How Should Ingredients Be Named in a Cosmetic Product Safety Report? INCI, CAS Numbers and the CPSR Submission Sheet

Half the delay in cosmetic compliance is translation. A submission arrives listing lavender oil, emulsifying wax NF, Optiphen and a fragrance called Midnight Fig, and before any assessment can begin someone has to work out which substances those actually are. A Cosmetic Product Safety Report cannot start from trade names, because Part A has to identify every substance precisely enough to screen it against the annexes of Regulation (EC) No 1223/2009 and retrieve toxicological data for it, and the label under Article 19, enforced through the Cosmetic Products Enforcement Regulations 2013, must use INCI names. The CosIng database and ECHA's chemicals database exist precisely to remove this ambiguity, and they are free.

This article is the naming guide Spectra's assessors would hand every new client. It explains what INCI names and CAS numbers are and which document each serves, how to name fragrance blends, essential oils, aroma chemicals and blended raw materials, how to search CosIng and ECHA, the seven naming errors that delay reports, the submission sheet we ask for and what each column does, how the names flow from your formula into Part A and onto your label, a worked example of a three scent range documented properly, and what to keep in the Product Information File afterwards. Get the naming right once and every document that follows is faster, cheaper and more accurate.

What are INCI names and CAS numbers, and which document needs which?

INCI, the International Nomenclature of Cosmetic Ingredients, is the standardised naming system maintained by the Personal Care Products Council and adopted in CosIng and in UK and EU law. Every ingredient on a cosmetic label must appear in its INCI name in descending order of weight: Aqua, Glycerin, Simmondsia Chinensis Seed Oil, Parfum, Linalool. A CAS number is the unique registry number assigned to a distinct chemical substance, and it identifies that substance regardless of what anyone calls it. The Cosmetics Regulation's annexes, supplier safety data sheets and toxicological databases all work from CAS numbers. So the INCI name serves the label and the composition table in Part A, and the CAS number serves the annex screen and the toxicological profile in Part A section 8. A Cosmetic Product Safety Report needs both, and a brand that records both from the day a material arrives never has to reconstruct them under time pressure.

How are the difficult materials named?

How do I search CosIng and ECHA?

CosIng is searched by INCI name, chemical name, CAS number or EC number, and returns the INCI name, the CAS and EC numbers, the declared functions, and any annex entry with a link to the relevant restriction. It is free and it is the practical authority for INCI names in both the EU and the UK. The PCPC INCI dictionary is the underlying source and offers lookups for many names. ECHA's database, searched by CAS number or substance name, confirms the substance's identity and classification under REACH, which is where to check that a CAS number really belongs to the material you think it does rather than to a related isomer. For botanicals, CosIng's naming of genus, species, plant part and preparation is definitive: a supplier writing lemon oil should be corrected to Citrus Limon Peel Oil, and the distinction between peel oil and fruit extract is not pedantry, because they are different materials with different constituents and different phototoxicity.

The seven naming errors that delay a Cosmetic Product Safety Report

• Trade names in the formula. Optiphen, Emulsifying Wax NF, Ecogel: each must be broken down into component INCI names with percentages.
• Common names instead of INCI. Lavender oil, vitamin E, shea butter become Lavandula Angustifolia Oil, Tocopherol, Butyrospermum Parkii Butter.Scent names as ingredients. Midnight Fig is not an ingredient; the label says Parfum and the assessment needs the constituents.
• Blends recorded as one line. An emulsifying wax is two or three substances at different levels.
• Missing plant part. Citrus Limon Peel Oil and Citrus Limon Fruit Extract are not interchangeable.
• Wrong or absent CAS numbers. A CAS number for a related substance sends the assessor to the wrong toxicological data.
• Percentages that do not total 100. The commonest arithmetic error in submissions, and an automatic query.

The submission sheet Spectra asks for

One spreadsheet, one row per ingredient, with these columns: INCI name; trade name and supplier; CAS number and EC number where applicable; percentage in the formula to two decimal places; function; and the documents held, with dates, for the safety data sheet, specification, IFRA certificate, allergen statement and certificate of analysis. A second sheet lists the constituents of every fragrance and essential oil, with INCI names, CAS numbers and percentages taken from the allergen statement or gas chromatography report. That is the whole requirement, and a submission arriving in that form is the reason some Cosmetic Product Safety Reports are delivered in three days while others take five weeks. The same sheet then becomes an asset: when a regulation changes, it is how you find in minutes which of your products are affected, rather than opening forty supplier PDFs.

How do the names flow into Part A and onto the label?

Part A section 1 records every ingredient by INCI name, trade name and supplier with its exact percentage, and the assessor uses the CAS numbers to screen each against Annex II for prohibitions and Annex III for restrictions, and against the positive lists in Annexes IV, V and VI for colourants, preservatives and UV filters. Fragrance blends are expanded by CAS number so each sensitising or phototoxic constituent is assessed individually and the allergen declaration is calculated. Section 8 uses the same CAS numbers to retrieve toxicological data for each substance. The label ingredient list is then generated from the formula: descending order of weight above one percent, then free order, with Parfum standing for each fragrance blend and its declarable allergens named after it, essential oils by botanical name, colourants by CI number at the end, and nano materials marked. A blended raw material's components appear in their own positions, which can mean they sit in different parts of the list.

Why does Part A need percentages to two decimal places?

Because almost every calculation in the assessment runs off them. The margin of safety for an active depends on its exact level, not a range. The allergen declaration depends on the allergen's percentage in the concentrate multiplied by the concentrate's percentage in the formula, so a fragrance recorded as about two percent produces a declaration that is about right, which is not a standard a label can be printed to.

