Ingredient Names From 1977 Still Good?

Second Edition (1977)

Second Edition (1977)

The Code of Federal Regulations specifies where to find the names by which cosmetic ingredients should be identified in the ingredient declaration on a cosmetic. First are any names “established by the Commissioner” (there are a few) and then the CTFA Cosmetic Ingredient Dictionary, Second Ed., 1977.

After some searching, I was finally able to locate a copy of this elusive book ($200 from an online used book distributor). Now I’ll share what I found in the book.

Fourteenth Edition (2013)

Fourteenth Edition (2013)

The Second edition is a mere single volume with just 513 pages. For come comparison, the Fourteenth edition (2013) was 4 very fat volumes (see picture) and the Fifteenth edition (February 2014) looks to be even larger. The parts of the book that are most pertinent to us are:

Monographs which cover defintions, structures, and other information for CTFA Adopted Names (350 pages) and

Chemical/Trade Names which cross-reference chemical terms, trademarks, generic names and common names to CTFA Adopted Names (110 pages).

NOTE: The “CTFA Adopted Names” are now the “International Nomenclature Cosmetic Ingredient” (or “INCI”) names./

Monographs

Monograph: a detailed written study of a single specialized subject of an aspect of it.

The monographs define what is meant by a particular ingredient name. Looking at the details of the monograph makes it very clear what the ingredient is. In the Second edition, plant-based ingredients (botanicals) are identified by their common name.

Second Ed. uses common names

Second Ed. uses common names

According to the publishers webiste, the current (2014) edition of the Cosmetic Ingredient Dictionary contains 21,000 monographs, which is considerably more than the Second Ed. from 1977.  If you’re using an ingredient that isn’t in the Second Ed., the FDA has indicated that they will accept ingredients from later editions (although botanicals should still be listed by the common name).

NOTE: The Code of Federal Regulations lists a number of ingredient names that were NOT adopted from the Second Ed. of the CID. They are mostly Acid and Solvent colors (i.e. “Acid Black 58″ and “Solvent Brown 43″). There is also a list of ingredients that were adopted provisionally pending revision of the monographs, which was done in subsequent editions of the CID.

Chemical/Trade Names

The second interesting section of the Second Ed. is the Chemcial/Trade Name section which cross-references chemical terms, trademarks, generic names and common names to the CTFA Adopted Names. The chemical and trade names are listed in alphabetical order on the left, with the CTFA adopted name listed on the right. Most of the time it’s pretty straight-forward.

For example, ingredients with trade names of Tween 80 (from ICI United States), Emsorb 6900 (from Malmstrom Chemical Corp) or GlycosperseO-20 (from Glyco Chemicals, Inc) should all be listed with the CTFA adopted name of Polysorbate 80.

Where it gets a little more interesting is where the CFTA adopted name consists of several components.

For example, Preservatol (from Van Dyk & Company) shows a CTFA adopted name of “methylparaben (and) propylparaben (and) benzylparaben”.

In this case, while it LOOKS like the stated CTFA is what should go in the ingredient declaration, that would be incorrect, as explained (and documented) below).

1. Note on the Chemical/Trade Name Pages:

At the bottom of each page in the Chemical/Trade Names section, there is a note that says:

“In some instances the CTFA Adopted Name does not reflect all components present. See Important Regulatory Information on page xvii.”

2. Regulatory Information (page xvii):

This section discusses ingredient labeling, and states:

“CTFA Adopted Names when applied to trade named ingredients identify the principal components in these materials. Occasionally other components such as diluents, solvents, preservatives, antioxidants and the like may be present in ingredients. When these components do not conform to the definition of ‘incidental ingredients’, they must be included in the ingredient listing on the label.”

3. Conventions used in Chemical/Trade Names section:

In the Introduction, Sub-section G. covers the conventions used in the Chemical/Trade Name sections of the book, and says:

“Terms in parentheses in the CTFA Adopted Names column are explanatory terms and are not meant to be included on labels.”

