List it: Getting your INCI right in the EU and US

Published: 26-Jan-2022

CE.way Regulatory Consultants' Tjaša Grum reveals what you need to know when writing ingredient lists in the US and EU/UK

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Selling cosmetic products worldwide often comes with a regulatory headache when trying to keep up with the requirements of different markets across the world.

The part that companies generally struggle with is the labelling, which is an important part of a cosmetic product packaging, both from a regulatory and marketing view.

In this article, we will look at how to write an ingredient list that will be compliant on the US, EU and UK markets.

The ingredient list is one of the most informative parts of the label as it provides an insight into the product composition, so it is important to write it correctly.

Applicable regulation

Cosmetic products placed on the European Union's market have to comply with the Regulation (EC) 1223/2009 on cosmetics products, which also lists the labelling requirements.

Cosmetics sold in the US must comply with the Federal Food, Drug and Cosmetic Act (FD&C Act) and Fair Packaging and Labeling Act (FPLA). Both acts should be considered when creating the ingredient list.

Product composition

In order to have a compliant ingredient list, we need to make sure that our product formula is compliant. That means we need to thoroughly check that our formula does not include any prohibited ingredients and that in the case it includes a restricted ingredient, it complies with the restrictions.

There is one important difference between the EU and US in regard to the ingredient listing.

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