Tag: MFDS notice

  • Korea’s 25 Fragrance Allergens: When a Name Has to Leave the Word Fragrance (Ingredient Guide 26)

    Cover image for a Dr. J Ingredient Notes article on fragrance allergen labelling in Korea. The Cosmetics Act requires every ingredient to be listed on the package, and the Enforcement Rule allows a perfuming agent to be written as the single word fragrance. When the perfuming agent contains one of the 25 fragrance allergens named in a ministry notice, that word is not enough and the substance must be named. The thresholds are above 0.01 percent in rinse-off products and above 0.001 percent in leave-on products, judged for each substance rather than on the total.

    🇰🇷 한국어판

    Hello, this is Dr. J. Today: Korea’s 25 fragrance allergens, and the rule that decides when one of them stops hiding inside the word fragrance and gets a name of its own on the box.

    Start with the thing most guides skip. A long tail of unfamiliar names after fragrance does not mean the product is heavily perfumed. It means something in the perfume crossed a labelling threshold. The names are not a leak. They are the rule working.

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    Primary sources first

    📄 Cosmetics Act Article 10 (Korea Cosmetic Association)

    📄 Annex 2, fragrance allergens (Korean Law Information Center)

    📄 Labelling Q&A (Korea Cosmetic Association)

    📄 Regulation (EU) 2023/1545 (EUR-Lex)

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    Five lines, if you are in a hurry

    ✔ A perfuming agent may be written as the single word fragrance

    ✔ But if it contains one of the listed 25, that substance must be named

    ✔ Thresholds: above 0.01% in rinse-off, above 0.001% in leave-on products

    ✔ Judged per substance, never on the sum of them

    ✔ The EU uses the same two figures — and its list is getting much longer

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    Why a name leaves the word fragrance — a rule in three tiers

    Korean guides usually explain the third tier alone, which makes the rule look arbitrary. It is not. It is a principle, an exception, and a proviso inside the exception.

    Tier What it says Source
    Principle The package lists every ingredient used in manufacturing Cosmetics Act Art. 10(1), item 3
    Exception A perfuming agent may be written as the single word fragrance Enforcement Rule Annex 4 (labelling standards and methods)
    Proviso If the perfuming agent contains a fragrance allergen listed by the ministry, the single word is not enough and the substance must be named Same Annex 4 · MFDS notice Annex 2

    A fragrance is not one ingredient but dozens blended together, which is why the middle tier exists at all. The proviso has applied to products manufactured or imported since 1 January 2020.

    Evidence figure for an article on fragrance allergen labelling in Korea. First, Cosmetics Act Article 10 paragraph 1 item 3 requires the package to list every ingredient used, Enforcement Rule Annex 4 allows a perfuming agent to be written as one word, and a listed allergen inside that perfuming agent must be named separately; the rule has been in force since 1 January 2020. Second, there are two thresholds ten times apart: above 0.01 percent in rinse-off products and above 0.001 percent in leave-on products, judged per substance rather than on the sum, as the Korea Cosmetic Association question and answer states. Third, the 25 substances are amyl cinnamal, benzyl alcohol, cinnamyl alcohol, citral, eugenol, hydroxycitronellal, isoeugenol, amylcinnamyl alcohol, benzyl salicylate, cinnamal, coumarin, geraniol, anise alcohol, benzyl cinnamate, farnesol, butylphenyl methylpropional, linalool, benzyl benzoate, citronellol, hexyl cinnamal, limonene, methyl 2-octynoate, alpha-isomethyl ionone, evernia prunastri extract and evernia furfuracea extract. Fourth, Korea and the European Union use the same two figures but their lists are drifting apart: the EU works through Article 19 paragraph 1 point g and Annex III of Regulation 1223/2009, and Regulation 2023/1545 added 45 entries, replaced 17 and deleted 10 after the scientific committee identified 56 further fragrance allergens, with a transition until 31 July 2026 for placing on the market and 31 July 2028 for sale.

