Choosing Cosmetic Ingredients in Korea: What a Brand Has to Check Before Formulation

The short answer: ingredient selection starts with eligibility, not efficacy

The list a brand brings to a development meeting is usually a list of ingredient names it wants to use. Before that list can become a formula, though, it has to pass four checks, and none of them is about efficacy. Can the ingredient be used in a cosmetic product in Korea at all? If it can, in which product types and up to what limit? Does it entitle the brand to the wording it wants on the package? And what does the choice leave behind on the ingredient list?

This article works through those four checks using the Cosmetics Act in force, its Enforcement Rule, and the relevant notices of the Ministry of Food and Drug Safety (MFDS). It does not assess the efficacy or the safety of any particular ingredient, and it describes cosmetics distributed in Korea. If you plan to export, the rules of the destination market have to be checked separately. Korean statute and notice titles are quoted here in unofficial English translation.

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1. Start with two lists

Article 8 of the Cosmetics Act (Act No. 20901, effective 2 April 2026) splits raw materials into two tracks.

• Paragraph (1) requires the Minister of Food and Drug Safety to designate and publicly notify the raw materials that may not be used in the manufacture, etc. of cosmetics. That is the prohibited list.
• Paragraph (2) requires the Minister to designate and publicly notify standards of use for raw materials that need particular restrictions on use, such as preservatives, colourants and ultraviolet-ray blocking agents (UV filters), and states that preservatives, colourants and UV filters other than those whose standards of use have been designated and notified may not be used.

That second sentence is a part that is often missed in practice. Paragraph (2) is not only a rule about staying under a limit; it is also a rule that a raw material not on the list may not be used. For a preservative, a colourant or a UV filter, being absent from the prohibited list is not permission.

The lists themselves live in the Regulation on Safety Standards for Cosmetics (MFDS Notice No. 2026-19, effective 18 March 2026). Article 3 sets out the raw materials that may not be used in cosmetics as Attached Table 1, and Article 4 sets out the raw materials requiring restrictions on use together with their standards of use as Attached Table 2, repeating that preservatives, UV filters and the like other than the materials in Attached Table 2 may not be used. Under Article 2 of the same notice, the regulation applies to every cosmetic manufactured, imported or distributed in Korea.

So the first question to ask about a submitted ingredient list is not whether a material is good. It is whether it appears in Attached Table 1, and, if it belongs to the preservative, colourant or UV-filter family, whether it appears in Attached Table 2.

2. Limits change with the product type and with rinse-off

Attached Table 2 records a limit on use and a remarks column for each raw material. For the same material the number changes with the product, and in some formats the material is prohibited outright. The following examples are taken directly from the preservatives table of the current Attached Table 2.

• Glutaral (pentane-1,5-dial) has a limit of 0.1 per cent, and its remarks column states that it is prohibited in aerosol products (sprays only).
• Methylisothiazolinone is allowed at 0.0015 per cent in products that are rinsed off after use and is prohibited in other products. Using it alongside the mixture of methylchloroisothiazolinone and methylisothiazolinone is also prohibited.
• Benzalkonium chloride, bromide and saccharinate are allowed at 0.1 per cent as benzalkonium chloride in products that are rinsed off after use and at 0.05 per cent as benzalkonium chloride in other products, and benzalkonium chloride is prohibited in sprayable products.

Those three examples show why the product type has to be fixed before the ingredient list is. A combination that works for a cleanser can become prohibited the moment the same idea moves to a toner or a mist. Fixing raw materials while the format and the manner of use are still open usually means reworking the formula later.

One more point belongs here. A standard of use is not a fixed value. Article 8(5) of the Act requires the Minister to review periodically the safety of the standards of use for raw materials designated and notified under paragraph (2) of the same article, and allows the standards to be changed according to the result; Article 17-2(1) of the Enforcement Rule sets that review cycle at five years. Under Article 17-2(2) of the Enforcement Rule, the Minister selects the subjects of the safety review in advance before carrying it out. For a product you intend to sell for a long time, it is safer not to assume that the standard in force on the day the formula is fixed will stay the same.

