China Moved Cosmetic Ingredient Lists Behind a QR Code in February. Korea Only Filed a Bill.
Pick up any bottle in your bathroom and turn it over. The ingredient list is the grey block on the back, usually the last thing printed and usually the smallest type on the package. It is there because a law says it has to be there.
In China, since the first of February, that is no longer quite true.
The National Medical Products Administration opened a three-year electronic-label pilot with a notice numbered 国药监妆〔2025〕16号. Products enrolled in it carry a QR code, and the code has to display everything the label rules require. The physical package keeps a much shorter list. We went and read the notice and its first annex because we sell fifty-six products and every one of them has a printed ingredient list, and we wanted to know whether that is about to stop being the normal arrangement.
China's cosmetic electronic-label pilot took effect on 1 February 2026 and runs for three years. A product in the pilot has to show every required label item through the code, the full ingredient list included. On the visible face of the physical package, only six items stay mandatory, and the ingredient list is not one of the six. Europe has not done this for cosmetics, whatever the digital-labelling headlines from last year suggested. Korea has a filed bill and nothing else, and a filed bill is not a law.
What the notice actually says
The notice is short. The detail is in the first annex.
Article 6 of that annex is the one most summaries get wrong. Pilot products can be produced and sold across the whole country. There is no six-city carve-out, no restricted sales channel, no separate registration track for pilot goods. If a company is in the pilot, its product is a normal Chinese-market product that happens to carry a code.
Article 10 sets the standard for the code itself, and it is a high one. The electronic label has to display every item required by Article 7 of the 化妆品标签管理办法, the labelling rules that already govern Chinese cosmetics. Every item includes the full ingredient list. So nothing disappears from the regulatory record. It moves.
Six items. That is the entire physical label.
Article 11 is where the pilot stops being an administrative detail. On the visible surface of the physical sales package, six things stay mandatory. The full ingredient list is not among them.
That is the whole change, and it is bigger than it sounds. A Chinese shopper in the pilot period can pick up a jar, read the visible face, and not find out what is in it without a phone and a working signal.
Six items is enough to tell you what the product is, who made it, how much is in the tin and when it expires. It is not enough to tell you whether the thing contains something you personally react to. Those are different questions and only one of them is answered on the box now.
| Where | Ingredient list on the physical package | Status |
|---|---|---|
| China, pilot products | Not among the six mandatory items | Live since 1 Feb 2026, three-year term |
| China, everything else | Required | Standing rule, unchanged |
| European Union | Required, Article 19 | Unchanged for cosmetics |
| Korea | Required, 화장품법 제10조제1항 | Bill filed 30 Mar 2026, not law |
We have not held one of these packages. We do not sell into China, we have not seen a pilot product in a shop, and we are not going to describe how the code reads in a badly lit aisle as though we had tried it. What we can read is the text, and the text says the ingredient list is optional on the box.
Europe is not doing this, whatever you read
Article 19 of Regulation (EC) No 1223/2009 is still the European rule, and it still puts the list of ingredients on the container and the packaging. Nothing in 2025 or 2026 changed that for cosmetics.
The confusion comes from the Omnibus VI package and COM(2025)531, which did move real labelling work onto screens. That work sits under CLP, the chemical classification and labelling regime. Detergents and chemical products, not shampoo. We went looking for the cosmetics equivalent and there isn't one.
The two get merged in trade-press summaries constantly, and a European brand that reads those summaries and quietly shortens its printed label is breaking Article 19.
Korea filed a bill. That is the whole Korean story.
On 30 March 2026, 안상훈 filed a 화장품법 일부개정법률안 that would open the door to electronic labelling in Korea.
Filed. That is the verb, and we are going to leave it there. We could not confirm what has happened to the bill since, and we have watched enough coverage turn "filed" into "passed" into "in force" to know how that goes. Meanwhile 화장품법 제10조제1항 still requires the printed particulars on Korean packaging, and it will keep requiring them until something is promulgated and takes effect.
Sixty-one lines behind one square
We recounted our own catalogue for this piece rather than trusting the last count. Fifty-six products. The longest ingredient list we sell runs to 87 entries, on a spicule ampoule. The shortest runs to one, because it is a bottle of jojoba oil and there is nothing else in it.
