citation of the function “skin protectant” for an ingredient that
is not an OTC Category I Skin Protectant in the United States).
If during the process of making an ingredient, a filter aid,
decolorizing/deodorizing activated carbon, or other component is introduced and subsequently removed, it is not considered part of the final composition. If ingredients are added
and react to form another ingredient (for example, adding lactic acid and sodium hydroxide to make in-situ sodium lactate),
the individual components do not have to be listed separately
(except in polymer naming protocol); instead, the newly formed
ingredient could be considered part of the composition. If the
ingredient is present as a small residual component of the composition but does not contribute to its functionality, it usually does not become part of the final ingredient composition.
Examples of situations in which non-functional residuals are
not considered part of the blend/mixture composition include:
( 1) small amounts of preservative that allow for safe shipping
and storage of the ingredient but represent a very small nonfunctioning part of the final composition; ( 2) small amounts of
emulsifiers that keep the ingredient in suspension for ease of
use and storage—although most companies today include suspension ingredients in the blend/mixture composition of the
product nomenclature; and ( 3) unreacted starting ingredients
or excess of one ingredient to drive the reaction to completion
that are considered a minor portion of the composition—such
ingredients are usually not considered as separate component
of a blend/mixture, although this is a gray area.
The declaration of ingredients on cosmetic products back
label ingredient statement lists ingredients in order of predomi-
nance. Ingredients that are equal to or below a concentration
of 1% may be declared in any order. Colors are also listed in
random order at the end of the ingredient declaration.
Whether the presence of a large amount of an incidental should
be identified in the INCI name and/or declared in the ingre-
dient listing is debatable. As a general rule, FDA advises that
when there is doubt about whether the ingredient is truly inci-
dental, the ingredient should be declared in the ingredient list-
ing. Flavors and fragrances may be listed by these terms in
their respective descending order. The labeling of OTC drugs
and cosmetic drugs follow special requirements not covered in
this article. In these cases, readers are directed to consult the
appropriate OTC drug labeling regulations, or the CTFA Label-
INC follows written conventions which are extensively
covered in the Dictionary/Handbook Introduction in Volume
1 page xxii (as well as contained in the On-Line). These conventions are guidelines to assure consistency of assignments,
although the committee occasionally modifies them or adds
new ones. To help clarify how names are assigned, the key
conventions are summarized on page 60.
Eric Abrutyn has more than 45 years of experience in the personal care cosmetics industry. He is a member of the Technical Advisory Board and past-contributing editor for Cosmetics
& Toiletries magazine, a contributing author and instructor for
SpecialChem4Cosmetics, and a member (and past chair) of the
International Nomenclature Committee (INC)—part of Personal
Care Products Council’s (formerly C TFA). Abrutyn founded the
consulting firm TPC2Advisor’s Ltd., Inc, which provides technical
support to clients in the cosmetics and personal care industries.
He can be contacted at email@example.com.
Fig. 1. INcI application process flowchart
optional based on
INcI ApplIcAtION REvIEW pROcEss