cosmetic label reading
Article by: Perry Romanowski

My first experience with cosmetic labeling came in college when I turned over the bottle of a shampoo and looked at the ingredient list. It was right around the time when I was learning how to name chemicals and I was confused why I couldn’t recognize almost any of the ingredients. It turns out that the cosmetic industry doesn’t follow the IUPAC system which is what they teach you in college. It follows the system set up by the Personal Care Products Council (PCPC) as described in the INCI Dictionary. See our previous post on cosmetic labeling and the naming conventions in it. cosmetic label reading

But the ingredients names in your formula are only part of the labeling process. You also have to follow the labeling rules laid out by the FDA that affect ingredient order, placement on the label, text size, language and more. Here are the relevant facts.

Cosmetic ingredient list

In the United States, it is a requirement that all cosmetics be labeled with their ingredients. The LOI (list of ingredients) is supposed to be printed on the container and needs to follow some rules when listing ingredients.

  1. Ingredients above 1% need to be listed in order of concentration
  2. Ingredients 1% or below can be listed in any order
  3. Exception: Color ingredients are listed at the end

The names of the ingredients must be those found in the INCI (International Nomenclature of Cosmetic Ingredients) Dictionary.

Where does the list go?

Once you have the list, you’ll have to put it on the package in the proper position. The FDA requires that it be put on the principle display panel which in most cases just means somewhere on the primary package where people can read it. See this for details.

What kind of font?

To ensure that the ingredient list is readable, the FDA requires that the font size be no smaller than 1/16th of an inch unless your packaging is really small in which case you can make the font 1/32nd of an inch.

What language?

Products sold in the United States must be written in English.

What else do you include?

Other information you need to list includes

  1. Name of the product (e.g shampoo, lipstick, eyeshadow)
  2. Name of manufacturer or distributor
  3. Address of manufacturer including city and zip code
  4. Net contents in container
  5. Warning statements if required

For more details about what and how you specifically need to list information on your labels in the United States, see this section on the FDA website.

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About the Author

Perry Romanowski

Perry has been formulating cosmetic products and inventing solutions to solve consumer problems since the early 1990’s. Additionally, he has written and edited numerous articles and books, taught continuing education classes for industry scientists, and developed successful websites. His latest book is Beginning Cosmetic Chemistry 3rd Edition published by Allured.

116 comments

  1. Avatar
    Kunal Shah

    Nice blog! Always remember that all ingredients in a cosmetic must be declared on the label in descending order of predominance.

    1. Avatar
      Perry Romanowski

      That’s not exactly correct. You only need to list them in order of concentration above the 1% level. After that you can list them in any order.

  2. Avatar
    Robin Pugh

    i absolutely love this! This was so helpful.

    1. Avatar
      Perry Romanowski

      That is 1% by weight

    2. Avatar
      Perry Romanowski

      That is 1% by weight (mass)

  3. Avatar
    Pricila

    I want to start private labeling cosmetics. I finally found a manufacturer who’s starting as well as me but this company is telling me I have to add on my label their name and manufacture address. I thought it only needed to be Distributor or Manufacturer… not both? Please advise.

    Thanks,
    Pricila

    1. Avatar
      Perry Romanowski

      It really depends on the manufacturer. If you’re following the rules of the FDA you can put your company’s address on & not the mfg. But they may have a policy that says otherwise.

  4. Avatar
    Kristie

    Question, I cannot find the answer anywhere. Do you know if you have to use the INCI name on labels in the US? I don’t plan on shipping outside the US at this time. Thanks in advance 🙂

    1. Avatar
      Perry Romanowski

      Yes, I recommend you only use the INCI name on labels. This is what is standard in the cosmetic industry.

  5. Avatar
    Helen

    Perry I work for a company and our Aromatherapy oils State 100% pure essential oils. I see no guidance as to compliance how to label sub-ingredients. For example-a sespiration essential oil blend that only calls out the eucalyptus and not the d-limonene. Is this correct? should the d-limonene be labeled or is it incidental? Where do I find the documentation stating what is correct and what is mislabeling?

    1. Avatar
      Perry Romanowski

      I’d suggest you post your question to Robert Tisserand. http://roberttisserand.com/ If you are not selling in the EU then you technically would not be required to list known allergens. But most companies in the cosmetic industry list them as it’s required in the EU and some products might make there way over there. You can find labeling documentation at the FDA site mentioned in the post.

