The publication of the new Commission Implementing Decision (EU) 2025/1175 reorganizes the common ingredient names (INCI): timing, impacts, and practical actions.

1. A bit of context

The European cosmetic sector is continuously evolving, both from a regulatory and a formulation innovation standpoint. In this context, ingredient nomenclature plays a key role: according to Article 19(1)(g) of Regulation (EC) No 1223/2009, the list of ingredients on a cosmetic product must be indicated “using the common ingredient names contained in a glossary to be compiled and updated by the Commission.”

On 16 June 2025, the European Commission published Implementing Decision (EU) 2025/1175, which updates the glossary of ingredient names and fully replaces the previous Decision (EU) 2022/677.

In summary:

• The glossary of cosmetic ingredients (INCI nomenclature and common names) has been updated.

• The goal is to ensure consistent and internationally aligned labelling and greater transparency for consumers.

• For brands and formulators, this entails operational adjustments to both technical documentation and labelling.

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2. What’s new

The main changes introduced by Implementing Decision (EU) 2025/1175 include:

• An update of the common ingredient names (INCI) to include newly introduced ingredients and to correct errors or omissions from previous versions.

• Repeal of the previous regulation (i.e., Decision (EU) 2022/677) governing the former glossary.

• Transition timeline: the Implementing Decision (EU) 2025/1175 entered into force on 30 July 2025 and will apply from 30 July 2026.

The Responsible Person must:

• Verify that ingredient lists on product labels use the correct common names as per the updated glossary.

• Update cosmetic notifications in the CPNP portal, if required.

• Plan resources and timing to ensure compliance within the legal deadlines.

Attention: the Responsible Person is not the only stakeholder involved!

• Manufacturers must ensure that formulation ingredient lists reflect the updated INCI names and request updates to the raw material technical documentation where needed.

• Raw material producers and suppliers must update their technical documentation accordingly.

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3. Benefits for professionals

For professionals working in R&D, quality, or regulatory affairs in the cosmetic sector, timely alignment offers tangible advantages:

• Regulatory compliance, reducing the risk of sanctions or product recalls due to incorrect ingredient naming.

• Transparency towards distribution channels and end consumers, who increasingly demand clarity and accuracy in ingredient lists.

• Streamlined documentation management: updated nomenclature facilitates internal and external communication (with suppliers, distributors, and authorities).

• Competitive advantage: brands communicating their ingredients correctly and consistently reinforce their credibility.

• Reduced formulation risk: outdated or incorrect terminology can create confusion in procurement or production, especially when working with international suppliers.

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4. Practical implications and implementation checklist

Here is an operational checklist to support a swift and systematic compliance process:

• Identify all products in your portfolio falling under the EU Cosmetics Regulation (EC No 1223/2009).

• Extract the complete list of INCI ingredients currently used for each product.

• Verify each ingredient against the updated EU glossary (Decision 2025/1175) to confirm its current common name.

• For ingredients not found in the new glossary: contact the supplier or regulatory consultant to clarify whether a new denomination is foreseen or the ingredient has become obsolete.

• Update technical documentation (technical data sheet, product information file, CPNP) with the new denomination, including the date of update.

• Update product labels: ensure that the common name displayed is compliant and that the change is validated by quality/production departments.

• Communicate the change internally (R&D, production, packaging, marketing) to ensure cross-functional alignment.

• Plan an annual review of ingredient terminology to anticipate future updates.

• Document a risk/mitigation position: for example, if an ingredient is under revision, evaluate potential alternatives or replacement timing.

Recommended timeline:

• By end of 2025: internal audit of ingredient portfolio.

• During Q1 2026: update of documentation and notifications.

• By 30 July 2026 (application date): all new products placed on the market must bear the updated labelling.

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