Tag: wrinkle improvement

  • Functional Cosmetics in Korea: The 11 Categories, the Notified Ingredients, and What the Label Certifies (Ingredient Guide 16)

    Cover image for a guide to functional cosmetics in Korea, explaining the eleven categories set by the Cosmetics Act and its Enforcement Rule and what the words on the package certify. Ingredient Guide 16 from Dr. J Ingredient Notes.

    🇰🇷 한국어판: 기능성화장품 뜻과 종류 11가지 – 무엇을 보증하나

    Hello, this is Dr. J. If you have ever turned over a Korean cream and seen the words 기능성화장품 — functional cosmetics — this post is about what that line actually certifies.

    It is not a marketing word. It is a legal category, with a fixed list of eleven things a product is allowed to be, a fixed set of ingredients and amounts, and a fixed sentence the package has to carry. Once you know where the line comes from, the shelf reads differently.

    There is one more reason this is worth reading if you are outside Korea. The EU forbids exactly what Korea requires. Under EU rules, a cosmetic label may not claim that an authority approved it. In Korea, that approval is the label. Same bottle, two opposite drawers — the table further down sets them side by side.

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    📄 The original documents

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

    📄 Enforcement Rule of the Cosmetics Act, Annex 4 — labelling standards (Korean)

    📄 21 CFR 333.310 — US acne treatment active ingredients

    📄 Commission Regulation (EU) No 655/2013 — common criteria for cosmetic claims

    📄 Regulation (EC) No 1223/2009 on cosmetic products

    🏠 FDA — Is It a Cosmetic, a Drug, or Both?

    The two Korean links download the annex tables themselves. They give the ingredient, the amount, the permitted form, the claim wording and the directions for use, one line each.

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    The short version

    ✔ The Act names five groups; the Enforcement Rule splits them into eleven categories

    ✔ Build a product to a notified ingredient at a notified amount and you file a report instead of a full review

    ✔ Annex 4 lists 9 whitening ingredients, 4 for wrinkles, 29 UV filters and one for acne

    ✔ The package carries the words and the reviewed claim, in type at least as large

    ✔ Hair loss, acne, barrier and stretch marks also carry “not a drug”

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    Five groups in the Act, eleven categories in the Rule

    Article 2(2) of the Cosmetics Act defines functional cosmetics as products falling under one of five items, “as prescribed by Ordinance of the Prime Minister”. That ordinance is the Enforcement Rule, and its Article 2 is where the list becomes eleven.

    Cosmetics Act, Article 2(2) Enforcement Rule, Article 2 — the eleven categories
    a. Helps whiten the skin 1. Prevents melanin from settling, so freckles and dark spots are held back
    2. Lightens melanin that has already settled
    b. Helps improve wrinkles 3. Firms the skin so wrinkles are eased or improved
    c. Helps tan the skin evenly, or protects it from UV 4. Shields from sunlight for an even tan
    5. Blocks or scatters UV to protect the skin
    d. Helps change, remove or nourish hair colour 6. Changes hair colour, or bleaches and strips it
    7. Removes body hair (physical removal excluded)
    e. Helps prevent or improve dryness, cracking, falling out or keratinization caused by weakened skin or hair function 8. Eases hair loss symptoms (coating and other physical methods excluded)
    9. Eases acne-prone skin (cleansing products)
    10. Restores barrier function so itching improves
    11. Improves the red lines of stretch marks

    Read the table left to right and one thing stands out. Four categories came out of a single item — item e. Hair loss, acne, barrier repair and stretch marks all sit under a sentence about dryness, cracking, falling out and keratinization. Those same four are the ones that must carry the “not a drug” sentence, which we will get to.

    Anything outside these eleven cannot be sold as a functional cosmetic. A Korean pack may still shout about pores or firmness in large type — that is ordinary advertising copy, not this category.

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    A review, or a report

    Article 4(1) of the Act: “A cosmetics manufacturer, a cosmetics responsible distributor, or a university or research institute prescribed by Ordinance of the Prime Minister that intends to sell a product recognised as a functional cosmetic shall, for each item, either undergo a review by the Minister of Food and Drug Safety as to safety and efficacy, or submit a report to the Minister.”

