INCI ingredient lists for cosmetics: how to set them on pack

The ingredient list is often the longest block of text on a cosmetic pack, and one of the most rule-bound. In the European Union and the United Kingdom it must use INCI names in a defined order. In the United States, the FDA has its own naming and order rules that overlap with INCI. This guide explains how INCI lists work, the order rules, fragrance allergens and how to fit a long list onto a small pack without making it unreadable.

It is a practical guide for brands and designers, not legal advice. Your formulator and regulatory adviser should supply and check the final list. The European Commission's CosIng database and the FDA's labelling guidance, linked below, are the official references.

What INCI is

INCI stands for International Nomenclature of Cosmetic Ingredients. It is a system of standard names for cosmetic ingredients, so that the same ingredient has the same name on labels in different countries. INCI names are assigned through an international process and published in industry dictionaries. In the EU, the Commission's CosIng database lists ingredient names and information.

INCI names often look technical. Water appears as "Aqua", shea butter as "Butyrospermum Parkii Butter", and vitamin E as "Tocopherol". Botanical ingredients usually use the Latin genus and species followed by the plant part and form, such as "Rosa Damascena Flower Oil".

Where ingredient lists are required

• EU: Article 19 of the Cosmetics Regulation (EC) No 1223/2009 requires a list of ingredients. It may appear on the outer packaging only, preceded by the word "ingredients".
• UK: The same requirement applies under the UK's cosmetics rules.
• US: 21 CFR 701.3 requires an ingredient declaration on the outer container, on any panel, in descending order of predominance with some exceptions.

The order rules

Descending order of weight

In all three markets, ingredients are generally listed in descending order of weight at the time they are added to the product. The ingredient used in the largest amount comes first, usually water or a base oil.

Ingredients at 1% or less

In the EU and UK, ingredients present at a concentration of less than 1% may be listed in any order after those above 1%. In the US, ingredients at 1% or less may also be listed in any order after the others, under 21 CFR 701.3.

This is why a product's "hero" ingredient can appear near the end of the list even when it is the focus of the front-of-pack claims.

Colourants

In the EU and UK, colourants may be listed in any order after the other ingredients, using their Colour Index (CI) number or the INCI name, such as "CI 77891" for titanium dioxide. For products sold in a range of shades, such as lipsticks or foundations, all colourants used across the range may be listed with "may contain" or "+/-", so one ingredient list can cover several shades.

US rules have similar provisions for listing colour additives, using names approved by the FDA, such as "Titanium Dioxide" or "Red 40", and permit "may contain" listings for shade ranges in some cases.

Fragrance and flavour

Perfume and aromatic compositions can generally be listed as "Parfum" (EU/UK) or "Fragrance" (US), or "Aroma" for flavours, rather than listing every component. There are important exceptions for fragrance allergens.

Fragrance allergens

In the EU and UK, certain fragrance substances known to cause allergies must be listed by name when they exceed set concentrations in the finished product: currently 0.001% in leave-on products and 0.01% in rinse-off products. Historically, there were 26 such substances, including Limonene, Linalool and Citral.

The EU has adopted rules to significantly expand this list, with transition periods for existing products. If you sell in the EU, check the current list and dates with your adviser. UK rules may follow a different timetable.

In the US, MoCRA directs the FDA to issue rules requiring fragrance allergens to be disclosed on labels. Until those rules apply, there is no federal requirement to name fragrance allergens individually, but many brands do so for EU compliance and customer transparency.

Other naming rules

• Nanomaterials: in the EU and UK, ingredients present as nanomaterials must be followed by "(nano)" in the list.
• Impurities and processing aids that are not present in the final product, or are only present as traces, are generally not considered ingredients.
• US naming: the FDA requires certain names, which usually match INCI names but not always. For example, US labels commonly use "Water" rather than "Aqua", and certain botanicals use English common names. Some brands use both, such as "Water (Aqua)".

