Cosmetics Manager Qualifications in Korea: Can a Company Representative Serve?

3 Key Takeaways

1. A sole proprietor or corporate representative may personally perform the duties of a Responsible Cosmetic Distribution Manager if the business has 10 or fewer regularly employed workers and the individual meets the statutory qualifications.
2. Being a company representative or operating a small business does not waive the qualification requirements. Eligibility must be established through a recognized degree, relevant professional experience, examination results, or another applicable statutory route.
3. Before registration, identify the proposed manager, review their qualifications and supporting documents, and confirm that they can actually perform the required quality-control and post-sale safety duties.

Launching a cosmetics brand in South Korea involves more than selecting an OEM manufacturer and developing a product.

Even when manufacturing is outsourced, a business that commissions cosmetics production and distributes the resulting products under its own responsibility may be required to register as a Responsible Cosmetic Distribution Business.

One important part of that registration process is determining who will serve as the Responsible Cosmetic Distribution Manager.

For a small startup, the most immediate question is often straightforward:

Can the founder or company representative serve as the manager personally, without hiring someone else?

Yes, but only when the statutory conditions are satisfied.

For example, consider a hypothetical Korean cosmetics company with three employees.

Its representative holds a bachelor's degree in business administration but has no experience in cosmetics manufacturing or quality control.

The company meets the workforce-size condition for the small-business provision. However, the representative's position and business degree alone do not establish the qualifications required to serve as the manager.

If the representative has no other recognized qualification, the company must identify another eligible person who can perform the required duties.

The practical issue is therefore not simply whether the company is small enough.

It is whether the proposed manager meets a recognized qualification route, can prove that qualification, and can actually perform the regulated management duties.

This article explains those requirements for businesses preparing to launch their own cosmetics brands through OEM manufacturing in Korea.

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1. When Can a Company Representative Serve as the Responsible Distribution Manager?

Article 3(3) of the Cosmetics Act (「화장품법」) requires a responsible cosmetic distributor to establish applicable quality-control and post-sale safety management standards and appoint a manager qualified to oversee those responsibilities.

The qualifications and duties of the manager are further addressed in Article 8 of the Enforcement Rule of the Cosmetics Act (「화장품법 시행규칙」).

The Enforcement Rule provides a special arrangement for certain small businesses.

Under Article 8(3), a person operating a Responsible Cosmetic Distribution Business with 10 or fewer regularly employed workers may personally perform the manager's duties if that person meets the qualifications specified in Article 8(1).

For a corporation, the provision refers to its representative.

Two separate conditions must therefore be satisfied.

Condition 1: The business has 10 or fewer regularly employed workers

The statutory threshold is 10 or fewer workers, not fewer than 10.

The workforce must be assessed according to the applicable legal standard.

A founder should not assume that every person associated with the startup is automatically included or excluded without examining the actual employment arrangements.

Likewise, the fact that a company initially qualifies does not mean the same arrangement can continue indefinitely if its workforce grows beyond the threshold.

Condition 2: The representative personally meets a statutory qualification

A company representative does not become a qualified manager solely by holding that position.

The representative must satisfy at least one of the qualification routes established in Article 8(1).

Consider a company with four regularly employed workers.

Its representative holds a qualifying engineering degree and intends to perform the manager's duties personally.

If the degree satisfies the statutory criteria and the other requirements are met, the representative may be eligible to undertake the role under the small-business provision.

Now consider a company with only two employees whose representative has no recognized qualification.

The smaller workforce does not eliminate the qualification requirement.

The special provision permits a qualified representative to perform the manager's duties. It does not exempt an unqualified representative from the law.

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2. Who Qualifies as a Responsible Cosmetic Distribution Manager?

Article 8(1) of the Enforcement Rule establishes several qualification routes.

An applicant does not need to satisfy every route. Meeting one applicable statutory route is sufficient, subject to the relevant evidence and individual circumstances.

1. Physicians and pharmacists

A physician recognized under Korea's Medical Service Act or a pharmacist recognized under the Pharmaceutical Affairs Act falls within a statutory qualification category.

