Writing a Cosmetics Product Brief for a Korean Manufacturer: Which Fields Lock the Route and the Schedule

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The short answer: a brief is a record of decisions, not a list of preferences

The fields to fill in first are not the texture notes or the reference products. They are these five: who the responsible distributing business is, whether you intend to make a functional-cosmetics claim, where the product will be sold, whether you will present it as a product for infants or children, and what the volume and primary packaging will be. Once those five are answered, the procedure you have to follow and the documents you have to prepare become fixed, and the schedule and the quotation stop moving every time something is decided.

The rest can be narrowed down as development proceeds. Sensory priorities, fragrance direction and container feel are all adjusted while you review samples. The five fields above work differently: changing them late moves testing that is already finished, labels that are already printed and documents that have already been filed.

This article keeps the six preparation questions from the original version and adds what each answer actually unlocks, how to record a field you have not decided yet, and what belongs on a one-page brief.

The scope is Korean law. The Act and the Enforcement Rule cited here were checked against the current text on the Korean Law Information Center on 18 October 2026. This is not legal advice for a specific case, and it makes no claim about EVAS minimum order quantities, prices, lead times or testing records.

Key points

• Five fields set the route: the responsible distributing business, the functional claim, the sales territory, infant or child labeling, and the volume with its primary packaging.
• Functional cosmetics have to be reviewed or reported item by item, and Article 4(1) of the Cosmetics Act adds that the same applies "when any reported or reviewed matter is modified." The point at which the formula has to be locked moves earlier.
• If you intend to label or advertise a product as usable by infants or children, the three product safety data sets have to be prepared in advance. The retention period runs from a different starting point depending on whether the primary packaging shows a use-by date or a period after opening.
• Packaging of 10 mL or less, or 10 g or less, may carry a reduced set of label items, and the band above it, over 10 mL up to 50 mL, may omit some ingredient entries. Deciding the volume is deciding the label.
• A product that is not sold domestically and is intended solely for export may, under Article 30 of the Act, follow the importing country's rules instead of a listed set of provisions. That exception is not available if you also plan to sell in Korea.
• If there is a claim you want to use in advertising, write it into the brief. Factual matters in labeling and advertising have to be substantiable, and substantiation data has to be submitted within 15 days of a request.

What should you prepare before a development consultation?

You can discuss a product's direction without a finished formula or packaging mockup. Start by setting priorities for the customer, usage occasion and sensory experience. This makes the samples to compare and the questions to ask more specific.

One addition changes the density of that first meeting: write down what has been decided and what has not, separately. A brief is not a document in which every field is filled. It is a document in which both sides read the empty fields the same way. Once an empty field is visible, you can agree on the information and the date needed to close it.

The six questions below follow the order you would use when preparing for a first consultation. Under each one is what the answer actually decides.

1. Who will use the product, and when?

Describe the usage situation rather than listing only an age group. Washing the face on a busy morning, cleansing the scalp after exercise and bodycare after a shower call for different product experiences. If your brand is already selling products, recurring customer questions and frustrations are also useful starting points.

One part of this is procedure rather than preference. The brief has to state clearly whether you intend to label or advertise the product as one that infants or children can use. Article 10-2(1) of the Enforcement Rule of the Cosmetics Act defines infants as three years old or under and children as four to thirteen years old. Paragraph 2 of the same article sets the scope of labeling and advertising that triggers the data obligation: for labeling, it is the case where the primary or secondary packaging specifically indicates that the product can be used by infants or children, and that includes cases where the product name itself carries such an expression.

Where that intention exists, Article 4-2(1) of the Act requires the cosmetics responsible distributing business operator to prepare and retain product safety data, namely an explanation of the product and its manufacturing method, cosmetic safety assessment data, and evidence of the product's efficacy and effects. Article 10-3(1) of the Enforcement Rule states that all three have to be prepared in advance. These are not documents you assemble after launch.

