Getting INCI Names Right on Your EU Ingredient List

A supplier data sheet says "Emulium Delta." Your label needs something else entirely. That gap between what a formulator buys and what a consumer reads on the back of a jar is exactly what INCI exists to close, and it trips up more new brands than any other single labeling requirement.

INCI stands for International Nomenclature of Cosmetic Ingredients. It is the standardized naming system used across most major markets so that a given chemical or botanical extract has one recognized name regardless of which supplier sold it to you or what marketing name they gave it. Water, for instance, is always Aqua on an ingredient list, never "purified water" or "aqua distillata." That consistency is the whole point. A regulator, a competitor, or an allergic consumer in Lisbon should be able to read the same name a regulator in Warsaw would recognize.

Why trade names never make it onto a filing

Raw material suppliers love catchy names because that is how they differentiate blends and market them to formulators. But a blend sold under a trade name is rarely a single substance. It is usually two, three, or more INCI-listed ingredients combined at specific ratios. When you notify a product through the CPNP portal under Regulation (EC) No 1223/2009, you cannot list the trade name. You have to break the blend down into its individual INCI components and carry each one's real concentration in the finished product through to your ingredient list and your Product Information File.

This means asking your supplier for the full INCI declaration of any blend before you finalize a formula, not after. Some suppliers provide this readily. Others treat it as proprietary and only release it under an NDA. Either way, you need it before you can build an accurate ingredient list or safety report.

Descending order by weight, then the under-1-percent exception

Once every component has an INCI name, the next question is order. The default rule is straightforward: ingredients are listed in descending order by concentration, heaviest first. Your water phase almost always leads, followed by major emollients, then thickeners, then active ingredients, tapering down through preservatives and fragrance.

The exception that catches people is the 1 percent threshold. Once you reach ingredients present at or below 1 percent concentration, strict descending order is no longer required for that group. You can list everything under that threshold in any order you like, which in practice means most formulators group micro-dose ingredients like preservative boosters, chelators, and fragrance allergens together near the end of the list without agonizing over whether 0.3 percent should sit before or after 0.2 percent.

Colorants are their own case: they are conventionally listed at the end regardless of concentration, often marked with CI (Colour Index) numbers.

A worked example

Say you are formulating a lightweight facial serum:

Ingredient (INCI)	Approx. concentration	Position in list
Aqua	70%	First, water phase
Glycerin	8%	Early, humectant
Butylene Glycol	5%	Mid
Niacinamide	4%	Mid, active
Xanthan Gum	0.4%	Grouped, under 1%
Phenoxyethanol	0.8%	Grouped, under 1%
Limonene	0.02%	Grouped, allergen disclosure
CI 77891 (Titanium Dioxide)	0.1%	Last, colorant

Notice that Xanthan Gum, Phenoxyethanol, and Limonene are all under 1 percent, so their relative order among themselves is flexible even though Phenoxyethanol technically outweighs Limonene by a wide margin.

Where this connects to your CPSR and PIF

Getting the INCI list right is not just a labeling nicety. The same concentrations feed directly into the Cosmetic Product Safety Report that your Responsible Person's safety assessor signs off on, and they live in the Product Information File that must be available if a market surveillance authority asks for it. An ingredient list built loosely from trade names, with concentrations estimated rather than calculated from actual blend ratios, is the kind of thing that unravels during an audit.

If you are used to filing in a single-ingredient market and are now looking at the EU's CPNP process for the first time, budget real time for this conversion step. It is tedious but not conceptually hard, and getting it right the first time saves you from re-notifying later. Some teams handle the ingredient mapping themselves with spreadsheets; others use a tool like Cosmetic Comply to take a formula and automatically resolve trade names and blends into INCI and CAS with the concentrations carried through, which is exactly the kind of grunt work that benefits from automation once your product line grows past a handful of SKUs.