[Yeah, I get that the title–and the whole post–is boring as hell, but I’m trying to be as plain and unsensationalist as possible in hopes of setting the tone for a rational discussion.]

This post demonstrates that South Korea and the United States have different cosmetic ingredient list order regulations leading to the exact same product having a differently ordered ingredient list in each country. A key difference in terms of what is demanded from manufacturers in South Korea versus the United States means that kbeauty ingredient lists for products sold in the U.S. that have simply been translated from Korean may not meet U.S. FDA regulations and cannot be read in the same way one reads an FDA-compliant label.

A History of the problem: I was just trying to write a decent review, I swear

In the course of writing a review of Laneige’s Multiberry Yogurt Pack (which I was reviewing because I really like it) I realized that the product might have two formulations or versions. There’s a product sold by Laneige in Korea called Multiberry Yogurt Pack. There’s a product sold in the United States at Target called Multiberry Yogurt Repairing Mask. I own and tested the Korean version, but I thought that my readers–many of whom are based in the U.S.–would want to know if the product I was reviewing, the Korean Multiberry Yogurt Pack, is the same as the Multiberry Yogurt Repairing Mask that they could easily buy online from Target. I didn’t know, so I wrote to Laneige USA to ask if the products are the same and if I could have a U.S. ingredient list.

Laneige USA was nice enough to write back and confirm that the formulations are the same and provide an ingredient list. Laneige USA confirmed, “[t]he Multiberry Yogurt Pack and Multiberry Yogurt Repairing Mask are the same product. Product names have been adjusted for US market.”

Now…if you have been following my blog, you’ll know that I’m very…careful about ingredient translation. As in, I’m a hard-ass. So I compiled a list of Korean ingredients using the fabulous Hwahae ingredient app and cross-checked it against the Hangul ingredient list in my Laneige product box. Then I compared it to the list I was given by Laneige USA and realized that there is a problem.

Korean Laneige Multiberry Yogurt Pack ingredient list vs. U.S. Laneige Multiberry Yogurt Repairing Mask ingredient list

Korean version ingredients (from the Hwahae app and confirmed by me using the paper insert)

Water, Glycerin, Shea Butter, Propanediol, Cacao Seed Butter, Butylene Glycol, Dimethicone, Cetyl Alcohol, Squalane, Diisostearyl Malate, PEG/PPG-17/6 Copolymer, Lactobacillus/Soybean Ferment Extract, Yeast Ferment Extract, Strawberry Fruit Extract, Raspberry Fruit Extract, Lycium Chinense Fruit Extract, Cranberry Fruit Extract, Sapindus Mukurossi Fruit Extract, Blueberry Fruit Extract, Rubus Chamaemorus Seed Extract, Coffee Seed Extract, Yogurt Powder, Niacinamide, Acetyl Glucosamine, 1,2-Hexanediol, Glyceryl Stearate, Glyceryl Stearate Citrate, Dimethicone/Vinyl Dimethicone Crosspolymer, Mannan, Meadowfoam Seed Oil, Sodium Polyacrylate, Sucrose, Sucrose Palmitate, Ethylhexylglycrin, Xanthan Gum, Carbomer, Triethylhexanoin, Polysorbate 20, Hydroxypropyl Starch Phosphate, CI 17200, Disodium EDTA, Phenoxyethanol, Fragrance.

U.S. version ingredients (supplied by Laneige USA)

Water, Glycerin, Butyrospermum Parkii (Shea) Butter, Propanediol, Butylene Glycol, Theobroma Cacao (Cocoa) Seed Butter, Dimethicone, Cetyl Alcohol, Squalane, Diisostearyl Malate, PEG/PPG-17/6 Copolymer, Limnanthes Alba (Meadowfoam) Seed Oil, Triethylhexanoin, Dimethicone/Vinyl Dimethicone Crosspolymer, Sodium Polyacrylate, Sucrose Palmitate, Phenoxyethanol, Lactobacillus/Soybean Ferment Extract, Yeast Ferment Extract, Glyceryl Stearate, Fragrance, Acetyl Glucosamine, Yogurt Powder, Niacinamide, Hydroxypropyl Starch Phosphate, Polysorbate 20 Ethylhexylglycerin, Carbomer, Disodium EDTA, Mannan, Glyceryl Stearate Citrate, Sucrose, Xanthan Gum, 1,2-Hexanediol, Lycium Chinense Fruit Extract, Rubus Idaeus (Raspberry) Fruit Extract, Vaccinium Angustifolium (Blueberry) Fruit Extract, Coffea Arabica (Coffee) Seed Extract, Sapindus Mukurossi Fruit Extract, Vaccinium Macrocarpon (Cranberry) Fruit Extract, Fragaria Chiloensis (Strawberry) Fruit Extract, Rubus Chamaemorus Seed Extract, Red 33 (CI 17200).