The retention period is tied to a labeling decision as well. Paragraph 2 of the same article distinguishes two cases: where the primary packaging shows a use-by date, the period runs from the day of the labeling or advertising until one year after the use-by date of the last product manufactured or imported; where the primary packaging shows a period after opening, it runs until three years after the manufacturing date of the last product manufactured or imported. Change the way the date is expressed and the end of the retention obligation changes with it.

One label item is added too. Article 19(4), item 8 of the Enforcement Rule requires the content of preservatives, among ingredients whose standards for use have been designated and announced, to appear on the packaging where the product is specifically labeled or advertised as usable by infants or children. The detail is covered in the guide to safety data for baby and kids cosmetics.

2. Which sensory qualities matter most?

Prioritize qualities such as light spreadability, a rich feel during massage, quick rinsing and residual feel. If you have a product you like, explain what you like about it rather than sharing only its name. Reference products help explain the development direction; they do not imply an identical formula.

Sensory qualities are narrowed down across sample rounds. What shortens those rounds is writing down what you are willing to give up. When reducing tackiness and extending the moisturizing feel pull against each other, noting in advance which one comes first saves a meeting after the samples arrive.

How to set comparison criteria is covered in the sample feedback guide, and the choice between adjusting an existing formula and designing a new one is in base formula versus custom formulation. If the form of the product is not settled yet, from a formulation idea to an actual product is a good place to start.

3. Where will you sell the product?

The experience conveyed through an online product page may differ from a hands-on experience in a store. Sharing the target countries, channels, price range and size helps with reviewing product and packaging conditions.

Sales territory is one of the first fields that should be closed. Article 30 of the Cosmetics Act provides that for products that are not sold domestically and are intended solely for export, Article 4, Articles 8 through 12, Article 14, Article 15, items 1 and 5, Article 16(1), items 2 and 3, and Article 16(2) do not apply, and the rules of the importing country may be followed instead. Functional-cosmetics review, the domestic labeling standards and domestic advertising substantiation are all on that list.

The point to watch is that the exception applies only to products not sold domestically. If the same product is also planned for the Korean market, the domestic requirements have to be met from the start, and adding domestic sales late means rebuilding labels and documents. Whether the product is export only or sold in both markets is worth a single line in the brief. The distinction is covered in the export-only cosmetics guide and in Made in Korea origin marking.

If you are planning online sales, check the information that has to be provided on a product listing as well. It is set out in the online product information guide.

4. Which conditions are essential, and which can be adjusted?

Separate requirements such as essential ingredients, fragrances to avoid, preferred containers and the desired launch date. Rather than fixing every condition at once, agreeing on the non-negotiable criteria first makes decisions easier during development.

In practice it helps to order these not by importance but by how expensive they are to undo. The expensive ones are usually the items tied to paperwork and printing.

• A functional claim: it brings a review or report procedure, and changing it afterwards means going through that procedure again.
• Container and packaging components: compatibility with the contents, tooling and print preparation all move together. See the packaging compatibility guide and packaging environmental rules.
• Fragrance and the ingredient list: changing a fragrance composition can change the ingredient declaration, and the label artwork follows. This is covered in the ingredient selection guide.
• Use-by date or period after opening: this is tied to the stability study schedule. See shelf life and period after opening.

What can stay open longer is the detail of the carton design, set composition and promotional extras, in other words the parts that do not affect the contents or the primary packaging.

Which fields in the brief decide the legal route?

Taking the five fields one at a time:

First, who is the cosmetics responsible distributing business operator. Article 3(1) of the Cosmetics Act requires anyone who intends to run a cosmetics manufacturing business or a cosmetics responsible distribution business to register with the Minister of Food and Drug Safety, and adds that "the same shall apply where any important registered matter prescribed by Ordinance of the Prime Minister is modified." Under Article 3(3), a business registering as a responsible distributor has to meet the standards for quality control and post-distribution safety control and appoint a responsible distribution manager. Article 4(2) of the Enforcement Rule requires the registration application to be accompanied by the internal rules meeting those standards and by documents confirming the manager's qualifications. Whether the brand itself becomes the responsible distributor or another company takes that role determines who carries the labeling duty and who retains the data. More detail is in the duties of a private-label brand owner and the business registration guide.

