Korean cosmetics OEM and packaging: private label import guide

How do overseas brands get a private-label cosmetic made and packed in Korea?

Product rules and cautions for importers

OEM versus ODM, and who owns the formula

In an OEM arrangement the brand supplies or commissions its own formula and the factory manufactures to that specification. In an ODM arrangement the factory develops the formula, or offers one from its library, and the brand chooses and adjusts it. With ODM the factory normally keeps the formula unless the contract says otherwise, which means the brand cannot simply move production to another factory. Before paying for development, get in writing who owns the formula, whether it is exclusive to you and in which countries, whether the full quantitative formula will be disclosed to your safety assessor, and what happens to it if you stop ordering.

Minimum order quantities and lead times

We do not publish figures because they vary widely by factory and product. As a general pattern, catalogue formulas in stock packaging have the lowest minimums and the shortest lead times; custom formulas need development, stability and packaging-compatibility testing first; and printed or custom-moulded packaging usually has a higher minimum than the filling run itself, so the packaging minimum often sets the real order size. Each component has its own lead time, and the slowest one decides the filling date. Ask every supplier for its minimum and lead time in writing.

Who is responsible for registration

The importer of record, or the responsible person it appoints in the destination country, is responsible for product notification or registration, label approval and any licences. The Korean exporter and manufacturer supply the documents needed for those filings. Nobody on the Korean side can promise that a notification or registration will be accepted.

• European Union. Regulation (EC) No 1223/2009 allows a cosmetic on the market only if a responsible person established in the EU is designated. A product safety report must be prepared before the product is placed on the market, and the product is notified once through the Cosmetic Products Notification Portal (CPNP), which then covers all member states. Nanomaterials need an extra notification and are marked “(nano)” in the ingredient list. From the factory you will need the full formula, raw material specifications and safety data, manufacturing and GMP evidence, stability and compatibility results and packaging specifications for the Product Information File.
• United Kingdom. Great Britain requires a Responsible Person with a UK-established address, a Product Information File containing the safety report, GMP documentation and evidence for claimed effects, kept for 10 years, and notification through the Submit cosmetic product notifications (SCPN) service before the product is made available. The label must carry the Responsible Person’s name and address and the country of origin for imported products. For Northern Ireland the Responsible Person must be established in Northern Ireland or the EU.
• United States. Under MoCRA, manufacturers and processors, including foreign facilities, register with the FDA and renew every two years, and foreign facilities need a US agent. The responsible person, meaning the manufacturer, packer or distributor named on the label, lists each product with its ingredients and updates the listing annually, keeps records supporting adequate safety substantiation, and reports serious adverse events within 15 business days. Some small businesses are exempt from registration and listing, with exceptions for certain product types. The FDA does not issue certificates confirming registration or listing. Ask your factory for its FDA registration details before you order.
• ASEAN countries. The ASEAN Cosmetic Directive harmonises requirements across member states: a local company notifies the product to the national regulator before sale, keeps a Product Information File, follows the ASEAN labelling requirements and observes the ingredient annexes (prohibited and restricted substances, permitted colourants, preservatives and UV filters). Singapore’s HSA shows the annexes as last revised in June 2026.
• Indonesia. In addition to notification, regulated products including cosmetics must carry a Bahasa Indonesia label before distribution. Indonesia’s halal product law is being extended to cosmetics; confirm the current deadline and the status of your product with the halal authority BPJPH and your importer before ordering, and ask the factory early whether it can support halal certification for the formula and the production line.

Korean rules that affect an export order

Korea’s Cosmetics Act defines three business types: cosmetics manufacturer, responsible seller and customised-cosmetics seller. For products sold in Korea, the label must show the product name, the name and address of the business operator, all ingredients, content, batch number, expiry date or period after opening, price and precautions. Article 30 of the Act lets products made only for export follow the importing country’s rules instead of these labelling provisions. In practice that means your export label is designed to the destination country’s law, and whether the factory’s name appears on the pack is decided by that law and by your contract. The Korean legal database also lists several amendments to the Act that take effect between October 2026 and 2029, so ask the factory whether any of them changes what it can supply.

How origin is decided for a cosmetic made in Korea

A cosmetic filled in Korea is not automatically Korean origin for FTA purposes. Each agreement has a product-specific rule. Under the Korea-UK FTA, for example, headings 3302 to 3307 qualify either when the non-originating materials come from other headings (materials of the same heading are allowed up to 20% of the ex-works price) or when all non-originating materials are no more than 40% of the ex-works price. Simple operations such as changing packaging do not confer origin. Retail packaging that is classified together with the product is treated as part of the product for origin purposes. KORUS rules are set out in General Note 33 of the US tariff schedule, and other agreements have their own lists, so the factory needs to check its bill of materials against the rule of the agreement you will claim.

Empty packaging shipped on its own must qualify by itself. Under the Korea-UK FTA, plastic articles in 3922 to 3926 qualify when non-originating materials are no more than 50% of the ex-works price, and glass containers in 7010 when they are manufactured from materials of another heading. Packaging that a Korean supplier imported from a third country and resold does not qualify.

Packaging rules in the destination market

The EU Packaging and Packaging Waste Regulation (EU) 2025/40 entered into force on 11 February 2025 and applies from 12 August 2026. It aims to make all packaging on the EU market recyclable by 2030, sets minimum recycled content for plastic packaging from 2030, restricts substances of concern, introduces harmonised sorting and material labels, and requires producers to register with extended producer responsibility schemes in the member states where they sell. Commentary by law firms describes a declaration of conformity for each packaging type from the application date. It also restricts small single-use toiletry packs used in the accommodation sector. We did not verify the individual recycled-content percentages, so take them from the regulation text. When you brief Korean packaging suppliers, ask for material composition, recycled-content evidence and heavy-metal test data for each component.

Trademark before production

File your trademark in the destination markets, and in Korea where the goods are made, before you approve packaging artwork. Printed cartons and decorated containers cannot be reworked if the name has to change. The Madrid System lets you extend a home application or registration to other member countries through one filing; WIPO reports that it covers 133 countries.

Products outside an ordinary cosmetics order

A product sold as a cosmetic in Korea can be classed as a drug or medical device in another country because of its ingredients or claims. Medical devices and prescription or drug-classified products need licensing in both countries and are outside ordinary consolidation orders.

Related guides: sourcing existing K-beauty brands in one shipment and Korean corporate gift sets.

News and recent developments

Capacity, tariffs and packaging law all moved in 2026, and each affects cost or timing for a private-label order.

Frequently asked questions