INCI Naming and Classification of White Iron Oxides EasyMix™ for FDA Notification

Asked by: dearpoy On: August 29, 2019 Product Type: Cosmetics

Question

Hello,

Since I recently purchased White Iron Oxides EasyMix™, I would like to ask:

1. When notifying the FDA, can I list the name "Iron Oxides" and then put the INCI Name in parentheses afterwards? That is, write "Iron Oxides (Mica, Titanium Dioxide (CI77891), Aluminum Hydroxide, Hydrogen Dimethicone)"

2. Are White Iron Oxides EasyMix™ and Iron Oxide with INCI Names CI77491, CI77492, CI77499 considered to be in the same family of Iron Oxides?

Thank you.

Answer

Subject: Re: White Iron Oxides EasyMix™

Hello,

Thank you for your purchase and questions regarding White Iron Oxides EasyMix™.

  1. Regarding FDA notification and ingredient listing:
    For cosmetic product notification, ingredients must be listed using their correct INCI (International Nomenclature of Cosmetic Ingredients) names. The product "White Iron Oxides EasyMix™" is a blend. Based on the information you provided, its INCI name is Mica, Titanium Dioxide (CI 77891), Aluminum Hydroxide, Hydrogen Dimethicone.
    Therefore, you should list the ingredients individually using these INCI names on your product label and in your notification documents, not simply "Iron Oxides" followed by the list in parentheses. The correct listing should be:

    • Mica
    • Titanium Dioxide (CI 77891)
    • Aluminum Hydroxide
    • Hydrogen Dimethicone
  2. Regarding the classification of pigments:
    "White Iron Oxides EasyMix™" primarily contains Titanium Dioxide (CI 77891) as the white pigment, along with Mica and surface treatments.
    Standard Iron Oxides (such as CI 77491 Red, CI 77492 Yellow, and CI 77499 Black) are chemically different compounds based on iron oxides.
    While both are used as colorants in cosmetics, Titanium Dioxide (CI 77891) is a titanium compound, not an iron oxide. Therefore, "White Iron Oxides EasyMix™" (which contains Titanium Dioxide) and standard Iron Oxides (CI 77491, CI 77492, CI 77499) are not considered the same chemical family.

We hope this clarifies your questions.