Cosmetic Label Review (INCI)

MoCRA and FDA regulations require cosmetic labels to list ingredients using proper INCI nomenclature in descending order of predominance. We review your cosmetic labels for full compliance before products reach the U.S. market.

INCI Ingredient List Review

We verify every ingredient on your cosmetic label uses the correct INCI name, listed in descending order of predominance as required by FDA and MoCRA.

  • Full INCI nomenclature verification
  • Descending order compliance
  • Fragrance & flavor ingredient rules
  • Sub-ingredient disclosure assessment

MoCRA Label Compliance

MoCRA introduced new labeling requirements including Responsible Person contact information and safety warnings. We review your labels against all new MoCRA requirements.

  • Responsible Person contact info
  • Safety warning statements
  • Professional-use label requirements
  • MoCRA compliance assessment

Claims Review

Cosmetic claims must not cross into drug territory. We review your marketing and label claims to ensure they comply with FDA’s cosmetic vs. drug distinction.

  • Cosmetic vs. drug claim analysis
  • Structure/function claim review
  • SPF & sunscreen claim compliance
  • Anti-aging claim assessment

Net Quantity & Mandatory Elements

We review all mandatory cosmetic label elements: net quantity, country of origin, principal display panel, and distributor/manufacturer statements.

  • Net quantity declaration review
  • Country of origin statement
  • PDP & information panel compliance
  • Manufacturer/distributor statements

Ready to get your labels reviewed? Register Now:

We’ll check your cosmetic labels for INCI accuracy, MoCRA compliance, and claims risk before you reach the U.S. market.


Cosmetic Label Review (INCI) FAQs

What is INCI, and why does my cosmetic label need it?

INCI (International Nomenclature of Cosmetic Ingredients) is the standardized naming system FDA requires for ingredient declarations on cosmetic labels. Every ingredient must be listed by its correct INCI name, in descending order of predominance, so U.S. consumers and regulators can identify exactly what’s in the product. This ingredient declaration requirement comes from the Fair Packaging and Labeling Act and longstanding FDA cosmetic labeling rules, not MoCRA. Getting an INCI name wrong, or listing ingredients out of order, is one of the most common reasons cosmetic labels fail FDA review.

Is fragrance allergen disclosure required yet?

Not yet, but it’s coming. MoCRA directed the FDA to issue a rule requiring disclosure of fragrance allergens above certain thresholds, but that rulemaking is still in progress. FDA missed its original 2024 deadline for the proposed rule, and the final rule has faced repeated delays. We track the rule making status closely and build labels that are ready to adapt once the final requirement takes effect, so you’re not caught off guard by the transition.

What’s the difference between a cosmetic claim and a drug claim?

A cosmetic can cleanse, beautify, or alter appearance. The moment a label or marketing claim suggests a product treats, prevents, or cures a condition, or affects the body’s structure or function, the FDA may regulate it as a drug instead, which triggers a much heavier compliance burden. Common red flags include anti-aging claims that imply changing skin structure, acne claims, and SPF or sunscreen claims, which are automatically regulated as drugs regardless of how the product is marketed. We review your claims language before launch to keep your product safely on the cosmetic side of that line.

Do I need a “professional use only” statement on my label?

If your product is intended exclusively for use by licensed professionals, such as certain salon-strength chemical peels or hair straighteners, MoCRA requires a conspicuous label statement such as “Administered or used only by licensed professionals.” This has been an active enforcement requirement since December 29, 2023. If your product is sold for professional use but your label doesn’t carry this statement, that’s a compliance gap worth fixing before your next shipment.