Check the 'not a medicine' statement on hair loss and acne functional cosmetic boxes

What counts as a functional cosmetic?

According to Easy Law, a cosmetic sold with a functional label must undergo Ministry of Food and Drug Safety review or a report for each product. The Enforcement Rule of the Cosmetics Act sets 11 functional categories, which group by purpose as follows.

Article 19 of the Enforcement Rule requires the "not a medicine" statement only for items 8 to 11 of Article 2, the four categories in the last row. The skin barrier category used to refer to dryness from atopic skin; a 2020 amendment changed it to the current wording.

Where should the "not a medicine" statement appear on the box?

Since the November 2017 amendment to the Enforcement Rule, it must appear directly below the words "functional cosmetic", in letters no smaller than those words. Easy Law's labeling guide describes the same position and size.

So when you choose a hair loss, acne, skin barrier or stretch mark product, first check that the "functional cosmetic" mark and this statement sit together. Whitening or wrinkle products without the statement are not breaking the labeling rule.

Why do acne functional products seem to be only cleansers?

Item 9 of Article 2 limits the acne-prone skin category to body cleansing products. Only cleansing products such as foam cleansers and cleansing gels fall into this category.

If you see "acne functional" on a toner, serum or cream box, reread the "functional cosmetic" mark and the efficacy section. Its actual functional category may be something else, such as whitening or wrinkle improvement.

In what order should you check the box?

When you pick up a box in a shop, check it in this order.

1. Find the words "functional cosmetic" on the front or back of the box.
2. For hair loss, acne, skin barrier or stretch mark products, check that "not a medicine for preventing or treating disease" appears directly below them.
3. Read the efficacy section to see which function was reviewed or reported. Article 19 requires this item on functional cosmetic packaging.
4. Check the directions section for how and how often to apply or rinse off the product.

If the efficacy section is blank or differs from the advertising, photograph the box and ask the responsible seller which function was reviewed or reported. Save the answer with the product name and batch code so you can find it quickly when you buy the same product again.