INCI – International Nomenclature of Cosmetic Ingredients

This topic is part of the SG Systems Global regulatory & operations glossary.

Updated October 2025 • Cosmetics Labeling, MoCRA Alignment, Master Data • R&D, Regulatory, QA, Packaging, Supply Chain

INCI (International Nomenclature of Cosmetic Ingredients) is the standardized naming system used across the cosmetics industry to declare ingredients on labels and technical documents. It is the common language that lets scientists formulate, regulators review, retailers list, and consumers compare—without decoding trade names or regional synonyms. Practically, INCI is master data that must be governed with the same discipline you apply to recipes, labels, and genealogy: versioned under Document Control, embedded in the label engine, tied to formulas, and protected by audit trails. With the U.S. MoCRA tightening expectations on safety substantiation, listings, and labeling, sloppy INCI practices are no longer a paperwork nuisance—they are a regulatory risk and a retail blocker.

“If your INCI table lives in a spreadsheet on someone’s desktop, your label isn’t compliant—it’s lucky.”

1) What INCI Covers—and What It Does Not

Covers: the standardized names that appear in ingredient declarations, safety dossiers, product information files, and retailer/lister portals. It includes mapping of supplier trade names to INCI, governance of synonyms and multi‑component ingredients, handling of botanicals and extracts, fragrance/flavor disclosures, color additives, and allergen signaling. INCI also covers how names flow into pack panels, e‑commerce content, and GS1 data (see GTIN/EPCIS attributes).

Does not cover: casual marketing descriptors (“clean,” “natural,” “toxin‑free”) or technical claims that sit outside the ingredient list. INCI does not replace safety substantiation, laboratory testing, or jurisdictional restrictions. And it does not excuse data‑integrity failure: ingredient names on artwork must come from controlled systems—not copied by hand from legacy files.

2) Legal, System, and Data Integrity Anchors

Retailers and regulators expect standardized ingredient declarations. In the U.S., the MoCRA framework strengthens obligations for facility registration, product listing, adverse event reporting, safety substantiation, and labeling updates (including fragrance allergen disclosures as timelines mature). Electronic records supporting INCI and label control must meet Part 11/Annex 11 expectations: validated applications (CSV), unique users (UAM), secure audit trails, and resilient record retention. Bottom line: a compliant INCI program is a governed data pipeline from supplier to shelf, not a PDF library.

3) The Evidence Pack for INCI Compliance

Build an “INCI pack” per product that an auditor or retailer can follow without a guided tour: (i) master ingredient table (INCI name, role/function, allergens, restrictions, and permissible ranges); (ii) supplier mapping (trade name → INCI) with COAs and spec sheets; (iii) formula record linking %w/w and batch instructions (Products & Formulas); (iv) jurisdictional listing logic (order‑of‑listing and threshold rules) referenced for the markets you sell; (v) pack artwork approvals under Labeling Control; (vi) label print proofs plus label verification scans; (vii) change history with reasons/approvals (Change Control); (viii) data‑integrity evidence (audit trail, users, timestamps); (ix) safety/test references (Lab Analyses & Review). Store under Document Control with effective dates.

4) From R&D Brief to Shelf—A Standard Path

1) Define & source. R&D drafts target claims and a preliminary formula; Procurement onboards suppliers under VQ/SQM; raw materials receive provisional INCI mappings.

2) Validate names. Regulatory confirms INCI names and localized presentation; synonyms and botanicals are fixed under Document Control; allergens and color additives are flagged.

3) Build formula master. Author the product record with governed ingredients, %w/w, and market scope in Recipe Management; route for approval via Recipe Versioning.

4) Artwork & copy. Artwork Control pulls INCI master data and generates ingredient panels; proofs circulate for sign‑off; label verification rules are set in line‑side scanners.

5) Execution & release. Ingredients flow through Incoming Inspection and Component Release; batches execute under MES with labels printed from governed data; QA reviews the eBMR and artwork proofs before shipment.

6) Market support. Listings, GS1 syndication, and retailer portals consume the same INCI source; changes trigger NoC to partners as required.

5) INCI Master Data—The Model That Doesn’t Break

Design “Ingredient” as a governed entity: INCI name, synonyms/trade names, function (emollient, surfactant, colorant), allergens, restrictions/notes by jurisdiction, CAS (when applicable), origin (animal/plant/synthetic), processing aids/solvents, and label presentation. Link ingredients to product formulas with concentration ranges and to WMS item masters/lots. Build an approval matrix so regulatory, QA, and brand sign off changes, each with e‑signatures under audit trail. If your data model can’t express “same INCI, different market presentation,” you’ve engineered rework and relabel risk.

