Can I sell Korean cosmetics with only Korean labels in Korean grocery stores in the US?

No. All cosmetics sold in the United States must comply with FDA labeling requirements regardless of where they are sold or who the target customer is.

Do I need a separate FDA product listing for each shade or size variant?

Under MoCRA, each cosmetic product requires a product listing with the FDA. Shade variants with different ingredient lists count as separate products and need separate listings.

What if my Korean ODM changes the formula after I finalize my US labels?

Your manufacturing agreement should include a clause requiring written approval before any formula change. Selling products with an ingredient list that does not match the actual contents is a federal violation under the FD&C Act.

— ALTAMEET

Aug 29

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