Regulation of over-packaging in e-commerce in Taiwan and South Korea

• In Hong Kong, the e-commerce market saw a robust growth of 83% between 2019 and 2023. Massive online shopping has fuelled growing concerns over influx of packaging waste that poses severe threats to the environment. On the one hand, plastic packaging waste (e.g. stretch films and plastic tapes) can persist in the ground for over 500 years, with a low recycling rate of just 9% globally.^{1Legend symbol denoting Agriculture and Agri-Food Canada (2024), The Granite Tower (2024) and Environment Bureau (2021).} On the other hand, online shopping reportedly generates 4.8 times more packaging waste than offline retail activities, partly due to higher demand for protective packaging to facilitate shipment.^{2Legend symbol denoting Kim (2022).} Despite the lack of official data on local packaging waste, some estimated that around 780 million pieces of plastic packaging were generated by online shopping in 2020.^{3Legend symbol denoting South China Morning Post (2021).}
• At present, only two types of packaging (i.e. plastic shopping bags and glass beverage containers) are regulated locally under the Producer Responsibility Schemes ("PRSs"), which charge manufacturers, importers, retailers and/or consumers for the costs of recycling them. For the reduction of most other kinds of packaging waste, particularly those generated by e-commerce (e.g. delivery cartons and filling materials such as bubble wrap), it relies on government-issued voluntary guidelines and industry initiatives.^{4Legend symbol denoting Environment and Ecology Bureau (2025).} There are thus rising calls in society for more comprehensive packaging waste regulations. Since 2022, the subject of packaging waste from e-commerce has been discussed at the Legislative Council ("LegCo") on at least five occasions.^{5Legend symbol denoting As requested by members, the topic of “Regulation of excessive packaging” was also included in the outstanding item list for discussion of the Panel on Environmental Affairs in 2025. See Panel on Environmental Affairs (2023, 2024), Legislative Council Secretariat (2025) and Subcommittee to Study Policy Issues Relating to Municipal Solid Waste Charging, Recovery and Recycling (2022a, 2022b, 2023).}
• Globally, e-commerce has exploded in popularity as technology advances, with its global sales soaring by around 60% to US$27 trillion (HK$211 trillion) during 2016-2022. Continued boom in online shopping is expected to boost the global e-commerce packaging market to US$86.9 billion (HK$680 billion) by 2030, representing a 75% growth from 2023.^{6Legend symbol denoting United Nations (2024) and Deloitte (2024).} A number of advanced economies have introduced measures such as taxes and mandatory reduction plans to control packaging waste in recent years.^{7Legend symbol denoting Since the 2020s, some places have imposed new measures on producers in tackling the rapid growth of packaging waste, regardless of whether it is related to e-commerce. These mainly include (a) extending PRS to cover more types of packaging waste (e.g. France); (b) introducing a tax on packaging that is hard to recycle (e.g. the United Kingdom); and (c) mandatory reporting of packaging data and packaging reduction plan annually (e.g. Singapore). See CMS Legal (2024), GOV.UK (2025) and Ministry of Sustainability and the Environment (2021).} However, only a few have dedicated measures for curbing those items generated by e-commerce, and Taiwan and South Korea are amongst the few in Asia.^{8Legend symbol denoting Under the Packaging and Packaging Waste Regulation of the European Union (“EU”) (February 2025), EU countries will require all transport and e-commerce packaging to maintain a maximum 50% empty space ratio after product placement, effective January 2030. Since July 2022, Germany has additionally required electronic marketplace operators and fulfilment service providers (e.g. courier and logistics firms) to verify that online sellers are registered with the Central Agency Packaging Register and have paid licence fees to accredited producer responsibility organizations. Service providers must not serve non-compliant sellers. See Official Journal of the European Union (2025) and Zentrale Stelle Verpackungsregister (2024).} As these two places share similar socio-economic characteristics with Hong Kong, this issue of Essentials studies the approaches to regulating e-commerce packaging in Taiwan and South Korea, including their specific packaging requirements and exemption policies, which could have some reference value for Hong Kong.

