Amber cosmetic bottles with blank labels — Ingredient and labelling review for imported cosmetics
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Ingredient and labelling review for imported cosmetics

Before imported cosmetics enter Korea, the full ingredient list should be checked against the lists of ingredients that cannot be used and ingredients with use limits, and the Korean-language packaging must carry the required particulars in the required manner. The cosmetics responsible seller (화장품책임판매업자) reports the ingredient list before distribution and sale and prepares and keeps an import management record.

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Short answer

An ingredient and labelling review for imported cosmetics (수입화장품 성분·표시 검토) compares the full ingredient list with the lists of ingredients that cannot be used and ingredients with use limits before import, and checks that the Korean-language packaging meets the required particulars and labelling method. The cosmetics responsible seller (화장품책임판매업자) must report the ingredient list to the Ministry of Food and Drug Safety (MFDS, 식품의약품안전처) before distribution and sale (this may be omitted when importing with a standard customs clearance pre-report filed as an electronic trade document) and prepare and keep an import management record. YouSun Administrative Agency supports document review of ingredient lists and label drafts and prepares filings such as the ingredient list report.

Who typically engages us

  • Cosmetics responsible sellers bringing overseas cosmetics brands into Korea
  • Foreign cosmetics companies that have set up a Korean entity to import their own products
  • Importers and distributors finalising Korean labels and full ingredient lists before shipment
  • Businesses also importing small-volume products, samples or gift sets

Ingredient and labelling review for imported cosmetics at a glance

Who needs it
Cosmetics responsible sellers importing cosmetics manufactured abroad for distribution and sale in Korea
Requirements
No ingredients that cannot be used; preservatives, UV filters, hair dye ingredients and similar within use limits; Korean particulars and full ingredient listing (5 points or more, descending order of content); fragrance allergen and precaution labelling; ingredient list report; import management record prepared and kept
Process
Obtain formula and full ingredient data → check against prohibited and restricted ingredient lists → review Korean label draft and precautions → check advertising wording → ingredient list report or standard customs clearance pre-report as an electronic trade document → prepare and keep the import management record
Documents
Ingredient specification and content data, certificate of manufacture and sale, sample product description in Korean, packaging label draft, copy of the functional cosmetics review result notice (if applicable), substantiation data for labelling and advertising (if applicable)
Timeline
Ingredient list reported before distribution and sale; substantiation data submitted within 15 days of the request; the result of an application to designate or change an ingredient use standard is notified within 180 days of submission / the label review itself depends on how quickly formula data are received and whether supplementation is needed

Common situations

Pick the question closest to your case: each one gives the conclusion first, then what changes it, the documents involved and the expected timeline.

  1. Our overseas product contains phenoxyethanol and parabens. How do we check whether it exceeds Korea's limits?

    Short answer Compare the manufacturer's ingredient content data with the list of ingredients requiring use restrictions. Phenoxyethanol is limited to 1.0%, and parabens (excluding phenylparaben) to 0.4% as a single ingredient and 0.8% in mixtures (as acid); preservatives not on the list cannot be used.

    • All preservatives are within the limits Move on to reviewing the full ingredient label draft.
    • A limit is exceeded or a preservative is not on the list Adjust the formula for Korea or consider applying to designate or change an ingredient use standard.
    Documents
    Ingredient specification and content data, manufacturer's full ingredient list
    Timeline
    Complete the check before import / in practice, allow time for the manufacturer to send content data
  2. What happens if the cosmetics we want to import contain an ingredient prohibited in Korea?

    Short answer Cosmetics using an ingredient that cannot be used may not be sold or imported, stored or displayed for sale, and violations are subject to imprisonment of up to 3 years or a fine of up to KRW 30 million. Lead and its compounds, mercury and its compounds, hydroquinone and antibiotics are among the listed ingredients.

