If you dream of selling your handmade skincare someday, one of the many responsibilities you’ll be taking on is properly labelling your products. Different countries have different labelling requirements (so make sure you’re researching and following all the rules set out by the relevant regulatory bodies in the country/countries you’re selling in), but no matter where you are, you can be pretty sure your cosmetic products will need an ingredient label.

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The ingredients bit of the label sounds pretty darn simple, but it’s something I see a lot of small makers get wrong when I’m reading ingredient lists at farmer’s markets and whatnot. So, in this blog post I’m going to share some labelling mistakes (and how to fix them!) so you don’t have to worry about getting a scary letter from the FDA about selling a “misbranded” product. This definitely isn’t a complete how-to guide for labelling your products in a legally compliant way, but it does tackle what are probably the most common mistakes I see when reading the ingredient lists on products sold by small brands.

Now—the basic gist of an ingredient list is that it needs to list all the ingredients in the product in descending order. That is, the one that’s used the most is at the top, and the one that’s used the least is at the bottom. The order below the 1% line doesn’t matter, but we’re not going to go into that much today. Manufacturers are required to disclose all the ingredients so their customers/potential customers know what’s in them.

Most labels get this more or less right, but I often see a mistake that betrays a lack of understanding of the ingredients being used, and that leads to an ingredient list that is missing a lot of essential (legally required!) information.

To show you what I mean, let’s start with this sample formulation for simple emulsion:

Heated water phase
68.5% water
6% glycerin

Heated oil phase
15% sunflower oil
5% Ritamulse SCG
3% cetyl alcohol

Cool down phase
1.5% Optiphen™ Plus
1% Fragrance

If we arrange these ingredients in descending order, we get:

Water, sunflower oil, glycerin, Ritamulse SCG, cetyl alcohol, Optiphen™ Plus, fragrance.

This is an accurate ingredient list if you’re thinking as a formulator about the ingredients you used to make the product. Unfortunately, that’s not accurate (enough) once you’re selling to the public.

Both Ritamulse SCG (the emulsifier) and Optiphen™ Plus (the preservative) are product names, not ingredient names. Those names alone don’t give the customer enough information about what is in the product.

Both of these ingredients have their own ingredient lists—called the INCI (or International Nomenclature of Cosmetic Ingredients)—and those component/INCI ingredients need to be in your ingredient list.

You can get full the INCIs for your ingredients from your suppliers. If your suppliers don’t provide this information on their product pages, I’d recommend shopping elsewhere.

The INCI for Ritamulse SCG is Glyceryl Stearate (and) Cetearyl Alcohol (and) Sodium Stearoyl Lactylate, and the INCI for Optiphen Plus is Phenoxyethanol (and) Caprylyl Glycol (and) Sorbic Acid.

Now, you might’ve see these INCI values included on ingredient lists this way:

Water, sunflower oil, glycerin, Ritamulse SCG (Glyceryl Stearate (and) Cetearyl Alcohol (and) Sodium Stearoyl Lactylate), cetyl alcohol, Optiphen Plus (Phenoxyethanol [and] Caprylyl Glycol [and] Sorbic Acid), fragrance.

And while this is better—now all the ingredients that are in the product are on the ingredient list—this isn’t quite correct, either. The ingredient label shouldn’t have any product/trade names on it, and it shouldn’t have any (“and)”s. If we remove them, we end up here:

Water, Sunflower Oil, Glycerin, Glyceryl Stearate, Cetearyl Alcohol, Sodium Stearoyl Lactylate, Cetyl Alcohol, Phenoxyethanol, Caprylyl Glycol, Sorbic Acid, Fragrance.

This isn’t correct, either, because now this ingredient list isn’t in descending order—as you can see when we assign percentage values to each ingredient:

• Water: 68.5%
• Sunflower oil: 15%
• Glycerin: 6%
• Glyceryl Stearate: ?? (less than 5%)
• Cetearyl Alcohol: ?? (less than 5%)
• Sodium Stearoyl Lactylate: ?? (less than 5%)
• Cetyl alcohol: 3%
• Phenoxyethanol: ?? (less than 1.5%)
• Caprylyl Glycol: ?? (less than 1.5%)
• Sorbic Acid: ?? (less than 1.5%)
• Fragrance: 1%

So, how to you figure out what order to put the ingredients in once you’ve broken them out of their product names? You know each component of Ritamulse SCG will be present at less than the 5% used in this formulation (since all three of those add up to a total of 5%), but we need more information than just “less than 5%” to sort things properly.

To figure out how much of each component ingredient is in the overall formulation so we can put them in order, we’ll need to do a bit of sleuthing and math.