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    Two thresholds, ten times apart

    ✔ Rinse-off products — above 0.01%

    ✔ Leave-on products — above 0.001%

    The leave-on figure is ten times lower because the product stays on the skin. That is why perfumes, mists and body lotions carry longer allergen tails than a body wash does.

    One point is easy to get wrong: the figures are not a combined total. The Korea Cosmetic Association’s Q&A puts it plainly — the figure refers to the content of each individual substance, and each is judged on its own. Five allergens at low levels are five separate decisions, not one sum.

    The denominator is the net content of the product. In a 250 g body lotion, 0.05 g of limonene is about 0.02% — over the line, so limonene is named.

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    The 25, as the notice names them

    # #
    1  Amyl cinnamal 2  Benzyl alcohol
    3  Cinnamyl alcohol 4  Citral
    5  Eugenol 6  Hydroxycitronellal
    7  Isoeugenol 8  Amylcinnamyl alcohol
    9  Benzyl salicylate 10  Cinnamal
    11  Coumarin 12  Geraniol
    13  Anise alcohol 14  Benzyl cinnamate
    15  Farnesol 16  Butylphenyl methylpropional
    17  Linalool 18  Benzyl benzoate
    19  Citronellol 20  Hexyl cinnamal
    21  Limonene 22  Methyl 2-octynoate
    23  Alpha-isomethyl ionone 24  Evernia prunastri (oak moss) extract
    25  Evernia furfuracea (tree moss) extract

    Entries 24 and 25 are not single molecules but botanical extracts. The notice sets no order or format for where the names go; the association recommends following the ordinary ingredient-list method, and the ministry has said that pulling allergens out into a separate block of their own is not appropriate, because it suggests those substances alone are a problem.

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    When nothing is named

    Situation Why What follows
    Below the threshold Under 0.01% / 0.001% there is no duty to name The substance can be present and still invisible on the box
    Small packages Net content of 10–50 mL (g) leaves no room The listing may be omitted, but the information must be findable on the company’s website
    Online listings — The ingredient list shown on a sales page must carry the allergens too
    Raw material reporting — Allergens that appear on the label are included in the annual raw material report

    So an absent name does not mean an absent substance — and a present name does not mean a bad one. It means a threshold was crossed and the rule asked for daylight.

    There is Korean market data on how this plays out. The Seoul Institute of Health and Environment tested 106 fragranced cosmetics on sale in the city — 85 leave-on (perfume, body mist, body cream, hand cream) and 21 rinse-off (body wash) — screening for 23 of the allergens by GC-MS. One body mist failed the coumarin labelling requirement and was referred for administrative action; the other 105 complied. Measured levels ran from not detected up to about 1.5%.

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    Korea and the EU: the same two numbers, lists drifting apart

    This is the part worth knowing if you buy Korean products abroad, or sell them there.

    Korea European Union
    Legal basis Cosmetics Act Art. 10 · Enforcement Rule Annex 4 · MFDS notice Annex 2 Regulation (EC) No 1223/2009 Art. 19(1)(g) · Annex III
    The single word fragrance 「Perfume and aromatic compositions and their raw materials shall be referred to by the terms ‘parfum’ or ‘aroma’」
    What comes out of it the 25 substances in Annex 2 「the presence of substances, the mention of which is required under the column ‘Other’ in Annex III」
    Thresholds above 0.01% rinse-off · above 0.001% leave-on the same — 「0,01 % in rinse-off products」 · 「0,001 % in leave-on products」
    Most recent change Annex 2 still stands as amended on 16 December 2019 Regulation (EU) 2023/1545 added 45 entries to Annex III, replaced 17 and deleted 10, after the SCCS identified 56 further fragrance allergens
    Transition — non-compliant products may be placed on the market until 31 July 2026 and sold until 31 July 2028

    Read that last row together with the one above it. From August 2026, the same formula will need a longer allergen list in Brussels than it needs in Seoul. A short tail on a Korean box is not a cleaner perfume, and a long tail on a European one is not a heavier one. The two lists are simply different lengths, and only one of them has just grown.

