A simple product-photography setup in natural light: an unlabelled frosted glass pump bottle and a white cosmetic tube standing side by side on a sheet of white backdrop paper laid over a wooden table, with a grey board and folded linen beside them

AI-generated image.

The short answer: the product-page duty attaches to the seller, not the maker

Once the product is finished and the label is printed, development looks complete. But the moment that product is listed on your own shop or on a Korean open market, one more statute attaches: the Act on Consumer Protection in Electronic Commerce.

That Act does not call on the party that made the product. It calls on the party that sells it. Whether the cosmetic was made under contract manufacturing, imported, or produced in your own plant, selling it online to consumers as a business makes you a mail-order distributor. And a mail-order distributor has its own list of what the product page has to say. Cosmetics are one of forty product categories for which that list is set out separately.

This creates a confusion brands run into often. The label entries were settled with the manufacturer, but nobody owns the product-page entries, and the page goes to design as a visual job. The two lists are different, and what you were allowed to leave off one does not fall off the other.

This guide puts the two lists side by side and reads the provisions directly: who the online duty attaches to, what the cosmetics entries on a product page are, who marks the selling price, how liability is divided once you list on an open market, and what two provisions added in 2026 change.

The scope is the law of the Republic of Korea, and every provision and notice quoted here was read in the original on the Korean Law Information Center on 13 October 2026. This is not legal advice on a specific matter, and it makes no claim about EVAS's commercial terms, facilities, or test records.

Key takeaways

1. Who does this duty attach to?

Article 2(2) of the Act defines mail-order sales as providing information on the sale of goods or services by post, telecommunications or another method prescribed by Ordinance of the Prime Minister, receiving the consumer's offer, and selling the goods or services. Article 2(3) defines a mail-order distributor as a person who engages in mail-order sales as a business, or who performs mail-order business under an agreement with such a person.

Neither definition mentions manufacturing or importing. Where the Cosmetics Act divides business into manufacturing, responsible distribution and customised cosmetics retail, this Act does not ask who made the product. It asks who sells it to the consumer. So a brand selling a contract-manufactured product through its own shop may be a responsible distributor under the Cosmetics Act on the facts, and is a mail-order distributor under this Act as long as it conducts mail-order sales as a business. Two sets of duties land on the same company.

The Act also says where it does not apply. Article 3(1) provides that its provisions do not apply to transactions in which a business operator purchases for the purpose of a commercial activity. The proviso to the same paragraph adds that this does not hold where a business operator in substance trades in the same position and on the same terms as a consumer. That is why a purely wholesale site and a site selling to the general public cannot be treated the same way.

Article 3(3) is worth reading alongside it. Articles 13 through 15 and Articles 17 through 19 do not apply to a mail-order distributor that brokers mail-order sales between persons who are not mail-order distributors. A platform brokering sales between persons who are not mail-order distributors and a brand selling directly are handled by different provisions.

2. The three items the advertisement itself has to carry

Article 13(1) requires a mail-order distributor to include three items in any display or advertisement made for the purpose of receiving offers for a transaction. These are the trade name and the representative's name; the address, telephone number and email address; and the number of the report made under Article 12 to the Fair Trade Commission or to the Mayor of a Special Self-Governing City, the Governor of a Special Self-Governing Province, or the head of a city, county or district, together with the name of the body that received it and other particulars by which the report can be verified.

The third item connects to the mail-order business report. Article 12(1) requires a mail-order distributor to report its trade name, address and telephone number, its email address, internet domain name and the location of its host server, and other particulars prescribed by Presidential Decree. The proviso to that paragraph exempts operators whose number and size of transactions fall at or below a standard set by Fair Trade Commission notice. The figures in that standard sit in a separate notice, which this guide did not read. Paragraphs (2) and (3) require further reports when the reported particulars change and when the business closes temporarily, closes permanently, or restarts.

