How Should I List Flavours as they are Trade Secrets?

How Should I List Flavours as they are Trade Secrets?

Flavours are an important part of some cosmetic products, but we are not told what is in them.  We often get asked how they should be labelled.
Here is the answer from the Consumer Goods Legislation that refers to cosmetics:

flavour has the same meaning as the definition of flavor in the International Cosmetic Ingredient Dictionary and Handbook, Sixteenth Edition 2016.

Note:          The International Cosmetic Ingredient Dictionary and Handbook, Sixteenth Edition 2016 defines flavor as follows:

        “Flavor is a term for ingredient labeling used to identify that a product contains a material or combination of materials normally added to a cosmetic to produce or to mask a particular flavor. The term Flavor may be used instead of listing the individual components of the flavor in accordance with U.S. 21 CFR 701.3(a). The labeling name in the EU will be Aroma under the 6th Amendment to the EC Cosmetics Directive. See “Regulatory and Ingredient Use Information,” regarding use of the INCI Names, Flavor and Aroma in Volume 1, Introduction, Part A.”.

Flavours, fragrances and incidental ingredients

             (7)  A flavour or flavours in a cosmetic product must be shown in the list of the product’s ingredients by including in the list:

                     (a)  the word “flavour”, “flavours”, “aroma” or “aromas”; or

                     (b)  the ingredients in the flavour or flavours.

             (8)  A fragrance or fragrances in a cosmetic product must be shown in the list of the product’s ingredients by including in the list:

                     (a)  the word “fragrance”, “fragrances”, “parfum” or “parfums”; or

                     (b)  the ingredients in the fragrance or fragrances.

             (9)  An incidental ingredient in a cosmetic product need not be included in the list of the product’s ingredients.

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2 comments

Hi Sheryl,
That is correct – only “flavour” needs to be listed. As the formulations of the flavours are trade secrets all ingredients are not known. “Flavour” is accepted under this circumstance.

Kerry Pearson

Hi, I am in the process of doing my labels for my new lip balms. Does this mean that I just need to put “flavour” on the ingredient list or do I also need to list the ingredients of the flavouring? It is considered natural flavour. Thanks!

Sheryl

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