Selling to the EU from South Korea

For most goods, yes. The EU–Korea Free Trade Agreement has been fully in force since 13 December 2015. As always the preference depends on meeting the origin rule for your product and on holding valid proof; the agreement lowers the rate, it does not remove the paperwork.

No: the FTA is a trade agreement that removes or reduces customs duties on qualifying goods. GPSR, CE marking, REACH and the Responsible Person apply on top, exactly as to goods from countries without any FTA. The tariff is a discount, not a regime.

Cosmetics have their own regime; Regulation (EC) 1223/2009; with a Responsible Person duty built in (Article 4), CPNP notification before placing on the market, a Product Information File, and labelling including the EU Responsible Person's name and address. GPSR sits on top as the general safety net.

The cosmetics regulation (1223/2009) has its own Responsible Person concept; it must be established in the EU and named on the label. GPSR adds the general-safety Responsible Person. For cosmetics, one EU entity can often carry both roles, but the duties and paperwork are distinct.

€200–800 per year per catalogue for general consumer products. Cosmetics RP services tend higher (€500–1,500/year) because they carry CPNP notification and PIF maintenance. Ask for the scope in writing: per company, per brand, or per product line.

The obligation sits with the authorised CBAM declarant, not with you, but the data has to come from you. That declarant is the importer established in a member state; where the importer is established outside the EU it is his indirect customs representative. The definitive regime applies from 1 January 2026.

Threshold. He is exempt for as long as the net mass he imports in a calendar year, added up over iron and steel, aluminium, cement and fertilisers, does not pass 50 tonnes (Article 2a, with the figure in Annex VII, point 1). Once he passes it in a calendar year, the obligations apply to the embedded emissions of that whole year. The threshold counts per importer, not per shipment and not per supplier. It does not apply to hydrogen or to electricity (Article 2a(4)): for those he is in scope from the first consignment, however small.

Authorisation. The goods may only be released for free circulation by an authorised CBAM declarant, or by his indirect customs representative (Article 4; application under Article 5). Transitional rule: where the application is submitted by 31 March 2026, he may keep importing during 2026 for as long as the competent authority has not decided. If it is refused afterwards, a penalty follows on the emissions imported in the meantime.

Certificates. There are no CBAM certificates on sale in 2026. Sales start on 1 February 2027 (Article 20(1)). For import year 2026 the CBAM declaration is filed and the certificates are surrendered by 30 September 2027 (Article 22). The cost counts in his margin from 2026, but the cash leaves in 2027.

What he will ask you for. Which goods are in scope is decided by the CN code in Annex I: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. For those he chooses how the embedded emissions are determined: from the actual emissions of the installation, or from default values (Article 7(2)). He is not required to ask you first, and not required to show that actual data cannot be obtained. It is a cost calculation, not a penalty. Default values are set at the average emission intensity of the exporting country, raised by a mark-up fixed in implementing acts; where reliable data for the exporting country is missing, the average emission intensity of the ten exporting countries with the highest emission intensity is used instead. Against that, only actual emissions have to be checked by an accredited verifier (Article 8(1)), so working from default values saves him that verification. Your figures are worth buying when your installation is cleaner than the country average plus mark-up by more than the verification costs; for an installation dirtier than that average, the default value can be the better deal for him.

Regulation (EU) 2023/1542 replaced the old batteries directive and treats the battery as a product in its own right, whether it is sold loose or built into something. Chapter VIII, which carries the registration, has applied since 18 August 2025 (Article 96(2)(c)).

Read the word 'producer' carefully, because it is not the maker. It is whoever first makes the battery available on a member state's market on a professional basis. For cells and packs shipped from Korea that is normally your EU importer: he is established in a member state and supplies them there for the first time (Article 3(47)(c)). He may only make them available on that market once he is entered in that member state's producer register, and that covers batteries already built into an appliance, a light means of transport or another vehicle (Article 55(2)). Registration is required in each member state where he himself first makes batteries available, not in every member state the goods eventually reach; the next party to supply them there for the first time becomes the producer in that state. The filing may be made on his behalf by a producer responsibility organisation (Article 55(6)) or by an authorised representative for extended producer responsibility (Article 55(7)), and the competent authority has up to 12 weeks once the file is complete (Article 55(9)(b)), so it is not something to start when the container lands.

Registration is not the same as the duties it triggers. Take-back and collection are not in Article 55: extended producer responsibility, meaning the financing of separate collection, transport, treatment and recycling, is in Article 56, and the collection duties themselves are in Article 59 for portable batteries, Article 60 for light means of transport batteries and Article 61 for SLI, industrial and electric vehicle batteries. If you sell direct to end users in a member state by distance contract, you are the producer there yourself and must appoint an authorised representative in every member state you sell to (Article 56(3)). From 18 February 2027 every electric-vehicle battery, industrial battery above 2 kWh and light means of transport battery placed on the market needs a battery passport reachable from a QR code on the battery. Neither duty is satisfied by CE marking, and neither is EU-wide: the register is national.

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