Tag: not tested on animals

🇰🇷 한국어판 읽기

Hello, this is Dr. J. A Korean cosmetic box that says vegan almost never says “not tested on animals” beside it. Shoppers read the gap as a gap. It is not one — it is a rule.

Here is the part most summaries skip. No statute anywhere defines the word “vegan” for cosmetics — not in Korea, not in the EU, not in the United States. What differs between the three is what fills that empty space, and what a label is allowed to print next to the word.

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Primary sources

📄 Guide to Vegan Labelling and Advertising of Cosmetics, 2025 (Korea Cosmetic Association, PDF, Korean)

📄 Cosmetics Act Article 15-2 (Korean Law Information Center)

📄 Regulation (EU) No 655/2013, common criteria for cosmetic claims (EUR-Lex)

📄 “Cruelty Free”/“Not Tested on Animals” (U.S. FDA)

The Korean guide runs to a few pages and has three chapters: purpose, scope, and criteria. The EU regulation carries the six common criteria in its Annex.

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The five lines, if you are in a hurry

✔ “Vegan” is not defined in Korean law — a 2025 industry guide sets the requirements

✔ A product must meet all three: no animal ingredient, none animal-tested, and no testing of the finished product

✔ Ingredients processed with micro-organisms are allowed — fermentation does not break a vegan claim

✔ Share a production line with a non-vegan batch and you wash it thoroughly first

✔ A Korean label cannot print “not tested on animals” — the sale is already banned, so the claim would mislead

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The word is not in the statute — a 2025 industry guide fills the gap

Search the Korean Cosmetics Act for “vegan” and nothing comes back. The text that does define it was issued in 2025 by the advertising advisory committee of the self-regulatory review body run by the Korea Cosmetic Association. The guide says of itself that it exists to give advertisers “the minimum requirements for making a vegan claim.”

Its scope is a single line: “This guide applies to cosmetics that are labelled or advertised as vegan.” A product that does not make the claim is outside it.

	What the guide requires	What it means on a shelf
1	A cosmetic that contains no ingredient of animal origin	The ingredient side. Honey, beeswax and lanolin are the familiar examples
2	A cosmetic that contains no ingredient tested on animals under the Cosmetics Act	The ingredient’s history, which never appears on the ingredient list
3	A cosmetic not itself tested on animals under the Cosmetics Act	The finished product, not only its parts
All	“A cosmetic that satisfies all of the requirements below”	Miss one and the word may not be printed

※ The clause numbers inside the guide do not survive text extraction from the PDF, so this article names the chapters rather than the subparagraphs.

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Ingredients, manufacturing, substantiation — the three chapters that follow

After the definition the guide sets out how to keep to it. The second line below is the one that surprises formulators.

Chapter	The guide’s wording	Reading
Ingredient standard	“Ingredients of animal origin and ingredients that have been tested on animals shall not be used. An ingredient that has been processed with micro-organisms not derived from animals (bacteria, yeasts, fungi and the like) may be used.”	A fermented ingredient does not break a vegan claim. Using a micro-organism is not the same as using an animal
Manufacturing and control	“Ingredients of animal origin shall be kept from entering a vegan product during manufacture. For example, where a vegan and a non-vegan product are made on the same equipment, machines, equipment, tools and contact surfaces shall be washed thoroughly before the vegan product is made.”	A dedicated line is not required. Cleaning is accepted in its place
Substantiation	“A cosmetic labelled or advertised as vegan shall be able to substantiate that it meets the criteria.”	Making the claim means holding the file. It runs on the same track as Article 14 of the Cosmetics Act

The guide cites, as its legal footing, Articles 10, 13 and 14 of the Cosmetics Act with Articles 19, 22 and 23 of the Enforcement Rule and its Annex 5 — and Article 15-2. The guide itself carries no penalty; those provisions do.

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What may be said, and what may not

Two of the four rows below are the ones a brand entering Korea tends to get wrong.