Annex III limits are numerical and several sit at levels such as 0.1 or 0.001 percent, where rounding decides compliance. And where the same substance arrives from two sources, a fragrance and an essential oil for example, the contributions are summed, which cannot be done from approximations.

Submitting a formula that totals 100.00 percent with two decimal places on every line is therefore not bureaucratic tidiness; it is the input the Cosmetic Product Safety Report is calculated from. Accurate percentages also allow the assessor to trace individual chemical substances through the formulation and assess their relevant exposure and restrictions.

A worked example: a three scent body oil range

A brand launches one body oil base in three scents: a fragrance oil, a lavender essential oil, and a two-molecule accord. For the fragrance oil the sheet records the trade name, code and supplier, Parfum as the label name, and the constituent sheet takes coumarin, benzyl benzoate and linalool with CAS numbers and percentages from the allergen statement.

For the lavender it records Lavandula Angustifolia Oil with its CAS Registry Number from CosIng, the supplier and the lot, and the constituent sheet takes linalool, linalyl acetate, limonene and geraniol from the gas chromatography certificate.

For the accord it records both molecules by INCI name and CAS, and the assessor screens both against Annex III and finds both are declarable allergens.

The Cosmetic Product Safety Report is written as a multiple variant report: one base assessed once, three scents assessed for their differences, three label ingredient lists generated, each with Parfum or the botanical name and the correct allergens after it. Delivery, three working days.

When the expanded allergen list lands, the brand filters its constituent sheet and finds in under a minute that one variant needs a new declaration. Accurate CAS Registry numbers help the assessor distinguish individual substances and cross-check information against authoritative databases and supplier documentation.

What about ingredients with no INCI name at all?

Occasionally a material arrives that CosIng does not list: a novel botanical preparation, a bespoke blend from a small supplier, a biotech-derived ingredient new to cosmetics. This is not a dead end, but it is a decision point.

The supplier should be able to supply the substance identity, the CAS number or EC number where one exists, the manufacturing route and a toxicological dossier, and an INCI name can be applied for through the Personal Care Products Council process, which takes time.

A CAS Registry Number is a unique identifier assigned through the Chemical Abstracts Service, and where one exists it can help establish the identity of a chemical substance. However, a CAS number by itself does not provide the safety information needed for a cosmetic assessment.

Without an INCI name the ingredient cannot be listed correctly on a label, and without an identity and data the assessor cannot profile it, so a Cosmetic Product Safety Report cannot conclude.

The practical advice is to establish before purchase whether a novel material has an INCI name and a dossier; a fascinating ingredient that cannot be named is an ingredient that cannot be sold, however good the marketing story.

What to keep afterwards

The submission sheet and the constituent sheet belong in the Product Information File alongside the supplier documents, because the PIF must describe the product's composition and hold the raw material information the assessment relied on.

Keep the documents matched to lot numbers in your batch records, so that a certificate of analysis can be tied to the batch a customer bought. Supplier Safety Data Sheets should also be retained with the relevant raw material documentation, particularly where they provide substance identity, classification or composition information.

Update the sheet whenever a supplier, a grade or a percentage changes, and tell your assessor, because a change of supplier for a fragrance is one of the most common triggers for an addendum.

For every raw material, keep the available CAS Registry numbers, EC numbers, INCI names and supporting supplier documentation together. This creates a clear traceability record and makes it easier to cross-check chemical substances against relevant authoritative databases when the formulation or regulatory requirements change.

Our article on choosing a CPSR partner covers what an addendum should cost and how quickly it should arrive.

Myths we hear

•      The scent name is the ingredient. The label says Parfum; the assessment needs the constituents.

•      Lavender oil is an INCI name. Lavandula Angustifolia Oil is.

•      Emulsifying wax is one ingredient. It is two or three, at different levels and in different label positions.

•      CAS numbers are only for chemists. They are how the annexes and the toxicological data identify what you used.

•      I can copy an INCI list from a similar product. Your list is generated from your formula in your order; a copied list will not match Part A and is a labelling breach.

What to do this week

•      Build the submission sheet with the columns above.

•      Look up every material in CosIng and correct the names.

•      Add the constituent sheet for every fragrance and essential oil.

•      Check that percentages total 100.

•      File both sheets in the Product Information File and keep them updated.

Naming is the least glamorous part of cosmetic compliance and the one that decides how fast everything else goes. A morning with CosIng and a spreadsheet is the best value work a small brand can do, and it is the difference between a Cosmetic Product Safety Report in three days and one in five weeks.

Related reading on the Spectra blog

•      Does one Cosmetic Product Safety Report cover every market?

•      Which fragrance documents does a Cosmetic Product Safety Report need?

•      Clean beauty and the Cosmetic Product Safety Report

•      All Spectra articles

Spectra services mentioned in this article

•      The Complete Compliance Pack: CPSR, PIF, SDS and SCPN or CPNP (£295)

•      CPSR services by product type

•      CPSR for Perfumes and Fragrances (from £84)

•      PIF services

•      UK and EU Responsible Person

•      Contact Spectra

Official sources and legislation

•      CosIng, the European Commission cosmetic ingredient database

•      PCPC INCI dictionary

•      ECHA information on chemicals

•      Regulation (EC) No 1223/2009 on cosmetic products, Article 19 and Annex I

•      Cosmetic Products Enforcement Regulations 2013

•      OPSS guidance on cosmetic products regulations

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.