Filing a Premade Lotion or Soap Base by Its INCI

You bought a shea butter lotion base, or a melt and pour block, added your own scent and color, and now you need to file. The problem is your invoice says "moisturizing lotion base" and nothing else. That is not an ingredient list. That is a product name. You need the actual INCI string before you can notify anything.

Start with the supplier, not the internet

Do not guess the composition of a base from a similar-sounding product you found online. Two suppliers can sell what looks like the same "white lotion base" with different preservatives, different emulsifiers, and different trace allergens from their fragrance-free fixative. You need the specific document from the specific supplier for the specific lot family you are using.

Ask for one of these, in order of usefulness:

1. A certificate of composition or a full INCI declaration. This is the cleanest document. It lists every component by INCI name, usually with a percentage or a range.
2. A safety data sheet (SDS). Section 3, composition and information on ingredients, will list hazardous components by name and CAS number. It will not always list everything, since non-hazardous ingredients like water or many emollients do not need to appear in section 3. Use it as a supplement, not a replacement.
3. A technical data sheet. Often marketing-flavored, but sometimes includes the INCI list.

If the supplier only gives you a product name and a smiling description of how nourishing it is, ask directly for the INCI declaration. Reputable suppliers have this on file. If they will not produce it, that is a sign to find a different supplier, because you cannot file what you cannot document.

Reading what you get back

A typical melt and pour or lotion base INCI list might look like this on paper:

INCI name	Typical function	Notes
Aqua	Solvent	Often the largest ingredient by weight
Glycerin	Humectant	Common, low concern
Sodium Cocoate	Cleansing agent (soap base)	Saponified coconut oil
Cetearyl Alcohol	Emulsifier/thickener	Not a drying alcohol despite the name
Butyrospermum Parkii (Shea) Butter	Emollient
Phenoxyethanol	Preservative	Has its own restrictions in most markets
Parfum	Fragrance	Umbrella term, may hide allergens

That last row is where people get stuck. If the base already contains "Parfum" from the supplier's own fragrance-free-but-not-really formulation, or if it contains a mild proprietary scent, you need to know what allergens are inside that fragrance blanket term, not just that it exists. Ask the supplier for the allergen breakdown of any fragrance component in their base. If you are also adding your own essential oil or fragrance oil on top, those two sources of allergens combine and need to be assessed together against the finished product's total concentration.

Multiply, do not just append

If the base itself is a blend, meaning a supplier ingredient that is really several INCI components sold under one trade name, you cannot just add its name to your list. You have to expand it into its components and multiply each one by how much of the blend you are using. If your base is 85% of your finished bar and the base's shea butter component sits at 12% of the base itself, then shea butter's real concentration in your finished product is roughly 10.2%, not 12%. This kind of expansion happens constantly with premade bases, and it is the step most home-based makers skip, usually because the math feels like busywork rather than because they are trying to cut corners.

What changes when you add to a base

Once you melt in your fragrance oil, your mica, your exfoliant, or your extra oils, the finished formula is now yours to notify, even though you did not build the base from scratch. In Canada, your Cosmetic Notification Form needs the complete finished-product ingredient list with concentrations or concentration ranges, not just the parts you personally weighed out. The base supplier's ingredients are just as much a part of your filing as your additions are.

Keep every supplier document you collect. If a regulator or a customer asks how you know your base does not contain something on the Cosmetic Ingredient Hotlist, "the supplier told me it smells natural" is not an answer. "Here is the INCI declaration and here is how it maps to the Hotlist" is.

A quick filing checklist for premade bases

• Get a full INCI declaration in writing, not a product name.
• Cross-check the SDS section 3 for anything the declaration might be missing.
• Ask specifically about fragrance allergen content inside any base fragrance.
• Expand any blend components and multiply by use level.
• Recalculate every percentage once your additions are mixed in, using the full finished-product weight as your denominator.

This is exactly the kind of grunt work Cosmetic Comply was built to shorten. Feed it your base's INCI list plus what you added, and it maps every component to its INCI name and CAS number, expands blends automatically, and flags anything that needs a closer look before you file.