The Problem becomes apparent

As you can see, the lists aren’t exactly the same, but very nearly so. The facts:

• The number of ingredients is the same (43).
• The names of the ingredients are the same.
• Laneige USA has confirmed that the formulations are the same.
• The ingredients are in a different order.

Let’s look at the comparison in a table:

Korean ingredients

U.S. ingredients

Water Glycerin Butyrospermum Parkii (Shea) Butter Propanediol Theobroma Cacao (Cocoa) Seed Butter Butylene Glycol Dimethicone Cetyl Alcohol Squalane Diisostearyl Malate PEG/PPG-17/6 Copolymer Lactobacillus/Soybean Ferment Extract Yeast Ferment Extract Fragaria Chiloensis (Strawberry) Fruit Extract Rubus Idaeus (Raspberry) Fruit Extract Lycium Chinense Fruit Extract Vaccinium Macrocarpon (Cranberry) Fruit Extract Sapindus Mukurossi Fruit Extract Vaccinium Angustifolium (Blueberry) Fruit Extract Rubus Chamaemorus Seed Extract Coffea Arabica (Coffee) Seed Extract Yogurt Powder Niacinamide Acetyl Glucosamine 1,2-Hexanediol Glyceryl Stearate Glyceryl Stearate Citrate Dimethicone/Vinyl Dimethicone Crosspolymer Mannan Limnanthes Alba (Meadowfoam) Seed Oil Sodium Polyacrylate Sucrose Sucrose Palmitate Ethylhexylglycerin Xanthan Gum Carbomer Triethylhexanoin Polysorbate 20 Hydroxypropyl Starch Phosphate Red 33 (CI 17200) Disodium EDTA Phenoxyethanol Fragrance

Water Glycerin Butyrospermum Parkii (Shea) Butter Propanediol Butylene Glycol Theobroma Cacao (Cocoa) Seed Butter Dimethicone Cetyl Alcohol Squalane Diisostearyl Malate PEG/PPG-17/6 Copolymer Limnanthes Alba (Meadowfoam) Seed Oil Triethylhexanoin Dimethicone/Vinyl Dimethicone Crosspolymer Sodium Polyacrylate Sucrose Palmitate Phenoxyethanol Lactobacillus/Soybean Ferment Extract Yeast Ferment Extract Glyceryl Stearate Fragrance Acetyl Glucosamine Yogurt Powder Niacinamide Hydroxypropyl Starch Phosphate Polysorbate 20 Ethylhexylglycerin Carbomer Disodium EDTA Mannan Glyceryl Stearate Citrate Sucrose Xanthan Gum 1,2-Hexanediol Lycium Chinense Fruit Extract Rubus Idaeus (Raspberry) Fruit Extract Vaccinium Angustifolium (Blueberry) Fruit Extract Coffea Arabica (Coffee) Seed Extract Sapindus Mukurossi Fruit Extract Vaccinium Macrocarpon (Cranberry) Fruit Extract Fragaria Chiloensis (Strawberry) Fruit Extract Rubus Chamaemorus Seed Extract Red 33 (CI 17200)

I see no reason to doubt Laneige USA, especially since the ingredient lists are exactly the same except for the issue of product order. This suggested to me that the United States and Korea actually have different product order regulations.

A Crash Course in South Korean and U.S. Ingredient Order Regulations

U.S. ingredient order rules

The U.S. Food and Drug Administration (FDA) has a Labeling Guide on their site that explains the cosmetics ingredient labeling regulations.

Main points:

• The ingredients must be listed in descending order of predominance. Ingredients that are part of compounds need to be listed individually according to their own predominance in the whole product.
• Exceptions: if the ingredient is a drug (in that case, the ingredient can be listed before the purely cosmetic ingredients), “[i]ngredients present at a concentration not exceeding 1% may be listed in any order after the listing of the ingredients present at more than 1% in descending order of predominance”, color additives may be listed last no matter their concentration, and trade secret ingredients don’t need to be listed as long as the words “and other ingredients” appear at the end of the list.