• Rising concerns about e-commerce packaging waste in Hong Kong: According to the Environmental Protection Department ("EPD"), environmental problems caused by over-packaging have been "a growing concern" in Hong Kong. This is particularly significant in the e-commerce sector, where over-packaging has gained prevalence in recent decade, primarily in the form of (a) unnecessarily large containers/cartons; and (b) multiple layers of packaging and excessive filling materials. In 2021, it was estimated that an average of 2.3 pieces/layers of packaging (e.g. cartons, bubble wrap and foam particles) were used for each product purchased online in Hong Kong.^{9Legend symbol denoting Consumer Council (2013), South China Morning Post (2021) and Environmental Protection Department (2025).}
• During 2021-2022, the advisory body Council for Sustainable Development ("CSD") was commissioned by the Government to gauge public views on the control of single-use plastics, including packaging waste. Based on its survey of over 9 400 respondents under three main groups (i.e. individuals, organizations, and companies), 78% of all agreed that local packaging was being used excessively. Specifically, 73% of the surveyed companies and over half of the surveyed organizations and individuals supported introducing regulations to curb excessive packaging for local products, retail, logistics and online shopping. In view of positive responses in society for packaging regulation, CSD recommended that the Government "should explore using administrative and legislative means" for effective control, with reference to the experiences of other places.^{10Legend symbol denoting Council for Sustainable Development (2022).}
• Voluntary guidelines for most packaging waste: So far, only two types of packaging (i.e. plastic shopping bags and glass beverage containers) have been regulated locally under PRSs since July 2009 and May 2023 respectively. In July 2025, LegCo passed the Promotion of Recycling and Proper Disposal of Products (Miscellaneous Amendments) Bill 2025, widening the packaging types under PRSs to plastic beverage containers and beverage cartons, without a concrete timeframe yet.^{11Legend symbol denoting Environment and Ecology Bureau (2025) and GovHK (2025b). Besides the aforesaid packaging waste, electric vehicle batteries, vehicle tyres and lead-acid batteries are also covered.}
• For the vast majority of other packaging waste, however, EPD only issued voluntary Practical Guides on Packaging Reduction and Management in May 2022 for business operators in several sectors, including logistics and e-commerce, and suggested eco-friendly packaging design for their products. In March 2025, EPD further launched a Packaging Reduction Charter, encouraging businesses to adopt sustainable packaging reduction practices and innovations voluntarily, with some 120 signatories as of September 2025.^{12Legend symbol denoting Environmental Protection Department (undated) and GovHK (2025a).}
• Key issues of concern: While key stakeholders appreciated the existence of PRSs for certain products, some urged the Government to expand the regulatory coverage to wider packaging types, which will be more effective than relying on voluntary guidelines.^{13Legend symbol denoting Subcommittee to Study Policy Issues Relating to Municipal Solid Waste Charging, Recovery and Recycling (2022b, 2023), 大公文匯網(2025) and 環境及生態局(2025).} On the other hand, some commentators expressed concern that cutting down on packaging would be challenging due to logistical, hygiene and merchandise protection reasons. This might also imply additional cost for businesses, and smaller ones might even see a larger impact. Considering also difficulties in enforcement, some suggested that the Government "should strike a balance between environmental protection and the needs of citizens and relevant trades".^{14Legend symbol denoting Panel on Environmental Affairs (2023), Legislative Council Secretariat (2024) and Council for Sustainable Development (2022).}
• In response, the Government acknowledged that packaging varies widely in purpose, format and materials, making unified legislative control challenging and potentially problematic for the trade. Hence, its initial approach is to provide voluntary packaging reduction guidelines for specific sectors and accumulate relevant experiences. Legislative control "might be considered in the future" after drawing on experience from elsewhere and insights from voluntary initiatives.^{15Legend symbol denoting Legislative Council Secretariat (2024) and 環境及生態局(2025).}

