Ingredients Allowed in Korea but Restricted in the EU: What to Check Before Importing

An importer falls for a Korean ampoule, orders three hundred units direct, and only then runs the INCI list past a consultant. The formula contains a UV filter the brand uses across its Korean sun care, a preservative the EU restricts to lower levels than this product uses, and, in last year's batch, a fragrance component the EU banned outright in 2022. The ampoule is a hero product in Seoul. In the EU it is three hundred units of evidence.

Both markets regulate cosmetics seriously. They just regulate differently, and the differences are not exotic edge cases: they sit in the everyday ingredient classes K-beauty is famous for, which is why "it sells everywhere in Korea" is the least informative safety sentence in the trade.

The short version

• The EU controls substances through the annexes of Regulation (EC) No 1223/2009: Annex II banned, Annex III restricted with limits and warnings, Annexes IV to VI for colourants, preservatives and UV filters. Anything not listed positively in those three function annexes is not allowed in that function.
• Korea's MFDS runs its own lists, and the two do not match. Products can be fully compliant in Seoul and unsellable in the EU without reformulation.
• Screening is free and takes minutes per product: run the INCI list against the EU's CosIng database before you price the import, not after the goods land.

How the EU system reads an INCI list

Start with the logic, because it inverts what many buyers assume. The EU does not approve products; it controls substances. Annex II is the ban list, over a thousand entries. Annex III is the restriction list: allowed, but only up to a concentration, in certain product types, sometimes with mandatory warnings. Annexes IV, V and VI are positive lists: a colourant, preservative or UV filter may be used only if it appears there, within its conditions. An ingredient can be a beloved staple of Korean formulating and simply absent from the EU positive list, which ends the conversation.

The examples that bite in practice are not theoretical. Lilial, a fragrance aldehyde that spent years in Korean and European perfumes alike, has been banned in the EU since 2022. The cyclic silicones D4, D5 and D6, texture heroes in Korean skin care, carry restrictions and wash-off limits. Retinol and its esters, the backbone of half the anti-ageing launches in Seoul, moved onto Annex III with concentration caps that began phasing in from late 2025, with sell-through deadlines into 2027. And the preservatives class, where Korean "clean" formulations lean on organic acids and alternatives, has its own EU boundary conditions.

The filters problem, in one paragraph

Sun care deserves its own warning because it is K-beauty's gateway category. The EU treats UV filters as a positive-list function: only Annex VI filters, at their limits. Korean domestic sunscreens are built partly around filter combinations optimised for the Korean system, and while many of those molecules also appear in Annex VI, not every Korean domestic-market formula survives the comparison, and the SPF and UVA evidence behind the claims has to satisfy EU testing standards too. The full map, including the export-version phenomenon where brands reformulate specifically for Europe, is in Korean sunscreens in the EU.

Screening before you buy

The working tool is CosIng, the Commission's free ingredient database. Per product: take the full INCI list from the supplier, check every functional ingredient (filters, preservatives, colourants) against its annex entry and conditions, and flag anything in Annexes II or III for the consultant before money moves. Ten minutes per product, no subscription, no excuse. What CosIng will not do is assess the final formulation's safety: that is the CPSR's job, covered in why a Korean test certificate is not a safety report, and it is the step that turns a screened formula into a sellable product.

For everyone buying from EU stock rather than importing: the same screen is the reason to prefer suppliers whose assortment is already EU-assessed, and the smart questions to ask them live in the supplier document checklist.

Questions buyers ask

The brand sells this exact product in Europe already. Is my import covered?

If the exact same formulation is genuinely placed on the EU market by a Responsible Person, the formula itself has presumably been assessed against the annexes. The trap is the word exact: Korean brands reformulate for export more often than buyers expect, and the domestic version on a Korean exporter's price list is not always the EU version on a European shelf. Compare the INCI list on your offer against the INCI list on the EU pack, ingredient by ingredient. If they differ, you are not importing the product that was assessed.

Who is responsible if a banned ingredient slips through?

Everyone in the chain, starting with the Responsible Person, and for direct imports that is you. Distributors have their own duty under Article 6 not to sell products they should recognise as non-compliant. "The manufacturer formulated it" is true and irrelevant; the EU system allocates responsibility by role, not by who mixed the batch, and the importer role is the heaviest one in it.

Where do I check whether an ingredient is allowed?

CosIng, the Commission's database, first: it shows the annex status and conditions per ingredient. The consolidated text of Regulation (EC) No 1223/2009 on EUR-Lex carries the annexes themselves. For anything ambiguous, a cosmetic safety assessor or regulatory consultant is the paid answer, and the ten-minute CosIng screen is what tells you which products need that call and which do not.

Sources

• EUR-Lex, Regulation (EC) No 1223/2009 on cosmetic products, consolidated 2025
• European Commission, CosIng ingredient database, 2026

The annex structure and examples were checked against the consolidated regulation and CosIng on 2 September 2026.