Second, whether you will use a functional claim. Article 2 of the Enforcement Rule lists eleven categories of functional cosmetics: two forms of skin whitening, improvement of wrinkles, helping the skin tan evenly under strong sunlight, protection against ultraviolet rays, change of hair color (excluding products that change the color temporarily), removal of body hair (excluding products that remove it physically), relief of hair loss symptoms (excluding products that make hair look thicker physically, such as by coating), relief of acne-prone skin (limited to personal cleansing products), restoration of the skin barrier function, and reduction of the red lines caused by stretch marks. Article 4(1) of the Act requires an item-by-item review or report on safety and efficacy before a product can be sold as a functional cosmetic, and then adds that the same applies "when any reported or reviewed matter is modified." The review dossier is set out in Article 9(1) of the Enforcement Rule and runs to the origin and development history, safety data, efficacy or functional data, the data supporting the sun protection factor and the UVA protection grade for sun protection products only, and "data on the standards and test methods [including a sample specimen]." It is not a paperwork-only procedure. The proviso to the same paragraph does allow items whose active ingredient and content have been announced to omit the data under items 1 to 4, and items whose standards and test methods have been announced to omit the data under item 5. Where the conditions are met a report can replace a review, but Article 10(1), item 2 of the Enforcement Rule requires the type, specification and content of the raw material that produces the efficacy and effects, the efficacy and effects, the standards and test methods, the dosage and administration, and the dosage form all to be the same as an already reviewed item, and it notes that the standards exclude "standards concerning the degree of acidity (pH)." That route is limited to cases where the cosmetics manufacturer of the already reviewed item is the same (only where the manufacturer designed, developed and produced the product), or the responsible distributing business operator is the same, or the reviewed research institution is the same. Related practice is covered in hair-loss relief claims for shampoo and SPF and PA labeling.

Third, where the product will be sold. This is the export-only exception under Article 30 discussed in question 3 above.

Fourth, whether you will label or advertise the product for infants or children. The product safety data and the preservative content declaration discussed in question 1 above follow from it.

Fifth, the volume and the primary packaging. The next section covers this separately.

One forward-looking item is also worth a note in the brief. An amendment of 30 December 2025 inserts Article 4-2 (cosmetic safety assessment) into the Act, requiring a responsible distributing business operator to prepare, before distribution and sale, data substantiating that each product is safe, to have it reviewed by a safety assessor, and to retain it. The commencement dates are staged from 1 January 2028 to 1 January 2031 depending on the annual production or import value of the business and the type of product, and the same amendment moves the current Article 4-2 on cosmetics for infants and children to Article 4-3. If the launch date you are planning falls inside that window, it is worth checking early.

Why do the volume and the primary packaging have to be decided first?

How much text fits on a label is not a design question. It is a volume question.

Article 10(1) of the Cosmetics Act lists what has to appear on the outer packaging: the name of the cosmetic, the trade name and address of the business operator, all ingredients used in manufacturing (excluding ingredients prescribed by Ordinance of the Prime Minister, such as harmless ingredients present in trace amounts), the volume or weight of the contents, the manufacturing number, the use-by date or period after opening, the price, the functional-cosmetics indication where applicable, and the precautions for use. The proviso to that paragraph allows packaging prescribed by Ordinance of the Prime Minister, such as packaging for cosmetics with a small content volume, to carry only "the name of the cosmetic, the trade name of the cosmetics responsible distributing business operator and the customized cosmetics selling business operator, the price, the manufacturing number and the use-by date or period after opening," with the manufacturing date shown alongside whenever a period after opening is used.

The packaging covered by that proviso is defined in Article 19(1) of the Enforcement Rule: packaging of cosmetics with a content of 10 mL or less or 10 g or less, and packaging of cosmetics manufactured or imported for consumers to try in advance rather than for sale. Cosmetics announced as requiring special care in use are excluded, and for the try-before-you-buy packaging the price means an indication such as "sample" or "not for sale."