  6. Pingback:What Ingredients Could be Hiding In Your Lipstick? - Lectualbeldrio

  7. Avatar
    Nina

    I have a question about colors. I am a distributor of cosmetics produced in Bulgaria. Some of the colors in the ingredients list are labeled in accordance with European standards. For example, CI 45100 and CI 14720, the problem is that I can’t find them in the FDA listing of color additives as exempt from certification or subject to certification. What needs to be done in this situation so that everything to be properly?

    1. Avatar
      Perry Romanowski

      You need to find out what INCI name they use (do a Google search CI 45100 INCI). Then look up the alternative name on the FDA Cosmetics website.

  8. Avatar
    VERLINDEN

    Does a production additive(such as an antifoam) needs to be putted as an ingredient with an INCI name in Europe, I heard that it would depends from the concentration

    1. Avatar
      Perry Romanowski

      I don’t know the specific EU regulations. In the US if there is an ingredient you add on purpose, you have to list it.

  9. Avatar
    franck

    if you use a homemade sun-infused herbal oil, like calendula infused in olive oil, you mention “Olea Europaea fruit oil, Calendula Officinalis flower extract”, isn’t it? but how do you know the amount of calendula since it’s only infused? do you need to have your herbal oil analysed??

    1. Avatar
      Perry Romanowski

      I don’t know the answer to this. You should check with the PCPC.

  10. Avatar
    Mollie Jensen

    Hi Perry,

    How can I legally list a proprietary blend that has a trademarked name? Can the TM’d name be used in the list, such as “Blah de Blah proprietary blend”? Or would the legal phrase simply be “proprietary blend”? Thanks so much!

  11. Avatar
    Thomas C

    Hi Perry,
    Thanks for the great resource. My question is about the name of the business on the label, I understand it says it has to be the corporate name but what if you are running as a “doing business as”, could you put the DBA name instead of the corporate name, and then include the city and zip code per the requirements?
    Thanks!
    Thomas C

    1. Avatar
      Perry Romanowski

      I think the point is that whoever buys your product should be able to find you. So if the DBA name allows them to find you with city and zip then you are probably following the spirit of the law.

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  13. Avatar
    Isabelle

    how stringent is FDA regarding conformity of the net content, ingredients and warning sizes? I am not talking about what’s written in the law here but more about how it is applied.

    tx

    1. Avatar
      Perry Romanowski

      That depends on the agent reviewing your case. It is best to follow the regulations the way they are written.

  14. Avatar
    Terri

    The front of my jar of body butter, I have company logo and the weight of product. Everything else, type and fragrance of product, direction,warning, inredients, address is on a round label on the lid of jar. Is this acceptable?

      1. Avatar
        Terri

        Thank you for your quick response. Ive read the regulation guidelines several times and do not see anything reguarding my question. I have even went as far sending the same question to them and the response was the same as yours. The link is not helping me with this particular question.

        1. Avatar
          Perry Romanowski

          Ah, well it would probably be better if you had all the information on the side label. That way if the cap got separated from the container it would still be properly labeled. At the very least you should have the identification of what the product is on the container.

          This is just one of those fuzzy regulatory questions which might not have a specific answer. You would probably be fine doing it the way you suggest. I haven’t seen the FDA send a warning letter to anyone for labeling their product in the way you suggest. It would help if you could find some market examples to show that other people have done this. (e.g. look through http://drugstore.com to find others doing a similar thing).

          Sorry I can’t be more definitive but that is the nature of cosmetic regulations.

  15. Avatar
    Manjari

    Thanks for the article. Is is okay to list essential oils in my product as just Essential Oils? I feel my blends are my trade secrets and make my products unique. They are less than 1% of the total volume.

    1. Avatar
      Perry Romanowski

      No, that is not ok to do. You have to list the INCI name of each essential oil that you use.

      1. Avatar
        Manjari

        Thank you!

  16. Avatar
    Amy

    Hi Perry, your website is a wonderful resource. I have a question about ingredient listings on labels. If you remove an ingredient from a formula due to lack of supply and no need to include this ingredient (low level, not functional), are you able to continue using the same labels (with the ingredient still listed) until you run out inventory? I appreciate any background you have on this.
    Thanks!

    1. Avatar
      Perry Romanowski

      This is more of a legal question and I’m not a lawyer. I think you’ll find that opinions would differ depending on the level of risk you are willing to take.

