Cosmetic Ingredient Labeling Guide HC. Eng
Cosmetic Ingredient Labeling Guide HC. Eng
Cosmetic
Ingredient Labelling
Health Canada is the federal department responsible for helping the people of
Canada maintain and improve their health. We assess the safety of drugs and
many consumer products, help improve the safety of food, and provide information
to Canadians to help them make healthy decisions. We provide health services to
First Nations people and to Inuit communities. We work with the provinces to
ensure our health care system serves the needs of Canadians.
The information in this guide has been prepared to provide an overview of the INCI
labelling requirements of the Cosmetics Regulations under the Food and Drugs Act.
It is not intended to substitute for, supersede or limit the requirements under the
legislation. This guide is prepared for convenience of reference only and as such has
no official sanction. In case of discrepancy between this guide and the legislation,
the legislation will supersede the guide. In order for a product to comply, all condi-
tions of the Act must be met. A copy of the Food and Drugs Act and the Cosmetics
Regulations may be obtained by contacting your nearest Product Safety Offices
found on the Health Canada Web site. Go to www.healthcanada.gc.ca/cosmetics
and click on “Contact Us”.
© Her Majesty the Queen in Right of Canada, represented by the Minister of Health, 2009
This publication may be reproduced without permission provided the source is fully acknowledged.
HC Pub.: 4109
Cat.: H128-1/08-556E
ISBN: 978-1-100-10897-1
Table of Contents
This document is intended to help clarify the Cosmetic Regulations with respect
to ingredient labelling. It is not intended to substitute requirements under the
applicable legislation. In case of any discrepancy between this document and the
legislation, the legislation will prevail.
Table 1: Sections 21.1—21.5 of the Cosmetic Regulations which pertain to INCI labelling
Section Summary
21.1 Sections 21.1—21.5 do not apply to any product whose ingredient labelling is regulated
under the Food and Drug Regulations or the Natural Health Products Regulations.
21.2(1) Subject to subsection (4), a list of ingredients must appear on the outer label of a cosmetic,
with each ingredient listed by its INCI name.
21.2(2) In the case of makeup and nail polish and enamel sold in a range of colour shades, all
colouring agents used in the range may be listed if they are preceded by the symbol “+/-”
or “±” or the phrase “may contain / peut contenir”.
21.2(3) Botanicals must be listed by specifying at least the genus and species portions of the
INCI name.
21.2(4) An ingredient that is included in the schedule may be listed either by its European Union
(EU) trivial name set out in column I of the schedule or by the appropriate English and
French equivalents set out in columns 2 and 3.
21.3 An ingredient that has no INCI name must be listed by its chemical name.
21.4(1) Subject to subsections (2) and (3), ingredients must be listed in descending order of
predominance, in their concentration by weight.
21.4(2) Ingredients that are present at a concentration of 1% or less and all colouring agents,
regardless of their concentration, may be listed in random order after the ingredients that
are present at a concentration of more than 1%.
21.4(3) In the case of fragrance and flavour, the words “parfum” and “aroma”, respectively, may
be inserted at the end of the list to indicate that such ingredients have been added to the
cosmetic to produce or to mask a particular odour or flavour.
21.5(1) Despite subsection 21.2(1) in the case of a cosmetic whose immediate container or outside
package is so small that the label cannot comply with the requirements of paragraph 18(b),
the list of ingredients may appear on a tag, tape or card affixed to the container or package.
21.5(2) Despite subsection 21.2(1), in the case of a cosmetic in an ornamental container that has
no outside package, the list of ingredients may appear on a tag, tape or card affixed to the
container.
21.5(3) Despite subsection 21.2(1), in the case of a cosmetic that has no outside package and
whose size, shape or texture, or that of its immediate container, makes it impractical for a
tag, tape or card to be affixed to the container, the list of ingredients may instead appear in
a leaflet that must accompany the cosmetic at the point of sale.
All cosmetic products require the ingredient names to be listed on the outer label.
INCI nomenclature is not required for non-cosmetic products (however it is
acceptable for drugs and natural health products in order to list non-medicinal
ingredients). Since most cosmetics have packaging, the ingredient list should be on
the outer label, and clearly visible to the consumer at the time of purchase of the
product.
Note:
The intention of the Regulations is to have ingredients clearly visible and in
an obvious location such that consumers can read them at the point of sale.
An ingredient list should not be placed on the underside/bottom of a container
if it can be easily placed on a display panel.