The band above it has its own rule. Article 19(2), item 3 of the Enforcement Rule allows some ingredient entries to be omitted on packaging with a content over 10 mL up to 50 mL, or over 10 g up to 50 g, but not tar colorants, gold leaf, the types of phosphate in shampoos and rinses, alpha hydroxy acids, the raw material responsible for the efficacy of a functional cosmetic, or raw materials for which a maximum use level has been announced. Where entries are omitted, Article 19(5) requires either a telephone number or website address on the packaging so consumers can check the full ingredient list immediately, or printed material carrying the full list kept available at the point of sale.

The primary packaging has a minimum set of its own. Article 10(2) of the Act requires the primary packaging of a cosmetic that also has secondary packaging to carry the name of the cosmetic, the trade name of the business operator, the manufacturing number, and the use-by date or period after opening, with an exception for solid soap and similar products where consumers remove the primary packaging before use. Article 19(6) of the Enforcement Rule defines that exception as cosmetic soap, which Article 2-2 of the same Rule defines as face-cleansing soap in solid form.

So deciding the volume and the container is simultaneously deciding the label area and the way the dates are expressed. A 10 mL sample and a 50 mL full size are not the same artwork at two scales. The detail is in the small packaging labeling guide and the precautions for use guide.

5. Have you organized reference materials and identified decision-makers?

Gather market reference products, mood boards and existing customer feedback in one place. Assigning someone to consolidate sample feedback helps organize differing opinions.

While you are naming people, it is worth recording who retains each document. As described above, the duty to prepare and retain product safety data sits with the responsible distributing business operator. Ownership of the formula and the scope of access to test data are matters for the contract, so it is worth reading who owns the formula alongside this. Which tests are run at the finished-product stage, by whom, and who receives the results is covered in the batch release testing guide.

The decision structure needs one line. If the person who collects sample feedback, the person who approves the specification and the person who signs off the label copy are different people, saying so is enough to reduce the number of rounds.

Should the claims you want to advertise go in the brief too?

Yes. Even if the copy is not written, the direction of what you want to say belongs in the brief, because whether that claim needs substantiation changes what has to be prepared during development.

Article 14(1) of the Cosmetics Act provides that a business operator or seller has to be able to substantiate factual matters in its own labeling and advertising. Article 14(3) requires substantiation data to be submitted within 15 days of the request (the period may be extended where there is a justifiable reason), and Article 14(4) provides that where the operator continues the labeling or advertising without submitting within that period, an order to suspend the labeling or advertising has to be issued until the data is submitted.

The requirements for that data are in Article 23(2) of the Enforcement Rule. Test results have to be human application test data, non-human test data, or research data of an equivalent or higher standard; survey results require the sampling, the questions and the survey method to be consistent with the purpose of the survey and with statistical method; and the method of substantiation has to be scientific and objective, either academically well known or generally accepted in the relevant industry. A sensory questionnaire collected during development does not meet those requirements as it stands.

Where the line falls between label copy and advertising is covered in the advertising substantiation guide, and disclosure for seeded reviews and influencer posts is in the sponsored review disclosure guide.

6. What should you confirm at the first consultation?

Confirm the development scope suited to your product direction, sample comparison criteria, container and packaging-component reviews, and the basis for discussing schedules and quantities. MOQ, unit price and lead time are reviewed individually according to the item and conditions; they are not fixed using general figures before consultation.

One more thing is worth confirming: the scope of the quotation. The same unit price means different things depending on whether it covers the bulk only, filling and assembly, or the container and carton as well. If you already have quotations in hand, the quotation comparison sheet shows how to separate what is included, what is charged separately and what is still undecided, and if the quantity is the open question, start with the small-batch and MOQ guide. If you are still comparing development models, OEM, ODM and private-label routes is the place to begin.