    • The ingredient can be removed from the formula Switch to a formula for the Korean market and check the full ingredient list again.
    • The ingredient is essential Consider an application to lift or change the prohibition, and do not import until the result is notified.
    Documents
    Ingredient specification and content data, manufacturer's full ingredient list, and for an application to lift or change a prohibition, data on the ingredient's origin, characteristics and safety
    Timeline
    The result of an application to lift or change a prohibition is notified within 180 days of submission
  3. How can we import a product containing a preservative that has no use standard in Korea's notice?

    Short answer Preservatives, colourants, UV filters and similar ingredients without a designated use standard cannot be used, so to import the product as it is, an application to designate an ingredient use standard must be filed with MFDS.

    • The formula can be changed Switching to a listed preservative is faster.
    • You apply to designate an ingredient use standard Attach a summary, data on the ingredient's origin, development history and use standards in Korea and abroad, its characteristics, safety and efficacy data, and a test report on its specifications and test methods.
    Documents
    Application to lift or change an ingredient prohibition (designate or change a use standard), summary of submitted data, data on origin and current use, ingredient characteristics data, safety and efficacy data, test report
    Timeline
    Result notified within 180 days of submission (or of submitting supplementary data); if supplementation is requested, submit additional data or request an extension within 60 days
  4. Do 10 ml miniatures or tester samples also need the full ingredient list in Korea?

    Short answer Products of 10 millilitres or 10 grams or less and samples not for sale may show only the name, the cosmetics responsible seller's business name, the price (for samples, a 'sample' or 'not for sale' mark), the batch number and the expiry date or period after opening.

    • 10 ml (g) or less, or a sample Only the five simplified items may be shown.
    • Over 10 ml (g) and up to 50 ml (g) List only tar colours, gold leaf, phosphate types, fruit acids, functional ingredients and ingredients with published use limits, and make omitted ingredients available by phone, website or a booklet kept at the store.
    • External feminine washes or eyelash permanent wave products They are not eligible for simplification, so label everything.
    Documents
    Label drafts for each volume, phone number or website for full ingredient information, or a full ingredient booklet
    Timeline
    Finalise before printing / there is no separate application procedure
  5. If the fragrance contains limonene or linalool, do they have to be listed separately in the full ingredients?

    Short answer Fragrance may be shown as 'fragrance', but any of the 25 designated allergens (including limonene and linalool) present above 0.01% in rinse-off products or above 0.001% in leave-on products must be named.

    • Rinse-off products (shampoo, cleanser, etc.) Name only components above 0.01%.
    • Leave-on products (cream, lotion, etc.) Name components above 0.001%.
    Documents
    Fragrance supplier's allergen content data, full ingredient label draft
    Timeline
    In practice, allow time to obtain content data from the fragrance supplier
  6. Can cosmetics be imported in their original foreign-language packaging, and how much must be labelled in Korean?

    Short answer The particulars must be shown accurately in easy-to-read Korean, and Chinese characters or foreign languages may be added. Imported cosmetics additionally show the country of manufacture and the manufacturer's name and address, distinguished from the domestic cosmetics manufacturer.

    • Only foreign-language labelling exists Prepare a label draft with all statutory particulars in Korean.
    • The country of origin is shown under the Foreign Trade Act The country of manufacture may be omitted, but the manufacturer's name and address are still shown.
    Documents
    Photos or artwork of the original packaging, Korean label draft, sample product description in Korean
    Timeline
    Finalise before import / there is no separate application procedure
  7. What is needed to say 'suitable for acne-prone skin' on the product page of imported cosmetics in Korea?

    Short answer Factual labelling and advertising claims must be capable of substantiation, and this wording is substantiated with human application test data. If the regional MFDS office requests it, the data must be submitted within 15 days of the request.

    • A general cosmetic effect claim Have human application test data, in-vitro test data or survey data of an equivalent or higher level before using it.
    • A functional claim such as whitening, wrinkle improvement or UV protection Complete the functional cosmetics review or report first.
    Documents
    Substantiation data (test or survey results), a submission stating the substantiation method, the testing body's details and the content and results of substantiation
    Timeline
    Submit within 15 days of the request (extendable for justifiable reasons)
  8. When and where is the ingredient list for imported cosmetics reported in Korea?

