Common Name
In the US, the law and regulations state that the ingredients in the ingredient declaration should be identified by their common name1. But what is that, exactly?
Most Cosmetic Ingredients
Generally, what is considered the common name for a cosmetic ingredient is the name that is adopted in the International Cosmetic Ingredient Dictionary (ICID) published by the Personal Care Product Council.2 That is the name that is commonly and internationally used to identify a specific cosmetic ingredient.
Where an ingredient has several aliases or synonyms, the one that is used in the ICID is the one that should be used in the ingredient declaration. For example, common baking soda is known in various regions and industries as “baking soda,” “sodium bicarbonate,” “sodium hydrogencarbonate,” “bread soda,” “cooking soda,” “carbonic acid” and/or “bicarbonate of soda.”3 However, it is listed in the ICID only as “sodium bicarbonate,” which is how it should be identified in a cosmetic ingredient declaration.4
In the event that a cosmetic ingredient is not listed in the ICID, the following sources should be consulted to locate the correct name:5
- United States Pharmacopeia
- National Formulary
- Food Chemicals Codex
- USAN and the USP dictionary of drug names
- In the absence of such a listing, the name generally recognized by consumers.
- In the absence of any of the above, the chemical or other technical name or description.
So far, emulsifying wax is the only cosmetic ingredient that has been found which frequently used by handcrafters but that is NOT listed in the ICID (it was removed prior to 2002). It is listed the National Formulary and so long as the formulation of the emulsifying wax complies with specification of the National Formulary,6 the name “Emulsifying Wax NF” may be used in the ingredient declaration.7
Botanical Ingredients
In 1995, the Cosmetic Ingredient Dictionary went international and became the International Cosmetic Ingredient Dictionary. As part of being adopted as the European standard for cosmetic ingredient naming, the ICID adopted the international system of identifying botanical ingredients according to the Linne species/genus system with the English name in parentheses. However, when they petitioned the FDA to accept this change, the FDA denied the petition stating:
"[W]e cannot accept the current CTFA proposal that the genus/species names, using the Linne system in the primary position with the English plant name in parenthesis, be allowed for the purpose of declaring botanical ingredients on the labels of products intended for distribution and sale in the United States."8
Later editions of the ICID have taken this even further, removing the parenthetical English name from most botanicals. This is the name that is most often referred to as the “INCI name” and which most commonly causes confusion.
The FDA has steadfastly maintained that the common name for botanical ingredients is the common English name for the plant, NOT the name included in the ICID. The genus/species name may be included in parentheses, but not used as the primary name. Note that where the ingredient is derived from specific parts of a plant, the ICID standard is to include the plant part and the form.
Acceptable examples:
- Lavender Oil
- Lavender (Lavandula Angustifolia) Oil
- Shea Nut Butter
- Shea (Butyrospermum Parkii) Nut Butter
- Orange Peel Powder
- Orange (Citrus Aurantium Dulcis) Peel Powder
Comment: While the current regulations and statements by the FDA consistently hold that the common English name should be used to identify botanical ingredients, there are numerous cosmetic products on the market which use only the scientific name as adopted by the ICID in recent editions. There is no indication that the FDA has taken – or is likely to take – enforcement action against cosmetic products which use only the scientific species/genus name to identify botanical ingredients in the ingredient declaration.
1 15 USC 1454(c)(3) – Fair Packaging and Labeling Act
2Current Issues in the Safety and Labeling of Cosmetics. Office of Cosmetics and Colors, FDA. YouTube, 2011. Video, 30:42 min.
3 “Sodium Bicarbonate.” Wikipedia.
4 “Sodium Bicarbonate.” Joanne Nikitakis and Beth Lange (Editors), International Cosmetic Ingredient Dictionary and Handbook, 16th ed. Personal Care Products Council, Washington DC, 2016.
5 21 CFR 701(3)(c) – Designation of Ingredients
6 "Emulsifying Wax." US Pharmacopeia. January 1, 2007.
7 There are a number of ingredients sold as “emulsifying wax” and not all of them meet the NF specifications. Where the emulsifying wax does not meet the NF specifications, it is considered a “blended ingredient” and all of the component ingredients must be listed individually in the ingredient declaration based on their percentage of the whole. See Ingredient Declaration: General Requirements
8 FDA. Letter to G. N. McEwen, CTFA. June 1, 1995. "FDA Response to CTFA Requests Regarding Harmonization of Ingredient Names"
