
AI-generated image.
The short answer: a compensated review is allowed, but it has to be labelled as advertising
A review is not prohibited merely because you paid for it, but an economic interest capable of affecting the endorsement's content or credibility has to be disclosed, and the disclosure itself has to satisfy four conditions at once: where it appears, how visible it is, what it says, and which language it uses. The Korea Fair Trade Commission's review guideline sets those four out medium by medium, in fairly concrete terms.
For cosmetics, however, some endorsements remain prohibited even when disclosed. Labelling or advertising stating, or implying, that a doctor, a pharmacist, or another medical or pharmaceutical expert recommends or uses the product is prohibited by the Enforcement Rule of the Cosmetics Act, so no amount of correct ad labelling makes it usable. That means a campaign brief has to answer two separate questions. What must this post disclose, and may this person appear at all?
It is also worth saying up front that disclosure is only one axis. Whether a compensated review is acceptable also turns on whether its content matches actual experience, whether the advertiser distorted it, and whether factual claims can be substantiated.
This guide reads both questions directly from the provisions and the guideline text: who carries the disclosure duty, which forms of compensation trigger it, how narrow the exception is, where the wording has to sit in text, photo, video, and live broadcast, what has to be revealed when an AI-generated virtual person appears, and why the sanctions run along two separate tracks.
The scope is Korean law and advertising aimed at consumers. Every provision and guideline passage cited here was read in the original on the Korean Law Information Center on 15 October 2026. This is not legal advice for a specific matter, and it makes no claim about EVAS commercial terms, facilities, or test records.
Key points
- The backbone of the disclosure duty is deceptive labelling or advertising under Article 3, paragraph (1), item 2 of the Fair Labeling and Advertising Act. Article 3, paragraph (2) of its Enforcement Decree defines deceptive labelling or advertising as labelling or advertising "by means of concealing or reducing facts", and section Ⅳ.2 of the Review Guideline on Endorsement Advertising states that failure to disclose an economic interest may constitute unfair labelling or advertising.
- The disclosing party is the advertiser or the endorser. Section Ⅴ.6(a) lets either one do it, and requires that every single endorsement make clear to consumers that it is commercial labelling or advertising.
- The listed forms of compensation are cash, the product itself, gift certificates, accumulated points, discount benefits, and being directly employed by the advertiser. Arranging group purchases sits on the same line.
- The exception is narrow. Where an economic interest exists but does not affect the content or credibility of the endorsement, it may be left undisclosed, and the guideline's example is a cosmetic sample given to every applicant, followed by a voluntary review.
- The wording has its own requirements. The position must be close to the endorsement, the form must stand out from the background, the content must be clear, and the language must match the endorsement. The guideline lists expressions such as "trial review", "review team", "gift", "AD", "PR", "Sponsor", and "Ambassador" as inadequate.
- For cosmetics, one prohibition is not solved by disclosure. Item 2(c) of Attached Table 5 to the Enforcement Rule of the Cosmetics Act forbids labelling or advertising stating, or implying, that a doctor, dentist, oriental-medicine doctor, pharmacist, medical institution, or other medical or pharmaceutical expert designates, certifies, recommends, guides, researches, develops, or uses the cosmetic.
- An AI-generated virtual person must be disclosed as such. Section Ⅴ.5 requires that where a virtual person hard to distinguish from a real one endorses a product, the fact be shown in a way consumers recognise clearly and easily.
- Sanctions come from two agencies. On the Fair Trade Commission side: corrective orders, a surcharge not exceeding 2 percent of turnover, no-fault damages liability, and up to two years' imprisonment or a fine of up to 150 million won. On the Ministry of Food and Drug Safety side: administrative action under Article 24, paragraph (1), item 10 of the Cosmetics Act, and up to one year's imprisonment or a fine of up to 10 million won under Article 37, paragraph (1).
