Surfactants and Function Codes for a Shampoo Notification

A basic shampoo looks simple on the bottle, water, a couple of cleansing agents, maybe a conditioning ingredient and a fragrance. Then you actually sit down to file it and realize that "cleansing agent" was never one ingredient, it was a supplier blend hiding three or four INCI names, each needing its own line.

Start with what a surfactant blend actually contains

Most shampoo bases sold to small and mid-size makers aren't a single surfactant. They're pre-blended systems, something like a sodium laureth sulfate and cocamidopropyl betaine combination sold under a trade name, formulated to balance cleansing power against mildness. Trade names never appear on a Cosmetic Notification Form filing. You have to map the blend back to its actual INCI components and carry each one's real concentration through into your formula.

That math is straightforward but easy to get wrong. If your base is 40% total active surfactant and you're using that base at 15% of your finished shampoo, the actual surfactant concentration in your product is 6%, not 40% and not 15%. And if the blend itself is a mix, say 70% of that 40% active is sodium laureth sulfate and 30% is cocamidopropyl betaine, you need to break that down further to get each individual INCI name's real percentage in the finished bottle.

A typical shampoo's INCI breakdown

Here's the kind of ingredient list a simple cleansing shampoo often reduces to once you've done the mapping, using illustrative values rather than a specific formula, since your actual concentrations depend entirely on your supplier's blend ratios:

INCI name	Typical function	Notes for filing
Aqua	Solvent/base	Water is always listed as Aqua
Sodium Laureth Sulfate	Primary surfactant/cleansing agent	Concentration depends on blend dilution math
Cocamidopropyl Betaine	Secondary surfactant, mildness	Often paired with SLES in blends
Glycerin	Humectant	May be a standalone addition or part of a blend
Polyquaternium (various types)	Conditioning agent	INCI varies by specific polymer used
Citric Acid	pH adjuster	Small percentage, easy to overlook on a filing
Sodium Chloride	Viscosity/thickening	Common in surfactant systems, sometimes forgotten
Fragrance components	Scent	Subject to allergen disclosure above threshold
Preservative system	Antimicrobial	Check Hotlist concentration limits

Every one of these needs its own INCI name and concentration on the CNF. There's no shortcut where a whole trade-named base gets listed as one line.

Where people miss ingredients entirely

The ingredients that get forgotten aren't usually the big surfactants, those are obvious enough that people remember to map them. It's the small functional additions: the pH adjuster added at under half a percent, the salt used purely to thicken the surfactant system, the tiny amount of a chelating agent added to stabilize the formula against hard water or trace metals. These are real ingredients in real concentrations, and the CNF expects them listed just like the big ones. A filing that only lists the surfactants and skips the pH adjuster and viscosity modifier is an incomplete filing.

The Hotlist check still applies

Once you have your full INCI breakdown, each ingredient needs checking against the Cosmetic Ingredient Hotlist, the same as any other product category. Fragrance components in particular deserve attention given the upcoming allergen disclosure changes. List 1 fragrance allergens become mandatory on the CNF and label on April 12, 2026, and List 2, the expanded set aligned with international lists, follows on August 1, 2026. A shampoo is a rinse-off product, so the disclosure trigger is above 0.01% (100 ppm), a higher threshold than leave-on products, but if your fragrance blend includes common allergens like limonene or linalool from essential oils, it's worth checking the actual percentage against that threshold rather than assuming a rinse-off product is automatically exempt.

Amendments when you reformulate

If you tweak the surfactant ratio later, swap in a different conditioning polymer, or change your fragrance supplier, that's a formula change requiring an amendment to your existing CNF filing, not a fresh filing from scratch, as long as the product itself hasn't been discontinued and relaunched under new branding. Keeping your original ingredient breakdown well documented makes that amendment much faster, since you're updating specific lines rather than rebuilding the whole mapping exercise.

This is the kind of ingredient-level work Cosmetic Comply is built to handle, taking a shampoo's full ingredient list, including supplier surfactant blends, expanding them into INCI names and CAS numbers with real concentrations, screening against the Hotlist with a confidence score, and having a human reviewer confirm it before filing. It also lets you duplicate a past filing when you're launching a minor variant, a new scent or a slightly adjusted conditioning system, rather than starting the whole breakdown over.