Dear all, 
I would like to know if the impurities must be announced in the INCI list of cosmetic product 


  • EVchemEVchem Member
    are you in the US?

    Incidental Ingredients

    Any processing aid added and removed or converted to a declared ingredient
    Any ingredient of another ingredient or processing aid present at an insignificant level and having no technical or functional effect

    Need not be declared

    Incidental ingredients need not be declared on the label.

    An incidental ingredient is defined in § 701.3(1) as:

    1. A substance added during manufacture and removed from the cosmetic in accordance with good manufacturing practices before the cosmetic is packaged in finished form. Example: Filter aid.

    2. A substance that is added during manufacture of a cosmetic, is converted to an ingredient declared on the label, and does not significantly increase the concentration of the declared ingredient. Example: Sodium hydroxide added to a sodium stearate and stearic acid-containing cosmetic.

    3. A substance added to a cosmetic during manufacture for its technical effect in processing but present in the finished cosmetic at an insignificant level and not having any technical or functional effect in that cosmetic. Example: Defoaming agent.

    4. A substance added to a cosmetic as a component of a cosmetic ingredient and having no technical or functional effect in the finished cosmetic. Example: Preservative of a raw material added to a cosmetic as an ingredient at a concentration which reduces the preservative to a level at which it is no longer effective.

  • Hi @Tyss
    I am in the EU.

    Do you mind saying what your product is and what the ingredient/impurity is?

  • TyssTyss Member
    Dear all, 
    Thanks for your feedback
    I am in Tunisia and we work according to European regulations
    My cosmetic product is hard soap
    The ingredient is tetrasodium etidronate 
    The impurities in this raw material are: disodium phosphonate, sodium phosphate, sodium acetate
    Best regards 
  • Hi @Tyss in Tunisia

    We went to Tunisia a number of years ago Tunis, Hammamet... I rode my first camel in the Tunisian Sahara. We still love harissa.

    I can help you. My specialty is soap and I am an EU safety advisor. Do you need the EDTA in your formula? 

    It might be helpful if I could see the SDS. Would you be willing to send that? I can then tell you more. 

    Kind regards,

  • TyssTyss Member
    Dear Dr Sara,
    Thank you for your help and I am very happy to hear your impressions of Tunisia.
    In fact, I use the two chelating agents in my hard soap formula: Tetrasodium etidronate (0.09% active ingredient) and tetrasodium EDTA (0.07% active ingredient).
    You find in PJ the SDS of tetrasodium etidronate 
    Best regards

  • Good Morning, Tyss

    For TURPINAL® 4NL  you would list INCI Tetrasodium Etidronate. I have listed the relevant information below. Do you need help with your safety assessment/CPSR?

    IN THE EUROPEAN UNION; Updated Guidelines for the Cosmetics Industry based on the 7th Amendment to the Cosmetics Directive

    "If a raw material is supplied as an intentional mixture, each individual ingredient must be declared separately, taking into account its concentration in the finished product."

    The following applies toTurpinal 4NL

    "all ingredients must be listed, except: 
    • Impurities in raw materials used; 
    • Subsidiary technical materials used in the preparation but not present in the final product; 
    • Materials used in strictly necessary quantities as solvents or as carriers for perfume and aromatic compositions.
  • TyssTyss Member
    Thanks a lot Dr Sarah, for your comments and your response.
    Very kind to your request and I would like to hear your opinion 
    Find in the PJ documentation that can help you
    I am at your disposal if you want something to love about Tunisia and I will be very happy to accept my request.
    See you soon

  • Your formulation is very straight forward. When are you going to start selling in the EU? 

    Send me a DM if you would like me to give you more info about getting a CPSR. :)
  • TyssTyss Member
    Hello Dr Sara 
    What is the DM?? 
  • Sorry. Direct message/mail.

    Perhaps you can send me an email and we can discuss further?
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