Ingredient Labeling Compliance

Achieving regulatory compliance for a cosmetic product hinges significantly on accurate and standardized ingredient labeling. The cosmetic label serves as the primary communication tool between the manufacturer and the consumer, providing necessary details for safety, use, and informed purchasing decisions.¹ Strict adherence to established labeling requirements, particularly those set by the EU (Regulation EC No 1223/2009), is mandatory.

The INCI Standard: Uniformity is Key

The most critical rule in cosmetic labeling is the mandatory use of $\text{INCI}$ (International Nomenclature of Cosmetic Ingredients) names. This global standard ensures that the same ingredient is listed identically across all markets, regardless of the local language.² For instance, water is always listed as “Aqua,” and a common preservative is listed by its chemical name, not a brand name.³

Ingredients must be listed in descending order of weight or concentration at the time the product is compounded. This means the ingredient present in the highest amount (usually water) appears first, and the ingredient present in the smallest amount appears last.

Special Rules for Low-Concentration Ingredients and Colorants

There are specific exceptions to the descending order rule designed to manage the complexity of formulations:

1. Ingredients Below 1%: Any ingredient present at a concentration of less than ⁴$1\%$ can be listed in any order after the ingredients present at ⁵$1\%$ or more.⁶ This prevents minor adjustments in very low-level components from forcing a complete re-sequencing of the entire list.
2. Colorants: Color additives, which are present in varying amounts depending on the specific shade, are always listed last.⁷ They must be identified using their ⁸$\text{CI}$ (Colour Index) number (e.g., ⁹$\text{CI } 77891$ for Titanium Dioxide).¹⁰ For products sold in multiple shades (like foundations or lipsticks), all colorants used across the entire product line may be listed at the end, preceded by the words “May contain” or the symbol ¹¹$[\pm]$.¹²
3. Perfume and Aroma Compounds: These are typically grouped under the blanket term “Parfum” (or “Aroma” for flavoring agents).¹³ However, if the fragrance includes any of the specific, highly allergenic fragrance ingredients identified in Annex $\text{III}$ of the EU regulation, those individual chemicals must also be listed separately if they exceed a certain trace threshold.

Placement and Label Elements

The entire list of cosmetic ingredients must be clear, legible, and indelible on the cosmetic packaging. If the packaging is too small to display the full list (e.g., a small lipstick tube), the list must be included on an attached leaflet, tag, or strip, and the primary packaging must then display the “Refer to Enclosed Information” symbol (an open hand pointing to a book).

In summary, successful Ingredient Labeling Compliance requires meticulous accuracy, strict adherence to the $\text{INCI}$ nomenclature, correct sequencing, and the proper use of all required label elements to ensure the cosmetic label provides complete and accurate information to every consumer.