What is the “Common Name”?

2015-03-28-names

The FDA has said that the “common name”1 is required for cosmetic ingredients.

But what does that mean, exactly?

Let me tell you the story of the Cosmetic Ingredient Dictionary and INCI names.

Once upon a time …

Back in the 1970’s, a book called the Cosmetic Ingredient Dictionary (CID) was published by the Cosmetic Toiletries and Fragrance Association, a US trade association for the cosmetic industry.  The CID listed the acceptable (“common”), human understandable, names for cosmetic ingredients.  Since it was a US publication, the plant-based (botanical) ingredients were listed by their common English names.

The FDA said that was a good place to get the names of the ingredients used in cosmetics for the newly required ingredient declaration.

Fast forward to 1995, and the face of the cosmetic industry was changing. Products were being manufactured and sold in multiple countries.  The European Union was establishing regulations to cover multiple countries with multiple languages.  To accomodate all the big players, a new edition of the CID was published which used the universal, multi-lingual Latin name to identify botanical ingredients.  The EU accepted the CID as the International Nomenclature of Cosmetic Ingredients,  the international standard for listing cosmetic ingredients (from whence we get the international “I” in “INCI”).

The CTFA (now the Personal Care Products Council) tried to get the FDA to accept the new edition of the CID as the standard, including the Latin names for botanicals; the FDA declined, saying (essentially) that the Latin name is not the common name for people in the US2.

However, the FDA has acknowledged that when it comes to non-botanical ingredients, the CID is typically the  go-to source for the correct name to use3.  You want to know what your emulsifier or preservative is made of? The names used to describe those ingredients are typically the ones that have been approved for inclusion in the INCI … the place all cosmetic manufacturers go to get the ingredient names.  It makes it much easier for consumers to read and understand ingredient declarations when everyone uses the same names.

So, where does that leave us?

Trade Name or Brand Name

First of all, it’s not the “trade name” or the “brand name” of the ingredient.  Just because you refer to your lye as “Red Devil” (and maybe it IS a red devil), doesn’t mean that you should use that in your ingredient list.  That’s not the common name.  In that case, the common name is the correct chemical name, “sodium hydroxide.”

Generally, a cosmetic ingredient has a common name by which it is recognized – and that name is listed in the Cosmetic Ingredient Dictionary by its INCI name.

If the product is a blended ingredient, the supplier should be able to tell you the common (“INCI”) names for the components.

Chemical (Non-Botanical) Ingredients

The “common name” for chemical cosmetic  ingredients (that is, they are not plant or botanical ingredients)  is most often the name that is listed in the Cosmetic Ingredient Dictionary.  That’s the name that all the cosmetic manufacturers use, making it the common name that the consumer will understand.

Botanical Ingredients

For botanical ingredients, that are named from the plant they come from such as olive oil, rose petals, cinnamon bark or shea butter, the name to use is determined by the country you are in.

Latin

Outside the United States, due to a multitude of languages and multi-lingual regulations, the general rule (required by most countries) is to use the Latin name, which is the one listed in the CID. By using the Latin name you can ensure that people of different languages can identify the exact plant source for the ingredient. Latin, as a standard for identifying botanicals is, indeed, “common” is most of these countries.

English

Inside the United States, however, the FDA has determined that the “common name” for plant-based ingredients is the English name.  So in the US, the correct way to identify botanical ingredients is by their common English name.

The FDA has said that you may include the Latin name in parenthesis as a secondary name if you want, but it is not required.

More Info

For more information about how to identify ingredients in the ingredient declaration, see pages 100 – 108 in Soap and Cosmetic Labeling (3rd ed.) by Marie Gale.

References   [ + ]

Comments

  1. Well, sure, for the EASY cases. 😉

    Please forgive me if I’ve gone over this ground before, but I’m not sure I’ve done so here. 20 yrs. ago I participated in some soapmaking & related forums on CompuServe & some business-supported e-mail lists. One of the participants was Tony O’seland, a person of very limited means who, among other products, was using the unscented & uncolored version of Ivory Dishwashing Liquid, purchased at retail, for the foaming base of bubble bath that he sold. How would he have been legally obligated — or allowed — to list this as an ingredient? They weren’t selling it for cosmetic or toiletry use, so they didn’t label it with the CTFA names of its ingredients, and I’m sure they’d’ve had no interest in supplying him with that info, although it was not sold at retail with any covenant against any particular use. It might’ve said, “Keep out of reach of children,” but the same might be said on many toiletry products. The closest I could figure (not that he was asking me, I just thought it was in interesting “hard case”), he’d have to call it by its labeled name, possibly with add’l info that might aid in batch tracing in case that formula changed between when he bought it and when a consumer might have a question about his product. It might’ve been more face-saving for him to take a good guess at its ingredients based on industry sources.

    I think Tony might’ve also had a face cream or something made in part with mud from the bank of a nearby creek, or maybe that was just my imagination looking for another “hard case” of ingredient labeling. I suppose that could be listed as mud with identification of the location & time it was dug up. Or maybe it could just be called “mud”, although it might have more label appeal to specify further.