    The review route asks for a good deal. Article 4 of the Regulation on the Review of Functional Cosmetics sets out what has to be filed:

    ✔ Origin and development history

    ✔ Safety — single-dose toxicity, skin irritation, sensitisation, photo-toxicity, human patch testing

    ✔ Efficacy or function — efficacy testing, human application testing, hair-dye efficacy testing

    ✔ Supporting data for the SPF, water resistance and PA figures

    ✔ Specifications and test methods, with samples

    The report route replaces all of that in three situations: the ingredient, amount, claim, directions, specifications and test methods are already notified; the product is identical in every one of those respects to something already reviewed; or it mixes a reviewed product with a notified one. Article 6 of the same Regulation is the hinge — meet Annex 4 and the data requirement falls away.

    Evidence card image summarising Korea's rules on functional cosmetics. First, the Cosmetics Act Article 2(2) names five groups: whitening, wrinkle improvement, tanning or UV protection, hair colour change, removal or nourishment, and preventing or improving dryness, cracking, hair loss and keratinization. Second, Article 2 of the Enforcement Rule splits them into eleven categories including acne relief in cleansing products, barrier repair for itch and stretch mark lines. Third, Annex 4 of the Regulation on the Review of Functional Cosmetics lists nine whitening ingredients, four wrinkle ingredients and twenty-nine UV filters, with lotion, liquid, cream and sheet mask as the permitted forms, and salicylic acid 0.5 percent for acne in rinse-off cleansing products. Fourth, the package must carry the words for functional cosmetics or the official symbol, the reviewed or reported claim with directions for use, and for hair loss, acne, barrier and stretch marks the sentence that it is not a drug for preventing or treating disease.

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    Annex 4 — read its title slowly

    The table is called “Types of functional cosmetics for which data submission is omitted”. So the amounts in it are not ceilings, and they are not “the dose that works best”. They are the amounts at which you no longer have to prove anything new.

    Group in Annex 4 Ingredients Forms and product type Claim wording
    Even tanning · UV protection 29 filters with maximum levels
    benzophenone-3 5% · zinc oxide 25% · titanium dioxide 25% and others
    Lotion, cream and oil; basic and colour make-up product types Carried by the SPF and PA figures
    Skin whitening 9 ingredients Lotion, liquid, cream and sheet mask “Helps whiten the skin”
    Wrinkle improvement 4 ingredients Lotion, liquid, cream and sheet mask “Helps improve skin wrinkles”
    Hair colour change Dyes, bleaches and strippers Set out by form in the table Dyeing, bleaching, stripping
    Hair removal As listed in the table Liquid, cream, lotion, aerosol “Depilation (removal of body hair)”
    Acne-prone skin relief Salicylic acid 0.5% — the only one listed Cleansing product type (soap-based); liquid, lotion, cream “Helps ease acne-prone skin”
    Directions: “rinse off immediately with water”

    The acne row is the one people misread. The directions column says “rinse off immediately with water”, and the product type is a cleansing preparation. That is why so many Korean products with an acne functional claim are face washes rather than leave-on serums.

    Notice also what is not in Annex 4: hair loss, barrier repair and stretch marks. No ingredient has been notified for those three, so a product claiming them goes down the review route. How those individual reviews are decided in practice is something I could not open a source for, so I will leave it there.

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    The nine and the four, by name

    This is the table to hold against a back label. If one of these names appears and the front says functional cosmetic, the product was most likely built to the notified amount and reported.

    Whitening (9) Amount Wrinkle improvement (4) Amount
    Broussonetia extract 2% Retinol 2,500 IU/g
    Arbutin 2–5% Retinyl palmitate 10,000 IU/g
    Ethyl ascorbyl ether 1–2% Adenosine 0.04%
    Oil-soluble licorice extract 0.05% Polyethoxylated retinamide 0.05–0.2%
    Ascorbyl glucoside 2% — —
    Magnesium ascorbyl phosphate 3% — —
    Niacinamide 2–5% — —
    Alpha-bisabolol 0.5% — —
    Ascorbyl tetraisopalmitate 2% — —

    Both groups also have fixed forms: lotion, liquid, cream and sheet mask. The claim wording is fixed too, and so are the directions (“apply an appropriate amount evenly to the skin”; sheet masks are removed after 10 to 20 minutes).

