Asian Cosmetics Standards + FAQ

Sunday, May 31, 2015

Asian Cosmetics safety standards and regulations and frequently asked questions faq
Inspiration for today's #skincaresunday post comes from reading statements such as "I am not about to trust the chemicals in Asian products" and "in Asian countries, [lack of regulation] is worse" over and over again.

I am going to preface this entire post by stating that I am not an Asian cosmetics expert. I am an enthusiast. And as such, I took it upon myself to investigate the standards to which different Asian cosmetics brands are held... for my own benefit and hopefully yours as well. Today's discussion will cover the different health and safety standards in different parts of (East) Asia, touching upon the cosmetics oversight in South Korea, Japan, Taiwan, and China. I've also crafted some answers to common questions posed by people interested in Asian cosmetics based on my personal experience, and by drawing upon the collective experience of the wonderful members of the (20000+ strong and growing) AsianBeauty community on reddit. Interested? Read on!


Let's do a little benchmarking exercise and first familiarize ourselves with the regulations in the U.S. as per the official FDA website.

DEFINITION OF COSMETICS: Cosmetics are "articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body...for cleansing, beautifying, promoting attractiveness, or altering the appearance". It does not include soap which is regulated by the Consumer Product Safety Commission.

LABELING: Cosmetic products must be labeled as per the Fair Packaging and Labeling Act and the Federal Food, Drug, and Cosmetic Act.

APPROVALS: What is most surprising to me is that cosmetic products and ingredients (besides color additives) do not need approval by the FDA before going on the market. Also surprising was the fact that manufacturers and importers are not required to register with the FDA or file their formulas.
However, there are safeguards in place. The product must be properly labeled (adhering to only ingredients that are safe under labeled conditions of use), and the product must not be adulterated or misbranded. Also, the manufacturers and importers are under full liability to ensure their products are safe. The FDA has the authority to pursue regulatory actions (like recalls and seizures) against any company whose products are deemed unsafe.
Companies may also voluntarily participate in the FDA Voluntary Cosmetic Registration Program (VCRP), which includes the upholding of the Personal Care Product Council's Consumer Commitment Code. So, a bit of a scout's honor type thing.

MONITORING: The FDA does monitor the safety of cosmetics on the market and can work with companies to make sure recalls are effective. The FDA does also reserve the right to inspect cosmetic manufacturing facilities. Adulterated cosmetics are subject to the Federal Food, Drug, and Cosmetic Act.

RESEARCH: The FDA conducts research on cosmetics to provide guidance to cosmetics companies and to support regulatory actions. The Cosmetic Ingredient Review (CIR) Expert Panel was established in 1976 to assess the safety of cosmetics in the U.S. 

Under section 801(a) of the FD&C Act, imported cosmetics are subject to review by FDA at the time of entry through U.S. Customs. Products that do not comply with FDA laws and regulations are subject to refusal of admission into the United States.

So presumably, if your package makes it through customs, you are most likely in the clear (with the caveat that if the product is a fake, it may get through customs under the presumption that the contents match the label. I cover fakes in the FAQ).

So let's now take a deep dive into what the 4 aforementioned countries do to ensure their cosmetics are safe for consumption.

Asian Cosmetics safety standards and regulations and frequently asked questions faq
Since you're here, I'm going to assume that you, dearest darling-est reader, are somewhat interested in Asian cosmetics, and are completely aware that the whole of Asia is not just China, and that each country has different standards regarding their cosmetics. 

So with that out of the way, our first stop is South Korea, the hotbed of innovation, and the current darling of beauty editors everywhere... This market is one of the fastest growing cosmetics markets in the world, and rising demand comes from not only exports to international fans, but also a growing male consumer base. Leading brands are those of the AmorePacific group (Etude House, AmorePacific, Iope, Laneige, + 26 more) and LG H&H (TheFaceShop, OHUI, SU:M37, + 18 more).

DEFINITION OF COSMETICS: Cosmetics are categorized as general cosmetics, functional cosmetics, and quasi-drugs. Functional cosmetics include products that contain whitening/brightening, self-tanning, UV filtering, and anti-aging ingredients. Quasi-drugs include anti-acne products. Both functional cosmetics and quasi-drugs are held to a higher standard.

LABELING: Similar to the US, all cosmetic products must be labeled to meet Korean Cosmetic Products Act (KCPA) standards and cannot intentionally mislead consumers. All advertising must not be misleading as well. The CEOs of cosmetics companies must obtain a certificate of manufacture, ensuring their ingredients are in accordance with the International Cosmetics Ingredients Dictionary (ICID) published by the Personal Care Product Council (PCPC).

