Can Pharmacies Sell Korean Skincare in the EU?

30 August 2026 · The Glow Trade

A pharmacist in Linz clears half a metre next to the dermocosmetics for a Korean line her customers keep asking for, and her wholesale rep tells her, with some confidence, that pharmacies are not allowed to sell that. He is wrong on the law and right about the work. Cosmetics are pharmacy goods in Germany, Austria and France. What decides whether one specific Korean serum may go on her shelf is the pack, the paperwork behind it and one or two ingredient caps, none of which has anything to do with the word pharmacy over the door.

We supply pharmacies alongside perfumeries and concept stores, and pharmacy orders go wrong in one particular way: the pharmacist assumes the pharmacy status adds requirements to the product. It adds requirements to how much of it you may sell and what your staff may say about it. Regulation (EC) No 1223/2009 governs the product and whoever placed it on the EU market; your national pharmacy ordinance governs what may sit in a pharmacy and in what proportion.

The short version

Body care products are pharmacy goods in Germany under § 1a Abs. 10 Nr. 3 of the Apothekenbetriebsordnung, and § 2 Abs. 4 caps the side range only at what does not impair the pharmacy's medicines supply role.
In France, cosmetic products are item 14 on the list of goods a pharmacist may sell in the officine under the arrêté of 15 February 2002, made under Article L5125-24 of the Code de la santé publique.
Commission Regulation (EU) 2024/996 caps retinol at 0.3 % retinol equivalent in face products and kojic acid at 1 % in face and hand products, so Korean retinol and brightening lines need a concentration check per product before a pharmacy buys them.

Where the permission actually comes from

Nothing in Regulation (EC) No 1223/2009 names the outlet, and there is no pharmacy-only cosmetic category in EU law. The permission to carry cosmetics is national, and in the three markets where we see pharmacies buy most Korean skincare it is explicit.

Germany lists "Mittel zur Körperpflege" among apothekenübliche Waren in § 1a Abs. 10 of the Apothekenbetriebsordnung, last amended in December 2023, and § 2 Abs. 4 lets the pharmacy manager offer them only to an extent that does not impair the proper operation of the pharmacy and the priority of its medicines supply mandate. That is a proportion test, applied by the inspector walking through your shop. A metre of Korean skincare beside the dermocosmetics passes it; a shop that looks like a drugstore with a dispensary at the back does not.

Austria's Apothekenbetriebsordnung 2005 lets a pharmacist dispense apothekenübliche Waren in § 1 Abs. 5 and publishes no list, so the product's connection to health and what customers expect from a pharmacy are the working test. Skincare passes.

France runs a closed list. Article L5125-24 of the Code de la santé publique limits a pharmacist to goods on a ministerial list, and the arrêté of 15 February 2002 that carries it names cosmetic products as item 14. Elsewhere, ask your chamber before assuming; we have not read every ordinance and the rule differs by member state.

What the pack has to carry before it goes into a pharmacy

Buy from a wholesaler established in the EU and you are a distributor. Article 6(2) of Regulation 1223/2009 makes you check, before the product is made available, that the pack carries the Responsible Person's name and EU address with the country of origin, the batch number and an ingredient list headed "Ingredients", that the language rules are met and that the durability date has not passed. Article 19(5) hands the language of the nominal content, durability date, precautions and function to the member state where the product reaches the end user, so in a German or Austrian pharmacy those four elements have to be in German. INCI names are language neutral; a Korean brand's export ingredient list is fine if it is complete and headed correctly.

The notification portal is closed to the public, so ask the wholesaler for the Responsible Person's written confirmation that the product is notified under Article 13(1) and compare the name on it with the address on the pack. When the two differ, the pack wins, because that is what the inspector reads. Whose name should be there, and why a Korean exporter cannot sign the role away, is in who the Responsible Person is under EU cosmetics rules.

Two traps show up in pharmacy orders more than anywhere else. A pack with a Dutch Responsible Person and Dutch-language text, offered to a Bavarian pharmacy at a good price, is valid on the address under Article 4 and invalid on the language under Article 19(5); stick your own German label over it and Article 13(3) makes you file a notification of your own. And a Korean price list is an invitation to import, which under Article 4(5) makes the pharmacy the Responsible Person for every unit it clears, with the safety assessment of Article 10 and a product information file kept for 10 years under Article 11. For a twenty-line side range, that is a compliance function nobody budgeted for.

