About “INCI”, the List of Cosmetic Ingredient Labeling Names, and Cosmetic Ingredients
In Japan, two commonly recognized methods for displaying cosmetic ingredient names are the “INCI name” by the U.S.-based PCPC and the “List of Cosmetic Ingredient Labeling Names” by the Japan Cosmetic Industry Association. Here, we explain the meaning of these cosmetic ingredient names and the nature of cosmetic ingredients.
The names of ingredients listed on cosmetics may vary among manufacturers, who may use formal chemical names, product names, or general terms. This can result in multiple names for the same ingredient, despite it being chemically identical.
To standardize ingredient names and ensure global understanding, the U.S.-based industry organization Personal Care Products Council (PCPC) established the “International Nomenclature of Cosmetic Ingredients,” known as the “INCI name.”
“INCI” stands for International Nomenclature of Cosmetic Ingredients and is pronounced “Inky.” It serves as the de facto international naming standard for cosmetic ingredients.
When a company submits a request to register a new INCI name with the PCPC, they must also provide global identifiers like the CAS number, which defines the manufacturing method and chemical structure. This allows the ingredient to be identified precisely using one standardized name.
Most commonly used cosmetic ingredients already have INCI names. As a result, globally manufactured and distributed cosmetic products generally follow INCI labeling. However, products like gel nail items, which are made from substances different from traditional cosmetics, may still lack complete INCI name registrations.
Similar to the INCI system, Japan maintains a standardized list of ingredient names through the “List of Cosmetic Ingredient Labeling Names” managed by the Japan Cosmetic Industry Association (JCIA).
Like the PCPC’s INCI system, JCIA’s list requires a registration process. However, to apply, the INCI name of the ingredient must already be registered. New applications cannot be submitted unless the ingredient has a valid INCI name.
One unique feature of this list is that it includes names from the previous Japanese regulatory framework, specifically those listed in the “Cosmetic Category Approval Standards” (a Ministry of Health notification from March 24, 1999), which were in effect before the system was reformed in March 2001.
Under the Pharmaceutical and Medical Device Act, it is mandatory to list all ingredients used in cosmetics. However, there are no legal requirements specifying how these ingredients must be named.
Aside from restricted ingredients, limited-use ingredients, and approved colorants defined in the Cosmetic Standards, manufacturers are free to determine how they label the remaining ingredients.
Although there is no legal obligation, it is generally recommended to use names already registered in the “List of Cosmetic Ingredient Labeling Names” to avoid confusion caused by multiple names for the same chemical substance.
Some sources claim that listing unregistered names (such as “urethane acrylate oligomer”) violates the law, but this is incorrect.
INCI names and the JCIA list are **not** legally required names under the Pharmaceutical and Medical Device Act, so using names not registered in these lists is **not** a legal violation.
Phrases such as “INCI-registered cosmetic ingredients” or “listed in the Cosmetic Ingredient Labeling Name List” can misleadingly imply that the ingredients are verified as safe for use.
While many ingredients listed in INCI and JCIA have been used in actual cosmetic products, being registered in these databases does not confirm their safety.
There is **no safety review** process involved when registering ingredient names in either INCI or the JCIA list. Manufacturers are not required to submit safety data.
These systems merely allow for **consistent identification of ingredients using a unified name**, not an evaluation of whether the substance is safe or legal to use under cosmetic regulations.
It is possible for an INCI-registered ingredient to be **non-compliant with Japan’s cosmetic standards**.
For gel nail products, it is essential not only to follow the law but also for manufacturers to independently assess ingredient safety, prioritize health considerations, and take full responsibility in their formulation process.
The INCI system is widely used as the global standard for cosmetic ingredient naming.
Although Japan does not legally require the use of INCI names, countries like China do. When exporting products to countries where INCI names are mandatory for cosmetic registration, the use of INCI names is essential.
If any of the ingredients in a gel nail product are not registered under INCI, the product cannot be registered or exported as a cosmetic in countries that require INCI compliance.
Statements like “main ingredients are INCI-registered” can be misleading—unless all ingredients are registered, the product cannot be exported to INCI-mandatory countries as a cosmetic.
You may encounter terms like “industrial grade” and “cosmetic grade” when discussing raw materials for gel nail products. In short, any ingredient used in a legally sold cosmetic product must meet the “cosmetic grade” standard.
If a substance complies with Japan’s cosmetic regulations, it is considered cosmetic grade and legally permitted in cosmetics. By contrast, substances not meeting these standards cannot be used.
Some raw material manufacturers market ingredients as “cosmetic grade” to emphasize their regulatory compliance. While this is not incorrect, calling other ingredients “industrial grade” may cause confusion and imply non-compliance, even when that may not be the case.
Ultimately, it is the cosmetic manufacturer’s responsibility to:
1. Thoroughly assess each ingredient
2. Ensure compliance with the Cosmetic Standards
3. Take full responsibility for manufacturing and selling the product as a cosmetic
● March 11, 2020 – Production and sales of “Premium Gel Global” fully compliant with INCI names have begun
● April 23, 2020 – About “INCI names” – Why are INCI names rarely used in Japanese gel nail ingredient labeling? (Part 1)
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