INCI List Preparation & Review

Why the ingredient list is where labels fail

Under Article 19 of Regulation (EC) No 1223/2009, every cosmetic product on the EU market must declare its ingredients using INCI names — the International Nomenclature of Cosmetic Ingredients — in descending order of weight at the time of addition. It sounds simple. In practice it is the single most common labelling defect we see.

Trade names instead of INCI names. Ingredients listed in the order the manufacturer happened to write them. Fragrance allergens buried inside “parfum” when they exceed the declaration threshold. Colourants scattered through the list instead of grouped at the end. Any one of these makes the label non-compliant.

What we do with your formulation

You send us your formulation with percentages. We return a list you can hand straight to your designer:

• Nomenclature — each raw material resolved to its correct INCI name, including compound raw materials broken down into their constituents.
• Order — descending by weight, with ingredients at or below 1% correctly placed in any order after the 1% threshold.
• Fragrance allergens — the declarable allergens named individually where they exceed 0.001% in leave-on or 0.01% in rinse-off products.
• Colourants — grouped and expressed as CI numbers, with the shade-range convention where applicable.
• Restricted substances — anything caught by Annexes II to VI flagged, with the applicable limit and any mandatory warning.

The allergen list is expanding

Regulation (EU) 2023/1545 raises the number of individually declarable fragrance allergens from 26 to over 80. Products placed on the market must comply from 2026, with a sell-through period for existing stock. If your artwork was written against the old list of 26, it is already out of date — we check against the new list.