    These could stand for any sort of situation in which someone takes a material over the threshold that converts it from something else to something that’s statutorily a “cosmetic”. Probably members of Congress 40 yrs. ago took trade groups’ word on usual operations, which assumed rather different conditions from the ones I’m positing.

  2. Author

    Well, seems to me that an even more fundamental concept than how to LABEL the products you’re talking about is knowing exactly what you are making and what’s in it. If you don’t know what the components are of an ingredient – be it Ivory Dish Soap or mud from a local creek bed – how can you be sure the product is SAFE? Before the labeling issue there’s the idea of sufficient good manufacturing practices to ensure that the product is not adulterated and that it is safe for use.

    From there, it’s my understanding that when it comes to labeling you have to list the componentt ingredients in a blended ingredient and b) there are no exceptions to the rule.

  3. Long story short, I know what you mean. Microenterprise is at a huge disadvantage breaking into any market. Takes money to make money.

    A local retired man and hobbyist sells scented liquid hand soap at craft fairs. They are scented with essential oils from the grocery or health food store. For the base he buys bulk liquid soap from the dollar store. He doesn’t put labels on the bottles, doesn’t have a computer or printer, and hand-writes “lavender” or “lemon”.

    I have seen him working early in the morning, making mixtures, and he told me what he does, where he gets cheap ingredients. His wife used to help him and he does it to stay busy.

    If the FDA came in he, and all the little budding artisans like him, would be shut down. I see the government’s point of view, public safety, but don’t want to see little people shut down before they’ve had a chance to get off the ground.

    1. Author

      When it comes to handcrafted soap and cosmetics there is a wide, somewhat blurry line between “hobbyist” and “professional.” When a hobbyist starts selling to customers, they enter the professional world and should know enough about their ingredients, uses, safety, manufacturing, testing, packaging and regulations to — at the very least — be sure they are not putting anyone at risk.

    2. I really don’t see your friends as a “budding Artisan”. By definition, an Artisan is somebody who “2. a person or company that makes a high-quality or distinctive product in small quantities, usually by hand or using traditional methods:”

      What he does it not high quality. It’s not making anything per se. It’s taking a cheap base, putting in a fragrance and selling it. He’s just making a quick buck. Anybody selling to the public should know exactly what goes into her/her product so his inability to do so, should make him pause, think and change what he’s doing.
      He wouldn’t be facing this issue if he were to make his own liquid soap from scratch.

  4. So, is the only definitive way to know the common name to step through the references in the regs (§ 701.30)? Most suppliers seem confused when I ask for the common name and tell me I need to used the INCI. Some are obvious, but I’m getting hung up on some clays, etc.

    1. Author

      The names in the Cosmetic Ingredient Dictionary – which have been accepted as INCI names – is what you should use for cosmetic ingredients …. EXCEPT in the case of botanical ingredients, where the INCI name is the LATIN NAME and the FDA requires the common (ENGLISH) name.

      So for baking soda you’d use the INCI name “sodium bicarbonate”.

      For olive oil you’d use “olive oil” (the latin name could go in parenthesis, if desired).

  5. Marie, I’ve been reading your posts and researching online including the actual FDA sight. Your insights, information, and advice are great! What I’m wondering is how can I actually find the correct common or latin name for an ingredient? I looked up the 6th edition and its $300, way out of my budget. Also, if I use a different brand or version does that change things? For example using refined ivory shea butter vs unrefined shea butter… how specific would it need to be? Would you say refined shea butter, refined ivory shea butter, or just shea butter?

  6. I made a body butter out of a base call aloe vera butter and I am confused as to how to put this on my label.. The FDA approved name is Aloe butter so can I use that or do I need to use the INCI names which I thought was opptional?

    1. Author

      There is a general confusion about what the “INCI” name is for a product.

      In the case of “aloe vera butter”, I believe it is standardized “International Nomenclature for Cosmetic Ingreidents” name. It means that an ingredient called “aloe vera butter” is an exact thing, defined in the Cosmetic Ingredient Dictionary.

      In the case of Aloe Vera Butter, it is actually made up of several ingredients; it is a blended ingredient. Most suppliers will state the “INCI name” as “coconut oil and aloe leaf extract” In that case, the component ingredients still must be listed in the ingredient declaration individually, in descending order of predominance in the whole.

      In the US, the FDA has stated they want the common English name stated first; whether you also include4 the Latin names (sometimes confusingly called the “INCI name”) is up to you.

      So you would list “coconut oil” or “coconut (cocos nucifera) oil” where it belongs in the ingredient declaration, and separately list “aloe leaf extract,” or “aloe vera” or “aloe (aloe barbadensis) leaf juice” where it belongs in the ingredient declaration.

      Note that while the FDA says they want the common English name first, they apparently are not enforcing when the Latin name is used first, or is only used, in the ingredient declaration.

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