The cyber mall itself carries a display duty too. Article 10(1) requires the operator of a cyber mall engaged in electronic commerce to display, in the manner prescribed by Ordinance of the Prime Minister, the trade name and the representative's name, the address of the place of business, the telephone number and email address, the business registration number, the terms of use of the cyber mall, and other matters prescribed by Presidential Decree, so that consumers can easily identify the business operator. The address in the second item includes the address of the place where consumer complaints can be handled.

In other words, before you build the product page, the site itself has to carry its own set of disclosures. Footer text and a terms page are often the last thing a brand site handles. In the order of the provisions, they come first.

3. Transaction terms before the contract, the written document after it

Article 13(2) requires a mail-order distributor to display, advertise or notify the matters listed in its subparagraphs by an appropriate method, so that the consumer can understand the transaction terms accurately before concluding the contract and trade without mistake. Once the contract is concluded, it must deliver to the contracting party a written document stating those matters by the time the goods are supplied. The proviso allows that document to be delivered to the person receiving the goods instead of the contracting party where grounds prescribed by Presidential Decree exist and the contracting party's rights are not infringed.

Those subparagraphs run as follows: the trade name of the supplier and the seller with the representative's name, address and telephone number; the name, type and content of the goods; information about the goods; the price, with the specific method of determining it where it is not fixed, and the method and timing of payment; the method and timing of supply; the period, method of exercise and effect of withdrawal of an offer or cancellation of the contract; the conditions and procedure for exchange, return, warranty, refund and compensation for delayed refund; technical particulars needed for goods supplied through electronic media; handling of consumer damages, complaints and disputes; the terms and conditions of the transaction, including how they can be checked; the option of payment-deposit or a consumer damage compensation insurance contract in prepayment-type sales; and other matters prescribed by Presidential Decree that affect the purchase decision or are needed to remedy consumer damage.

The third of those, subparagraph 2-2, sits closest to cosmetics. It requires information about the goods, and adds that in this case the statements displayed on the product may stand in place of stating them in the written document on the contract. That means the label text can do work on the written-document side. It does not mean the duty to display or advertise before the contract disappears.

The written-document duty also has carve-outs. Article 3(2) lists transactions prescribed by Ordinance of the Prime Minister in which the consumer trades frequently under terms or a standardised method already well known to them, and transactions for which another statute prescribes a duty to deliver a contract document by a method different from this Act. In the first case the content of the document or the method of delivery may be varied as prescribed by Ordinance of the Prime Minister.

Article 13(6) matters for any brand running a subscription. Where a recurring payment is increased, or goods supplied free convert to a paid subscription, the operator must obtain the consumer's consent to the timing, the price before and after the change and the payment method within a period prescribed by Presidential Decree before that increase or conversion, and must notify the conditions, methods and effects of cancelling or terminating it.

4. The eleven cosmetics entries on a product page

Article 13(4) allows the Fair Trade Commission to set, by notice, the content and method of the display, advertisement and notification of information about the goods and the transaction terms. The notice issued under that delegation is the Notice on Provision of Information on Goods in Electronic Commerce.

Part II.1 of the notice requires a mail-order distributor selling goods through a mail-order channel to display, advertise or notify, before the contract is concluded, both the category-specific information on the goods and the information on transaction terms, in that channel. The categories run from (1) clothing to (40) other goods, and cosmetics are (18). Part II.2 directs operators to follow the entries of the closest category, judged by the product's characteristics, function and utility and by consumer perception, and to fall back on (39) other services or (40) other goods where no similar category exists.

Category (18) cosmetics has eleven entries.

The transaction-terms information is required regardless of category. Part III.2 lists the delivery method and the expected delivery period, delivery costs including surcharges for islands and remote areas, the period for withdrawal and the return costs borne by the consumer where the withdrawal is a simple change of mind, the specific grounds and basis where withdrawal on a simple change of mind is not possible, the period and the return costs borne by the distributor where the withdrawal follows a defect or a wrong delivery, the exchange, return and warranty conditions and the quality warranty standard, the after-sales service telephone number, the refund method and the conditions and procedure for delayed-refund compensation, the handling of consumer damages, complaints and disputes, and the terms and conditions or the way to check them.