  17. Avatar
    Raghu

    Hi Perry,
    This is a wonderful forum. Got many of my questions answered. I have one question.

    If my cosmetic product contains, water/alcohol extract of some plants/leafs, should I write the ingredient as “water/alcohol extract of that plant” or just write “plant extract”

    Many Thanks
    Raghu

    1. Avatar
      Perry Romanowski

      You would list it as three separate ingredients. Water, Alcohol, Plant Extract

  18. Avatar
    Andrew

    Hi Perry
    You said :………If a raw material has preservatives in it, you need to show those one the label of your final product.
    I am not sure it make any sens in my case:
    1. My raw material (amino acids blend) has a preservative
    2. Preservative concentration in my raw material is …..0.0012% to 0.0018%
    3. Amino acids in my formula is: 0.2 %
    4. Calculated Preservative concentration in my final product is: 0.0000024% to 0.0000036% or from 0.024ppm to 0.032ppm (!!!!!) or from 24 ppb to 32 ppb (!!!!!!!)
    What to do in this case
    Shoud I discosure this preservative in INCI list ????

    1. Avatar
      Perry Romanowski

      Well, this is really a matter of what your regulatory or legal department thinks. I could see you arguing for both leaving it off and putting it on your list. The fact is that you know the ingredient is in your formula and the FDA rules do not have any minimum level. Therefore, I’d say you would have to list it. However, as you rightly point out the level is minuscule & likely won’t matter. The labeling rules also allow for not listing processing ingredients. So I don’t know what the “right” answer is. It depends on what level of risk you are comfortable with.

      1. Avatar
        Andrew

        Wow ! Thank you Perry for your immediate reply! 🙂

        I am writing from Poland so we have to fulfill European Regulation No 1223/2009 regarding product labeling. To solve my problem I am planning to use definition of “ingredient” . According to EU Regulation …..”an ingredient means any substance or mixture INTENTIONALLY used in cosmetic product”
        My intention was to use AMINO ACIDS in my formula. So this is my real INGREDIENT (!) Not this crumb of preservative .
        Of course this preservative is still a part of my “intentionally used mixture” even at 0.0012% concentration. But shoud’t we use common sens???
        Do you think my approach is too risky ?

        1. Avatar
          Katie Short

          Your approach is too risky, and you are the reason governments keep making more and more specific laws. Even in small quantities, someone who is allergic could have a reaction. Some of us simply prefer to know what is in the things we put on or in our bodies. Proper labeling will net you more customers if they know they can trust that you are as honest and transparent as humanly possible. It will keep you from being sued when someone has a reaction to something you didn’t list, or from losing your client base when they find out. It’s not about the law, it’s about morally running a business. Morals and law are frequently very far apart.

  19. Avatar
    Dian

    Wow, I love your website. So much useful information. I have a question regarding labeling correctly. Its a little convoluted…I currently use BTMS-50 in my lotions and conditioners. BTMS-50 has an INCI of Behentrimonium methosulfate (and) Cetyl alcohol (and) Butylene glycol. I know the Behentrimonium methosulfate is 50% of the product so, if I use 5% in my lotion, the Behentrimonium methosulfate would be 2.5%, correct? Then how would I factor the Cetyl alcohol and Butylene glycol? I thought maybe split the remaining 2.5% by 2 (1.25% each)? But I also use additional Cetyl alcohol in my formula at 3%. If I add the Cetyl alcohol from the BTMS, that would bump my usage to 4.25% in my formula, is that correct or am I just figuring this out all wrong?

    1. Avatar
      Perry Romanowski

      To get the exact answer you have to know the exact percents of Cetyl Alcohol an dButylene Glycol in the BTMS-50. The supplier should be able to tell you.

      But you are correct. If you use 5% in your lotion you would use 2.5% as the amount of Behentrimonium Methosulfate for labeling. For Cetyl alcohol you would use the amount you added additionally + the amount that comes from the BTMS. If you are correct in saying that there is 1.25% cetyl alcohol from the BTMS than your Cetyl Alcohol calculations are correct.

      1. Avatar
        Dian

        Thank you so much! I’ll have to ask the supplier to get more information.

  20. Avatar
    Kim

    Hi there – I have searched high and low for an answer to this question: Do sample sized bottles of shampoo/lotion/conditioner etc. have the same labeling requirements as full sized bottles? My frustration is that it is waaay too much information to fit legibly on a tiny label for a one ounce bottle. Am I allowed to refer people to a “package insert” for information? And if so, what are the “package insert” requirements? Going nuts trying to figure this out! Thanks in advance for any help you are able to give me.