• In Taiwan, while a PRS is in place for certain packaging, containers and filling materials (e.g. flat plastic containers and plastic blister), the upsurge in e-commerce packaging has triggered social concern and the Taiwan environmental affairs authorities ("the Taiwan authorities") thus have responded with measures in recent years. Initially, the Taiwan authorities implemented a number of voluntary measures in August 2019. These include (a) issuing the Guidelines for Reducing Online Shopping Packaging (網購包裝減量指引) ("the Guidelines") to the trade with best practice and reduction targets; (b) certifying online shopping platforms for reducing packaging, using eco-friendly packaging materials or recycling packaging waste; and (c) encouraging businesses to join the Online Shopping Packaging Reduction Alliance to formulate industry initiatives.^{16Legend symbol denoting Ministry of Environment (2020, 2023).}
• The voluntary Guidelines have brought about a 23% drop in the average packaging weight per e-commerce product to about 0.25 kg during 2019-2022, but still fell short of the reduction targets set out in the Guidelines (e.g. a maximum packaging-to-product weight ratio of 10% by 2019, and a 10% usage rate of reusable packaging by 2022). As such, lawmakers and environmental groups questioned the effectiveness of the voluntary approach and urged for legally binding regulations.^{17Legend symbol denoting 環境資訊中心(2020), 江建逸(2023) and 環境部資源循環署(2024).}
• In light of the recent global regulatory trend, the booming e-commerce sector, and a projection that the volume of packaging waste will double by 2030, the Taiwan authorities began preparing a dedicated regulatory regime in September 2022, with two public hearings held in late 2022.^{18Legend symbol denoting 工商時報(2022) and 天下雜誌(2023).} In February 2023, the Taiwan authorities introduced the regulation, namely Targets and Measures for Restrictions on Internet Shopping Packaging (網際網路購物包裝限制使用對象及實施方式) ("the Restrictions") to strengthen the management of e-commerce packaging, effective from July 2023.^{19Legend symbol denoting In May 2023, the Taiwan authorities also launched the Guidelines 2.0 to encourage businesses to achieve additional goals such as providing option of shipping with original box and disclosing packaging carbon footprints. See 環境部新聞專區(2023), 資源回收管理資訊系統(2023) and Ministry of Environment (2023).} Here are its salient features:
  • (a)
    Mandatory use of recycled materials for internet retailers: To reduce packaging waste and enhance its recyclability, online sellers are obliged to (i) ensure cardboard boxes are made from at least 90% recycled paper; (ii) ensure plastic packaging contains at least 25% recycled materials; and (iii) refrain from using packaging materials with polyvinyl chloride, which is considered harmful to the environment and health and hard to recycle;
  • (b)
    Covered businesses: These regulations apply to all online retailers and platforms providing product information via websites and/or mobile applications where consumers can place orders directly.^{20Legend symbol denoting 環境部主管法規查詢系統(2023).} The Restrictions also apply to non-local e-commerce companies that provide websites or platforms for order placement by consumers in Taiwan and deliver the packaged goods to Taiwan.^{21Legend symbol denoting 環境部資源循環署(2025a).} Offenders may be subject to a fine of up to NT$150,000 (HK$39,750);
  • (c)
    Extra packaging requirements for larger businesses: Additional rules are imposed on larger firms considering their bigger role in social responsibility and better resources. For medium-sized firms with a capital of at least NT$50 million (HK$13.3 million) or 300 delivery pickup points, they must also comply with the packaging weight ratio caps, which vary between 15% and 40% of the total weight of the packaging and the goods to be shipped (i.e. heavier goods are subject to a lower packaging weight ratio cap and vice versa).^{22Legend symbol denoting 環境部主管法規查詢系統(2023).}

    For large-sized businesses with a capital of NT$150 million (HK$40 million) or 500 delivery pickup points, they must further adhere to the annual targets of packaging reduction or the usage rates of reusable packaging for the period of 2024-2026 set out by the Taiwan authorities, as well as fulfil their data reporting duties certified by accredited auditors.^{23Legend symbol denoting Large businesses are required to reduce the average weight of packaging by 25% by 2024, 30% by 2025 and 35% by 2026, as compared to the baseline in 2019. Or else, they can meet the target usage rates of reusable packaging at 2% of all parcels packaged and delivered by 2024, 8.5% by 2025 and 15% by 2026. See GPC (2023) and 環境部主管法規查詢系統(2023).} Those who fail to meet these targets are required to submit an improvement plan to the Taiwan authorities, and report the outcomes six months after implementing the plan;
  • (d)
    Exemptions on packaging/transactions: Certain packaging types or transactions are exempt, including (i) online transactions between individuals; and (ii) products shipped in their original boxes or reusable bags/boxes, or weighing less than 250 grams; and
  • (e)
