INCI names: how to write the ingredient list of a cosmetic sold in the EU

An INCI name is a name from the International Nomenclature of Cosmetic Ingredients. The name you print on a cosmetic is not “the INCI name” in general but the common ingredient name in the Commission’s glossary, which takes account of INCI (Art. 33Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 33Click opens the article on EUR-Lex.). The Commission builds the glossary in particular from the new INCI names published by the Personal Care Products Council (Decision (EU) 2025/1175, recital 3).

What the ingredient list is made of

The list is one of the seven label items of the Cosmetics Regulation (Art. 19(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1Click opens the article on EUR-Lex.). It is “preceded by the term ‘ingredients’”, and an ingredient “means any substance or mixture intentionally used in the cosmetic product during the process of manufacturing”. Two things are not ingredients: impurities in the raw materials, and subsidiary technical materials used in the mixture but not present in the final product (Art. 19(1)(g)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (g)Click opens the article on EUR-Lex.).

A finished list, with the colorant last and the perfume named with its allergen, reads:

Ingredients: Aqua, Glycerin, Cetearyl Alcohol, Butyrospermum Parkii Butter, Phenoxyethanol, Parfum, Linalool, CI 77891

The list gives the order of the ingredients, not their percentages. The only rule on quantity is the descending order of weight (Art. 19(1)(g)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (g)Click opens the article on EUR-Lex.). Separately from the label, the responsible person makes the composition of the product easily accessible to the public; the quantitative part is limited to hazardous substances under CLP (Art. 21Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 21Click opens the article on EUR-Lex.). The same names go into the safety report: its composition part gives each substance’s chemical identity, “incl. chemical name, INCI, CAS, EINECS/ELINCS, where possible”, and its function (Annex I, Part A, point 1).

The glossary in force is Decision (EU) 2025/1175

The Commission compiles and updates the glossary of common ingredient names, taking account of INCI. The Regulation adds that the glossary “shall not constitute a list of the substances authorised for use in cosmetic products”, and that a common ingredient name is applied for labelling at the latest twelve months after the glossary is published in the Official Journal (Art. 33Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 33Click opens the article on EUR-Lex.). Three Decisions have set the glossary in turn:

The Commission’s glossary page lists Decision (EU) 2025/1175 as the latest of these. The landing page of its CosIng database still says the glossary was “established by Decision (EU) 2019/701” (European Commission, Cosmetic ingredient database); the Official Journal texts above are the law.

The Annex to the Decision lists the names in alphabetical order, numbered 1 to 30418, in capital letters. Neither the Regulation nor the Decision says which letter case the label uses. What an entry looks like:

The glossary has no entry named “shea butter”, “coconut oil”, “aloe vera”, “vitamin E” or “fragrance”. A seller who searches for the everyday word finds nothing, and prints the entry for the ingredient itself. The Annexes of the Cosmetics Regulation help here: the substance tables of Annexes III, IV and VI each carry a column with the glossary name of the substance.

Colorants, hair colorants and nanomaterials

Colorants other than hair colorants “may be listed in any order after the other cosmetic ingredients”. For decorative products sold in several shades, all those colorants used in the range may be listed, as long as the words “may contain” or the symbol “+/-” are added. “The CI (Colour Index) nomenclature shall be used, where applicable” (Art. 19(1)(g)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (g)Click opens the article on EUR-Lex.). The Decision turns that into the glossary: the CI number is the common ingredient name for colorants other than hair colorants (Decision (EU) 2025/1175, recital 5). The list of allowed colorants, Annex IV, gives each one’s CI number or glossary name in a single column. The glossary lists titanium dioxide twice, as CI 77891 (entry 6482) and as TITANIUM DIOXIDE (entry 28903).

The freedom to list colorants in any order is limited to colorants “other than colorants intended to colour the hair”. A hair colorant therefore loses that freedom. It stays in the weight order, unless it is below 1%, and it carries its glossary name, such as HC BLUE NO. 2.