  21. Avatar
    Q Kim

    Thank you so much for the information, I was getting super frustrated with label requirements and I found you!

    Just wanted to see if this is the proper way to label my cosmetic product! I assume it is based on what I am reading but wanted to ahead and get it reviewed by you.

    Water, Camellia Sinensis Leaf Extract, Glycrrhiza Inflata Extract, Paeonia Suffruticosa Root Extract, Scutellaria Baicalensis Root Extract, Xanthan Gum, Vitis Vinifera (Grape) Fruit Exact, Cedrus Atlantica Bark Oil…..

    Is this proper way to list the ingredients? I just took all names from INCI.

    Thanks for the help in advance!

    1. Avatar
      Perry Romanowski

      That could be the proper way to list them but it would depend on the concentration of the ingredients you used.

    2. Avatar
      Tracy

      In order for someone to tell you if your label is correct, you’d need to let them know the percentage of each ingredient in your product. If there is 4% Vitis Vinifera & 5% Cedrus Atlantica Bark Oil, the label would be wrong.

    3. Avatar
      Serena J Grey

      Hi, did you find an answer to this? I am also looking for this answer!

  22. Avatar
    Raz

    Hi Perry,

    If using the ‘natural’ colors such as beta carotene, lycopene etc, do these need to be explicitly labelled as such or can they be labelled as carrot or tomato extract’? Both the color and the extract have an INCI so this is causing some confusion.

    Some large ‘natural’ companies have the plant extract in the color section e.g. 100% Pure Cosmetics, Pacifica etc. state lycopersicum fruit (tomato) extract, and beta vulgaris (beetroot) extract as a colorant or that they are ‘fruit pigmented’ from blackberries, as opposed to listing ‘anthocyanin’ or ‘betalain’.

    Thanks!

    1. Avatar
      Perry Romanowski

      Hello Raz – you have to use the INCI name. Your ingredient supplier should give you the proper one. Those natural companies that aren’t using the INCI are improperly labeling their products.

  23. Avatar
    Nat

    So, how much of ingredients concentration can consider as the impurity?

    1. Avatar
      Perry Romanowski

      If you know an ingredient is in your raw material and it was put in there for a purpose then you should list it no matter how much is in there. So when you know a preservative is in the formula because of a raw material you should list it, but if there is an impurity in a raw material (like 1,4 – Dioxane) you don’t have to list it because it wasn’t meant to be in the ingredient.

  24. Avatar
    Alexander

    Hi Perry – I have been hearing from multiple sources that ingredients which together constitute 1% or less of total formulations do not need to be listed, or can be listed as “proprietary blend.” My understanding is that this is not correct – that all ingredients must be listed, with the only exceptional provision for <1% being that the order is no longer from highest to lowest concentration. Could you please help clarify? Thanks!

    1. Avatar
      Perry Romanowski

      That is not correct. If you know an ingredient is in your formula you MUST list it no matter what % you have.

  25. Avatar
    Ryan Behner

    I’ve been wanting to but some hydrolyzed protein but notice that some show the INCI as the hydrolyzed protein and then a few lines down show what it is preserved with, e.g., methylparaben. Aren’t companies supposed to list the preservative in the INCI list? Now when I see other hydrolyzed proteins as the only listed ingredient under the INCI, how can I be sure it does not carry a preservative? And shouldn’t all Hydrolyzed proteins be preserved?

    1. Avatar
      Perry Romanowski

      Yes, companies are supposed to list preservatives if they know they are in the formula.

  26. Avatar
    Mike

    Hi, I can’t find this info anywhere and the FDA is no help. I have a new label for false eyelashes which are synthetic. Technically they are made of a polyster. Do you know if my label needs to specify this? I currently just have “Synthetic lashes” along with the other requirements such as net weight, name of business, etc.

    1. Avatar
      Perry Romanowski

      I’m not sure. I don’t think false eyelashes would qualify as cosmetics

  27. Avatar
    Rachel B

    Hello Perry,

    Do you know of any courses that teach how to write ingredient list? Specifically if you get bases from another company and then add your ingredients then how do you put that in order and if you add extra of an ingredient that is already in the base do you have to add it in again? How do you find the % of the ingredients within the formula as well?