2. A bachelor's degree or higher in a recognized field

A person who has obtained a bachelor's degree or higher in science, engineering, or another specifically recognized field may qualify.

Recognized fields include certain cosmetics-related and health-related disciplines identified in the Enforcement Rule.

Examples include cosmetic science, cosmetology-related academic fields, Korean medicine, pharmacy-related Korean medicine studies, and specified nursing disciplines.

The actual qualification depends on the legally recognized academic field and degree.

Having completed several science-related courses is not the same as holding a qualifying degree.

3. A recognized associate degree and at least one year of relevant experience

A person who has obtained an associate degree in a recognized cosmetics-related field may qualify after completing at least one year of work in cosmetics manufacturing or quality control following the award of that degree.

Both requirements matter.

The degree must fall within an eligible field, and the relevant employment must satisfy the post-degree experience condition.

Holding an associate degree alone is insufficient under this route.

4. At least two years of cosmetics manufacturing or quality-control experience

A separate qualification route exists for a person with at least two years of relevant work experience in cosmetics manufacturing or quality control.

This route is particularly important for applicants whose university degree does not satisfy the academic qualification criteria.

However, general employment in the cosmetics industry is not automatically qualifying experience.

The actual work performed must be examined.

5. Passing the Customized Cosmetics Preparation Manager examination

A person who has passed the statutory Customized Cosmetics Preparation Manager examination may qualify under the applicable provision.

This examination must not be confused with a private certificate or a general industry training course.

6. Completing a designated professional training course

The Enforcement Rule also recognizes a professional training route designated by the MFDS for specified product categories.

This is a limited route.

It should not be interpreted as allowing every cosmetics OEM entrepreneur to become a responsible distribution manager simply by completing an ordinary training course.

Certain business categories may also be subject to distinct requirements or exceptions.

Accordingly, the intended business activity must be classified before applying the qualification rules.

Source: Korean National Law Information Center, Enforcement Rule of the Cosmetics Act, Article 8.

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3. Five Practical Eligibility Scenarios for Cosmetics Startups

The following examples are hypothetical and are intended to illustrate how the statutory conditions apply.

They do not represent actual registration decisions or guaranteed outcomes.

Scenario A: An engineering graduate operating a small corporation

A Korean cosmetics company has five regularly employed workers.

Its representative holds a bachelor's degree in engineering.

If the degree is recognized under the applicable qualification criteria and the representative can actually perform the management duties, the representative may qualify under the small-business provision.

The principal documents to examine are the official degree certificate and information establishing the relevant business and workforce conditions.

Scenario B: A representative with a business administration degree

A cosmetics company has three employees.

Its representative holds a bachelor's degree in business administration and has no relevant cosmetics manufacturing or quality-control experience.

A business administration degree alone does not satisfy the listed science, engineering, or related-degree requirements.

Unless the representative qualifies through another recognized route, the company must identify a different eligible manager.

Scenario C: A business graduate with two years of quality-control experience

A company representative holds a business administration degree but previously worked in cosmetics quality control for more than two years.

Although the degree itself does not establish academic eligibility, the professional experience route may apply.

The important question is whether the individual actually performed qualifying manufacturing or quality-control duties for the required period.

Employment certificates and supporting records become central to the assessment.

Scenario D: An associate degree followed by relevant professional experience

An employee obtained an associate degree in a recognized cosmetics-related field.

After graduation, the employee worked in cosmetics quality control for one year and two months.

The associate-degree route may apply if the academic field, post-degree experience period, and actual duties satisfy the statutory conditions.

Experience gained before graduation should not automatically be counted toward the specific post-degree requirement.

Scenario E: A qualified representative of a company with 12 workers

A company's representative has an engineering degree.

However, the business has 12 regularly employed workers.

The small-business provision allowing a qualified representative to personally perform the manager's duties cannot be relied upon because the workforce threshold is exceeded.

The company must establish a manager appointment and duty-performance arrangement that satisfies the applicable requirements independently of that special provision.

These examples demonstrate that eligibility cannot be determined from a degree, job title, or workforce number in isolation.

The statutory qualification, workforce condition, and actual management arrangement must be considered together.

