Creating an INCI list: order, rules and an example for cosmetic products

Under Article 19, an ingredient is any substance or mixture intentionally used in the manufacturing process. Not regarded as ingredients are impurities in the raw materials used and subsidiary technical materials used in the mixture but not present in the finished product.

In practice: a trade raw material is often a mixture itself, for example an active in a solvent with a preservative. The list then shows the individual ingredients with their share of the finished product, not the trade name. Conversely, the same ingredient can enter the formula through several trade raw materials. Raw material and INCI are therefore two different data objects.

The list names the ingredients in descending order of weight at the time they are added to the cosmetic product. The basis is therefore the formula, not an analysis of the finished product. Ingredients in concentrations of less than 1% may be listed in any order after those above 1%.

Colorants other than those intended to colour hair may be listed in any order after the other ingredients. For decorative products marketed in several shades, all colorants used in the range may be listed, provided the words “may contain” or the symbol “+/-” are added. The CI (Colour Index) nomenclature is used where applicable.

Perfume and aromatic compositions and their raw materials are referred to by the terms “parfum” or “aroma”. Substances that must be mentioned under the column “Other” in Annex III are additionally named individually in the list. That mainly concerns fragrance allergens, whose list was significantly extended by Regulation (EU) 2023/1545.

All ingredients present in the form of nanomaterials must be clearly indicated, and their names are followed by the word “nano” in brackets.

The list uses the common ingredient names from the glossary under Article 33. The Commission compiles this glossary taking into account internationally recognised nomenclatures, including INCI. Where there is no common name, a term from a generally accepted nomenclature is used.

Important: the glossary is not a list of substances authorised for use. An entry says nothing about whether a substance may be used in a particular product. The Commission’s CosIng database is a good starting point for looking up names and regulatory entries. The Commission makes clear, however, that CosIng itself has no legal value; the Regulation and its annexes are what count.

First, take the approved formula version with all raw materials and percentages. Second, break each trade raw material down into its ingredients and their shares, using the supplier information. Third, add up identical ingredients coming from different raw materials. Fourth, remove impurities and subsidiary technical materials not present in the finished product.

Fifth, sort by weight in descending order and move the ingredients below 1% to the end. Sixth, list perfume and aromatic compositions as “parfum” or “aroma” and add the listed allergens above the threshold. Seventh, mark nanomaterials and put colorants with their CI number at the end. Eighth, check the names against the glossary.

A simple cream could be declared as follows: Ingredients: Aqua, Glycerin, Caprylic/Capric Triglyceride, Cetearyl Alcohol, Butyrospermum Parkii Butter, Glyceryl Stearate, Phenoxyethanol, Parfum, Tocopherol, Linalool.

Water comes first because it has the largest share. From Phenoxyethanol onwards the ingredients are below 1%, so their order is free. Linalool is a listed fragrance allergen and appears in addition to “parfum” because in this example it is above the threshold. The example is for illustration and does not replace checking your own formula.

Trade names instead of common ingredient names. Components of a mixture that are not listed individually. A list that was not updated after a formula change. Allergens above the threshold under the extended list that are missing. And an order taken over from an older version.

Most of these mistakes arise when the list is maintained by hand, separately from the formula and raw-material data.

A development system that knows raw materials with their composition and INCI names can derive the list from the formula version and rebuild it with every change. A person still needs to check it, especially for mixtures, perfume and colorants. Responsibility for the label remains with the responsible person.