    That form restriction has a practical edge. The same ingredient at the same percentage in an essence or ampoule falls outside the table, and the product has to be reviewed rather than reported.

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    Korea, the United States and the EU — three different drawers

    If you buy Korean skincare from abroad, this is the part worth keeping. The same tube can be a state-reviewed “functional cosmetic” in Seoul, an ordinary cosmetic in Paris, and, depending on what the label says, a drug in the United States.

    Korea United States European Union
    Is there a category for this? Yes — “functional cosmetics”, defined in the Cosmetics Act No. A product that claims to affect the structure or function of the body becomes a drug under the FD&C Act No. Everything is a cosmetic product under Regulation 1223/2009
    Who checks before it is sold? MFDS review, or a report, product by product (Act Article 4) No premarket approval for cosmetics. OTC drugs may follow a monograph instead A responsible person must be designated (Art. 4) and the product notified to the Commission (Art. 13)
    Where do the numbers come from? Annex 4 — whitening 9, wrinkles 4, UV filters 29, acne salicylic acid 0.5% Monograph ranges — for acne, salicylic acid 0.5 to 2% (21 CFR 333.310) The Annexes restrict what may be used; they do not set amounts for efficacy
    May the label say a public authority approved it? Yes — the words on the pack are exactly that There is no approval to point to Not allowed. “Claims that indicate that the product has been authorised or approved by a competent authority within the Union shall not be allowed” (Reg. 655/2013)
    What else must the label carry? The reviewed claim with directions; four categories add “not a drug for preventing or treating disease” A Drug Facts panel when the product is an OTC drug Claims must be legal, truthful, evidenced, honest, fair and clear (the six common criteria)

    The last two rows are where the systems genuinely collide. The EU’s common criteria open with this: “Claims that indicate that the product has been authorised or approved by a competent authority within the Union shall not be allowed.” The whole point of the Korean line is the opposite — it tells you the Ministry looked at it.

    The US draws its line somewhere else again. FDA’s own wording is that cosmetics are “intended to be rubbed, poured, sprinkled, or sprayed on… for cleansing, beautifying, promoting attractiveness, or altering the appearance”, while a drug is “intended to affect the structure or any function of the body”. Claim the second thing and the product changes category. FDA also notes that “cosmeceutical” has no meaning under the law.

    So a Korean whitening cream with adenosine at 0.04% is not “approved” anywhere else — the category it belongs to simply does not exist outside Korea. That is worth knowing before you read too much into the words.

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    What has to be on the package

    ✔ The words 기능성화장품, or the symbol the Minister designates — Act Article 10(1)8

    ✔ The claim and the directions that were reviewed or reported

    ✔ For hair loss, acne, barrier and stretch marks: “not a drug for the prevention or treatment of disease”

    ✔ For products labelled for infants (3 and under) or children (4 to 13): the preservative content

    The placement is fixed as well. Annex 4 of the Enforcement Rule says the sentence goes directly beneath the words 기능성화장품, in type at least as large. So if you can see the words but not the claim, look again just under them.

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    How I read the label after that

    I treat the line as an answer to one question: which of the eleven, and did it clear the procedure for that one? It is a good answer, and it is a narrow one.

    It does not tell you how much the product will do. The notified amount is the amount that lets a company skip new data, not the amount chosen for the strongest result. So the next thing I look at is the amount and the form.

    For wrinkles, is adenosine there at 0.04%? For whitening, is arbutin or niacinamide in the 2–5% band? And where does that name sit in the ingredient list? Remember that below 1% the order stops meaning anything (Ingredient Guide 14).

