INCI Labeling Requirements: US & EU Rules Explained

Quick Answer

INCI labeling requirements demand that every cosmetic ingredient appear by its International Nomenclature of Cosmetic Ingredients name, listed in descending order of weight, with ingredients at 1% or less permitted in any order after those above 1%. 

The United States enforces this through 21 CFR 701.3 and sets a minimum type height of 1/16 inch, while the European Union applies Article 19 of Regulation 1223/2009 and requires only that characters be indelible, easily legible, and visible. Colorants are listed last in any order, identified by CI number in the EU.

Introduction

The ingredient list is the most legally exposed piece of text on a cosmetic package. Getting INCI labeling requirements wrong turns a compliant product into a misbranded one, and this is where small brands are caught more often than anywhere else.

This guide explains the rules in plain terms, though it is general information rather than legal advice, so verify specifics with your regulator before printing.

I have reviewed labels where the ingredient order was built from the recipe sheet rather than the finished weight, which quietly misstated the whole formula. The rules are precise, and they reward formulators who understand why each one exists.

By the end you will know how to write a correct INCI list, how ordering and the 1% threshold work, how the USA and EU rules differ, and which naming conventions apply to botanicals, colorants, and fragrance.

What INCI Actually Is?

INCI, the International Nomenclature of Cosmetic Ingredients, is a standardised naming system that gives every cosmetic ingredient one consistent identifier worldwide. It exists so a consumer or clinician in any country can identify an ingredient regardless of the label’s language.

The nomenclature is maintained by the Personal Care Products Council and published in the International Cosmetic Ingredient Dictionary and Handbook. The EU mirrors these names in its CosIng database, which is where formulators check current status.

INCI names are not translated. Aqua stays Aqua and Butyrospermum Parkii stays Butyrospermum Parkii, which is precisely the point of a standardised system.

The Core Ordering Rules

Ingredient order is the rule most often broken, and it follows the weight of each ingredient in the finished product rather than the order you added them. Three tiers govern the list.

Ingredients present above 1% are listed first, in strict descending order of weight. Ingredients present at 1% or less may then follow in any order, which gives formulators freedom over the tail of the list.

Colorants sit last. They may appear in any order at the end of the declaration, regardless of concentration, since their weight tells the consumer nothing useful.

That 1% threshold is the practical hinge of the whole list. Above it, order is mandatory and audit-checkable, and below it, you choose.

Writing Your First INCI List

Building a list correctly is a sequence, not a guess. Follow these steps, and the result will hold up to scrutiny.

1. Take the finished formula percentages, not the batch sheet order.
2. Separate colorants from everything else.
3. Split remaining ingredients into those above 1% and those at 1% or less.
4. Order the above-1% group strictly by descending weight.
5. Append the 1%-or-less group in any order you choose.
6. Append colorants last, using CI numbers where the EU applies.
7. Declare fragrance as Parfum or Fragrance, and flavour as Aroma or Flavour.

Compound raw materials need unpacking. If a supplier sells you a blended preservative or an extract in a glycerin carrier, you declare its individual components at their true finished concentrations rather than the trade name.

That unpacking step is where most first attempts fail. The trade name on the drum is a commercial label, and the INCI list must show what is actually in the jar.

INCI Names for Natural and Botanical Ingredients

Botanical ingredients follow the Linnaean binomial, giving genus and species in Latin. Shea butter appears as Butyrospermum Parkii Butter, and lavender oil appears as Lavandula Angustifolia Oil, with the plant part and processing method forming part of the name.

Many labels add a common name in parentheses for consumer clarity, such as Butyrospermum Parkii (Shea) Butter. This is a widely accepted convention rather than a substitute for the Latin binomial, which must always be present.

Natural does not mean exempt. A cold-pressed oil, a botanical extract, and a synthetic ester all carry equal INCI obligations, and no marketing term changes what the list must show.

Fragrance, Colorants, and Nanomaterials

Fragrance compositions are declared under the single term Parfum in the EU or Fragrance in the USA, which protects the formulation as a trade secret. That umbrella has limits, since specified fragrance allergens must be named individually above defined thresholds.

EU allergen disclosure is expanding significantly. Eighty allergens must be declared individually above 0.001% in leave-on and 0.01% in rinse-off products, with compliance required for products placed on the market from 31 July 2026 and existing stock saleable until 31 July 2028.