The middle of that range is where the argument lives. Take our grey-coverage dye shampoo: 61 entries on a 300ml bottle. Two of those 61 we grade high risk, and they are the two you would most want to see before you buy — p-Phenylenediamine and Resorcinol, both well-documented contact allergens in hair dye. We have written about that product before and we did not enjoy it then either.
Sixty-one lines genuinely do not fit legibly on that bottle. The typography argument for the screen is real and we are not going to pretend otherwise.
But a printed line is a decision you can make in four seconds while holding the thing. A code is a decision you make afterward, if you remember, if you have signal, and if the page loads. Those are not the same product experience, and the people most likely to need the PPD line — someone who reacted to a dye once and has been careful since — are exactly the people who will be reading in a hurry.
One more from our shelf: a colouring shampoo we list at 51 entries, two of them high risk. The pattern in hair colour is consistent. The lists are long, the flagged ingredients sit deep in them, and the flagged ingredients are the point.
The length problem is not confined to hair dye either. A perfumed hair treatment we carry runs to 74 entries. A barrier cream runs to 66. A cleansing foam runs to 51, and every single one of those 51 lines grades low risk, which is the happy version of a long list and also the version nobody needs to check.
Position matters as much as length. In that 74-entry hair treatment, the individually named fragrance allergens — the ones a dermatologist would actually ask you about — sit at entries 18, 23, 25 and 28. Nobody reads to entry 28 on a physical bottle. But you can scan a printed block for one word you already know is your problem, and that scan takes about as long as finding the QR code does.
We could not verify one thing we wanted to verify: how many companies actually enrolled in the pilot. The notice sets the framework and the annex sets the rules, but enrolment figures were not something we could confirm from primary sources, so we have no idea whether this is fifty products or five thousand. Treat the scale of it as unknown.
What our screening found
Our own position here is weaker than the argument we just made. We publish a full ingredient list on all fifty-six product pages, and we grade every line, but we built those lists from what suppliers sent us. We have never audited one of them against a physical package we were holding in our hands. So when we say the printed label matters, we are defending something we have not personally verified for a single product we sell. That is a real gap and it is ours. Separately, the product in this piece with the strongest case for a printed list is also one of our lower scores — the dye shampoo sits at 8.6 out of 10, held down by exactly the two high-risk entries we are arguing should stay on the box. On the substance of the pilot: nothing is being hidden, and China's requirement that the code carry every Article 7 item is stricter than most coverage credits. What changes is who has to make an effort, and the effort moves from the printer to the shopper.
The thing to watch is not the pilot. Three years is a long test and the notice is careful. The thing to watch is what a successful pilot licenses everywhere else, because the shortened physical label is the part that travels well and the strict electronic-label requirement is the part that does not.
If you buy Korean or Chinese products online, none of this changes anything for you yet, and it may never — you are already reading a screen. If you buy in a shop and you have a known allergen, keep reading the box while the box still has to tell you. And if you want to know how we decide what counts as a claim worth trusting on a label, we wrote that up in label claims that mean something and listed the ten ingredients we flag most. Our scoring method, including where it falls down, is on our awards page.
- National Medical Products Administration, 国家药监局关于开展化妆品电子标签试点工作的通知, 国药监妆〔2025〕16号, and Annex 1 (Articles 6, 10, 11). Effective 1 February 2026, three-year term.
- NMPA, "Notice on Conducting a Pilot Program for Electronic Labeling of Cosmetics," English release of GYJZ [2025] No. 16.
- 化妆品标签管理办法 (Measures for the Administration of Cosmetic Labelling), Article 7 — required label particulars.
- Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products, Article 19 — labelling, including the list of ingredients.
- COM(2025)531, Omnibus VI package — digital labelling provisions under the CLP framework, not the Cosmetics Regulation.
- 화장품법 제10조제1항 — 화장품의 기재사항 (required printed particulars, Republic of Korea).
- 화장품법 일부개정법률안, 안상훈 의원 대표발의, filed 30 March 2026.