    The EU also folded in prehaptens and prohaptens — substances that become allergens after air oxidation or metabolism on the skin — and grouped similar substances under shared names to make the labels readable. Korea’s notice has not taken that step.

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    What to check on the box

    ✔ Look at the tail end of the ingredient list, around the word fragrance

    ✔ A leave-on product showing more names than a rinse-off one is the rule working, not a warning

    ✔ If a scent has stung before, write down that one name and compare boxes

    ✔ On a small bottle with no names, check the brand’s own website listing

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    In one line

    A name after the word fragrance is not something that slipped out — it is something the rule pulled out. The thresholds are 0.01% and 0.001%, and each substance is judged on its own.

    What I left out, and why

    ✔ CAS numbers for the 25 — the Korean Law Information Center was unreachable the day this was written, so Annex 2 itself could not be opened. The names are taken from two trade publications that match character for character; the numbers are omitted rather than guessed

    ✔ Verbatim text of Enforcement Rule Annex 4 — same reason: the substance of the provision is given, but not in quotation marks

    ✔ The EU’s own list of substances — Annex III tables do not come through in the consolidated text. Only the entry counts stated by the amending regulation are given

    ✔ The current Korean status of butylphenyl methylpropional (Lilial) — the EU moved it to the prohibited annex in 2022. Korea’s prohibited-ingredient annex could not be opened, so whether it may still be used here is not stated either way

    ✔ Prevalence figures for individual allergens — no primary studies were opened for this article, so none are quoted

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    📌 Earlier guides

    📌 How to Read a Korean Cosmetic Ingredient List (Ingredient Guide 14) — where the order stops at 1%

    📌 Ceramides: cholesterol and fatty acid ratio (Ingredient Guide 4)

    📌 Panthenol: What the Dexpanthenol Studies Show (Ingredient Guide 7)

    📌 Skin Concern Ingredient Map

    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.

    📄 Sources

    · Cosmetics Act (Korea), Article 10 · Enforcement Rule, Annex 4 (labelling standards and methods)

    · MFDS notice, Precautions for Use of Cosmetics and Labelling of Fragrance Allergens, Annex 2

    · Korea Cosmetic Association, ingredient dictionary Q&A on allergen labelling

    · MFDS guidance on labelling fragrance allergens (via trade press reporting)

    · Seoul Institute of Health and Environment, survey of 106 fragranced cosmetics

    · Regulation (EC) No 1223/2009, Article 19(1)(g) · Regulation (EU) 2023/1545

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    This article summarises statutes and ministry notices and is not a substitute for diagnosis or treatment. The Korean Law Information Center was unreachable the day it was written, so the 25 names were cross-checked against an association Q&A and two trade publications, and CAS numbers and verbatim provisions were left out. EU material is taken from the current public text on EUR-Lex.

    — Dr. J Ingredient Notes

  • Cosmetic Color Additives in Korea: Why a Colorant Not on the List Cannot Go in the Bottle (Ingredient Guide 24)

    Cover image for a Dr. J Ingredient Notes article on cosmetic colorants in Korea. It explains that the Cosmetics Act has the ministry set use standards for colorants by notice, so only colorants written in Annex 1 of the notice may be used, and that the restriction column decides where each colorant may be used rather than how much of it.

    🇰🇷 한국어판 보기

    Hello, this is Dr. J. Today we are reading Korea’s cosmetic colorant rules — which colorants a product may contain, and which it may not.

    Here is the part that surprises people. Korea does not regulate colorants by banning the dangerous ones. It writes down the ones you may use, and everything outside that list is off the table. The United States and the European Union work the same way.

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    The sources, first

    📄 Cosmetics Act Article 8 (Korea Cosmetic Association)

    📄 Types and Standards of Cosmetic Colorants, MFDS Notice No. 2023-61

    📄 Annex 1 — Cosmetic colorants (to Article 3)

    📄 Color Additives and Cosmetics (U.S. FDA) · 21 CFR Part 74, Subpart C

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

    Annex 1 gives every colorant a number, a name, a CI number, a restriction and a remark. Look your product’s colorant up there and the answer to «where may this colour be used» is one line long.

