[Feature] Korean Agri-Food in the European Market ② From PPWR to Pesticide Residues, Paperwork Determines Sales Channels

〈Editor’s Note〉
The Korea Agricultural Technology News, together with Kim Ki-chul, head of the Jeonnam-Gwangju Integrated Special City Europe Office and an overseas contributor who has supported Korean companies’ entry into Europe from the Frankfurt, Germany region since 2012, examines the current state of Korean agri-food in the European market in two installments. The first story covered item-by-item gaps revealed in export statistics and the issue of repeat orders. The second story addresses EU regulatory barriers that became full-fledged in 2026 and practical response measures. Following the two-part feature, a written interview with Director Kim is included.

 

On August 12, the EU Packaging and Packaging Waste Regulation (PPWR) entered into general application. The EU Deforestation Regulation (EUDR) will apply from December 30 to medium and large operators and to micro and small enterprises that were already subject to the existing EU Timber Regulation, while the Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase from January 2026. The thresholds Korean agri-food must cross to reach European shelves are rising all at once.

The burden is greatest for products that must block oxygen and moisture. Laver, kimchi, and sauces (gochujang, soy sauce, doenjang) often use multilayer films or aluminum pouches because taste, color, aroma, and shelf life depend on barrier performance. According to the Korea Agro-Fisheries & Food Trade Corporation (aT) Agri-Food Export Information (KATI), exports of processed laver, kimchi, and sauces to the EU (including the United Kingdom) in the first half of 2026 amounted to $55.52 million, accounting for 8.3% of total agri-food exports to the EU. For the full year of 2025, the figure was $107.10 million.

Packaging regulations do not immediately block these products. However, because recyclability obligations are structured to strengthen in stages, market access after 2030 will depend on what is prepared now.

In a written interview with the Korea Agricultural Technology News, Kim Ki-chul, head of the Jeonnam-Gwangju Integrated Special City Europe Office, said, “The application of PPWR does not mean that multilayer films or aluminum pouches must immediately be replaced across the board,” adding, “The regulation has been under general application since August 12, but obligations related to recyclability will be strengthened in stages.”

PPWR recyclability: detailed criteria by January 2028; in principle, A, B, and C grades mandatory in 2030

According to Director Kim’s explanation, the timetable is as follows. The EU Commission will establish detailed design-for-recycling criteria by January 1, 2028, and, in principle, from 2030 only packaging that meets recyclability A, B, or C grades may be placed on the market. From 2035, whether large-scale recycling is actually taking place will also be assessed, and from 2038, even C-grade packaging will be restricted from being placed on the market. However, the application dates in 2030 and 2035 may be delayed depending on when the relevant delegated acts and implementing acts enter into force.

What, then, should be done now? Director Kim said diagnosis should come before replacing packaging materials. He said, “Companies need to accurately identify each package’s layer structure, materials, weight, inks, adhesives, and product-protection functions,” adding, “A multilayer structure itself is not immediately banned, but if different materials cannot be easily separated or if adhesives and coatings interfere with the recycling process, it may receive a low evaluation.”

He also suggested an order of action. First reduce unnecessary packaging and excessive area and weight, then test whether it is possible to switch, within the range where barrier performance can be maintained, to mono-material polyethylene (PE) or polypropylene (PP) series packaging or to recycling-friendly high-barrier structures.

He also warned of the adverse effect of losing quality by pursuing recyclability alone. Director Kim said, “For kimchi, sauces, and dried seaweed products, oxygen and moisture barrier performance determines taste, color, aroma, and shelf life, so changing packaging based only on recyclability can create a bigger problem: food deterioration or increased waste,” adding, “Before and after changing packaging, companies must verify oxygen and moisture transmission rates, sealing strength, food-contact suitability, transport stability, and actual shelf life together.” His advice is that, rather than changing all products at once, it is realistic to test alternative materials first on representative products, confirm the results, and then expand. 

Carrefour and Lidl applied their own packaging standards even before the law took effect

The change felt on the ground came before the law took effect. This is because major European retailers have been applying their own packaging standards to suppliers.

According to Director Kim, Carrefour has pursued reduced overpackaging and expanded refill and reuse, setting a goal of cutting 15,000 tons of virgin plastic from its private-label single-use packaging by 2030. The Schwarz Group, which operates Lidl and Kaufland, also said that as of fiscal year 2025 it had reduced plastic use in private-label primary packaging and plastic transport aids by 36% compared with 2017, and raised the average recycled-content share of private-label plastic primary packaging to 26%.

As a result, Director Kim diagnoses that consultation outcomes differ depending on the level of preparation. He said, “The real difference now is not whether a company has an eco-friendly image, but whether buyer consultations lead directly to orders or come back as packaging-improvement tasks,” adding, “Sustainable packaging has now become not an optional promotional element for companies, but a purchasing standard for retailers.”

