How to Create an INCI Ingredient List for a Cosmetic Product

An INCI-style ingredient list should be built from the complete formula and current supplier documentation—not from marketing names, memory, or another brand’s label. In the United States, FDA requires retail cosmetics to identify ingredients by applicable names and generally list them in descending order of predominance, subject to specific exceptions.

Start with the formula as manufactured

Record every raw material and its exact percentage when ingredients are combined. Obtain the supplier’s current composition or ingredient statement for blends, extracts, preservatives, fragrances, color dispersions, and premixes. A trade name such as “Silky Base 200” is not automatically the label name.

Expand compound raw materials when required by the applicable declaration method. Preserve supplier document version and lot applicability so a reformulated premix triggers label review.

Apply ordering rules carefully

FDA’s US cosmetic guidance explains that ingredients above 1% are declared in descending order of predominance. Ingredients at 1% or less may generally follow in any order, and color additives have separate ordering flexibility. Cosmetics that are also drugs require active-ingredient presentation before cosmetic ingredients.

Do not use the 1% threshold to omit an ingredient. It changes permitted order, not whether the ingredient exists. Do not assume an international INCI database by itself establishes the exact name FDA expects for every US label.

Example workflow

1. Lock the formula revision and total it to 100%.
2. Replace supplier trade names with documented label components.
3. Sort ingredients above 1% by formula predominance.
4. Review ingredients at or below 1% and colors under the applicable rules.
5. Review identity, net quantity, business information, warnings, claims, and package presentation as part of the whole label.
6. Retain the approved declaration with its formula and supplier-document fingerprint.

Use the free INCI ingredient-order generator to organize a draft from percentages. It is a formatter, not a substitute for supplier composition records, safety substantiation, claim review, or qualified regulatory review.

FDA sources

Review FDA’s current summary of cosmetic labeling requirements and cosmetic ingredient-name guidance. Requirements differ for products that are drugs, soaps under a different statutory definition, professional-use products, and international markets.

Batch Scale’s formula and document records can preserve the source formula, supplier evidence, revisions, and review history needed to maintain the declaration when materials change.