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    Five things to check when buying

    ✔ Is what you want one of the eleven — whitening, wrinkles, sun, and so on

    ✔ Does the claim directly under the words match it

    ✔ Is a notified ingredient in the list — adenosine 0.04%, arbutin 2–5%

    ✔ Is the form lotion, liquid, cream or sheet mask (for whitening and wrinkles)

    ✔ For sun care, are the SPF and PA figures printed alongside

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    One line

    “Functional cosmetic” means the product cleared a review or a report for one of eleven named claims. Read the sentence under the words first; then read the amount and the form.

    Next up: expiry dates and period-after-opening — the two dates on a Korean package, and what the open-jar symbol means (Ingredient Guide 17).

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    📌 Earlier posts

    📌 Arbutin vs Alpha-Arbutin: What Korea’s 2–5% Means (Ingredient Guide 15)

    📌 Adenosine 0.04%: Who Decided That Number (Ingredient Guide 12)

    📌 How to Read a Korean Cosmetic Ingredient List (Ingredient Guide 14)

    📌 Sunscreen SPF and PA: How to Read the Numbers (Ingredient Guide 11)

    📌 Niacinamide: How Much Is Enough (Ingredient Guide 2)

    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), Articles 2(2), 4 and 10(1)8

    · Enforcement Rule of the Cosmetics Act, Articles 2, 9 and 10, and Annex 4 (labelling standards)

    · Regulation on the Review of Functional Cosmetics (MFDS Notice No. 2023-61), Articles 4 and 6, Annex 4

    · 21 CFR 333.310 — Acne treatment active ingredients (eCFR)

    · Regulation (EC) No 1223/2009, Articles 4, 13 and 20

    · Commission Regulation (EU) No 655/2013, Annex — common criteria

    · US FDA, “Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?)”

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    This post summarises statutes and regulatory notices and is not a substitute for diagnosis or treatment. If something about your skin worries you, please talk to a professional.

    — Dr. J Ingredient Notes

  • Adenosine 0.04%: Who Decided That Number – Korea’s List of Four Wrinkle Ingredients, a 126-Person Trial, and Why the Figure Vanishes Abroad (Ingredient Guide 12)

    Cover image for a Dr. J Ingredient Notes guide on what adenosine 0.04% means, ingredient guide 12. Adenosine is one of the four ingredients Korea's notification lists for the wrinkle-improvement claim, the listed level is 0.04 percent, and the guide covers a trial in which 126 women aged 45 to 65 applied it around the eyes twice a day for 8 weeks.

    🇰🇷 한국어판: 아데노신 0.04%, 고시가 정한 숫자 (성분 백과 ⑫)

    Hello, I’m Dr. J. Today: adenosine in skincare, and what the 0.04% on the back of a Korean wrinkle cream actually certifies.

    Pick up three Korean wrinkle creams and you will often find the same ingredient at the same level: adenosine, 0.04%. Different brands, different prices, one identical figure. That is odd enough to be worth explaining, and the explanation is the whole of this guide. It is Ingredient Guide 12.

    The short answer: no brand chose that number. It is written into a government document — Annex 4 of Korea’s functional-cosmetics review regulation, which lists four ingredients that may carry a wrinkle claim and the level each one has to be used at. This guide reads those four lines, works out what 0.04% weighs in a jar, goes through the one human trial the number rests on, and then sets the Korean system beside the American and European ones, because neither of those has a list like it.

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    📄 If you’d rather read the primary sources

    📄 MFDS notification, Annex 4 — functional cosmetics for which data submission is waived (Korean)

    📄 Abella ML (2006) — 126 women, around the eyes, 8 weeks

    📄 Commission Regulation (EU) No 655/2013 — common criteria for cosmetic claims

    📄 US FDA — “Is It a Cosmetic, a Drug, or Both?”

    🏠 Regulation on the Review of Functional Cosmetics (Korea Law Information Center)

    Annex 4 opens as an attachment. The wrinkle ingredients sit alongside the brightening ones in the same table.

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    In four lines, if you’re in a hurry

    ● Adenosine is one of four ingredients Korea lists for the wrinkle-improvement claim

    ● The listed level is 0.04%. Use exactly that and the efficacy dossier is waived

    ● Retinol is listed at 2,500 IU/g, adenosine at 0.04% — different units, so the figures do not compare

    ● 126 women applied it around the eyes for 8 weeks; texture beat placebo from week 3

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    What it is — a signalling molecule the body already makes

    Adenosine is not a laboratory invention. It is what a cell leaves behind after spending energy, so it is already circulating in the body. Skin cells carry adenosine receptors on their surface, and when the molecule docks there a signal travels inward.

