A 21cSt oil needs a child-resistant cap. A pump does not.
Packaging usually looks like a decision you make after the formula is signed off. In Korea one rule runs the other way: a thin hydrocarbon oil has to ship in child-resistant packaging, and the same liquid in a pump spray bottle is exempt.
In Korea the same liquid can be in or out of the child-resistant packaging rule depending on the closure. Article 18 of the Enforcement Rule covers non-emulsion liquids with 10% or more hydrocarbons and a kinematic viscosity at or below 21 centistokes (40°C), then exempts pump and trigger spray bottles and compressed spray containers. Breaching it carries up to one year in prison or a fine of up to ₩10 million.
The closure decides which rule applies
Packaging is normally picked once the formula is locked. One Korean rule inverts that order, because it defines its own scope with a formulation number. Article 18(1) of the Enforcement Rule of the Cosmetics Act lists three groups that must ship in child-resistant packaging, and the second is written as a spec sheet.
It covers non-emulsion liquids containing 10% or more hydrocarbons per individual package with a kinematic viscosity of 21 centistokes or less, measured at 40°C. A thin baby oil lands inside it. The proviso to the same paragraph then exempts single-use products, spray containers operated by a pump or trigger at the mouth of the container, and compressed spray containers such as aerosols.
So the identical liquid is in scope under a screw cap and out of scope in a pump spray bottle. A packaging choice here is a regulatory choice, not a cosmetic one.
| In scope ① | Nail enamel / polish removers containing acetone |
| In scope ② | ≥10% hydrocarbons + ≤21cSt at 40°C + non-emulsion liquid |
| In scope ③ | Liquids containing ≥5% methyl salicylate |
| Exempt | Single-use / pump or trigger spray / compressed spray (aerosol) |
| Test | Openable by an adult, not by a child under five (Act Art. 2(4)) |
| Penalty | Up to 1 year in prison or a fine up to ₩10 million (Act Art. 37) |
21 centistokes is a formulation figure, not a packaging one
The measurement sits at 40°C, not room temperature. An oil that feels substantial in the hand thins out considerably by 40°C, so judging by feel will mislead you. There is a single threshold, which makes it cheap to measure early and expensive to discover late.
Three conditions have to hold at once for the rule to bite: the hydrocarbon content, the viscosity, and not being an emulsion. Break any one of them and the duty disappears. That gives a planner four levers rather than one — drop hydrocarbons below 10%, lift viscosity above 21cSt, emulsify the base, or move to a pump spray bottle.
Each lever costs something. Child-resistant packaging adds tooling and testing; reformulating changes the skin feel; a pump raises the unit cost. Putting those four side by side is what the product planner is for.
The Act itself does not define how resistant is resistant enough. Article 18(2) of the Enforcement Rule delegates the criteria and test method to the Safety Standard for Child-Resistant Packaging of Consumer Products, so a packaging supplier's certificate needs to be written against that standard. Export-only goods can follow the importing country's rules instead under Article 30 — which moves the obligation rather than removing it.
Four lines stay on the primary container
This is where print-area decisions slip. Article 10(2) of the Cosmetics Act requires four items on the primary pack even when a secondary pack is added: the product name, the business operator's trade name, the batch number, and the expiry date or period-after-opening.
The exclusion is narrow — only cosmetics such as bar soap, where the consumer removes the primary packaging before use. A glass dropper bottle or a 15ml mini tube keeps all four lines.
Small fills get a separate allowance under Article 10(1), which permits a reduced set: name, trade name, price, batch number, and expiry date or period-after-opening. One condition travels with it. Where the period-after-opening is used, the date of manufacture has to be shown alongside it. Nothing vanishes at small volumes; the list shortens and a manufacturing date moves in.
Run the empty-space maths before drawing the carton
After the bottle comes the box. Annex 1 of the Rule on Standards for Packaging Materials and Methods splits single cosmetic products in two. Body and hair cleansing products are capped at 15% empty space, other cosmetics — air fresheners included, fragrance excluded — at 10%. Both are limited to two layers of packaging.