Situation	What the guide sets	On the box
The finished product meets the criteria	It may be labelled and advertised as vegan	The word describes one finished product
Only some ingredients meet them	“A product may not be labelled or advertised as a vegan cosmetic on the basis of particular ingredients alone, rather than the finished product, even where those ingredients meet the criteria.”	“Made with vegan ingredients” and “vegan cosmetic” are different claims
“Not tested on animals”	“Although the distribution and sale of cosmetics tested on animals … is prohibited, wording such as ‘not tested on animals’, which could lead consumers to believe that animal-tested cosmetics are also on the market, may not be used.”	Its absence is not an omission — the phrase is not permitted
Certification marks	The guide carries no rule on certifying bodies or marks	A mark tells you whose standard was met, which you check separately

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The statute behind the banned line — Cosmetics Act Article 15-2

The reason the phrase is off-limits sits in the statute. Korea already bans the sale, so printing the claim would suggest that products without it are the tested ones.

Paragraph	The provision	Reading
(1), main text	“A cosmetics responsible distributor or a customised cosmetics seller shall not distribute or sell a cosmetic on which animal testing under Article 2(1) of the Laboratory Animal Act has been conducted, or a cosmetic manufactured (including contract manufacture) or imported using an ingredient on which animal testing has been conducted.”	What is blocked is selling. “Including contract manufacture” sits in brackets, and imports are in the same sentence
(1), proviso	“Provided, that this shall not apply in any of the following cases” (amended 13 Mar 2018, 17 Aug 2021)	Six exceptions follow (next table)
(2)	“The Minister of Food and Drug Safety shall endeavour to develop alternative test methods and shall take the measures necessary for cosmetics responsible distributors and others to use them.”	The duty that pairs with the ban, and the provision that narrows exception 2
Inserted	[This Article Newly Inserted on 3 February 2016]	Reported as in force from 4 February 2017; we could not open the addendum itself

The six exceptions, as the statute words them:

No.	The provision	In short
1	Where necessary to designate standards of use for ingredients requiring particular restriction — preservatives, colorants, ultraviolet filters and the like under Article 8(2) — or to carry out a risk assessment under Article 8(3) of ingredients raising public-health concerns	Safety work. Three ingredient classes are named
2	Where animal testing is necessary because no alternative test method exists (an alternative test method being a method that uses no animals, or that reduces the number of animals used or lessens their pain, recognised as such by the Minister of Food and Drug Safety)	Nothing else will do. The definition sits inside the provision
3	Where animal testing is required by the law of the country of export	The receiving market demands it
4	Where animal testing is required for product development by the law of the country of import	The sourcing market demands it
5	Where an ingredient developed through animal testing under another statute is used in manufacturing a cosmetic	A pharmaceutical-track ingredient, for instance
6	Other cases, designated by the Minister of Food and Drug Safety, where an alternative test is impracticable	Room left for a ministry notice

The penalty is an administrative fine of up to KRW 1 million under Article 40(1)7. Translations of the Korean provisions here are ours.

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Korea, the EU and the United States — one word, three situations

Set the three side by side and the pattern is clear. None of them defines the word. What differs is what stands in for a definition, and whether the adjacent claim is allowed.

	Korea	European Union	United States
Is “vegan” defined in law?	No. A 2025 industry guide sets three requirements	No. Regulation (EU) No 655/2013 sets six common criteria for every claim	No. FDA: “there are no legal definitions for these terms”
What fills the gap	A self-regulatory guide, plus a substantiation file	Criterion 6, informed decision-making, and a technical document listing “‘free from animal-derived ingredients’, e.g. in products intended for vegans” among acceptable claims	Nothing. The claim is left to the company
“Not tested on animals”	May not be printed — Article 15-2 already bans the sale	Permitted if the six criteria are met; Regulation (EC) No 1223/2009 Article 18 bans the testing itself	Unrestricted. FDA notes firms “may rely on raw material suppliers or contract laboratories to perform any animal testing necessary”
Who holds the evidence	The advertiser — “shall be able to substantiate”	The responsible person, in the product information file (Article 2 of 655/2013)	The company, by whatever means it chooses

For a brand, the practical reading is that Korea regulates the words around the claim rather than the claim itself. A pack artwork that pairs “vegan” with “not tested on animals” passes in the EU and the United States and fails in Korea — and the Korean reason is not that the statement is false, but that it is already true of everything on the shelf.

