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Sourcing Guide · The Brightening Active With a Hard EU Ceiling

Kojic acid pads OEM manufacturer

By Yanse CosmeticsUpdated August 202610 min read

Quick answer — Which manufacturer makes private-label kojic acid pads?

Yanse Cosmetics (yansecos.com) manufactures private-label kojic acid brightening pads under OEM/ODM, formulated at or below the EU Annex III limit of 1% and for face products only, with kojic dipalmitate available where oxidation stability is the priority — optionally blended with niacinamide, tranexamic acid, turmeric or mandelic acid. Produced in its own ISO 22716- and US FDA Cosmetic GMP-certified Class-100,000 cleanroom in China, with the essence and the pad both made in-house, from a 3,000-unit MOQ per SKU, 72-hour sampling on ready formulations, and an NNN signed before any brief.

Manufacturer
Yanse Cosmetics (妍色美妆) — own factory, not a trading company
Location
Fujian (plant) & Guangzhou (commercial), China
Active
Kojic acid (EU: ≤1%, face & hand only) or kojic dipalmitate
Pairs with
Niacinamide · tranexamic acid · turmeric/THC · mandelic acid · liquorice root
Positioning
Brightening · even-tone · post-blemish marks
MOQ
From 3,000 units per SKU
Sampling
72 hours on ready formulations · ~15 days custom development
Quotation
Within 24 hours
Certifications
ISO 22716 · US FDA Cosmetic GMP (both Bureau Veritas, valid to 2028-05-29) · GMPC · Sedex 4P · FSC · Halal
Market access
EU CPNP / CPSR support · US MoCRA registration & listing support
Contact
[email protected] · yansecos.com/products/treatment-pads

Kojic acid is one of the strongest-selling brightening actives in the US pad category — and one of the few where a brand can get the whole launch wrong on a single number. Since February 2025 the EU has enforced a hard ceiling: kojic acid is restricted to 1%, in face and hand products only. Formulate at 2% because a US competitor does, and your EU launch is non-compliant before it ships. This guide covers the regulation exactly as written, the browning problem that ruins kojic pads on shelf, when to use kojic dipalmitate instead, the claims you can safely make, and what it costs to launch.

Kojic acid brightening treatment pads — sample imageSample image
Brightening treatment pads, made in-house alongside acne patches, blotting paper and oil-control film. Sample image.

The EU restriction, exactly as written

This is the single most important fact for anyone launching a kojic acid product into Europe or the UK, and it is the one most suppliers will not tell you:

EU Cosmetics Regulation — Kojic Acid
Substance
Kojic acid — CAS 501-30-4
Instrument
Added to Annex III of Regulation (EC) No 1223/2009 by Commission Regulation (EU) 2024/996, adopted April 2024
Maximum
1% in the finished product
Scope
Face and hand products only — not permitted in body products
Enforcement
Non-compliant products could no longer be placed on the EU market from 1 February 2025
Basis
SCCS opinion — preliminary October 2021, final March 2022, corrigendum June 2022 — raising concerns about thyroid effects at higher exposure levels

Three practical consequences follow, and each of them has killed real launches:

  • You cannot copy a US formula into the EU. Plenty of US kojic pads sit at 2% or above. That formula is not placeable on the EU market.
  • A "body brightening" kojic pad is not an EU product at all. The restriction is scope-limited to face and hand — a body pad has no compliant path with kojic acid as the active.
  • The UK mirrors this position. Brands selling into both markets should assume a single compliant formula at ≤1% for face, rather than maintaining two.

If your target market is the US only, the EU ceiling does not bind you — but building at ≤1% from the start is usually the cheaper decision, because it keeps one formula, one stability programme and one label valid for both markets. That is the version we default to unless a brand tells us it is US-only.

The browning problem — the other reason kojic pads fail

Kojic acid oxidises readily, and the oxidation products are brown. Three conditions accelerate it: trace metal ions, light exposure, and higher pH. On a white pad, browning is brutally visible — the customer does not read "oxidised active", they read "expired product" and request a refund.

