Tag: hypoallergenic

  • Sensitive Skin Ingredients: The Category No Regulator Names, and Five with Human Studies

    Cover image for a guide to sensitive skin cosmetic ingredients in Korea. Korea's Regulation on Review of Functional Cosmetics, Annex 4, notifies actives in six categories: UV protection with 27 ingredients, brightening with nine, wrinkle improvement with four, hair colour change, hair removal with thioglycolic acid, and acne relief with salicylic acid at 0.5 percent. Sensitive skin is not one of them. The Ministry of Food and Drug Safety guideline on test methods for substantiating cosmetic claims sets out ten methods, and sensitive skin is not among those either; people with sensitive or hyper-reactive skin are instead screened out of those tests. In the United States there are no federal standards or definitions for the term hypoallergenic, and in the European Union the only permitted lists of ingredients are for colorants, preservatives and UV filters. Five ingredients with human studies fill the gap: ceramide, panthenol, colloidal oatmeal, licochalcone A and niacinamide. A Dr. J Ingredient Notes cover.

    🇰🇷 한국어판

    Hello, this is Dr. J. Today I want to pick five ingredients for sensitive skin the only way that is left — from studies done on people.

    One thing first, because it sets up everything else. Sensitive skin barely appears in the rules at all. Where it does appear, it is not as something to measure. It is a reason to exclude someone from a test.

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    The sources, first

    📄 Regulation on Review of Functional Cosmetics, Annex 4 (Korean Law Service)

    📄 MFDS, Guideline on Test Methods for Substantiating Cosmetic Claims (2018-03, PDF)

    📄 U.S. FDA, “Hypoallergenic Cosmetics”

    📄 Regulation (EC) No 1223/2009, Article 14

    Six categories in the Korean annex, ten methods in the guideline. Sensitive skin is in neither.

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    Five lines, if you are in a hurry

    ✔ Korea notifies actives in six categories, and sensitive skin is not one

    ✔ The MFDS test-method guideline lists ten methods, and sensitive skin is not one either

    ✔ In those tests, sensitive skin is an exclusion criterion

    ✔ The United States wrote a definition for “hypoallergenic” in 1975 and lost it in court

    ✔ So five ingredients are picked here from human studies, weaknesses included

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    What Korea names, and what it leaves out

    Korea’s functional cosmetics system works from a notified list. Annex 4 of the Regulation on Review of Functional Cosmetics sets out the ingredient and the amount. Make a product to those numbers and you do not have to file fresh efficacy data — which is another way of saying the state has already decided what counts.

    Category What the notification sets out How to read it
    UV protection 27 ingredients with maximum amounts Names and numbers are both fixed
    Brightening Nine ingredients (arbutin 2–5%, niacinamide 2–5% and others) Same
    Wrinkle improvement Four ingredients (retinol 2,500 IU/g, adenosine 0.04% and others) Same
    Hair colour change A dyeing list split across six sub-tables Same
    Hair removal Thioglycolic acid, 3.0–4.5% as the acid, pH 7.0 to under 12.7 One ingredient
    Acne relief Salicylic acid 0.5%, in cleansing products One ingredient
    Sensitive skin Nothing There is no such category

    Acne gets one ingredient. Sensitive skin gets no category at all. So “for sensitive skin” and “low irritation” on a Korean box are not reviewed phrases.

    Evidence figure on sensitive skin ingredients. First, Korea notifies actives by category. Six categories each carry named actives and set amounts: UV protection 27, brightening nine, wrinkle four, hair colour, hair removal with thioglycolic acid, and acne with salicylic acid 0.5 percent. Sensitive skin is not one of the six. The source is the Regulation on Review of Functional Cosmetics, Annex 4. Second, sensitive skin is not in the test-method guideline either. The Ministry of Food and Drug Safety guideline sets out ten test methods covering moisturising, elasticity, sebum, dark circles, fine dust and others, and sensitive skin and low irritation are not among the ten. Instead people with sensitive or hyper-reactive skin are an exclusion criterion in those tests. Third, the United States had a definition and lost it. FDA proposed a hypoallergenic rule in February 1974 and issued the final regulation on 6 June 1975, but an appeals court held the definition was unreasonable. FDA now writes that the term means whatever a particular company wants it to mean and that there are no federal standards or definitions governing its use, as of 25 February 2022. Fourth, the European Union names actives for three jobs and not for claims. Article 14 of Regulation 1223/2009 bans colorants not listed in Annex 4 and does the same for preservatives and UV filters in Annexes 5 and 6, and no annex is a permitted list of actives for a claim. Claims instead need adequate and verifiable evidence under Regulation 655/2013. Fifth, the human studies have to do the work: ceramide with 50 subjects over four weeks in a single arm, panthenol 5 percent with 25 enrolled over 26 days in a randomised placebo-controlled trial, colloidal oatmeal with 29 women investigator-blinded, licochalcone A with 1,221 subjects over four weeks in an open study, and niacinamide with 50 women over four weeks with one forearm untreated. Two of the five had no control group and one did not report its duration.

