Ingredients To Die For Blog

Steps to Prevent your Customer from using the INCI
to go around Your Business
by coming Directly to Us

In today's electronic age it is easier, than ever, for anyone to do a search of an INCI name, that is used exactly the way that we write it, and have it lead back to us. This may not be a good thing for your company as it allows your customers to go around you by coming directly to us, which is not our intention and we are happy to help you take steps to prevent this.

Our INCI is not intended to be copied, and pasted, directly onto a retail label as it would result in misbranding due to the language. We write the INCI, for each product, with two goals:

1. to help our customer, quickly, see what kind of ingredients are being use

2. to help our customer meet the disclosure requirements

While there are elements, in our posted INCI, that are required, there are several steps that you can take to help avoid traceability by eliminating language that is not required:

• almost every formulation will have a couple of ingredients that are used, at the same level, and can be re-arranged so that your INCI doesn't read exactly as ours

• almost every INCI will have descriptive key words that can be removed without violating the requirements of disclosure

• when we use descriptive words such as: purified water, vegetable glycerin and so on … those are key words being used for your benefit, not your customers benefit, and they should be removed

• the requirements for cosmetic labeling do not allow for the use of such descriptors as they imply that there is something wrong with other types of the same ingredient

 

When you are setting up your ingredient deck please send us an email, to info@ingredientstodiefor.pro and we will help you eliminate, or re-arrange, item names to help you avoid that traceability.

Some tips in labeling conformance:
The use of an adjectives to further describe an ingredient, which imply inferiority in any other form are considered to be misbranded. To further describe water, such as purified, deionized, natural, spring, etc. Purified water is the drug name for water, as defined in the US Pharmacopoeia, and may only be listed on the labels of drugs that do not make cosmetic claims. Purified water on the product label is automatically considered a drug claim, constituting misbranding.

Parenthetically adding descriptors … “vitamin A, C, E, etc.” after the INCI name. The US Food and Drug Administration (FDA) considers vitamins as separate from cosmetic ingredients as they are not recognized as providing health benefits in the cosmetic product. Vitamin is automatically considered a food, with a nutritional / health value claim, constituting misbranding. The FDA does not object to stating that the product contains vitamins outside of the ingredient listing.

Another labeling mistake is highlighting the origins of ingredients by using terms like vegetable, natural, organic, or even certified organic. This constitutes misbranding as there is no recognized difference in chemicals from different origins; a molecule of glycerin is just that, as it is known that there is no data showing “certified organic” materials to be safer or different from other materials with the same INCI designation.

To help you eliminate 'desciptive' language, while still being in compliance with regualtions, please review the federal guideline 'exerpts' below.

 

Federal Labeling Requirements:
The ingredients must be declared in descending order of predominance. Color additives (21 CFR 701.3(f)(3)) and ingredients present at one percent or less (21 CFR 701.3(f)(2)) may be declared without regard for predominance. The ingredients must be identified by the names established or adopted by regulation (21 CFR 701.3(c)); those accepted by the FDA as exempt from public disclosure may be stated as "and other ingredients" (21 CFR 701.3(a)).

Cosmetics which are also drugs must first identify the drug ingredient(s) as "active ingredient(s)" before listing the cosmetic ingredients (21 CFR 701.3(d)).

All label statements required by regulation must be in the English language and must be placed on the label or labeling with such prominence and conspicuousness that they are readily noticed and understood by consumers under customary conditions of purchase (21 CFR 701.2).

The ingredient declaration must be conspicuous so that it is likely to be read at the time of purchase. It may appear on any information panel of the package, i.e., the folding carton, box wrapping if the immediate container is so packaged, and may also appear on a firmly affixed tag, tape or card. The letters must not be less than 1/16 of an inch in height (21 CFR 701.3 (b)). If the total package surface available to bear labeling is less than 12 square inches, the letters must not be less than 1/32 of an inch in height (21 CFR 701.3(p)). Off-package ingredient labeling is permitted if the cosmetic is held in tightly compartmented trays or racks, it is not enclosed in a folding carton, and the package surface area is less than 12 square inches (21 CFR 701.3(i)).

 

HAPPY CRAFTING!
From the Ingredients To Die For staff