    Thank you for your help! Love your website!!

    1. Avatar
      Perry Romanowski

      I do not know of a course like this. Perhaps we will make one.

      1. Avatar
        Rachel B

        Let me know if you ever have a course like this. I will be your first student!!

        Thanks!

  28. Avatar
    tasha

    Hi, I don’t know if you know but why do companies list so many ingredients on the back if you only a few to do its job?

    1. Avatar
      Perry Romanowski

      Because people think more ingredients means a better product.

    2. Avatar
      Felicia

      Check out wholesalesuppliesplus.com they have a list of all INCI

  29. Avatar
    Dee

    Hello,

    I read somewhere that if a product contains 3 ingredients or less the specific ingredients do not need to be listed on the product label? Let’s say I sell a hair care product that contains 1 essential oil and 2 carrier oils; must I list my ingredients? Please shed some light on this for me. There is a product called Kemi Oyl that does exactly that. Thank you.

    1. Avatar
      Perry Romanowski

      You have been mislead. In the US you are required to list your ingredients for any cosmetic product you sell. It doesn’t matter how many ingredients are in the formula. If Kemi Oyl is doing that they are not following the law.

  30. Avatar
    pat

    Very informative. I especially appreciate you taking time to answer all the questions asked! Good site. I am glad I stumbled on your site!

  31. Avatar
    Bri

    If your product contains two items with the same concentration, which should be listed first? Is it alphabetical or up to the discretion of the manufacturer?

    1. Avatar
      Perry Romanowski

      In these situations, it’s up to you. Just be consistent.

  32. Avatar
    Georgina

    Gosh! Vert informative article! I had no idea they had to label their products like that. I’ll be double checking everything I buy now!

  33. Avatar
    Patent Attorney

    Excellent guide! You cover everything that is important, and with cosmetic products there’s not much space for getting things wrong!

  34. Avatar
    Heather

    Perry
    Can you clarify how to list the name and address of the distributor on cosmetic packaging. I am running an on line business out of my home and don’t want to list my home address on the packaging. Can I open a PO Box and use that address?
    The manufacturer is in Asia. For my packaging, can I just list Made in Korea, Dist. by Corp name, PO Box #, Street address of post office, City and Zip?

    thank you

    1. Avatar
      Perry Romanowski

      You just need to list the City and Zip code. You don’t need your street address.

      1. Avatar
        Rae

        This information in not correct. Address must be on the label UNLESS your business is listed in the phone directory and that recently was updated to include an online directory..such as yellow pages online. PO Boxes are not allowed.

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  36. Avatar
    Michelle

    On the IL for a consumer porduct is it possible to list the trade name following the INCI name?
    For example:

    Panthenol (Pro-Vitamin B-5)

    Thanks.

    1. Avatar
      Perry Romanowski

      No. The proper listing is Panthenol. If you want to say Pro-Vitamin B-5 you have to do it in the label copy outside of the LOI.

  37. Avatar
    agabeain

    hi Perry
    pls send formula hair stiling gel

    1. Avatar
      Perry

      See out post on free cosmetic formulas and search the databases.

  38. Avatar
    Guuky

    Do a google search online about labeling and you will see most of the large companies are not putting ingredients, etc on their products. They are listing ingredients in the packaging box (that you throw away immediately) and all that is left is their large logo on product it self as free advertising for several months.

    1. Avatar
      Perry

      Well, most cosmetic products are not sold in boxes so this is not true. I’m including in that personal care products.

  39. Avatar
    daniella

    hi there Perry im wanting to make natural cosmetics also and am making up a massage blend using essential oils, im aware of the inci name for these oils but i thought you also had to list known sensitisers that canbe found in the essential oils. Are you aware of this and how would i get such a list?

    1. Avatar
      Perry

      You should get the list of sensitizers from your supplier of the oil.

  40. Avatar
    pintoo

    @ Perry, what about the calculation of fill weights?
    How does the Production batch in weight translate to Volume while filling?

  41. Avatar
    KC

    Hi Perry,
    Your article is really informative, but I have a question.
    If in a product, a % of formulation which in itself contains some preservatives, was added, the labeling needs to show all the preservatives from that formulation by law? thank you!

    1. Avatar
      Perry

      Yes. If a raw material has preservatives in it, you need to show those one the label of your final product.

