For food products labeled in multiple languages, is it permissible not to have the product name in Korean on the main display?

[Regulatory Case Study] For food products labeled in multiple languages, is it permissible not to have the product name in Korean on the main display?

Case Explanation
In the case of imported food products, if one wishes to display only the English brand name and product name on the main display (front view) to make it appear as a foreign product, while only including the Korean labeling information required by domestic regulations on the information display (back or side), is this permissible according to domestic regulations?

 

Relevant Regulations
According to Korean food regulations, the following food labeling standards require the Korean product name, quantity, and caloric content to be displayed on the main display (front view).

1. According to the Food Labeling Standards Notification [Notification No. 2025-27, 2025.04.21] - II. Common Labeling Standards - 1. Labeling Method - 1), the main display must include the product name, quantity, and caloric content corresponding to the quantity (note that the caloric content should be indicated in parentheses following the quantity, applicable only to foods subject to nutritional labeling as per Article 6 and related Annex 4). However, if items other than the product name, quantity, and corresponding caloric content are displayed on the main display, those items may be omitted from the information display.

Additionally, it is important to consider that the main display and information display may be applied differently based on the product's container and packaging form.

1. Food Labeling Standards Notification [Notification No. 2025-27, 2025.04.21] - [Figure 1] Distinction between Main Display and Information Display of Containers and Packaging.
   
   

 

Judgment Criteria
When considering imported food products simply from overseas countries (such as the US, Europe, etc.), if a product label is displayed in English (both front and back), once the product arrives in Korea, the importer attaches a Korean sticker (which includes all domestic legal Korean labeling details) to the back of the product in the bonded area, and then proceeds with import customs declaration.

 

However, during the product label development stage, there may be instances where a multilingual labeled product is created for use in multiple countries. For example, if a product sold in the US is also intended for sale in Asian countries (such as Korea, Japan, China), even though it is the same formula, the front display (main display) may only show the English brand name, product name, and volume, while the information display (back) includes the legal labeling requirements of each country in English, Korean, Japanese, and Chinese. In such cases, is it permissible not to display the product name, quantity, and caloric content in Korean on the main display according to domestic regulations? The domestic labeling guidelines mentioned above do not appear to include any exceptions.

1. It is advisable to take a conservative approach by suggesting and discussing internally that the Korean product name, quantity, and caloric content be displayed on the main display wherever possible. The reason is that there is no regulation in domestic law that mandates only English to be displayed on the main display.
2. However, for imported food products intended for use in various countries, the Ministry of Food and Drug Safety (referred to as 'MFDS' hereafter) has provided exceptions for imported food products through the National Complaint Center, as follows: "For products intended for import into multiple countries, the advertising phrases on the main display should be in the language of the exporting country, while the information display should include Korean and the labeling requirements of various countries printed on the product. In such cases, the details to be marked in Korean can be shown on the main display."

To date, the MFDS's position is that for imported foods with multilingual labels, only English can be displayed on the main display, while multilingual labeling is allowed on the backside. Nonetheless, it is perceived within the MFDS to be that 40-50% of the main display should include the Korean product name, quantity, and caloric content. Please be aware that it is a delicate situation to oppose practices that have been conventionally observed for imported food products for a long time.

 

Additionally, there may be ambiguous cases concerning multilingual labeling. If there is only English on the main display and only English and Korean on the back, it is unclear whether this constitutes a multilingual display and would be permitted. However, if you visit the import food section of a large supermarket, you will find many products sold with only English displayed on the main display.

 

Conclusion
If you inquire whether a multilingual labeled food product can have the Korean product name omitted from the main display, I would suggest considering the addition of the Korean product name, quantity, and caloric content wherever possible. Furthermore, I recommend obtaining a positive response from the MFDS through the National Complaint Center before importing the product, as this will facilitate resolution of any potential legal interpretations that may differ among local MFDS officials during the import process.