The information required by the Regulations takes precedence and is of greater
priority than voluntary information listed on the product label.
Legibility:
A box listing ingredients that is wrapped in clear cellophane would be considered
acceptable since the ingredients are clearly visible. Products with ingredients listed
on the back surface of an outer label that are read through a transparent container
and clear liquids are considered acceptable unless the container and contents distort
the lettering and affect the legibility of the ingredient list.
4.3 Testers
Product testers, which allow the public to try the product prior to purchase, do not
need to supply ingredient lists. Testers usually appear in close vicinity to the
cosmetic that is available for sale. The ingredient list would appear on the label
of the product for sale, thus allowing the public to review the ingredients prior to
testing the product.
4.6 Samples
The cosmetic ingredient labelling requirements apply to samples in the same
manner that they apply to other cosmetic products.
Cosmetics such as makeup or nail polish/enamel that come in various shades can
list all colouring agents used in the range of products if preceded by the symbols
“±” or “may contain/peut contenir”. It is recommended that when the symbol “±”
or “may contain/peut contenir” is used, the colouring agents be the last ingredients
listed, in order to reduce the confusion over what substances are included under
“may contain/peut contenir”. Note that this does not apply to hair dye colourants,
but can apply to all makeup, hair mascara, and temporary coloured hair sprays that
can be rinsed off.
Colouring agents should be listed as CI numbers, or colour names (formerly
“FD&C” names). For example: CI 42090 (Blue 1). The order of listing them as
either CI# or colour name first does not matter.
Either naming conventions can be used (if they are in the International Cosmetic
Ingredient [ICI] Dictionary), however it must be clear if both are listed that they
are the same ingredient and not separate ingredients. For example: CI 42090
(Blue 1). The two synonymous names for the ingredient can be separated by
brackets or a slash, e.g. CI 42090/Blue 1, CI 15985/Yellow 6. Note that the use of
slash for colouring agents does not have the same meaning as the use of a slash
for ingredients.
Please note that not all colours have both the name and CI index listed, there are
some colours which do not have a corresponding CI number in the ICI Dictionary
(e.g. Basic Blue 99).
Please note that “FD&C” is not part of any INCI name.
Botanical and herbal ingredients must be listed using the genus and species names
(at minimum) or the complete INCI name. Examples of proper INCI names of plants
with the genus and species listed are as follows:
Aesculus hippocastanum
Salix alba
Sambucus nigra
Mentha piperita
Melaleuca alternifolia
Chamomilla recutita
As stated previously, only the genus and species of the INCI name OR the entire
name should be listed. A complete INCI name may include genus and species,
common name, plant part, and/or method of preparation. There should not be any
partial INCI names listed, however “partial” can vary depending on what the com-
plete name is in the ICI Dictionary (e.g. some botanical INCI names may not include
method of preparation). The common names of the botanical ingredients should not
be translated.
Peppermint ✗
In most cases, a slash does not mean "and" or "or" but rather indicates a reaction
between each ingredient on either side of the slash, e.g. Acrylates/Styrene
Copolymer. In the case of botanical ingredients, where a slash is between plant
parts, this means that all the indicated plant parts are used in the preparation. For
example, for Camellia sinensis flower/leaf extract, the flower and leaves were
used in the extraction.
If a vendor requires an INCI name for a plant part (alone) or a combination that is
not currently published to the Dictionary, that vendor should submit an INCI name
application at: www.ctfa-inciapplication.org
Aqua ✓ Column 1
Water/Eau ✓ Column 2 + 3
Aqua/Water/Eau ✓ Column 1 + 2 + 3
Water ✗ Column 2
Eau ✗ Column 3
Aqua/Water ✗ Column 1 + 2
Aqua/Eau ✗ Column 1 + 3
The Cosmetic Regulations require that the INCI terms “parfum” and “aroma” are
used for fragrance and flavour ingredients, respectively.
Note: The term “flavour” (Canadian spelling) does not appear in the ICI Dictionary.
It is not an official INCI name, however this spelling will be accepted because of its
reference as “flavour” in the Cosmetic Regulations.
Label reviews:
Requests for pre-market label reviews may be directed to a consultant. A list
of consultants is available through the Canadian Cosmetic Toiletry and Fragrance
Association (CCTFA) Web site. Consultants are listed under “Associate members”.
This list is available to the public. www.cctfa.ca/en/cctfa/members.php
Consultants can also be found through the local yellow pages, and by internet
search.