Korea's retinyl palmitate cap is the EU 0.3% line
Retinoid quotes arrive with mixed units. One line is in IU/g, the next in percent, and nothing lines up. Converted to a retinol basis, Korea's two listed caps are 0.075% and 0.3% — a fourfold gap hiding behind the unit.
Korea's listed wrinkle-care caps are 2,500 IU/g for retinol and 10,000 IU/g for retinyl palmitate. On a retinol basis those are 0.075% and 0.3%, so the palmitate cap lands exactly on the EU face limit of 0.3% RE. Retinal appears on neither list — not in Korea's four listed ingredients, not in EU Annex III entry 376.
The same retinoid family, quoted in different units
Open a retinoid quote and the units shift line by line. Retinol comes in IU/g, retinal in percent, retinyl palmitate back in IU/g. The bigger number looks like the stronger formula, but with the units mismatched that comparison does not hold.
IU measures vitamin A activity. One IU equals 0.3 µg of retinol, so retinol at 2,500 IU/g is 750 µg/g — 0.075%. Retinyl palmitate is a heavier ester: one IU corresponds to 0.55 µg of the raw material, which puts 10,000 IU/g at 0.55% by ingredient weight.
To place those two lines side by side you have to restate both on a retinol basis. Converted that way, 10,000 IU/g becomes 3,000 µg/g, or 0.3%. Korea's two listed caps are four times apart once the unit stops hiding it.
Korea opens four doors, and retinal is not one of them
The data-waiver route for a wrinkle-care claim lives in Annex 4 of the Regulation on the Review of Functional Cosmetics, and it runs to four lines: retinol at 2,500 IU/g, retinyl palmitate at 10,000 IU/g, adenosine at 0.04%, and polyethoxylated retinamide at 0.05–0.2%.
| Ingredient | Korean listed level | On a retinol basis | Note |
|---|---|---|---|
| Retinol | 2,500 IU/g | 0.075% | Vitamin A alcohol |
| Retinyl palmitate | 10,000 IU/g | 0.3% | 0.55% by ingredient weight |
| Adenosine | 0.04% | n/a | Not a vitamin A compound |
| Polyethoxylated retinamide | 0.05–0.2% | n/a | Retinoid derivative |
| Retinal | Not listed | — | Needs its own study |
Retinal's absence from that annex is widely misread. It is not prohibited. What it loses is the shortcut: to put wrinkle care on the label, the brand owes an efficacy study and a review. So when a proposal reads "retinal 0.1%, wrinkle care," the question to ask is not the report number but whether a study exists.
The EU line falls on the palmitate cap
Regulation (EU) 2024/996 added vitamin A to Annex III as entry 376. The ceilings are expressed as retinol equivalent: 0,05% RE in body lotion and 0,3% RE in other leave-on and rinse-off products. Three substances — retinol, retinyl acetate and retinyl palmitate — are counted together rather than each against its own allowance.
That is where Korea's cap runs into the wall. Retinyl palmitate at 10,000 IU/g converts to 0.3% RE, which is the face limit precisely. Add any further vitamin A material and the combined total clears the line.
Body products have no room at all. At 0.05% RE — roughly 1,667 IU/g — a formula built to the Korean ceiling comes in at six times the EU body-lotion limit. A legitimate Korean report number tells a buyer nothing about EU compliance here.
| Product type | EU limit (retinol equivalent) | In IU/g | Against Korea's cap |
|---|---|---|---|
| Face, other leave-on, rinse-off | 0.3% | about 10,000 IU/g | Identical to the palmitate cap |
| Body lotion | 0.05% | about 1,667 IU/g | One sixth of it |
The label moves too. Products caught by entry 376 must state "Contains Vitamin A. Consider your daily intake before use." Non-compliant products have been barred from being placed on the EU market since 1 November 2025, and the deadline for clearing stock already held downstream is 1 May 2027.
Retinal is missing from the EU list as well
Entry 376 names three substances: retinol, retinyl acetate and retinyl palmitate. Retinal is not among them. Some industry guidance nonetheless tells formulators to sum every vitamin A derivative, so for EU-bound volume it is worth getting the Responsible Person to confirm the scope of that calculation in writing.
Put the two markets together and retinal occupies an odd position: no functional route in Korea, no name on the EU ceiling. A gap in the rules sounds like an advantage, and in practice it means building the evidence yourself on both sides. Which materials are moving which way right now is tracked daily in today's ingredient signal.
Three questions for the quote
First, ask for one unit. A table that mixes IU/g with percent cannot be read across, and adding a retinol-equivalent column costs the supplier one line.
Second, confirm the dosage form. The waiver route covers lotions, liquids, creams and sheet masks, and fixes the claim text to "helps improve skin wrinkles." A balm or a stick falls out of the route regardless of the level.
Third, name the destination market before the formula is drawn. The same formula can clear a Korean report and fail an EU body lotion, so stating the target up front saves a second round of development. To take a direction and run it through to a quote, work it out in the product planner.
In short
- One IU of vitamin A is 0.3 µg of retinol, so 2,500 IU/g is 0.075%.
- Retinyl palmitate at 10,000 IU/g is 0.55% by weight and 0.3% on a retinol basis.
- The EU caps are 0.3% RE for face products and 0.05% RE for body lotion, summed across three substances.
- Built to the Korean ceiling, a palmitate formula is six times the EU body-lotion limit.
- Retinal is on neither list — not Korea's four ingredients, not EU entry 376.
*Sources: listed levels and dosage forms — Annex 4 of Korea's functional cosmetics review regulation, annotated, Annex 4 text summary / EU limits, warning and dates — CosIng Annex III 376 (Regulation (EU) 2024/996) / IU conversion — Conversion of Vitamin A Retinol to Vitamin A Palmitate / retinal's absence from the Korean annex — a check of the regulation text. Verified 13 October 2026.*
Questions people ask
0.075%. One IU of vitamin A equals 0.3 µg of retinol, so 2,500 IU/g works out to 750 µg/g. Any quote that mixes IU lines with percent lines needs this conversion before two formulas can be compared.
On the face, the two limits touch; on the body, it does not clear. The EU sets 0.3% retinol equivalent for leave-on and rinse-off products and 0.05% for body lotion. Retinyl palmitate at 10,000 IU/g is six times the body-lotion ceiling.
The data-waiver annex lists four ingredients — retinol, retinyl palmitate, adenosine and polyethoxylated retinamide. Retinal is not one of them. It is not a banned material, but the claim now requires an efficacy study and a review.
Products caught by entry 376 must carry "Contains Vitamin A. Consider your daily intake before use." Non-compliant products could not be placed on the EU market from 1 November 2025, and distributor stock has until 1 May 2027.