Analysis of Packaging Regulation Blind Spots in the Rapid Growth of C-commerce and Proposals for Expanding Korea’s EPR System

The rapid growth of China-based e-commerce (C-commerce) has led to a sharp increase in cross-border direct purchases, resulting in a substantial inflow of packaging waste into Korea without a clear management framework. Using 2024 itemized customs clearance data, the volume of packaging waste generated through C-commerce is estimated at a minimum of 24,413 tons. With the 2030 ban on direct landfilling of municipal solid waste approaching, such uncontrolled inflows pose a significant burden on domestic sorting and treatment facilities. Under the current Extended Producer Responsibility (EPR) system, established by the Act on the Promotion of Saving and Recycling of Resources, obligations are limited to domestic manufacturers and authorized importers, effectively excluding overseas sellers from regulatory oversight. This structural limitation allows foreign operators to free-ride on environmental costs and exacerbates regulatory blind spots in waste management. As an alternative, this study examines the European Union’s Packaging and Packaging Waste Regulation (PPWR), which preemptively legislates environmental responsibility for offshore sellers, to derive insights for platform-based regulatory enforcement. Based on this analysis, the study proposes a “Korean EPR Enforcement Structure Extension Model,” which integrates: (1) an Authorised Representative system, (2) the Korea One-Stop Shop (K-OSS), and (3) Functionally differentiated Producer Responsibility Organization (Type-C PRO). The proposed model incorporates cross-border distribution into the domestic regulatory framework, offering a concrete policy alternative for future EPR system design.