Turning Surfactant Trade Blends Into Filing-Ready INCI

If you've formulated a shampoo bar or liquid cleanser, you've probably bought something with a name like Plantapon or Miracare and just listed the trade name on your working formula sheet. That's fine for your own notes. It's not fine for a filing, because trade names never appear on a Cosmetic Notification Form. Every one of those blends is a mixture of individually named surfactants, and each one needs its own INCI line with its own real concentration.

Why trade names don't work on a filing

A supplier surfactant blend is a marketing product, not a chemical identity. Two blends with completely different names can share ingredients, and the same trade name can occasionally shift its exact composition between supplier updates. What Health Canada wants is the actual substances in your finished product, named in standardized INCI, with a concentration or concentration range for each. That means your job is to open the blend up and see what's actually inside it.

Where to find what's in the blend

Your supplier's technical data sheet or safety data sheet is the source. Section 3 of the SDS, Composition and Information on Ingredients, typically lists the components and often gives approximate ranges. If the documentation you have is thin, ask the supplier directly for the INCI breakdown and the percentage of each component in the blend as sold. This is a standard request in the trade and most suppliers have it ready.

A worked example

Say your shampoo bar formula calls for 8% of a coco-glucoside and glyceryl oleate blend sold under a common trade name, and the supplier's spec sheet shows the blend is composed as follows:

Component (as supplied)	Approximate share of blend
Coco-Glucoside	55%
Glyceryl Oleate	45%

To get the real concentration in your finished product, multiply the component's share of the blend by the blend's use level in your formula:

• Coco-Glucoside: 0.55 x 8% = 4.4% of finished product
• Glyceryl Oleate: 0.45 x 8% = 3.6% of finished product

Those are the two lines that go on your ingredient declaration and your CNF, not "8% surfactant blend." The same math applies to a Miracare-type amphoteric blend, which commonly expands into something like Cocamidopropyl Betaine plus a smaller carrier or stabilizer component, or a sulfate-free system that expands into a primary surfactant plus a co-surfactant and sometimes a small amount of a thickener or salt.

Common blend families and what tends to be inside

This isn't a substitute for your specific supplier's documentation, since exact ratios vary by product and can change, but it helps to know roughly what family of components you're looking for:

• Glucoside-based cleansers often expand into Coco-Glucoside or Decyl Glucoside plus a co-emulsifier like Glyceryl Oleate or Coco-Glucoside paired with Glyceryl Caprylate.
• Betaine-based blends typically center on Cocamidopropyl Betaine, sometimes with a small amount of residual amine or salt from the manufacturing process.
• Sulfate alternatives like sodium cocoyl isethionate systems often carry a co-surfactant and sometimes a small preservative already built in, which is easy to miss if you're not reading the full component list.

That last point matters more than it looks. A blend can quietly carry a preservative or a pH adjuster as a minor component, and if you don't expand the blend fully, that ingredient never makes it onto your filing at all. It's a common gap, not because anyone's being careless, but because a trade name reads like one ingredient when it's really three or four.

Rounding and ranges

Suppliers often give you a range rather than an exact number, something like "45 to 55%" for a component. When that happens, carry the range through the same multiplication and declare a concentration range on your CNF rather than picking one number arbitrarily. It's more honest to the filing and it also gives you flexibility if the supplier's ratio shifts slightly between lots without triggering an amendment every time.

Expanding blends by hand is tedious once you've got three or four of them stacked in one formula, and it's exactly the kind of arithmetic where a transposed percentage slips through unnoticed. Cosmetic Comply does this expansion automatically from your ingredient list and supplier documentation, carrying blend components through to their real finished-product percentage before anything gets screened against the Hotlist or filed.