Part II.5 prescribes how the quality warranty standard is to be given. The operator must state the specific compensation standard for defects, or state that compensation is available under a named compensation scheme; and where the scheme applied is not the Consumer Dispute Resolution Standards under Article 16 of the Framework Act on Consumers, the way to find that scheme must be given alongside it.

5. What you left off the label does not fall off the page

Article 10(1) of the Cosmetics Act sets ten entries for the outer package, and the proviso to that paragraph allows a package of small content volume, as prescribed by Ordinance of the Prime Minister, to carry only the name of the cosmetic, the trade name of the responsible distributor and the customised cosmetics seller, the price, the batch number and the use-by date or period after opening. The conditions and the reach of that reduction are covered in small packs, testers and samples.

The seventh entry in the notice, however, is every ingredient that has to be stated under the Cosmetics Act. Nothing in the notice says that entry shrinks because the printed ingredient list was shortened for a small pack. Article 19(5) of the Enforcement Rule of the Cosmetics Act points the same way: where the operator omits the ingredient statement under Article 19(1) or Article 19(2)3, the package must carry a telephone number or website address through which the consumer can immediately check every ingredient, or printed matter listing every ingredient must be kept at the point of sale.

The way the parties are named differs too. Article 10(1)2 of the Cosmetics Act requires the trade name and address of the business operator, while the fifth entry in the notice requires the cosmetics manufacturer, the cosmetics responsible distributor and the customised cosmetics seller. The label shows a trade name and an address; the product page has to make the type of operator visible. For a product made under contract manufacturing, that means the manufacturing party's details belong on the page.

The country of manufacture works the same way. The sixth entry in the notice requires it, while origin marking moves under the Foreign Trade Act on its own track. That boundary is set out in what "Made in Korea" actually means.

6. When an entry cannot be filled

Part II.3 of the notice provides that where a mail-order distributor cannot provide information for an entry, it must give the specific reason and endeavour to provide information of an equivalent kind. The notice carries an illustrative sentence using the date of manufacture: it gives the reason that the goods ship directly from the production site so the date of the unit that will be delivered is not known, states that a product made within a given number of days of the order date will be shipped, and gives a contact number at the producer.

Entries that vary by stock have their own route. Part II.4 covers the year and month of manufacture, the date of manufacture, the distribution period, the use-by date, the quality retention period and the consumption date, and sets three alternatives for them: the earliest such date among identical products held for sale, the range across all identical products held, or, for categories with fast stock rotation or where the operator cannot track each physical unit's date, a period calculated from the order date or the dispatch date.

Cosmetics use this provision often. The same product carries different use-by dates by incoming lot, and where the period after opening is stated the date of manufacture has to appear alongside it. The difference between the two is covered in shelf life and period after opening.

7. How the information is presented is prescribed as well

Part IV of the notice governs presentation.

Part IV.1 requires the information given to consumers to be provided clearly, choosing position and text size with regard to colour differentiation, the use of borders and the overall screen size, so that consumers can take it in easily. It also recommends that the category-specific information be displayed ahead of the product introduction. A recommendation is weaker than a duty, but it is clear that pushing the whole list into small type at the bottom of the page is not the direction the notice points in.

Part IV.2 is stronger. Information on certification or authorisation among the category-specific entries must be shown clearly in text of a size consumers can easily read, and cannot be replaced by a note such as "stated separately on the product" or by posting a photograph in which the consumer cannot properly make out the certification or authorisation number. That sentence addresses certification and authorisation information, and the notice does not state whether the functional-cosmetic review or reporting phrase falls within it. Setting the phrase out as readable text, rather than leaving it visible only as print inside a packshot, is the safer course.

