Anyone drafting a business plan around used batteries in Korea runs into a problem that has less to do with a lack of information than with where that information sits. Where can the batteries be sourced, what application can that supply support, which certification track that application requires, what equipment and traceability the track demands, and what registration and insurance a business needs to operate — none of this lives in a single procedure. It is split across several laws under different ministries. This blog has already covered three of those pieces separately: which applications second-life batteries actually fit, what KC 62619 certification covers, and how the KC 10031 safety inspection works. This piece strings those three together in the order a business review actually has to follow, where the answer at each step decides the fork in the next one.
1. Supply: where, and in what condition
There is no official answer to this yet. The Act on Management and Industry Promotion of Used Batteries was promulgated on May 26, 2026, and will take effect on May 27, 2027. It sorts battery-related businesses into four registered categories — distribution, remanufacturing, reuse, and recycling — each required to register with the Ministry of Trade, Industry and Energy. That means a formal “distributor” channel does not exist as a matter of law until May 2027. Until then, the realistic route is direct arrangements with automakers’ service and recall networks, licensed vehicle dismantlers under the Motor Vehicle Management Act, and rental or insurance companies.
What matters most at this stage is the physical condition of the supply. Whether the batteries have been flooded, burned, deformed, or damaged — and whether cell damage carries a risk of hazardous leakage, fire, or explosion — determines later whether a waste-handling permit is required at all. That should be confirmed with the supplier early, not discovered after the plan is built. On how reliably volume itself accumulates, our earlier piece on second-life applications already noted a wide gap between government projections and actual disposal volumes, which is worth weighing here too.
2. Application: where the batteries you secured can go
Battery condition feeds directly into performance evaluation. The pre-removal evaluation system the government is preparing grades batteries on remaining performance, safety, and history, and the design being discussed routes top-grade batteries back to their original use (remanufacturing), mid-grade batteries to other applications such as ESS (reuse), and bottom-grade batteries to material recovery (recycling). The specific scope of products subject to this evaluation, however, is still delegated to a presidential decree and not yet finalized.
Within the batteries headed for reuse, which specific application fits is narrowed by the three questions laid out in our second-life criteria piece: does the use case demand sudden high power, does it run in a fixed environment where monitoring is possible, and can the pack or module be reused as-is. The answer decides which certification track the business enters next.
3. Certification: the track your application determines
If the application is remanufacturing — returning the battery to its original use — neither KC 62619 nor KC 10031 applies, since both exclude batteries reused in a vehicle’s drive system from their scope. This path runs through a separate track altogether: the Motor Vehicle Management Act, not the electrical-appliance line. A February 27, 2026 amendment to that act (Act No. 21412) newly defined “used battery” and “remanufactured battery,” introduced a performance-evaluation system the Minister of Land, Infrastructure and Transport carries out before a battery is removed, and imposed a parts-manufacturer registration requirement on anyone making or assembling remanufactured batteries, along with a pre-distribution safety inspection for any EV fitted with one. It takes effect July 1, 2027. The specific registration and inspection requirements are something this blog has not yet confirmed and written up, and will be covered separately.
If the application is reuse — converting the battery to a different use such as ESS — the path runs through KC 10031, the safety inspection system built specifically for this case rather than KC 62619, which our earlier pieces explained was designed around new industrial cells.
If the application is recycling — disassembling the battery to recover metals — it sits outside this certification framework entirely. It falls under a waste-treatment (recycling) business permit governed by the Wastes Control Act, and depending on the process, may still lack a settled legal standard, in which case a regulatory sandbox approval is required first.
4. Inside the track: equipment, inspection, traceability
Entering the reuse track (KC 10031) brings two kinds of requirements. Reused battery modules undergo a 100%-inspection — three pre-inspection items and five electrical-test items — on every single unit, while reused battery systems undergo functional safety testing, drawn from KC 62619 Section 8, on a per-model basis. This inspection is carried out by agencies designated by the Korean Agency for Technology and Standards, and the list of designated agencies keeps growing, so the current roster is worth checking through KATS’s own notices rather than repeating here. Most reuse businesses need equipment for disassembly, reconfiguration, and storage rather than test equipment of their own. The pre-inspection stage includes serial-number assignment and record-keeping, so a traceability system for individual battery history needs to be in place at this stage as well; the inspection items and procedure are detailed in our KC 10031 piece. A business that wants to become a designated inspection agency itself rather than outsourcing this — PMGROW, a manufacturer, is one existing example of a company doing both — takes on one more requirement, covered in the next section.
