Welche Verpackungen für koreanische Kosmetik verkaufen sich tatsächlich im Einzelhandel?

A pharmacy put forty Korean lines on a gondola end in spring and had reordered three of them twice before summer: the sunscreens, a lip mask in a clear tub, and a box of sheet masks with the ingredient drawn on the front. About a third of the other lines had not sold a unit. What they shared was a front panel that told a person standing a metre away nothing: not which step it was, not whose skin it was for, not what to do with it. Nobody asked the staff, because nobody asks about a box they cannot place.

You can sort an order sheet by that test before the goods arrive, and you should.

The short version

• Article 19(1)(f) of Regulation (EC) No 1223/2009 requires the function of a cosmetic product on the pack unless the presentation makes it obvious, and Article 19(5) leaves the language of that line to the country where the product is sold.
• Germany's Kosmetik-Verordnung of 2014 (§ 4) demands German for the content, durability date, precautions and function under Article 19(1)(b), (c), (d) and (f), while the ingredient list stays in INCI, so the front panel a shopper actually reads is untouched by either rule.
• Commission Regulation (EU) No 655/2013 applies to cosmetic claims "irrespective of the medium or type of marketing tool used", so a one-line shelf strip is judged by the same six criteria as the pack itself.

Three things a box has to say from a metre away

A shopper gives an unfamiliar pack about three seconds at arm's length. In that time she needs three answers: which step this is, whose skin it is for, and what she does with it.

Sun care answers all three on its own. "SPF 50+" is a language every European reads, the format is a tube, the use is obvious. Sheet masks with the hero ingredient drawn on the front do the same in one picture. Lip masks in a transparent tub, hydrocolloid patches visible through the pack, hand creams, cleansing foams with a face on the tube: all of these sell to someone who has never heard of the brand.

Now hold up an essence. The front reads "96 Mucin Power Essence" in English, the rest is Korean, the bottle is a plain pump. Which step? Whose skin? Before or after the toner, and what is the 96? A regulator is satisfied, because the over-label on the back carries the function line in the local language in small type. The shopper never turns it round. Toners with percentages, pads in a jar, ampoules with a number: these stall in a shop with nobody on the floor, and they are most of what makes a Korean assortment interesting. The pack was designed for a shopper who already knows the routine, and in Seoul she does.

What the law translates, and what it leaves in Korean

Article 19(1)(f) of the cosmetics regulation requires "the function of the cosmetic product, unless it is clear from its presentation", and Article 19(5) hands the language of the function, the nominal content, the durability date and the precautions to the member state where the product reaches the end user. Germany writes that into § 4 of its Kosmetik-Verordnung as German for exactly those four items.

Note what stays out. The ingredient list is in INCI names under Article 19(1)(g) and nobody translates it. The brand name, the product name and every marketing line on the front are not in the list at all. So a fully compliant Korean product in a German shop can carry German only in small type on the base, with the panel the shopper looks at entirely in Korean and English. The over-label settles the legal question and leaves the self-service question exactly where it was.

Fixing the front yourself has consequences: Article 13(3) makes a distributor who translates any element of the labelling on its own initiative a notifier, one of the traps in who counts as the responsible person. Ask for stock already over-labelled for your market and treat the front panel as fixed.

The strip does one job

A shelf strip in the local language gives the pack the sentence it does not have. One line, under twelve words: what it does, for whom, when. "Hydrating essence for dry skin, after toner, morning and evening." That line turns a Korean pump bottle into something a person can pick up without help. Every block gets one, as laid out in the shelf-by-shelf plan for a first bay.

The strip is a claim. Commission Regulation (EU) No 655/2013 covers claims in "texts, names, trade marks, pictures and figurative or other signs" in labelling, making available and advertising, whatever the medium. So the strip must be true of the product, supported by what the brand can evidence, and it must stay cosmetic. "Calms redness-prone skin" is a cosmetic claim. "Treats rosacea" is a medical one, and a strip that makes it has taken the product out of cosmetics law. Copy the brand's own function wording and shorten it; never upgrade it.