APPROVALS: Cosmetics fall under the Korean Cosmetic Products Act (KCPA) which has been enforced since 2000 by the Ministry of Food and Drug Safety (MFDS) and Korean Food and Drug Adminstration (KFDA). Similar to the U.S., general cosmetics and cosmetic ingredients (besides sunscreens, preservatives and color additives) do not require approval and the companies bear the full legal responsibility of ensuring the products are safe. However, functional cosmetics and quasi-drugs must be approved by the KFDA before going to market.

The main difference with the U.S. is that all cosmetics manufacturers and importers must register with the MFDS in order to do business in Korea. Functional cosmetics manufacturers/importers must additionally submit their products for evaluation to the MFDS before conducting any commercial activities. Before conducting any marketing activities, manufacturers/importers must gain approval once more.

The KCPA undergoes revision often with the most recent version in 2014 adding a cosmetic ingredients "negative list" or blacklist.


Asian Cosmetics safety standards and regulations and frequently asked questions faq
Japan is a highly developed cosmetic market and the world's second largest after the U.S. Competition is fierce and consumers are highly sophisticated. Many of the brands that lead the way in Japan are already household names in the U.S. such as the Shiseido group (which owns even NARS), Kose (anyone hear of a little brand called Tarte?), Kao brands, Kanebo, and Pola. 

DEFINITION OF COSMETICS: Cosmetics are divided into quasi-drugs and cosmetics, regulated by the Ministry of Health, Labor, and Welfare (MHLW). Cosmetics include sub-categories such as fragrance, makeup, haircare, etc. while quasi-drugs are products designed to prevent discomfort such as nausea, rashes, soreness, and hair growth or removal.

LABELING: Labeling standards are set by the MHLW.

A list of ingredients on the positive list and negative list are available here.

APPROVALS: Japan is similar to the U.S. and South Korea in that if a product is labelled according to MHLW standards, companies do not require approval to sell it. However, they must file each product with the governor of the jurisdiction  in which the operations and sales arms are located. If a product does not have all ingredients labelled according to standards, the product must be approved by the MHLW prior to launch.

Companies are required to apply or renew cosmetics manufacturing and sales permits every 5 years.

MONITORING: There are reporting standards in place to assist the MHLW act upon adverse reactions to quasi-drugs and cosmetics. Cases must be reported to the authority within a set time period.


Asian Cosmetics safety standards and regulations and frequently asked questions faq
Shills, My Scheming, My Beauty Diary, Niu 'Er, and Naruko, are all esteemed Taiwanese brands that have a growing following in the West. 

DEFINITION OF COSMETICS: Cosmetics fall into a generic or medicated category. Medicated cosmetics include any products that contain ingredients as per their Standard List of Maximum Levels of Medical, Poisonous, or Potent Drugs in Cosmetics.

LABELING: Products must be labelled in accordance with the Statute for Control of Cosmetic Hygiene and Approved ingredients

APPROVALS: Taiwan's ruling body is the Food and Drug Administration (FDA 2.0!) of the Ministry of Health and Welfare. Similar to the U.S., general cosmetics do not need approval and onus (+ legal responsibility) again falls on the manufacturer to ensure safety standards are met. Medicated cosmetics are subjected to a rigorous approval process administered by the FDA.

Above and beyond what we do in the U.S., cosmetic manufacturers must register with and gain approval from the FDA. 


Asian Cosmetics safety standards and regulations and frequently asked questions faq
The elephant in the room is China. In Western media, we regularly see stories about product contamination and counterfeit products containing dangerous ingredients, all stemming from China. The natural response is to become a bit wary. But the Chinese cosmetics market is growing and the regulatory bodies in China are working on cracking down on cosmetics.. not only for public health reasons, but also to alter the perception that Chinese cosmetics are inferior in any way on the global stage.

DEFINITION OF COSMETICS: Cosmetics are classified as ordinary cosmetics or special use cosmetics. Ordinary cosmetics include hair care, skin care, fragrances, face/nail/toe cosmetics while special use cosmetics include hair growth products, sunscreens, and deodorants among others.

LABELING: All cosmetics are subject to labeling requirements as per the standard GB 5296.3 -2008.

