FDA Labeling Requirements: Can You Use Korean Packaging?

Cosmetics and food: what the label US shoppers see has to say

Brands from Korea ask us this all the time:

"Can we ship the packaging we already sell in Korea?"

"Can't we just put an English sticker on the back?"

The short answer: whether Korean packaging works depends on the label US shoppers see, not on the package itself. Every statement the rules require has to be on it, in English.

Stickers are the hard part: none of the FDA pages we reviewed approves an English sticker over Korean packaging. Below are the rules for cosmetics, food, origin marking and barcodes, and what a wrong label costs at the border.

1. FDA cosmetic labeling requirements: every required statement in English

Per FDA's summary of cosmetics labeling requirements, cosmetics sold in the US, made here or imported, must comply with the FD&C Act and the Fair Packaging and Labeling Act. Every required label statement must be in English and easy to notice and read (21 CFR 701.2).

Principal display panel (PDP)

The PDP is the panel shoppers are most likely to see on the shelf. Per FDA's summary, it must show:

The product name
What the product is or does (the statement of identity), in words or a picture
The net quantity, in the bottom area of the panel, parallel to the base

Information panel

Other panels carry company details and ingredients (FDA):

Name and place of business of the marketing company, with street address, city, state and ZIP code (21 CFR 701.12)
"Manufactured for ..." or "Distributed by ..." if the distributor is not the manufacturer
Ingredients in descending order of predominance; those at 1% or less and color additives can go in any order
Ingredient letters at least 1/16 inch high, or 1/32 inch under 12 square inches of label space (FDA)

These rules fix what each statement says and where it goes, so a line-by-line translation of your Korean label is not enough.

The US contact MoCRA added

MoCRA (the Modernization of Cosmetics Regulation Act) added one line. Under 21 U.S.C. 364e, every cosmetic label must include a domestic address, a domestic phone number, or electronic contact information (a website counts) where the responsible person can receive adverse event reports.

The responsible person is the manufacturer, packer or distributor named on the label. Per FDA's registration and listing page, that party lists each product and its ingredients with FDA and updates the listing every year. So the name on your label is not a design choice. It decides who carries the MoCRA duties. More in MoCRA: what foreign cosmetic brands need to prepare.

2. Can you put an English sticker on Korean packaging?

FDA guidance does not give a clear yes, for two reasons.

First, the foreign language rule. FDA's Cosmetics Labeling Guide says that if a label contains any foreign language, all required statements must also appear in that language. If Korean text stays visible, check whether the US required statements must also appear in Korean. Check food packages the same way.

Second, what the sticker covers. FDA's summary says the cosmetic ingredient list may appear on a firmly affixed tag, tape or card. That is about the ingredient list only. It is not permission to sticker over the PDP.

If you are considering a sticker, check at least:

Does it carry every required PDP and information panel statement?
Does it leave the country of origin marking visible?
Does the remaining Korean text require Korean versions of those statements?
Has your customs broker or FDA counsel confirmed it?

Do not decide on stickers alone. Confirm them with an expert before you print.

3. Net quantity: US units first, metric optional

Most Korean packages show net quantity in grams or milliliters only. US rules start from US units.

Cosmetics: FDA's summary says net quantity "may additionally be stated" in metric units. At one pound or one pint or more, it must be expressed in ounces, followed in parentheses by the largest whole units.
Food: 21 CFR 101.7 says statements of weight shall be in avoirdupois pounds and ounces. A metric statement may also appear on the PDP or other panels.
Food placement: the same rule puts net quantity in the bottom 30% of the PDP, in type at least 1/8 inch high when the PDP is more than 5 and up to 25 square inches (21 CFR 101.7).

If your Korean package shows only g or mL, plan to add US units.

4. FDA labeling requirements for food: Nutrition Facts and allergens

For food, the biggest job is Nutrition Facts. FDA's Nutrition Facts page says foods imported to the United States must meet the final requirements. The compliance dates have passed: January 1, 2020, for manufacturers with $10 million or more in annual sales, and January 1, 2021, for smaller ones.

A translated Korean nutrition table is not this format. Plan to build the US panel from scratch.

Check allergens too. Under the FASTER Act, sesame has been the ninth major food allergen since January 1, 2023, and must be labeled on packaged foods. A sauce with sesame oil, for example, needs a sesame allergen statement.

Food also needs FDA facility registration and FSVP. See FSVP and FDA food facility registration: who does what.

5. Cosmetics vs food: what must be on the label

Here are the main FDA labeling requirements side by side, as of October 2026.

Item	Cosmetics	Food	Source
PDP	Name, what it is, net quantity	Net quantity in bottom 30%	FDA, 21 CFR 101.7
Units	US units; metric optional	Pounds and ounces; metric optional	Same
Type size	Ingredients 1/16 inch (1/32 under 12 sq in)	Net quantity 1/8 inch (PDP 5 to 25 sq in)	Same
Ingredients, allergens	Descending order	Nine major allergens; sesame since Jan 1, 2023	FDA, FDA
Nutrition	Not required	Nutrition Facts, imports included	FDA
MoCRA contact	US address, phone or electronic	Not applicable	21 U.S.C. 364e
Country of origin	English country name	English country name	CBP
Korean packaging as is	Only with all required statements in English	Only with FDA-format Nutrition Facts and allergens	Section 2

To use Korean packaging as is, every item in this table must already be on it, in English and in the right place.

