16 INTERVIEW Tim Probert – Editor, Personal Care Global


Seongmin (Mike) Sohn is the general manager and principal consultant at global regulatory compliance consulting firm REACH24H Korea. Mike, who is based in Seoul, Korea, talks to editor Tim Probert about the latest cosmetic regulations, as well as K-beauty trends


Tim Probert (TP): How long have you been with REACH24H? What is your background? Mike Sohn (MS): Since 2020. My undergraduate major is biotechnology, and I studied public health for my Master’s degree.


TP: What does REACH24H do? MS:We are a consulting firm that helps companies comply with chemicals regulations, including for cosmetics. We help Korean companies, for example, to enter the US market by registering their products and complying with the regulatory issues.


TP: You have extensive experience with global cosmetics regulation. What is the overall direction of travel? MS: Many countries are increasingly utilising regulations as a sort of barrier, a trade wall. Over the past four or five years, it’s been changing quite rapidly. They have become harsher, in China, in the European Union (EU), in the US, even Korea. It seems every country is making the regulatory hurdles higher so that it is more difficult for the outside world to enter their domestic market.


TP: No more so than China, perhaps. MS: China’s new regulations are a major issue for global companies who want to enter the Chinese market. Chinese regulation is based on a


‘positive list’ system, which means the Chinese authorities created a list of approved ingredients that can be used in cosmetics. If they are not listed on the


approved cosmetics ingredient list, you cannot formulate with it – even if it’s something that has been considered safe in other countries for the past, say, five to


PERSONAL CARE November 2025


ten years. If they are not on the Inventory


of Existing Cosmetic Ingredients in China (IECIC), you have to begin a separate process called New Cosmetic Ingredient Registration. It takes a lot of time and energy, and there is no guarantee of success. Then there’s the Cosmetic


Safety Assessment Regulation, which means that every substance that’s being formulated into a finished product has to be guaranteed as safe. There are a lot of substances


that have no testing data, and if there is any substance that lacks data, even if it’s listed, then you cannot use it in China under Chinese regulations. So, it all takes extra effort, more


money, more time, more energy, more human resources, to solve these kinds of basic problems from the start of the process.


TP: Does it apply to Chinese companies as well? MS: Yes, it applies to Chinese companies. Some say it is partially an attempt to clear up some of the uncompetitive state-owned domestic companies. But, in the end, they want to


make standards higher, to make products safer, and to help their domestic companies to grow.


INTERVIEW the hurdles


TP: Can you put a time estimate on how long the process takes under the new Chinese regulation system? MS: Like I said, if your ingredient is not listed then it has to be registered separately. That takes about 18 months. Then to register a finished


product using that new ingredient will take a further six months. So, in effect, it could take at least two years – maybe two-and-a-half or three years.


TP: Complaints? MS: That it’s too harsh. So they do know it. But they still want to protect their own local industry and let them grow through the regulations.


TP: How about the US? Has MoCRA (the Modernization of Cosmetics Regulation Act of 2022) made it more difficult for foreign companies to do business in the US? MS: I think MoCRA has changed the landscape somewhat for exporting products to the US. The previous system was managed voluntarily; it was not mandatory regulation. The safety aspect of MoCRA,


www.personalcaremagazine.com Clearing


TP: Do you think the Chinese authorities realise these new regulations are so demanding on the cosmetics industry? MS: Yes, they do. They do because there have been some recent relaxation amendments of the regulations following complaints from both the global and domestic local industry.


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