    What happens after that signal is where published accounts diverge, and it is not something I could confirm from the abstracts available to me, so this guide stops there. What is solid is narrower and more useful: Korea placed this molecule on its wrinkle list rather than its brightening or UV lists, and there is a human trial behind it.

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    Reading the list — four lines, two units

    Here is the wrinkle section of Annex 4 in full. The thing that trips people up is the unit column: the first two entries are given in IU, the last two as a percentage by weight.

    Listed ingredient Listed level Unit Covered in this series
    Retinol 2,500 IU/g activity units Guide 1
    Retinyl palmitate 10,000 IU/g activity units —
    Adenosine 0.04% percent by weight this guide, 12
    Polyethoxylated retinamide 0.05–0.2% percent by weight —

    An IU measures activity, not mass. Putting 2,500 next to 0.04 and concluding that one ingredient is stronger is therefore a category error — each level was set for that ingredient on its own terms.

    Turn 0.04% into something you can picture and it comes to 20 mg in a 50 g jar. That is a normal amount to find near the end of an ingredient list, and finding it there does not mean the product skimped.

    Evidence figure for adenosine. Annex 4 of Korea's functional-cosmetics review regulation lists four ingredients for the wrinkle claim: retinol at 2,500 IU per gram, retinyl palmitate at 10,000 IU per gram, adenosine at 0.04 percent and polyethoxylated retinamide at 0.05 to 0.2 percent; IU and percent are different units, so the figures do not compare, and because Annex 4 only waives data submission the 0.04 percent is not a ceiling. In a trial of 126 women aged 45 to 65 who applied an adenosine cream, a dissolving film or a placebo around the eyes twice daily for 8 weeks, 84 per product, three-dimensional surface measurement showed eye-area texture significantly better than placebo by week 3 and sustained to week 8, with the cream also changing the glabella, International Journal of Cosmetic Science 2006. 0.04 percent works out at 20 milligrams in a 50 gram jar.

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    Why every jar says the same thing — what Annex 4 actually is

    Now read the title of the document. Annex 4 is called “Types of functional cosmetics for which data submission is waived.” It is not a table of guaranteed effects. It is a list of formulations that have already been assessed once, so a company matching one does not have to file its own efficacy dossier.

    Route a formulator can take What has to be filed What the label may say
    Match Annex 4 — adenosine at 0.04% efficacy data waived · reporting route wrinkle-improvement functional cosmetic
    A different level, or a different ingredient efficacy and safety data, individual review wrinkle-improvement functional cosmetic
    No listed ingredient, no review — no wrinkle-improvement wording

    So 0.04% is not a ceiling. A company that wants more can have more, provided it brings the evidence and goes through the review. The reason the same figure keeps appearing on the back of the jar is that the first route is lighter, not that the door above it is locked.

    This also settles a question left hanging in the peptide guide. Peptides are nowhere on Annex 4, so a Korean peptide cream carrying the wrinkle wording either contains one of these four listed ingredients as well, or it went through an individual review of its own.

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    What the trial found — 126 women, around the eyes, 8 weeks

    One human trial sits under all of this. 126 women aged 45 to 65 applied an adenosine product around the eyes twice a day for 8 weeks, comparing an adenosine cream, an adenosine dissolving film and a placebo, with 84 subjects per product.

    Element Detail
    Participants 126 women aged 45–65
    Arms adenosine cream · adenosine dissolving film · placebo, 84 per product
    Site and frequency around the eyes, twice daily, 8 weeks
    Measurement three-dimensional measurement of the skin surface
    Result eye-area texture significantly better than placebo by week 3 · sustained to week 8 · the cream also changed the glabella

    The abstract reports no percentage change, so this guide says “significant” and leaves it there rather than inventing a figure. The number that is worth carrying away is the week 3 mark: the difference appeared inside the first month, which makes 8 weeks a fair window to judge an eye product over.