    Short answer The cosmetics responsible seller reports the ingredient list to MFDS before the cosmetics are distributed or sold, and again when the list changes. When importing with a standard customs clearance pre-report filed as an electronic trade document, the import performance and ingredient list reports may be omitted.

    • Importing with a standard customs clearance pre-report as an electronic trade document The import performance and ingredient list reports may be omitted.
    • Other cases Report the ingredient list before distribution and sale, and report the previous year's import performance through a cosmetics industry association by the end of February each year.
    Documents
    Ingredient list for each product, import performance data
    Timeline
    Ingredient list before distribution and sale, import performance by the end of February each year / failing to report is subject to an administrative fine of up to KRW 1 million
  9. What goes into the import management record, and is a certificate of manufacture and sale always required?

    Short answer The import management record contains the product name, ingredient specifications and content, country of manufacture and manufacturer's name and address, a copy of the functional cosmetics review result notice, the certificate of manufacture and sale, a sample product description in Korean, the date of first import, import and quality test details by batch number, and buyers and sale quantities.

    • You hold a certificate of manufacture and sale Attach it to the record and keep it.
    • The product is the same as one imported by a seller holding the certificate The certificate may be omitted with confirmation from the import requirement confirmation body and a test report from a designated body's quality test.
    Documents
    Certificate of manufacture and sale, ingredient specification and content data, sample product description in Korean, customs clearance records, quality test results by batch number, sales records
    Timeline
    Prepared for each import and kept on file
  10. Can overseas cosmetics made with animal-tested ingredients be sold in Korea?

    Short answer In principle, a cosmetics responsible seller may not distribute or sell cosmetics that were animal-tested or made or imported using animal-tested ingredients, and violations are subject to an administrative fine of up to KRW 1 million.

    • Testing was required under the importing country's law, or the ingredient was developed under another law, etc. Check with documents whether a statutory exception applies.
    • No exception applies Do not distribute or sell the product in Korea.
    Documents
    Manufacturer's confirmation of whether animal testing was conducted, ingredient supplier documents
    Timeline
    Check before signing the import contract
  11. Who can handle an ingredient and labelling review for imported cosmetics in Korea, and how far does an administrative agent go?

    Short answer YouSun Administrative Agency compares full ingredient data with the prohibited and restricted ingredient lists on paper, reviews Korean label drafts, precautions and advertising wording, prepares ingredient list reports and substantiation submissions, prepares and files applications to designate or change an ingredient use standard, and responds to supplementation requests.

    • Ingredient content testing or human application tests are needed These must be commissioned from a testing body; we reflect the results in the documents.
    • A customs import declaration is needed at clearance A licensed customs broker handles it.
    Documents
    Manufacturer's full ingredient and content data, original packaging artwork, draft advertising wording, letter of authorisation
    Timeline
    In practice, depends on how quickly formula data are received and whether supplementation is needed
  12. What should we prepare first to estimate the cost of a label review for imported cosmetics in Korea?

    Short answer The workload depends on the number of products, the length of the ingredient lists, the number of volume and set packages and whether advertising claims need substantiation, so start by collecting full ingredient and content data and packaging artwork for each product.

    • Only listed ingredients are used and only the label needs fixing The work ends with the label review and preparing the ingredient list report.
    • An unlisted ingredient is used or efficacy wording is planned An application to designate a use standard or preparation of substantiation data is added.
    Documents
    Product list, full ingredient and content data for each product, packaging artwork for each volume, draft advertising wording
    Timeline
    If an application to designate a use standard is added, the result may take up to 180 days from submission

Summary

  • Who: cosmetics responsible sellers importing cosmetics manufactured abroad for distribution and sale in Korea.
  • Filed with: the Ministry of Food and Drug Safety (MFDS, 식품의약품안전처) for the ingredient list report (before distribution and sale; may be omitted when importing with a standard customs clearance pre-report filed as an electronic trade document), and the regional MFDS office (지방식품의약품안전청) that requested substantiation data for labelling and advertising (where the relevant report or application is filed).
  • Key checks: prohibited ingredients, use limits for preservatives, UV filters and hair dye ingredients, Korean-language particulars and full ingredient listing, fragrance allergens and precautions for use.
  • Deadlines: ingredient list before distribution and sale; substantiation data within 15 days of the request; the result of an application to designate or change an ingredient use standard is notified within 180 days of submission.
  • Our scope: document review of ingredient lists and label drafts, and preparing documents filed with the authorities (no testing or analysis, no customs import declarations).