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    In short, five lines

    ✔ A colorant that is not on the list cannot be used — this is a permitted list, not a ban list

    ✔ The notice in force is Types and Standards of Cosmetic Colorants (MFDS Notice No. 2023-61)

    ✔ Annex 1 has four columns: number, colorant, use restriction, remarks

    ✔ The restriction column decides where a colour may be used, not how much of it

    ✔ Red No. 2 and Red No. 102 may not go into products labelled for children

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    A permitted list, not a ban list

    There are two ways to regulate what goes into a cosmetic. You can name the materials that must stay out, or you can name the materials that may go in. Korea’s Cosmetics Act does both — and colorants belong to the second kind.

    Paragraph What it sets The text
    Article 8(1) A list of raw materials that cannot be used The Minister of Food and Drug Safety shall designate and give public notice of raw materials that cannot be used in manufacturing cosmetics
    Article 8(2) Use standards for preservatives, colorants and UV filters For raw materials that need particular restrictions on use, such as preservatives, colorants and ultraviolet blocking agents, the Minister shall designate and give public notice of their use standards

    Paragraph 1 is the ban list. Paragraph 2 is the permitted list, and colorants are named in it, next to preservatives and ultraviolet filters. The consequence is simple: a colour that has not been written into the notice cannot be used in a cosmetic, even though no rule says it is dangerous.

    Read the other way round, every colorant name printed on a Korean cosmetic box has already been through that door.

    Evidence figure on cosmetic colorants in Korea. First, Cosmetics Act Article 8 paragraph 1 has the ministry list raw materials that cannot be used, and paragraph 2 has it set use standards for preservatives, colorants and ultraviolet filters by notice, so a colorant that is not on the list cannot go into a cosmetic product. Second, the notice is Types and Standards of Cosmetic Colorants, MFDS Notice No. 2023-61 of 21 September 2023, formerly titled Types, Standards and Test Methods of Cosmetic Colorants, and its Annex 1 table has four columns, number, colorant, use restriction and remarks, with number one being Green No. 204 Pyranine Conc, CI 59040. Third, Article 2 of the notice defines seven terms: colorant, tar colorant, pure colorant, lake, substrate, diluent and area of the eye. A lake is a tar colorant chemically fixed onto a substrate such as alumina, and the area of the eye covers the eyebrow, the skin below it, the eyelid and eyelashes and the area inside the orbital ridge. Fourth, the restriction column carries entries such as not for use around the eyes or on the lips, not for products labelled for infants or children aged 13 or under which applies to Red No. 2 and Red No. 102, for toilet soap only which applies to Pigment Red No. 5, and for temporary hair colorants only, a condition attached to 25 colorants added in the 2016 amendment.

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    Seven terms, and the two that matter at the shelf

    The notice is called Types and Standards of Cosmetic Colorants (MFDS Notice No. 2023-61, 21 September 2023). Its former title was Types, Standards and Test Methods of Cosmetic Colorants — worth knowing, because a good deal of what is written online still cites the old name. Article 2 defines seven terms.

    Term How the notice defines it
    colorant an ingredient whose main purpose is to give colour to a cosmetic or to the skin
    tar colorant a colorant derived from coal tar or its intermediates, or obtained by organic synthesis, together with its lakes, salts and mixtures with diluents
    pure colorant the colorant itself, without intermediates, diluents or substrates
    lake a tar colorant fixed onto a substrate by chemical bonding — an aluminium lake when the substrate is aluminium
    substrate the material a pure colorant is spread onto when a lake is made — alumina, titanium dioxide and the like
    diluent a material mixed in to make a colorant easier to handle. It may not be a raw material that cosmetics cannot use
    area of the eye the eyebrow, the skin below the eyebrow, the eyelid and the eyelashes, and the area inside the orbital ridge

    Two of them show up on labels.

