How to List Water and Aqua on a Canadian CNF

First-time filers ask this one constantly, and it's a completely fair question. If water is just water, why does it need its own line, and why does everyone write "Aqua" instead of just saying water like a normal person?

Aqua is the INCI name, and yes it needs a line

Water is still a formulation ingredient, even though it seems too obvious to count. Under the INCI system, the standardized name for water is Aqua, which is simply the Latin word, consistent with how INCI treats other ingredients through their scientific or standardized naming rather than the casual English term. So when you're filling out your Cosmetic Notification Form, water goes in as "Aqua," not "Water," even though your customers will see "Water" or both terms on the retail label.

If your product contains water at all, meaning almost any lotion, cream, liquid soap, shampoo, or spray, it needs its own ingredient line on the CNF like every other component. There's no exemption for water just because it seems like a non-ingredient.

Concentration reporting for water

The CNF asks for ingredients listed with a concentration or a concentration range. Water is very often your highest-percentage ingredient by far, sometimes 60 to 90 percent of a formula depending on what you're making. You report it the same way you'd report any other ingredient's concentration, as an actual percentage or an appropriate range reflecting your formula.

A practical note: if you reformulate slightly and your water percentage shifts because you adjusted an active or an oil phase, that's the kind of change that may call for an amendment, since the notification is meant to reflect your actual current formula, not a rough approximation from whenever you first filed.

What about other simple diluents?

Water isn't the only "obvious" ingredient that beginners sometimes think doesn't need declaring. The same logic applies to:

• Alcohol used as a solvent or carrier, INCI name Alcohol or Alcohol Denat. depending on whether it's denatured, which needs its own line just like any active or oil.
• Any carrier or diluent used to dissolve or dilute an active, a fragrance, or a preservative before it's blended into your main batch. If you diluted a preservative in propylene glycol before adding it to your cream, both the preservative and the propylene glycol need to appear, at their actual final concentrations in the finished product, not just the preservative alone.
• Aqueous extracts. If your "rose water" is actually Aqua plus Rosa damascena flower extract, or if it's a genuine hydrosol with its own distinct composition, you need to know which one you actually bought and declare accordingly, since these are not interchangeable declarations even though they're often marketed with overlapping names.

A quick example

Say you're making a simple lotion. Your formula sheet might read something like this before translation to INCI:

Formula sheet term	INCI declaration	Approx. concentration
Water	Aqua	70%
Shea butter	Butyrospermum Parkii Butter	10%
Emulsifying wax	(varies by specific wax blend, check supplier INCI)	5%
Preservative blend	(declare each component INCI separately)	1%
Fragrance oil	Parfum, plus any disclosed allergens above threshold	1%
Remaining oils/actives	Individual INCI names	Remainder

Notice water sits right at the top as the highest-percentage ingredient, listed plainly as Aqua, same formatting expectation as everything below it.

Why this trips up new filers specifically

I think the confusion comes from retail labeling conventions bleeding into notification expectations. On a store shelf, ingredient lists are sometimes ordered by descending concentration with water first and unmistakably labeled "Water" for consumer clarity, sometimes with "(Aqua)" following in parentheses. That's a labeling convention, and it's genuinely helpful for consumers. But the underlying regulatory declaration, the one that goes into the notification system itself, wants the INCI term, Aqua, not the consumer-facing English word, even if both appear together on your actual product packaging.

Once you've filed one product with your water declaration handled correctly, every future product mostly repeats this same simple step. It's a good template to nail early, since it sets the pattern for how you'll declare every subsequent common ingredient in your line.

If you're filing a first product and want the concentration math and INCI mapping double-checked before you submit, that's a core piece of what Cosmetic Comply handles: it takes your actual formula, maps every ingredient including the obvious ones like water to its correct INCI name, and carries the real percentages through to the notification.