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How to list blends of ingredients on product label
What are the rules regarding how to list ingredients that are made up of multiple things? For example an emulsifier or preservative blend that has 3-4 things in it, do you just list them in order based on the total % they collectively make up in your formula? For instance if you use 4% of Montanov 202 do you place all three components of it in order on your LOI wherever the 4% line is?
Or….
Do you try and find out the rough %’s of each individual component ingredient and place it on your LOI accordingly? And what if that information is not made available by the manufacturer?
Hope that makes sense it’s kind of a difficult question to put into words…or maybe it’s just late here and I should stop thinking about this stuff and go to sleep.
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6 Replies
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I think (but I’m not 100% certain) you are supposed to find out the rough %’s of each individual component and place them on your LOI accordingly.
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https://www.fda.gov/cosmetics/cosmetics-labeling-regulations/cosmetics-labeling-guide#clgl
Unless 1% or less, list in order of concentration. For those >1%, you do need to separate mixtures. Don’t use suppliers who don’t share compositional data - it’s often on SDS.
The ingredients must be listed in descending order of predominance. However, there are a few exceptions to this requirement.
1. If the cosmetic is also a drug, section 502(c) of the FD&C Act requires that the active drug ingredient(s) be declared before declaration of the cosmetic ingredients. A declaration, thus, would read as follows: “Active Ingredient: … (Name of drug ingredient). Other (or Cosmetic) Ingredients: … (Names of cosmetic ingredients in descending order).” [§ 701.3(d)]
2. Ingredients present at a concentration not exceeding 1% may be listed in any order after the listing of the ingredients present at more than 1% in descending order of predominance. [§ 701.3(f)(2)]
3. Color additives of any concentration may be listed in any order after the listing of the ingredients which are not color additives [§ 701.3(f)(3)].
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I have the exact same question. I feel like the answers above maybe don’t quite answer what you posted….did you ever figure it out? My emulsifier is made of three different ingredients at varying percentages - do I have to do calculations and list the three different INCIs at the various percentage points, or list them in descending order at the say, 6% line, if I’m using the emulsifier at 6%?
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You would need to do the calculations and place them at the various percentage points.
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Ok, thanks!
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You have to get the compositional breakdown from the chemical vendor…. After that you multiply each individual part of the composition by the percentage of the blend in your formula to come up with the actual percentage of the particular ingredient in the blend in your formulation… Then you can determine how to list them in descending order and as mentioned, if less than 1 % it is up to you how to list them… I usually keep preservatives at the end of the list as well as any Vitamins……
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