Labeling woes

So out of 12 markets I've done ( I know, not a lot yet), I haven't seen one vendor label their products in the way everyone here is always saying it should be done. I realize that soap technically doesn't even have to be labeled with ingredients, but when it IS labeled, shouldn't it be done correctly? lotions/cosmetics I know have strict guidelines but I have yet to see those properly labeled as well. For example
Lotion label
Olive, shea butter, beeswax, sunflower, essential oils and or fragrance, preservative (or says brand name of the preservative)...
Soap is similarly labeled, usually just stating may contain oils of.... And essential oil blend or fragrance

I've had customers say I have a long ingredient list compared to others but I use inci nomenclature as well as common name as is required by FDA. So...each of my ingredients has two names making the label seem long. I also use phenoxyethanol, sorbic acid... You get the idea. How do I respond to these customers? How can I tactfully state that Im just following the law?

You just say, "I prefer follow the law."

Following the law does not require explanation or justification. You are not saying anything bad about the other vendors. If you absolutely must prove it to someone, print out the law where it is stated. Keep it in your purse or somewhere inconspicuous, but available for if/when the other vendors come challenge you.

You don't need to label as long as you have a list of ingredients on your stall that was what I learned from trading standards so I would do that than have long labels

I label all my products with INCI and basic names. It's required to labeled on all products other than soap. I also label my soaps though too.

elmtree said:

I've had customers say I have a long ingredient list compared to others but I use inci nomenclature as well as common name as is required by FDA. So...each of my ingredients has two names making the label seem long. I also use phenoxyethanol, sorbic acid... You get the idea. How do I respond to these customers? How can I tactfully state that Im just following the law?

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This is not a woe, this is an opportunity for you to explain to people why you label with your full ingredient listing according to the law.

I label all my soap and cosmetic products with the INCI and common names, with tinctures and other herbal items I label with the botanical name, common name, lot #, mfg date, ratios, etc. etc. etc.

I might say "I use the best ingredients available and I am proud of them so I list them fully on my package, that way I am both following the law and showing people exactly what they are purchasing." or something like that.

gurdeep said:

You don't need to label as long as you have a list of ingredients on your stall that was what I learned from trading standards so I would do that than have long labels

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This is not true for cosmetics. Labels must be on products and be able to be read and include inci and common names for each ingredient. This is regulated by the FDA. Federal regulations are not something to mess with. I'm not sure why craft fair organizers would say this was ok. Seeing what the government does to farms that sell raw milk, they obviously have nothing better to do than to find and harass the little guy.

maya said:

This is not a woe, this is an opportunity for you to explain to people why you label with your full ingredient listing according to the law.

I label all my soap and cosmetic products with the INCI and common names, with tinctures and other herbal items I label with the botanical name, common name, lot #, mfg date, ratios, etc. etc. etc.

I might say "I use the best ingredients available and I am proud of them so I list them fully on my package, that way I am both following the law and showing people exactly what they are purchasing." or something like that.

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Yes, very good explanation! Thank you! Good idea.

shunt2011 said:

I label all my products with INCI and basic names. It's required to labeled on all products other than soap. I also label my soaps though too.

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I label everything as well. There are so many allergies and so many ingredients people don't want in their soaps etc that why even risk it. Plus,
I do like putting my ingredients on because I do have a nice looking list of oils! Thanks everyone!

I label everything with INCI and basic, plus a very I have a warning label such as peppermint soap

cmzaha said:

I label everything with INCI and basic, plus a very I have a warning label such as peppermint soap

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This is a good idea as well and I have been thinking of doing this myself. I verbally counsel customers on pregnancy, nursing, and epilepsy and essential oil usage as much as possible. Thanks cmzaha!

I label my soap with common names, but everything else with INCI. It does, however, irk me when I see labels or websites without any type of ingredient lists. "What are you hiding?"

maya said:

This is not a woe, this is an opportunity for you to explain to people why you label with your full ingredient listing according to the law.

I label all my soap and cosmetic products with the INCI and common names, with tinctures and other herbal items I label with the botanical name, common name, lot #, mfg date, ratios, etc. etc. etc.

I might say "I use the best ingredients available and I am proud of them so I list them fully on my package, that way I am both following the law and showing people exactly what they are purchasing." or something like that.

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I think you said that very well!

I am going to give you the FDA's cosmetic labeling requirements because you DO NOT have to label in both ways.

