An INCI list is not a simple copy of the manufacturing formula. Accurate labelling requires the composition of every raw material, correct ingredient names and calculation at finished-product level.
From raw-material formula to finished-product composition
A manufacturing formula often lists trade names, while the label must show the components of those materials under appropriate common ingredient names. Every mixture needs to be expanded using supplier documentation.
Reliable calculation requires both the use level of the raw material and its composition. Ranges must be handled carefully so that the order and presence of ingredients are not misrepresented.
Ingredient order and the one-per-cent threshold
Ingredients are generally listed in descending order by weight at the time they are added. Ingredients present at one per cent or less may be listed in another order after those above the threshold.
The threshold applies to the ingredient in the finished product, not the trade raw material. The same ingredient may enter through several raw materials and must be totalled correctly.
Practical checkpoint
Every conclusion should be linked to the exact formula, document and market-material version. This makes it possible to demonstrate which evidence supported the regulatory decision.
Fragrances, allergens, colorants and nanomaterials
Fragrance and aromatic compositions are generally identified by the appropriate terms, while individual fragrance allergens are listed when applicable thresholds are exceeded. Current supplier data and a finished-product calculation are essential.
Special rules may apply to colorants, particularly shade ranges. Ingredients present in nanomaterial form are identified by the required ingredient name followed by the word nano in brackets.
Botanical ingredients and name verification
Botanical names should reflect the species, plant part and preparation. A marketing name for an extract is not necessarily the correct name for the ingredient list.
Names should be checked against current regulatory and nomenclature sources. A similar spelling is not enough, because different names may represent a different material or ingredient form.
Version control and final verification
The INCI list must be tied to the exact quantitative formula and raw-material documentation version. A supplier change can alter composition even when the commercial function remains the same.
Final review compares the manufacturing formula, calculation, CPSR, artwork and CPNP information. Decisions on order and special labelling should be documented.
Frequently asked questions
Can raw-material trade names appear instead of ingredient names?
No. Trade documentation helps determine composition but does not replace the required names used in the ingredient list.
Must every trace substance be listed?
It depends on whether the substance is an ingredient, impurity or technically unavoidable trace; classification requires evidence and the applicable definitions.
Should an INCI list be reviewed after a supplier change?
Yes. Confirm whether composition, name, concentration or supporting documentation has changed.
Official sources and further reading
This article is for general information and does not replace an assessment of the specific product, formula and supply chain. Legislation and guidance may change after publication.