5. Entry requirements: registration, liability coverage, waste permits
Business registration is the baseline. Applying for a KC 10031 inspection already requires submitting a business registration certificate. On top of that, from May 27, 2027 the new law will require reuse businesses to register separately with the Ministry of Trade, Industry and Energy, though the facility and personnel standards for that registration are still delegated to presidential decree and not yet set. The law does provide, as enacted text, that operating unregistered or trading with an unregistered business carries criminal liability.
Liability insurance splits into two separate obligations. Inspection agencies themselves are liable under Article 34-9 of the Electrical and Living Appliance Safety Control Act for damages caused by a negligently conducted inspection, and their liability insurance coverage is checked as part of their designation review. That requirement does not fall on most reuse businesses, which simply outsource inspection — it only applies to a company that becomes an inspection agency itself. Separately, the new used-battery law requires reuse businesses themselves to carry indemnity insurance or join a mutual-aid fund to cover consumer damages, though that obligation also only takes effect once the law itself does, on May 27, 2027.
Whether a waste-handling permit is needed loops back to the battery condition confirmed in step one. Under the Framework Act on Resource Circulation, the Ministry of Environment has designated end-of-life EV batteries among the items recognized as “circular resources.” A battery free of flooding, fire, deformation, or damage, with no risk of hazardous leakage, fire, or explosion from cell damage, that is reused — in its original use or another — within the designated conditions and methods is not treated as waste, and no waste-treatment permit is required. A battery outside that scope, or one intended for recycling into raw materials from the start, falls under the waste-treatment business permit required by Article 25 of the Wastes Control Act.
ARC’s observation
The reason this whole picture is hard to see at once seems to be that each step comes from a different ministry’s law. Supply and waste status sit under the Ministry of Environment’s Framework Act on Resource Circulation; certification sits under the electrical appliance safety standards the Korean Agency for Technology and Standards issues; business registration and industry promotion sit under the new law from the Ministry of Trade, Industry and Energy. That new law has been promulgated, but the details that will actually shape day-to-day operations — registration standards, the scope of the performance evaluation — are still left to subordinate legislation. Watching how those get filled in before the law takes effect looks like it will remain part of any serious business review.
Reference: [ZDNet Korea] “‘Used Battery Act’ Passes Cabinet Meeting… ‘Managed as a National Strategic Resource’” (https://zdnet.co.kr/view/?no=20260520090026)
Reference: [Jipyong LLC] “[Climate Energy Center] Key Contents and Implications of the ‘Act on Management and Industry Promotion of Used Batteries’ Bill” (https://www.jipyong.com/kr/board/news_view.php?seq=15114)
Reference: [Korea Law Information Center] Motor Vehicle Management Act amendment reasons (Act No. 21412, promulgated Feb. 27, 2026, effective Jul. 1, 2027 — new definitions for used/remanufactured batteries, performance-evaluation system, parts-manufacturer registration, pre-distribution safety inspection) (https://law.go.kr/LSW/lsRvsRsnListP.do?lsId=001747&chrClsCd=010102&lsRvsGubun=all)
Reference: [Innopolis Foundation] “Battery Recycling Regulatory Checklist” (Aug. 2025) (https://www.innopolis.or.kr/fileDownload?titleId=182135&fileId=1&fileDownType=C¶mMenuId=MENU00403)
Reference: [Shin & Kim] “Seven Items Including EV Waste Batteries Designated as ‘Circular Resources,’ Exempted from Waste Regulation” (https://www.shinkim.com/kor/media/newsletter/2262)
Reference: [Korea Law Information Center] Administrative Rule, “Guide to Designation and Review of Certification Bodies under the Electrical and Living Appliance Safety Control Act” (re: Article 34-9 liability) (https://lbox.kr/v2/statute-admin/%EC%A0%84%EA%B8%B0%EC%9A%A9%ED%92%88%EB%B0%8F%EC%83%9D%ED%99%9C%EC%9A%A9%ED%92%88%EC%95%88%EC%A0%84%EA%B4%80%EB%A6%AC%EB%B2%95%EC%97%90%EC%9D%98%ED%95%9C%EC%95%88%EC%A0%84%EC%9D%B8%EC%A6%9D%EA%B8%B0%EA%B4%80%EB%93%B1%EC%A7%80%EC%A0%95%EB%B0%8F%EC%8B%AC%EC%82%AC%EA%B0%80%EC%9D%B4%EB%93%9C)