    Lake. A water-soluble colorant fixed onto a powder so that it stays where it is put. On an ingredient list it reads «Red No. 202 Aluminum Lake». The same colour index number behaves differently once it is a lake, which is why colour cosmetics carry the word so often.

    Area of the eye. The notice draws the boundary itself: the eyebrow, the skin below it, the eyelid and the eyelashes, and the area inside the orbital ridge. Eyeshadow, eyeliner, mascara and eye cream are all inside it. So a colorant marked «not for use around the eyes» can still colour a lipstick or a blusher — it simply cannot go near the eye.

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    What the restriction column decides

    If you only read one column of Annex 1, read this one. It is not about concentration — it is about place of use, and it comes in four shapes.

    What the restriction column says Which colorants Where it came from
    Not for use around the eyes or on the lips Green No. 204 · Green No. 401 · Orange No. 206 · Orange No. 207 · Purple No. 401 · Red No. 205-208 · Red No. 219 · Red No. 225 · Red No. 405, among others Annex 1, restriction column
    Not for products for infants, or for products labelled as usable by children aged 13 or under Red No. 2 (Amaranth) · Red No. 102 (New Coccine) The 2019 amendment (Notice No. 2019-73) widened this from infant products alone
    For toilet soap only Pigment Red No. 5 Same 2019 amendment, in force from 31 December 2019
    For temporary hair colorants only basic, HC and disperse series colorants 25 colorants entered on this condition in the 2016 amendment

    Two reds make the point. Red No. 2 and Red No. 102 are permitted colorants in Korea; they simply cannot go into a product that is labelled as usable by children aged 13 or under. Before the 2019 amendment the bar covered infant products alone.

    This is the same construction we met in the children’s cosmetics guide: the rule starts at the label, not at the ingredient. Print «for children» on the box and this line attaches to the product.

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    Four amendments in ten years

    Notice When What changed
    No. 2016-49 24 June 2016 Tar colorants and other colorants were brought into one notice, and 25 colorants for temporary hair colorants were added
    No. 2019-73 2019 Red No. 2 and Red No. 102 were barred from products labelled for children aged 13 or under; Pigment Red No. 5 became toilet-soap only (stock made or imported before the date had two years to sell through)
    No. 2020-64 20 July 2020 Toilet soap moved from industrial goods into cosmetics, so colorants usable in toilet soap were added
    No. 2023-61 21 Sep 2023 The notice in force today. Its title settled as Types and Standards of Cosmetic Colorants

    The 2016 amendment was the structural one. Until then tar colorants had a notice of their own; bringing tar colorants and the rest into a single table is what produced the Annex 1 we read today.

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    Korea, the United States and the EU: one method, three lists

    The FDA states it plainly: «All color additives used in cosmetics (or any other FDA-regulated product) must be approved by FDA.» The EU Cosmetics Regulation does the same job in Article 14(1), which bars «colorants other than those listed in Annex IV». Three jurisdictions, three lists, one method.

    Korea United States European Union
    Method Use the colorants written in Annex 1 of the MFDS notice Use the colorants on the FDA list — 29 exempt from certification (21 CFR 73), 36 subject to it (21 CFR 74) Use the colorants listed in Annex IV
    A colorant off the list Cannot be used (Cosmetics Act Article 8(2)) «failure to meet U.S. color additive requirements causes a cosmetic to be adulterated» «colorants other than those listed in Annex IV… » may not be present (Article 14(1)(c)(i))
    Around the eye The notice defines «area of the eye» and writes the limit into each colorant’s row The permitted-colorant table carries a separate «Eye Area» column Written into the conditions of use in Annex IV
    Batch testing None Synthetic organic colors are certified batch by batch: «All batches… shall be certified in accordance with regulations in part 80» None
    Hair dye Colorants for temporary hair colorants sit inside the same list Coal-tar hair dyes are the stated exception Hair colorants fall outside Annex IV (Article 14(2))

    Two differences are worth carrying with you.

