How to Label Cosmetic Ingredients? INCI Naming and Prohibited/Restricted Ingredients (Malaysia)

Ingredient labelling and safety control for cosmetics come down to two things: all ingredients must be listed using INCI international nomenclature, and you must comply with the prohibited, restricted, and permitted lists of the ASEAN Cosmetic Directive (ACD). Using the wrong name, using a prohibited ingredient, or exceeding the limit on a restricted ingredient will all prevent the product from being marketed in compliance. This article explains how to label ingredients and where the most common pitfalls are. (For the complete overview, see the Malaysia Cosmetic Regulations and Labelling Guide.)

Why must you use INCI?

Ingredients must be listed using INCI (International Nomenclature of Cosmetic Ingredients). INCI is a globally common system of standard names, whose benefit is that authorities, channels, and consumers in different countries can all identify the same raw material by the same name.

This means you cannot use only common names or trade names. For example, "hyaluronic acid" must be written with the corresponding INCI name (such as Sodium Hyaluronate), and "vitamin C" and "vitamin E" must also use standard nomenclature. Common names and marketing names may appear in copy, but the ingredient list itself must be INCI. A wrong name or a common name is one of the most common ingredient-labelling defects found during inspection.

Three lists: prohibited, restricted, permitted

Malaysia manages ingredients per the annex lists of the ASEAN Cosmetic Directive (ACD), and in practice you must watch three kinds of list at once:

In other words, functional ingredients such as preservatives, colourants, and UV filters cannot just be added freely; they must be selected from the permitted list and kept within their respective concentration limits and conditions of use. For the concentration red lines of restricted ingredients, see Restricted Ingredients and Concentration Limits; for sunscreen-related UV filters, see UV Filters and SPF Labelling.

Certain ingredients require warning statements

Some restricted ingredients, while approved for use, are required to carry a corresponding warning statement or condition of use on the label (for example, certain ingredients must state precautions for use). That is, ingredient compliance is not only about "the concentration not exceeding the limit," but also about "whether the required warning has been labelled." A missing warning statement also counts as non-compliant labelling.

How should the ingredient list be arranged? Three practical reminders

Beyond using INCI for naming, there are conventions for how the ingredient list is presented that you should note:

• Listed in descending order of content: ingredients are generally ordered from highest to lowest, with those earlier in the list present in higher amounts. This order must match the actual formula and cannot be rearranged to push a "star ingredient" to the front for marketing.
• Handling of fragrance and colourants: fragrance is often represented by a collective term, and colourants have their own dedicated labelling method; both are written differently from ordinary raw materials, so confirm the format is correct before submission.
• Align one substance with multiple names: the same raw material may have common names, trade names, and an INCI name across different sources — always standardise back to the INCI name, so that the ingredient list and the PIF do not fail to reconcile. See PIF and Safety Assessment.

The ingredient list may look like just a small block of text on the label, but it is the most direct basis for comparing the formula and tracing violations during inspection; any inconsistency may trigger follow-up scrutiny.

Common mistakes

• The ingredient list does not use INCI, or uses only common names or trade names.
• The ordering or names of ingredients are wrong and inconsistent with the actual formula.
• Using a prohibited ingredient, or a restricted ingredient exceeding the concentration limit.
• Containing an ingredient that requires a warning but not labelling the warning.
• Preservatives, colourants, or UV filters not in the permitted list.

Frequently asked questions (FAQ)

Q: Do I have to label all ingredients? Yes. Cosmetics must list all ingredients, named using INCI. This is one of the mandatory label items — see Mandatory Items on a Cosmetic Label.

Q: Are there rules for ingredient ordering? The ingredient list has its ordering convention (generally by descending content); the names and order must match the actual formula and cannot be adjusted at will to beautify the marketing impression.

Q: Can an imported product's ingredient list carry over the overseas version directly? Not necessarily. The overseas version may use local common names or different nomenclature, and each country's prohibited/restricted lists differ; before importing, re-check against the ACD lists whether the ingredients comply and whether the naming is INCI.

Q: Are natural / organic ingredients exempt from prohibited/restricted rules? No. Whether natural or synthetic, all must comply with the ACD prohibited, restricted, and permitted rules; a natural origin does not mean automatically safe or compliant.

Self-check list

• [ ] All ingredients listed using INCI nomenclature, with no common names or trade names
• [ ] Compared against the ACD prohibited list and confirmed no prohibited ingredients
• [ ] Restricted ingredients do not exceed the concentration limit and meet conditions of use
• [ ] Preservatives, colourants, and UV filters are drawn from the permitted list
• [ ] For ingredients requiring a warning, the corresponding warning is labelled

Summary

The compliance formula for cosmetic ingredients: INCI naming + compliance with the ACD prohibited / restricted / permitted lists + the required warnings in place. Ingredients are not a marketing field but hard evidence during inspection; getting naming, lists, and warnings right the first time is what keeps you from getting stuck before launch.

Want to confirm whether your ingredient list is compliant? Run a free label check now.

This article is compiled from official regulations and is for reference only; actual compliance is subject to the latest official text and review by the competent authority.