Why Korean Sunscreen? Korea’s Annex Lists 32 UV Filters

Ask why Korean sunscreen keeps coming up and the answers you get are usually about ingredients. People type the question already phrased, as why are Korean sunscreens better. We can answer a narrower version of it, and the narrowing is the honest part of this page.

Two governments publish documents saying which ingredients may work as UV filters. We opened both. Korea’s cosmetics notice lists 32 ingredient names in one annex, and you can count them in an afternoon.^[1] The American answer is not one annex, which turns out to be the interesting part.

What neither document contains is a ranking. Neither one says a formula built from its list outperforms a formula built from the other. We went looking for those sentences and they are not there to quote.

Korea’s list is one annex long

The document is 화장품 안전기준 등에 관한 규정, the Regulation on Cosmetic Safety Standards. UV filters are in Annex 2, under the heading 자외선 차단성분. We downloaded the ministry’s own attachment and counted the table.^[1]

Thirty-two ingredient names. Thirty of them are carbon-based. The other two are the minerals, 징크옥사이드 and 티타늄디옥사이드, and the 사용한도 column caps each at 25%. Every row carries a number in the 사용한도 column, and three of them add a condition in 비고 on top of that number: an inhalation restriction, an aerosol ban, and a nano particle-size and purity condition. 벤조페논-3, oxybenzone, puts its own condition inside the limit column instead, reading 2.4% with 5% kept for products used on the face, hands and lips.^[1]

How we counted needs saying, because the table has a trap. One entry, 4-메칠벤질리덴캠퍼, prints an extra line carrying only its second CAS number and isomer name. Read row by row, that line looks like a thirty-third ingredient. It belongs to the entry above it. Counting names gives 32; counting rows gives 33. We are reporting names.^[1]

The annex also carries a note about when a listed substance does not count. It names no ingredient and turns on a concentration threshold, and our hybrid sunscreen piece already quotes it in full and works through what it does to counting filters on a Korean listing. We are pointing you there rather than paraphrasing a sentence that is easy to widen by accident.

The American list moves by administrative order

In the United States sunscreen is a drug, not a cosmetic. That single difference reorganizes everything downstream, including where the list of permitted actives is kept and how it changes.

That list is part of an over-the-counter monograph, and monographs are amended by administrative order. On 10 June 2026 the FDA announced final order OTC000039, docket FDA-2025-N-6494, printed at 91 FR 35220. The order amends OTC Monograph M020, Sunscreen Drug Products for Over-the-Counter Human Use, to add bemotrizinol at concentrations up to 6 percent as a sunscreen active ingredient.^[3] The order’s own sentence for what that means:

“A sunscreen drug product containing bemotrizinol is generally recognized as safe and effective (GRASE) if it meets the conditions described in OTC Monograph M020 as amended by this final order.”

A proposed order came first, in December 2025, under the same monograph title.^[4] So the sequence is public and datable: proposal, then final order, then the date the order starts operating. Our piece on the effective date read the order document itself and covers when a US bottle can actually carry the filter, which is a separate date from the June announcement.

The reason this matters for the question at the top: the American list is not frozen, it is slow. One ingredient was added by the June 2026 order, and our explainer on that decision puts the interval in context. A snapshot of the American list is a snapshot of a process, and quoting a count from it without a date is how people end up arguing past each other.

Where the sixteen names in 201.327 come from

You will see “the US allows 16 filters” quoted a lot, including in places that link to 21 CFR 201.327 as proof. We read that section in full, and the number is real but the framing is off.^[2] Here is how it opens:

“The following provisions apply to sunscreen products containing aminobenzoic acid, avobenzone, cinoxate, dioxybenzone, ensulizole, homosalate, meradimate, octinoxate, octisalate, octocrylene, oxybenzone, padimate O, sulisobenzone, titanium dioxide, trolamine salicylate, or zinc oxide, alone or in combination.”

That sentence names sixteen substances, and it is doing one job: setting the scope of a labeling rule. The section that follows tells a product containing those substances what to print on itself. It is not a register of what may be sold, which is why an ingredient can join the monograph without that opening sentence changing on the same day.

The last three words repay attention. Combining filters is not a special category in that sentence; it is one of two ways the rule expects a product to be built. Our hybrid piece follows that thread.

We also ran a word search across the whole section, because the vocabulary shoppers use is not the vocabulary the rule uses. Hybrid, mineral, inorganic, organic and chemical return zero hits each. Physical returns two, and both sit inside the phrase physical examination, which belongs to a testing procedure and says nothing about filter type.^[2] Those three category names are clinical and market language. Our label-trap piece pulls apart what happens when they get translated.