3. A raw material does not secure a claim

The most common misunderstanding in ingredient selection is that adding a given material entitles the brand to print the corresponding effect on the package. In the Korean system, whether a raw material may be used and how far a label or an advertisement may go are handled as separate procedures.

Which effects fall inside the functional-cosmetics scope, and how review differs from reporting, are covered in our article on shampoo development and hair-loss wording. What a claim must be able to prove is covered in our article on advertising substantiation. At the ingredient-selection stage one point is enough: a raw material is only material for a claim, and the evidence for the claim has to be built separately.

There is, however, a place where the ingredient choice creates a labelling duty directly. Article 19(4) of the Enforcement Rule lists the particulars that must appear on the package under Article 10(1), subparagraph 10 of the Act; its own proviso excludes subparagraphs 1 and 6 for customised cosmetics. Among the subparagraphs of Article 19(4), subparagraph 3 requires the ingredient name and its content where an ingredient name is used as part of the product name, excluding fragrance products. Subparagraph 4 requires the content where a human cell or tissue culture fluid is included, and subparagraph 5 requires the content of the raw material where the product is to be labelled or advertised as natural or organic. Subparagraph 8 requires the content of preservatives among the raw materials whose standards of use have been designated and notified under Article 8(2) of the Act, where the product is to be labelled or advertised specifically as usable by infants or children. In short, putting a raw-material name into the product name brings a content declaration with it.

4. Whether the raw material survives the formula and the container is a separate check

A raw material that may be used is not thereby stable in your formula. Whether it discolours or separates in the formulation, and whether it reacts with the container material, is not something the statutory ingredient lists answer. We covered that ground in our article on formulation and container compatibility.

What the selection stage needs is not the conclusion but the order of work. Once the candidate materials are narrowed, look at them together with the intended format and container type, and decide first whether the combination is one that calls for stability work. The extent of that check also depends on whether you start from an existing base or design a new formula, and that difference is set out in our comparison of base formulas and custom formulation.

5. What the label keeps: the full ingredient list, fragrance, and other ingredients

Article 10(1), subparagraph 3 of the Act requires all ingredients used in manufacturing the cosmetic to be stated on the package, with a parenthetical carve-out for ingredients prescribed by Ordinance of the Prime Minister, such as ingredients contained in small amounts that are harmless to the human body. Those exclusions are in Article 19(2) of the Enforcement Rule.

• Subparagraph 1 covers ingredients removed during the manufacturing process that do not remain in the final product.
• Subparagraph 2 covers incidental ingredients present in the raw material itself, such as stabilisers and preservatives, in an amount smaller than the amount that would produce their effect.
• Subparagraph 3 applies to packaging for cosmetics of more than 10 millilitres up to 50 millilitres, or more than 10 grams up to 50 grams, and allows omission of ingredients other than tar colours, gold leaf, the types of phosphates contained in shampoos and rinses, fruit acids (AHA), raw materials that produce the efficacy and effect of a functional cosmetic, and raw materials for which the Minister has publicly notified a limit on use. Cosmetics that the Minister designates and publicly notifies as requiring special care by consumers are excluded from this subparagraph.

Omitting under subparagraph 3 does not make the information disappear. Paragraph (5) of the same article requires a telephone number or a website address on the package so consumers can check the omitted ingredients immediately, or printed matter, such as a booklet listing all the ingredients, kept at the point of sale at all times.

The method of labelling is in item 3 of Attached Table 4 to the Enforcement Rule. The type size is 5 points or larger (item 3(a)). Ingredients are listed in descending order of content, except that ingredients used at 1 per cent or less, fragrances and colourants may be listed in any order (item 3(b)). A compound raw material is listed under the names of its individual constituent ingredients (item 3(c)). An ingredient used to adjust pH may be listed as the product of the neutralisation reaction, and an ingredient that goes through saponification may be listed as the product of the saponification reaction (item 3(f)).