Fitting the list on the pack

A long ingredient list on a small product is a common design challenge. Some techniques:

Use the outer packaging

In the EU, UK and US, the ingredient list can usually appear on the outer carton rather than the container itself. If your product has a carton, use it for the full list and keep the container label clean.

Use a leaflet or tag for very small products

In the EU and UK, if it is impossible for practical reasons to label the ingredients, such as on very small products or products without outer packaging, they can appear on an enclosed leaflet, label, tag or card, or on a notice near the product for products sold without packaging, with the hand-and-book symbol on the product. In the US, there are similar provisions for small packages and off-package labelling in certain circumstances.

Typeset it properly

• Pick a legible typeface with clear letter shapes at small sizes. Condensed typefaces can save space without becoming unreadable.
• Use sentence case or the case your adviser recommends, not all-caps, which is harder to read.
• Separate ingredients with commas and consistent spacing.
• Keep contrast high. Light grey text on a pastel background is hard to read.
• Check minimum sizes required by your market and your retailer.

Plan for shade and variant ranges

For ranges, decide whether each variant gets its own list or whether a "may contain" list covers several. This affects artwork templates and print runs.

Front-of-pack claims and the ingredient list

The ingredient list and the front of the pack must agree. If the front says "with rosehip oil", rosehip oil must be in the list, under its INCI name. If you highlight an ingredient, customers will look for it in the list, and regulators may check that the amount is meaningful.

A few practical points:

• "Free from" claims must be accurate and not misleading. In the EU, the common criteria for cosmetic claims discourage "free from" claims for ingredients that are prohibited anyway, or that imply other products are unsafe.
• Natural and organic claims are not defined by the EU Cosmetics Regulation itself. If you use them, private standards such as COSMOS are often used to give them a clear basis.
• Percentages on the front of pack, such as "10% niacinamide", should match the formula and be supported by your product information file.

Ingredient lists for multi-market packaging

If one pack is sold in the US, EU and UK, the ingredient list usually has to satisfy all three. Common approaches:

• use INCI names with US names in brackets where they differ, such as "Aqua (Water)"
• list fragrance allergens required in the EU and UK, which is also accepted in the US
• use CI numbers with US colour names where needed for colourants
• check whether any ingredient is restricted or banned in one market, which may require a different formula rather than a different label

Checking the list

Mistakes in ingredient lists are common and can be costly. Before printing:

1. Get the list from your formulator, not from memory or an old label.
2. Check every INCI name against CosIng or your adviser's references.
3. Check the order against the formula.
4. Check fragrance allergens against the concentrations in the finished product.
5. Proofread at actual size and compare with the source list line by line.

How we help

We design cosmetic, skincare and makeup packaging and make cartons and rigid boxes in our own factory. We typeset the ingredient list you supply so it is legible and fits the panel, and we plan cartons, leaflets or tags when space is tight. We do not write or verify ingredient lists; that responsibility stays with your formulator and adviser.

See our cosmetic packaging design and makeup packaging design services, or get a free quote for your packaging.

Official sources

• European Commission: CosIng cosmetic ingredient database
• EUR-Lex: Regulation (EC) No 1223/2009, Article 19 labelling
• 21 CFR 701.3: Designation of ingredients (eCFR)
• FDA: Cosmetics labeling guide

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Questions

What does INCI stand for?

International Nomenclature of Cosmetic Ingredients: a standard naming system for cosmetic ingredients used on labels in many countries.

In what order do ingredients go?

In descending order of weight at the time they are added. In the EU, ingredients under 1% can be listed in any order after those above 1%, and colourants can go at the end.

Do I have to list fragrance allergens?

In the EU and UK, certain fragrance allergens must be listed by name above set concentrations. The EU list is being expanded. In the US, MoCRA directs the FDA to set fragrance allergen labelling rules.

What if the list does not fit on the pack?

The rules allow the list to appear on an outer carton, or on an enclosed leaflet or tag for very small products in some cases. Plan this with your adviser.