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Step 1: find the composition of the compound ingredient. This can require some sleuthing. Start by reading through the data sheets from your supplier; if it’s not there, look at data sheets for the same ingredient from different suppliers. You can also reach out to your suppliers to ask.

The product page for Ritamulse SCG at LotionCrafter (they call it ECOMulse). They clearly list the breakdown.

Ritamulse SCG is approximately 55–65% glyceryl stearate, 20–30% cetearyl alcohol, and 10–20% Sodium Stearoyl Lactylate (source). If we take the middle of each range, that’s 60%, 25%, and 15%, and that adds up to 100%, so let’s roll with that for our calculations.

Step 2: Multiply the composition percentage (60%, 25%, and 15%) by the usage rate (5%) to get the amount of each component ingredient in the overall formulation.

Since the overall formulation contains 5% Ritamulse SCG, that breaks down to:

• 3% glyceryl stearate (60% × 5% = 3%)
• 1.25% cetearyl alcohol (25% × 5% = 1.25%)
• 0.75% Sodium Stearoyl Lactylate (15% × 5% = 0.75%)

Now we’ve got:

• Water: 68.5%
• Sunflower oil: 15%
• Glycerin: 6%
• Glyceryl Stearate: 3%
• Cetearyl Alcohol: 1.25%
• Sodium Stearoyl Lactylate: 0.75%
• Cetyl alcohol: 3%
• Phenoxyethanol: ??
• Caprylyl Glycol: ??
• Sorbic Acid: ??
• Fragrance: 1%

With those values, we can re-arrange the ingredients list into descending order:

• Water: 68.5%
• Sunflower oil: 15%
• Glycerin: 6%
• Cetyl alcohol: 3%
• Glyceryl Stearate: 3%
• Cetearyl Alcohol: 1.25%
• Phenoxyethanol: ??
• Caprylyl Glycol: ??
• Sorbic Acid: ??
• Fragrance: 1%
• Sodium Stearoyl Lactylate: 0.75%

This information is found in the Safety Data Sheet for Optiphen™ Plus from Voyageur Soap and Candle Co.

Next, let’s do the Optiphen™ Plus. It is approximately 52.26% phenoxyethanol, 41.74% caprylyl glycol, and 6% sorbic acid. A usage rate of 1.5% Optiphen™ Plus gives us:

• 52.26% × 1.5% = 0.7839% phenoxyethanol
• 41.74% × 1.5% = 0.6261% capryly glycol
• 6% × 1.5% = 0.09% sorbic acid

We’ll add those values to our list:

• Water: 68.5%
• Sunflower oil: 15%
• Glycerin: 6%
• Cetyl alcohol: 3%
• Glyceryl Stearate: 3%
• Cetearyl Alcohol: 1.25%
• Phenoxyethanol: 0.78%
• Caprylyl Glycol: 0.63%
• Sorbic Acid: 0.09%
• Fragrance: 1%
• Sodium Stearoyl Lactylate: 0.75%

And then re-arrange it into descending order:

• Water: 68.5%
• Sunflower oil: 15%
• Glycerin: 6%
• Cetyl alcohol: 3%
• Glyceryl Stearate: 3%
• Cetearyl Alcohol: 1.25%
• Fragrance: 1%
• Phenoxyethanol: 0.78%
• Sodium Stearoyl Lactylate: 0.75%
• Caprylyl Glycol: 0.63%
• Sorbic Acid: 0.09%

Now we’ve got everything on the ingredient list, and in the right order!

And then for a couple small changes to switch everything into INCI and meet Health Canada’s labelling guidelines:

• Aqua: 68.5%
• Helianthus Annuus Seed Oil: 15%
• Glycerin: 6%
• Cetyl alcohol: 3%
• Glyceryl Stearate: 3%
• Cetearyl Alcohol: 1.25%
• Parfum: 1%
• Phenoxyethanol: 0.78%
• Sodium Stearoyl Lactylate: 0.75%
• Caprylyl Glycol: 0.63%
• Sorbic Acid: 0.09%

That gives us a final ingredient list that reads:

Aqua, Helianthus Annuus Seed Oil, Glycerin, Cetyl Alcohol, Glyceryl Stearate, Cetearyl Alcohol, Parfum, Phenoxyethanol, Sodium Stearoyl Lactylate, Caprylyl Glycol, Sorbic Acid.

You can see that this breaks up the compound ingredients and scatters the parts through the ingredient list, somewhat disguising the original compound ingredients. Now that you know this, keep an eye out for clusters of ingredients you recognize in commercial ingredient lists—you’ll feel like Sherlock Holmes when you do!

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