Identification of Ingredients by Name

1. The name established by the commissioner as specified in § 701.30.
2. The name adopted for the ingredient as listed in:
   
   (a) CTFA Cosmetic Ingredient Dictionary
   (b) United States Pharmacopeia
   (c) National Formulary
   (d) Food Chemical Codex
   (e) USAN and the USP Dictionary of Drug Names
   
3. The name generally recognized by consumers
4. The chemical or technical name or description

21 CFR 701.3(c)
Section 701.3(c) requires that an ingredient be identified by the name established by the Commissioner for the purpose of cosmetic ingredient labeling or, in the absence of a name established by the Commissioner, the name adopted for that ingredient in the editions and supplements of the compendia listed below.
The Commissioner may establish a name as petitioned or propose such a name on his own initiative. See section 701.3(e). The names specified by the Commissioner are listed in section 701.30.
The currently recognized edition of the CTFA (Cosmetic, Toiletry and Fragrance Association, Inc.) Cosmetic Ingredient Dictionary is the second edition published in 1977. This edition is recognized only in part, i.e., not all names listed in the second edition have been adopted.
The third edition of the CTFA Cosmetic Ingredient Dictionary published in 1982 and the Supplement published in 1985 have not yet been recognized. However, FDA has informed the CTFA that the agency will not take regulatory action against products labeled in accordance with these editions while their review is in progress.
The compendia are listed in the descending order by which they must be utilized for identification of an ingredient name. If none lists a name for an ingredient, the name generally recognized by consumers, or the chemical or technical name or description, must be used.

I understand you like using both but it is not necessary. If you are wondering where the dictionary that lists the name of the ingredients can be found it is here: https://law.resource.org/pub/us/cfr/ibr/003/cfta.cosmetic.1977.pdf

Note that most ingredients are in their common names as well. So cocoa butter is there, so is Apricot kernel oil, and most others.

Now I'm assuming you are in the US, because if not I have no idea what is required. However using common names in cosmetics is not a bad thing, it is not the law that you need to use the chemical names.

I know that in the UK, INCI is expected - nothing else in required, but you must have the INCI names.

"...I use inci nomenclature as well as common name as is required by FDA..."

If y'all are in the USA, that is NOT what the FDA says. Please read this May 2013 article from Marie Gale who specializes in this issue: http://blog.mariegale.com/botanical-names-ingredient-declarations/

Summary: "...Based on some fairly recently posted information on the FDA website, it is now clear that common names are required, and when used as a secondary listing, Latin names are accepted. Although the “INCI name” (which usually means the Latin name) is commonly thought to be required, it isn’t – it’s optional...."

As Dorymae points out, this is not true in other countries.

Very interesting indeed! It seems that many people are confused by the previously wishy washy FDA regulations. This does clear things up for me. How does this work for emulsifiers and ingredients with several ingredients in them? Like BTMS for example? I've seen numerous labels that state 'essential and or fragrance oils'. Isn't it really important that each essential oil be included? I mean pregnant, epileptic, elderly, the infirm, and children may use these products not realizing that one or more essential oils may not be safe for them.

elmtree said:

Very interesting indeed! It seems that many people are confused by the previously wishy washy FDA regulations. This does clear things up for me. How does this work for emulsifiers and ingredients with several ingredients in them? Like BTMS for example? I've seen numerous labels that state 'essential and or fragrance oils'. Isn't it really important that each essential oil be included? I mean pregnant, epileptic, elderly, the infirm, and children may use these products not realizing that one or more essential oils may not be safe for them.

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BTMS or Behentrimonium Methosulfate is not listed in the cosmetics dictionary. Therefore you may choose to either use the most common name BTMS or the chemical name . If you are using BTMS 50 and choose to use the chemical name you would need to use Behentrimonium methosulfate (and) cetyl alcohol (and) butylene glycol or you could just say BTMS-50.

As for essential oils and fragrance oils it is fine legally to list them as such. However remember no matter how you label them YOU are responsible for the safety of your product. So if you are using a essential oil you know should not be used by pregnant women it would be prudent not only to list the name of the essential oil but also a warning on the label that the product is not intended to be used by pregnant women.

Added a disclaimer that I am not an attorney - I just read a lot.

DeeAnna said:

"...I use inci nomenclature as well as common name as is required by FDA..."

If y'all are in the USA, that is NOT what the FDA says. Please read this May 2013 article from Marie Gale who specializes in this issue: http://blog.mariegale.com/botanical-names-ingredient-declarations/

Summary: "...Based on some fairly recently posted information on the FDA website, it is now clear that common names are required, and when used as a secondary listing, Latin names are accepted. Although the “INCI name” (which usually means the Latin name) is commonly thought to be required, it isn’t – it’s optional...."

As Dorymae points out, this is not true in other countries.

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I've seen this issue go round and round so many times that my head spins at the thought.. What is the proper way to label cosmetics? Common name (INCI name) or INCI (common name) or just common name?

Common name is correct and what the FDA wants and expects. However they will accept the common name first and then the INCI name in ( )'s if you wish to include it.

Again not an attorney, I just read the FDA website.

That's what I thought too after I read a Soap Queen post and the FDA website but then I was told that it should be in INCI format so I changed all of my labels because I just assumed I had misinterpreted.