    The eye is treated as its own place everywhere. The FDA defines the area of the eye as «the area enclosed within the circumference of the supra-orbital ridge and the infra-orbital ridge, including the eyebrow, the skin below the eyebrow, the eyelids and the eyelashes, and conjunctival sac of the eye» — the same boundary Korea’s notice draws, in almost the same words. And where a colour is cleared for that area, the US regulation says so in the colorant’s own section: «FD&C Blue No. 1 may be safely used for coloring cosmetics generally, including cosmetics intended for use in the area of the eye».

    Batch certification exists only in the United States. Synthetic organic colors must be submitted to FDA lot by lot — «All batches… shall be certified in accordance with regulations in part 80 of this chapter» — while colors drawn from mineral, plant or animal sources are exempt. Korea and the EU have no equivalent step. If you have wondered why an imported product’s colorant line sometimes carries an extra designation, this is one of the reasons.

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    What to check on the box

    ✔ Colorants sit near the end of the ingredient list, as «colour No. N» or a CI number

    ✔ «Aluminum Lake» means the colour has been fixed so that it does not bleed

    ✔ On a product labelled for children, look for Red No. 2 and Red No. 102

    ✔ Eyeshadow, mascara and eye cream are all «area of the eye» products

    ✔ How deep the colour looks is a question of amount; whether it may be there at all is a question of the list

    A long row of colorant names is not a warning sign. Being named at all means the colour is on the list. What is worth checking is not how many there are, but whether this colour belongs in this kind of product.

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    What I left out, and why

    ✔ The full Annex 1 table. Korea’s national law portal did not open on the day this was written, so I kept to the shapes of the restriction column and the colorants named in them

    ✔ How many colorants are on the list. The 2016 amendment carried 127; three amendments have followed, so today’s count may differ and I did not print a number

    ✔ Safety debates about tar colorants. I could not open primary sources. What the notice settles is where a colour may be used, and that is the scope of this article

    ✔ The notice’s entry-into-force date and review deadline. I saw them on a mirror but not in the original, so they are not here

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    One line

    A colorant is used where the list says it may be used. Next to the colour’s name on the back of the box, the place it is allowed to go has already been decided.

    Next in this series: cosmetic preservatives — parabens, phenoxyethanol, and how to read the limits on the back label.

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    📌 Related

    📌 How to Read a Korean Cosmetic Ingredient List (Ingredient Guide 14) — where colorant names appear

    📌 Salicylic Acid (BHA): 0.5% vs 2%, Explained (Ingredient Guide 8) — the preservative named beside colorants in Article 8(2)

    📌 Sunscreen SPF and PA: How to Read the Numbers (Ingredient Guide 11) — the third material in the same paragraph

    📌 AHA vs BHA: Is Glycolic Acid an AHA? (Ingredient Guide 13)

    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.

    📄 References

    · Cosmetics Act (Korea), Article 8 — Safety standards for cosmetics

    · Types and Standards of Cosmetic Colorants, MFDS Notice No. 2023-61 (21 September 2023), Articles 2, 3, 5 and Annexes 1 and 2

    · Types, Standards and Test Methods of Cosmetic Colorants, Notice No. 2016-49 (24 June 2016) and its partial amendment draft

    · Notice No. 2019-73 as reported by Cosmorning, 3 September 2019 · Notice No. 2020-64 per the Korea Cosmetic Association

    · U.S. FDA, Color Additives and Cosmetics · Color Additives Permitted for Use in Cosmetics · 21 CFR Parts 73, 74 and 80

    · Regulation (EC) No 1223/2009, Article 14 and Annex IV

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    This article summarises statutes and administrative notices and is not a substitute for diagnosis or treatment. The full Annex 1 table could not be retrieved on the day of writing; the restriction wording and the colorants named here were confirmed against the notice text and the 2016 amendment draft. US and EU material is quoted from the current public versions published by those authorities.

    — Dr. J Ingredient Notes