Your BHA Toner Isn't a Legal Acne Product in Korea

Pick up a Korean BHA toner and read the box. Few say the product treats acne. Most stop at "for acne-prone skin," and some don't mention acne at all.

There's a specific reason, and concentration has nothing to do with it. Korea's 화장품법 시행규칙 (제2조) lists eleven categories of 기능성화장품, the official "functional cosmetics" label, and item 9 covers acne. It reads: "여드름성 피부를 완화하는 데 도움을 주는 화장품. 다만, 인체세정용 제품류로 한정한다."

The One Approved Ingredient

MFDS keeps a shortcut for brands that don't want to fund their own efficacy trial for this claim. 기능성화장품 심사에 관한 규정 별표4, item 6, names exactly one qualifying ingredient at exactly one concentration, salicylic acid at 0.5%.

The same clause of 별표4 pins the product down just as tightly as the ingredient. Type has to be 인체세정용 제품류(비누조성의 제제). Form is limited to liquid, lotion or cream, ruling out anything soaked into a pad or sheet, and the label reads: "본품 적당량을 취해 피부에 사용한 후 물로 바로 깨끗이 씻어낸다."

Where the Line Actually Sits

That restriction isn't a quirk of the exempt-ingredient list. It comes from how 별표3 sorts every cosmetic type in Korea to begin with. 인체 세정용 제품류, human-cleansing type, covers foam cleanser, body cleanser, liquid soap and bar soap. Toners sit in a separate group, 기초화장용 제품류, next to essence, lotion and cream, and the list's own word for a toner is "화장수."

A cleansing water sold as a makeup remover stays on the skincare side of that same line. Item 10 of the list still groups it under 기초화장용, the identical basic-skincare category a toner falls into, whether or not the instructions say to wipe or rinse it away.

It Used to Be a Quasi-Drug

This category is newer than most of the others in 제2조. A 2017-05-18 report from CMN covers a law taking effect that same month, expanding 기능성화장품 from three original categories, whitening, wrinkles and sunscreen, out to nine. Hair color, hair removal, hair-loss relief, acne relief, atopic-skin-dryness relief and stretch-mark relief were the other six additions written into that 2017 revision.

Before then, a product like this wasn't reviewed as a cosmetic at all. It fell under 의약외품, Korea's category for something stronger than an ordinary cosmetic but short of a prescription drug. Items still mid-review as 의약외품 when the law changed had their filings carried straight into the 기능성화장품 track instead of restarting, and the rinse-off condition transferred with them, unchanged since 2017.

One more rule survives from that same period. "여드름" itself counts as a banned word in Korean cosmetics advertising unless a product holds this exact certification. MFDS's own published interpretation confirms a general cosmetic can only be reviewed for this claim "인체 세정용 화장품에 한하여," with two narrow exceptions to the ban, the certified wording itself, or a substantiated line that reads: "여드름성 피부에 사용에 적합."

That second phrase, suitable for use, is what a leave-on product can reach for. The full interpretation adds one more wrinkle worth flagging, an abbreviation like "AC" or "아크" can trip the same ban if an ordinary shopper would read it as a stand-in for the word acne.

The US Doesn't Draw This Line

Cross the Pacific and the same active ingredient at the same concentration sits inside a different kind of product. 21 CFR 333.310, the FDA's OTC acne drug monograph, permits salicylic acid at 0.5 to 2 percent with no leave-on or rinse-off distinction anywhere in the section. A 2 percent leave-on liquid clears the same monograph as a 0.5 percent foaming wash, and neither one needs a pre-market review from a regulator before it ships.

That gap isn't down to weaker science on the US side. The AAD's 2024 acne guideline says: "For patients with acne, we conditionally recommend salicylic acid. ( C, L )." Benzoyl peroxide and topical retinoids both get a strong recommendation on moderate-certainty evidence in that same 2024 guideline.

What to Check on Your Own Bottle

Whether a given toner works on your own skin stays an open question. The guideline's own phrase, "conditional recommendation, low-certainty evidence," is roughly as far as the current science goes toward settling that.

What Korean law settles is narrower. Flip the box. A Korean cleanser carrying 제2조's exact certified wording, plus a rinse-off instruction, is the certified product. A leave-on toner or serum that only reaches "acne-prone skin," or skips the word entirely, is following the same 2017 rule to the letter.

The two Korean phrases from earlier are the actual test. Concentration on the front label isn't. "완화하는데 도움을 준다" (relieves) only appears where a rinse-off product earned the certification described above. "사용에 적합" (suitable for use) is the phrase available to everything else, toners included, and it stays weaker by design.

So the next time a leave-on BHA product's English marketing leans hard on the word "acne," check the same brand's Korean packaging. Does it carry the certified phrase, and does it still say to rinse the product off?

---

This is a running series, not a one-off post — a new post goes up every day, at around 1am Korea time.

About · Contact · Privacy Policy

Read next: Korea's Retinol Shortcut, and the Retinal Trials · How Korea Defines a Niacinamide Whitening Serum (2-5%) · Why Korean Sunscreen Isn't FDA-Approved in 2026

You might also like: How to Read the Date on Korean Food Packages After the 2023 Law Change (Korean Table)