The EU technical document is worth one caution. It carries the line “IT IS NOT A EUROPEAN COMMISSION DOCUMENT” and is dated as a version of 3 July 2017, agreed by a sub-working group. It is guidance on how to apply the six criteria, not a statute.

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Four things to check on a Korean box

✔ Next to “vegan”, look for which standard or certifier is named

✔ “Made with vegan ingredients” is not the same claim as “vegan cosmetic”

✔ A missing “not tested on animals” is not a missing feature — the phrase is not allowed

✔ Whether a product is gentle is a question of ingredients and concentrations, read separately

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In one line

No statute defines “vegan” for cosmetics, and in Korea a 2025 industry guide sets three requirements that must all be met. No ingredient of animal origin, none tested on animals, and no testing of the finished product — with fermented ingredients expressly allowed, and one neighbouring phrase expressly forbidden.

What we left out, and why

✔ The guide’s subparagraph numbers — they do not survive text extraction from the PDF, so we name the chapters instead

✔ Any vegan certifier or mark — the guide names none, and we verified none as a primary source, so we name none either

✔ A list of animal-derived ingredients — the guide carries no such table; honey, beeswax and lanolin appear here as commonly cited examples

✔ The commencement date of Article 15-2 — the law portal does not return addenda, so 4 February 2017 rests on press reports

✔ Any vegan entry in the MFDS labelling guidance — the 14 August 2025 guidance lists natural and organic wording among restricted expressions, but nothing on vegan or animal testing

✔ Claims that vegan products are gentler — no primary source, so not written

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📌 Earlier guides

📌 How to Read a Korean Cosmetic Ingredient List (Guide 14) — where the ingredient names are checked

📌 Collagen: Topical vs Oral (Guide 5) — an ingredient that comes from an animal

📌 Bakuchiol vs Retinol — the 44-person trial (Guide 3) — an ingredient that comes from a plant

📌 Sunscreen SPF and PA: How to Read the Numbers (Guide 11) — one of the three classes named in exception 1

📄 Sources

· Korea Cosmetic Association, Guide to Vegan (VEGAN) Labelling and Advertising of Cosmetics (issued 2025), by the advertising advisory committee of the self-regulatory review body for cosmetic labelling and advertising

· Cosmetics Act of Korea, Article 15-2(1) and (2), Article 40(1)7, Article 8(2) and (3), Articles 10, 13 and 14

· Laboratory Animal Act, Article 2(1)

· Ministry of Food and Drug Safety, Guidance on the Management of Cosmetic Labelling and Advertising (14 August 2025)

· Regulation (EU) No 655/2013, common criteria, Annex points 1–6

· European sub-working group on claims, Technical document on cosmetic claims, Annex III (version of 3 July 2017)

· Regulation (EC) No 1223/2009, Article 18

· U.S. FDA, “Cruelty Free”/“Not Tested on Animals” (content current as of 25 February 2022)

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This article summarises an industry guide and statutes for general information and is not a substitute for diagnosis or treatment. On the day it was written the Korean law portal was unreachable, so Article 15-2 was taken verbatim from a statute mirror and the commencement date from press reports. Translations of the Korean provisions and of the guide are ours; the subparagraph numbers inside the guide do not survive text extraction from the PDF, so chapters are named instead.

— Dr. J Ingredient Notes