Colorants take Colour Index numbers in the EU, written as CI followed by five digits. The USA instead uses the FDA-approved colour additive names, such as D&C Red No. 6.

Nanomaterials carry their own EU flag. Any ingredient present in nanoform must be followed by the word nano in square brackets, immediately after its INCI name.

INCI Labeling Rules: USA Versus EU

Both systems share the same logic and diverge in the details. The table below compares the points that most often trip up brands selling across the Atlantic.

Many brands print a hybrid list to serve both markets, writing Aqua/Water and Parfum/Fragrance. That practice is common and widely accepted, though the surrounding label must still satisfy each market’s own rules.

Typeface Size and Placement for INCI

The USA is prescriptive here. The ingredient declaration must appear on an information panel in letters no less than 1/16 of an inch in height, dropping to 1/32 of an inch only where the available labelling surface is under 12 square inches.

The EU takes a different approach, setting no numeric minimum. Article 19 instead requires that the information be indelible, easily legible, and visible, which places the burden on demonstrable legibility rather than a measured height.

Legibility is not a formality in either system. A reduced type size is a regulatory accommodation for small packages, never a licence to make the list unreadable.

Placement matters too. The declaration must sit where a consumer can find it at the point of purchase, without decoration or crowding obscuring the text.

Multilingual Labelling of INCI

INCI names themselves never change across languages, which is the system’s entire purpose. What changes is the surrounding text.

In the EU, the language of mandatory label information is determined by the law of the member state where the product is made available. The heading Ingredients may therefore be translated, while the names beneath it remain in standardised INCI form.

Warnings, the product function, and the period-after-opening statement usually need translation for each market. Brands selling across several countries often print multilingual panels or use a peel-back label to fit everything legibly, an approach worth planning before artwork is finalised.

Common INCI Labeling Mistakes

Label errors follow predictable patterns, and each mistake below carries a direct fix. Correcting these before print is far cheaper than reprinting a batch.

The first mistake is ordering ingredients by the batch sheet rather than the finished weight. Manufacturing order feels natural, so rebuild the list from the final formula percentages instead.

Declaring a supplier trade name is a second error. A blended preservative or carrier-based extract is not a single ingredient, so break it into its component INCI names at their true concentrations.

Misplacing the 1% threshold is a third mistake. Formulators guess where the cut falls, so calculate it from the actual formula and order everything above it strictly.

Listing colorants in the main sequence is a fourth error. Their weight is not informative, so move them to the end of the declaration in any order.

Using only a common name for a botanical is a fifth mistake. Shea Butter alone is not compliant, so give the Latin binomial and add the common name in parentheses if you wish.

The sixth error is setting type below the legal minimum on small packages. Designers shrink text to fit, so use the permitted reduced size only where the surface qualifies and keep the result genuinely legible, a discipline resources like Formula Chemistry stress before any artwork goes to press.

Which Rules Apply to You

A brand selling only in the USA follows 21 CFR 701.3, uses FDA colour additive names, writes Fragrance and Water, and meets the 1/16 inch type minimum in English.

A brand selling only in the EU follows Article 19, heads the list with Ingredients, uses CI numbers, writes Parfum and Aqua, tags nanomaterials, and satisfies legibility rather than a fixed height.

Brands selling into both markets should design one label that satisfies the stricter requirements on each point. That usually means EU-style naming with US type sizing, checked separately against each jurisdiction.

Whatever your market, build the list from the finished formula and check every name against the current nomenclature. To start, rewrite your ingredient list from actual percentages today and verify each INCI name before your next print run.

Frequently Asked Questions

INCI labeling requirements rest on one principle: every ingredient is named in standardized form, ordered by finished weight, with a 1% threshold below which order becomes free. Colorants go last, and fragrance sits under a single umbrella term.

The USA and EU share this logic but differ on headings, colorant naming, water and fragrance terms, nanomaterial tagging, type size, and language. Selling into both markets means meeting the stricter requirements on each point.

Build every list from the finished formula rather than the batch sheet, and unpack compound raw materials into their true components. To act now, recalculate your 1% threshold, verify each INCI name against the current nomenclature, and confirm your type size before artwork goes to print.

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