Looking Beyond the European Union: Key EPR Outline within Asia

The forerunner of EPR in Asia: unpacking Japan’s key packaging regulations:

When discussing extended producer responsibility regulations for packaging within Asia, Japan is one of the primary starting points. Japan was at the forefront within Asia for introducing its regulation for packaging entitled ‘Act on the Promotion of Sorted Collection and Recycling of Containers and Packaging.’ This was enacted in 1995 and implements a system for better recycling practices and the reduction of waste packaging and containers.

What products and packaging are in-scope?

Containers and packaging are defined under this regulation as ‘containers and packaging of goods, including the cases where containers and packaging of goods are paid for, which become unnecessary when the said goods have been) consumed or when the said containers and packaging have been removed from the goods.’ Companies that place the in-scope products and packaging onto the market are obliged to take responsibility for those packaged goods.

The main organisation, The Japan Containers and Packaging Recycling Association, lists out numerous examples of what is considered a container, which include bags used for storing goods and wrapping goods. There are certain exemptions under this regulation that include steel and aluminium cans, drink cartons and cardboard.

Who is obligated under this progressive act, and what should they do?

Under this regulation, ‘specified container users’ are defined as ‘business operators that use specified containers for goods they sell in their business.’ This can include manufacturers, importers, retailers, and wholesalers.

Once an obligation has been determined, companies must ensure that they reduce waste in containers and packaging. Along with reducing waste packaging, companies are required to report on an annual basis to the Minister on the number of containers and packaging used in the business, as well as adhere to the annual recycling obligation.

As we can see from this overview of the regulations, Japan has had a comprehensive system for waste containers and packaging since 1995, ensuring that businesses are effectively managing their waste and moving towards a more circular economy. Alongside Japan, it is important to see what steps other countries, such as South Korea, have taken to implement EPR regulations.

Moving west of Japan: an overview of South Korea

South Korea initiated an EPR program in 2003 with the ‘Act on the Promotion of Saving and Recycling of Resources’. The primary aim of this act is to aid in the preservation of the environment through controlling the generation of waste. This means that companies must ensure that their waste does not cause any harm to the surrounding environment.

The definition ‘recycling of resources’ is defined as ‘using and managing the process of recycling resources in an environment-friendly manner by controlling the generation of wastes to a necessary extent and properly recycling or treating generated wastes.’ The regulation aims to recycle resources by placing various obligations on those who manufacture, process, import, sell, or consume materials or products.

What products and packaging are in the scope of this Act?

Under this act, packaging materials are defined as ‘materials and containers used to pack products for protecting their value and condition, and preserving their quality in the processes of transportation, keeping, handling, and use.’

In general, companies that manage the above in-scope packaging materials are required to register with the main packaging compliance scheme: the Korea Environment Corporation (KECO). Once a company has registered, it must report on an annual basis on the relevant packaging materials that it places onto the market. As part of EPR, companies will need to adhere to the mandatory recycling obligations set within the regulations.

Continuing west of South Korea, understanding the foundations of EPR within China:

China has been developing their plans for a sufficient EPR system with a particular focus on beverage and consumer packaging. Where paper beverage packaging is concerned, the industry in general must adhere to a 40% recycling and reuse rate. Currently, China does not have a national packaging compliance scheme nor any related registration or reporting requirements due by companies that place packaging onto the market. However, with the progression of EPR and existing waste management laws, it is important for businesses to understand the best and most sustainable waste management practices that align with the Chinese Government's requirements.

Looking towards India, an Overview of the Federal Regulations for Packaging:

India has a thorough system for handling packaging and plastic waste under EPR. India’s federal packaging regulations entitled the ‘Guidelines on Extended Producer Responsibility for Plastic Packaging (Plastic Waste Management Rules),’ entered into force in 2021, with the latest amendment having effect from July 2025. These rules aim to ratify the obligations of producers under EPR, setting various obligations that cover the need for producers to register, report, comply with recycling targets for materials and establish a collection target for their plastic waste.

