Step 1: Formula & Ingredient Names
The first step in creating an ingredient list for any jurisdiction is ensuring that the correct names are used. Formulas from manufacturers may often use common names or trade names. Also check that the formulation provided adds up to 100%, any formulas which do not add up to 100% cannot be correct, and therefore, cannot be used to create a correct ingredients listing.
EU/UK
We need to ensure that we’re using INCI (international nomenclature of cosmetic ingredients) names for products sold in the EU and UK. We can use the COMMISSION DECISION (EU) 2019/701 establishing a glossary of common ingredient names for use in the labelling of cosmetic products, or COSING (an online database).
USA
In the USA, ‘common names’ are used for cosmetic ingredients. Because INCI names are common, they are used in ingredient listings, with some exceptions.
CI numbers (colourants)
The ingredients “CI 77491”, “CI 77492”, “CI 77499” all have the same name of “IRON OXIDES” in the USA. These common ingredient names for colourants can be found on the FDA website.
Plant extracts
In the EU/UK, latin names for plant extracts are used, for example “CITRUS NOBILIS FRUIT EXTRACT” is simply called “MANDARIN EXTRACT”
Latin translations
The INCI system uses latin names, however, the common naming system in the USA doesn’t, therefore, ingredients such as “AQUA” are simply referred to as “WATER”.
Canada
Canada also uses the INCI system, however, when used in conjunction with the US common name system – common names must be translated into French. Therefore, “WATER” must be translated into the French “EAU”.
Step 2: Descending Order of Ingredients
Ingredients are required to be listed in descending order of concentration above 1%, below 1%, ingredients can be listed in any order, and colourants can be listed anywhere after the main ingredients in the formulation.
Ingredients above 1%
Ingredients above 1% must be listed in descending order of concentration. This is to ensure that consumers know what makes up the largest proportion of the products they are buying – it informs consumers and doesn’t mislead them in believe the product is something which it is not.
Ingredients below 1%
Ingredients below 1% may be listed in any order, but can remain in descending order for ease of ingredients list creation. Consumers are unlikely to be significantly mislead when ingredients are very far down the ingredients list (below 1%).
Colourants
Colourants may be listed after the main ingredients in the formulation, but can remain within the bulk of the ingredient listing if the ingredients listing is for a single product, for a singly range/colourway.
Allergens
Allergens are not ingredients, therefore, they should not be found in the ingredient list. However, for ease, the allergens can be declared after the ingredients list (in any order). They cannot be found amongst ingredients, as allergens are not classified as ingredients.
You will need to perform a calculation to determine which allergens should be declared on pack based on the concentration of aroma/parfum in the product and the concentration of allergens in the aroma/parfum.
Step 3: Formatting
Once the descending order of ingredients has been created, it needs to be formatted. It is important that you keep the main jurisdiction as the predominant form of ingredient list, most commonly the EU/UK. This means that the EU/UK INCI names will be listed before any common names or translations.
Combine EU/UK, USA and Canadian ingredient names
Example: AQUA (WATER/EAU)
“AQUA” is the EU/UK INCI name, “WATER” is the US common name and “EAU” is the Canadian translation of water. EU takes prominence followed by the common names and translations in brackets, these are separated by a forward slash “‘/”.
Separate ingredients with commas
Example: AQUA, PANTHENOL, GLYCERIN, ETHYLHEXYLGLYCERIN
It is important to know where an ingredient starts and ends, for example, CITRUS NOBILIS FRUIT EXTRACT is one ingredient but contains 4 words.
Standardise capitalisation
Example: AQUA, PANTHENOL, GLYCERIN, ETHYLHEXYLGLYCERIN
or Aqua, Panthenol, Glycerin, Ethylhexylglycerin
or aqua, panthenol, glycerin, ethylhexylglycerin
This is not a regulatory requirement to format consistently or any which way, it is simply up to preference of the brands. Please bear in mind the minimum font requirements of texts where applicable.
Add may contain section if applicable
A ‘may contain’ section may be added if an ingredients listing is used for a range of products. This is typically seen on eyeshadow palettes or products containing more than one product with similar bases. It is very important that the only deviation between merged formulas are the descending order or inclusion of colourants, all other ingredients must be listed in the descending order above 1%, and all the ingredients in one formula must also be present in the other formula (with the exception of colourants).
Example: MAY CONTAIN +/-: IRON OXIDES, YELLOW 10
