How to Create an INCI List for Your Skincare Product, Line by Line

This guide walks you through how to create an INCI list for skincare, step by step, with no chemistry degree required.

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What Is an INCI List?

INCI stands for International Nomenclature of Cosmetic Ingredients. It's the globally standardized naming system for cosmetic and personal care ingredients, maintained by the Personal Care Products Council.

Every ingredient in your formula has an INCI name. Not the trade name your supplier uses (that might be something like "Hydrasoft Complex 3"), not the common name you know it by ("glycerin"), but the standardized INCI name (also "Glycerin" in this case, though it's not always that clean).

The INCI list on your label must:

• Use the correct INCI name for every ingredient
• List ingredients in descending order of concentration
• Be placed on the product label in a legible font
• Meet the regulatory requirements of every market you sell into

That last point matters. The US, EU, UK, Canada, and Australia all require INCI labeling, but the specific rules vary. This guide focuses primarily on US and EU requirements, which cover most indie brand launches.

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Why Your INCI List Is More Than a Legal Requirement

Before we get into the mechanics, it's worth understanding what's at stake.

Retailers like Sephora, Credo, and Whole Foods require accurate INCI lists before they'll stock your product. Clean beauty certifiers like EWG and MADE SAFE verify ingredient safety against your INCI list. Customers who have allergies or follow specific ingredient philosophies read your label and make purchasing decisions based on it.

An accurate INCI list is also your defense if a customer has a reaction. It creates a traceable record of exactly what was in the product.

Get it right from the start.

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Step 1: Confirm Every Ingredient's INCI Name

Start with your full formula. Every raw material in it, including preservatives, fragrance, colorants, and anything added at trace levels, needs an INCI name.

The primary resource for INCI name lookup is the CosIng database, maintained by the European Commission. It's free, searchable, and the authoritative source for EU-compliant naming. The PCPC's International Cosmetic Ingredient Dictionary is the US equivalent, though it requires a subscription.

For most ingredients, CosIng is enough. Search by the supplier's trade name or common name and confirm the standardized INCI name.

Pro tip: Your supplier's Safety Data Sheet (SDS) or Technical Data Sheet (TDS) will often list the INCI name. Cross-reference it with CosIng anyway. Supplier documentation is sometimes outdated or uses regional variants.

A few things to watch for:

• Trade blends: If your supplier sells you a pre-made blend (an emulsifier blend, a preservative system, a skin-feel complex), that single trade ingredient may contain multiple INCI names. You need to list all of them individually on your label, not the trade name.
• Fragrance: In the US, you can list a fragrance blend as "Fragrance" (or "Parfum" in the EU). However, if any of the 26 EU-regulated fragrance allergens are present above threshold levels (0.001% in rinse-off, 0.01% in leave-on), those specific allergens must be listed individually by INCI name in the EU.
• Colorants: In the US, colorants are listed by their Color Index (CI) number, for example "CI 77891" for titanium dioxide used as a colorant. In the EU, the same convention applies.

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Step 2: Know the Descending Concentration Rule

This is the core rule of ingredient list order for cosmetics: ingredients are listed from highest concentration to lowest.

The ingredient present in the greatest amount goes first. The ingredient present in the smallest amount goes last. This is true in the US (FDA requirement), the EU (EU Cosmetics Regulation 1223/2009), and most other markets.

The 1% threshold exception: In the EU (and commonly followed in the US as well), ingredients present at 1% or below can be listed in any order after all the above-1% ingredients are listed in descending order. This gives you flexibility at the tail end of your INCI list, which is where most actives, preservatives, and fragrance components sit.

In practice, your list will look like this:

1. Water (almost always first in aqueous formulas)
2. Main emollients, humectants, or carrier oils (in order of their percentage)
3. Emulsifiers, thickeners, and functional ingredients (in order)
4. Then, in any order below 1%: actives, preservatives, fragrance, colorants, trace components

Pro tip: You don't have to publish the exact percentages on your label. The order communicates relative concentration to informed readers, but you're not required to disclose the exact numbers publicly. Your manufacturing-ready formula document will have exact percentages; your consumer label just shows the order.

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Step 3: Handle Water Correctly

Water sounds simple. It's not always.

The INCI name for water is Aqua in the EU (and Aqua/Water is acceptable in dual-market labeling). In the US, "Water" is the accepted term. Many brands use "Aqua (Water)" to cover both markets on a single label.

Water is almost always the first ingredient in emulsions, serums, toners, and most rinse-off products. If your formula is water-based, expect to see it at the top.

If your formula is anhydrous (a face oil, a balm, a dry serum), there's no water in the formula and it won't appear on your list at all. In that case, your first ingredient is typically your primary carrier oil or wax.

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Step 4: Expand Every Supplier Blend Into Its Components

This is where a lot of indie founders get tripped up.

You might use a single ingredient called "Preservative Eco" or "Olivem 1000" or "Tego Care 450." These are trade names. Each of them contains multiple INCI-named ingredients inside.

You are required to list every individual INCI component on your label, not the trade name.

For example, Olivem 1000 (a common emulsifier) contains: Cetearyl Olivate, Sorbitan Olivate. Both of those go on your label, positioned according to their actual concentration in the final formula.

To get this right:

• Request the full INCI breakdown from your supplier (sometimes called a "INCI declaration" or "component list")
• Get the percentage of each component within the blend
• Calculate each component's actual percentage in your final formula (blend percentage × component percentage within the blend)
• Place each component in the correct position on your list

Pro tip: Keep a master spreadsheet with every raw material, its trade name, its INCI components, the component percentages within the blend, and the usage level in your formula. This becomes your source of truth for every label you ever write.

