530 JOURNAL OF COSMETIC SCIENCE
Over time, global acceptance of the standardized INCI naming system evolved and was
pivotal to:
Product safety: consistent identification of a substance is essential to ingredient safety
and the assessment of risk to human health and the environment.
Regulatory considerations: harmonization ensures that substances are identified
consistently across borders which streamlines the registration and tracking of substances.
Innovation: accurate, consistent substance identification is important to research and
new material evaluation for product development.
Trade: a harmonized naming system facilitates trade and reduces potential barriers that
could arise from different naming approaches between regions.
There is no question that the international harmonization of INCI nomenclature was essential
to the global cosmetics industry, but moving toward a single system was challenging. The
effort called for engagement and support for collaboration—it required recognition of the
scientific basis for INCI names by all stakeholders, a mutual understanding for differences
in naming approaches, the interest in convergence on terms, and a sustained focus to make
the system workable for all. In recent years, sharing datasets of INCI names and technical
synonyms with global authorities has facilitated reference to INCI nomenclature in cosmetic
regulatory procedures, especially in the EU, Canada, Japan, and China. The cross-indexing
of INCI names with safety, regulatory and technical information in other databases, and
the publication of INCI names in technical references and trade journals has strengthened
the recognition of INCI terms in diverse sectors and furthered the harmonization process.
While communication is an important component of harmonization, there are still
opportunities for a greater understanding about the INCI process. Two of the most common
misunderstandings are the notions of ingredient safety and approval. The assignment
of an INCI name (which occurs at the request of an ingredient supplier) does not mean
that the ingredient has been reviewed for its safety. Safety data is not required as part of
the INCI nomenclature process. Independent scientific reviews for ingredient safety are
conducted by the Cosmetic Ingredient Review (CIR, https://www.cir-safety.org) and other
scientific bodies and authorities. The finished product manufacturer has the responsibility
of assessing and documenting safety prior to marketing the final product. In a similar way,
the designation of an INCI name does not mean that the ingredient has been approved for
use in a specific global region or for a specific purpose. Companies are expected to consider
intended use and comply with the regulations in the jurisdiction where the product is
marketed. Another common misunderstanding is about equivalence. While the INC can
assign the same INCI name to different trade name ingredients, it does not necessarily
mean that they are interchangeable in a particular formulation. Polymer ingredients serve
as a good example here where some trade names may have the same INCI name but
impart different rheological properties. Finally, it cannot be assumed that a trade name
associated with an INCI name in technical literature was truly assigned that name by the
INC through the INCI process. In these instances, a supplier could mistakenly attribute
an incorrect INCI designation. Finished product manufacturers should carefully evaluate
material composition and confirm the INCI name information as part of the ingredient
selection process.
The challenge of INCI name changes and acceptance of the newer terms deserves a brief
mention. In recent years, new processes for ingredient development have given rise to new
INCI names and new INCI naming principles. When this happens, older names based on
531 INCI NOMENCLATURE INTERNATIONAL HARMONY
the outdated naming principles require change. PCPC, on behalf of the INC, will continue
to share updated INCI information with global authorities and advocate for inclusion of the
newer terms in regulatory databases so that product innovation can thrive.
In closing, knowledge of raw material composition is essential to a harmonized approach to
sustainability, just like harmony in nomenclature is necessary for ingredient selection and
product development, and ultimately for the consumer who has the right to recognize and
choose a product for its ingredients wherever it is marketed in the world.
REFERENCES
(1) Personal Care Products Council, INCIpedia. https://incipedia.personalcarecouncil.org/. Accessed
11/11/2024.
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