One more thing we did not do: we did not cite 21 CFR Part 352. The same source returns it under the heading PART 352, SUNSCREEN DRUG PRODUCTS FOR OVER-THE-COUNTER HUMAN USE, STAYED INDEFINITELY.^[2] A stayed part is not current law, and quoting one as though it were would put a wrong foundation under everything above it.

Fifteen of the sixteen are on both lists

Counting is only half the work. We put the sixteen names from 201.327 next to the 32 in Korea’s annex and matched them one at a time, by Korean ingredient name and CAS number rather than by eye.^[1]

Fifteen of the sixteen are on Korea’s list. The one that is not is aminobenzoic acid, PABA. Korea’s annex does carry 에칠디하이드록시프로필파바, a PABA derivative, and that is a different substance, not the same one under a different name, which is exactly the sort of near-match that makes this comparison worth doing slowly.

Name in 21 CFR 201.327	On Korea’s annex as
avobenzone	부틸메톡시디벤조일메탄
cinoxate	시녹세이트
dioxybenzone	벤조페논-8(디옥시벤존)
ensulizole	페닐벤즈이미다졸설포닉애씨드
homosalate	호모살레이트
meradimate	멘틸안트라닐레이트
octinoxate	에칠헥실메톡시신나메이트
octisalate	에칠헥실살리실레이트
octocrylene	옥토크릴렌
oxybenzone	벤조페논-3(옥시벤존)
padimate O	에칠헥실디메칠파바
sulisobenzone	벤조페논-4
titanium dioxide	티타늄디옥사이드
trolamine salicylate	티이에이-살리실레이트
zinc oxide	징크옥사이드
aminobenzoic acid	not on the annex

How we matched, because this is where a comparison like this goes wrong. Korean ingredient names are transliterations, so 부틸메톡시디벤조일메탄 maps onto butyl methoxydibenzoylmethane syllable by syllable, and we read each one against the CAS No. column instead of trusting the transliteration alone. Two of our own first attempts were wrong in a way worth reporting: a substring search for 파바 matched the PABA derivative and reported PABA as present, and a search for 살리실레이트 matched octisalate before it reached 티이에이-살리실레이트. Both were caught by checking the CAS numbers. String matching over transliterated names is not a method we would ask you to trust, so the table above is the matched-and-checked version.

The seventeen on Korea’s list only

Thirty-two minus the fifteen shared names leaves seventeen, and this is where the answer to the question at the top is. Grouped roughly, with limits from the 사용한도 column:^[1]

• Broad-spectrum triazines and benzotriazoles: 비스에칠헥실옥시페놀메톡시페닐트리아진 10% · 메칠렌비스-벤조트리아졸릴테트라메칠부틸페놀 10% · 에칠헥실트리아존 5% · 디에칠헥실부타미도트리아존 10% · 페닐렌 비스-디페닐트리아진 5% · 트리스-바이페닐 트라이아진 10%
• UVA-focused: 디에칠아미노하이드록시벤조일헥실벤조에이트 10% · 테레프탈릴리덴디캠퍼설포닉애씨드 및 그 염류 산으로서 10% · 드로메트리졸트리실록산 15% · 드로메트리졸 1.0% · 메톡시프로필아미노사이클로헥세닐리덴에톡시에틸사이아노아세테이트 3%
• Others: 폴리실리콘-15(디메치코디에칠벤잘말로네이트) 10% · 4-메칠벤질리덴캠퍼 4% · 이소아밀-p-메톡시신나메이트 10% · 디소듐페닐디벤즈이미다졸테트라설포네이트 산으로서 10% · 디갈로일트리올리에이트 5% · 에칠디하이드록시프로필파바 5%

Two of these print the limit as 산으로서 followed by a percentage, which caps the acid form. Read the grouping as ours, not the annex’s. The notice presents one flat table in Korean alphabetical order and does not sort by what a filter covers, so the headings above are our reading while the limits are the annex’s.

The first group is the concrete version of every “Korean sunscreens use better filters” claim you have read. Two of those names are the pair our Tinosorb S versus M piece takes apart, and one of them joined the American monograph in 2026 while the rest did not.^[3]

Two documents doing two different jobs

The overlap explains something the raw counts hide. Both lists carry the same two minerals, 징크옥사이드 and 티타늄디옥사이드, and Korea caps each at 25%.^[1][2] So the mineral end of the shelf is common ground, and the seventeen names above are where the two systems part.

The rest of the difference is structural rather than chemical, and the table sets it out.

