Ingredient lists, PAO, expiry dates and claims on skincare labels
The details that most often send a label back for correction: INCI names and their order, the opened-jar symbol, net content, warnings, the country of origin and words that turn a cosmetic into a drug.
A compliant skincare ingredient list uses INCI names, starts with the ingredient present in the largest amount and continues in descending order, with ingredients at 1% or less allowed in any order after the rest and colorants at the end. The date is either a best before or expiry date or the PAO symbol, an open jar with the months of use after opening, such as 12M.
INCI names: one ingredient, one name
INCI (International Nomenclature of Cosmetic Ingredients) gives each cosmetic ingredient one standard name, so a buyer, a regulator and a lab all read the same list. Niacinamide, Sodium Hyaluronate and Centella Asiatica Extract are INCI names.
- US: names follow FDA's rule in 21 CFR 701.3, which in practice means INCI names, with "Water" for water.
- EU and UK: the common ingredient names from the European Commission's glossary; water is "Aqua", and plants use their Latin names, such as "Camellia Sinensis Leaf Extract".
- One list for both: many brands write "Water (Aqua)" and "Fragrance (Parfum)" so the same list works in the US, the EU and the UK.
- Japan, China and Korea: the list is written in the local language with the official local names, translated from the INCI names.
We prepare the INCI list from the actual formula, in the right order, so your designer only places it. Full lists are shared after our mutual NDA is signed.
The order of the ingredient list
- Descending order of weight at the time they are added.
- Ingredients at 1% or less may follow in any order (US, EU, UK and Australia allow this).
- Colorants come at the end in any order: CI numbers in the EU, such as CI 77891, and FDA names in the US, such as Titanium Dioxide.
- Fragrance can appear as one word, "Fragrance" or "Parfum", but named allergens above the thresholds must be listed separately in the EU, the UK and Canada.
- Nanomaterials carry "(nano)" after the name in the EU and the UK.
- In the US, a product that is also a drug lists the active ingredients first, in the Drug Facts panel.
PAO symbol or expiry date?
| Market | What goes on the pack |
|---|---|
| EU and UK | A best before date (or the hourglass symbol) if the product keeps 30 months or less; otherwise the PAO symbol, an open jar with the months, such as 12M |
| US | No FDA requirement for cosmetics; Amazon asks for an expiration date on topical products; drugs such as sunscreen carry an expiration date |
| Japan | An expiry date if quality does not hold for 3 years |
| Korea | An expiry date, or the PAO together with the manufacture date |
| China | Production date and shelf life, or batch number and use-by date |
| India, the Gulf and ASEAN | Manufacture and expiry dates are expected; in some ASEAN countries the expiry date is required when the product keeps 30 months or less |
Our library formulas usually keep about 2 to 3 years unopened, with a PAO of 12 months; the exact figures for your product come from its stability data. We print the batch number and the date your market needs on every unit. More in stability testing and the testing guide.
Net content and units
- US: on the bottom 30% of the front panel in US units, "Net Contents 1 fl. oz." or "Net Wt. 1.7 oz.", with the metric amount usually added.
- EU, UK, Canada, Australia and Asia: metric, mL for liquids and g for creams. The ℮ sign is optional in the EU and the UK.
- Small packs: the EU and UK do not require the content or date on packs under 5 g or 5 mL, free samples and single-use packs.
Warnings and directions
- Directions for use, in the language of the market, unless use is obvious.
- Warnings required by an ingredient's conditions of use, such as the restrictions in the EU's Annex III, or by US rules for certain products, such as aerosols.
- Common precautions, such as "For external use only" and "Avoid contact with eyes", on products where they apply.
- Where a pack is too small, the EU and UK allow the precautions and ingredients on a leaflet or tag, shown with the hand and book symbol.
Country of origin: Made in Korea
The US requires imported products to show the English name of the country of origin. The EU and UK require the country of origin for imported cosmetics, and Gulf and Asian markets expect "Made in" on the pack. For skincare we make, that is "Made in Korea" or "Product of Korea".
Cosmetic or drug: the claims decide
What you say the product does decides how it is regulated. A cosmetic cleans, moisturizes, beautifies or changes the look of the skin. Treating, preventing or healing a condition is a drug claim in the US, Canada and most markets, and a quasi-drug claim in Japan.
| Usually a cosmetic claim | Usually a drug claim |
|---|---|
| Hydrates and softens skin | Treats eczema or dermatitis |
| Reduces the look of fine lines | Removes wrinkles or rebuilds collagen |
| Helps skin look clearer | Treats or prevents acne |
| Brightens the look of skin | Whitening or treating dark spots (a quasi-drug claim in Japan) |
| Soothes the feeling of dry skin | Heals, repairs damage or reduces inflammation |
| Hair looks fuller | Stops hair loss or regrows hair |
- US: sunscreen, acne, anti-dandruff and antiperspirant claims make the product an over-the-counter drug.
- EU and UK: every claim must meet the six common criteria of Regulation (EU) No 655/2013: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. "Free from" claims about banned ingredients are not allowed.
- Tested claims: "dermatologist tested" and "hypoallergenic" need a test behind them, such as a patch test or HRIPT.
- Vegan and cruelty-free: different claims with different proof. See vegan, cruelty-free and halal.
Frequently asked questions
What is an INCI name?
What does 12M on a skincare label mean?
Do ingredients under 1% have to be in order?
Can I write that my serum treats acne?
Who writes the ingredient list for my label?
Sources
- FDA: Cosmetics Labeling Guide (ingredient order, net contents, name and address, origin)
- FDA: Is it a cosmetic, a drug, or both?
- EUR-Lex: Regulation (EC) No 1223/2009, Articles 19 and 20 and Regulation (EU) No 655/2013 on claims
- European Commission: CosIng cosmetic ingredient database
- GOV.UK (OPSS): cosmetic labelling in Great Britain
- Health Canada: Labelling of cosmetics
- Australia: Consumer Goods (Cosmetics) Information Standard 2020
- Singapore HSA: cosmetic labelling requirements