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    Why you won’t see 0.04% outside Korea

    If you buy the same category of product in the United States or the European Union, the figure disappears. That is not because the ingredient is treated as weaker there. It is because neither system has a list of pre-cleared wrinkle actives at all, so there is no official level for a label to match.

    Question Korea (MFDS) United States (FDA) European Union
    A list of approved wrinkle actives? Yes — Annex 4, four ingredients at set levels No. Cosmetic products and ingredients need no FDA approval before sale, colour additives excepted No positive list for these actives
    What permits the claim match the listed level, or pass an individual review intended use decides: a claim about appearance stays cosmetic, a claim to affect the structure or function of the body makes it a drug adequate and verifiable evidence under the common criteria of Reg. (EU) 655/2013
    Where the evidence sits with the regulator, before launch with the company; FDA acts after the fact in the Product Information File, open to the authorities
    Does 0.04% mean anything? yes — it is the listed level no regulated meaning no regulated meaning

    One footnote on the American column, because it explains a lot of careful wording on US packaging: the FD&C Act has no category for a cosmetic with drug-like powers, and the FDA says plainly that it “does not recognize any such category as ‘cosmeceuticals.’” So an American anti-wrinkle cream talks about the appearance of lines. A Korean one is allowed to say “wrinkle improvement” outright — because a regulator checked the file first.

    Neither arrangement is strictly better. Korea’s gives you a number you can verify and a claim someone reviewed; the American and European ones leave more room for a formula that does not match any list. What they mean for a shopper is simply different: in Korea, read the claim wording; elsewhere, read the evidence the brand offers.

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    Using it — an easy ingredient to place

    ✔ Morning or night, either works. After a serum, before a cream

    ✔ Some products carry it alongside retinol. Both are on the same wrinkle list, so they are not a clashing pair

    ✔ There is no ramp-up period to serve. It does not ask for the first-four-weeks routine the retinol guide describes

    ✔ The trial looked at the eye area over 8 weeks. If that is where you’re using it, give it that long

    ✔ Daytime use runs alongside sunscreen — the sunscreen guide’s 2 mg/cm² is the amount that makes that number real

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    Four things to check when you buy

    Where to look How to read it
    The functional-cosmetic wording On a Korean product this is the tell: it means the listed level was matched, or an individual review was passed. Without it, the wrinkle wording is not allowed
    Where adenosine sits in the list Near the end is normal. Ingredients at 1% or below may be listed in any order, and 0.04% is far below that
    No percentage printed Levels do not have to appear on the label. The claim wording carries that information instead
    Is it made for the eye area That is the site the trial studied. A size and texture suited to the eye area makes 8 weeks of use realistic

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    In one line

    Adenosine’s 0.04% is a level a regulator set, not one a brand picked — and it is a waiver threshold, not a ceiling. A small number here is not a weak one.

    Next in the series: AHA vs BHA — what actually differs (Ingredient Guide 13). Glycolic acid and salicylic acid are regulated in two different ways, which is where that guide starts. The “1% or below, any order” rule gets its space in Guide 14.

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    📌 Earlier guides

    📌 Retinol: Start at 0.1% – How to Read the Concentration Numbers (Ingredient Guide 1)

    📌 Skincare Ingredient Compatibility Chart – What to Layer and What to Split

    📌 PDRN (Salmon DNA) Skincare: What a Korean Bio PhD Wants You to Know

    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

    · MFDS, Regulation on the Review of Functional Cosmetics, Annex 4 — types of functional cosmetics for which data submission is waived

    · Abella ML. Int J Cosmet Sci 2006;28(6):447–451 — 126 women aged 45–65, eye area, twice daily, 8 weeks

    · Commission Regulation (EU) No 655/2013 — common criteria for claims used for cosmetic products

    · US FDA, Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?) — FD&C Act secs. 201(i) and 201(g)(1)

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    This article summarises published research and public regulatory documents. It is information, not a diagnosis or a treatment plan. If something about your skin worries you, please talk to a professional.

    — Dr. J Ingredient Notes