Fragrance deserves separate attention. Item 3(e) of the same attached table allows a fragrance to be shown as "fragrance", but provides that where the constituents of the fragrance include an allergenic substance designated and publicly notified by the Minister, it may not be shown as "fragrance" and the name of that substance must be stated. That list sits in Article 4 of the Regulation on Precautions for Use of Cosmetics and Labelling of Allergenic Substances (MFDS Notice No. 2026-56, effective 5 August 2026) and its Attached Table 2, which currently carries 25 substances with serial numbers and CAS registry numbers. That Attached Table 2 carries a proviso: it applies only where the content exceeds 0.01 per cent in products that are rinsed off after use, or 0.001 per cent in products that are not rinsed off after use. If the project fixes a fragrance concept early, it is better to check at the perfumery stage whether the composition crosses those thresholds.

There is also a route for a formula that is hard to disclose. Item 3(g) of the same attached table provides that where stating the ingredients under Article 10(1), subparagraph 3 of the Act is likely to seriously infringe the legitimate interests of the business operator, the operator must submit supporting material to the Minister, and where the Minister recognises the likelihood of such infringement, the ingredients may be stated as "other ingredients". It is not automatic; submission and recognition come first.

6. The finished product has its own standards to meet

Clearing each raw material does not automatically make the finished product compliant. The safety standards for distributed cosmetics, based on Article 8(8) of the Act, are in Article 6 of the Regulation on Safety Standards for Cosmetics. Under paragraph (1), a distributed cosmetic must conform to the standards in paragraphs (2) through (5) and additionally to the standards in paragraphs (6) through (9) for its product type. Testing follows Attached Table 4 to the same notice, although a company's own method may be used where it is otherwise recognised as scientifically and reasonably valid.

The items that connect most directly to ingredient selection are these.

• Only where a substance was not added intentionally, objective data confirm that it came in unintentionally, such as by migrating from packaging material during manufacturing or storage, and complete removal is technically impossible does paragraph (2) set detection limits for lead, nickel, arsenic, mercury, antimony, cadmium, dioxane, methanol, formaldehyde and phthalates (limited to dibutyl phthalate, butyl benzyl phthalate and di(2-ethylhexyl) phthalate). These are detection allowances, not permission to formulate with those substances.
• Paragraph (3) provides that where a raw material listed in Attached Table 1 is detected for the reason in paragraph (2) but no detection limit has been set, the risk must be assessed and decided under Article 17 of the Enforcement Rule of the Cosmetics Act.
• Paragraph (4) sets microbial limits. 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. For wet wipes, bacterial and fungal counts must each be 100 counts per g (mL) or less. Escherichia coli, Pseudomonas aeruginosa and Staphylococcus aureus must not be detected.
• Paragraph (6) sets a pH range of 3.0 to 9.0 for liquid products in liquid, lotion, cream and similar formats within products for infants and young children (excluding infant shampoo, infant rinse, infant body cleansing products and infant bath products), eye make-up products, colour make-up products, hair products (excluding shampoo and rinse), shaving products (excluding shaving cream and shaving foam), and basic skincare products (excluding make-up removers such as cleansing water, cleansing oil, cleansing lotion and cleansing cream). Products that contain no water and products that are rinsed off with water immediately after use are excluded.

Where a raw material came from, and which excipients come with it, connects to these standards. That is why the documentation you request from a raw-material supplier should cover specifications and test items, not only the ingredient name.

7. If you want a raw material that has no standard yet

The Act also provides a route for a raw material that has not been designated and notified. Article 8(6) allows a cosmetics manufacturer, a cosmetics responsible distributor, or a university, research institute or other person prescribed by Ordinance of the Prime Minister to apply for the release or amendment of a raw material designated and notified under paragraph (1), for the designation and notification of standards of use for a raw material not designated and notified under paragraph (2), and for the amendment of the standards of use for a designated and notified raw material. Paragraph (7) requires the Minister to examine whether the application is well grounded and, where it is, to release or amend the designated material, or to designate and notify or amend the standards of use, and in that case to inform the applicant of the result of the examination in writing.

What is actually submitted, and how long it takes, is in Article 17-3 of the Enforcement Rule.

• Under paragraph (1), the application uses attached Form 13-2 and carries five documents: a summary of the entire submission; material on the origin of the raw material, the course of its development, and its standards of use and current use in Korea and abroad; material on the characteristics of the raw material; material on safety and efficacy, with the efficacy material submitted only where applicable; and a test report on the standards and test methods for the raw material.
• Under paragraph (2), where the submitted material is not appropriate, the Minister may specify what is wrong and request supplementation, and the applicant may submit additional material within 60 days from the date of supplementation or request an extension of that deadline.
• Under paragraph (3), the Minister must send a notice of the examination result within 180 days from the date the applicant submitted the material, or, where supplementation was requested, from the date the supplemented material was submitted.