6) Naming Rules—Precision Beats Personality

INCI syntax is precise. Normalize capitalization, hyphenation, salts/hydrates, and mixture descriptors. Keep trade names out of ingredient lists; store them as supplier aliases. For multi‑component raw materials, list the components individually by INCI unless a permitted collective term applies (e.g., “Fragrance”). For blends (surfactant systems, botanical complexes), ensure the label engine expands the components correctly for the market in scope—no manual “find/replace.” Codify rules in the label engine and lock them under Document Control.

7) Botanicals, Extracts & Ferments—Where Errors Multiply

Botanicals require the correct Latin binomial, plant part, and extraction medium where required by market. Extracts and ferments introduce variability (solvent, carrier, residuals). Govern standard presentations (e.g., “Camellia Sinensis Leaf Extract”) and tie variants to the same canonical entry with notes for solvent/carrier disclosure. Capture allergens associated with botanicals (e.g., nut‑derived oils) and bind to Allergen Control so warehousing and production safeguards match the label promise.

8) Fragrance, Flavor & Allergen Disclosure

“Fragrance” and “Flavor” are permitted collective terms in many jurisdictions, but allergen disclosures may still be mandated once thresholds are met. Build an allergen table for fragrance components and connect it to the ingredient engine so labels can render required statements as rules come into force under MoCRA and other frameworks. Don’t wait for enforcement dates—design once and toggle by market rules. Verification belongs in label verification checks at print and pack.

9) Color Additives—Names, Not Nicknames

Color additives may require precise identifiers and in some markets certification. Build colorant families into the INCI master with market notes and eligibility. If a color is prohibited in a market, the product should be ineligible for pack copy in that jurisdiction until the formula changes—enforce with Labeling Control interlocks and WMS release holds. Never translate colorant names into marketing prose on the ingredient panel; keep the ingredient list factual and standardized.

10) Order‑of‑Listing & Thresholds—Rules, Not Rituals

Ingredient order on labels is governed by market rules (often descending by predominance above a threshold, with flexibility below it). Bake jurisdictional listing logic into the label engine with clearly authored rules—don’t leave it to artwork operators to remember whether 1% or 0.5% triggers a switch. Tie listing logic to the approved product formula; if %w/w changes push an ingredient across a threshold, the label should re‑render automatically and re‑route for approval under Change Control.

11) CAS, Synonyms & Trade Names—One Truth, Many Aliases

Suppliers bring trade names and CAS numbers; R&D speaks chemistry; labels must speak INCI. Maintain a cross‑reference table (CAS, EC, trade) → INCI and lock it to the ingredient master. Never allow artwork to pull “whatever the vendor wrote”—vendors change blends and carriers. If a supplier issues a NoC, require re‑verification that the INCI mapping still holds. Ambiguity is the enemy—kill it in the data model, not in email threads.

12) Claims, Safety & Substantiation—Names Must Match Evidence

INCI is not a claim—but claims depend on ingredients. Align your claim language with the INCI list and safety substantiation. If the formula shifts carriers or residual solvents, verify claims and warnings. Park test data under Lab Analyses & Review and route claim copy through Labeling Control. Don’t let marketing “go live” while the INCI list is still in draft; that is how you buy rework and returns.

13) Artwork & Printing—Control the Last Mile

Ingredient panels must be rendered from the governed INCI source, not retyped. Enforce templated panels, fonts, and spacing in the label engine; prohibit manual edits to the text objects. At print, require verification scans to ensure the SKU/market variant uses the correct panel. Reprints demand reason codes and must be linked in the audit trail. If a printer UI allows free‑text ingredient edits, you have a counterfeit gateway—close it or expect findings.

14) Supplier & Change Management—Upstream Determines Downstream

Quality begins at onboarding. Vet suppliers under VQ/SQM; require COAs with INCI references and allergen statements; tie deviations to SCAR when mappings drift. Any change in carrier, solvent, preservative, or botanical source triggers NoC and internal Change Control. If Procurement can swap suppliers without re‑approval, your INCI program is built on hope.

15) Digital Shelf & Syndication—One Feed, Many Channels

E‑commerce and retail portals demand ingredient data in structured feeds. Publish INCI panels from the same source that prints your labels—never from marketing spreadsheets. Use GTIN and, where applicable, EPCIS events to keep digital listings in lockstep with pack copy and Pack & Ship operations. If your website shows different INCI than your label, you’ve created a consumer‑protection problem and a complaint magnet.

16) Data Integrity—Reconstructable or It Didn’t Happen

Every ingredient list must be reconstructable: which master version, which formula %w/w, which market rules, who approved, and when. Enforce named users (UAM), immutable audit trails, and tested backups (Record Retention). Ban side‑systems (shadow spreadsheets, ad‑hoc word processors). If a junior auditor can’t rebuild the panel in minutes from governed data, your controls are insufficient.

