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Water in plant’s extracts
Just a pothetical situation: if I don’t add water in a product but use plant’s extract which contain water (eg.: “CAMELLIA SINENSIS LEAF WATER”), should I disclosure the ingredient “water” as well? In my opinion I shouldn’t do this. Because If I should disclosure “water” then I also should disclosure the other hundreds substances that I vegetal extract can contain. But I don’t know if everyone would agree with me…
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10 Replies
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Some ingredients that are extracts, will be in a water base and may also contain a preservative or other ingredients in the blend and will be labelled as such.Here’s an example of a Green Tea Leaf Extract that I use:
INCI: Vegetable Glycerin (and) Purified Water (and) Camelia Sinensis (Green Tea) Leaf Extract (and) Gluconolactone (and) Sodium BenzoateYou can list the ingredients on your label in the manner above. Just follow the way the plant extract you use is labelled.Or, you can go to the FDA Substance Registration System and search for the UNII for the main ingredient in your extract. In this case, it would be Camelia Sinensis (Green Tea) Leaf Extract (there are other acceptable names or variants, but you will not find the INCI that I listed above. So, in that case, I just go with the name and UNII in the SRS system that most closely matches the active ingredient. -
You are supposed to list the ingredients in order of concentration so you aren’t supposed to list ingredients as suggested here…
INCI: Vegetable Glycerin (and) Purified Water (and) Camelia Sinensis (Green Tea) Leaf Extract (and) Gluconolactone (and) Sodium BenzoateThe proper way to list this is in order of concentration and in order of concentration in your formula. So, if you have water somewhere else in your formula you would add the mass of this water to the mass of all the water and list it in that order.
If you are selling cosmetics you must use the INCI nomenclature for naming ingredients. Unless there is no name for the plant extract you shouldn’t use the FDA Substance Registration System.@pma - you should list water first. You know that the ingredient contains water so it should be listed. You raise a good point but that’s just not how it is done in the cosmetic industry (and for good reason).The LOI is not supposed to be used for marketing purposes. -
While it may not be technically correct, I have seen it done this way on some labels.
Perry, if the ingredients are included at 1% or less, then they can be listed in any order? Is that correct? -
Yes, at 1% or less they can be listed however you like.
There are lots of companies who don’t follow the rules and get away with it. Especially in the US where you don’t need pre-market approval to sell a cosmetic. For a small company there is very little risk to ignoring FDA rules. They probably won’t get caught. But that doesn’t make it right.Incidentally, this fact about small companies is why I recommend to friends and family that they stick with products produced by big companies. There is just less of a chance of getting a low quality, less safe product. (e.g. Badger Sunscreen for kids that is improperly preserved due to an asinine stance on parabens) -
Perry is so right! In fact, the reason why I formulated my first skin cream was just such a ‘small company’ product. (Hell, I run a small company! Our #1 principle is “Do no harm”)
I bought a dish washing liquid that I found in the local supermarket not realising it was made locally… 3 weeks later my hands and my wife’s hands, the skin was lunar in nature. Horrendous. So being into chemistry I bought and tested an Evy & Crab hand cream, found it excellent, and decided to duplicate it.In my local marketplace which is a huge fast-growing city, I see all the time small companies selling products with no LOI whatsoever, and often making ludicrous claims. Coffee that cures cancer and makes you slim and better looking, “alkaline” water, face creams that are basically yoghurt.
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I was just thinking more about this. Surely we aren’t required to calculate %LOI precedence on anhydrous content? It would be pretty horrendous to do … because most of the polar ingredients are solutions in water. For instance when you buy SLES, it comes in all sorts of different concentrations. I don’t take notice of the % actives when I compile the LOI of a finished product. I just list in order the % used of each ingredient, an ‘ingredient’ being a drum of stuff that arrived from a distributor.
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The regulation is that ingredients are to be listed in descending order of concentration by their “common or usual names” …Take the example of Green Tea Leaf Extract. The extract of Green Tea Leaf in an aqueous base will contain numerous catchins, polyphenols, etc. … but, the usual or common name for this chemical stew is “Green Tea Leaf Extract” or “Camelia Sinensis (Green Tea) Leaf Extract.” This is why I like to use the FDA Substance Registration System, because it gives you a Preferred Name for any given ingredient and there is a listing of alternate names for each ingredient, if there are alternate names or variants. I just use the Preferred Name using the logic that the government would have to take issue with its own data registry if there is a dispute.The regulations are specific, but also intended to be practical in implementation as the purpose is for the consumer to understand what are the ingredients in a product. But, yes, for a multi-component ingredient, you are supposed to break it down to the individual components as Perry described.
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Let me make that more clear:
The regulation is that ingredients are to be listed in descending order, on the basis of % by weight of each individual ingredient in the formulation and the ingredients are to be identified by their “common or usual names.” …If you have doubts, your supplier can provide you with guidance on how their ingredient should be labelled.So in the case you brought up, the Preferred Name for SLES is:Preferred Substance Name: SODIUM LAURETH-3 SULFATE [show more names] UNII: BPV390UAP0 Formula: C18H37O7S.Na Search Term: SODIUM LAURETH SULFATE Synonyms and Mappings
- 9004-82-4
- SODIUM LAURETH SULFATE
- SODIUM LAURETH SULFATE [II]
- SODIUM LAURETH SULFATE [INCI]
- SODIUM LAURETH SULFATE [VANDF]
- SODIUM LAURETH-3 SULPHATE
- SODIUM LAURYL ETHER SULFATE
- STEOL CS-460
Right when you have SLES in a formula you use the % active as deciding where it should be listed in your LOI. You do not use the % of the ingredient as used. You also have to include the water in your %. So a 25% SLES solution used in a formula at 10% would list
There is a bit of a loophole, however.
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