APPROVALS: Chinese cosmetics are under the control of the State Food and Drug Administration (SFDA). China's efforts to improve safety standards are evident here as ALL cosmetics require approval before market entry. Additionally, this approval is only valid for 4 years. Even more rigor is applied if a new cosmetic ingredient is included in the formula; in this case, a separate pre-approval must be obtained.

Manufacturers, exporters, and distributors must be licensed by the SFDA. 


My main takeaways from this exercise were...
  • Consumers have two levels of protection when it comes to imported Asian cosmetics: 
    • (1) Asian countries implement their own health and safety standards regarding which ingredients are allowed in the cosmetics, and these standards are often more stringent than the FDA's
    • (2) Imported cosmetics must ALSO comply with U.S. FDA laws and regulation or they are refused admission into the U.S. 
  • Fake cosmetics are the ones to watch out for, as they may make it through the U.S. customs inspection under the presumption that the contents match the label. Read the FAQ to see how you can protect yourself from buying a fake item!

Here are my answers to some frequently asked questions about Asian cosmetics.

Well, yes and no. 

Paula Begoun of Paula's Choice hit the nail on the head in that "there is no regional or national inside track to having great skin" and there are good and bad products in every country. When choosing skincare, Asian or otherwise, it must be done with a measure of ingredients awareness, with clear goals in mind.

No country has a monopoly on good R&D. L'oreal is testing lab-grown human skin. Korean brands led the way in developing the ever-popular alphabet creams (BB's, CC's), and using snail juice in skincare. What I've found though is that Asian skincare lines are generally more cost-effective and a bit more experimental when it comes to choosing ingredients and formulations. However, as we saw above, each ingredient is registered and labeled according to national and international standards, and is composed of time-tested well-researched ingredients

What I do to help mitigate the risk of purchasing a fake product is to purchase products from sellers that have good ratings from a large customer base. I also usually purchase from someone on this list of approved sellers. If a seller is not on it, like I said, I make my decision based on the number of transactions the seller has made and the feedback from their customers.
The FBI published this guide for identifying counterfeit cosmetics and much of it makes a lot of sense. 

Whitening/brightening Asian products contain a whitening agent that is not bleach. Rather, the active ingredients in these products are usually arbutin, hydroquinone, kojic acid (among others)... antioxidants that can also be found in Western skincare. Like we saw above, whitening products are often regulated much more strictly than regular cosmetics in Asia.

A lot of Asian cosmetics feature ingredients that have been used for centuries such as camellia oil in Japan or rice water in Korea... and many of these ingredients can be loosely classified as natural or organic. (not that those words technically mean anything). 
If you are interested in these types of products, I would recommend checking out the retailer, a site that curates Asian cosmetics formulated without parabens, triclosan, hydroquinone, benzophenones, BPAs, tar, talc, sodium lauryl/ laureth sulfates, aluminum, DEET, formaldehyde, PABA, toluene, camphor, PVC, phthalates or synthetic dyes.

While I have seen reports that Taiwan may be the next country to end animal testing for cosmetics... they are just getting started.
Unfortunately, China requires cosmetics to be tested on animals in their approval process.

Skincare is very personal and no routine fits all skin types and lifestyles. In fact, a person may require different routines during different seasons! However, let me make the case for applying a more specialized approach with regards to purchasing skincare products. My main point is that your all-in-one cream may be a jack of all trades, but is probably a master of none. Not to mention that certain ingredients cannot be formulated together without detracting from each other's benefits. They must be applied to the skin in layers (read: different products) to actually unleash their benefits to the best of their abilities. Take into account requisite pH environment and absorption times, and it gets even more complicated.

Well I would say that Asian sunscreens are miles ahead of their Western peers - Asian regulators have approved new ingredients for use that not only boost protection, but make for amazing formulas that you'll actually want to wear. Unlike gloopy, heavy, Western sunscreens, Asian sunscreens are thin fluids that dry down quickly and with very little sheen or white cast. There is currently an ongoing petition with the U.S. FDA to get these new ingredients approved and available in U.S. products.
I would also recommend trying out sheet masks. While Western brands have embraced the sheet mask, and released some of their own... Asian brands were the first movers with this breed of mask. Generally speaking, they also offer way better prices. 
I 'm also in a loving relationship with my snail secretion filtrate cream. I highly recommend trying one out, but totally get if you have reservations.


If you made it this far, congratulations, you deserve a gold star(-fish)! If you use Asian cosmetics, I would love to hear your thoughts on or experiences with this topic. If you haven't tried any but are interested, I'd like to know what you think as well! What's been holding you back from trying?

xx Joan

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