Ingredient Declaration: Blended Ingredients

Blended ingredients are ingredients that you add to your cosmetic that contain specific individual components. Common blended ingredients are color additives (e.g. “colored mica”), preservatives, infusions or extracts, and some commercial products (example: BTMS-25 or some emulsifiers).

The regulations mandate that when listing ingredient declarations for cosmetics, all the ingredients must be listed, and that includes the components of a blended ingredient. In order to list them correctly, you must determine the percentage of each component in the whole.

It can take a little bit of math to figure out.

Where to Get the Amounts?

First, you need the percentages of the components in the blended ingredient.

When you purchase a blended ingredient you should be able to get that information from the supplier. It will be on the website in the product description, in the Safety Data Sheet, or in the Certificate of Analysis. If you can’t find it there, then ask for it.

Fragrance components don’t have to be disclosed, so it is unlikely that you will be given those. See Ingredient Declaration: Fragrance and Flavor for how to handle that.

You also are unlikely to get the components of color additives, but that’s okay since you can just list the color additive components at the tail end of the ingredient declaration anyway (see below).

Alternate Order of Ingredients

When you have blended ingredients, listing the alternate order of ingredients in your ingredient declaration can be helpful. It is:

  1. Ingredients present at more than 1% in descending order of predominance.
  2. Ingredients present at 1% or less in any order.
  3. Color additives, regardless of amount, in any order.

The benefit here is that you don’t really need to figure out the exact amount of a component if it is present at 1% or less, or if it is a color additive.

Calculating the Percentage of Components

The formula to figure out the percentage of a component in the whole is:

[ % ingredient in the whole]
x [ % component in the ingredient ]
————————————
= [ % component in the whole ]

Keep in mind that to multiply percentages, it’s easiest if you convert to decimal:

i.e. 40% = .40

Let’s say you used 4% BTMS-25 in your formulation. BTMS-25 is made up of 75% cetearyl alcohol and 25% behentrimonium methosulfate. Then your calculation for the cetearyl alcohol would be

.40 [4% – the percentage of BTMS-25 in the whole]
x .75 [ 75% – the percentage of cetearyl alcohol in the BTMS-25 ]
————————————
= .30 [ 3% – the percentage of cetearyl alcohol in the whole ]

You can use the same formula for figuring out any type of blended ingredient.

There are some special cases:

Infusions and Extracts

For infusions and extracts, the bulk of the material is removed. You soak your calendula petals in olive oil for “calendula-infused olive oil,” But you can’t possibly figure out the amount of calendula “goodness” that remains in the oil after you remove the petals. In that case, it is likely to be less than 1%, so you can place the extract portion in any order among the other ingredients present at 1% or less. The carrier (in this case the olive oil) is placed in the ingredient declaration based on its total percentage in the whole.

Note that the “extracted part” is always called “extract” regardless of whether it is an infusion, tea, extract, or tincture.

Preservatives

Usually, you can get the exact amount of the components of a commercial preservative. However, since they are typically used at 1% or less in your formulation, all of the components would be present at 1% or less as well. That makes it easy to place them in the ingredient declaration.

Why does it matter?

First off, a correct ingredient declaration is required by law and regulation. Technically, a product with an incorrect ingredient declaration is misbranded and therefore prohibited from being sold.

Secondly, consumers rely on the ingredient declaration to see what is in the product. They use it to determine if there are ingredients that they want, or don’t want–so accuracy is important to the consumer. When they feel confident that the ingredient declaration is correct, it builds trust.

Finally, presenting an incorrect ingredient declaration can also be considered “false and misleading.” At a state level, false and misleading statements on product packaging can lead not only to enforcement by officials, but to lawuits by consumers with over-active attorneys.

Bottom line: Make sure your ingredient declaration is correct, and that all the components of your blended ingredients are properly included in the ingredient declaration.

Marie-Gale-Consultant

Labeling, marketing, and compliance with the regulations can be confusing, but you don’t have to do it alone. Help is available through coaching, Zoom meetings, and more.

Comments

  1. Hi Marie, love your informative posts!

    I use lard in my soap recipe, and the ingredients are “Lard, Bha, Propyl Gallate and Citric Acid Added to Help Protect Flavor”. Assuming the last 3 ingredients are less than 1%.

    Can I list it on my ingredient label as “Lard (Bha, Propyl Gallate and Citric Acid Added to Help Protect Flavor)”? I don’t have the bandwidth to render my own lard or tallow so I need to buy lard that contains extra ingredients.

    Same with aloe juice, I use some aloe from my plants but need to supplement with store bought juice, which lists this for ingredients:
    Organic Aloe Vera Gel (Water and Aloe Vera Gel Concentrate), Citric Acid, Sodium Benzoate (A food preservative at 1/10 of 1%)

    Thank you for everything!

    1. Marie Gale

      It would not be correct to list the lard as “Lard (Bha, Propyl Gallate and Citric Acid Added to Help Protect Flavor)” (and the same for the aloe vera).

      You’d definitely need to list lard, water, and aloe vera gel concentrate in their correct amounts. (If you already have water in your ingredient list, you wouldn’t list it twice, but would add the amounts to determine where to place it.

      The preservatives in the lard and aloe vera (BHA, Propyl Gallate, Citric Acid and Sodium Benzoate) would be listed with the ingredients present at 1% or less.

      There is another factor – incidental ingredients, which can be omitted under certain circumstances. What might apply to this situation is:

      Substances that have no technical or functional effect in the cosmetic but are present by reason of having been incorporated into the cosmetic as an ingredient of another cosmetic ingredient.

      The preservatives from the lard and aloe vera no longer really have any functional effect in your soap, so they could, technically, be omitted. (That said, there’s the question of whether you WANT to do that – the incidental ingredients “loophole” has been getting some blowback lately).

      I assume that your ingredient declaration also includes your other ingredients (water, sodium hydroxide, and any frangrance).

Leave a Reply

Your email address will not be published. Required fields are marked *