      1. Avatar
        KC

        A follow up question is: if that product didn’t show all the preservatives, is it susceptible to lawsuit? thank you

        1. Avatar
          Perry

          I’ll preface my answer with the following…I am not a lawyer and am not giving legal advice. This is just my opinion based on my knowledge of the labeling rules. If you want a legal opinion, you should talk to a lawyer.

          Alright, when someone puts out a product that is mislabeled (which is what they would be doing by not listing all the preservatives) the FDA would consider it a Misbranded product and this is what they say would happen….

          “FDA may take regulatory action if it has information to support that a cosmetic is adulterated or misbranded. The agency can pursue action through the Department of Justice in the federal court system to remove adulterated and misbranded cosmetics from the market. To prevent further shipment of an adulterated or misbranded product, the agency may request a federal district court to issue a restraining order against the manufacturer or distributor of the violative cosmetic. Violative cosmetics may be subject to seizure. FDA also may initiate criminal action against a person violating the law.”

          In reality, there is a low probability that you would ever be taken to court over something like this. It is against the rules & a shady business practice but lots of small companies do it.

          1. Avatar
            KC

            Thank you Perry. I really appreciate you took the time to answer my question.

          2. Avatar
            Dorian

            Would like to ask you (Perry) about your thoughts (besides the preservatives in an ingredient) about additives in an ingredient that are declared in the composition section of an Safety Data Sheet (SDS) or Technical Data Sheet (TDS) BUT is NOT declared on the INCI in those documents. Should they (additives) be declared on the LOI? I’m asking because some additives may be Prop 65. Your thoughts?

          3. Avatar
            Perry Romanowski

            If you know that an ingredient is in your formula you should declare it on your label. Especially if the ingredient is no the Prop 65 list.

  42. Avatar
    AC

    Hi Perry

    I just wondered how to come up with an INCI list for this particular situation. If for instance I have the following ingredients in the product that I made (just a sample formulation to show my point):

    1) Deionized Water — 98 %
    2) Basil Extract (INCI name: Water, Butylene glycol, Ocimum Basilicum (Basil) Flower/Leaf Extract, Lactic acid) — 0.10 %
    3) Lactic acid — 0.25 %

    How is the INCI listing then for this product, considering the extract contains water and lactic acid, ingredients that are used in the formulation as stand alone or the as the individual ingredients themselves?

    Thank you so much. Hope to hear from you.

    1. Avatar
      Perry

      If the ingredient is in the formula at under the 1% level then the order does not matter. It can be listed anywhere (as long as it is below the 1% line).

      So, this ingredient list would be

      WATER
      LACTIC ACID
      BUTYLENE GLYCOL
      OCIMUM BASILICUM (BASIL) FLOWER/LEAF EXTRACT

      or it could be

      WATER
      OCIMUM BASILICUM (BASIL) FLOWER/LEAF EXTRACT
      BUTYLENE GLYCOL
      LACTIC ACID

      You have to list all the ingredients that make up the extract but the order you use doesn’t matter in this case because it is under 1%

      1. Avatar
        AC

        Thank you a lot Perry. So that means to say then, one cannot tell by just looking at the ingredients list if the extract does contain butylene glycol as solvent and the lactic acid. One can assume then any of the following:
        1) that maybe these two ingredients (butylene glycol and lactic acid) are used independently in the formulation, and that the Basil Extract’s INCI could be just ‘Water and Ocimum Basilicum (Basil) Flower/Leaf Extract’.
        2) that maybe, yes, they are part of the INCI name for the Basil Extract as I have laid down in the formulation above.

        Am I correct in saying that? 🙂

        1. Avatar
          Perry

          Yes, that’s correct. You can not tell from an ingredient list which of the ingredients are added to the formula as a blend.

          1. Avatar
            AC

            I see. Another scenario. What if the formulation now is like the one below. How is the INCI list?

            1) Deionized Water – 97.40 %
            2) Basil Extract (INCI name: Water, Butylene glycol, Ocimum Basilicum (Basil) Flower/Leaf Extract, Lactic acid) – 0.10 %
            3) Butylene glycol — 1.10 %
            3) Lactic acid – 1.50 %

            A second question would be: Are the percentages by weight for instance of the components “water”, “butylene glycol”, and “lactic acid” in the extract not considered?