This procedure runs on a different clock from product development. It adds its own timeline and does not guarantee an outcome, so setting a launch date up front that presupposes a new raw material is not advisable.

8. Moving an ingredient list into a development brief

In practice this order tends to be the fastest.

1. Fix the product type and the manner of use first. Whether the product is rinsed off, whether it is sprayed, and whether it is used near the eyes change the decisions that follow.
2. Check the list against Attached Table 1. If a material appears there, the rest of the review is moot.
3. For preservatives, colourants, UV filters and the other families subject to standards of use, check whether the material appears in Attached Table 2 and what the limit is for the product type you have chosen.
4. Put the product name and the labelling and advertising plan next to the ingredient list and check whether any content-declaration duty is triggered.
5. Check whether the fragrance composition crosses the notified thresholds for allergenic substances.
6. Check that the supplier documentation includes specifications and test methods.
7. Write the result into the development brief. Our article on writing a product brief covers that step.

9. Frequently asked questions

The raw material is used abroad. Can we use it in Korea?

A history of use in another country does not decide whether a material is permitted here. Under Article 2 of the Regulation on Safety Standards for Cosmetics, the notice applies to every cosmetic manufactured, imported or distributed in Korea, so the check has to be made again against Attached Table 1 and Attached Table 2 of that notice. Where no Korean standard exists, the application procedure in Article 8(6) of the Act and Article 17-3 of the Enforcement Rule becomes the option.

Can we hide our formula on the ingredient list?

Item 3(g) of Attached Table 4 to the Enforcement Rule provides the procedure. Note, though, that ingredients may be stated as "other ingredients" only where the operator has submitted supporting material and the Minister has recognised the likelihood that the operator's legitimate interests would be infringed; applying is not enough on its own.

Can we simply write "fragrance"?

Item 3(e) of Attached Table 4 to the Enforcement Rule allows a fragrance to be shown as "fragrance", but where a notified allergenic substance is among its constituents it may not be shown that way and the name of the substance must be stated. Under the proviso to Attached Table 2 of the Regulation on Precautions for Use of Cosmetics and Labelling of Allergenic Substances, this applies where the content exceeds 0.01 per cent in products rinsed off after use and 0.001 per cent in products that are not.

Can a small-size product omit part of the ingredient list?

Separate the size bands first. For packaging of cosmetics of 10 millilitres or less, or 10 grams or less, the proviso to Article 10(1) of the Act and Article 19(1), subparagraph 1 of the Enforcement Rule allow only the product name, the trade name, the price, the lot number and the expiry date or period after opening to be stated. The larger band of more than 10 millilitres up to 50 millilitres, or more than 10 grams up to 50 grams, is governed by the omission rule in Article 19(2), subparagraph 3, which excludes tar colours, gold leaf, the types of phosphates in shampoos and rinses, fruit acids (AHA), raw materials that produce the efficacy and effect of a functional cosmetic, and raw materials with a notified limit on use from what may be omitted. In both bands, cosmetics notified as requiring special care by consumers are excluded, and where ingredients are omitted the means of verification in paragraph (5) of the same article must be in place.

We changed one raw material. What has to be redone?

It depends on the scope of the change. For a material with a limit on use, check the limit for the product type again. Where the material is connected to the product name or to the labelling and advertising plan, check the content declaration in Article 19(4) of the Enforcement Rule. Where the fragrance composition changed, check the allergenic-substance labelling again. Formula stability and container compatibility remain separate checks.

10. Next step

An ingredient list is where development starts, not where it concludes. The same material can be workable or not depending on the product type it enters, the concentration it enters at, and the labelling plan it arrives with, and the documentation to prepare changes with it.

EVAS runs planning, design, research, manufacturing, logistics and brand content together in-house. Look through the ingredient references and the formulation library for development direction, review our development process, and if you already have a specific list, tell us about it through project enquiry. Our other articles are in insights.