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    There is no method to measure it either

    This is the part that is specific to Korea, and it is worth knowing if you sell there. The MFDS publishes a separate guideline that tells you how to run the test behind a claim — which instrument, how long, what unit. Each claim gets its own chapter.

    Chapter Test method Added
    1 Skin moisturising 2012-05, at issue
    2 Skin elasticity 2012-05, at issue
    3 Sebum control 2012-05, at issue
    4 Temporary reduction of cellulite 2013-11
    5 Suitability for acne-prone skin 2013-11
    6 Dark circle improvement 2014-08
    7 Skin blood-flow improvement 2015-12
    8 Puffiness reduction 2015-12
    9 Paraben-free 2017-03-31
    10 Fine-dust blocking 2018-03-28
    — Sensitive skin, low irritation Not among the ten

    Moisturising is there. Sebum is there. Dark circles are there. Sensitive skin is not.

    ★ The one place “sensitive” does appear

    In the subject-selection rules for chapters 1, 2 and 3 — moisturising, elasticity and sebum — one of the exclusion criteria is “people with sensitive or hyper-reactive skin”. Chapter 5, on acne-prone skin, excludes “people whose skin is sensitive to adhesive components”.
    So in this document sensitive skin is not something you measure. It is something you screen out before you measure anything else.

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    The United States tried, and the courts said no

    The American story is the sharpest of the three, because the definition existed and then stopped existing.

    When What happened Where it stands
    February 1974 FDA proposed a regulation on the term hypoallergenic A definition was on the table
    6 June 1975 FDA issued the final regulation Manufacturers would have had to test
    On appeal The court held FDA’s definition was unreasonable The regulation fell
    Today «There are no Federal standards or definitions that govern the use» «The term means whatever a particular company wants it to mean»

    FDA’s own page puts it plainly: «There are no Federal standards or definitions that govern the use of the term “hypoallergenic.”» And then, one sentence later: «The term means whatever a particular company wants it to mean.»

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    The EU names actives for three jobs, and claims are not one of them

    It is easy to assume the EU, with its long annexes, must have a list somewhere. It does not — not for claims.

    Annex What it is What that means for a claim
    Annex II Prohibited substances A list of what cannot go in at all
    Annex III Restricted substances Conditions, not a permitted list
    Annex IV Colorants — permitted list A colorant not listed cannot be used
    Annex V Preservatives — permitted list Same
    Annex VI UV filters — permitted list Same
    For a claim No annex Evidence under Reg. 655/2013 instead of a list

    Article 14 is a list of prohibitions. Three of them work as permitted lists, because a colorant, a preservative or a UV filter that is not in its annex cannot be used. There is no fourth annex for “soothing” or “for sensitive skin”. Under Regulation (EC) No 655/2013 a claim has to rest on «adequate and verifiable evidence» instead, and the method is left to «state of the art practices».

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    So the studies have to do it

    That is the whole argument for reading the trials themselves. Here are the five, with the size, the length and the design next to each.

    Ingredient People Length Design Measured Number
    Ceramide 50 4 weeks Single arm, no control Hydration, TEWL Hydration median 50 to 80
    Panthenol 25 enrolled
    21 finished
    26 days Randomised, double-blind, placebo-controlled Hydration after irritation Better on the active side in 11, placebo in 1
    Colloidal oatmeal 29 women Not reported Investigator-blinded Dryness, scaling, roughness, itch All four improved
    Licochalcone A 1,221 4 weeks Open study, no control Redness and related scores P<0.001
    Niacinamide 50 women
    46 finished
    4 weeks One forearm untreated, investigator-blind TEWL, capacitance TEWL 2.5 vs 3.9

    The last row is worth a pause. Niacinamide sits on Korea’s brightening list at 2–5%. This study measured something else entirely — barrier. The ingredient name does not tell you what was measured.

