- Nearly 631 exporters to come under revised regulations
- New compliance costs estimated at KRW 3.27 billion
South Korea’s Ministry of Climate, Energy and Environment has proposed bringing copper scrap, iron scrap and other non-ferrous metal scrap under the country’s mandatory waste export declaration framework, strengthening oversight of recyclable metal exports. The amendment, currently under public consultation until 5 August 2026, is scheduled to take effect on 1 January 2027.
The proposal does not prohibit or restrict exports of ferrous or non-ferrous scrap. Instead, it removes the long-standing exemption for these materials and requires exporters to comply with advance declaration and inspection procedures before overseas shipments.
The move aims to improve traceability, curb disguised exports of valuable recyclable metals and align South Korea’s regulatory framework with evolving global policies on critical mineral security.
Under the proposed amendment on the movement and disposal of waste across countries, iron scrap (ferrous scrap) and non-ferrous metal scrap, including copper scrap, will be added to the list of waste materials requiring export declarations. Although South Korea has operated a waste import-export reporting system since 2008, metal scrap has remained exempt despite successive revisions covering other waste categories.
Once implemented, exporters will be required to submit declarations before shipment, while the Ministry will review supporting documents and conduct inspections where necessary before approving exports.
Illegal copper scrap exports prompt regulatory action
The proposal follows growing concerns over disguised exports of high-value recyclable metals, particularly copper scrap. According to the Ministry’s regulatory impact assessment, several cases involved copper-bearing waste being falsely declared as ordinary scrap to bypass export monitoring, with shipments reportedly destined for China.
In March 2024, industry associations highlighted the increasing incidence of disguised copper scrap exports. Later that year, authorities uncovered a smuggling case involving copper-bearing waste that had been mis-declared as scrap metal. In 2025, the government’s Private Expert Committee on Critical Mineral Recycling recommended tighter regulations on exports of electronic waste, battery scrap and copper-bearing recyclable materials.
The Ministry noted that rising global competition for critical minerals has increased the strategic importance of recyclable metal resources. Several major economies, including Japan, the European Union, the United States and China, have also strengthened controls on recyclable materials and critical mineral-bearing waste.
The amendment also extends mandatory export declaration requirements to ferrous scrap. While the proposal does not cite significant cases of illegal iron scrap exports, the government aims to establish a uniform regulatory framework covering all major recyclable metal streams, improving traceability and monitoring of cross-border scrap movements.
Compliance requirements likely to increase for exporters
Following implementation, exporters of iron and non-ferrous metal scrap will be required to submit detailed shipment information and supporting documents, while customs authorities may conduct physical inspections before approving exports.
The revised framework is expected to affect around 631 exporters involved in scrap and non-ferrous metal trade. The Ministry estimates total compliance costs of approximately KRW 3.27 billion (US$2.2 million) over the assessment period, primarily due to additional reporting and documentation requirements.
Outlook
The revised framework is expected to have the greatest impact on scrap exporters, recyclers and trading companies that previously operated without mandatory export declarations.
Businesses handling legitimate exports may face higher administrative requirements but are unlikely to experience restrictions on overseas sales once compliance procedures are completed.
From a market perspective, the regulation is unlikely to disrupt legitimate trade flows but could marginally lengthen export processing timelines during the initial implementation phase. Increased scrutiny may also discourage illicit shipments, improving transparency across South Korea’s ferrous and non-ferrous scrap export channels.
As global competition for secondary raw materials continues to intensify, tighter monitoring of both ferrous and non-ferrous scrap exports is expected to become an increasingly important feature of international resource security policies.
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