Still life of an unlabelled glass pump bottle, a ceramic jar of cream and a white dish holding dispensed gel, arranged with folded linen

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A body line usually starts with two items: one body wash that is rinsed off, and one body lotion that is not. From a brand's side this looks like a single concept, a single fragrance and a single hero ingredient distributed across two textures. Once development begins, though, the two formulas narrow at different speeds. The reason is usually the same. Several provisions of the Korean cosmetic standards write "products that are rinsed off after use" and "products that are not rinsed off" into separate columns.

This article sets out where that boundary actually sits, using the wording of the official instruments. Its scope is products distributed in Korea; rules in an export destination have to be checked separately.

Key takeaways

The first decision is the product type, not the texture

To read how much of a raw material you may use under the Korean standards, you first have to settle which cosmetic product type the product belongs to. The list of product types appears in Attached Table 1, subparagraph 1 of the Regulation on Precautions for Use and on Labelling of Fragrance Allergens in Cosmetics (MFDS Notice No. 2026-56, in force 5 August 2026).

So a body wash is a human cleansing product and a body lotion is a basic skin care product. The two belong to one commercial line but to different regulatory columns. A second axis, whether the product is rinsed off after use, then overlaps with the first, and the differences below follow from that.

One raw material, two limits: salicylic acid

Article 8(2) of the Cosmetics Act (Act No. 20901, in force 2 April 2026) requires use standards to be designated and published for raw materials that need particular restriction, such as preservatives, colourants and ultraviolet filters. It then provides that preservatives, colourants, ultraviolet filters and the like other than those whose use standards have been designated and published may not be used. Those standards are Attached Table 2 of the Regulation on Safety Standards for Cosmetics (MFDS Notice No. 2026-19, in force 18 March 2026). Article 4 of the same notice repeats that preservatives, ultraviolet filters and the like other than the raw materials in Attached Table 2 may not be used. Note that Article 8(2) of the Act also names colourants while the wording of Article 4 of the notice does not, so it is safer not to merge the two sentences.

Within Attached Table 2, the material that most often constrains a body line first is salicylic acid and its salts. The limit column carries only two entries.

The remarks column attaches two conditions. The first is that the material is prohibited in products for infants and young children, or in products specifically labelled as usable by children aged 13 or under, except in shampoo. The second is that the material may only be used as an active ingredient of a functional cosmetic, and is prohibited in other products. The remarks cell belongs to the whole row, so the limit entries and these two conditions have to be read together rather than separately.

Applied to a body line, the table reads as follows. A body wash is a human cleansing product, so the 2% entry is the one that corresponds to it, but the remarks column on the same row confines use to an active ingredient of a functional cosmetic, so that condition has to be met as well. A body lotion is neither a human cleansing product nor a rinse-off hair product. The limit column has no entry covering a leave-on body product and the remarks column states that the material is prohibited in other products, so on the wording of Attached Table 2 there is no column that permits it in a body lotion. The acne-relief function is in any case limited to human cleansing product categories by the proviso to Article 2, subparagraph 9 of the Enforcement Rule of the Cosmetics Act (Ordinance of the Prime Minister No. 2109, in force 2 April 2026).

In other words, a two-item body brief built on one hero ingredient can be viable on the rinse-off side and not viable on the leave-on side. What that situation needs is not a lower percentage but a different concept axis for the second item.

Preservatives that are open only to rinse-off products

The same axis returns in preservation design. In the same annex, some materials carry a limit only for rinse-off products and are written as prohibited elsewhere.

Other materials carry a limit on both sides, but not the same number. Benzalkonium chloride, benzalkonium bromide and benzalkonium saccharinate are limited to 0.1% as benzalkonium chloride in products that are rinsed off after use and to 0.05% as benzalkonium chloride in other products. The remarks column adds that benzalkonium chloride may not be used in spray products.

In practice this surfaces at a predictable point. A preservative system that has been stabilised in the body wash rarely transfers to the body lotion unchanged: one material may drop out entirely, or its ceiling may fall by half or more. Preservation then has to be designed again for the second product, and the schedule moves with it. What to check at the raw-material stage is set out separately in our ingredient selection guide.

The pH requirement applies to only one side

Article 6(6) of the Regulation on Safety Standards for Cosmetics sets a pH requirement for cosmetics on the market. It applies to liquid products in liquid, lotion, cream and similar forms within six categories. Those are products for infants and young children (excluding shampoo and rinse for infants and young children, human cleansing products for infants and young children, and bath products for infants and young children), eye make-up products, colour make-up products, hair products (excluding shampoo and rinse), shaving products (excluding shaving cream and shaving foam), and basic skin care products (excluding make-up removers such as cleansing water, cleansing oil, cleansing lotion and cleansing cream). The requirement is a pH of 3.0 to 9.0, provided that products that do not contain water, and products that are washed off with water immediately after use, are excluded.

The human cleansing product category does not appear in that list. The basic skin care product category does. So a body lotion in liquid form has a pH band to check, while an anhydrous body format falls outside this requirement under the proviso above. A body wash is not among the product types this paragraph covers in the first place.

The microbial limits in paragraph 4 of the same article run on a different axis. The total aerobic microbial count must be 500 counts per g(mL) or less for products for infants and young children and for eye make-up products, and 1,000 counts per g(mL) or less for other cosmetics, while wet wipes must hold bacteria and fungi to 100 counts per g(mL) or less each. Escherichia coli, Pseudomonas aeruginosa and Staphylococcus aureus must not be detected. Here the dividing line is the product type, not whether the product is rinsed off. Reading which provisions split by type and which split by rinse-off is the core skill at this stage.

