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Later in the document, the FDA went on to say: Nor is the agency willing to accept the Latin name as the common or usual name of such ingredients. The statute requires the use of the common or usual name, and there is no way that such a requirement can be considered to be met by the placement of the recognized common or usual name in parentheses after the Latin name. The use of Latin names as the primary identifying term for plant extract ingredients, with the current common name appearing imbedded in parenthesis, would not be consistent with the FPLA. The section concerning the Latin names for botanicals is quoted here : They sent a follow-up letter changing the original request, asking that dual names be allowed as part of a “transition period”. In March 1995, the CTFA wrote the FDA in preparation of their upcoming 6th edition of the Cosmetic Ingredient Dictionary, requesting that the FDA agree not to take action against labelers using the Latin genus and species to identify botanicals. In the last several months, the FDA posted several documents on their website that give some insight into their position. It appears that when it comes to using the Latin name for botanicals in ingredient listings, the FDA and PCPC aren’t on the same page after all. Most people, including myself, figured that the PCPC and the FDA were on the same page and that, so long as the common name was included, any of the different versions were okay to use. The goal, I think, was to standardize and harmonize the ingredient naming standards between the US and other countries, which were going toward requiring the Latin names for ingredients. In that edition, botanicals were named first by the Latin genus and species and then with the common name in parenthesis (i.e. Then, in the 8th edition, published several years later, PCPC again changed the way botanicals were identified. In 1995, the CTFA (now Personal Care Products Council) published in 6th edition of the Cosmetic Ingredient Dictionary, which used the Latin genus and species names of botanicals in parenthesis along with the common name (i.e. Either way, the correct wording is the common name, which complies with the FPLA requirements. Chapter 21, Part 701.3, specifies that “The label on each package of a cosmetic shall bear a declaration of the name of each ingredient…” and later clarifies how the ingredient should be identified.įor botanicals, the name should be either as identified in the CTFA Cosmetic Ingredient Dictionary, Second Ed (1977) – which listed botanicals by their common English name – or if not listed there, the name generally recognized by consumers.
TINCTA BOTANICAL MEANING CODE
Code of Federal RegulationsĬhapter 21 of the Code of Federal Regulations deals with food, drugs and cosmetics. The FPLA specifies that when the ingredients must be listed, the common or usual name is used. The FDA is responsible for the regulations applying to foods, drugs and cosmetics. The FPLA directs the Federal Trade Commission and the Food and Drug Administration to issue regulations to implement the requirements outlined in the FPLA. It sets specific requirements for the labeling of consumer commodities (that is, products that are used by consumers and generally used up over time). The Fair Packaging and Labeling Act was enacted in 1967. The actual law and regulation governing the way ingredients should be identified in cosmetic ingredient declarations comes from several sources. Most other countries require that the Latin name for botanicals is used in the ingredient declaration. Important Note: This information applies to soap and cosmetic regulations in the United States. Based on some fairly recently posted information on the FDA website, it is now clear that common names are required, and when used as a secondary listing, Latin names are accepted.Īlthough the “INCI name” (which usually means the Latin name) is commonly thought to be required, it isn’t – it’s optional. There has been considerable discussion over the years on how botanicals should be listed in the ingredient declaration for cosmetics.