1. One campaign, two sets of rules
If you research a review campaign in one place only, you will miss half of it. Two separate regimes apply, administered by two different agencies.
The first is the Fair Trade Commission side. Article 3, paragraph (1) of the Fair Labeling and Advertising Act provides that a business entity shall not engage in, or cause another business entity to engage in, labelling or advertising that is likely to deceive or mislead consumers and to undermine fair trade order. The four prohibited types are false or exaggerated, deceptive, unfairly comparative, and slanderous labelling or advertising, with the specifics delegated to Presidential Decree. The starting point for the disclosure question is Article 3, paragraph (2) of that Decree, which defines deceptive labelling or advertising as labelling or advertising by means of concealing or reducing facts.
On top of that sits the Review Guideline on Endorsement Advertising (Fair Trade Commission Established Rule No. 499, in force 1 June 2026). Section Ⅰ states its own purpose as presenting detailed review criteria for unfair labelling or advertising under Article 3 of the Act and Article 3 of the Decree. The scope in section Ⅱ covers labelling or advertising a business entity carries out including endorsement content, and the parenthesis adds that this includes labelling or advertising that an endorser directs at consumers, in endorsement form, on the basis of an economic interest with the advertiser. In other words, the guideline reaches not only the brand's own advertisement but the post a compensated person publishes on their own account.
The second regime is the Ministry of Food and Drug Safety side. Article 13, paragraph (1) of the Cosmetics Act bars business operators and sellers from labelling or advertising that is likely to be mistaken for a medicine, that is likely to make a non-functional cosmetic be mistaken for a functional cosmetic or that differs from the examination result for a functional cosmetic, and any other labelling or advertising likely to deceive consumers contrary to fact or to cause them to be mistaken. Paragraph (2) of the same Article delegates the scope of such labelling and advertising, and other necessary matters, to an Ordinance of the Prime Minister, which is Article 22 of the Enforcement Rule and its Attached Table 5.
So the Fair Trade Commission track asks whether consumers can tell this is an advertisement, and the Ministry of Food and Drug Safety track asks whether the content is usable in a cosmetics advertisement at all. Disclosure is what the first track requires; the second is a prohibition that disclosure does not cure. Even on the first track, disclosure alone does not close the file: the truthfulness of the content and the advertiser's burden of substantiation are taken up separately in section 9.
It is worth reading section Ⅳ.3 of the guideline alongside this. Because the guideline is written around representative cases, conduct not expressly listed is not automatically lawful, and conversely conduct that matches one of its examples may still not be unfair where there is no likelihood of misleading consumers or of harming fair trade order. It looks like a checklist, but the checklist is not the whole of it.
2. How far "endorsement" reaches
Section Ⅲ.1 of the guideline defines an endorsement as content that can be perceived as the independent opinion of a third party rather than the advertiser's own, expressed through voice, text, figures such as signatures and seals, photographs, or video. There are two branches. Item (a) covers content that, based on the person's own use or experience, recognises or rates the product well in terms of efficacy, effect, or performance, or recommends buying or using it. Item (b) covers an expert or an organisation telling people the product is good or recommending that consumers buy or use it.
What matters in practice is how wide that reach is.
- The definition of a well-known person is broad. Section Ⅲ.2 covers entertainers, artists, athletes, doctors, professors, religious figures, and bloggers who, through achievements in a particular field, are widely known to consumers through television, the internet, or social media, or are able to exert influence over them.
- Saying nothing can still be an endorsement. Section Ⅴ.2(d) states that where a well-known person deliberately exposes a product on social media, mentions a brand or product name, or links to a site where product information can be checked, that may be regarded as endorsing the product.
- Using a name in the product name counts too. Section Ⅴ.2(c) states that where a well-known person's name is used in a product or business name, that person may be regarded as endorsing the product.