	Korea, cosmetics notice	United States
Where the permitted list is kept	Annex 2 of one notice[1]	an OTC monograph, amended by order[3]
Ingredient names we counted	32, of which 15 also appear in 201.327[1]	We did not count the monograph; see note
Minerals on the list	zinc oxide, titanium dioxide	zinc oxide, titanium dioxide[2]
Mineral cap in the 사용한도 column	25% each[1]	not set in the labeling section
Product category	cosmetic	over-the-counter drug[3]
Uses the words mineral / chemical / hybrid	no	no, in the labeling section[2]

The note the table needs: we counted Korea’s annex ourselves and we did not count the monograph. Counting M020 properly means reading the monograph as amended, and the June 2026 order is one amendment among others we have not read. So the row is blank rather than filled with a number we would be guessing at. If you want the comparison at filter-by-filter resolution, our filter explainer is the page for it.

There is a second structural difference worth knowing about, because it changes what you can learn from a bottle. Because a US sunscreen is a drug, its label carries a Drug Facts panel with an Active ingredient heading, and unless an applicable monograph or approved application provides otherwise, a topical must state the proportion of each active ingredient rather than a quantity per dose.^[5] A Korean sunscreen is a cosmetic and carries no such panel. Comparing the two systems by reading two bottles therefore does not work, and that is why we compared the documents instead.

Europe: three attempts, no readable text

Europe writes its own rules, which we did not open. We tried three addresses on 30 July 2026 and none of them returned readable text to us: the consolidated regulation returned an empty body, the ingredient database’s programmatic endpoint returned a not-found error, and the annex search page returned a document containing none of the terms we were looking for.^[6]

So Europe is absent from the table instead of summarized from memory. We are saying that out loud because a three-column table would have been easy to write and impossible for you to check against what we actually read.

One correction we owe our own archive. Our Korea versus Europe piece is built around a filter it describes as European-only, and the annex we counted for this page lists that substance: 메톡시프로필아미노사이클로헥세닐리덴에톡시에틸사이아노아세테이트, CAS 1419401-88-9, at a limit of 3%, with a note barring products that could expose the lungs through inhalation.^[1] Read that narrowly. It means the substance appears on Korea’s list, not that any Korean bottle contains it, and patents and licensing sit between a permitted list and a shelf. We would rather flag the conflict here than let two of our own pages disagree quietly. The Japan piece covers Japan on its own terms.

A bottle you can check yourself

For a test you can run in a shop, the American Academy of Dermatology gives one sentence: any of these sunscreens can protect you “if you select one that is broad spectrum, water resistant, and has an SPF 30 or higher.”^[7] Nationality is not in that sentence. The academy does add one group-specific line, and it is worth quoting whole rather than in halves: “Dermatologists recommend physical sunscreens, also called mineral sunscreens, for people with sensitive skin.” The closing phrase is part of that sentence, not a general ranking.^[7]

Which leaves the thing you can verify without a regulator. Turn the bottle over. If a filter printed on it appears in Korea’s annex, you know it is permitted there and at what limit. If you are holding an American drugstore bottle, the Drug Facts panel prints the actives and their proportions for you. Either way you are reading a product, not a passport.

One caution before you treat any number on a bottle as settled, including the ones on this page: printed SPF is a test result, and test results move between labs. Our piece on Korean SPF labels is the one to read on that, and it is the reason we describe lists and not performance here.

Where to go next on this site. The main guide is the general introduction and covers SPF, PA and how to choose by skin type. The filter explainer goes ingredient by ingredient. This page is the narrow one: what the two rulebooks are, and what each kind of document can and cannot tell you.

FAQ

Are Korean sunscreens better than American ones?

We cannot show that from primary documents, and we looked for the sentence. What the documents show is where each permitted list lives and how it changes. Korea’s notice lists 32 UV filter ingredients in one annex. The American list belongs to an OTC monograph amended by administrative order. Neither document ranks formulas or countries.

Does the US really allow only 16 UV filters?

The sixteen names come from the opening sentence of 21 CFR 201.327, and that sentence sets the scope of a labeling rule rather than tallying what may be sold. The permitted actives belong to OTC Monograph M020, which is amended by order; one such order added bemotrizinol at up to 6 percent in June 2026.

How much do the two lists actually overlap?

Fifteen of the sixteen substances named in 21 CFR 201.327 appear on Korea’s annex. The one that does not is aminobenzoic acid, PABA. That leaves seventeen names on Korea’s list only, and most of the modern broad-spectrum filters people associate with Korean sunscreen are in that group.

Do Korea and the US allow the same mineral filters?

Zinc oxide and titanium dioxide are the two minerals in Korea’s annex, capped at 25% each, and both appear in the opening list of 201.327 as well.

Does the US labeling rule call sunscreens mineral, chemical or hybrid?

No. Those three words return zero hits in 21 CFR 201.327. The word physical appears twice and both times inside the phrase physical examination, which belongs to a testing procedure.

What about European sunscreens?

We did not open the EU regulation for this page, so Europe is not in the comparison. Our Korea versus Europe piece is where that comparison lives.