            I hope I am not too much, though I am. You are already very helpful! 🙂

          2. Avatar
            Perry

            In this scenario, you have to figure out the % actives in the extract. So, if the extract is 90% butylene glycol and 10% everything else, the amount of butylene glycol in your whole formula would be 1.19% giving the label…

            WATER
            LACTIC ACID
            BUTYLENE GLYCOL
            (rest of the basil extract name)

            But if it were 1.5% Lactic Acid and 1.45% Butylene Glycol + Extract, then the order would change because the total amount of Butylene Glycol would be 1.54% (1.45% + .09%)

          3. Avatar
            AC

            Thanks so much Perry. The percentages of the componets in the extract are something that the supplier or manufacturer of the extract can provide so that makes it easy then for the formulator, isn’t it? Do you see the scenarios I mentioned above the same in both the US and the EU?

          4. Avatar
            Perry

            Yes, the % breakdown of a raw material should be given to you by the supplier. Both the US and EU follow the naming convention of the INCI so yes, the rules should apply. However, I’m not well-versed in all the country specific cosmetic regulations so I would check with a lawyer or EU cosmetic chemist consultant before moving ahead in one of the EU countries.

  43. Avatar
    Aisha

    Are there any regulations on labeling and expiration dates/shelf life dates?

    1. Avatar
      Perry

      In the US, the only regulations are related to OTC products, not cosmetics. In the EU, there are regulations about expiration dates.

  44. Avatar
    Perry

    @Tiffany – it really depends on the claims you make. If you are making medical claims then that would make them a drug and they would be regulated differently. However, stick to cosmetic claims (makes things look better, improves appearance of…) and then you can follow the cosmetic rules.

    If you are worried about it, you should check with a lawyer. We are not lawyers here so don’t take what we say as legal advice.

  45. Avatar
    Tiffany

    BTW not sure why my avatar is a grumpy face.. sorry

  46. Avatar
    Tiffany

    Even if it’s for stretch marks, scars, and the likes?

  47. Avatar
    Tiffany

    At what point do I need to write “These statements have not been evaluated by the FDA. This product is not intended to treat, cure, or prevent any disease”? I am looking to make all natural (aside from synthetic preservatives though I’m testing natural ones such as NataPres first) skin care products and I want to label them correctly. I intend to write that they are used for moisturizing, etc but I read that makes them a drug not a cosmetic.. I need help!

    Thanks!

    1. Avatar
      Perry

      Saying they are moisturizers does not make them a drug. You do not need to write the statement that you have indicated. You just need to properly label the ingredient list, the product description, the amount in the bottle, the business location and the other things outlined in the post.

  48. Avatar
    Shalini

    is there any legal implications if i used “and” on the methyl (and) propyl paraben as my ingredients?

    1. Avatar
      Perry

      It is a violation of the INCI naming rules however, this is unlikely to be something that the FDA would take action against. What would be the benefit of using “and” rather than proper naming rules?

  49. Avatar
    maria

    when u list ingredients that have more than one item(like a blend)
    i.e glycerin (and) water (and) sodium…do u need to use the (and)’s or do you just list the ingredients>

    1. Avatar
      Perry

      no you do not use the ‘and’. You use the specific INCI name for the individual ingredients.

  50. Avatar
    Karen

    Hi, I am designing the labels for our organic facial oils and was wondering what point font is 1/16th of an inch and what font is 1/32nd of an inch. Anyone know?

  51. Avatar
    Tumur

    I like your article but you need to write more about how to handle customer compaints. I am working in cosmetic company last 6 years. We had lot’s of problems of labeling products with our customer. I am writing about cosmetic chemitry in my blog. Please feel free to leave a comment.
    http://btumur.blogspot.com
    Good a job Perry, keep writing articel. I will visit your blog once in well.

  52. Avatar
    Perry

    Kim

    There is not an exception for lipsticks. What many companies do is use an outer packaging and put the ingredient list on the outer box. The ingredients are listed for the consumers.

    I would suggest you take a look at what other companies do when labeling their lipsticks. Take particular note of what big companies do. They are the most likely to be properly following the rules.

  53. Avatar
    Kimberly Riley

    Great article Perry! This information is very helpful. I need to be aware of the regulations before I purchase any labels for my cosmetics.

    As I have been formulating my lipsticks and lip glosses for Kimistry Cosmetics, I wondered “How am I going to declare all of my ingredients on the small containers?” I noticed some companies only declare the active ingredients or some don’t have a declaration list at all. Is there an exception for lipsticks and lip glosses? Or are the ingredients provided to the customer and not necessarily to the consumer? Thanks and have a nice day!

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