What does an ingredient and labelling review for imported cosmetics cover?

Three things. (1) Ingredients: that the product contains no ingredient MFDS has designated as one that cannot be used, and that ingredients requiring use restrictions, such as preservatives, colourants and UV filters, stay within their limits. (2) Labelling: that the primary and secondary packaging carry the statutory particulars in clear Korean and list all ingredients in the prescribed manner. (3) Labelling and advertising claims: that no wording could make the product be mistaken for a medicine or a functional cosmetic, and that factual claims can be substantiated.

No one may sell cosmetics that use a prohibited ingredient, or import, store or display them for sale; a violation can lead to imprisonment of up to 3 years or a fine of up to KRW 30 million. Cosmetics that breach the labelling rules also may not be sold, stored or displayed for sale. It is therefore safer to align the formula and the label draft before shipment.

What is checked when comparing the full ingredient list before import?

The specification and content data for each ingredient obtained from the manufacturer are compared with the two lists in the Regulation on Cosmetics Safety Standards (화장품 안전기준 등에 관한 규정).

(1) Ingredients that cannot be used: for example, lead and its compounds, mercury and its compounds, hydroquinone and antibiotics are on this list. If any is present, the formula for the Korean market must be changed.

(2) Ingredients requiring use restrictions and their limits: for preservatives, phenoxyethanol is limited to 1.0%, and parabens (p-hydroxybenzoic acid, its salts and esters, excluding phenylparaben) to 0.4% as a single ingredient and 0.8% in mixtures (as acid). For UV filters, zinc oxide and titanium dioxide are each limited to 25%; the hair dye ingredient p-phenylenediamine may be used up to 2.0% in oxidative hair dyes and not in other products. Preservatives, UV filters and similar ingredients not on this list cannot be used.

To use an ingredient without a designated use standard, an application can be made to designate one, and the result is notified within 180 days of submission (or of submitting supplementary data, if requested). Animal testing is also checked: a cosmetics responsible seller may in principle not distribute or sell cosmetics that were animal-tested or made or imported using animal-tested ingredients.

What must appear on cosmetics packaging?

The outer packaging shows (1) the name of the cosmetic (2) the business name and address (3) all ingredients used in manufacture (4) volume or weight of contents (5) the batch number (6) the expiry date or period after opening (7) the price (8) for functional cosmetics, the words 'functional cosmetics' (기능성화장품) or the designated mark, and (9) precautions for use. Where secondary packaging is added, the primary packaging shows the name, business name, batch number and expiry date or period after opening (cosmetic soap is exempt from primary-packaging labelling).

Also required are a barcode; where an ingredient name is used in the product name, that ingredient and its content (except fragrance products); and, if the product is labelled or advertised specifically for infants or children, the content of preservatives. For imported cosmetics, the name of the country of manufacture (may be omitted if the country of origin is shown under the Foreign Trade Act), the manufacturer's name and its address are shown, distinguished from the domestic cosmetics manufacturer.

All particulars must be placed where they are easier to see than other text, in accurate and easy-to-read Korean; Chinese characters or foreign languages may be added. Breaching the labelling particulars (other than price) is subject to a fine of up to KRW 2 million.

How must the full ingredient list be shown?

(1) The font size is 5 points or more. (2) Ingredients are listed in descending order of content, but ingredients at 1 percent or less, fragrances and colourants may be listed in any order. (3) For a blended raw material, each individual ingredient is named. (4) In colour make-up, eye make-up, hair dye or nail products where colourants differ by shade, all colourants may be listed together after '± or +/-'. (5) Fragrance may be shown as 'fragrance' (향료), but if it contains a designated allergen, that ingredient must be named. (6) pH-adjusting ingredients may be shown as their neutralisation products, and saponified ingredients as their saponification products.