Korean ingredient order rules

From the oneclick.law.go.kr site.

Main points:

• Ingredients need to be listed in descending order. However, ingredients not exceeding 1%, flavorings, and coloring agents may be listed in any order after ingredients in concentrations exceeding 1%. [“화장품 제조에 사용된 함량이 많은 것부터 기재·표시합니다. 다만, 1퍼센트 이하로 사용된 성분, 착향제 또는 착색제는 순서에 상관없이 기재·표시할 수 있습니다.”]
• Compounds consisting of multiple ingredients need to be broken down into individual ingredients and written out separately. [“혼합원료는 혼합된 개별 성분의 명칭을 기재·표시합니다.”]

The difference, from what I can tell

From my understanding of the U.S. and South Korean regulations, the only difference is that the U.S. requires each individual ingredient in a compound to be listed in order according to its own predominance in the whole product and South Korea doesn’t.

While explaining this to my confused friend Cat at Snow White and the Asian Pear, she asked if this whole issue is like food labeling, and I think that’s a good way to put it. South Korea’s cosmetics ingredient order regulations are kind of like U.S. food ingredient order regulations where compounds are concerned.

If you buy a chocolate-covered ice cream in the U.S. it’s totally legal for the ingredient list to say something like:

Ingredients: milk, sugar, chocolate (cocoa butter, chocolate liquor, sugar, lecithin, vanilla), soy, and preservatives.

If that chocolate covered ice cream bar were a South Korean cosmetic product, from my understanding it would be totally legal to write the ingredients out as:

Ingredients: milk, sugar, cocoa butter, chocolate liquor, sugar, lecithin, vanilla, soy, and preservatives.

In this case, the chocolate compound has been broken down into the individual ingredients, as the South Korean cosmetics regulations require.

The U.S. has different regulations concerning cosmetic ingredient order. The Food and Drug Administration requires not only compounds to be broken down and listed as individual ingredients, but also all of the ingredients to be listed individually according to their own predominance in the whole product. That’s where the shuffling comes in. So that means going back to the recipe and determining how much of each thing is in the product and then resorting the list:

milk (83.15%)
sugar (5%)
cocoa butter (3%)
chocolate liquor (2%)
sugar (0.5%, now factored into the sugar above)
lecithin (0.25%)
vanilla (0.1%)
soy (4%)
preservatives (2%)

The U.S. FDA-compliant cosmetic ingredient list would read:

Ingredients: milk, sugar, soy, cocoa butter, chocolate liquor, preservatives, lecithin, and vanilla. (Although anything under 1% can be listed in any order.)

If you compare the South Korean ice cream bar ingredient list to that of the U.S. you can see why the difference might be a problem:

South Korean ingredient list: milk, sugar, cocoa butter, chocolate liquor, sugar, lecithin, vanilla, soy, and preservatives.

U.S. ingredient list: milk, sugar, soy, cocoa butter, chocolate liquor, preservatives, lecithin, and vanilla.

For people, say, who are hoping to avoid a lot of soy in their diets, the difference in ingredient lists is pretty major; soy visibly jumps higher in the U.S. ingredient list, signalling that it makes up a significant portion of the ice cream bar. This is the impact of requiring ingredients in compounds to not only be listed individually, but by their own predominance in the whole product.

You can’t read even a translated South Korean cosmetic ingredient list the same way you would a U.S. ingredient list

If you read a South Korean ingredient list (that hasn’t been reshuffled to comply with U.S. FDA regulations) the same way you would an FDA-compliant ingredient list, you’re likely to make incorrect assumptions about just how much of each ingredient is present in the formula.

When I looked at how much ingredients moved up or down in the U.S. list for the Laneige Multiberry mask, I found that the ingredients that excite customers the most (extracts) fell furthest down the list while things some people try to avoid such as preservatives moved up most. Again, keep in mind that the only difference between the lists is U.S. labeling regulations, not a change to the actual product.