- Organisational endorsements are a separate type. Section Ⅴ.4 requires that where an organisation's recommendation appears in an advertisement, the organisation be in a position to assess the quality or performance, and that the content reflect the organisation's official intent through proper internal procedures. Using a recommendation letter from an overseas institute that issues one on payment of a fee without any assessment is listed as unfair.
Collaboration product names, an ambassador's everyday post, and an association endorsement line all have to be reviewed within the same frame.
3. Which arrangements have to be disclosed
Section Ⅴ.6(a) requires that where an economic interest capable of affecting the content or credibility of an endorsement exists between the advertiser and the endorser, the advertiser or the endorser disclose it. The guideline then shows the range by example: where the endorser receives cash or the product itself, a gift certificate, accumulated points, a discount benefit, or other economic consideration from the advertiser, or endorses or arranges group purchases while directly employed by the advertiser. In those cases the economic interest must be stated clearly, for every single endorsement, so that consumers can tell it is commercial labelling or advertising.
The guideline's examples of interests that do affect credibility read like a list of common cosmetics campaign formats.
- Receiving a gift certificate from the advertiser and writing a review of the product on social media
- Receiving the product from the advertiser, agreeing to write a recommendation, and then posting it in an online community
- Receiving a discount at purchase, agreeing to write a review, and then posting a review as a comment on the purchase page
- An employee of the advertiser or of its advertising agency posting an endorsement of a product on a blog, an online community, social media, or a portal question-and-answer service
That last example is often overlooked. A post written by an internal team member or an agency employee is judged by the same standard as an external influencer's.
There is an exception as well. Even where an economic interest exists, it may be left undisclosed in the exceptional case where it does not affect the content or credibility of the endorsement. The guideline's examples are a cosmetic sample given to every applicant on the advertiser's website, used and then reviewed voluntarily; a souvenir given to every participant at a large event such as a marathon, followed by a voluntary write-up; and an industry expert who receives a small sample as a participation souvenir at a new fragrance launch event open to the general public, tries it, and voluntarily posts a review.
All three examples involve a voluntary review, but the third does not expressly state that the item went to everyone. The test is whether this is an exceptional case in which the economic interest does not affect the content or credibility of the endorsement. As an editorial suggestion rather than a legal test, recording whether the offer was open to everyone and whether a review was required makes that judgment easier to explain later.
4. The four requirements for the disclosure wording
Section Ⅴ.6(b) states that a disclosure meeting the following four principles is regarded as an adequate method. The structure looks less at whether wording exists than at how it was placed.
(1) Position. The wording goes close to the endorsement so consumers can find it easily, and is presented so that consumers perceive the wording and the endorsement as a single posting. Examples of hard-to-find positions: wording written into the middle of the body text without separation, wording written as a comment, and wording visible only after pressing "see more".
(2) Form. The wording is expressed so consumers recognise it easily. In text, it must be clearly distinguishable from the background, with a suitable size, font, and colour; in voice, it must be understandable without adjusting volume or speed. Lettering too small to notice, letter colours similar to the background, and speech too fast to follow are the inadequate examples.
(3) Content. The nature of the economic interest, such as financial support, a discount, or sponsorship, must be stated clearly enough for consumers to understand. The guideline's adequate examples are written in Korean, and the English given here is a gloss, not a list of English wording approved for a Korean-language endorsement. They are "위 ○○ 상품을 추천(보증, 소개, 홍보 등)하면서 ◇◇사로부터 경제적 대가(현금, 상품권, 수수료, 포인트, 무료 상품 등)를 받았음" (received economic consideration from Company ◇◇ for recommending the product ○○ above), along with "금전적 지원" (financial support), "대가성 광고" (paid advertising), "무료 상품" (free product), "상품 협찬" (product sponsorship), "상품 할인" (product discount), "#광고", and "#협찬".
