INCI rules: word AND

GuntherGunther Member
edited December 2018 in Formulating
In preblends where the supplier won't disclose the composition, the word and is used

Do ingredients need to be lised in descending concentration order within the group (separated by and words)?

Thanks and Merry Christmas everyone.
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Comments

  • Thats such a good question Gunther. Since we do not seem to have a functioning oversight body locally it seems anything goes. I have always tried to not use the and
  • MicroformulationMicroformulation Member, Professional Chemist
    edited December 2018
    I love when people use "And" although by common standards it is usually left out. To whit, I will put forth that you usually see these less than accurate Ingredient Declarations from smaller lines without a Regulatory Department. Not a lot of "and" in big line INCI Decks.

    Here is my theory and the use of "and" has a great deal benefit if you use "and" in your list and then I am asked to knock-off your product. The lines that I see using this are cutting and pasting the INCI names.

    For example, Chamomile in Sunflower Oil (Biobotanica) has a listed INCI as "Chamomilla Recutita (Matricaria) Flower (and) Carthamus Tinctorius (Safflower) Seed Oil." List it with the "and" makes it clear that you used this product.

    Another issue I see with these lines without proper oversight is that they do not reference Ingredient Breakdowns (such as 90% Sunflower and 10% Chamomile in this case for example). Let's say that you used 3% of this extract. You MUST break-up the components as the Sunflower oil will be declared at 2.7% and the Chamomile would be below the 1% line. As such, using the "and" (pasting the combined ingredients at the 3% line) is inaccurate. I see this error in some emerging lines several times a week.

    In my opinion, leave out the "and." It makes it easier for me to knock-off (Thank you), I have never seen a Regulatory Department approve it and it is likely going to lead to an inaccurate ingredient declaration. 


    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
  • @Microformulation great answer. Is there some sort of search engine where one can search for these combinations "and"'s. I am trying to reverse a combination and since i see it regulary i aasume its a premix from someone.
  • MicroformulationMicroformulation Member, Professional Chemist
    UL Prospector. They do require that you be confirmed as an Industry Professional and will not use a gmailor yahoo account.

    Other sources are;





    There are various other search engines.




    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
  • Thanks been using ul for some years now. Even got the app on my phone. I will try the others 
  • MicroformulationMicroformulation Member, Professional Chemist
    If you search a portion of the INCI in the mixture with any of these sites, UL Prospector as well as others, they will show combinations.
    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
  • Thank you. Have a wonderful holiday
  • MicroformulationMicroformulation Member, Professional Chemist
    Search the INCI of a component of the mixture. When you get your results on UL Prospector, select "mixtures." Now, at this point, you really need to look through and do some Detective work.
    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
  • I love when people use "And" although by common standards it is usually left out. To whit, I will put forth that you usually see these less than accurate Ingredient Declarations from smaller lines without a Regulatory Department. Not a lot of "and" in big line INCI Decks.

    Here is my theory and the use of "and" has a great deal benefit if you use "and" in your list and then I am asked to knock-off your product. The lines that I see using this are cutting and pasting the INCI names.

    For example, Chamomile in Sunflower Oil (Biobotanica) has a listed INCI as "Chamomilla Recutita (Matricaria) Flower (and) Carthamus Tinctorius (Safflower) Seed Oil." List it with the "and" makes it clear that you used this product.

    Another issue I see with these lines without proper oversight is that they do not reference Ingredient Breakdowns (such as 90% Sunflower and 10% Chamomile in this case for example). Let's say that you used 3% of this extract. You MUST break-up the components as the Sunflower oil will be declared at 2.7% and the Chamomile would be below the 1% line. As such, using the "and" (pasting the combined ingredients at the 3% line) is inaccurate. I see this error in some emerging lines several times a week.

    In my opinion, leave out the "and." It makes it easier for me to knock-off (Thank you), I have never seen a Regulatory Department approve it and it is likely going to lead to an inaccurate ingredient declaration. 


    What if you use a preblend and the manufacturer won't tell you the composition since it's a trade secret, you only know the total active % (sum of all ingredients in the preblend)?
  • What if you use a preblend and the manufacturer won't tell you the composition since it's a trade secret, you only know the total active % (sum of all ingredients in the preblend)?
    I am in this position, what I do is simply list the ingredients in the order supplied by the manufacturer without bothering to use 'and'. You run the risk of guesstimating the correct order on the LOI because you can only guess at the relative percentages in the blend. 
    Cosmetic Brand Creation. Concept to name to IMPI search to logo and brand registration. In-house graphic design inc. Pantone specs. Cosmetic label and box design & graphics.
  • For instance let's say I choose to make a shampoo with Stepan APB (replaced Plantaren APB recently) and CAPB. If I have say 10% CAPB and 15% APB where in the LOI does the CAPB go? And then I decide to add some Lamesoft PO65 of which two ingredients are similar/identical to two in the APB. And so on.
    Cosmetic Brand Creation. Concept to name to IMPI search to logo and brand registration. In-house graphic design inc. Pantone specs. Cosmetic label and box design & graphics.
  • SibechSibech Member, Professional Chemist
    @Gunther If they won’t give you a specific compositional breakdown, they might be willing to give you a range, from which you can reasonably estimate proper labeling.

    If even that is a problem, I would find another supplier, because they should be an assistance, not a hindrance to proper regulatory compliance.
    Dabbling Formulator — Qualified Cosmetic Safety Assessor — experienced in claim substantiation & EU regulatory affairs.
  • MicroformulationMicroformulation Member, Professional Chemist
    @GuntherHonestly, if one of my clients used a manufacturer who would not reveal at the minimum the ranges in the pre-blend, it would likely be a deal breaker. The distributor (my client) has the ultimate responsibility to ensure proper labeling. As said, it would certainly be an area where I would expect them to provide this info for Regulatory purposes.
    markfuller@microformulation.com Microformulation.com Microformulation Cosmetic Consulting provides Custom Formulations for both large Commercial accounts as well as smaller entrepreneurs. We can provide Naturally compliant Formulations under the NSF, NPA, Whole Foods and USDA Organic Certifications. BS.Pharm Albany College of Pharmacy, Union University.
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