resin with specific gravity less than 1, meeting all of the following conditions: - Structure that enables consumers to separate the label easily2) - Use of separable thermal alkaline adhesive3) - Minimized4) area ‧ amount where adhesive is applied Best: non-adhesive or any equivalent label5) Use of separable thermal alkaline ink, designed to be non-adhesive and made of the same material as the body, allowing for separation during the recycling process6) Ÿ Synthetic resin material with specific gravity not less than 1 and without structure that enables consumers to separate the label easily7) Ÿ Use of an adhesive that does not allow thermal alkaline separation Ÿ Directly printed on the body (except for marking expiration date and production date) 8) PVC-type material, material other than synthetic resin, and metal-included material   1)     In the case where a label is not used or only the bottle cap attaching label is used, ‘best for recycling’.  (In this case, the criteria of specific gravity and structure that enables consumers to separate the label easily don’t have to be met.) 2)   Cut lines or edges to which adhesive is not applied [including a state where the adhesive force has been removed], excluding the cases where it would be technically impossible to apply the PE stretch label, etc. 3)   Separable thermal alkaline adhesive refers to an adhesive that is reacted to sodium hydroxide (2%) at a certain temperature (80℃) and separated during a recycling process. 4)   Where the area to which separable thermal alkaline adhesive is applied (excluding the area where the adhesive force has been removed) is 20% or less of the PET bottle’s entire area (based on the surface area except for the cap) and 60% or less of the label’s area. 5)   Where separable thermal alkaline adhesive is applied to an area less than 0.5% of the total label area. 6)   Separable thermal alkaline ink refers to an ink that is reacted to sodium hydroxide (2%) at a certain temperature (80℃) and separated during a recycling process. 7)   If there are cut lines making the label separable, ‘normal for recycling’.  8)   In the case of drinking spring water, etc., exclude the mandatory labeling matters stipulated in Article 14, subparagraph 1 of the Standard, Specifications, and Labeling Requirements for Drinking Spring Water.

 

[Appendix 2] Methods to determine the quality, structure, and recyclability of packing materials

