Declaring Ingredients in a UV-Cured Gel Nail Polish

Gel polish formulas confuse a lot of small nail brands because the ingredients doing the actual work, the acrylate monomers and the photoinitiator that makes the whole thing cure under a lamp, are chemically different from anything in a traditional air-dry lacquer. If you're used to nitrocellulose-based polish, gel is a different animal on paper as well as on the nail.

What's actually in a gel system

A typical UV or LED gel polish is built from oligomers and monomers, most commonly urethane acrylates or methacrylate esters, plus a photoinitiator that absorbs UV or visible light and kicks off the polymerization (curing) reaction. Color comes from pigments as in any polish. The base chemistry is closer to a UV-cured coating than to a solvent-based nail lacquer, and that changes what needs to show up on your ingredient declaration.

Photoinitiators need their own line

The photoinitiator is a functional ingredient, not a processing aid you can leave off the list. It has its own INCI name and CAS number like anything else, and it belongs on your Cosmetic Notification Form the same way a preservative or a colorant would. Get the exact INCI designation from your raw material supplier's technical data sheet or SDS, since photoinitiators are often sold under trade names that don't obviously map to their chemical identity.

Acrylate monomers and residual monomer

The oligomer or monomer backbone of the gel also needs INCI declaration. Where this gets more involved than a standard polish is residual, uncured monomer. Even a well-cured gel can retain trace unreacted monomer, and some acrylate-family substances have known sensitization potential when they contact skin repeatedly, which is part of why gel manicure allergies have become a recognized issue in the nail industry generally. That's a formulation and safety substantiation question as much as a labeling one, but from a filing standpoint it means being precise about which monomer or combination of monomers you're actually using, not just describing the product as "gel base."

Building the ingredient table

Here's a simplified way to think about what typically needs its own row:

Component type	Function	Needs own INCI/CAS line
Acrylate/methacrylate oligomer or monomer	Forms the cured film	Yes
Photoinitiator	Triggers UV/LED curing	Yes
Pigments/colorants	Color	Yes, per colorant
Film formers (nitrocellulose etc., if present)	Adhesion, flexibility	Yes
Solvents (if any carried over from base)	Application, leveling	Yes

Every row gets its actual INCI name and CAS number, not a supplier trade name for the "gel system" as a whole, for the same reason any premixed blend gets expanded into components: the Hotlist screen and the allergen check both work off INCI names, not trade names.

Is a gel polish a cosmetic or a drug in Canada?

Nail polish, gel or otherwise, is a cosmetic under the Food and Drugs Act and Cosmetic Regulations as long as it's not making a therapeutic claim. That means it goes through the standard Cosmetic Notification Form process: notify within 10 days of first sale, get a Cosmetic Notification (CN) number, list ingredients by INCI with concentration or a concentration range, and screen everything against the Cosmetic Ingredient Hotlist. There isn't a special gel-polish carve-out in the notification process itself. The complexity is entirely in getting the ingredient identification right before you file, since gel chemistry suppliers are less used to fielding INCI mapping questions than, say, a shea butter supplier is.

Base coat, color coat, top coat: one filing or several?

If you sell a gel system as separate SKUs, a clear base coat, a pigmented color, and a glossy top coat, each is typically a distinct formula with its own ingredient list and its own notification, even if they share a common oligomer backbone. Treat them the way you'd treat any other product line with shared raw materials: same due diligence on the shared components, separate filings per distinct formula.

Sourcing the INCI names with confidence

Ask your gel chemistry supplier directly for a full INCI breakdown of both the base and each additive, including the photoinitiator and any UV stabilizers. Nail-specific raw material suppliers deal with this request often enough that most can produce it without much friction. If a supplier can only offer a generic "proprietary gel system" answer, that's worth pushing back on before you file, not after.

Cosmetic Comply's ingredient matching handles this kind of mapping automatically, taking whatever the supplier calls something and resolving it to the correct INCI name and CAS number so the Hotlist screen has something real to check against, then carrying it through to a filed notification with a trackable CN number.