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Selling it

INCI, and the ingredient list

By Dwight Davis, Founder

Updated

On this page5

The ingredient declaration is the part of a cosmetic label with an actual vocabulary attached, and it is not the vocabulary you buy the material under.

What INCI is

The International Nomenclature of Cosmetic Ingredients: a standard naming system used for cosmetic ingredient declaration, so that a list is readable across products and across countries.

Ingredients are declared on the label by their INCI names, in descending order of predominance.

It is a naming convention rather than a translation you may approximate. Cera Alba is the INCI name for beeswax and "beeswax" is not.

Descending order, with one exception

Everything in descending order by amount, with color additives conventionally declared at the end rather than in order.

Which matters when a tinted range shares a base: the base list is identical across shades and only the color tail changes, and that is the argument for a single artwork with a variable panel.

And note the contrast with the drug side, where the inactive ingredients in a Drug Facts panel are listed alphabetically, not by predominance. Same product, two different orderings, depending which regime it is in.

The names that surprise people

Cera Alba for beeswax. Butyrospermum Parkii Butter for shea. Theobroma Cacao Seed Butter for cocoa. Simmondsia Chinensis Seed Oil for jojoba. Ricinus Communis Seed Oil for castor. Copernicia Cerifera Cera for carnauba. Euphorbia Cerifera Cera for candelilla. Tocopherol for vitamin E.

Which is why a natural lip balm's ingredient list reads as forbiddingly chemical. That is the system working as intended, and it is not optional.

Where to get them right

From your supplier's specification sheet, which should state the INCI name for the exact material sold, and keep it with the batch record.

Not from another brand's label, which may be wrong, and not from a search, which will give you a name for a similar material rather than yours. Refined and unrefined grades and different extraction methods can carry different INCI names.

References

Fair Packaging and Labeling Act, and INCI nomenclature for cosmetic ingredient declaration in descending order of predominance. fda.gov
US Food and Drug Administration. Summary of Cosmetics Labeling Requirements. fda.gov
21 CFR 201.66, Format and content requirements for OTC drug product labeling (the Drug Facts panel). Paragraph (d)(10) permits a modified format where the panel would otherwise require more than 60 percent of the total surface area available to bear labeling. ecfr.gov
Written from the federal regulation and FDA guidance named on each page, not from a laboratory or a legal practice. Whether a particular formula and a particular label make a cosmetic or a drug is a determination about your product, and this is not that determination.