Ingredient names must be the standardised generic names. Rather than translating the names on the overseas label, each one is matched to the Korean standardised generic name; for an ingredient without a standardised generic name, the name should be settled before the label draft is finalised.

How is labelling reduced for small-volume products and samples?

Packaging of cosmetics with contents of 10 millilitres or 10 grams or less, and of samples manufactured or imported so that consumers can try them rather than for sale, may show only the name, the business name of the cosmetics responsible seller, the price (for samples, a mark such as 'sample' or 'not for sale'), the batch number, and the expiry date or period after opening (with the manufacturing date where the period after opening is shown).

Products over 10 millilitres (grams) and up to 50 millilitres (grams) may list, instead of all ingredients, only tar colours, gold leaf, the type of phosphates in shampoos and rinses, fruit acids (AHA), the ingredients giving a functional cosmetic its efficacy, and ingredients with a published use limit. Where ingredients are omitted, the packaging must give a phone number or website where all ingredients can be checked at once, or a booklet listing all ingredients must always be kept at the point of sale.

External feminine washes and eyelash permanent wave products are excluded from this simplification.

How are precautions for use and advertising wording reviewed?

For all cosmetics, the common precautions are: (1) consult a specialist if red spots, swelling, itching or similar symptoms appear from direct sunlight during or after use (2) avoid use on areas with wounds (3) keep out of reach of children and away from direct sunlight; wording published for each product type and ingredient is added. Twenty-five fragrance allergens are designated, and each must be named when present above 0.01% in rinse-off products or above 0.001% in leave-on products.

Labelling and advertising must not suggest the product is a medicine, make a non-functional cosmetic look like a functional one, use AI-generated sounds, images or videos that are hard to tell from reality to make it appear that doctors, pharmacists or other experts recommend or use the product, or otherwise mislead consumers. Wording that makes a foreign product look domestic (or the reverse), claims technical partnerships with foreign firms that do not exist, or uses exclusive absolute terms such as 'the best' or 'the finest' is also prohibited. Violations are subject to imprisonment of up to 1 year or a fine of up to KRW 10 million.

Factual claims must be capable of substantiation; when the regional MFDS office requests substantiation data, it must be submitted within 15 days of the request. Substantiation data include human application test data, in-vitro test data or survey data of an equivalent or higher level. Functional claims such as whitening, wrinkle improvement or UV protection require a functional cosmetics review or report first.

How are the ingredient list report and the import management record prepared?

The cosmetics responsible seller reports the list of ingredients used in manufacture to MFDS before the cosmetics are distributed or sold, and reports again when the list changes. The previous year's production or import performance is reported by the end of February each year through a cosmetics industry association such as the Korea Cosmetic Association (대한화장품협회), including the Korea Pharmaceutical Traders Association (한국의약품수출입협회). When importing with a standard customs clearance pre-report filed as an electronic trade document, the import performance and ingredient list reports may be omitted. Failing to report the ingredient list and similar items is subject to an administrative fine of up to KRW 1 million.

An import management record is prepared and kept for imported cosmetics. Its items are (1) product name or the name for sale in Korea (2) specifications and content of ingredients (3) country of manufacture, manufacturer's name and address (4) a copy of the functional cosmetics review result notice (5) a certificate of manufacture and sale (6) a sample product description written in Korean (7) date of first import (customs clearance date) (8) import date and quantity by batch number (9) quality test date and result by batch number and (10) buyers, sale dates and quantities. The certificate of manufacture and sale may be omitted where the import requirement confirmation body confirms the product is the same as one imported by a seller holding the certificate and a test report from a designated body's quality test is kept.

How far can an administrative agent help?

Under a letter of authorisation, YouSun Administrative Agency compares the full ingredient data of products to be imported with the lists of prohibited and restricted ingredients on paper, reviews Korean label drafts and precaution wording, checks advertising wording, prepares ingredient list reports and substantiation submission documents, prepares and files applications to designate or change an ingredient use standard, and responds to requests for supplementation.

