Article by: Perry Romanowski
When you look at the back of a cosmetic product label, you will see all of the raw materials included on the list of ingredients (LOI). At least you should. We’ve previous talked about the rules for cosmetic labeling and how you are supposed to use the concentration to list ingredients in order above the 1% line. But someone posted an interesting question on the SCC Linked In page. Specifically, they wanted to know whether there was some lower limit to meet before you have to list an ingredient.
Cosmetic Labeling Rules
The short answer is No, there is no lower limit. If you know that an ingredient is in your formula then you should list it. This includes all intentionally added ingredients by you, and even the intentionally added ingredients from your raw material supplier. For example, if you are buying a surfactant in which the supplier has put a preservative, you are required to list that preservative on your LOI no matter how minuscule the amount. However, if there is some unintentional ingredient then you don’t have to list that. For example, companies do not have to list 1,4 Dioxane or Lead even though the raw material might contain trace levels of these impurities.
Impurities do not have to be listed. Intentionally added ingredients do.
Which raises an interesting point. Many exotic cosmetic raw materials like natural herbs and extracts are incredibly expensive. However, they also go a long way to help sell your product so companies like to include those ingredients in their LOI. The problem is if they put too much of the ingredient in the formula it could have a negative impact on performance, odor, or just lead to a formula that costs too much. So one of the strategies of cosmetic companies is to put a very small amount of the “feature” ingredient in the formula; say 0.001%. And when they look for cost savings projects, that level might be cut down to 0.0001%.
The reason you can do this is because the reality is that most of these “feature” ingredients do not have a consumer noticeable effect. When you reduce the level, it’s unlikely that anyone will notice except maybe your accounting department.