Do Korean cosmetics have to be made in Korea?

I. Lack of Definition: The "Gray Area" of Korean Cosmetics Without Official Certification In the global beauty market, "K-beauty" has become a golden IP worth billions. Data from the Korea Beauty Industry Association shows that in 2024, South Korea's cosmetics exports reached $10.3 billion, with China, the United States, and Europe being the core consumer markets. However, this highly sought-after concept still lacks a unified official definition and, more importantly, a geographical indication protection system similar to that for champagne or Parmesan cheese. Jang Nam-jang, chairman of the Korea Beauty Industry Association, stated in an interview that the association currently has no plans to establish a Korean cosmetics certification system, saying, "We are more focused on promoting the industry and do not want to stifle global growth trends through sanctions." The association only has basic requirements for its members: they must be Korean-registered companies, and their products must be approved by the Korean Food and Drug Administration (KFDA). This means that products not manufactured in South Korea but meeting the above conditions may also be recognized by the association as "K-beauty." This ambiguity in definition has given rise to diverse forms of "K-beauty." For example, the American brand Seoul Ceuticals, headquartered in Los Angeles, manufactures all its products in the United States but claims to be "genuine Korean skincare products." Ann Majeski, the brand's Retail Relations Director, explained, "All our raw materials come from Korea, and our formulas follow Korean skincare principles." The brand projects sales of $14 million by 2025, with products exported to India, Europe, and other regions. Meanwhile, Hwarangbang, headquartered in Finland, insists on "all-Korean manufacturing." Co-founder Kim Seung-gu emphasized, "The core of Korean cosmetics must be a Korean perspective—from concept and formula to production, everything should reflect Korean characteristics." Although the company is registered in Finland, its core team members are Korean, and all products are manufactured in Korea and certified by the KFDA. Industry experts point out that the root of the confusion lies in the disconnect between the cultural and commercial attributes of Korean cosmetics. “It was originally a style label based on Korean skincare culture, not a geographical indication product,” said Li Min, a Chinese beauty industry analyst. “Once capital discovered the commercial value of ‘Korean cosmetics,’ it grafted this concept onto products in various ways, leading to a complete blurring of the boundaries between origin, brand, and raw materials.”

II. Global Expansion: The Wave of “Outbound Production” by Korean Cosmetic Giants In the context of a globalized supply chain, even authentic Korean cosmetic brands have long since broken away from the single “Made in Korea” model. Kolmar Korea—a leading global cosmetics contract manufacturer—was recently selected for the South Korean government’s “AI Factory Alliance” project, and its ambitions extend beyond domestic production in South Korea. According to a PR Newswire report in October 2025, Kolmar Korea plans to develop an AI-powered autonomous manufacturing system covering the entire process of R&D, production, and quality inspection, aiming to achieve over 95% process accuracy. This system will first be applied to its Sejong factory in South Korea, and then extended to its global production bases, including the United States, Canada, and China. “Our goal is to achieve manufacturing self-sufficiency, not to be limited by geographical origin,” said a spokesperson for Kolmar Korea. Some products manufactured in their Chinese factories are already supplied to brands like Shiseido and Innisfree in the Chinese market. This strategy reflects a dual consideration of cost and market. After the China-Korea Free Trade Agreement came into effect, although import tariffs on Korean cosmetics decreased by 20%, overseas manufacturing still saves on logistics and labor costs and circumvents trade barriers. Data from Changsha Customs shows that in 2024, China imported 32 billion yuan worth of cosmetics from South Korea, while the domestic market for “Korean-style” cosmetics manufactured under contract exceeded 50 billion yuan, including many products manufactured overseas for Korean brands. Brands are also becoming increasingly vague about the place of origin. Some lotions and masks from top Korean brands like Laneige and Mamonde are labeled “Made in Guangzhou, China” or “Made in Suzhou, Jiangsu” on their packaging, only mentioning “based on Korean R&D technology” in the formula description. A public relations manager for a certain brand in China revealed, "As long as the core formula and quality standards are consistent with those in South Korea, overseas production has become the norm in the industry, and this does not affect the product's 'Korean cosmetics attribute.'" However, consumers have a huge misconception about this. In the comment sections of the "Korean cosmetics section" on e-commerce platforms, many consumers still say, "I only buy products made in Korea," and "Overseas-manufactured products are fake." This difference in perception provides fertile ground for false advertising.