(4) Language. The wording uses the same language as the endorsement. Some foreign wording may be included where the disclosure can still be seen overall as the same language and consumers can easily understand it. The guideline lists "Advertisement", "AD", "PR", "Collaboration", "Partnership", "Sponsor", "spon", "sp", "Collabo", "Thanks to ~", and "Ambassador" as examples that cannot be regarded as the same language when the audience is Korean consumers, and gives the Korean phrases "디스카운트 받는 대가로 작성" (written in return for a discount) and "적립포인트 받는 대가로 작성" (written in return for accumulated points) as examples that can.
5. Easy wording that is not adequate
The guideline collects separately the expressions that do not qualify as clear content. A good number of them turn up in ordinary campaign briefs. The guideline is written in Korean, so the English below is a translation of its examples rather than a list of English wording.
- "체험 후기" (trial review), "일주일 동안 사용해 보았음" (used it for a week), "체험단" (review team)
- "This post is informational or promotional", "this post contains promotional wording"
- "Gift", "thank you to the CEO of Company ○○", "it was sent to me by ~"
- Simply tagging a brand or product, as in "#[brand name]" or "@[product name]"
- Showing a collaboration with a multiplication sign, as in "[brand name] × [account name]"
- Any other abbreviation that is hard to understand
You may of course use "review team" as an internal programme name. The problem is putting only that label in the disclosure slot, which is exactly the shape the guideline lists as inadequate. Keeping operational vocabulary separate from disclosure wording removes most of this confusion.
6. Where the wording goes, medium by medium
Section Ⅴ.6(c) divides media into four and sets out a method for each, with the caveat that a method not listed there may still be adequate if it satisfies all four principles above.
Text. For blog posts, community posts, and other text endorsements, the wording goes in the title or the opening part of each posting. When placed in the opening part, it is separated from the body, and made easy to recognise by using a larger size than the body text or a different colour. Writing it as a comment, or requiring a press on "see more" or a link, may not qualify. English translations of the guideline's Korean examples include "received a modest commission", "I received a modest writing fee, but this is my honest review", "received a commission", and "paid advertising".
Photographs. The rule is to place the wording inside the photograph. Where the photograph and the body text are connected so consumers recognise it easily, it may be left out of the photograph, but then it goes in the opening part of the text. If entered as a hashtag, it goes in the first hashtag as a rule, and may sit elsewhere only where it is still expressed so consumers recognise it easily. Slipping it in among many hashtags, so that consumers struggle to notice it, is the inadequate example.
Video. The wording is included in the posting title or within the video. If it goes in the title, the title length is adjusted so the wording is not truncated; the guideline's inadequate example is a long title that leaves a mobile screen showing only the first part. Within the video, where the whole video is an endorsement, the wording is inserted at the start and the end and displayed repeatedly in between; where only part of it is, the wording is inserted at the start and end of that section and displayed repeatedly while the endorsement runs. Where a well-known person endorses by deliberately mentioning or exposing a product or brand, insertion at the start and the end is available. One adequate example is a subtitle repeated every five minutes.
Live broadcast. The rule follows the video method, in the title or within the video. Where live transmission makes a title or subtitles impractical, the wording may be delivered by voice, placed at the start and end of the endorsement and repeated so that consumers who watch only part of the broadcast still notice it. Here too, where a well-known person endorses by deliberately mentioning or exposing a product or brand, the disclosure may be placed at the start and the end of the video. Mentioning it once in a thirty-minute review segment, so viewers joining midway cannot notice it, is the inadequate example.
If live commerce and short-form run inside one campaign, a single approved sentence is not enough; the insertion rule for each medium belongs in the brief as well.
7. When an AI-generated virtual person appears
Section Ⅴ.5 treats endorsements by virtual persons as a separate type. Where a virtual person hard to distinguish from a real one is generated using artificial intelligence or similar technologies and used to endorse a product, the fact that the endorser is a virtual person generated using such technologies must be disclosed, and the disclosure must be presented in a way consumers recognise clearly and easily. "Artificial intelligence" here means, under section Ⅲ.3, artificial intelligence as defined in Article 2, item 1 of the Framework Act on the Development of Artificial Intelligence and the Establishment of a Basis for Trust.