Companies that prepared in advance can immediately present alternative specifications, quotations, and samples when buyers ask about removing unnecessary packaging, switching to mono-materials, or the recycled-content ratio. Reducing the amount of packaging materials used can help lower raw-material costs, transportation costs, and burden-sharing payments under extended producer responsibility (EPR) schemes. However, actual costs vary depending on packaging structure, each country’s fee system, and the costs of material conversion and testing. Citing Carrefour’s announcement that it would reduce packaging plastic for hygiene and detergent products by 30% through refill formats and lower prices for refill products by 10–20%, Director Kim said, “This shows that sustainable packaging is directly linked to cost and price competitiveness as well.”

Conversely, if preparation is delayed, consultations may be delayed or halted. Director Kim said, “Even if the quality of the product itself is good, companies that are late in preparing may see consultations stopped because of packaging,” adding, “To change a composite-material pouch for laver snacks, a company must go through everything again, from selecting a packaging company to testing shelf life, food-contact suitability, and transport stability, as well as revising the design and label.” Inventory of already produced packaging materials is also a burden. In the meantime, a buyer may postpone listing the product or choose a supplier that can respond more quickly. 

Caps, labels, and adhesives are also subject to substantiation… packaging is not a single component

There is a separate point that companies most often miss in practice. It is the habit of treating finished-product packaging as if it were a single component.

Director Kim said, “Not only containers or pouches but also caps, labels, sealing films, printed layers, adhesives, coatings, zippers, desiccants, tape, and transport boxes can each be subject to verification,” adding, “Even when test reports exist, there are many cases where companies cannot connect the packaging actually delivered with the product used as the test sample.”

Printing inks, adhesives, and coatings are particularly difficult. Even finished-product manufacturers often do not know the exact ingredients, and suppliers may be reluctant to provide data on the grounds of trade secrets. Director Kim said, “Companies should not rely on assumptions, but should secure documents by tracing the packaging-material supply chain,” and presented as a request list the packaging composition table, technical data and safety data sheets (TDS/SDS), food-contact compliance declarations, ink, adhesive, and coating confirmation letters, test reports, and change-management information.

There are also workarounds when full formulation disclosure is difficult. The supplier can directly declare regulatory compliance, or submit the relevant information confidentially to a testing body. Director Kim said, “By first reviewing the materials secured in this way and then selecting only unverified risk items for additional testing, we are reducing unnecessary testing costs and time.”

The first local-government PPWR Response Support Center linked to a European local office supports each packaging case through to an actual transaction

In line with the general application of PPWR, the Jeonnam-Gwangju Integrated Special City Europe Office is supporting companies through the “Jeonnam-Gwangju EU PPWR Response Support Center.” Jeonnam-Gwangju introduces this as the first PPWR response support system linked to a European local office by a local government. As of August 2026, the main support targets are 44 companies that have entered Amazon Europe and 64 companies listed in permanent sales outlets in Germany and elsewhere.

The center handles everything from guidance on applicable regulations to diagnosis of document lists, review of substantiation, requests to supplement missing materials, drafting technical documentation (TD) and declarations of conformity (DoC), and responding to buyers’ requests for supplementation. However, the boundaries are clear. Director Kim said, “The legal responsibility for ultimately ensuring packaging compliance, managing the TD, and signing and issuing the DoC lies with the manufacturer,” adding, “The office’s support documents are required to undergo the company’s factual confirmation and final approval.”

The time required depends on the completeness of the documents. For simple packaging where product specifications, packaging composition and weight, supplier substantiation, test reports, and importer information are all in place, the practical goal is to prepare a first draft within one to two weeks after receipt. Conversely, if ink and adhesive data must be newly obtained, testing is required, and there are multiple items, it takes several weeks or more.

Regarding the division of roles with central agencies, Director Kim said it is not substitution but connection. He said, “Central support agencies have strengths in broad institutional guidance and professional infrastructure, while local offices have strengths in closely supporting a specific product and a single packaging case of an individual company until it leads to an actual transaction,” adding, “When a local importer requests supplementation, reducing language and time-zone barriers, and tracing even the documents of domestic companies and packaging-material suppliers to carry the resolution process through to the end is a role only a local office can play.”

As of September 15, a little over a month after implementation, no cases of official supplementation requests from buyers, product rejections, or sales suspensions due to PPWR had been confirmed among companies supported by the center. Director Kim explained, “Because not much time has passed since general application began, it is difficult to conclude that buyer requirements have changed clearly,” and said current support is focused on preventive preparation rather than after-the-fact responses.