“All ingredients present in the form of nanomaterials shall be clearly indicated in the list of ingredients. The names of such ingredients shall be followed by the word ‘nano’ in brackets” (Art. 19(1)(g)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (g)Click opens the article on EUR-Lex.). A nanomaterial is an insoluble or biopersistent, intentionally manufactured material with one or more external dimensions, or an internal structure, from 1 to 100 nm (Art. 2(1)(k)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 2, paragraph 1, point (k)Click opens the article on EUR-Lex.). The glossary has no “(nano)” entries of its own: the word goes after the glossary name. Annex VI shows the form: in its glossary-name column, entry 30a reads “Zinc Oxide (nano)”, a UV filter. A product with nanomaterials has its own notification, which the CPNP notification guide covers.

Perfume, “parfum” and fragrance allergens

“Perfume and aromatic compositions and their raw materials shall be referred to by the terms ‘parfum’ or ‘aroma’”. The presence of the substances an Annex III entry asks for, under its column “Other”, is shown in the list in addition to those terms (Art. 19(1)(g)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (g)Click opens the article on EUR-Lex.). The allergens take their names from the glossary or from the entry itself.

Regulation (EU) 2023/1545 extended the Annex III entries. Each reads: the substance is indicated in the list of ingredients when its concentration exceeds 0.001% in leave-on products or 0.01% in rinse-off products. A product that does not meet the new entries could be placed on the market until 31 July 2026; for the entries marked (*2), only if it met the restrictions that applied on 15 August 2023 (footnotes (*1), (*2) and (*4) to its Annex). Entry 70 (Citral) has later dates of its own. Which substances are named, how the limits work and the dates for stock are in fragrance allergens.

Where the list goes and in which language

The label items must be in “indelible, easily legible and visible lettering” on the container and packaging. The ingredient list “may be indicated on the packaging alone” (Art. 19(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1Click opens the article on EUR-Lex., Art. 19(1)(g)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (g)Click opens the article on EUR-Lex.). Three cases move it elsewhere:

• It cannot be printed as required. It goes on an enclosed or attached leaflet, label, tape, tag or card. Unless that is impracticable, the pack carries abbreviated information or the symbol in Annex VII point 1; for the ingredient list the symbol is on the packaging (Art. 19(2)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 2Click opens the article on EUR-Lex.).
• Soap, bath balls and other small products where even a leaflet is impossible: the list goes on a notice in immediate proximity to the container in which the product is exposed for sale (Art. 19(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 3Click opens the article on EUR-Lex.).
• Products that are not pre-packaged, packaged at the point of sale at the buyer’s request, or pre-packaged for immediate sale: each EU country adopts detailed rules for the information (Art. 19(4)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 4Click opens the article on EUR-Lex.).

The language of the label is set country by country. Art. 19(5)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 5Click opens the article on EUR-Lex. gives the law of the country where the product reaches the end user the language of points (b), (c), (d) and (f) of paragraph 1, meaning the content, the date of minimum durability, the precautions and the function, and of paragraphs 2, 3 and 4. Paragraph 2 covers the list on a leaflet and paragraph 3 the notice for soap and small products, so national law sets the language of a list printed there. Point (g) is not named, so the heading “ingredients” on the pack is left open. The names in the list are “expressed by using the common ingredient name set out in the glossary” (Art. 19(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 6Click opens the article on EUR-Lex.). The glossary prints one name per entry.

A reseller verifies, before selling, that the ingredient list is on the pack and that the language requirements of Art. 19(5)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 5Click opens the article on EUR-Lex. are met (Art. 6(2)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 6, paragraph 2Click opens the article on EUR-Lex.).

Where CosIng fits

CosIng is the Commission’s database of information on cosmetic substances and ingredients. It carries the common cosmetic ingredient names for labelling that the Commission compiles and updates, and it can be searched by CAS, ELINCS and EINECS number. The Commission states its status in two sentences, quoted from its CosIng page:

Please note that CosIng database has informative purpose and no legal value.