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4. How Does the MFDS Assess Science and Engineering Degrees?

One practical difficulty concerns university qualifications.

A founder may believe their degree belongs to a science or engineering field, but the official certificate may not clearly establish the relevant academic classification.

On March 30, 2026, the Ministry of Food and Drug Safety addressed an inquiry concerning the academic qualifications of a proposed Responsible Cosmetic Distribution Manager.

The question concerned whether the person's science or engineering background could be assessed using graduation certificates or academic records.

The MFDS explained that, in ordinary cases, the relevant assessment considers the classification shown on official graduation or degree certificates.

Examples include degrees or academic classifications corresponding to a Bachelor of Science, Bachelor of Engineering, natural sciences, or engineering.

However, the MFDS also explained that individual eligibility is determined through a comprehensive examination of the supporting documents by the competent regional MFDS office.

Source: Ministry of Food and Drug Safety, Official Interpretation on Responsible Cosmetic Distribution Manager Qualifications (March 30, 2026), Korean National Law Information Center.

Why the exact wording of the certificate matters

Consider two hypothetical graduates.

Graduate A has a degree certificate clearly identifying an engineering department and an awarded engineering bachelor's degree.

Graduate B has a certificate showing the name of a department, but the awarded degree classification is not sufficiently clear.

Graduate A has comparatively clear documentary evidence for assessing the relevant academic qualification.

Graduate B may need to obtain additional official documents from the university to clarify the nature of the degree and field.

An academic transcript may provide useful supporting information, but it does not automatically change the degree that was actually awarded.

Similarly, taking a limited number of science-related courses does not necessarily establish that the individual holds a qualifying science or engineering degree.

A practical document review sequence

1. Examine the graduation or degree certificate and identify the degree awarded.
2. Compare the stated academic field with the applicable statutory qualification categories.
3. Where the person has multiple majors, a transfer history, or an unusual degree title, review the official university records.
4. If the available documents do not resolve the qualification issue, identify what additional evidence or confirmation from the regional MFDS office may be needed.

The important point is to use the actual academic records rather than relying solely on an informal description of the university department.

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5. Does Two Years at a Cosmetics Company Count as Qualifying Experience?

Not necessarily.

The professional experience requirement refers to work in cosmetics manufacturing or quality control.

It does not automatically include every form of employment in a cosmetics-related business.

A company may employ manufacturing technicians, quality-control personnel, product planners, marketing specialists, and online sales managers.

Their experience is not legally interchangeable merely because they work for the same employer.

To illustrate the distinction, consider two hypothetical employment certificates.

Hypothetical Employment Certificate A: Quality Control

• Employment period: April 2023 to June 2025
• Department: Quality Control
• Duties: Reviewing finished-product test results, maintaining inspection records, and performing cosmetics-related quality-control work

The listed duties are relevant to the statutory manufacturing or quality-control experience requirement.

However, the certificate alone does not guarantee eligibility.

The actual duties and the period during which those duties were performed still need to be established.

Hypothetical Employment Certificate B: Brand Marketing

• Employment period: April 2023 to June 2025
• Department: Brand Management
• Duties: Product concept planning, online advertising, and sales-channel management

The employment period is the same.

However, the documented duties concern marketing and sales rather than cosmetics manufacturing or quality control.

Those activities alone do not establish the required manufacturing or quality-control experience.

What if the certificate only says "Product Development Team"?

This is a more ambiguous situation.

A product development team may handle commercial planning and brand positioning.

It may also include staff whose actual responsibilities involve manufacturing processes or product quality.

The department name does not necessarily identify the work performed.

The review should therefore examine:

• The actual tasks undertaken by the employee
• How those tasks relate to cosmetics manufacturing or quality control
• The period during which the relevant tasks were performed
• Whether the employer's records or other objective documents substantiate those duties

The purpose is not to rewrite an employment history to make an applicant appear eligible.

It is to identify whether the work actually performed satisfies a statutory qualification and whether the evidence establishes that fact.

Inventing duties, changing employment periods, or obtaining a misleading certificate is not an appropriate way to address a qualification gap.

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