Before April 14, 2023	From April 14, 2023
III. The definition of terms used in these guidelines is presented in the following table. 1. Common No. Term Definition 3 Inseparable • Status when it is difficult for consumers to separate labels, caps, and other components without using separate tools, or when some parts of the label, cap, or other components remain attached to the body even after separation. However, it is not considered to be inseparable in the case where the label, cap, and other components must be completely separated from the body to use the product, or the case where it is necessary to be inseparable for compliance with the safety standards for child-resistant packaging under the "Consumer Chemical Products And Biocides Safety Control Act," special packaging under the "Regulations on Safety Containers and Packaging for Medicines and Dosage Dispenser" (Notification of the Ministry of Food and Drug Safety), and safety containers  and packaging under the "Cosmetics Act."	III. The definition of terms used in these guidelines is presented in the following table. 1. Common No. Term Definition 3 Inseparable • Status when it is difficult for consumers to separate labels, caps, and other components without using separate tools, or when some parts of the label, cap, or other components remain attached to the body even after separation. However, it is not considered to be inseparable in the case where the label, cap, and other components must be completely separated from the body to use the product.   6. PET bottle No. Term Definition 10 Separable thermal alkaline ink •  An ink that is reacted to sodium hydroxide (2%) at a certain temperature (80℃) and separated during a recycling process.
.	Chapter 1 Methods to determine the quality, structure, and recyclability of paper packing materials 1.2.1.2 Determination of pulp of colors other than white: Examine visually the exterior and cross section of products to verify the presence of colored pulp other than white. If it is impossible to determine visually or difficult to determine clearly, confirm through instrumental analysis or any equivalent test analysis and supporting documents.
Chapter 2 Methods to determine the quality, structure, and recyclability of glass bottle packing materials 3.1.2 Difficult for recycling Cases where the retaining ring is separated from the cap when consumers open the cap, cases of a metal cap overlaid with synthetic resin, or cases of a cap that is inseparable from the body.	Chapter 2 Methods to determine the quality, structure, and recyclability of glass bottle packing materials 3.1.2 Difficult for recycling Cases where the retaining ring is separated from the cap when consumers open the cap, cases of a metal cap overlaid with synthetic resin, or cases of a cap that is inseparable from the body (excluding the cap which must be completely separated from the body to use the product).
Chapter 7 Methods to determine the quality, structure, and recyclability of PET bottle packing materials 2.1.1 Best for recycling Cases where a label is not used, or where the label is of non-adhesive synthetic resin material with specific gravity less than 1, or of synthetic resin material with specific gravity less than 1 in which separable thermal alkaline adhesive is applied to less than 0.5% of the entire label area having the structure of cut lines or edges to which adhesive is not applied enabling consumers to separate the label easily. However, if only a label that is attached to a bottle cap is used, it is not necessary to meet the conditions of specific gravity or structure enabling consumers to separate the label easily.       2.1.2 Excellent for recycling Limited to the cases where the label (1) is of synthetic resin material with specific gravity less than 1, using separable thermal alkaline adhesive that can be separated during recycling process; (2) have the structure of cut lines or edges to which adhesive is not applied enabling consumers to separate the label easily; and (3) have the area to which adhesive is applied 20% or less of the PET bottle’s entire area (based on the surface area except for the cap) and 60% or less of the label’s area.     2.2.1.3 With respect to specific gravity less than 1, separable thermal alkaline adhesive, adhesive-applied area ‧ amount, visual determination is not possible. It shall be confirmed through instrumental analysis or any equivalent test analysis and supporting documents.	Chapter 7 Methods to determine the quality, structure, and recyclability of PET bottle packing materials 2.1.1 Best for recycling One of the following cases is considered the best grade: (1) Cases where a label is not used; (2) Cases where the label is of non-adhesive synthetic resin material with specific gravity less than 1; (3) Cases where the label is of synthetic resin material with specific gravity less than 1 in which separable thermal alkaline adhesive is applied to less than 0.5% of the entire label area, having the structure of cut lines or edges to which adhesive is not applied, enabling consumers to separate the label easily; or (4) Cases where only a label that is attached to a bottle cap is used.   2.1.2 Excellent for recycling One of the following cases is considered the excellent grade: (1) Cases where the label is of synthetic resin material with specific gravity less than 1, featuring a structure that allows consumers to easily separate the label, such as with cut lines or edges where adhesive is not applied, using separable thermal alkaline adhesive, and having the area to which adhesive is applied 20% or less of the PET bottle’s entire area (based on the surface area except for the cap) and 60% or less of the label’s area; or (2) Cases where separable thermal alkaline ink is used, designed to be non-adhesive and made of the same material as the body, allowing for separation during the recycling process.   2.2.1.3 With respect to specific gravity less than 1, separable thermal alkaline adhesive, adhesive-applied area ‧ amount, and separable thermal alkaline ink, visual determination is not possible. It shall be confirmed through instrumental analysis or any equivalent test analysis and supporting documents.   2.2.2.6 Determination of separable thermal alkaline ink (1) Analysis method A.     Prepare samples by cutting and crushing the ink-printed area of the label into a size uniformly cut into 6-8mm in width and height. Samples with sizes beyond the range shall be excluded from the analysis. B.     Dry the crushed samples in a dryer at 60±1℃ for 3 hours or more. C.      Precisely measure the weight of an appropriate amount of the dried samples (about 20g) to the range of 0.01g. Prepare 10g of samples only if the weight of ink-printed label area per bottle is 1g or less. D.     Put samples in a 2% NaOH solution (1L) and stir the mixture at a speed of 200r/min for 10 minutes with an agitator set at 80±1℃. E.      Leave it for 1 minute and separate the floated ink layer on the surface. Repeat stirring and separation with a glass rod 3 times or more until no ink layer floats from precipitated samples. F.      Separate precipitated samples with a sieve and clean (and rinse) the separated samples with 1L of distilled water for 3 times. G.     Dry “cleaned labels from which ink is not removed (stripped)” in a dryer set at 60±1℃ for 3 hours or more and precisely measure the weight to the range of 0.01g. H.     Using the weight measurement, calculate the retention rate (%) of cleaned labels from which ink is not removed (stripped). ⓐ Retention rate (%) of cleaned labels from which ink is not removed (stripped) = (b / a) × 100 a: Weight (g) of crushed label (label + ink) prior to testing b: Weight (g) of cleaned label from which ink is not removed (stripped) after testing I.       Examine the residual ink of “cleaned labels from which ink is removed (stripped)” through “visual analysis” and with “infrared spectroscopy (FT-IR)”. (The instrumental analysis can be skipped if residual ink can be identified visually.) (2) Analysis result: The ratio of cleaned labels from which ink is not removed (stripped) shall be less than 3%, no residual ink shall be observed visually, and the result of instrumental analysis shall indicate that the PET material and the spectrum are identical.

 

Among the amendments, many of them do not affect the recyclability rating. This is because they were merely changes in the method of expression.

 

However, in the case of PET bottle with labels printed using separable thermal alkaline ink, a new criterion was introduced, which can lead to a change in recyclability rating. Therefore, it is recommended that importers of PET bottles or PET bottle-packaged products review their self-assessment of quality, structure, and recyclability before submitting import volume data to KECO (Korea Environment Corporation).