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Decoding the Natural and Organic Cosmetic Regulations in China, South Korea, and Japan

Asia-Pacific, one of the largest cosmetic market, holds great potential in natural and organic cosmetics amid post-COVID19. This article introduces the supervision situation of and compliance requirements for natural and organic cosmetic products in China, South Korea, and Japan.

The global market value of natural cosmetics expected a positive increase from almost 34.5 billion dollars in 2018 to roughly 54.5 billion dollars in 2027.1 Although Europe and North America have the largest natural and organic personal care product market, the Asia-Pacific, one of the largest cosmetic market, holds great potential in natural cosmetics.

According to a recent report2 from Mordor Intelligence, the Asia-Pacific region is expected to see the fastest growth of natural and organic cosmetics in the next five years. An increasing number of millennials and working women are the driving factors for natural skincare. However, entering the AP markets is not easy due to the complicated supervision situations. Therefore, ChemLinked analyses the natural and organic cosmetic requirements in China, Japan, and South Korea for enterprises' reference.

1. China

Although "organic cosmetic" and "clean beauty" are new concepts in China, more and more Chinese consumers prefer cosmetic products with inartificial content. However, China hasn't established a specific law related to organic or natural cosmetics yet. China's Organic Product Certification Inventory3 stipulates that products under the organic category are food, alcohol, Chinese herbal medicine, and fiber and clothing, excluding cosmetics.

As a result, overseas companies do not have access to official "organic cosmetic" or "natural cosmetic" registration in China and thus cannot claim the product as an organic or natural cosmetic. 

Besides, as China has strict cosmetic safety control, enterprises are recommended to check the product ingredients in advance. If any cosmetic ingredient is not listed in the Inventory of Existing Cosmetic Ingredients 2021 (IECIC 2021)4, the enterprise should apply for new ingredients registration or notification with National Medical Products Administration (NMPA).

The good news is that the cross-border e-commerce (CBEC) provides an option for overseas brands to enter into China's beauty market. As long as the products are in List of Import Goods through Cross-border E-commerce (2018 Edition)5, they can be sold via CBEC platforms. It is worth noting that the Chinese word "有机 (organic)" is still not allowed if a Chinese label is attached to the product package. The English word "organic" is permitted.

2. South Korea

2.1 Product Certificate

South Korea has a complete supervision system of organic and natural cosmetics, from product certificate to ingredient recognition. On July 29, 2019, Ministry of Food and Drug Safety (MFDS) implemented the Regulations on the Standards of Natural and Organic Cosmetic Products6, specifying the organic and natural cosmetic's definition, permitted ingredients, manufacturing processes, and requirements for the business entity.

natrual-and-organic-cosmetics.png

(Figure 1. Ingredient standards for natural and organic cosmetics)

As shown in Figure 1, the natural raw material concentration shall exceed 95% in a natural cosmetic. The standard of organic cosmetics is stricter than that of natural cosmetics. Apart from the 95% natural raw material concentration, organic cosmetics shall contain over 10% organic ingredients

Background

 

Natural raw material:

Natural ingredient (including organic ingredient, plant ingredient, animal ingredient, and mineral ingredient), natural derived ingredient, and water.


Organic ingredient:

A sub-category under "natural ingredient", including

a) organic agricultural and fishery ingredients certified by South Korean authority,

b) organic agricultural and fishery ingredients certified by foreign authorities, and 

c) organic ingredients certified by institutions registered in IFOAM (International Federation of Organic Farm Movements)

 

Check here7to find the organic and natural ingredient inventory.

To get a "natural cosmetic" or "organic cosmetic" certificate, the enterprise should submit the documents, which prove  the raw materials and manufacturing process comply with the natural/organic cosmetic standards, to any of the following designated institutions: 

Institutions

Homepage

Korea Testing & Research Institution

www.ktr.or.kr

Korea Conformity Laboratories

www.kcl.re.kr

Controlunion Korea

www.controlunion.co.kr

The application period is 60 days. After the institution confirms that the ingredient and manufacture methods are appropriate, the enterprises can advertise the product as an "organic cosmetic" or "natural cosmetic" and use the corresponding mark for market promotion.

 natural-and-organic-cosmetic-mark.png

(Figure 2. Natural Cosmetic Mark) (Figure 3. Organic Cosmetic Mark)

2.2 Ingredient Certificate

MFDS further introduced the natural and organic ingredient certification mechanism8 on January 29, 2021. If the enterprise uses the recognized natural or organic ingredients in the product, the documents for applying the natural/organic cosmetic product certification can be exempted. The application period would also be shortened. The new mechanism simplifies the product certification application process when using the same natural/organic raw material in multiple cosmetics. 

The application procedure is similar to that of the product certificate. However, in addition to the cosmetic enterprises, the ingredient producers can also apply for the natural or organic ingredient certificate.

3. Japan

Similar to China, Japan's organic recognition also excludes cosmetics. However, the boosting demand for natural and organic cosmetics pushed the authority to take actions to guide the industry. On February 1, 2018, the Japan Cosmetic Industry Association (JCIA) disclosed Regarding JCIA Guideline on Labelling of Natural, Natural-origin, Organic, and Organic-origin Contents According to ISO 161289 to specify the labeling standards for cosmetics containing natural raw materials.

This guideline was compiled based on ISO 1612810, the first international standardized guideline for natural and organic cosmetic ingredients. JCIA cited the definitions of natural and organic cosmetic ingredients in ISO 1612810 for industry's references: 

Natural Ingredients:

Cosmetic ingredients obtained only from plants, animals, micro-organisms or specific minerals (excluding fossil fuels).


Organic Ingredients:

Natural ingredients originating from organic farming methods or from wild harvesting in compliance with national legislation or equivalent International Standards.


Derived Natural Ingredients:

Cosmetic ingredients of greater than 50% natural origin.


Derived Organic Ingredients:

Cosmetic ingredient of organic or mixed organic and natural origin obtained through defined chemical and/or biological processes with intention of chemical modification.

The Regarding JCIA Guideline on Labelling of Natural, Natural-origin, Organic and Organic-origin Contents According to ISO 161289 specifies that only "natural/organic ingredients" can be labeled on the cosmetic's package. The items of "natural/organic cosmetic product" cannot be indicated in the product's label or advertisement as no such concept is defined in ISO 1612810. The natural/organic ingredient's concentration shall be calculated following the requirements in ISO 1612810 and labeled in Japanese. 

Besides, there are also associations providing unofficial organic cosmetic certifications in Japan, such as JNOCA11 and JOCA12. These associations have their own standards, such as the natural material's concentration, permitted additives, etc. After the association determining the products are in compliance with their standards, the enterprises can also label the certificate marks on the products. 

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