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  • Labelling plant ingredients for EU and US market

    Posted by Agate on June 27, 2021 at 9:56 am

    Hi everyone,

    I’m thinking of selling a relatively small amount of cosmetics into the EU and US market. I use a lot of plant ingredients, and I’m a bit stuck on how to create labels in a way that comply sufficiently with both sets of regulations at the same time, so I don’t have to make separate batches and labels.

    I’m considering the following options, with the example of argan oil:
    1) Label according to INCI: Argania Spinosa Kernel Oil
    2) Combine INCI with the common name in brackets: Argania Spinosa (Argan) Kernel Oil
    3) Combine the common name with INCI in brackets: Argan (Argania Spinosa) Kernel Oil
    (I’m ruling out using common names only in the EU, seems like they’re a bit hotter on it here, plus I prefer including the latin botanical names for precision.)

    From my european experience, I see either 1) or 2) on commercial product labels. How is the situation in the US? Is 2) acceptable? Aesthetically and for branding purposes I would prefer 3), but I’m not sure that would fly in the EU.

    Agate replied 1 year, 7 months ago 3 Members · 4 Replies
  • 4 Replies
  • MarkBroussard

    Member
    June 27, 2021 at 3:05 pm

    @Agate:

    In the US, you must use the INCI name and can also include the common name in brackets, sor both 1 and 2 are in compliance.

    Your option 3, I don’t think would be compliant.

  • Agate

    Member
    June 27, 2021 at 7:38 pm

    Thanks @MarkBroussard, I didn’t know the INCI name was common in the USA.

    I did some searching and came across this: https://www.fda.gov/cosmetics/cosmetics-labeling/cosmetic-ingredient-names

    International “Harmonization” of Ingredient Names
    Cosmetic companies sometimes ask FDA about identifying botanicals only by their Latin names, identifying color additives only by the “CI” numbers used in the European Union, or using terms from other languages, such as “Aqua” and “Parfum” instead of “Water” and “Fragrance.” Under the FPLA, however, ingredients must be listed by their “common or usual names,” and FDA does not accept these alternatives as substitutes. But FDA does not object to their use in parentheses following the common or usual name in English (or Spanish, in Puerto Rico). Here are some examples:

    • Water (Aqua)
    • Fragrance (Parfum)
    • Honey (Mel)
    • Sweet Almond (Prunus Amygdalus Dulcis) Oil
    • FD&C Yellow No. 5 (CI 19140)

    So this would suggest that 3) is preferable for the US, but 1) and 2) are also used in practice?

  • MarkBroussard

    Member
    June 27, 2021 at 8:20 pm

    @agate:

    The FPLA is a guideline from the Federal Trade Commission, which is different from the FDA … No, most companies in the US label in accordance with your #2 … INCI name with (common name in parentheses).

  • PhilGeis

    Member
    June 29, 2021 at 2:22 pm

    Cosmetics are subject to both FPLA and FD&C legislation.  As Mark noted, INCI (as CTFA dictionary) is the primary guidance for ingredient labeling.  Please look at the actual regulation 21CFR 701.3 Designation of Ingredients https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=79073513f7ba6a05126c6da0aa85c460&r=PART&n=21y7.0.1.2.11#se21.7.701_13

  • Agate

    Member
    June 29, 2021 at 10:44 pm

    Thank you for clearing that up @MarkBroussard and @PhilGeis ! In that case I’ll stick with 2) :)