Ingredient Declaration: What Name to Use?

One of the trickiest parts of making a compliant cosmetic label is deciding what name to use for each ingredient. Should you use the scientific term? The kitchen-friendly version? Or that long string of Latin words?

Fortunately, the regulations do tell us where ingredient names come from. But as with many labeling requirements, the answer has evolved over time—and there are still some quirks to be aware of.

What the Regulations Actually Say

The controlling regulation is 21 CFR 701.3(2). It spells out the sources of names that should be used in the ingredient declaration. The first source listed is the Cosmetic Ingredient Dictionary (CID), 2nd edition (1977), published by the Personal Care Products Council (PCPC).

The CID is now in its 16th edition (and continuously updated online), and it’s grown into a massive reference set—five volumes, 7,000+ pages, covering over 25,000 ingredients. Since the mid-1990’s when the Cosmetic Ingredient Dictionary was adopted internationally, the accepted names published there are referred to as INCI® names (International Nomenclature Cosmetic Ingredient).

So, when you see “This is the INCI name for ___,” it means that it’s the standardized, internationally recognized name that was identified and compiled by the Personal Care Products Council, and is the most likely name to use in your ingredient declaration.

In 2023, the Personal Care Products Council trademarked the term INCI. Technically, the term can only be used to identify their products and services, and their list of cosmetic ingredients.

The Standard

Since it’s inception, the Cosmetic Ingredient Dictionary (now the International Cosmetic Ingredient Dictionary and Handbook) provided a resource for a standardized and consistent name for each unique cosmetic ingredient. Now we also have CosIng, which is an ingredient lookup for the international standards (using EU requirements). Either way, consumers and regulators can recognize what’s in a product, regardless of brand or country of sale.

Examples:

• Sodium Bicarbonate is the name for what you might call baking soda, bicarbonate of soda, or carbonic acid, monosodium salt.
• Sodium Hydroxide or Potassium Hydroxide are the correct INCI names for “lye.”
• Tocopherol is the INCI name for Vitamin E.

In most cases, it works well, eliminates confusion, and provides a nationally and internationally accepted and recognized name. It also means that a label can be compared across products and countries with consistency.

Botanicals: A Special Case

Botanical ingredients are the main place where things get messy – at least in the US.

• Up to the 5th edition, the CID listed botanicals by their common English names (e.g., Fir Needle Oil).
• Starting with the 6th edition (1995), the Dictionary adopted the internationally accepted Linne (Latin) classification system (e.g., Abies Siberica Oil).

However, the FDA did not accept the Latin names as the “common or usual names” for U.S. labeling. In fact, when PCPC petitioned the FDA to accept Latin INCI names for botanicals, the FDA said no, the common English name should remain primary. They suggested that companies could optionally include the Latin name in parentheses — but not instead of the English name.

So, technically, in the U.S.:

• Botanicals should be declared by their common English name.
• The Latin name may be placed in parentheses.

Example:

• Lavender Oil
• Lavender (Lavandula Angustifolia) Oil
• Coconut Oil
• Coconut (Cocos Nucifera) Oil

Also, just as a note, the international standards do not include using italics for the Latin name. That’s the practice in the the scientific community, but for cosmetic labels the Latin name should be in the same text as everything else.

Reality vs. Regulation

Here’s the reality: The cosmetic industry generally uses the international format, including Latin names for botanicals on labels. Many of the products you see in stores list “Cocos Nucifera (Coconut) Oil” or “Lavandula Angustifolia (Lavender) Oil,” and some use just the Latin name (without the English in parentheses). Consumers are familiar with those names, and internationally, they are the standard.

In my years of reviewing FDA warning letters, I have never seen FDA take action against a company solely for using theintrenational style (Latin name first). Nor have I seen them challenge imported products that are labeled that way.

This suggests that FDA is, in practice, accepting the harmonized international system—even though the law says “common name” and the regulations technically reference the 1977 edition of the Cosmetic Ingredient Dictionary which used the simple common English name.

Given that FDA participates in the International Cooperation on Cosmetics Regulation, it seems likely that sooner or later it will be clarified with updated regulations. It remains to be seen if or how the FDA will recognize or authorize the INCI® naming system since it now privately trademarked and accessed only with a fee.

UNII Names: Another Layer

Adding to the mix, there’s also the Unique Ingredient Identifier (UNII) system. A UNII identifies ONE ingredient, and associates it with other synomyms, references, and databases. They are used internally by the FDA and other health databases, and are also part of the information recorded for ingredients of products that are listed with the FDA under MoCRA.

For each ingredient, UNII designates a “preferred name.” It’s usually, but not always, the same as the international name for the ingredient … EXCEPT for botanicals. They use the common English name as the preferred name and keep the Latin name as a “synonym.”

Examples:

• Beeswax
  • US Ingredient Declaration: Beeswax
  • International: Cera Alba
  • UNII preferred term: Beeswax
• Shea Butter
  • US Ingredient Declaration: Shea Butter or Shea (Butyrospermum Parkii) Butter
  • International: Butyrospermum Parkii (Shea) Butter
  • UNII preferred term: Shea Butter
• Coconut Oil
  • US Ingredient Declaration: Coconut Oil or Coconut (Cocos Nucifera) Oil
  • International: Cocos Nucifera (Coconut) Oil
  • UNII preferred term: Coconut Oil

So, which is correct? For labeling, follow the international system—EXCEPT for botanicals. For those, in the US, use the common English name. Or, alternatively, use the FDA preferred name from the UNII database.

Practical Takeaways

Ingredient names are one of those areas where regulation and practice don’t always perfectly align. Officially, the rules point back to the Cosmetic Ingredient Dictionary and the “common or usual name.” In practice, the industry has harmonized internationally on international standard names—including Latin names for botanicals—and FDA seems to be fine with it.

So, what should you actually do when writing your ingredient declaration?

1. Use international standard names from the Cosmetic Ingredient Dictionary for all non-botanical ingredients.
2. For botanicals in the U.S., technically the common English name should come first, with the Latin name in parentheses.
3. For color additives, use the name as listed by the FDA for the approved color additive.
4. Do your best, but don’t overly stress about enforcement on this issue. FDA has never (to my knowledge) issued a warning letter over the order of botanical names. Their attention is on bigger issues.