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ESG
2026-10-127 min read2

Year One of Korea's All-Product Electronics EPR — From 50 Items to Every Electrical and Electronic Product: How SME Manufacturers and Importers Should Confirm Coverage and Prepare Shipment Records and Recycling Contributions

Korea's electronics EPR expanded from 50 items to all electrical and electronic products in January 2026. This guide covers how SME manufacturers and importers should confirm coverage, compile first-year shipment records and prepare for recycling contributions.

KITIM Consulting Team

What Changed on January 1, 2026 — From 50 Items to Every Product

On January 1, 2026, Korea's extended producer responsibility (EPR) scheme for electrical and electronic equipment expanded from 50 designated items, mostly mid-size and large appliances such as refrigerators, washing machines and TVs, to all electrical and electronic products in principle. The change came through an amendment to the Enforcement Decree of the Act on Resource Circulation of Electrical and Electronic Equipment and Vehicles. Smaller products that were previously outside the scheme, such as clothes dryers and portable fans, are now covered.

  • A different cost structure: Newly covered companies are exempt from the waste charge they used to pay and instead meet their recycling obligation, typically by paying contributions to a producer responsibility organization. The government estimates a net reduction of about KRW 5.1 billion a year across all newly covered companies.
  • Excluded products: Some categories, including industrial equipment and military supplies, are excluded. The boundary of "industrial" varies by product, so check the decree text and Korea Environment Corporation (K-eco) guidance.
  • Small business exemption: The previous thresholds were manufacturers with prior-year sales under KRW 1 billion and importers with prior-year imports under KRW 300 million. Confirm the thresholds that apply after the amendment against the decree itself.
  • Is Your Company Covered — Judging by Business Type

    The most common question in year one was who the obligated party is. The principle is the manufacturer or importer that first places a finished product on the Korean market.

  • Own-brand manufacturing: The company that makes the product and ships it domestically is obligated.
  • Contract manufacturing (OEM/ODM): The ordering company that owns the brand is generally the obligated party. Contract manufacturers should confirm this from the contract and the shipping entity.
  • Import and resale: The importer of record is the reference point. Online-only sellers and small-lot, multi-product importers are not exempt by channel.
  • Parts and modules: Components assembled into a finished product are normally counted in the finished-goods company's records. The deciding question is whether the item is sold as a standalone product.
  • For borderline products, send a written inquiry to K-eco and keep the reply on file.

    Closing Year-One Records and the Early-2027 Schedule

    2026 is the first year newly covered companies finalize annual shipment records. Three things need to be settled before year-end.

  • Product group classification: Decide which product group each item belongs to. Contribution rates differ by group.
  • Weight-based totals: The obligation is calculated on shipped weight, not units sold. In practice, build a unit-weight table by model first and multiply by shipment quantities.
  • Reconciliation with customs data: Importers should be able to explain any gap between import declarations and internal shipment records.
  • Filing deadlines and contribution settlement dates follow notices from K-eco and the producer responsibility organization, and the detailed schedule for newly covered companies should be confirmed against those notices. Companies that used to pay the waste charge should review their assessments to make sure the charge has not been levied again on 2026 shipments.

    Choosing How to Comply — Joining the PRO or Complying Individually

    Companies can either pay contributions to a producer responsibility organization that handles collection and recycling on their behalf, or build their own collection and recycling arrangements.

  • The realistic option for SMEs: Because setting up a collection network and recycler contracts is difficult, most join the PRO (E-Cycle Governance).
  • Record keeping: Keep supporting data for shipment records, contribution payment records and membership documents by year.
  • Upstream obligations: The scope of hazardous substance limits has widened as well. Review the composition data and test reports you receive from component suppliers.
  • What to Build into Product Design and Cost

    Contributions scale with shipped weight, so lighter products and simpler material mixes reduce cost directly. Structures that are easy to disassemble and recyclable materials are also items customers check in ESG supply chain assessments. Exporters will work more efficiently by keeping product weight, material composition and hazardous substance information in a single product data sheet that serves both domestic EPR reporting and overseas regulatory requirements.

    How KITIM Can Help

    KITIM supports companies with EPR coverage assessments for electrical and electronic products, shipment record management systems, environmental compliance diagnostics and ESG supply chain assessment responses. If your product classification or obligated-party status is still unclear ahead of your first annual filing, please reach out through the KITIM consultation request. We will start by working through the checklist that fits your company.

    Extended Producer ResponsibilityEPRElectrical and Electronic EquipmentResource CirculationRecycling ObligationWaste ChargeImportersSMEs
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