INCI Names & CAS Numbers

Water, Aqua, or Eau: Which One Goes on Your CNF

Health Canada wants Aqua on the ingredient list, not Water. Here is why the trilingual convention exists and how to get it right on your CNF.

Diane R.3 min read

You'd think the simplest ingredient in your formula would cause zero confusion. Then you sit down to fill out a Cosmetic Notification Form and realize you're not sure whether to type Water, Aqua, or Eau, and whether it even matters.

It does matter, a little, and it's worth understanding why before you file.

Why Aqua Shows Up Instead of Water

INCI, the International Nomenclature of Cosmetic Ingredients, is built to work across languages without a translation step at every border. Instead of naming water in English, French, German, and everything else, the system picked one Latin-derived term, Aqua, and uses it everywhere. That's the same logic behind naming plant extracts in Latin binomials rather than common names. One label works globally without a re-translation cycle for every ingredient.

So on an INCI-formatted ingredient list, water is Aqua. Not Water, not H2O, not Eau. Aqua.

You'll sometimes see "Aqua (Water)" or "Aqua/Water/Eau" printed on international labels, especially products sold in North America and Europe from the same production run. That trilingual format exists because different markets have historically wanted the common-language term visible alongside the INCI name. Canada's bilingual labeling requirement is part of why you see the English and French versions sitting right next to the INCI term on products sold here.

What Health Canada Actually Wants on the CNF

The Cosmetic Notification Form asks for ingredients by INCI name. That means Aqua is the correct entry for your water content, regardless of what your finished product label says in plain English or French. The label is a separate labeling exercise governed by its own bilingual requirement. The CNF entry is about identifying the substance correctly in a standardized international vocabulary that a regulator, or another company's compliance team, can recognize instantly.

If you've been typing "Water" into the ingredient field out of habit, it's not going to sink your notification by itself, but it's a small inconsistency that makes your filing look less careful, and it can cause mismatches if you're ever cross-referencing your CNF against your own supplier documentation, which almost certainly lists Aqua.

A Quick Reference

Term Where you'll see it Correct for CNF?
Aqua INCI ingredient list Yes
Water Plain-English label text, common usage No, not as the INCI entry
Eau French label text No, not as the INCI entry
Aqua/Water/Eau Trilingual label format The label format is fine; the CNF entry is still just Aqua
H2O Never appropriate on a cosmetic label or filing No

Where This Gets Slightly Trickier

A few real-world wrinkles worth flagging:

  • Distilled, deionized, or spring water are still all Aqua on the INCI list. The purification method doesn't change the INCI name; if you want to communicate that detail, it goes in your marketing copy, not your ingredient declaration.
  • Floral waters and hydrosols are a different ingredient entirely, with their own INCI names (rose water, for instance, has its own designation), so don't collapse those into plain Aqua.
  • Supplier premixes that are mostly water, like many preservative blends or thickener dispersions, will list Aqua as one of several components. When you're calculating your finished product's actual water percentage, you need to add up the water contributed by every blend, not just your bulk water addition.

The Broader Habit This Builds

Getting Aqua right is a small thing, but it's a useful entry point into the bigger discipline INCI naming asks of you: map everything to its standardized name before you file anything, and don't let a trade name or a common-language habit slip into a regulatory document. That habit pays off most when you're working through a supplier's proprietary blend and need to expand it into its real components and concentrations, which is where filings actually go wrong.

Cosmetic Comply handles that mapping automatically when you upload your formula, matching each ingredient, including the humble water line, to its correct INCI name and CAS number before anything gets screened or filed. It's a small detail, but small details are exactly what a regulator's review catches.

READY TO FILE?

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