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INCI and label
After review of an IL, I have a question about the naming convention and does every name have to be INCI. The latin name of an extract was being used but the name used in parenthesis wasn’t an INCI name that corresponded to the CAS number. Is this ok?
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10 Replies
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No, not ok. In the US you are supposed to use INCI names
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@Perry
If the INCI name is coming from the supplier’s paperwork (i.e SDS, compositional statements, CoA, etc) is wrong. is a manufacturer liable for this mistake being put on a bottle? -
It does not make much sense that a supplier would apply for an INCI, get it approved, and then use a different naming convention than that approved by INCI on their documentation.
If you have questions, check with INCI to verify the naming convention.
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Labeling is responsibility of name on the bottle.
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What is the material?
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@Microformulation
this is a herbal blend and I am trying to confirm the verbiage that will go on the bottle. -
@Stanley - in the cosmetic industry, the ultimate responsibility for claims, labeling, product safety, and pretty much everything else is on the product manufacturer. It is their responsibility to ensure that they are following all the FDA regulations. You can’t make a mistake and then blame it on the raw material supplier. The FDA will not care. You will still be responsible for paying the fine and fixing the mistake.
If it was indeed the raw material supplier’s mistake that caused you to make a mistake, you would have to sue them to get compensation.
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Stanley said:@Microformulation
this is a herbal blend and I am trying to confirm the verbiage that will go on the bottle.You may have issues depending upon the distributor. We have disqualified several suppliers of botanicals (not real mainstream suppliers) due to poor documentation. It may sound picky, but some buyers (and all Natural Certification organizations) will require this paperwork.
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@Perry and @ microformulation
I have had to disqualify suppliers to because of the same thing. I understand.
Seems like there should be a IL workshop writing….hint hintAnother question… IL materials under 1%…
With an prelim IL that has ranges (not specific %’s) can you put items under the 1% any order or in order of abundance.
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@Stanley - Yes, any ingredient in the formula in a concentration 1% or below can be listed in any order that you like. The rules are a little different in the EU in that they require colorants to be listed at the end.
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