Two adequate examples are given. For a posting, wording in the title or the opening part such as "this posting includes a virtual person generated using artificial intelligence (AI)" or "includes a virtual person (virtual consumer, virtual celebrity, virtual expert, etc.)". For a photograph or video, wording such as "virtual person" displayed close to the virtual person while it appears.
Section Ⅴ.5(c) adds that where a virtual person's endorsement is expressed as resting on experiential fact, and the content does not match fact that actually occurred, it may constitute unfair labelling or advertising. Having a virtual person narrate a usage review is where the risk rises sharply. Replacing a model with a generated image is one thing; having a generated person say they tried the product is another.
For what it is worth, the cover image on this article is itself generated, which is why the caption says so. It is not the same provision as the disclosure duty in advertising, but the principle runs in the same direction: do not leave a generated asset looking like real photography or real use experience.
8. For cosmetics, one endorsement stays prohibited even when disclosed
This is where cosmetics campaigns go wrong most often. Item 2(c) of Attached Table 5 to the Enforcement Rule of the Cosmetics Act (amended 1 August 2025) provides that there shall be no labelling or advertising stating, or implying, that a doctor, dentist, oriental-medicine doctor, pharmacist, medical institution, or other expert in the medical or pharmaceutical field designates, certifies, recommends, guides, researches, develops, or uses the cosmetic concerned.
The prohibition is wide. It is not only recommendation: designation, certification, guidance, research, development, and current use are all inside it, and implying any of them is covered as well. So disclosing exactly what the expert was paid leaves the prohibition untouched. Disclosure is a Fair Trade Commission requirement; this is a Ministry of Food and Drug Safety prohibition.
The same item does carry a proviso. Where human-application-test findings that fit the definitions in Article 2, items 1 through 3 of the Act have been recognised through an academic-society presentation or similar, the relevant literature may be cited within that scope; in that case the original meaning of the cited literature must be conveyed accurately, and the researcher's name, the document name, and the date of publication must be clearly stated. Note how the conditions stack: the findings must come from a human-application test fitting the definitions in Article 2, items 1 through 3 of the Act, they must have been recognised through a relevant academic-society presentation or similar, the citation must stay within that scope, the original meaning of the literature must be conveyed accurately, and the researcher's name, the document name, and the publication date must be clearly stated.
Other duties in Attached Table 5 also bind review campaigns. Item 2(a) prohibits content, product names, and efficacy or effect claims likely to be mistaken for a medicine. Item 2(b) prohibits labelling or advertising likely to make a non-functional cosmetic be mistaken for a functional one. Item 2(f) requires that comparisons with competing products state the subject and the standard clearly and cover only matters that can be objectively verified, and prohibits exclusive absolute expressions such as "best" or "finest". Item 2(h) prohibits advertising quality or efficacy that cannot be or has not been objectively verified, and labelling or advertising that goes beyond the scope of a cosmetic.
A sentence an influencer wrote in their own words is still advertising copy. As editorial review examples, "recommended at a dermatology clinic" calls for checking whether it states or implies a recommendation by a doctor or a medical institution, and "my acne cleared up" calls for checking whether it could cause the product to be mistaken for a medicine. Neither phrase is quoted as an example in the provisions above, and attaching a disclosure line does not by itself make the content permissible. The boundary of functional claims is covered in the conditions for a hair-loss relief claim, what the evidence for a claim has to be in substantiation of labelling and advertising, and the current state of natural and organic wording in after the natural and organic certification scheme ended.
9. The content of the review is regulated too
Getting the disclosure line right is not the end of it. Section Ⅳ.1 of the guideline sets out six general principles for reviewing endorsement-style labelling and advertising.