    One-year transition to full enforcement: To encourage self-management of packaging reduction amongst businesses, a one-year transition period was granted. During the first year of implementing the Restrictions (i.e. July 2023-June 2024), efforts were focused on promotional campaigns, site visits and verifying if businesses had established "self-management" plans rather than outright enforcement. In fact, six months after the Restrictions became effective, Taiwan had already registered a 12% year-on-year decline in average weight of e-commerce packaging to 0.22 kg, although inspections at the time were conducted just on a limited basis and had not been operationalized.^{24Legend symbol denoting 台北市政府(2023) and 環境部資源循環署(2025b).}

• In South Korea, the use of packaging materials is governed by scattered regulations and guidelines.^{25Legend symbol denoting Major regulations include (a) the Act on the Promotion of Saving and Recycling of Resources; (b) the Rules on the Standards for the Materials and Methods of Packaging Products; and (c) the Guidelines for Reducing Logistics Packaging Materials and Parcel Delivery of Frozen Foods. See Yi (2019) and Korea Law Translation Centre (2023).} A range of packaging types (e.g. metal cans, glass bottles, drinks cartons and cosmetics packaging) had been under regulation since 2003, but packaging intended for delivery to consumers were unregulated. Amidst rise of e-commerce during the pandemic (annual usage of parcel deliveries per capita soared by 56% to 70 orders during 2017-2021), there were rising calls for reviewing the regulatory framework.^{26Legend symbol denoting Apart from delivery packaging, the Rules on the Standards for the Materials and Methods of Packaging Products also imposed caps on the empty space ratios and layers of packaging of other products, such as a 15% empty space ratio and two layers for processed food packaging, and a 35% empty space ratio for packaging of electronic products. See Yi (2019), 세계일보(2024), Korean Law Information Center (2020) and PREVENT Waste Alliance (2023).}
• In response, the Ministry of Environment ("MOE") amended the Rules on the Standards for the Materials and Methods of Packaging Products ("the Rules") in April 2022 to regulate packaging for product delivery to consumers (i.e. delivery packaging), with effect from April 2024.^{27Legend symbol denoting NEWSIS (2022) and Enviliance Asia (2024).} Here are the key measures:
  • (a)
    Mandatory caps on empty space and layers of delivery packaging: The Rules stipulate (i) an empty space ratio for delivery packaging of no more than 50% of the whole parcel filled with goods, with filling materials also counted as empty space; and (ii) a limit of only one layer of disposable wrapping for a delivery package;^{28Legend symbol denoting The Korea Times (2024) and KBS (2024).}
  • (b)
    Covered businesses: Local distributors and e-commerce platforms, totalling about 1.32 million businesses, must comply with the Rules. Offenders are liable to a fine of up to 3 million won (HK$16,800). To alleviate the compliance burden for smaller enterprises, MOE excludes firms with annual sales of less than 50 billion won (HK$280 million) from the Rules, given that they generate less than 10% of all delivery packages in South Korea. Unlike in Taiwan, overseas e-commerce platforms serving orders from South Korea are not regulated the Rules;^{29Legend symbol denoting Business Post (2024).}
  • (c)
    Exemptions on packaging/transactions: Certain packaging types or transactions are exempt, including (i) small parcels (e.g. accessories) with the sum of length, width and height not exceeding 50 cm; (ii) reusable packaging; (iii) gift packaging requested by customers; and (iv) online transactions among individuals; and
  • (d)
    Two-year grace period: When the framework was first unveiled, stakeholders (e.g. importers, retailers and logistics firms) expressed concerns over the potential logistics and personnel difficulties in making systematic improvements, and called for more detailed guidelines and extra time to prepare, such as diversifying the types of delivery packaging material. Hence, MOE provided a two-year grace period from March 2024 to guide relevant parties towards compliance without penalties being imposed, while soliciting more insights from key stakeholders and assisting companies in developing improvement plans concurrently for a smoother transition.^{30Legend symbol denoting The Korea Times (2024), The Granite Tower (2024) and Korea Waste Association (2024).}

• Both Taiwan and South Korea are amongst the Asian pioneers to implement dedicated regulations on e-commerce packaging beyond voluntary measures in recent years, laying down specific requirements such as caps on packaging weight, empty space ratios and wrapping layers. To alleviate the compliance burden, exemptions are granted for small firms and/or small packages, along with a grace period for the trade to adapt to the regulations. Initial results for Taiwan appeared positive in terms of packaging weight reduction, while those for South Korea remain to be seen as full implementation is scheduled for 2026.