Sources

Korea:
[1] 화장품 안전기준 등에 관한 규정, Ministry of Food and Drug Safety Notice No. 2026-19, in force 2026-03-18. Read on 2026-07-30 from the ministry’s notice board, board segment m_211, notice seq 14956, first attachment, an HWPX file of 555,463 bytes. A note on the address, because it bites: the board segment is part of the path rather than a query parameter, and requesting the same seq under a different board segment returns an unrelated notice. The UV filter table is Annex 2 under the heading 자외선 차단성분, parsed from Contents/section0.xml as table rows rather than from the PDF, because the PDF extractors available to us either drop Korean text entirely or drop the spaces inside Korean ingredient names. Table headers read 원료명, 사용한도, 비고, CAS No., 화학물질명. Counted by hand on 2026-07-30: 34 rows including the header, one of which carries only a CAS number and isomer name belonging to the 4-메칠벤질리덴캠퍼 entry above it, leaving 32 ingredient names. Limits quoted above are read from the 사용한도 and 비고 columns; two of them read 산으로서 followed by a percentage, which caps the acid form. One 원료명 cell carries a trailing (신설) marker, meaning newly added, and it is the only row in the table that does; we quote the ingredient name without that marker because it labels the amendment rather than the substance. The discolouration note is under 유의사항 on the same annex. link

United States:
[2] 21 CFR 201.327, Over-the-counter sunscreen drug products; required labeling based on effectiveness testing. Retrieved as XML from the eCFR versioner API at the 2026-07-27 issue date and read on 2026-07-30; the most recent issue date the API offered for title 21 at that moment was 2026-07-28. The opening sentence is quoted in full above. Word search over the extracted text of the whole section, 31,013 characters: hybrid, mineral, inorganic, organic and chemical return zero hits each; physical returns two, both inside the phrase physical examination; combination returns two; titanium and zinc return one each, inside the opening list. This is a search of one US labeling rule and is not evidence about any other jurisdiction’s documents. We did not cite 21 CFR Part 352, because the same source returns it under the heading PART 352, SUNSCREEN DRUG PRODUCTS FOR OVER-THE-COUNTER HUMAN USE, STAYED INDEFINITELY. link
[3] Amending Over-the-Counter Monograph M020: Sunscreen Drug Products for Over-the-Counter Human Use, and Related Information. Food and Drug Administration notice of availability, published in the Federal Register 2026-06-10, document number 2026-11578, citation 91 FR 35220, docket FDA-2025-N-6494, announcing final administrative order OTC000039. Read on 2026-07-30 from the Federal Register full text. The order amends OTC Monograph M020 to add bemotrizinol at concentrations up to 6 percent as a sunscreen active ingredient, and the GRASE sentence is quoted above. We read this Federal Register notice, not the 36-page order document itself; the effective date is written into the order, and our own piece on the effective date is the one that read it. link
[4] Amending Over-the-Counter Monograph M020: Sunscreen Drug Products for Over-the-Counter Human Use. Proposed order, published in the Federal Register 2025-12-12, document number 2025-22649. Cited here only to date the sequence; we did not read its contents for this page. link
[5] 21 CFR 201.66, Format and content requirements for over-the-counter (OTC) drug product labeling. Retrieved from the same eCFR API and read on 2026-07-30. Paragraph (a) states that the section “sets forth the content and format requirements for the labeling of all OTC drug products”. Paragraph (c)(1) makes the title Drug Facts, and paragraph (c)(2) requires an Active ingredient heading followed by the established name of each active ingredient, and provides that unless otherwise provided in an applicable OTC drug monograph or approved drug application, products marketed without discrete dosage units, topicals among them, shall state the proportion rather than the quantity of each active ingredient. link

What we could not read:
[6] The EU cosmetic regulation and its UV filter annex. Three attempts on 2026-07-30, none of which returned readable text to us: the consolidated regulation at eur-lex.europa.eu returned HTTP 202 with an empty body; the CosIng ingredient endpoint returned HTTP 404; the CosIng annex search page returned a document containing none of the terms we were searching for, which is consistent with a page that builds its table after loading. We are recording the attempts and not a conclusion, because “we could not open it” and “it does not say that” are different statements and only the first one is ours.

The practical test:
[7] Sunscreen FAQs, American Academy of Dermatology, read on 2026-07-30. The address aad.org/public/everyday-care/sun-protection/shade-clothing-sunscreen/sunscreen-faqs returns HTTP 302 to aad.org/media/stats-sunscreen, which is the page quoted here. Both quotations come from the section headed “What is the difference between chemical and physical sunscreens?”. The sensitive-skin recommendation is quoted with its qualifier intact; the page states it about that group rather than as a general ranking. link

Topics: Bemotrizinol · Hybrid Filters · Regulation & Labels · All topics