Director Kim identifies pesticide residues, packaging documents, EUDR, and CBAM as the main regulations over the next two to three years

As the regulations that will have the greatest impact on Korean agri-food exports over the next two to three years, Director Kim listed, in order, △pesticide residues and food-safety standards △packaging and document obligations, including PPWR △EUDR △CBAM.

The reason he placed maximum residue limits (MRLs) for pesticides first is the way their impact spreads. Director Kim said, “Even if just one specific substance exceeds the limit, the relevant lot is directly affected, and EU standards change frequently by item and substance.” PPWR has a broad impact on almost all packaged products, but obligations are strengthened in stages, while EUDR covers cattle, cocoa, coffee, palm oil, rubber, soybeans, timber, and annex-listed products derived from them. Whether it applies in a specific case must be checked by product code. CBAM directly covers steel, aluminum, cement, fertilizers, electricity, and hydrogen, so its impact is greater on fertilizers, materials, and some agricultural inputs than on general foods.

For agricultural-input and agricultural-machinery companies, the ranking changes. Director Kim said, “If fertilizers or steel and aluminum materials fall under directly covered codes, CBAM response comes first, and for smart machinery, CE conformity, machinery safety, cybersecurity, and data obligations may be more direct.”

He also pointed out recurring mistakes at the customs-clearance and quarantine stages. These include checking differences between the EU’s and Korea’s product classifications and ingredient standards only after shipment, using old test reports instead of the latest MRLs, omitting ingredient names, allergens, nutrition labeling, and local-language labeling, and failing to determine in advance with the importer the EU Combined Nomenclature (CN) code and responsible party. Director Kim said, “Even if companies think the product is the same, changes in manufacturing date, supplier, or packaging specifications can break the evidentiary link,” adding, “A product-by-product regulatory checklist before shipment and document version control are the most basic preventive measures.” 

Buyer document requirements: connecting lots and supply chains matters more than the number of certifications

The nature of the documents buyers require has also changed. Director Kim said, “A few years ago, consultations often proceeded with a single certificate and a basic test report, but now buyers require a bundle of evidence linking the product and the supply chain.” In addition to statutory labeling and food-safety documents, buyers’ internal standards overlap with organic certification, GLOBALG.A.P., food-safety certifications recognized by the Global Food Safety Initiative (GFSI), carbon footprint and ESG (environmental, social, and governance), and packaging-material data.

His diagnosis is that the key is not the number of certifications. Director Kim said, “What has become important is whether the relevant certification is connected to the actual lot, production site, and packaging, and whether renewals and changes are managed.”

He also suggested pathways for small farms and farming corporations that find it difficult to bear the costs. These include group certification and joint quality management through producer organizations, agricultural cooperatives, and export organizations, step-by-step certification centered on one or two items for which buyers have been confirmed, and use of public testing and consulting support and shared document managers. Director Kim said, “Rather than increasing certifications before marketability has been confirmed, companies should first decide on target countries, buyers, and products, and invest by distinguishing between legally mandatory requirements and transaction-essential requirements.”

As examined in Part ①, Korea’s agri-food exports to the EU and the United Kingdom reached $961.30 million in 2025, approaching $1 billion. However, the growth of prepared laver products such as seasoned laver remained in the single digits for the second consecutive year, and kimchi exports also appeared stagnant. This trend cannot be explained solely by regulatory responses or repeat-order issues. However, to turn an initial export into steady transactions, companies must be able to provide the materials buyers request on time, in addition to offering product taste and quality. Checking packaging information together with suppliers and preparing materials that prove regulatory compliance are becoming basic conditions for protecting and expanding sales channels in Europe. 

〈Profile of Director Kim Ki-chul〉

Director Kim Ki-chul earned a master’s degree in environmental engineering in Korea and then moved to Germany in 2001, where he obtained a Ph.D. in business administration from Leuphana University of Lüneburg for research on sustainable management. After returning to Korea, he provided sustainable-management consulting at the Korea Chamber of Commerce and Industry’s Institute for Sustainable Management and at Samjong KPMG, then moved back to Germany and handled technology commercialization and international cooperation at the Technology Management Team of the Korea Institute of Science and Technology (KIST) Europe Research Institute and at the Korea-EU Research and Business Cooperation Center. He has served as director since the establishment of the Jeollanam-do Europe Office in May 2012 (opened in June), and has led the Integrated Special City Europe Office since the launch of Jeonnam-Gwangju Integrated Special City in July 2026. As an overseas contributor to the Korea Agricultural Technology News, he serially publishes columns on European agtech and agri-food market trends.
 

※ This feature was prepared together with Director Kim Ki-chul, an overseas contributor to the Korea Agricultural Technology News. Director Kim’s remarks were quoted from a written interview for which the Korea Agricultural Technology News sent a questionnaire on August 26, 2026 and received responses during September.