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Step 5: Place Colorants and Fragrance Correctly

Fragrance: In the US, a fragrance blend can be listed simply as "Fragrance" regardless of how many individual aroma chemicals it contains. In the EU, it's listed as "Parfum" but with the caveat that regulated allergens above threshold must be called out individually.

Fragrance is almost always at or below 1% in leave-on skincare, so it typically sits near the end of the list.

Colorants: In the US, colorants can be listed at the end of the INCI list regardless of their concentration. The FDA permits this specifically for cosmetic colorants. In the EU, they follow the same descending order rule as other ingredients, but the 1% threshold flexibility often applies since colorants are used at very low levels.

For products sold in both markets, listing colorants at the end (after all other ingredients) is a common and accepted approach.

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Step 6: Format the List for Your Label

Once you have your ingredients in the right order with the right INCI names, formatting matters.

US requirements (FDA):

• The ingredient declaration must appear on an "information panel" of the label
• Must be preceded by the heading "Ingredients:"
• Minimum type size of 1/16 inch (roughly 4.5pt font)
• Must be conspicuous and legible

EU requirements:

• Must be preceded by the symbol of a hand with an open book, or the word "Ingredients"
• No minimum font size specified, but must be legible
• Must appear on the container or packaging

Practical formatting tips:

• Separate ingredients with commas
• Use consistent capitalization (first letter capitalized, rest lowercase is standard)
• If listing for both US and EU, use "Aqua (Water)" for water and include both "Fragrance" and "Parfum" separated by a slash: "Fragrance/Parfum"
• List CI numbers for colorants as "CI XXXXX" with a space between CI and the number

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Step 7: Get It Reviewed Before It Goes to Print

An INCI list on a consumer product is a regulatory document. Before your label goes to the printer or your product goes to a retailer, have your INCI list reviewed by a qualified cosmetic chemist or regulatory consultant.

This is especially important if:

• You're selling into the EU (which requires a full Cosmetic Product Safety Report)
• You're making any claims that could be interpreted as drug claims (SPF, anti-acne, etc.)
• Your formula contains restricted or regulated ingredients
• You're working with a fragrance that contains potential allergens

A chemist review catches errors in INCI naming, ordering mistakes, and missing components from supplier blends before they become a recall or a legal issue.

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How Genie Handles This

When you build a formula on Genie, the AI formulator works from a 180,000-row ingredient database that includes INCI names for every ingredient. The formula Genie generates includes exact ingredient percentages, and when you're ready to take it to manufacturing, the chemist review step (available through Own Your Formula) produces a manufacturing-ready tech pack with a verified INCI list.

You're not left doing an INCI name lookup for every raw material on your own. The formula already knows what everything is called.

Genie develops the formula and the tech pack. Your contract manufacturer produces the product. The INCI list that goes on your label comes out of that tech pack, reviewed by a qualified chemist, ready for your label designer.

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Frequently Asked Questions

Do I need an INCI list if I'm only selling in the US?

Yes. The FDA requires ingredient labeling for cosmetic products sold in the US under the Fair Packaging and Labeling Act. The INCI naming convention is the accepted standard. Selling without a proper ingredient declaration puts you out of compliance.

Can I list ingredients by their common names instead of INCI names?

No. The INCI name is the required standard for cosmetic labeling in the US, EU, and most other markets. Common names like "rose hip oil" or "vitamin C" are not acceptable as standalone declarations, though some brands add them parenthetically for consumer-facing clarity. The INCI name must be present.

What happens if two ingredients are at the same concentration?

If two ingredients are present at the exact same percentage, you can list them in either order relative to each other. In practice, this is rare and usually only comes up with trace-level ingredients that fall below 1%, where the ordering flexibility already applies.

How do I find the INCI name for an ingredient I can't identify?

Start with the CosIng database (the European Commission's free cosmetic ingredient database). Search by common name, trade name, or CAS number. If you can't find it there, contact your supplier directly and request the full INCI declaration for the raw material. A cosmetic chemist can also help identify unusual or proprietary ingredients.

Does my fragrance supplier need to give me the full INCI breakdown?

For EU labeling, yes, if any regulated allergens are present above threshold levels, you need to know which ones. Reputable fragrance suppliers will provide an allergen declaration. For US labeling, you can list the blend as "Fragrance" without disclosing individual components, but you should still have the allergen data internally for safety documentation.

What's the difference between an INCI list and a formula?

Your formula is your internal document. It shows every ingredient, its INCI name, its exact percentage, its supplier, and its function. Your INCI list is the consumer-facing version: ingredients in descending order, no percentages shown. The formula is your manufacturing document. The INCI list is your label document. Both need to be accurate and consistent with each other.

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Key Takeaways

• Every ingredient in your formula needs a verified INCI name. Use CosIng or your supplier's INCI declaration to confirm it.
• Ingredients are listed in descending order of concentration. Ingredients at or below 1% can be listed in any order after the above-1% ingredients.
• Supplier trade blends must be expanded into their individual INCI components. You list the components, not the trade name.
• Fragrance can be listed as "Fragrance" (US) or "Parfum" (EU), but EU-regulated allergens above threshold must be called out individually.
• Colorants can be listed at the end of the US ingredient declaration regardless of concentration.
• Have a qualified chemist review your INCI list before your label goes to print.
• Your INCI list is a regulatory document. Accuracy protects your customers, your retailer relationships, and your brand.

Ready to build a formula that comes with a verified INCI list already built in? Get started free on Genie