Part IV.3 requires the information to be written in terms consumers can understand, and where a foreign word or technical term is unavoidable, its specific meaning is to be added immediately beside it by a note or similar means. If your page lists ingredient names only in their English form, this is the sentence to check it against.

8. Who marks the selling price?

Article 10(1)7 of the Cosmetics Act makes the price one of the label entries, but Article 11(1) requires that price to be marked by the party selling the cosmetic directly to consumers, that is, the seller, as the price at which it intends to sell. Article 20 of the Enforcement Rule requires the seller to mark the intended selling price on the product's package so that ordinary consumers can read it easily, and delegates the detailed marking method to a notice of the Minister of Food and Drug Safety.

That notice is the Guidelines for Implementing the Cosmetics Price Marking System. Article 2 defines the party under the marking duty as the party selling cosmetics to general consumers, and the selling price as the actual price at which cosmetics are sold to general consumers. Article 3 makes every cosmetic manufactured or imported and sold in Korea subject to price marking.

Article 4 is the operative one. The main text of paragraph (1) makes the retailer the party under the duty where the sale is through a retail outlet, and the proviso adds that for door-to-door sales and sponsored door-to-door sales under the Act on Door-to-Door Sales, and for mail-order business under the Act on Consumer Protection in Electronic Commerce, that business operator marks the selling price, while for multi-level sales the seller does. That is where a brand selling online becomes the party that marks the price.

Article 4(2) closes the other side. A cosmetics responsible distributor or cosmetics manufacturer that is not the party under the duty in paragraph (1) must not mark the selling price. Printing a recommended price on the package of a product that moves through distribution can run into this provision. Paragraph (3) provides that the party under the duty must not sell, or display or exhibit for sale, without marking the price, regardless of the size of the premises.

The marking method sits in Article 6. Paragraph (1) requires a sticker or tag that is not easily damaged, erased or detached during distribution. Paragraph (2) requires a changed price to be marked so that the previous marking is no longer visible, except where the seller changes the price for a specified period, informs consumers of that period, and marks it clearly enough that it cannot be confused with the previous price. Paragraph (3) requires a sticker on each individual product, while allowing a combined marking on a set of individual products that is not sold separately. Paragraph (4) allows a seller that cannot mark individual products, given its business type, the kinds of products handled and the internal display arrangement, to mark the selling price separately by presenting information including the product name and the price in the way consumers can most easily see, in which case the individual products need not carry it. Paragraph (5) requires the marking to be clear and legible.

One point deserves care. The notice names the mail-order business operator as the party under the duty, but Article 6's marking methods are written around stickers and tags on packaging. The notice does not separately describe how a price shown on a screen is to be treated, so the specific application is worth confirming with the competent authority. On the e-commerce side, in any case, Article 13(2)3 makes the price one of the matters to be displayed, advertised or notified by an appropriate method, so there is no option in which the price goes unstated in the sales process.

9. How liability divides on an open market

Listing on an open market rather than your own shop adds another set of provisions. Article 2(4) defines mail-order brokerage as permitting the use of a cyber mall, or otherwise arranging mail-order sales between the parties by a method prescribed by Ordinance of the Prime Minister.

Article 20(1) requires a mail-order broker to give advance notice, by the method prescribed by Ordinance of the Prime Minister, that it is not a party to the mail-order transaction, in a way consumers can easily grasp. Paragraph (2) requires a mail-order brokerage business operator, where the party requesting brokerage is a business operator, to verify that party's name — or, for a corporation, its name and the representative's name — address, telephone number and other identity information prescribed by Presidential Decree, and to provide it to consumers before the offer is made. Paragraph (3) requires prompt action, including identifying causes and harm, to resolve complaints or disputes arising from use of the cyber mall.