17) Production Reality—Prevent Mix‑ups Before They Print

INCI discipline protects execution. Use line clearance to prevent mixed labels or wrong‑market panels; configure WMS to stage only eligible components; and interlock label prints to batch/variant identity. If a formula change removes an allergen, production should block old labels automatically. If operations can override ingredients on the label “to ship today,” you’ve built a recall engine.

18) Metrics That Matter—Turn Governance into Outcomes

• First‑Time‑Right Artwork (% panels approved without rework) by brand and market.
• INCI Drift Incidents (label vs. master mismatch) and time‑to‑correction.
• Supplier NoC Latency (days from vendor change notice to master update).
• Allergen Mismatch Rate (declared vs. actual) and near‑miss counts.
• Reprint Reason Codes completeness and recurrence.
• Audit‑Trail Review Health (on‑time reviews, significant events closed).
• Digital Shelf Parity (website/retailer feeds vs. label) by SKU.

Metrics exist to change behavior. Retire any metric that doesn’t drive a decision or an improvement action—vanity graphs don’t protect brands.

19) Common Pitfalls & How to Avoid Them

• Free‑text botanicals. Govern Latin names and extraction notes; never let artwork invent its own plant naming scheme.
• Copy‑paste from supplier PDFs. Map trade/CAS to INCI in the master first; then render labels.
• Threshold amnesia. Encode jurisdictional listing rules in the label engine; stop relying on memory.
• Shadow spreadsheets. Move ingredient panels into validated systems with audit trails.
• Uncontrolled reprints. Treat ungoverned reprints as counterfeit risk; require e‑sign and linkage.
• Supplier drift. Enforce NoC and SCAR for composition changes.
• Digital/physical mismatch. Publish one source to both; audit parity monthly.
• Claims divorced from ingredients. Route copy through Labeling Control tied to the INCI master.

20) What Belongs in the INCI Dossier

Canonical ingredient master; supplier mappings (trade→INCI) with COAs; allergen/colorant notes; jurisdictional listing logic; approved product formula with %w/w; artwork proofs and approvals; label print logs and verification scans; change‑control records; adverse event handling linkages; data‑integrity evidence (audit trails, UAM); and references to MoCRA readiness activities. House under Document Control with effective dates and approvals.

21) How This Fits with V5 by SG Systems Global

One INCI source of truth. The V5 platform maintains the INCI master as governed data tied to formulas, suppliers, and market variants. Changes flow through Recipe Versioning/Change Control with approvals and full audit trails.

Artwork & print integration. V5’s label engine renders ingredient panels from the master; verification scanners enforce correct panel/market at pack. Reprints demand reason codes; all actions are attributable (UAM).

Supply chain & listing. With WMS and EPCIS, V5 synchronizes physical inventory and digital shelf content; ASNs and retailer feeds reflect the same INCI truth that prints on pack.

Bottom line: V5 operationalizes INCI—one name, one label, one feed—so compliance risk drops, change velocity increases, and relabel costs stop bleeding margin.

22) FAQ

Q1. Is INCI legally required?
Jurisdictions require standardized ingredient declarations; INCI is the de‑facto standard widely recognized by regulators and retailers. Implement it as governed master data and tie it to labels and listings.

Q2. How do we handle supplier blends with partial disclosure?
Require sufficient disclosure to map to INCI and allergens; if the supplier won’t provide details, treat it as high risk, escalate via SQM/SCAR, or replace the material.

Q3. How do we manage different markets’ listing rules?
Author one canonical formula and INCI set; configure market‑specific rendering rules in the label engine; route each variant through Labeling Control.

Q4. Can marketing rename INCI for readability?
No. Keep INCI standardized on the ingredient panel. Marketing copy lives elsewhere and must still be factual and consistent with the formula and safety substantiation.

Q5. What triggers a relabel?
Any formula change that alters ingredient composition/order, allergen status, colorants, or market rules. Run changes through Change Control and re‑approve artwork.

Q6. How do we prove data integrity for labels?
Use validated systems (CSV) with named users (UAM), immutable audit trails, and tested retention. Labels must be generated from the master—no manual transcriptions.

Related Reading
• Governance & Regulation: MoCRA | Document Control | Change Control | Audit Trail | Record Retention
• Formulation & Quality: Products & Formulas | Laboratory Tests | Risk Management
• Label & Execution: Labeling Control | Label Verification | WMS | EPCIS | ASN
• Supplier & Materials: Vendor Qualification | SQM | COA | NoC | SCAR