How do you write a field you have not decided yet?

Do not leave it blank. Write its status instead. Four are enough.

• Fixed: a condition that will not change. Add one line on what it was fixed against.
• Adjustable: a condition that can move. Note what it can be traded against, for example schedule against container specification.
• Undecided: not settled yet. Note the information needed and the date by which it will be decided.
• Not applicable: excluded from this project. Note why it is excluded.

A blank field reads as "anything is fine," and the fields read that way turn into the most expensive revisions later. For the five fields above in particular, write "undecided" with a date rather than nothing at all.

Start with a one-page brief

The twelve lines below are enough for a first consultation. Mark each line with one of the four statuses above.

1. Product and size: category, volume, number of items
2. Target and usage occasion: who uses it, when and how
3. Infant or child labeling plan: yes or no
4. Desired sensory experience: two or three priorities, plus what can be given up
5. Reference products and why: the reason before the name
6. Functional claim plan: the claim you intend to use, or none
7. Sales territory: domestic, export only or both, with the target countries
8. Sales channels: online, offline, duty free, distributors
9. Container and packaging direction: preferred container, carton or not, set composition
10. How the date will be shown: use-by date or period after opening
11. Schedule: target launch and any date that cannot move
12. Decision structure: who consolidates feedback, who approves the specification, who signs off the copy

Once those twelve lines exist, the consultation stops being a product description and becomes the work of filling in the empty fields.

What this article does not cover

• The detailed preparation requirements and exemption scope for functional-cosmetics review dossiers sit in a separate Ministry of Food and Drug Safety notice and are outside the scope of this article.
• Notification for a customized cosmetics selling business and the requirements for a customized cosmetics preparation manager are a separate subject.
• Registration and notification procedures and ingredient rules in importing countries differ by country; this article covers Korean law only.
• Contract drafting, confidentiality and exclusive supply terms are outside the scope of this article.
• The detailed criteria for packaging material and structure assessment and for separate-disposal marking are covered elsewhere.

Frequently asked questions

Can we have a consultation without a brief?

Yes. A target customer and the purpose of the product are enough to start the conversation. The five fields have to be settled at some point, so simply recording that they are open today makes the next step clear.

Can a functional claim be added later?

It can, but a procedure comes with it. Article 4(1) of the Cosmetics Act sets the item-by-item review or report requirement and adds that the same applies when a reported or reviewed matter is modified. The formula, the label and the test data move together, so the schedule and the cost are recalculated.

If we only export, can we ignore the Korean requirements?

The exception in Article 30 of the Cosmetics Act applies to products that are not sold domestically and are intended solely for export. If you also plan domestic sales, or add them later, the domestic requirements have to be met separately. The importing country's rules have to be checked on their own.

What if we never say "for children" but the artwork simply looks child friendly?

Article 10-2(2) of the Enforcement Rule defines the labeling that triggers the data obligation as the case where the primary or secondary packaging specifically indicates that infants or children can use the product, and it includes cases where the product name carries such an expression. Because the assessment depends on the wording and the medium, it is safer to settle this at the planning stage.

Can we ask for an exact copy of the reference product in the brief?

A reference product explains a direction. Reproducing an identical formula is a different matter, and ownership of a formula and the scope of its use are set in the contract. Telling us what you liked about it lets us design toward that characteristic.

Can we receive samples first and write the brief afterwards?

You can. Without criteria, though, a sample round produces only "good" and "not quite." Writing just three of the twelve lines first, the category and size, the target, and the sensory priorities, is enough to give the comparison an axis.

Next steps

A brief is not a finished plan. It is a single page recording the current state of your decisions. Separate what is settled from what is not, close the five fields that are hard to undo, and the consultation becomes a place to decide rather than a place to explain.

EVAS runs planning, design, research, manufacturing, logistics and brand content together in house. You can look through the formulation library for a development direction, or fill in as many of the twelve lines as you can and send them through a consultation request. We will work through the empty fields with you and set out what to confirm next.