FDA’s Cosmetic Labeling Guide, Use of “(and)”

Following an example of the right and wrong ways to label a lipstick, the text points out one of the three common errors as:

“Proprietary mixtures of ingredients identified in the ingredient dictionary by a parenthetical “(and)” are often declared on the label as shown in the dictionary section listing chemical/trade names and their respective label names. The compounds of such mixtures must be separated, the “(and)” omitted, and the components treated as individual ingredients for labeling purposes.”

The Take-Away

This isn’t new information, it’s just a new way of looking at old information that’s still pertinent. Taking it back to the actual book that is referenced in the regulations, and seeing what IS says.

It also gives some clarification on how the INCI names have evolved, and how they were originally used. In the beginning, it was just the “adopted name”; now it’s the International Nominclature (in an attempt to standardize ingredient names internationally). Either way, it’s still the common name, and still listing components of a blended ingredient separately.

These details once again also reinforce the fact that just because the “INCI name” is “something (and) something (and) something”, it doesn’t mean that’s the way it’s supposed to be listed in the ingredient declaration. You still need to list the individual components in descending order of predominance based on the entire formulation.

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Comments (2)

  • comment_avatar

    Robert

    |

    I’ve long wondered about what the regs require in non-straightforward situations, such as when the formulator doesn’t have complete information about what they’re mfg. with. I’ve seen plenty of cosmetic labels with the ings. listed with those “and” phrases because they bought a proprietary concentrate and aren’t told how much it includes of each component, so they can’t rightly disaggregate it unless they undertake an analysis. You might say the seller of that concentrate SHOULD tell the buyer that, if they intend it for the cosmetic biz, but what if they don’t even intend that? For instance, Tony Ose’land sold bubble bath he made out of Ivory Dishwashing Liquid; presumably his ingredient declaration would’ve had to list just that, by that name. Similarly for someone who makes a cosmetic out of “the mud from the bed of the creek at [location]“. It’s not clear to what degree ingredients such as those would need to be specified, because, for instance, the formula of a proprietary component can change without notice.

    Probably NONE of those specs serve the purpose the law was instituted for, which was warning people with sensitivity to particular ings. The main offender in that regard is fragrance, which can simply be listed as that, and in other cases unlisted or unknown minor contaminants and breakdown products are the causes of allergies.

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    • comment_avatar

      Marie Gale

      |

      You bring up some interesting points.

      Anyone who is manufacturing a product should know exactly what’s in it. If a supplier won’t (or can’t) provide the necessary information for correct labeling, getting a new supplier or using an alternative ingredient might be the best (or only) solution.

      I don’t know who the person is that you said made bubble bath out of Ivory Dishwashing Liquid. If it was sold as “bubble bath” is required the ingredients to be listed (and a brand name is not suitable) and as a bubble bath, it also required a warning label if it could be used by children (wasn’t labeled as “adults only”).

      In the case of “mud from a creek,” the “common name” what’s required, so “mud” might work, although I would question the safety of a product that uses untreated mud from a creek bed. There are an awful lot of creepy crawlies that live in creek mud and without suitable testing there’s no way to know if any of them end up in or affect the finished product.

      The common denominator of all three of these points you mentioned is that the MANUFACTURER is responsible for knowing what is in their product, and ensuring that the product is, above all, SAFE. If a manufacturer makes a product out of a blended ingredient for which they don’t know the components, or from a commercial product that was never intended to be used in a cosmetic, or from an untested, possibly contaminated source — the final responsibility for the finished product and the label still falls to the person who is making and selling the finished product. They should know what they are doing before trying to sell a cosmetic product.

      Back when the law was crafted, I don’t think the original intent was as a warning for people with sensitivities. The declaration of ingredients was first instituted in foods and drugs, because people were a) getting sold products that weren’t what they seemed to be (“Strawberry jam” made with sugar, red dye and grass seed – no strawberries) or b) were sold products that contained poisonous ingredients (kerosene, arsenic, etc).

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