Testing and analysis of ingredient content and human application tests are carried out by testing bodies, and customs import declarations are handled by licensed customs brokers, so we do not take these on. We also do not take on court or administrative appeal cases. Functional efficacy claims are followed up through the functional cosmetics review or report procedure. Whether a label complies and any disposition are decided by the competent authority.

FAQ

Frequently Asked Questions

Q. If an ingredient name is part of the product name, what else must be shown?

A. The packaging must show that ingredient's name and its content. Fragrance products are excluded.

Q. What extra preparation is needed to label a product for infants or children?

A. The packaging must show the content of preservatives with designated use standards, and the cosmetics responsible seller must prepare and keep product safety data in advance. Infants are aged 3 or under, and children are aged 4 to 13.

Q. Can the deadline for submitting substantiation data be extended?

A. Yes, if a justifiable reason is accepted. If the data are not submitted in time and the same labelling or advertising continues, an order to stop it will be issued until the data are submitted.

Q. How are batch numbers and expiry dates shown on a set of several products?

A. The outer packaging of a set may show each component's batch number or a combined batch number. For the expiry date, only the earliest-expiring component's date is shown, and the others can be referred to with wording such as 'Expiry date: shown on each product'.

Q. Can a confidential ingredient be shown as 'other ingredients'?

A. Where listing an ingredient would seriously harm the business's legitimate interests, supporting data are submitted to MFDS, and if accepted, the ingredient may be shown as 'other ingredients' (기타 성분). Until then, all ingredients must be listed.

Q. Can an AI-generated video of an expert recommending the product be used in advertising?

A. No. Advertising that uses AI-generated sounds, images or videos that are hard to tell from reality to make it appear that doctors, pharmacists, professors or other experts recommend or use the product is prohibited.

Key terms

Ingredient and labelling review for imported cosmetics: key terms explained

Ingredients that cannot be used (사용할 수 없는 원료)
Ingredients MFDS has designated and published as not usable in manufacturing cosmetics; cosmetics using them may not be sold or imported, stored or displayed for sale.
Ingredients requiring use restrictions (사용상의 제한이 필요한 원료)
Ingredients such as preservatives, UV filters and hair dye ingredients with published use standards such as maximum limits; preservatives, UV filters and similar not listed cannot be used.
Primary and secondary packaging (1차 포장·2차 포장)
Primary packaging is the container in direct contact with the contents; secondary packaging is the packaging holding it, including protective materials and packaging for labelling purposes such as package inserts.
Standardised generic name (표준화된 일반명)
The standardised ingredient name that must be used when listing ingredients on cosmetics packaging.
Fragrance allergens (착향제 알레르기 유발성분)
The 25 designated components of fragrances that must be named individually instead of being grouped as 'fragrance' when above set concentrations.
Substantiation of labelling and advertising (표시·광고 실증)
Proof by test or survey results that factual matters in a business's or seller's own labelling and advertising are true.
Ingredient list report (원료목록 보고)
The duty of a cosmetics responsible seller to report the list of ingredients used in manufacturing to MFDS before distribution and sale.
Import management record (수입관리기록서)
A record a cosmetics responsible seller prepares and keeps for each imported cosmetic, containing or attaching the product name, ingredient specifications and content, manufacturer, certificate of manufacture and sale, and import and sales details.

Our office

YouSun Administrative Agency

YouSun Administrative Agency is a licensed administrative agent office (행정사사무소) on Toegye-ro in Jung-gu, Seoul. We prepare and file permit, registration and report applications with Korean government agencies on behalf of clients, in Korean, English, Chinese and Japanese.

Address
3F Seongwoo Bldg, 324 Toegye-ro, Jung-gu, Seoul 04614, Korea
Hours
Mon–Fri 09:30–17:30 (KST), closed weekends and public holidays
Languages
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Contact

YouSun Administrative Agency (+82-2-325-8222) supports document review and filing with the competent authority.