KOREA ROHS COMPLIANCE
On April 2nd, 2007, the South Korea Legislation Research Institute published its own Korea RoHS law. This regulation went into effect on January 1st, 2008, under the name of the Act on Resource Circulation of Electrical and Electronic Equipment and Vehicles. It is the South Korean version of the Europe RoHS, WEEE, and ELV directives combined.
Scope of the Korea RoHS Act on Resource Circulation of Electrical and Electronic Equipment and Vehicles
The following categories are mostly consumer-oriented products, focusing on items with significant market presence and environmental impact.
Initial 10 Consumer Product Categories
Initially, Korea RoHS has focused on these specific categories of Electrical and Electronic Equipment (EEE) and Vehicles:
- Major consumer products such as televisions, cellular phones, washing machines, PCs, printers, air conditioning units, and
- Automotive equipment like cars, vans, and trucks of less than 3.5 tons.
A first Expansion of 16 Categories
On July 1, 2013, Korea RoHS expanded its scope by adding 16 additional product categories to the list of regulated items. This move aimed to further reduce hazardous substances in a wider range of electrical and electronic equipment. Therefore, Korea demonstrated its commitment to strengthening environmental protection measures and aligning with international standards like the EU RoHS.
23 Specific Categories
The 2024 Korea RoHS Amendment
In September 2024, the South Korean Ministry of Environment drafted a revision to expand the scope of Korea RoHS to all EEE. Nevertheless, a list of excluded products remains, like military equipment.
The timeline for these revisions is:
- Public Consultation: September 25, 2024 – November 4, 2024.
- Legislative Review: By the end of November 2024.
- Promulgation and Grace Periods: By the end of December 2024, with enforcement of mandatory collection and recycling in 2026, and enforcement of hazardous substance restrictions in 2028.
Examples of Covered Products include:
- Industrial equipment
- Professional-use electronics
- Medical devices (with some potential exclusions)
- Commercial appliances (e.g., vending machines, industrial coffee machines)
- Consumer electronics (e.g., vacuum cleaners, kitchen appliances)
Excluded Products
Certain product categories are often excluded from RoHS due to their specialized use. These exclusions might include:
- Military equipment
- Large-scale stationary industrial tools
- Certain medical devices
- Products intended for research and development
However, these exclusions are subject to review and may vary based on specific product criteria and risk assessments.
Responsibilities of Manufacturers and Importers
As a manufacturer or importer, actively promoting recycling is a responsibility required by the Act. As such,
- developing technology for recycling;
- improving the materials and structures;
- restricting hazardous substance use;
- using products easily recyclable; and
- reducing/collecting any produced waste, are ways to uphold this responsibility.
Compliance with the restriction of hazardous substances is obtained through examination or assessment. Once compliant with the maximum concentration limits, the outcome must be publicly disclosed.
Korea RoHS Substance Restrictions
Products containing plastics or materials where phthalates are commonly used as plasticizers are particularly impacted by this amendment. Examples are:
- Power cords and cables
- Flexible PVC components (e.g., coatings, insulation)
- Adhesives, sealants, and films used in electronics
- Home appliances (e.g., refrigerators, vacuum cleaners, washing machines)
- Consumer electronics (e.g., televisions, audio devices, mobile phones)
- Computer peripherals (e.g., keyboards, mice)
The maximum allowable concentration of these chemicals is 0.1% (1000 ppm) by weight in homogeneous materials, except for cadmium which is 0.01%.
Korea WEEE
As in other countries, WEEE is an acronym that stands for Waste of Electrical and Electronic Equipment.
Manufacturers and distributors of electrical and electronic equipment are responsible for the future waste of the in-scope products they place into the Korean Market. As a result, to achieve their Extended Producer Responsibility (EPR) duties, manufacturers deal with local ‘producer compliance schemes’ (PCS). Then, PCS will arrange the collection and treatment of their WEEE. In addition, these PCS must recycle the e-waste according to the Ministry of Environment standards.
In the case of WEEE violation, the Minister of Environment can fine manufacturers, distributors, or producer compliance schemes, depending on the offence.
Korea ELV
ELV is an acronym standing for end-of-life vehicles. Just like the EU ELV Directive, Korea RoHS also restricts the use of four heavy metals in vehicles: lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr6+).
Any manufacturers or importers of vehicles and any persons managing vehicle scraps fall under the ELV scope of Korea RoHS.
On top of the restriction of heavy metals in vehicles, recycling obligations of end-of-life vehicles apply to in-scope stakeholders. Among other things, recycling facilities must shred residues and deal with hazardous substances separately.
Both the Minister of Environment and the Minister of Land, Infrastructure, and Transport demand periodical reports on the recycling, reuse, and disposal of vehicle scraps, for monitoring purposes.