What a strip cannot do is teach a routine. An exfoliating toner with an acid percentage on the front, a retinal serum, a two-step peel: twelve words will not carry the caution or the sequencing. Those lines need a person, and you should decide whether you have one before you order them.

Match the order to the staff you actually have

A gift shop or concept store with a till and no trained staff should carry almost nothing that needs explaining. Depth in self-selling categories beats variety across categories nobody can explain, which is the case made in the depth-or-variety decision. Sun care in three or four textures, a wall of sheet masks, lip and hand care, patches.

A pharmacy is the opposite: its staff diagnose all day, and the acids, the barrier repair and the ampoules are the lines that justify the counter. A salon sells from the treatment room, so pack language barely matters for the retail sizes by the till and matters a great deal for anything beyond them.

Unknown brands raise the bar. A brand nobody in your city stocks has no shortcut in the shopper's head, so the pack has to do all the work, which is the trade-off inside finding brands nobody else carries: the newer the brand, the more of its range has to pass the arm's-length test.

Nobody publishes sell-through by pack type for this category, so the sort below is our rule rather than a measurement, and you should keep your own count from the first reorder onward.

The arm's-length sort

Copy this and run every line on the order sheet through it before you confirm. Use a photo of the front of the retail unit if you do not have the box in hand.

THE ARM'S-LENGTH SORT     front panel only, one metre away, one line at a time

Q1  Can a shopper who reads no Korean name the STEP?
    (cleanse / tone / treat / moisturise / protect / mask)        yes = 1
Q2  Can she tell WHOSE skin it is for?                            yes = 1
Q3  Can she tell WHAT TO DO with it without opening it?           yes = 1
Q4  Under 10 euro, or product visible through the pack?           yes = 1

SCORE 3 or 4   BIN A  sells itself.   Strip optional. Any retail format.
SCORE 2        BIN B  needs the strip. One line, local language, under 12 words:
                      [what it does] for [whom], [when in the routine].
SCORE 0 or 1   BIN C  needs a person.  Acids, retinoids, peels, multi-step.
                      No trained staff on the floor: do not order it.

THE RATIO
  No trained staff (gift, concept):   A at least 7 in 10, C none.
  Salon:                              retail sizes of treatment-room products; rest B.
  Pharmacy, trained counter:          C up to half; every C line still gets a strip.

Questions buyers ask

Do Korean cosmetics come with English on the packaging?

It varies, even within a single brand's range. Brands built for export tend to print the product name and function in English on the front; brands built for the home market often carry no English at all. EU law requires the sale country's language only for the items named in Article 19(5) of Regulation (EC) No 1223/2009, never for the front panel, so ask the supplier for photos of the retail unit rather than assuming.

Can I print my own German or French sticker for a Korean product?

You can, and it does not make you the responsible person, because Article 4(6) of Regulation (EC) No 1223/2009 says a translation is not a modification that affects compliance. But Article 13(3) requires a distributor who translates any element of the labelling on its own initiative, for a product already on the market in another member state, to notify the Commission. Buying stock already labelled for your market avoids the obligation.

Do I need testers if nobody explains the products?

For texture-led products, yes, because the tester is the explanation: a balm, a cushion, a lip mask or a pad sells on feel, and a sealed box says nothing about feel. Date the tester when you open it and replace it at the period-after-opening on the pack, the symbol Article 19(1)(c) requires once durability exceeds 30 months; the hygiene side is in testers, samples and hygiene in a beauty store.

Sources

• EUR-Lex, Regulation (EC) No 1223/2009 on cosmetic products, Articles 4, 13 and 19 (2009)
• EUR-Lex, Commission Regulation (EU) No 655/2013, common criteria for cosmetic claims (2013)
• Bundesministerium der Justiz, Kosmetik-Verordnung 2014, § 4 (2014)

Regulation references checked against EUR-Lex and gesetze-im-internet.de on 2 September 2026; the sort and the ratios are our rule, not a measurement.