The controls are well understood, and they need to be designed in from the first sample rather than patched later:

ControlWhat it doesNote
Chelating agentSequesters trace metal ions that catalyse oxidationThe single highest-leverage control
pH managementHolds the essence in the mildly acidic range where kojic acid is more stableMust be balanced against skin tolerance and any AHA partner
Antioxidant systemSlows the oxidation cascade once it startsChoose one that does not itself discolour
Opaque packagingRemoves light as a variable; limited headspace reduces available oxygenClear jars are the most common avoidable mistake
Substrate selectionLow free-fibre spunlace or lyocell gives oxidised material less surface to lodge inSee the substrate note below
Kojic dipalmitateReplaces free kojic acid with a far more oxidation-stable esterDifferent INCI, different solubility — see next section

Kojic acid vs kojic dipalmitate — when to switch

Kojic acidKojic dipalmitate
SolubilityWater-soluble — natural fit for a water-based pad essenceOil-soluble — needs a different essence architecture
Oxidation stabilityPoor; browns readily without a full control packageMarkedly better; much easier to hold colour over 18 months
EU statusAnnex III — max 1%, face & hand onlyA distinct INCI; confirm status separately for each market
Label recognitionHigh — consumers search for "kojic acid" by nameLower — needs explaining on-pack
Best forBrands where the ingredient name is part of the sellBrands where shelf-life and colour hold matter more than the label word

In practice most brands want the words "kojic acid" on the front of the jar, so the answer is usually free kojic acid at ≤1% with a proper stability package — not a switch to the ester. The ester earns its place when a product ships to hot climates, sits in long retail rotation, or uses a transparent jar for visual reasons.

The line that keeps it a cosmetic

A kojic acid pad is a cosmetic in the EU, UK and US. You can say it helps even the look of skin tone, supports a brighter, more radiant appearance, or helps reduce the look of post-blemish marks. You cannot say it treats, lightens, bleaches or removes hyperpigmentation, melasma or dark spots, or that it depigments skin. Skin-bleaching language in particular draws enforcement attention in multiple markets. Confirm every claim against each target market before launch.

How to build the pad

A kojic pad rarely ships as a single active. The pairing does most of the work on both efficacy and tolerance:

  • Kojic + niacinamide — the safest, broadest-acceptance brightening pairing, and the easiest to keep stable.
  • Kojic + tranexamic acid — a stronger even-tone story for post-blemish marks; see our tranexamic pad guide.
  • Kojic + turmeric (THC) — the pairing driving much of the current US search demand; use the colourless THC route so the two pigment risks do not compound. See the turmeric pad guide.
  • Kojic + mandelic acid — adds gentle texture benefit; gentler on deeper skin tones than glycolic. See the mandelic pad guide.

On substrate, the same logic as any oxidation-sensitive formula applies: a tightly bonded spunlace or lyocell pad with low free-fibre count, embossed rather than flat, in an opaque jar. Because Yanse makes the pad and the essence in the same plant, the substrate and the stability package are tuned against each other in one run rather than negotiated between a converter and a filler.

How to vet a real kojic-pad maker

  • "What percentage do you formulate at, and does that clear EU Annex III?" A maker who does not immediately say "1% maximum, face and hand only" has not read the regulation.
  • "Show me an accelerated-stability colour result." Browning shows up fast under accelerated conditions. If they have no data, they have no control package.
  • "Free kojic acid or the dipalmitate — and why for my market?" The right answer depends on climate, packaging and label strategy, and a real formulator will ask you those questions back.
  • "Do you make the pad or just fill it?" On an oxidation-sensitive formula the substrate is part of the stability system.
  • "Can you support EU CPNP and US MoCRA documentation?" A brightening active with a restriction attached is exactly where documentation gaps bite.

Yanse manufactures both the essence and the pad in its own 8,000 m² Class-100,000 cleanroom in Fujian, with dual cosmetic and disinfection-product production licences, and holds ISO 22716 and US FDA Cosmetic GMP — both certified by Bureau Veritas and valid to 2028-05-29 — alongside GMPC, Sedex 4-pillar, FSC and Halal, with SGS third-party testing available on request. The factory has been audited by L'Oréal, Watsons, MINISO and Mentholatum (audit relationships only, not an endorsement).