6. Country of origin marking: do you need a "Made in Korea" label?

You need the English country name, but not always the words "made in". CBP's marking guide says every foreign article entering the US must be legibly marked with the English name of its country of origin, unless an exception applies, so a Korean-only origin line does not qualify. "Made in" is needed only when another place name on the article or container could mislead the buyer, for example a product name with Paris in it.

On stickers for origin marking:

CBP allows labels in some cases but does not recommend them; if one comes loose, the importer may pay to re-mark (CBP).
19 CFR 134.44 requires stickers in a conspicuous place, attached securely enough to stay on until the product reaches the ultimate purchaser.
Unmarked goods face additional duties unless marked, exported or destroyed under CBP supervision before liquidation (CBP).
Covering or removing the marking to conceal the origin can bring criminal penalties (same page).

Before you print any sticker, check that it does not cover the country of origin.

7. Barcodes: set them with the label, by sales channel

Barcodes sit outside the FDA and CBP rules, but settle them before the label design is final. GS1 US prices as of October 2026:

One GTIN (the number behind a UPC barcode): $30, paid once, no annual renewal fee
Company prefix for 10 barcodes: $250 initial fee, $50 a year
Company prefix for 100 barcodes: $750 initial fee, $150 a year
Every variation (size, color, pack) needs its own barcode

For example, one cream sold in 50 mL and 100 mL needs two barcodes. GS1 says prices can change. Amazon has its own barcode rules, so check Seller Central.

Fix your SKU list, then assign barcodes and print labels together.

8. California Prop 65: who needs to care?

If you sell in California, add Prop 65 to your label review. Per OEHHA's guide for small businesses, businesses with fewer than 10 employees are exempt by law.

The same guide gives a retailer five business days after a 60-day notice to correct the alleged violation, so retailers may ask about warnings even if your brand is exempt. For warning wording, check OEHHA's current rules with an advisor.

Check your headcount and what your retailers ask for.

9. What happens at the border when the label is wrong?

If FDA refuses a shipment, you have 90 days from the Notice of FDA Action to destroy or export it under CBP and FDA supervision (FDA).

FDA has no authority to extend the 90 days, and a refusal is a final decision.
One FDA example: labeling deficiencies remained after a second attempt to fix them.
After 90 days, CBP may assess liquidated damages against the bond (same page).
FDA's cosmetics summary also says misbranded foreign cosmetics may be refused entry.

Finish the label review before you print, not after the goods reach customs. On importer of record, brokers and bonds, see Importer of Record and US customs: what do you need?

Five checks before you print

1. Does the PDP show the name, what it is, and net quantity in US units, in English?

2. Are the company address and ingredients (for food, Nutrition Facts and allergens) in English?

3. For cosmetics, is the MoCRA contact there, and is the named company your real responsible person?

4. Is the country of origin in English, and left uncovered?

5. If Korean text stays or you use stickers, has an expert confirmed it?

Wrap-up

Cosmetics need the PDP, information panel and MoCRA contact set to US rules. Food needs Nutrition Facts and allergens. Origin goes on in English, and barcodes come with the label.

LinkONE supports import compliance from its warehouse in Fullerton, California, including English cosmetic and food labels, Nutrition Facts panels, MoCRA registration and relabeling.

In the end, the starting point for your US label is not your Korean package. It is the panel a US shopper sees.

Frequently Asked Questions

Do US cosmetic labels have to be in English?

Yes. Every statement required by regulation must be in English (FDA, 21 CFR 701.2). If the label also has Korean or another language, FDA's Cosmetics Labeling Guide says all required statements must appear in that language too. Check with FDA counsel before you keep Korean text on the package.

Can I put an English sticker on Korean packaging?

As of October 2026, no FDA page we reviewed approves an English sticker over Korean packaging, so confirm the approach with your customs broker or FDA counsel before you print. For country of origin marking only, 19 CFR 134.44 sets sticker conditions: a conspicuous place, attached securely enough to stay on until the product reaches the buyer. CBP also says labels are not a recommended form of marking.

How are ingredients required to be listed on the label?

On a cosmetic label, ingredients go in descending order of predominance, and ingredients at 1% or less and color additives can go in any order (FDA). The letters must be at least 1/16 inch high, or 1/32 inch on packages with less than 12 square inches of label space. On food, sesame has been one of the nine major allergens to label since January 1, 2023 (FDA).

Do I need a "Made in Korea" label?

You need the English name of the country of origin, but the words "made in" are required only when another place name on the product could mislead the buyer (CBP). Unmarked goods face additional duties unless they are marked, exported or destroyed before liquidation. Make sure no sticker covers the marking.

Do imported foods need a US Nutrition Facts label?

Yes. FDA says foods imported to the United States must meet the final Nutrition Facts requirements (FDA). The compliance dates were January 1, 2020, for manufacturers with $10 million or more in annual sales, and January 1, 2021, for smaller ones. Net weight goes in pounds and ounces, and a metric statement may also appear (21 CFR 101.7).

Sources

Fees and rules in this post are as of October 2026.

-LinkONE-