An Ingredient List Is the Starting Point

What the Ingredient Declaration Does

FDA explains that ingredients in cosmetics sold at retail to consumers generally must be declared using their common or usual names, in descending order of predominance, subject to the applicable labeling rules and exceptions. Its ingredient-naming guidance also explains differences between U.S. labeling requirements and some naming conventions used internationally.

TSB uses “ingredient disclosure” or “INCI” in its application to collect the submitted formula’s ingredient information. That application language is not a determination that a label meets every applicable legal naming requirement.

Sources: FDA: Cosmetic Ingredient Names · The Skincare Bureau: The Process

TSB perspective

Keep the Footnotes With the Ingredients

In TSB’s intake process, an asterisk or color key may explain a claim attached to a particular ingredient. Losing the key can change the apparent meaning. For example, a note saying “*Organic” needs to stay connected to the ingredients carrying that symbol.

Color coding creates an additional problem for plain-text copying: the ingredient names may transfer while the colors disappear. For review, preserve the original label or image and explicitly identify which ingredient each description applies to. Do not guess from an unexplained symbol.

Sources: The Skincare Bureau: The Process

TSB perspective

Separate the Wording From Its Support

Recording “cold-pressed” or “organic” in submitted material identifies a representation for review. Under TSB’s standards, the review then turns to the relevant source, processing, certification, or traceability records. The ingredient name and qualifier alone do not replace that documentation.

TSB asks brands to preserve current product information and keep it consistent across the ingredient disclosure, label, packaging, and applicable marketing. This is a review workflow, not advice to add promotional descriptions to a legally required ingredient declaration.

Sources: The Skincare Bureau: Our Standards

Questions to ask

Check the Product and Version

Before relying on a transcribed ingredient list, ask:

• Does it belong to this exact product and formula?
• Are all ingredients and explanatory notes present?
• Do the label and online listing agree?
• Has the brand confirmed any unclear symbol or description?