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    And where each one is weak

    Ingredient Where it is weak How to read it
    Ceramide No control group, one site, manufacturer-funded Read what was measured, not the size of the change
    Panthenol Only one endpoint reached significance The design is the strongest of the five
    Colloidal oatmeal The abstract does not give the duration Read it without knowing how long
    Licochalcone A No control, and the product also contained trans-4-t-butylcyclohexanol The two cannot be separated here
    Niacinamide The facial figures were not tested statistically Read the forearm numbers

    Of the five, one design is clearly the strongest, and it is the smallest study. Twenty-five people, randomised, double-blind, placebo-controlled, with the irritation deliberately induced. The study with 1,221 people has no control group at all. Size and strength are not the same thing, and a box never prints either.

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    Four things to check on the box

    ✔ Look past “for sensitive skin” and check whether the five names are in the ingredient list

    ✔ The earlier a name sits in that list, the more of it is in there

    ✔ Photograph the names after “fragrance” so you can compare them later

    ✔ Try anything new on the inside of your arm for a few days first

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    One line

    No regulator in these three places names an ingredient for sensitive skin, so the studies have to. Decide first whether your issue is barrier, itch or redness, and five becomes three.

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    What I left out, and why

    ✔ Centella asiatica and madecassoside — I could not open a human study, only reviews

    ✔ “Fragrance-free is safer” — no primary source for it

    ✔ The facial figures in the niacinamide study — cheek TEWL fell, but those values were not tested statistically

    ✔ Prescription drugs and procedures — they do not belong in a cosmetics piece

    ✔ An EU rule specific to sensitive skin — I did not find one, which is not the same as saying none exists

    About the author · Dr. J

    MS in Veterinary Medicine, PhD in Life Sciences. I worked as a researcher at the Korea Research Institute of Bioscience and Biotechnology (KRIBB) and now run Beaurea, a cosmetics manufacturing company, where I write the formulas myself. This blog reads the research papers and the regulatory documents and turns them into plain-language criteria for choosing ingredients. I don’t recommend specific products here – only criteria that apply to any product.

    📌 Previously

    📌 Niacinamide: How Much Is Enough — the same ingredient, seen from the brightening side

    📌 Ceramides – cholesterol and fatty acid ratio — the first ingredient here, in full

    📌 Panthenol for Skin: What the Dexpanthenol Studies Show — the irritation side

    📌 How to Read a Korean Cosmetic Ingredient List — where to find these names on the box

    📄 References

    · Regulation on Review of Functional Cosmetics, Annex 4 (Korean Law Service, opened 2026-10-17)

    · MFDS, Guideline on Test Methods for Substantiating Cosmetic Claims (2018-03, 안내서-0353-02)

    · MFDS, Guideline on Cosmetic Labelling and Advertising (2025-08-14, 안내서-0086-07), Annex 2

    · Draelos ZD, Raymond I. J Clin Aesthet Dermatol 2018;11(5):30-32

    · Biro K, Thaçi D, Ochsendorf FR, Kaufmann R, Boehncke WH. Contact Dermatitis 2003;49(2):80-84

    · Reynertson KA et al. J Drugs Dermatol 2015;14(1):43-48 · Jovanovic Z et al. ibid. 2017;16(6):605-611

    · Draelos ZD, Ertel K, Berge C. Cutis 2005;76:135-141

    · U.S. FDA, “Hypoallergenic Cosmetics” (content current as of 2022-02-25)

    · Regulation (EC) No 1223/2009, Article 14 · Regulation (EC) No 655/2013

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    This article summarises published studies and public regulatory documents. It is information, not diagnosis or treatment. Of the five studies, two had no control group and one does not report its duration, and one was run on a product containing two actives. Those limits are set out in the tables above rather than hidden. Ingredient names and concentrations are given as criteria for choosing a product, not as a recommendation of any particular one.

    — Dr. J Ingredient Notes