Mineral vs Chemical Sunscreen: Filters, Limits and Rules

Mineral and chemical sunscreens differ in their UV filters. Mineral (physical) sunscreens use zinc oxide, titanium dioxide or both; chemical sunscreens use organic filters such as ethylhexyl methoxycinnamate (octinoxate), homosalate or octocrylene; hybrids combine the two.

For an importer, the bigger difference is regulatory: each market classifies sunscreen differently and keeps its own list of permitted filters and maximum concentrations, so a Korean formula is not automatically legal everywhere.

Mineral vs chemical sunscreen compared

Swipe sideways to see the whole table.

Korean limits are from the Korea Cosmetic Association dictionary’s domestic regulation data (zinc oxide, titanium dioxide, ethylhexyl methoxycinnamate, homosalate, octocrylene).

EU limits are from CosIng Annex VI entries (zinc oxide VI/30¹, titanium dioxide VI/27², ethylhexyl methoxycinnamate VI/12³, homosalate VI/3⁴, octocrylene VI/10⁵). Rules change, so recheck the current texts when reviewing a formula.

“Reflect versus absorb” is only half right

Sunscreens are often explained as mineral reflects, chemical absorbs. The American Academy of Dermatology’s sunscreen guidance says both types form a protective layer that absorbs UV rays, and physical (mineral) sunscreens also reflect them. Training material for store staff should not claim mineral filters only reflect.

The AAD also explains how to tell them apart: titanium dioxide or zinc oxide in the Active Ingredients means physical; neither means chemical; a mix means hybrid. It notes that some sunscreens leave a white residue and that tinted sunscreens matched to skin tone can avoid it.

Korea: sunscreens are functional cosmetics

Korea’s Cosmetics Act Enforcement Rule⁶, Article 2, lists products that block or scatter UV to protect the skin as functional cosmetics. To carry that claim, a product must be reviewed or reported under Article 4 of the Cosmetics Act. The Ministry’s cosmetics safety standards notice⁷, Article 4, states that UV filters not listed in its Annex 2 may not be used: a positive list.

EU: sunscreens are cosmetics with an Annex VI positive list

In the EU, sunscreen is a cosmetic, and UV filters may only be used as listed in Annex VI of Regulation (EC) No 1223/2009⁸, within the stated limits and conditions. Nano forms of zinc oxide and titanium dioxide have their own entries (VI/30a and VI/27a) and may not be used in applications that could expose the user’s lungs by inhalation.

US: sunscreens are over-the-counter drugs

According to the FDA’s Q&A on its sunscreen regulatory actions⁹, sunscreens marketed without an approved application fall under OTC monograph M020.

In its 2021 proposed order the FDA proposed zinc oxide and titanium dioxide as GRASE, and said 12 others, including avobenzone, oxybenzone, octocrylene and homosalate, needed more data; the FDA stresses this does not mean they are unsafe.

In June 2026 it added bemotrizinol (bis-ethylhexyloxyphenol methoxyphenyl triazine) at up to 6%, as reported by the UK’s CTPA.

What importers should check

• Every filter against your market’s list and limits, even if the product is approved as a functional cosmetic in Korea. Labelling and SPF/PA rules are covered in sunscreen PA ratings and labels.
• Nano status for EU shipments, and the matching labelling.
• US plans: sunscreens are drugs there, so a Korean label cannot simply be relabelled.
• Claims: in Korea, UV protection can only be claimed within the scope of the functional review or report (Cosmetics Act, Article 13).

SEONGWOO GLOBAL is the Official Distributor of Carenology95, a Korean skincare brand created by a dermatologist and best known for its Re:Blue line with blue tansy oil and its sun care.

Related pages: Carenology95 · Brands we supply · FAQ · Contact us · Sunscreen PA rating meaning · Korean functional cosmetics · Korean skincare routine order