An INCI ingredient list uses the International Nomenclature of Cosmetic Ingredients. To prepare one, start with the approved quantitative formula. Before a designer receives label copy, the manufacturer or regulatory reviewer must confirm the composition of raw-material blends, combine repeated ingredients and apply the naming and ordering rules for each sales market.

This guide uses EU requirements as its baseline. Great Britain and the United States need separate checks; an EU ingredient list is not automatically a global label. Schedule the review during cosmetic product development, with a named owner and an approved formula version.

Obtain the formula and blend compositions

Ask the manufacturer for a formula identified by product code, revision and approval date. It should give each raw material’s addition level by weight, its supplier and grade, and enough composition information to calculate the finished product’s individual ingredients.

A supplier’s list of INCI names alone may not be enough. A botanical extract can contain water, a carrier and preservatives. A ready-made emulsifier or preservation blend can contribute ingredients already added elsewhere in the formula. If the supplier provides only broad concentration ranges, check whether they could change the ingredient order or whether a regulated threshold is exceeded. Obtain more precise composition data where needed before approving artwork.

Build a calculation sheet with a row for each contribution:

Ingredient contribution (%) = raw-material addition (%) × ingredient fraction in that raw material.

Add the contributions for each ingredient after verifying its identity. Keep supplier evidence with the calculation, including the rationale for any exclusion. Our raw-material documentation guide covers the records to request.

Worked example: a blend changes the order

Consider a hypothetical fragrance-free aqueous serum. The percentages below are invented to demonstrate ingredient-list arithmetic; this is not a validated formulation or a recommendation to manufacture it.

The inputs total 100%. After expansion, Aqua totals 89.40%, Glycerin 4.50% and Niacinamide 4.00%. Glycerin therefore precedes Niacinamide, even though the directly added glycerin was only 3%.

One illustrative EU declaration is:

Ingredients: Aqua, Glycerin, Niacinamide, Phenoxyethanol, Panthenol, Xanthan Gum, Sodium Citrate, Ethylhexylglycerin, Citric Acid.

Every ingredient after Niacinamide is below 1%. Their order can therefore vary within that part of the list under the EU rule. The 1% preservation blend is not listed as one ingredient: its constituents contribute 0.90% and 0.10%. A commercial trade name does not replace those constituent names.

Check the names and apply the ordering rules

Under Article 19 of the EU Cosmetics Regulation, ingredients are listed in descending order of weight at the time they are added. Ingredients below 1% may appear in any order after those above 1%. For an ingredient exactly at 1%, retain descending order rather than assuming the below-1% flexibility applies.

Use the common ingredient names in the Commission’s glossary. Where a common name is absent, Article 19 allows a term from a generally accepted nomenclature. Check botanical species, plant part and preparation carefully; a seed oil and a leaf extract are not interchangeable descriptions.

The current EU glossary is Implementing Decision (EU) 2025/1175, which applies from 30 July 2026 and replaces Decision 2022/677. A template citing only the older decision needs review.

The Commission explicitly warns that its glossary is not a list of authorised ingredients. A correct name does not establish that an ingredient is acceptable for the intended use. Check restrictions, permitted functions and the safety assessment through the EU compliance checklist.

Resolve fragrance, colour and nano details separately

Perfume and aromatic compositions use the EU terms Parfum or Aroma, but those terms do not remove separate disclosure obligations for substances covered by Annex III. Obtain current allergen data for the exact fragrance or essential-oil grade and calculate contributions from every relevant raw material, not just the perfume addition.

Regulation (EU) 2023/1545 expanded fragrance-allergen labelling requirements. Relevant entries require declaration above 0.001% in leave-on products or 0.01% in rinse-off products. Read the applicable entry, including grouped names and any additional restriction, rather than relying on an outdated supplier checklist.

The transition for placing affected products with the former labelling on the EU market ended on 31 July 2026. Qualifying products already placed on the market can continue to be made available until 31 July 2028 under the relevant transitional provisions. Stock manufacture dates alone do not establish eligibility. The fragrance-allergen labelling guide examines that distinction.

Article 19 also requires ingredients present as nanomaterials to have their names followed by “(nano)”. Colourants other than hair colourants have a special ordering rule and use CI nomenclature where applicable. The “may contain” or “+/-” option is for qualifying decorative shade ranges; it is not permission to list every possible ingredient in several alternative formulas.

Do not omit an intentionally included ingredient merely because it is present at a low level. EU exclusions cover raw-material impurities and subsidiary technical materials used in the mixture but absent from the final product. Document the basis for an exclusion instead of treating a trace concentration as an exemption.

Check the sales market before approving artwork

The FDA Cosmetics Labeling Guide describes US ingredient identification, fragrance terminology and colour-additive declarations. It permits ingredients at 1% or less to appear in any order after those above 1%, a wording difference from the EU’s below-1% rule. Do not copy an EU CI-number declaration into US artwork without checking the applicable US names.

Great Britain has its own cosmetics guidance. Do not assume later EU glossary or annex amendments automatically apply there. Northern Ireland requires a separate assessment; the linked GB guidance expressly excludes it.

For each market-specific artwork, record these checks:

• The raw-material specifications and allergen declarations correspond to the approved formula revision.
• Blend calculations reconcile and repeated ingredients appear once at their combined level.
• Names, order and any required allergen, colourant or nano declarations have been reviewed.
• The ingredient list uses the required heading and appears in an allowed location.
• The actual-size proof is legible, with no text hidden by a seam, fold or overlabel.
• The manufacturer and regulatory reviewer have signed off the final copy; the designer has not substituted a marketing name.

EU ingredient information may appear on the packaging alone. Practical-impossibility exceptions have specific conditions; a QR code should not be assumed to replace the required physical declaration.

Keep the calculation with the approved label

Keep the ingredient worksheet and supplier evidence with the approved artwork under version control. Review them again after a supplier substitution, blend-composition change, fragrance update or formula revision. Send the printer the approved declaration with its formula revision and sales market identified.