Vegan formulations and alternative ingredient trends

'Vegan' and 'not animal tested' are not the same claim

A vegan cosmetic is one that contains no animal-derived ingredients. The phrase 'and not tested on animals' usually follows — but in Korea and Europe that half of the statement is not a differentiator.

Under Article 15-2 of Korea's Cosmetics Act, distributing or selling cosmetics that have been animal tested, or that were manufactured or imported using animal-tested ingredients, has been prohibited since February 2017 (with a fine of up to KRW 1 million). Exceptions exist where no validated alternative method is available, but the rule is prohibition. The EU imposes the same ban under Regulation (EC) No 1223/2009. In other words, products legitimately sold in Korea are already, as a rule, not animal tested.

The real distinction therefore lies in ingredient origin. Cruelty-free is a claim about test methods; vegan is a claim about composition. Blending the two invites consumer confusion.

The market has grown large enough to make that distinction matter commercially. Korea's vegan cosmetics market is estimated to have grown from around KRW 570 billion in 2022 to roughly KRW 1 trillion in 2025, and the global market is projected at about USD 20.5 billion in 2026 growing at roughly 6% a year. These are private research estimates rather than government statistics, so cite the source alongside the figure.

The ingredients whose origin you cannot read off the label

On a first pass through an ingredient list, the obvious entries are beeswax (Cera Alba), lanolin, honey, propolis and royal jelly. The ones that cause problems are those whose origin cannot be inferred from the name.

Carmine (CI 75470) comes from cochineal insects, guanine from fish scales, chitosan from crustacean shells, and shellac from the secretions of the lac insect. Silk, sericin and hydrolysed silk, keratin and elastin are animal-derived as well.

Harder still are the ingredients where the same name covers different sources. Glycerin and stearic acid can be made from tallow or from plant oils such as palm and coconut, and the INCI name is identical either way, so the label alone tells you nothing. Allantoin exists in both synthetic and comfrey-derived forms, and hyaluronic acid was historically taken from rooster combs but is now produced almost universally by microbial fermentation. For all of these, origin has to be confirmed by supplier declaration.

Alternatives are a reformulation, not a substitution

Squalane is the most successful case. When it entered cosmetics in the 1950s the source was shark liver oil, and overfishing effectively pushed it out of the EU market after 2009. Today the market is split between squalane hydrogenated from olive-derived squalene and bio-squalane made by fermenting sugarcane sugar with engineered yeast via farnesene. The final molecule is identical, but supply stability and price volatility differ, and the fermentation route is often the stronger choice for formulation standardisation.

Waxes change sensorial properties along with chemistry. Replacing beeswax with candelilla wax gives higher hardness and stronger gloss, while sunflower and rice bran waxes are softer with different melting behaviour. A like-for-like swap at the same use level changes the hardness and payoff of a lip or balm formulation outright, so substitution has to be approached as a redesign.

The same applies to proteins. Animal collagen is replaced by recombinant collagen produced through microbial fermentation or by peptides with comparable function. The term 'plant collagen', however, is inaccurate: collagen is a protein found only in animals, so plant-derived ingredients are not collagen but separate substances that either support collagen synthesis or reproduce a similar feel.

Certification — all private standards, and they differ

Korea has no national standard or government certification for vegan cosmetics. There is, however, one public mechanism on the labelling side. Under the Regulation on Recognition of the Reliability of Certification and Verification Bodies for Cosmetic Labelling and Advertising, the MFDS designated the Korea Agency of Vegan Certification as recognition number 1 on 30 June 2020 (MFDS Public Notice 2020-276). It remains the only body recognised under that regulation in the vegan category. This does not make the certification itself a government certification — it means the body has been recognised as reliable for use in cosmetic labelling and advertising.

Differences between bodies affect schedule and cost directly. The Korea Agency of Vegan Certification assesses on three axes — no animal-derived raw materials, cross-contamination prevention, and no animal testing — combining document review and review of cross-contamination control procedures with animal DNA testing. Its certification is valid for 12 months.

The Vegan Society's Vegan Trademark in the UK requires, in addition to excluding animal-derived ingredients and animal testing, that no animal-derived substances be used in the development of genetically modified organisms. It does not accept a fixed cut-off date approach to animal testing, and requires cross-contamination to be minimised as far as reasonably practicable. V-Label, widely used across Europe, quantifies its threshold instead, requiring the finished product to contain less than 0.1% non-vegan substances, with certification valid for 36 months.

In short, assessment depth, cross-contamination tolerance, fee structure and validity period all vary. Deciding the target market and retail channel first, then fixing the certification body early in development, is what avoids paying for a second review.

From September 2026, the word 'vegan' is itself regulated

Europe's green claims rules land directly on vegan labelling. The Empowering Consumers for the Green Transition Directive (EmpCo, Directive (EU) 2024/825) becomes enforceable in member states from 27 September 2026 and bans vague terms such as 'eco-friendly', 'green' and 'climate neutral' where they are not backed by verified evidence.

The provision vegan brands should watch most closely is the one on redundant claims — presenting as a distinguishing benefit something the product could not fail to be. As noted above, animal testing is already prohibited by law in both Korea and the EU, so promoting 'not tested on animals' as a point of difference can fall squarely into that category.

One distinction is worth keeping straight. The separate Green Claims Directive proposal has been stalled since June 2025, when the Commission signalled its intention to withdraw it. What needs preparing now is not that one but EmpCo, which is already settled. Industry has asked for transition provisions covering existing stock, but as of August 2026 no grandfathering clause has been confirmed.

What development actually requires

Vegan formulation is usually decided by documentation rather than by chemistry. Every ingredient needs a vegan declaration and a no-animal-testing statement from the supplier, and ingredients with ambiguous origin — glycerin, stearic acid, tocopherol, lactic acid — need declarations that specify origin and manufacturing route.

Cross-contamination control on the production line has to be documented too. Where equipment is shared with animal-derived materials, cleaning procedures and validation records become part of the certification dossier.

On top of that come the tests that catch what substitution changes. Swapping waxes and emulsifiers destabilises both the emulsion and the preservation system, so stability testing and preservative efficacy testing have to be redesigned rather than carried over.

HBMIC reviews vegan suitability and certification criteria together at the ingredient selection stage, so that development does not have to double back once the formulation is fixed.