EU Labelling for Korean Cosmetics: What Must Be on the Pack and Who Adds It

7 July 2026 · The Glow Trade

A carton of Korean toner arrives at a shop in Linz. The pack is beautiful: Hangul on the front, English marketing on the back, a tiny ingredients panel in Korean. The owner sticks her price on it and puts it on the shelf. What she has just placed on the EU market is, in the eyes of the cosmetics regulation, an unlabelled product, and the fact that it is genuinely Korean, genuinely notified by somebody somewhere, and genuinely safe changes nothing about that.

Article 19(1) of Regulation (EC) No 1223/2009 lists what a cosmetic's container and packaging must carry. A Korean retail pack, made for the home market, satisfies almost none of it in a form the EU accepts. The gap between the two is where over-labelling lives, and it is work, not a sticker with a price on it.

The short version

Seven elements must appear on container and packaging in indelible, legible lettering, including the EU Responsible Person's name and address and, for imports, the country of origin (Article 19(1)).
Four of them must be in the language of the member state where the product is sold: nominal content, durability, precautions and function (Article 19(5)). Selling into three countries can mean three languages on one pack.
A Korean retail pack needs over-labelling before legal sale in the EU. That is a per-unit cost for translation, print and application, and it multiplies with every market added.

The seven elements, translated into what they mean for a Korean pack

Run the list against a typical Korean pack and the work shows itself. The Responsible Person's name and address: absent, because the pack was printed for Seoul, and this is the element that decides legality outright, with country of origin specified for imports. Nominal content in weight or volume: usually present, often usable. The date of minimum durability, or the PAO open-jar symbol where durability exceeds 30 months: Korean packs use manufacturing dates and their own conventions, covered in how to read Korean batch codes, so this element usually needs adding. Precautions for use, at minimum those the annexes prescribe: missing in EU languages. The batch reference: present on Korean packs and one of the few free wins. The product's function where it is not obvious from presentation: a Korean "skin" or "essence" is not obvious to a Graz grandmother, so it needs a line. And the ingredient list, headed "ingredients", in descending order with nano marking and CI numbers: Korean INCI lists often translate cleanly, but they have to be on the pack, in the right format, not on a website.

The language rule, and what it costs to sell into three countries

Article 19(5) sets the language of nominal content, durability, precautions and function by the member state where the product is made available to the end user. Not the import state: the sales state. A pack sold in Austria and Germany needs German. Add France and it needs French for those elements. Add Italy, a third set.

This is where the per-unit economics turn. Over-labelling a serum for one market is a design, a print run and an application cost per unit. Serving three markets either triples the sticker work or forces a multilingual design that fights the pack for space. It is also where the distributor's trap sits: translate any label element on your own initiative for a second market and Article 13(3) hands you your own CPNP notification duty for that product, even though you are still not the Responsible Person. Most small cross-border sellers discover this after the fact. The companion piece on what CPNP means when the pack is already Korean-labelled goes into that mechanism.

Who adds what, in the two buying models

Buying direct from Korea, you are the importer and the Responsible Person, and the whole list is your build: translation, label design, printing, application, and the notification that sits underneath it. Buying from an EU wholesaler, the pack arrives over-labelled already, with the wholesaler's RP address on it, and your duty collapses to the distributor's check under Article 6: verify the RP address and origin, the batch reference, the ingredient list and the language elements before the product goes on the shelf, and do not sell past the durability date.

That check is a two-minute job per product, once, at goods-in. Build it into the receiving routine, because "the wholesaler handles labelling" is true only until a market surveillance officer asks who verified the pack, and the answer "I assumed" is not in the regulation. The full verification habit, including the documents to demand upstream, is in the supplier document checklist.

The receiving check

LABEL CHECK AT GOODS-IN (2 minutes per product, once)

1. RP name + EU address on pack? (and "Made in Korea" origin)
2. Batch/reference number present?
3. Ingredient list headed "ingredients" present?
4. Durability: date or PAO jar present and not passed?
5. Language: content, durability, precautions, function
   readable in MY country's language(s)?
6. Function obvious or stated for THIS market's customer?

Any "no" -> quarantine the stock, email the supplier,
do not shelve "provisionally". Provisional is how fines happen.
Selling into a second country with your own sticker?
-> you owe an Article 13(3) notification for that product.

Questions buyers ask

Can I put a compliant sticker over the Korean back panel?

Yes, over-labelling is the normal route, as long as the result is indelible, easily legible and visible, and the underlying mandatory information still shows where required. The sticker has to carry everything missing: RP address, the language elements, durability, and the ingredient list if the pack lacks an EU-format one. What it cannot do is certify anything: the label is the visible tip of a notification and safety file that must exist underneath, or the prettiest sticker in Europe changes nothing.

The brand says the pack is "EU version". What do I still check?

Everything on the six-line check, because "EU version" is a marketing phrase, not a legal status. Plenty of so-called EU versions carry an English panel that satisfies no national language rule in the countries you actually sell to, or an RP address that turned out to be a mailbox service with no file behind it. The pack itself is the evidence: two minutes per product tells you more than the supplier's catalogue line.

Do testers and free samples need the full label?

Samples and single-application packs are exempt from the nominal-content element, and freebies have some relief, but the RP address, safety-relevant language elements and durability still matter in practice, and anything a customer can take home should carry them. Treat the mini the same as the full size at goods-in; the checklist costs the same two minutes and the exemption logic protects nobody when a customer reacts badly to an unlabelled pot.