Home Cosmetic Science Talk Formulating General Ingredient Declaration guidance/opinions: reconstituted materials?

  • Ingredient Declaration guidance/opinions: reconstituted materials?

    Posted by kefka on March 19, 2019 at 3:34 pm

    Hi!

    I’ve noticed a number of water-based products in the marketplace (USA) which list extracts/juices in place of water and pondered about the legality of this approach. I’ve always held the notion that you list “what you add”, not “what you create” during compounding; e.g., 200x aloe vera powder should be declared as aloe vera leaf extract, despite the fact that it becomes aloe vera leaf juice when reconstituted. However, I was unable to locate this scenario within FD&C/FP&L to verify if the approach is acceptable and legal. 

    Is anyone familiar with this strategy? Is it legal/appropriate to declare reconstituted materials as solutions on final package or is this a case of deceptive labeling? 

    Thank you in advance for your time and thoughts.

    Kefka

    kefka replied 5 years ago 2 Members · 2 Replies
  • 2 Replies
  • oldperry

    Member
    March 19, 2019 at 4:02 pm

    It’s not legal to do that. The rules for labeling cosmetics are published in the INCI Dictionary and governed by the PCPC.  The FDA specifically cites the PCPC as the relevant organization for setting the rules. 

    You can find the ingredient dictionary naming rules here.

    Relevant to this exact subject…

    “3. Solvents and Diluents - Solvents and diluents in raw materials, such as surfactants, polymers, and resins, are not always identified as part of the INCI name (see F. Nomenclature Conventions, Rule 32). However, diluents and/or solvents must be listed on the finished product package label in their proper order of predominance with respect to all other ingredients in the formulation. Information on the concentration of solvents and/or diluents contained in such raw materials must be obtained by the marketing company from the supplier.

    4. Extracts - The INCI names for extracts represent the “material extracted” (see F. Nomenclature Conventions, Rule 32). Many extracts are supplied with the extracting solvent and/or other diluents. The solvents and/or diluents in extracts must be listed in their proper order of predominance, along with all other ingredients in the formulation, on the package label. The solvents and/or diluents in a specific extract may be found under its trade name in Section 6, Technical/Trade Names/ INCI Names. Information on the concentration of solvents and/or diluents in a specific extract must be obtained by the marketing company from the supplier. “
  • kefka

    Member
    March 19, 2019 at 6:19 pm

    Fantastic! Many thanks, Perry!

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