- Where the endorsement rests on experiential fact, it must match what the endorser actually experienced; where it rests on professional judgment, it must match the reasonable judgment of an endorser who holds professional knowledge in the field.
- The original content of the endorsement must not be distorted by the advertiser's processing or restructuring.
- Where the endorser later changes or withdraws the content, the original endorsement can no longer be used. Likewise, where changes to the endorsed product or its environment call for a change to the endorsement, the existing endorsement cannot continue to be used unless the advertiser informs the endorser and obtains the endorsement again.
- Where the advertising presents the endorser as still using the product, the endorser must have been using it at the time the endorsement was made.
- Where the experience or judgment is not something that occurs generally among ordinary consumers, or is not a view generally accepted in the relevant professional field, the overall message must not be expressed as though it were.
- The advertiser bears the burden of substantiating what the endorser endorses. Where the content is received as a fact possible for ordinary consumers beyond the endorser's personal experience, the burden extends to that as well.
The third and fourth principles are operational. If the formula or the container changed, whether old reviews should stay up needs a decision; if an influencer edited or removed a post, the product page and the ad creatives that quoted it have to be reviewed alongside it.
The last principle leads into the substantiation duty. Article 14, paragraph (1) of the Cosmetics Act requires business operators and sellers to be able to substantiate factual matters in their own labelling and advertising, and paragraph (2) lets the Minister of Food and Drug Safety request materials in order to judge whether the labelling or advertising falls under Article 13, paragraph (1), item 4. Paragraph (3) sets 15 days from the request for submission, with a proviso allowing the period to be extended where justified grounds are recognised; Article 5, paragraph (3) of the Fair Labeling and Advertising Act uses the same 15-day structure and the same extension proviso.
The strength of the stop order differs between the two Acts. Where the materials are not submitted within the period and the advertising continues, Article 14, paragraph (4) of the Cosmetics Act provides that the Minister of Food and Drug Safety shall order the labelling or advertising stopped until the materials are submitted, whereas Article 5, paragraph (5) of the Fair Labeling and Advertising Act provides that the Fair Trade Commission may do so.
The two tracks are also wired together. Article 14, paragraph (5) of the Cosmetics Act allows an operator that was asked for substantiation materials by the Minister under paragraphs (2) and (3) of that Article, and submitted them, to refuse a submission request made by another agency under other statutes including the Fair Labeling and Advertising Act, and paragraph (6) requires the Minister to comply with another agency's request for those materials absent special grounds.
10. Who is sanctioned, and how
The sanctions run along two separate tracks.
The Fair Trade Commission track has four stages. Where Article 3, paragraph (1) is violated, Article 7 allows an order to stop the violation, to publish the fact that a corrective order was received, to run a corrective advertisement, and to take other necessary measures. Article 9, paragraph (1) allows a surcharge not exceeding 2 percent of turnover as prescribed by Presidential Decree, with a proviso that where the violator has no turnover or turnover is difficult to calculate, and the entity is one prescribed by Presidential Decree, the surcharge may be imposed within a limit of 500 million won. Article 10 imposes damages liability and states that a liable business entity cannot escape liability to the injured party by showing absence of intent or negligence. Article 17 punishes a business entity that violates Article 3, paragraph (1) by engaging in unfair labelling or advertising, or by causing another business entity to do so, with up to two years' imprisonment or a fine of up to 150 million won.
The Ministry of Food and Drug Safety track has two stages. Article 24, paragraph (1), item 10 of the Cosmetics Act lists labelling or advertising in violation of Article 13, or violation of a stop order under Article 14, paragraph (4), as grounds for administrative action. For item 10 the Minister may revoke the registration, order closure of a place of business limited to a business notified under Article 3-2, paragraph (1), prohibit manufacture, import, and sale of the item, or suspend all or part of the business for a fixed period of up to one year. The proviso requiring mandatory revocation or closure applies to item 1-2, item 3, or item 14, but excludes cases under item 14 where the suspension was limited to advertising activities. It does not apply to item 10. Paragraph (2) of the same Article leaves the detailed standards to Ordinance of the Prime Minister, and Article 28, paragraph (1) allows a surcharge of up to 1 billion won in lieu of a business suspension. The penalty provision is Article 37, paragraph (1): a violation of Article 13 carries up to one year's imprisonment or a fine of up to 10 million won, and paragraph (2) of the same Article allows imprisonment and a fine to be imposed together.