What packaging types do these rules apply to?

Under these rules, the following are in scope and considered obligated:

• Rigid plastic packaging.
• Flexible plastic packaging (either single-layer or multilayer).
• Multilayered plastic packaging (at least one layer of plastic and at least one layer of material other than plastic).
• Plastic sheets or similar materials that are used for carrier bags.

Which parties are obligated under these rules?

Under these federal rules, there are three primarily obligated parties that are commonly referred to as PIBOs, which include Producers, Importers and Brand Owners, with manufacturers also being obligated.

Under these rules, a producer is defined as a ‘producer of plastic packaging’, importers are defined as an ‘importer of various goods that include plastic packaging products or plastic packaging bags’, and brand owners are defined as ‘a person or company which sells goods under a registered brand label or mark’.

What comes next?

Once a company has determined their status under these rules, there are certain key steps to follow as usual with EPR requirements. Obligated companies must ensure they register with the Central Pollution Control Board (CPCB) by submitting various categories of information to their online central portal.

Once registered, companies must adhere to the required recycling targets at the following rates:

• 30-50% by 2024-5
• 40-60% by 2025-6
• 50-70% by 2026-7
• 60-80% by 2027-8 onwards.

These targets are mandatory and aim to ensure the proper recycling of plastic packaging, a higher level of reuse for rigid plastic packaging and recycled plastic content.

As well as ensuring that companies meet the relevant EPR targets, companies are required to submit annual records on the packaging placed on the Indian market.  Form this overview, India has a well-developed system for ensuring that companies better manage their waste packaging and plastic packaging through implementing concise requirements for PIBO’s.

Moving South-East to Thailand: Unwrapping Thailand’s plans for EPR

Thailand revised their ‘Sustainable Packaging Management Act’ in 2024, emphasising the need for a five-year plan to promote environmentally friendly packaging practices. This act applies to packaging, which ranges from boxes, containers to other materials.

As Thailand do not yet have a fully implemented EPR system, there are no associated packaging compliance schemes and, as such, no related registration or reporting requirements. With the continued progression of EPR laws, and the existing plans within Thailand, businesses should ensure they monitor these plans for further EPR developments.

Shifting Gears by Moving East: An Overview of Vietnam’s EPR Law:

Within Vietnam, companies are obligated under the ‘Law on Environmental Protection.’ This law obliges producers, manufacturers and importers to take responsibility for the packaging placed on the market. As part of their responsibility, in general companies must submit annual recycling plans to the main authority for EPR as well as report on their packaging quantities on an annual basis. 

What packaging materials are in-scope:

This law primarily applies to packaging and was expanded to include new sectors of EPR including batteries, tires, and lubricant oils. In 2027, Vietnam will expand their EPR sector to include vehicles. There are exemptions for companies under this law for food and beverage packaging that includes paper-mixed packaging, metal packaging and synthetic resin packaging.

Companies should ensure that they adhere to the pre-existing requirements for packaging within Vietnam and manage their packaging waste as required. Companies should adhere to Vietnam’s existent requirements for packaging and monitor the ever-changing field of EPR for new developments.

Rounding up EPR within Asia:

Having explored the vast continent of Asia and their key EPR regulations, it is clear that from these EPR systems implemented within Japan, South Korea, India, and Vietnam, have a comprehensive framework for enabling companies to take responsibility for their packaging. China is still in the beginning stages of EPR, with Thailand closely following along with their main Act on packaging, it is recommended to keep a close watch on evolving EPR developments.

The rapid rate at which EPR regulations are evolving can be frustrating for businesses that seek to make sense of how they might be affected by a potential law. Ecoveritas has and will continue to keep track of and interpret EPR regulations, along with other environmental laws impacting packaging, textiles, electricals, batteries, and wider sectors. Our exclusive Global EPR Matrix offers a unique insight into EPR laws that should educate you about your business’s obligations.

Get in touch with us today to learn more about our services. Please speak to one of our advisors today on +44(0)1865502176 or email us at info@ecoveritas.com