Allergen INCI Names vs Common Names on the Label

A maker emailed us last month convinced her label was fine because she'd written "contains clove oil" in the allergen line. It isn't fine, not on its own. Clove oil is a trade description of a botanical extract, and the allergen that regulators actually track inside it is Eugenol, listed by its INCI name. If your label says clove oil and nothing else, you haven't disclosed the allergen at all in the form the rules expect.

This mix-up shows up constantly with essential oils, because the marketing name and the regulatory name live in two different worlds.

Two naming systems, two different jobs

The common name on your ingredients page is there to tell a customer what plant or process the ingredient came from. Lavender oil, ylang ylang, bergamot. Those names are useful and you should keep using them where they help customers understand your product.

The INCI name is a different thing entirely. INCI stands for International Nomenclature of Cosmetic Ingredients, and it's the standardized system regulators, retailers, and other formulators all read the same way regardless of language or supplier. Water is Aqua under INCI no matter what country you're filing in. That standardization is exactly why regulatory filings, including Canada's Cosmetic Notification Form, ask for INCI names rather than trade names or common names.

Essential oils are where this gets tricky, because a single oil is really a cocktail of named allergenic constituents, and it's those constituents, not the oil itself, that show up on the disclosure list.

What's actually inside "clove oil"

Common name on label	What it actually contains for allergen purposes	INCI name for the allergen
Clove oil	Eugenol is a major constituent	Eugenol
Cinnamon leaf oil	Eugenol again, plus others	Eugenol
Citrus peel oils (bergamot, lemon, orange)	Limonene	Limonene
Lavender, coriander, many florals	Linalool	Linalool
Rose, geranium, palmarosa	Geraniol and Citronellol	Geraniol, Citronellol
Tonka bean, some vanilla-adjacent notes	Coumarin	Coumarin

Notice the pattern. Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin are named allergens that occur naturally across dozens of common essential oils, and none of those oils are exempt just because the allergen wasn't added on purpose. Naturally occurring counts the same as deliberately added.

Why this matters more starting in 2026

Canada is tightening this specifically. The original fragrance allergen set, referred to as List 1, becomes mandatory on both the CNF and the product label on April 12, 2026. A second, expanded set aligned with international allergen lists, List 2, becomes mandatory August 1, 2026. Disclosure is triggered above 0.001 percent (10 ppm) in leave-on products and above 0.01 percent (100 ppm) in rinse-off products, which are low thresholds that most fragranced or essential-oil-scented products will cross without anyone trying.

If your supplier's certificate of analysis only says "rosemary essential oil, 100 percent pure," you still need the constituent breakdown to know whether it's carrying Limonene or Linalool over threshold. Ask your supplier for a full GC-MS or constituent analysis, not just a purity statement. Most reputable suppliers already have this on file.

Getting the translation right

A few practical habits:

1. Keep a running reference sheet mapping every essential oil and fragrance blend you use to its known allergen constituents and approximate percentages.
2. Multiply the constituent percentage in the raw material by your use level in the finished product. A 2 percent lavender oil addition with 30 percent linalool content in the oil works out to 0.6 percent linalool, which is well above either threshold.
3. List the allergen by its INCI name, separately, in addition to (not instead of) your normal ingredient declaration.
4. Don't assume "natural" or "essential oil" language on a label substitutes for allergen-specific disclosure. It doesn't, and it never has.

This is one of those areas where a spreadsheet error is easy to make and easy to miss until a regulator or a retailer's compliance team flags it. Cosmetic Comply's ingredient matching step is built for exactly this kind of translation. It takes what you actually put in the batch, including your essential oil blends, and maps each one through to the INCI names and thresholds that need to appear, so common names and INCI names stop being two separate problems you have to reconcile by hand.