Compare the scale and the advertising side is heavier. Article 38, item 2 of the Cosmetics Act sets a fine of up to 2 million won for violating Article 10, paragraph (1), excluding item 7 of that paragraph, and Article 10, paragraph (2), whereas unfair labelling or advertising carries up to one year's imprisonment or a fine of up to 10 million won under Article 37, paragraph (1), and the Fair Trade Commission penalty reaches two years' imprisonment or 150 million won. The label side is set out in precautionary statements on the label.
The company itself is also in frame. The joint penalty provision in Article 39 of the Cosmetics Act applies where a corporation's representative, or an agent, employee, or other worker of a corporation or an individual, commits an offence under Articles 36 through 38 in connection with that corporation's or individual's business: the corporation or individual is also fined under the relevant provision in addition to the actor being punished, unless it did not neglect due care and supervision over that business to prevent the violation. That is the provision that gives a campaign brief and a training record real weight.
It also helps to be clear about who holds the duty. The duty holder under Article 13 of the Cosmetics Act is the business operator or the seller; the full structure of what a responsible distributor carries is covered in the duties a brand owner carries directly, and the registration unit in which registration you need first.
11. What to settle before the campaign starts
The list below is not a form required by law. It is the editorial team's practical translation of the provisions and guideline passages above into campaign work, and the basis for each item is in the preceding sections.
- Write down the form of compensation. Record, per campaign, whether it is cash, product, a gift certificate, points, a discount, employment, or group-purchase arrangement.
- Fix the disclosure wording in advance, in the language of the endorsement. For a Korean-language endorsement, use Korean wording: the guideline's examples include "#광고", "#협찬", and "소정의 원고료를 지급받았지만, 저의 솔직한 후기입니다". Decide one short form and one sentence form for each of text, photo, and video.
- Write down the placement rule. Title or opening part for text; inside the photo or the opening part of the text and the first hashtag for photos; start and end plus the repetition interval for video.
- Circulate the list of unusable expressions, so that "체험단" (review team), "체험 후기" (trial review), "선물" (gift), "AD", "PR", "Sponsor", "Ambassador", and "[brand] × [account]" never land in the disclosure slot.
- Screen the cast in advance. At the campaign design stage, exclude any concept that presents a medical or pharmaceutical expert as recommending, using, or developing the product, and where you intend to cite literature instead, secure the researcher's name, the document name, and the publication date first.
- Write down the change and withdrawal procedure: how existing reviews are handled when the formula or container changes, and how the product page and ad creatives are cleaned up when a post is edited or deleted.
- Keep records of who received what and when, whether a review was a condition, and whether distribution was universal, and keep factual claims backed by material you could file within 15 days.
- Disclose generated assets. Where a virtual person or a generated image is used, put the disclosure wording and its position in the brief as well.
EVAS keeps planning, design, research, manufacturing, logistics, and brand content in house, so a formula, the label content, and campaign copy can be lined up in one flow. What wording is permitted, though, is decided by the statutes and the guideline rather than by any company's capability, so the conclusion always has to be checked against the current original text. If you would like this reviewed against a product and campaign structure in progress, tell us through the consultation request.
12. What this article did not verify
- The guideline presents representative cases as examples. Forms not listed can still be unfair labelling or advertising, and conduct that matches an example may still not be unfair where there is no likelihood of misleading consumers.
- The detailed basis for calculating surcharges is delegated to Presidential Decree and was not checked here. Individual Fair Trade Commission decisions are not covered either.