Ingredients that moved down in the U.S. ingredient list in the Multiberry Yogurt Repairing Mask

Fragaria Chiloensis (Strawberry) Fruit Extract -27
Vaccinium Macrocarpon (Cranberry) Fruit Extract -23
Rubus Chamaemorus Seed Extract -22
Rubus Idaeus (Raspberry) Fruit Extract -21
Sapindus Mukurossi Fruit Extract -21
Lycium Chinense Fruit Extract -19
Vaccinium Angustifolium (Blueberry) Fruit Extract -18
Coffea Arabica (Coffee) Seed Extract -17
1,2-Hexanediol -9
Lactobacillus/Soybean Ferment Extract -6
Yeast Ferment Extract -6
Glyceryl Stearate Citrate -4
Red 33 (CI 17200) -3
Theobroma Cacao (Cocoa) Seed Butter -1
Yogurt Powder -1
Niacinamide -1
Mannan -1

Ingredients that moved up in the U.S. ingredient list in the Multiberry Yogurt Repairing Mask

Phenoxyethanol +25
Triethylhexanoin +24
Fragrance +22
Limnanthes Alba (Meadowfoam) Seed Oil +18
Sucrose Palmitate +17
Sodium Polyacrylate +16
Dimethicone/Vinyl Dimethicone Crosspolymer +14
Hydroxypropyl Starch Phosphate +14
Polysorbate 20 +12
Disodium EDTA +12
Carbomer +8
Ethylhexylglycerin +7
Glyceryl Stearate +6
Acetyl Glucosamine +2
Xanthan Gum +2
Butylene Glycol +1

A Second Ingredient Order Case Study: Dr.Jart+ Dermaclear Micro Water

I didn’t want to publish this post without making sure that the pattern of ingredient order switching happens across brands and in products other than just the Laneige pack mask. Although the Korean ingredient regulations seem to lack the U.S. FDA portion about reshuffling ingredients in compounds it makes sense to be cautious before cracking this discussion open, so I found the Korean and U.S. ingredient lists for a product I recently tried and confirmed with the maker, Dr.Jart+, that the formulation is the same in both countries.

Korean version ingredients (from the Hwahae app)

Water, Butylene Glycol, Dipropylene Glycol, PEG-6 Caprylic/Capric Glycerides, Citrus Aurantium Bergamia (Bergamot) Fruit Oil, Rice Ferment Filtrate (Sake), Pearl Powder, Galactomyces Ferment Filtrate, Hippophae Rhamnoides Fruit Extract, Salix Nigra (Willow) Bark Extract, Nymphaea Alba Flower Extract, Rosa Multiflora Fruit Extract, Royal Jelly Extract, Decyl Glucoside, PEG-40 Hydrogenated Castor Oil, PPG-26-Buteth-26, Ethylhexylglycerin, Sodium Citrate, Citric Acid, Madecassoside, Sodium Palmitoyl Proline, Caprylyl Glycol, Disodium EDTA, Phenoxyethanol.

U.S. version ingredients (supplied on the Sephora website)

Water, Butylene Glycol, Dipropylene Glycol, PEG-6 Caprylic/Capric Glycerides, Phenoxyethanol, Decyl Glucoside, PEG-40 Hydrogenated Castor Oil, PPG-26-Buteth-26, Ethylhexylglycerin, Sodium Citrate, Disodium EDTA, Citric Acid, Citrus Aurantium Bergamia (Bergamot) Fruit Oil, Madecassoside, Rice Ferment Filtrate (Sake), Pearl Powder, Galactomyces Ferment Filtrate, Hippophae Rhamnoides Fruit Extract, Sodium Palmitoyl Proline, Salix Nigra (Willow) Bark Extract, Nymphaea Alba Flower Extract, Rosa Multiflora Fruit Extract, Royal Jelly Extract, Caprylyl Glycol.

As you can see, the lists aren’t exactly the same, but very nearly so. The facts:

• The number of ingredients is the same (24).
• The names of the ingredients are the same.
• Dr.Jart+ has confirmed that the formulations are the same.
• The ingredients are in a different order.