III. Regulatory Loopholes: The Counterfeiting Tactics and Difficulties of Counterfeit Korean Cosmetics A case uncovered by the Huangshan Municipal Market Supervision Bureau in 2021 exposed a typical counterfeiting pattern for counterfeit Korean cosmetics. A batch of 58 products, including shampoos and moisturizers, labeled "Nature Paradise Cosmetics Co., Ltd." (Korea), had packaging entirely in Korean, with Chinese labels claiming "imported from Korea," but the actual place of production was Guangzhou. Enforcement officers discovered that the product barcodes began with 48 (a Hong Kong code), the production license was a Guangdong cosmetics license, and the registered company was a Hong Kong company with a name similar to a Korean brand, but had no connection to Nature Paradise. "This type of counterfeiting has extremely low costs but can generate high profits," explained an enforcement officer from the Huangshan Municipal Market Supervision Bureau. Genuine Nature Paradise aloe vera gel sells for about 30 yuan per jar, while the production cost of counterfeit products is only about 5 yuan. These are sold for 25 yuan through e-commerce platforms and beauty stores under the guise of "imported from Korea," resulting in a profit margin as high as 400%. The case involved 77,000 yuan and was ultimately seized in accordance with the Anti-Unfair Competition Law, but similar cases continue to occur. VEIRFOO's operations are even more deceptive. The brand did not directly claim "Made in Korea," but instead implied a Korean background through promotional phrases such as "Korean professional brand" and "medical-grade hydration," while also employing Korean models for promotional images and using bilingual (Chinese and Korean) packaging designs. This kind of "conceptual fraud" operates in a legal gray area, making it difficult for consumers to provide evidence. Current Chinese regulatory policies have clear requirements for country of origin labeling. The Cosmetics Supervision and Management Regulations stipulate that imported cosmetics must indicate the country (region) of origin, and domestically produced cosmetics must indicate the address of the manufacturer. However, there are no prohibitions on stylized concepts like "Korean makeup." "The law only governs factual labeling, not marketing concepts," explained Wang Hao, an intellectual property lawyer at a Beijing law firm. "As long as the product truthfully labels its place of production, even if it promotes 'Korean formula' or 'Korean inspiration,' it is difficult to determine it as false advertising." South Korean regulations are similarly lenient. The Korean Ministry of Food and Drug Safety (MFDS) only conducts quality inspections on cosmetics produced or sold domestically, and has no jurisdiction over "Korean concept" products manufactured overseas. The Korea Beauty Industry Association has also stated that it will not take legal action against "fake Korean cosmetics" sold by non-members. Consumers face multiple obstacles in protecting their rights. First, it is difficult to provide evidence, requiring them to prove that the brand engaged in false advertising; second, the cost of protecting their rights is high, with compensation for a single consumer dispute often lower than the cost of testing and litigation; finally, there is regulatory lag, and by the time law enforcement intervenes, counterfeit brands may have already relaunched under a different name.

IV. The Path to Breaking the Impasse: The Dual Awakening of Standards and Consumer Rationality Faced with the escalating controversy over the country of origin, calls have begun from within and outside the industry to establish clear standards. Eliza Ahornpa-Kim, co-founder of Hwarangbang Korea, suggests: "Korean cosmetics should be defined from three dimensions: brand ownership, formula development, and manufacturing: the brand owner must be a Korean company, the core formula must be developed in Korea, and at least 70% of the production must be completed in Korea." This suggestion has received support from some Korean domestic brands but has been opposed by multinational contract manufacturers. Chinese regulatory authorities have strengthened enforcement regarding origin labeling. Since 2025, the national market supervision system has launched the "Clean Cosmetics Market Campaign," focusing on investigating and punishing false labeling of origin and exaggerated advertising. In Guangzhou, Hangzhou, and other cities, 23 cases of counterfeit Korean cosmetics have been uncovered, involving over ten million yuan. Meanwhile, customs authorities strictly enforce the certificate of origin verification system, requiring cosmetics declared as "Made in Korea" to provide official Korean certificates of origin. For consumers, learning to distinguish genuine Korean-made cosmetics is crucial. Industry insiders offer three suggestions: First, check the barcode; Korean-made cosmetics barcodes begin with 88, Chinese-made with 69, and Hong Kong-made with 48. Second, check registration information; the National Medical Products Administration's cosmetics supervision APP allows users to check the product's manufacturer, country of origin, and other authentic information. Third, verify the brand background; use Korean search engines like NAVER and brand websites to confirm their operations in Korea. Jang Nam-jang, chairman of the Korea Beauty Industry Association, stated that a "Korea Beauty Certification Mark" may be launched in the future, awarded to products that meet Korean production standards, but the plan is still under discussion. "We need to find a balance between protecting our domestic industry and promoting global development," he said. "The core competitiveness of Korean cosmetics should be formulas, technology, and skincare concepts, not simply country-of-origin labels." This controversy over country of origin is essentially a clash between globalization and localization, and a struggle between commercial interests and consumers' right to know. As more and more "Korean cosmetics" are no longer produced in Korea, consumers need to re-examine "country of origin worship," while brands should uphold the bottom line of integrity. As the China Consumers Association stated in its 2025 beauty consumption alert: "True quality is unrelated to country of origin; false advertising is the trap." The future of Korean cosmetics will ultimately return to the value of the products themselves.

Conclusion: Korean cosmetics do not necessarily have to be made in Korea. Currently, there is no globally unified official definition for "Korean cosmetics," nor is there a system for protecting country of origin. The Korea Cosmetics Industry Association only requires that brands be registered companies in Korea and that products pass KFDA testing, without specifying the place of manufacture. In a globalized context, major Korean cosmetics companies generally have overseas production bases. Many products from brands like Laneige and Innisfree are manufactured in factories in China and other overseas locations. As long as the core formula and quality standards are met, the industry generally considers them to still be "Korean cosmetics." The core of compliance is whether the country of origin label is accurate, not whether it is made in Korea; false advertising of "Made in Korea" is illegal. Consumers should not blindly trust the "Made in Korea" label but should verify the country of origin through registration information, barcodes, etc., focusing on the product's formula and quality.

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