The ingredient caps that catch Korean lines in a pharmacy

Pharmacy customers ask for actives by name, and the Korean lines that sell best in a pharmacy are the ones Commission Regulation (EU) 2024/996 of 3 April 2024 touched. Retinol, retinyl acetate and retinyl palmitate are capped at 0.3 % retinol equivalent in face and other leave-on or rinse-off products and at 0.05 % in body lotion. Alpha-arbutin is capped at 2 % in face cream and 0.5 % in body lotion, arbutin at 7 % in face cream, kojic acid at 1 % in face and hand products.

For kojic acid the regulation's own wording is that non-compliant products "shall not be placed on the Union market" from 1 February 2025, with a stop on making them available from 1 November 2025; for the vitamin A entries the placing deadline also passed in 2025. Ask for the retinol equivalent per product in writing, because a front-of-pack percentage is a marketing number and the cap is an equivalence calculation.

What your team may say across the counter

The product is legal; the sentence that sells it may not be. Pharmacy staff are trusted, so they get asked medical questions about cosmetics, and a cosmetic presented as treating acne, eczema or rosacea is judged by that presentation, which is how a serum ends up assessed as an unauthorised medicine. Korean marketing copy is written for a market with its own claims rules; what you can legally claim about skincare at the counter goes through the common criteria line by line, and which dermocosmetic K-beauty lines fit a pharmacy covers the ingredient-led brands that survive that scrutiny.

The duty runs the other way too. Article 23 of Regulation 1223/2009 puts the obligation to report serious undesirable effects on distributors as well as the Responsible Person, and a pharmacy is where a customer with a reaction comes back to. Article 7 requires you to identify your supplier and your trade customers for a product for three years, so keep the invoice with batch numbers, not only the accounting entry.

The pharmacy assortment checklist

Work through it once per product, before the purchase order, and keep the answers with the invoice.

Outlet rule. Cosmetic under Regulation (EC) No 1223/2009, not a device or a medicine. Germany: § 1a Abs. 10 Nr. 3 ApBetrO, side range within § 2 Abs. 4. Austria: § 1 Abs. 5 ABO 2005. France: arrêté of 15 February 2002, item 14.
Responsible Person. Name and EU address on the pack, country of origin stated (Article 19(1)(a)). You are not the importer, or you know you are and have priced the role.
Notification. Written confirmation from the Responsible Person (Article 13(1)); product name matches the pack.
Language. Content, durability, precautions and function in your member state's language (Article 19(5)). No sticker of your own, or your Article 13(3) notification is filed.
Batch and date. Batch number on the unit (Article 19(1)(e)); best-before date or period-after-opening symbol present and not expired (Article 19(1)(c)).
Ingredients. List headed "Ingredients", complete, INCI names. Retinol equivalent at or below 0.3 % face and 0.05 % body; alpha-arbutin at or below 2 % face and 0.5 % body; arbutin at or below 7 %; kojic acid at or below 1 % (Regulation (EU) 2024/996). Supplier's concentration statement on file.
Claims. Shelf talker and staff briefing use the cosmetic function only; no disease words, no translated Korean claims.
Records. Supplier invoice with batch numbers kept 3 years (Article 7); one named person for Article 23 reports.

One sentence to send with every new line request: "For each product on this order, name the EU Responsible Person printed on the pack, confirm the notification in writing, and state the retinol equivalent, arbutin and kojic acid concentrations where present." A wholesaler who cannot answer that is selling you stock for a different kind of shop.

Questions buyers ask

Is "dermocosmetic" a legal category in the EU?

No. Regulation (EC) No 1223/2009 defines cosmetic products and nothing sits between them and medicines. "Dermocosmetic" and "cosmeceutical" are marketing words without a legal definition, and a product sold as treating a skin disease is judged as a medicine by its presentation whatever the label calls it. Ask the supplier what evidence sits behind a "dermatologically tested" claim before you repeat it.

Can a pharmacy sell a Korean product whose label is only in English?

Only where English is an official language of the member state. Article 19(5) of Regulation 1223/2009 leaves the language of the nominal content, durability date, precautions and function to the country where the product reaches the end user, so in Germany, Austria or France those four elements have to be in the national language. Ask the wholesaler for stock that already carries your country's layer rather than stickering it yourself.

What do I do if a customer reacts to a Korean product bought in my pharmacy?

Article 23 of Regulation 1223/2009 requires a distributor to notify a serious undesirable effect without delay to the competent authority of the member state where it occurred, and the Responsible Person then has to be told. Keep the batch number from the pack and the customer's description. For a reaction that is not serious, pass the batch and the details to the Responsible Person through your wholesaler and keep a copy.

Sources

Facts checked against EUR-Lex, gesetze-im-internet.de, JUSLINE and Légifrance on 2 September 2026. General information, not legal advice; your pharmacy chamber and national competent authority have the final word on your range.

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