Korean ingredients

U.S. ingredients

Water Butylene Glycol Dipropylene Glycol PEG-6 Caprylic/Capric Glycerides Citrus Aurantium Bergamia (Bergamot) Fruit Oil Rice Ferment Filtrate (Sake) Pearl Powder Galactomyces Ferment Filtrate Hippophae Rhamnoides Fruit Extract Salix Nigra (Willow) Bark Extract Nymphaea Alba Flower Extract Rosa Multiflora Fruit Extract Royal Jelly Extract Decyl Glucoside PEG-40 Hydrogenated Castor Oil PPG-26-Buteth-26 Ethylhexylglycerin Sodium Citrate Citric Acid Madecassoside Sodium Palmitoyl Proline Caprylyl Glycol Disodium EDTA Phenoxyethanol

Water Butylene Glycol Dipropylene Glycol PEG-6 Caprylic/Capric Glycerides Phenoxyethanol +19 Decyl Glucoside +8 PEG-40 Hydrogenated Castor Oil +8 PPG-26-Buteth-26 +8 Ethylhexylglycerin +8 Sodium Citrate +8 Disodium EDTA +12 Citric Acid +7 Citrus Aurantium Bergamia (Bergamot) Fruit Oil -8 Madecassoside +6 Rice Ferment Filtrate (Sake) -9 Pearl Powder -9 Galactomyces Ferment Filtrate -9 Hippophae Rhamnoides Fruit Extract -9 Sodium Palmitoyl Proline +2 Salix Nigra (Willow) Bark Extract -10 Nymphaea Alba Flower Extract -10 Rosa Multiflora Fruit Extract -10 Royal Jelly Extract -10 Caprylyl Glycol -2

Ingredients that moved down in the U.S. ingredient list in the Dr.Jart+ Dermaclear Micro Water

Salix Nigra (Willow) Bark Extract -10
Nymphaea Alba Flower Extract -10
Rosa Multiflora Fruit Extract -10
Royal Jelly Extract -10
Rice Ferment Filtrate (Sake) -9
Pearl Powder -9
Galactomyces Ferment Filtrate -9
Hippophae Rhamnoides Fruit Extract -9
Citrus Aurantium Bergamia (Bergamot) Fruit Oil -8
Caprylyl Glycol -2

Ingredients that moved up in the U.S. ingredient list in the Dr.Jart+ Dermaclear Micro Water

Phenoxyethanol +19
Disodium EDTA +12
Decyl Glucoside +8
PEG-40 Hydrogenated Castor Oil +8
PPG-26-Buteth-26 +8
Ethylhexylglycerin +8
Sodium Citrate +8
Citric Acid +7
Madecassoside +6
Sodium Palmitoyl Proline +2

It seems like similar things happened to certain kinds of ingredients in this reshuffling as in the Laneige list U.S. makeover: extracts that people want dropped the most while certain ingredients about which people feel negatively or neutrally have risen in the list. To me, this suggests that further research on whether cosmetics companies in Korea use compounds along with the Korean ingredient list order compound loophole, for lack of a better term, to “game” ingredient lists and make their products appear more desirable than they actually are to customers in Korea. An example of this would be bundling extracts about which the public feels favorably into a compound that allows them to appear higher on the ingredient list while making sure that ingredients like Phenoxyethanol remain uncompounded so that they can appear at the end of the list.

Reminder: Laneige USA and Dr.Jart+ are doing exactly what they’re supposed to be doing

I want to be clear that this post should, in no way, indicate that Laneige USA and Dr.Jart+ in the US have done anything wrong or deceptive whatsoever. In fact, the U.S. branches of both companies have done exactly what kbeauty companies in the U.S. should do: they’ve provided what appear to be U.S. FDA-compliant ingredient lists. They’ve also answered my questions about the products in a very straightforward way. I plan to continue to use their products and support their efforts to gain new fans in the U.S. They’ve done well.

Conclusions

• Our translations of Korean ingredient lists are probably useful only insofar as they let you know what’s in the product; they can’t be used to gauge the actual or relative amount of anything in there.
• Outside of the ingredient lists for the products I’ve broken down here, I simply don’t know which brands and products have U.S.-compliant ingredient lists. That’s a question for either the brand or a chemist.
• This is a first step in the direction of attempting to understand this issue. In this post I’ve laid out evidence that I think demonstrates a difference in U.S. and South Korean cosmetic ingredient order regulations and practice. I hope that actual journalists and bloggers will, with calm and prudence, explore the many issues and questions that I have not been able to tackle in this preliminary post. This sort of thing really isn’t my style, but I felt the need to share it and the material I’ve been able to assemble for the sake of advancing our knowledge, and yet I very much would like to get back to more fun and foufy things.