CosIng is a non-legally binding information database. It provides information on cosmetic ingredients but does not, in itself, determine their regulatory status. Only Regulation (EC) No 1223/2009Regulation (EC) No 1223/2009, Cosmetic Products RegulationThe whole regulationClick opens the law on the EU Publications Office. and its Annexes establish whether, and under which conditions, substances may be used in cosmetic products.

Two consequences:

• An INCI name in CosIng is not an approval. An ingredient with an INCI name in the inventory section “does not mean it is to be used in cosmetic products nor approved for such use”. Whether a substance may be used is in Annexes II to VI. The glossary is no list of authorised substances either (Art. 33Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 33Click opens the article on EUR-Lex.).
• The label is judged against the Regulation and the Decision. The name duty is in Art. 19(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 6Click opens the article on EUR-Lex. and the names are in the Annex to Decision (EU) 2025/1175, not in CosIng.

CosIng is where you find the name and the numbers for an ingredient quickly. The text the authority checks the label against is the Annex to the Decision.

Who owes what

What happens if you do nothing

A label with names that are not the glossary’s, or with the list missing or out of order, breaches Art. 19(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1Click opens the article on EUR-Lex. or Art. 19(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 6Click opens the article on EUR-Lex.. The authority requires the responsible person to take all appropriate measures, bringing the product into conformity, withdrawing it or recalling it, within a time limit it sets (Art. 25(1)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 25, paragraph 1Click opens the article on EUR-Lex., point (h)), across all the products concerned on the EU market (Art. 25(3)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 25, paragraph 3Click opens the article on EUR-Lex.). Where the responsible person does not act in time, or the risk is serious, the authority itself prohibits, restricts, withdraws or recalls the product (Art. 25(5)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 25, paragraph 5Click opens the article on EUR-Lex.). Each EU country sets the penalties, which must be effective, proportionate and dissuasive (Art. 37Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 37Click opens the article on EUR-Lex.).

What is agreed but not yet law

On 8 July 2025 the Commission proposed to amend the Cosmetics Regulation (COM(2025) 531). It would delete Art. 33Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 33Click opens the article on EUR-Lex., so the Commission no longer adopts a glossary, and replace Art. 19(6)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 6Click opens the article on EUR-Lex. with a rule that the list is expressed using “the common ingredient name in accordance with the internationally recognised nomenclature”, and, in its absence, a term from a generally accepted nomenclature. The proposal gives the reason that a Commission glossary would slow down the uptake of new names (recital 25). Parliament and Council negotiators reached a political agreement on 16 June 2026. It still awaits the legal-linguistic revision, formal adoption and publication in the Official Journal, and the Parliament’s summary does not say whether it keeps the deletion of Art. 33Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 33Click opens the article on EUR-Lex. (European Parliament Legislative Train). It is not law. In the consolidated text of 18 May 2026, Art. 33Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 33Click opens the article on EUR-Lex. still provides for the glossary, and Decision (EU) 2025/1175 applies.

What the law leaves open

• Units placed on the market before 30 July 2026 under the 2022 names. The Regulation ties the new names to labelling “cosmetic products placed on the market” within twelve months of publication of the glossary (Art. 33Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 33Click opens the article on EUR-Lex.). Decision (EU) 2025/1175 repeals Decision (EU) 2022/677 and applies from 30 July 2026, and it carries no provision for units already on the market. No article of the Regulation or the Decision says that such a unit must be relabelled, or that it may stay. Meanwhile: put the 2025 names on every unit you place on the market from 30 July 2026, and check the names on older stock against the new glossary.
• The language of the word “ingredients” on the pack. Art. 19(5)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 5Click opens the article on EUR-Lex. does not name point (g), which sets the heading “ingredients”. No article says which language that heading takes. Meanwhile: use the language of the country where the product reaches the end user, and keep the glossary names as they are.

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