The fragrance labelling threshold differs tenfold

The duty to print the names of allergenic substances among the constituents of a fragrance comes from Attached Table 4, subparagraph 3, item (e) of the Enforcement Rule, and the list of those substances sits in Attached Table 2 of Notice No. 2026-56 by way of Article 4 of that notice. The list contains 25 substances, including amyl cinnamal, benzyl alcohol, cinnamyl alcohol, citral, eugenol, linalool, limonene and oakmoss extract.

The line beneath the list is the one that matters. The duty applies only where the substance is contained above 0.01% in products that are rinsed off after use, or above 0.001% in products that are not rinsed off after use.

That is why an identical fragrance composition produces different outcomes. A fragrance constituent that never appeared in the ingredient list of the body wash can be named in full on the body lotion at the same fragrance load. If the fragrance is fixed first and then split across the two textures, the difference is only discovered when the ingredient lists are finalised. It is safer to look at both thresholds while the fragrance is still being developed.

The statements on the package split as well

Article 10(1), subparagraph 9 of the Cosmetics Act requires precautions for use to be stated on the package. Article 19(3) of the Enforcement Rule passes the content to Attached Table 3, and subparagraph 2 of that table passes the detailed statements, by product type and by contained ingredient, to a notice. That notice is Notice No. 2026-56, and the statements below all sit in subparagraph 2, item (b) of its Attached Table 1, the precautions by contained ingredient. The same axis appears three times there.

The IPBC entry makes the direction especially clear. Because its parenthesis carves out bath products, shampoos and body cleansers, the statement attaches to the body lotion even where both products use the same preservative. Adding statements after a small-label container has been chosen means reworking the design, so it is better to draw up the list of statements before the container is fixed. When to lock the container is covered in our article on packaging compatibility.

The claims you may use also follow the product type

Product type returns once more at the claims stage.

On the functional-cosmetic side, Article 2, subparagraph 9 of the Enforcement Rule, noted above, limits the function of helping to relieve acne-prone skin to human cleansing product categories. That route is open to the body wash and not to the body lotion.

The substantiation side works the same way. The Attached Table to the Regulation on Substantiation of Cosmetic Labelling and Advertising (Notice No. 2020-80 of the Ministry of Food and Drug Safety, in force 4 September 2020) assigns the evidence required for each expression, and to the antibacterial expression it adds the qualifier "limited to human cleansing products" together with a requirement to submit human application test data. The same table requires human application test data for "suitable for use on acne-prone skin", "temporary reduction of cellulite", "relief of swelling and dark circles" and "improvement of skin blood circulation", while "relief of skin ageing" may rest on either human application test data or non-human test data. Expressions about an increase, decrease or activation of collagen or of enzymes need data substantiating that function in a functional cosmetic. What a claim can be proved with is covered in more detail in our article on advertising claim substantiation.

A checklist for planning the two items together

If two body items start from one brief, it is worth writing the following out in two columns before development begins.

  1. Has the cosmetic product type been fixed for each product? (Human cleansing product category, or basic skin care product category.)
  2. Is the hero ingredient behind the concept listed in Attached Table 2? If it is, does its limit column cover both products?
  3. Has a preservation system been designed for each texture separately? Does either of them depend on a material that is usable on only one side?
  4. Has the pH band been checked for the leave-on product?
  5. At the 0.001% threshold, does the fragrance composition still produce the ingredient list you intended?
  6. Have the additional precautionary statements been drawn up for each product? Is there room for them on the chosen container?
  7. Is the claim you want restricted by product type? If it is, which of the two products can carry it?

Items 2 and 5 are the ones that most often trip a project up. Both are expensive to unwind once the formula is close to final.

Frequently asked questions

Can a body wash and a body lotion be built on the same formula base?

The bases differ in kind. A cleansing system and an emulsion are built from different raw materials, so moving one concept into two textures means designing each formula separately. Whether to start from an existing base or to develop a new formula is covered in our article on base formula versus custom formulation.

I want salicylic acid in a body lotion. Is there any route?

The limit column of Attached Table 2 lists only human cleansing product categories and rinse-off hair product categories, and the remarks column provides that the material may only be used as an active ingredient of a functional cosmetic and is prohibited in other products. So on the wording of Attached Table 2 there is no entry permitting this material in a leave-on body product, and the acne-relief function is in any case limited to human cleansing product categories by the proviso to Article 2, subparagraph 9 of the Enforcement Rule. Depending on the effect you are after, looking at a different raw material first is usually faster.

Can we keep the fragrance and simply lower the load to avoid the labelling duty?

The threshold is a concentration, so arithmetically it is possible. The threshold for leave-on products is above 0.001%, however, which leaves very little headroom, and the character of the fragrance can change. Designing the fragrance on the assumption that it will be labelled gives a more stable result than treating avoidance as the goal.

We want to use "antibacterial" on a body wash. What does that need?

The Attached Table to the substantiation notice qualifies the antibacterial expression as limited to human cleansing products and requires human application test data to be submitted. You need to confirm both that the product type matches and that the data can be obtained.

Do these rules apply in the same way to export-only products?

This article covers Korean requirements only. Each destination country sets its own permitted materials, limits and labelling duties, so those have to be checked separately.

Taking it into development

A body line has few items but twice as many boxes to tick. Deciding which concept belongs in which texture first makes everything after it simpler. EVAS carries out planning, design, research, manufacturing, logistics and brand content in house. Tell us the direction you have in mind for your body products and we will review it with you from a development standpoint.

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