The division of liability sits in Article 20-2. Paragraph (1) makes a broker that failed to give the Article 20(1) notice jointly liable with the party requesting brokerage for property damage caused to consumers by that party's intent or negligence. Paragraph (2) imposes the same joint liability for damage caused by failing to provide identity information or by providing information that turns out to be untrue, except where the broker exercised considerable care to prevent harm to consumers.

For a brand, paragraphs (3) and (4) matter most. The main text of paragraph (3) provides that, notwithstanding the Article 20(1) notice, a broker that is itself a mail-order distributor is not relieved of a mail-order distributor's responsibilities under Articles 12 through 15, 17 and 18; the proviso adds that where the brokerage is carried out at the request of a mail-order distributor, the requesting party bears responsibility for the part it agreed to bear and that was notified to consumers. Paragraph (4) provides that a requesting party that is a business operator is not exempted from property damage caused to consumers by the broker's intent or negligence merely because it was the broker's act, except where it exercised considerable care to prevent harm.

In short, listing on an open market does not by itself release the platform from its statutory duties or transfer all of the seller's responsibility to the platform. The duties each party carries under the Act, and what the listing agreement allocates and notifies to consumers, have to be read together.

10. The provisions to read alongside the product page now

The Act on Consumer Protection in Electronic Commerce currently in force was amended as Act No. 21312 and took effect on 21 July 2026. Two provisions sit closest to the product page: Article 21-4, added by that amendment, and Article 21-2, added in 2024 and already in application. The existing prohibition in Article 21(1)1 is noted at the end of this section as well.

The first is Article 21-4. Where a business operator engaged in electronic commerce or a mail-order distributor posts consumer reviews of goods traded through a cyber mall, it must disclose information on how those reviews are collected and handled, including the posting period, the criteria for rating and deletion, and the objection procedure where a review is deleted. Paragraph (2) delegates the specific content and scope of the disclosure, and the method and procedure, to Presidential Decree. If your rules for running review events or for deleting reviews have lived only in an internal document, the information the provision lists — the posting period, the rating and deletion criteria, the objection procedure — is what has to be disclosed.

The second is Article 21-2(1)1. On the first screen of a display or advertisement that tells consumers the price of goods through a cyber mall, it is prohibited to attract or trade with consumers by displaying only part of the total amount they must necessarily pay in order to buy or use those goods. The total amount includes the costs necessarily incurred to provide the goods on top of the price itself. The proviso excepts cases where there is a legitimate reason why the total amount cannot be displayed and that reason is given to consumers as prescribed by Ordinance of the Prime Minister.

That provision is part of Article 21-2, added on 13 February 2024. The same paragraph also prohibits marking an option as accepted before the consumer chooses, drawing differences in size, shape or colour between options that are conspicuous enough to mislead consumers into thinking only one option can be chosen or that a particular option is mandatory, designing cancellation, withdrawal or termination to be more complex than the purchase path or allowing it only by a method different from the purchase method, in both cases without a legitimate reason, and repeatedly asking through pop-ups that consumers change a choice they have already made. The last of those carries a proviso for the case where consumers can choose not to receive such requests for at least a period prescribed by Presidential Decree. It is the list to read when designing a promotion or a bundle.

The prohibition in Article 21(1)1 remains in place as well: informing consumers of false or exaggerated facts, or using deceptive methods, to attract them, to trade with them, or to obstruct withdrawal of an offer or termination of a contract.

11. The Cosmetics Act's advertising rules stay in place

Changing the medium to a web page does not remove the cosmetics-side advertising rules. Article 13(1) of the Cosmetics Act prohibits a business operator or a seller from making a display or advertisement liable to be mistaken for a medicine, one liable to make a non-functional cosmetic be mistaken for a functional cosmetic, or one whose content differs from the review result on the safety or efficacy of a functional cosmetic, or any other display or advertisement liable to deceive consumers or to make them misunderstand contrary to fact. The subject is a business operator or a seller, so it applies to a party that sells without manufacturing.