- Electronic-commerce rules on collecting and operating reviews on a retail page are outside this article's scope. What has to appear on the product page is covered separately in mandatory online product information.
- Duties under the Framework Act on the Development of Artificial Intelligence and the Establishment of a Basis for Trust were not verified. This article uses only the definition the guideline cites.
- Advertising rules for other product categories such as medical devices and health functional foods are out of scope, although the guideline's examples include many cases from them.
- Disclosure rules on overseas platforms and in export markets are not covered. For a campaign aimed at export, check the destination country's rules separately.
- Not every item of Attached Table 5 is reproduced here. Label and advertising copy should be checked against the current original text of Attached Table 5.
- Other insight articles are listed on the insights index.
Frequently asked questions
We only sent the product free of charge and paid no money. Does it still have to be disclosed?
Section Ⅴ.6(a) lists the product itself, gift certificates, accumulated points, and discount benefits alongside cash as examples of economic consideration. Providing only a free product does not automatically exempt the endorsement from disclosure. That said, a sample given to every applicant, used and then reviewed voluntarily, is listed as an exception that does not affect credibility. The test is whether the economic interest affects the content or credibility of the endorsement, so judge the campaign structure rather than the form of the payment alone.
Is "#체험단" (review team) or "#AD" enough?
Both are expressions the guideline lists as inadequate. "체험단" (review team) and "체험 후기" (trial review) appear among the examples that are not clear content, and "AD" appears among the examples that cannot be regarded as the same language when the audience is Korean consumers. The guideline's adequate examples are Korean: "#광고" (advertisement), "#협찬" (sponsored), "대가성 광고" (paid advertising), "무료 상품" (free product), "상품 협찬" (product sponsorship), and "금전적 지원" (financial support).
For a post with several photos and a lot of hashtags, where should the wording go?
The rule is to place it inside the photograph; where the photograph and the body text are connected so it is easy to recognise, it goes in the opening part of the text. If it is entered as a hashtag, the first hashtag is the rule. Slipping it in among many hashtags, where consumers struggle to notice it, is listed as inadequate.
A dermatology clinic director will recommend the product. Is accurate ad labelling enough?
No. Item 2(c) of Attached Table 5 to the Enforcement Rule of the Cosmetics Act prohibits labelling or advertising stating, or implying, that a doctor, dentist, oriental-medicine doctor, pharmacist, medical institution, or other medical or pharmaceutical expert designates, certifies, recommends, guides, researches, develops, or uses the cosmetic. This is a prohibited type, not a requirement that disclosure satisfies. The proviso to the same item leaves open the route of citing recognised human-application-test findings as literature, in which case the original meaning must be conveyed accurately and the researcher's name, the document name, and the publication date stated.
Do reviews written by our own staff or by the agency's staff need disclosure?
They are in the examples verbatim. The guideline lists an employee of the advertiser or of its advertising agency posting an endorsement on a blog, an online community, social media, or a portal question-and-answer service as an example where the economic interest affects credibility. Endorsing while directly employed by the advertiser is also expressly listed as subject to disclosure.
Sources
- Act on Fair Labeling and Advertising (Act No. 20712, in force 21 January 2025) ↗
- Enforcement Decree of the Act on Fair Labeling and Advertising (Presidential Decree No. 36416, in force 1 July 2026) ↗
- Review Guideline on Labeling and Advertising Involving Endorsements (Fair Trade Commission Established Rule No. 499, in force 1 June 2026) ↗
- Cosmetics Act (Act No. 21525, in force 8 October 2026) ↗
- Enforcement Rule of the Cosmetics Act (Ordinance of the Prime Minister No. 2109, in force 2 April 2026) ↗
- Attached Table 5: Scope of and Compliance Matters for Cosmetic Labeling and Advertising (Enforcement Rule of the Cosmetics Act) ↗