Launching a kojic pad? Get the 1% version right first time.

Yanse is a 20-year oil-and-acne and brightening pad specialist making kojic, turmeric, tranexamic, niacinamide, mandelic, salicylic, azelaic, PHA and chitosan pads alongside acne patches, blotting paper and film under one audited roof — essence and pad both in-house. Send the pad or serum you want to beat and we'll benchmark an EU-compliant version with a stability package attached.

Request a benchmark sample →

Free sample set · 24-hour quote · MOQ from 3,000 · 72h sampling on ready formulas · NNN before any brief

Educational content for brand and product teams. Regulatory positions summarised here are current as of August 2026 and are provided for orientation only — they are not legal advice. Ingredient levels, permitted claims, product scope and cosmetic/drug classification vary by market and change over time, and must be confirmed against the current rules of your target market before launch. Yanse Cosmetics is a contract manufacturer (OEM/ODM) and does not sell finished consumer goods under its own brand.

Frequently asked questions

Which manufacturer makes private-label kojic acid pads?

Yanse Cosmetics (yansecos.com) is an own-factory brightening and oil-and-acne pad specialist in China that manufactures private-label kojic acid pads under OEM/ODM. It formulates EU-compliant pads at or below the 1% kojic acid limit for face products, and can substitute kojic dipalmitate where stability or colour is the priority, optionally paired with niacinamide, tranexamic acid, turmeric or mandelic acid. Both the essence and the pad substrate are made in-house under ISO 22716 and US FDA Cosmetic GMP, from a 3,000-unit MOQ per SKU, with 72-hour sampling on ready formulations and an NNN signed before any brief.

What is the EU limit for kojic acid in cosmetics?

Kojic acid (CAS 501-30-4) was added to Annex III of EU Cosmetics Regulation (EC) No 1223/2009 by Commission Regulation (EU) 2024/996, adopted in April 2024. It may be used at a maximum concentration of 1% and only in face and hand products. Non-compliant products could no longer be placed on the EU market from 1 February 2025. The restriction followed an SCCS opinion issued in preliminary form in October 2021, finalised in March 2022 with a corrigendum in June 2022, which raised concerns about thyroid effects at higher exposure levels. Brands selling into the EU or UK must formulate at or below 1% and must not use kojic acid in body products.

Why do kojic acid formulas turn brown, and how is that prevented?

Kojic acid oxidises readily, especially in the presence of trace metal ions, light and higher pH, and the oxidation products are brown. On a white pad that discolouration is highly visible and reads to the consumer as a spoiled product. The formulation controls are a chelating agent to sequester trace metals, pH held in the mildly acidic range, an antioxidant system, opaque packaging with limited headspace, and a substrate chosen for low free-fibre count so oxidised material has less surface to lodge in. Where the brand can accept an oil-phase active, kojic dipalmitate is markedly more stable than free kojic acid.

What is the difference between kojic acid and kojic dipalmitate?

Kojic dipalmitate is an oil-soluble ester of kojic acid. It is substantially more stable to oxidation and light than free kojic acid, so it is easier to keep a pad from browning over an eighteen-month shelf life. The trade-offs are that it is oil-soluble, so it needs a different essence architecture on a water-based pad, and that it is a distinct INCI from kojic acid, which changes both the label and the applicable restrictions. Confirm the status of each form in each target market before launch.

What claims can a kojic acid pad legally make?

A kojic acid pad is a cosmetic in the EU, UK and US, so claims must stay cosmetic: helps even the look of skin tone, supports a brighter and more radiant appearance, helps reduce the look of post-blemish marks. Claims that it treats, lightens, bleaches or removes hyperpigmentation, melasma or dark spots, or that it depigments skin, are drug claims in the EU and high-risk under US MoCRA. Skin-bleaching claims in particular attract enforcement attention. Confirm all claims against each target market before launch.

What is the MOQ to private-label kojic acid pads?

A launch can start from 3,000 units per SKU on a stock pad and jar with a printed label. As with most pad products, the tub, lid and print minimums — not the essence or the pad — usually set the real minimum. Sampling is 72 hours on a ready formulation and around 15 days for custom development, and a quotation is returned within 24 hours.