The substantiation system in Article 14 moves with it. Which wording calls for which evidence is set out in advertising claims and the evidence behind them. A product page has far more room than a label, which makes claims easy to add, and a statement relating to facts has to be capable of substantiation.

One timing point has to be kept separate. An amended version of Article 13 of the Cosmetics Act has been promulgated with effect from 27 November 2026. The amended provision adds to the prohibited list an advertisement that uses artificial sound, images or video generated by an artificial intelligence system and hard to distinguish from the real thing, where it is liable to create the false impression that a doctor, dentist, oriental medical doctor, veterinarian, pharmacist, oriental pharmacist, university professor or other relevant expert guarantees, designates, certifies, recommends, instructs on or uses the cosmetic. If generative tools are in your plan for advertising assets, review this before the effective date.

12. What to obtain from the manufacturing side in advance

Some product-page entries cannot be written by the brand alone. Settling them during development means they can be checked once, rather than chased at launch.

Some entries, equally clearly, cannot come from the manufacturer. The quality warranty standard, the consumer enquiry number, the withdrawal policy, delivery and return costs, and the rules for running customer reviews belong to the selling side. Drawing that line early removes the stretch at launch where each side waits for the other.

13. Frequently asked questions

Manufacturing is outsourced but I do the selling. Who is responsible for the product page?

The party selling to consumers, that is, the mail-order distributor. The definition in Article 2(3) does not ask who made the product. That said, entries that come out of the product itself — the ingredient list, the country of manufacture, the use-by date — can only be filled with what the manufacturing side provides. It is worth settling in the contract that the party responsible and the source of the data are not the same party.

If I post a photograph of the label, is the product-page duty met?

Part IV.2 of the notice provides that information on certification or authorisation among the category-specific entries must be shown clearly in text of a size consumers can easily read, and cannot be replaced by a note such as "stated separately on the product" or by a photograph in which the number cannot properly be made out. Use the label photograph as support, but write the entries themselves as readable text.

We shortened the ingredient list on a 10 mL mini size. Can the product page be shortened too?

The seventh entry in the notice is every ingredient that has to be stated under the Cosmetics Act. Nothing in the notice allows that entry to be cut because the pack is small. Article 19(5) of the Enforcement Rule of the Cosmetics Act points the same way, requiring a telephone number or website address through which every ingredient can be checked, or printed matter kept at the point of sale, where the statement is omitted under Article 19(1) or Article 19(2)3.

Does a wholesale-only B2B site have to meet these duties?

Article 3(1) provides that the Act does not apply to transactions in which a business operator purchases for the purpose of a commercial activity. But the proviso removes from that exclusion a transaction in which a business operator, in substance, trades in the same position and on the same terms as a consumer. The fact that general consumers can also buy on the same site does not settle the question on its own; whether a given transaction meets that test has to be checked separately.

What has to be settled before running a review event?

Article 21-4 requires a business operator engaged in electronic commerce or a mail-order distributor that posts consumer reviews of goods traded through a cyber mall to disclose how those reviews are collected and handled, including the posting period, the criteria for rating and deletion, and the objection procedure where a review is deleted. The specific content and scope of that disclosure, and its method and procedure, are delegated to Presidential Decree. Writing the internal operating rules down first and then deciding the public form is the natural order. The treatment of reviews given in exchange for consideration under the labelling and advertising rules was not examined in this guide.

14. Next steps

A product page looks like marketing, but half of what goes on it is settled during development. The ingredient list, the volume, the use-by date, the country of manufacture and functional status are fixed while the product is being made; the quality warranty standard, the enquiry channel and the withdrawal policy are set by the selling side. Keeping both groups in one document removes the stretch before launch where each side waits for the other.

If you have a project under way, send the product type and size line-up, your plan for functional claims, and the sales channels you intend to use to development consultation. We will work back from what the product page has to carry and review it together with the development schedule. How development proceeds step by step is set out in the development process, and formulation material is in formulation development.

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