Ever wondered why your Canadian-bought shampoo and the likes have ingredient lists mixing up Latin, English and French (ex.: “aqua/water/eau, alcohol, parfum…”)?
The answer is simple:
While the government of Canada considers it to be “multi-lingual and based on Latin” (hence the use of words like “aqua”, “parfum”, etc.), INCI names are still managed by a U.S.-based organization (hence the dominant use of English).
There are however some exceptions:
- Ingredients having an “EU trivial name” (i.e. mentioned in the Schedule to the Regulations) must be listed either:
– in Latin (ex.: “aqua”); or
– in both English and French (“water/eau”); or
– in all three languages (“aqua /water/eau”)… although this is definitely not the most space-efficient option.
- Ingredients having neither an INCI name nor a so-called “trivial name” must be listed by their “chemical name from a recognized source”.
Bottom line is, whenever you have a cosmetic product packaging to translate, you should first make sure that every ingredient listed complies with the Canadian regulations requirements.
After all, since the INCI-based list is deemed to be “multilingual”, the translators should not even have to touch it, unless you ask otherwise!
Colourings may pose an additional challenge: sometimes, different INCI names can in fact refer to one same ingredient. For instance, in INCI terminology, one colouring is called “Acid Blue 9” as its Colour Index™ Generic Name (CIGN), while the same ingredient is called “CI 42090” when referring to the Colour Index™ Constitution Number (CICN), and it can also be called “Blue 1” with regards to the United States’ FD&C number… notwithstanding many non-INCI names, including “Blue 4” and “Brilliant Blue FCF” – all for the very same ingredient!
In such cases, the Canadian Guide to Cosmetic Ingredient Labelling, states that “it must be clear if both are listed that they are the same ingredient and not separate ingredients. For example: CI 42090 (Blue 1)”.
And of course, whatever the colour name, you should first make sure it is indeed an INCI one.
Additional technical notes:
- For the official, complete list of INCI names, you need access to the International Cosmetic Ingredient (ICI) Dictionary & Handbook, which requires subscription fees, but there is also a similar database available for free on the European Union’s website. The EU database is not totally identical to the official ICI Dictionary (for example, the “Blue 1” colour is not included as an INCI name), but it can still be of help to check certain ingredients.
- Nothing forbids to translate the INCI-based list as a totally separate French list (in keeping with the principles of Canadian English-French bilingualism), but it is merely a question of corporate choice: there is even a regulated exception to the Quebec’s Charter of French Language, stating that the “list of the ingredients of a cosmetic may be written according to the conditions prescribed by the [Canadian] Cosmetic Regulations (C.R.C., c. 869)”.
- Precision taken from the Labelling of Cosmetics guidance document provided by the Government of Canada:
“Some products can have a dual purpose and, as a result, will fall under more than one piece of legislation simultaneously. An example of such a product would be a chewing gum that claims to whiten the teeth. Under the Food and Drugs Act, a chewing gum is a food, but it must also adhere to the requirements of the Cosmetic Regulations because it also makes cosmetic claims (to whiten teeth).
Because many of these dually-classified products already require ingredient listing under other Regulations, the decision was made to exempt them from the provision to list the ingredients using the INCI system.
Therefore, the requirements to list the ingredients under the Cosmetic Regulations do not apply to any product whose ingredient labelling is regulated under the Food and Drug Regulations or the Natural Health Product Regulations.”