View as table
| Single-use shipping pack | 50.0% |
|---|---|
| Gift set | 25.0% |
| Cleansing single product | 15.0% |
| Other cosmetics | 10.0% |
Gift sets loosen the number. Cosmetics appear in a combined-product row alongside everything from fresh food to underwear, capped at 25% and two layers. A product that has to hit 10% on its own gets two and a half times the headroom once it is boxed as a set. Note 4 of the same annex keeps each constituent unit compliant with its own standard, while excluding the unit's ratio and layer count from the set's figures.
Two further notes are worth knowing. Note 7 excludes transparent film applied outside the secondary pack to protect cosmetic contents from the layer count altogether. Note 11 sets single-use consumer shipping packs at 50% and one layer, then waives the empty-space standard where the sum of width, depth and height is 50cm or less. The waiver covers the ratio only — the one-layer cap stays.
| Packaging | Empty space | Layers |
|---|---|---|
| Single product · body and hair cleansing | ≤15% | ≤2 |
| Single product · other cosmetics (ex. fragrance) | ≤10% | ≤2 |
| Combined product (gift sets) | ≤25% | ≤2 |
| Consumer shipping pack, single use | ≤50% (waived if 3 dimensions sum ≤50cm) | ≤1 |
One packaging change, three files to redo
A container swap puts three documents back on the desk: whether child-resistant packaging applies, whether the four mandatory lines still fit, and what the secondary pack does to the empty-space ratio. Moving a dropper to a pump, or 50ml to 30ml, moves all three at once.
Read the other way, the same structure is a set of levers. Design a thin oil as a pump spray and the child-resistant testing drops out; take the protective film out of the layer count; keep the shipping carton's three dimensions under 50cm. Where volumes and prices currently cluster by category sits in today's ingredient signal.
In short
- Non-emulsion liquids with ≥10% hydrocarbons and ≤21cSt at 40°C need child-resistant packaging; pump, trigger and compressed spray containers are exempt.
- Three conditions must hold together, so changing any one of formula, viscosity, emulsification or closure removes the duty.
- The penalty runs to one year in prison or ₩10 million, and the detailed criteria live in the Safety Standard for Child-Resistant Packaging of Consumer Products.
- Four lines stay on the primary pack, and using period-after-opening pulls the manufacturing date in with it.
- Empty-space ceilings are 15% for cleansing products, 10% for other cosmetics and 25% for sets, all capped at two packaging layers.
*Sources: scope, exemptions, definition and penalties from the Korea Ministry of Government Legislation's Easy Law service, "Use of child-resistant packaging" (Cosmetics Act Arts. 2(4), 9(2), 30, 37; Enforcement Rule Art. 18). Primary-pack labelling and the small-volume proviso from the Korean Law Information Center, Cosmetics Act Art. 10 (in force 20 Oct 2026, Act No. 22113). Empty-space ratios, layer limits and Notes 4, 7 and 11 from the Korean Law Information Center, Rule on Standards for Packaging Materials and Methods, Annex 1 (amended 29 Apr 2022).*
Making this format as a Korean private label product
Formats like child-resistant packaging decide packaging, filling line and unit cost long before the formula does. As a Korean private label manufacturer we quote the container, the fill and the MOQ together, so you see the real price per piece on day one.
Korean cosmetics private label — cost, MOQ and timeline →
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Questions people ask
Three groups. Nail enamel and nail polish removers containing acetone; non-emulsion liquids with 10% or more hydrocarbons per individual package and a kinematic viscosity of 21 centistokes or less at 40°C; and liquids containing 5% or more methyl salicylate.
Yes. The proviso to Article 18(1) exempts single-use products, spray containers operated by a pump or trigger at the mouth of the container, and compressed spray containers including aerosols. Identical contents, different duty.
Four. Article 10(2) of the Cosmetics Act requires the product name, the business operator's trade name, the batch number, and the expiry date or period-after-opening on the primary pack even when a secondary pack is added. Only products such as bar soap, where the consumer removes the primary pack, are excluded.
15% for body and hair cleansing products and 10% for other cosmetics, with fragrance excluded and air fresheners included. Both are capped at two layers of packaging; gift sets sit at 25% and two layers.
The Safety Standard for Child-Resistant Packaging of Consumer Products. Article 18(2) of the Enforcement Rule delegates the detail there, against the statutory test that an adult can open it while a child under five cannot.