“Alcohol” can mean a lot of different things depending on the context—and in cosmetics, that can get confusing fast. Ethyl alcohol, isopropyl alcohol, and denatured alcohol—not to mention vodka and Everclear—are all used in cosmetic and soapmaking settings, but they aren’t the same thing. Each has its own definition, regulations, and labeling requirements.
Let’s look what each type means, when you can use it, and how to list it correctly on your product labels.
Ethyl Alcohol (Ethanol)
Ethyl alcohol (also known as ethanol or grain alcohol) is the same type of alcohol found in beverages, such as vodka and Everclear. It’s considered consumable alcohol, even if it isn’t packaged as a beverage for sale.
Consumable alcohol can be naturally derived from fermentation or made synthetically. Because it’s drinkable, it’s regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB) and subject to federal and state excise taxes. The federal excise tax is $13.50 per gallon; state excise taxes vary from $2.00 (Missouri) to $36.55 (Washington) per gallon.
When you purchase consumable alcohol retail (as vodka, Everclear or something similar), the taxes are built into the price. Those taxes can make it prohibitively expensive to use retail alcohol in commercial cosmetic products.
There is a way to qualify to get alcohol at no (or reduced) taxes, but it usually requires a high usage rate to justify the cost of the application and process.
Denatured Alcohol
To make ethyl alcohol unfit for drinking—and avoid beverage taxes—manufacturers add denaturants, creating denatured alcohol. There are two main types:
- Completely Denatured Alcohol (CDA) – Chemically altered so it cannot be converted back into drinkable alcohol. Often used in fuels or cleaning products (not normally used in cosmetic products).
- Specially Denatured Alcohol (SDA or SD Alcohol) – Drinkable ethanol that has been modified with approved denaturants to render it undrinkable but still suitable for cosmetics and fragrances.
There are 32 different SDA formulas, each specifying the type and quantity of denaturants allowed. Some of the most common for cosmetics include:
- SD Alcohol 38-B (denatured with essential oils like lavender or menthol)
- SD Alcohol 39-C (denatured with diethyl phthalate)
- SD Alcohol 40-B (denatured with tert-butyl alcohol and denatonium benzoate)
Because SDA formulations can theoretically be reversed to recover drinkable alcohol, they are tightly regulated at both federal and state levels. Purchasing, or using them in production, usually requires a TTB permit and recordkeeping compliance.
Note that their regulations allow purchase of up to 5 gallons per year; some suppliers promote and sell small quantities of SD alcohols. However, the regulations also clarify that SD alcohol purchased under the small quantity exemption is for research and development and may NOT be used in commercial products for sale.
Isopropyl Alcohol (Isopropanol)
Isopropyl alcohol is a synthetic alcohol derived from petroleum. It’s not drinkable and therefore not regulated or taxed by the TTB. It’s readily available and is commonly sold as “isopropyl rubbing alcohol,” it’s widely used as a solvent, disinfectant, or cleaning agent.
It has a unique, somewhat pungent, smell, making it less than ideal for use in perfumes or cosmetic products.
However, because of it’s chemical structure it evapaorates quickly. That makes it sometimes useful for spritzing on melt-and-pour soap layers or cleaning packaging surfaces before labeling.
Isopropyl alcohol is highly flammable—both as a liquid and as a vapor. It can irritate the eyes and cause dizziness with prolonged inhalation. Never mix isopropyl alcohol with bleach—the reaction creates chloroform, a toxic sedative gas.
Keep a Safety Data Sheet (SDS) on hand and ensure proper ventilation when using alcohol, especially if you’re spraying or using it near a heat source.
Rubbing Alcohol
“Rubbing alcohol” is a general term for alcohols meant for external use. Historically, it distinguished topical alcohols (used for rubbing on the body or for cleaning) from drinkable ones—especially during Prohibition.
There are two types sold under this name:
- Isopropyl Rubbing Alcohol — straight isopropyl alcohol (typically 70–99%)
- Completely Denatured Alcohol — ethyl alcohol that’s been completely denatured.
Ingredient Declaration
How you identify alcohol in your ingredient declaration depends on what kind of alcohol it is.
- Consumable alcohol: list as Alcohol
- Specially denatured alcohol: list using the formula number (e.g., SD Alcohol 40-B), OR by general term Alcohol Denat.
- Isopropyl rubbing alcohol: list it as Isopropyl Alcohol.
- Completely denatured alcohol: list using the formula number (e.g., CD Alcohol 19)
When alcohol is used only in production (e.g., sanitizing molds, dissolving colorants, or spritzing surfaces) and evaporates fully, it’s usually considered an incidental ingredient and doesn’t need to be declared in the ingredient declaration.
General Safety and Regulatory Considerations
- Hazardous Substance: All alcohols—denatured or not—are flammable to some degree. If not sufficiently diluted, they remain flammable and may be classified as hazardous substances under OSHA and Department of Transportation rules for workplace safety and shipping. Check the flash point, and be aware of whether you need to take special precautions for the alcohol you are using. Products containing significant alcohol content (like perfumes or sprays) must carry proper flammability warnings and follow shipping restrictions for hazardous materials.
- Labeling & Storage: Keep alcohol of whatever kind in original containers or clearly label that they contain alcohol. If you store significant amounts, ensure there is appropriate signage in case of a fire or other emergency.
- Permits & Compliance: Using ethyl alcohol or SD Alcohols in manufacturing may trigger TTB oversight. Always check federal and state-level permit requirements.
In Summary
| Type | Source | Drinkable | Regulated by TTB? | Label as | Notes |
|---|---|---|---|---|---|
| Ethyl Alcohol | Fermented or synthetic | Yes | Yes | Alcohol | Use taxed, beverage-grade alcohol only |
| Specially Denatured Alcohol (SDA) | Ethanol + additives | No | Yes | SD Alcohol ___ or Alcohol Denat. | Common in perfumes |
| Completely Denatured Alcohol (CDA) | Ethanol + additives | No | Yes | CD Alcohol ___ | Rarely used in cosmetics |
| Isopropyl Alcohol | Petrochemical | No | No | Isopropyl Alcohol | Common solvent or disinfectant |
| Rubbing Alcohol | Ethyl or Isopropyl base | No | Sometimes | Alcohol Denat. or Isopropyl Alcohol | External-use only |
Final Thoughts
Understanding which type of alcohol you’re using—and how it’s defined—is key to proper labeling and safe manufacturing. Whether it’s ethanol, denatured, or isopropyl, knowing its regulatory path will help you stay compliant, protect your customers, and avoid costly mistakes.
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