Your INCI List Didn't Change. Your Label's Compliance Might Have.

Aug 18

4 min read

Keywords: EU INCI glossary 2026 · Implementing Decision (EU) 2025/1175 · cosmetic ingredient labelling EU · Colour Index CI nomenclature · Regulation (EC) 1223/2009 Article 33 · cosmetics label compliance deadline

Most indie beauty brands who caught wind of the EU's glossary update over the past year filed it under "348 new ingredient names, check if any apply to me." That reading is not wrong, but it is incomplete, and the gap matters. Commission Implementing Decision (EU) 2025/1175 was adopted on 16 June 2025 and published in the Official Journal on 10 July 2025, superseding the previous glossary, Implementing Decision (EU) 2022/677. It opened a 12-month transitional period, running from 29 July 2025 to 29 July 2026, during which brands could adopt the revised glossary voluntarily while the old version remained a legally valid reference. That window closed on 29 July. From 30 July 2026, the updated Glossary of Common Ingredient Names — the reference every INCI name on an EU cosmetics label is checked against — is the only version your Responsible Person, customs authorities, and market-surveillance inspectors recognise.

What the update actually contains

The headline number is 348: that's how many new INCI entries Implementing Decision (EU) 2025/1175 adds, bringing the Glossary of Common Ingredient Names to a total of 30,418 names. That part is the easy read. What most summaries skip is that the decision also revises and corrects entries that were already in the glossary — rectifying errors and omissions carried over from the previous version. And under Article 19(1)(g) of Regulation (EC) No 1223/2009, the same decision makes Colour Index (CI) nomenclature the mandatory way to name colorants other than hair dyes, wherever a CI number exists for that colorant. Both changes sit on the same legal basis as the glossary itself: Article 33 of the Cosmetic Products Regulation, which requires INCI names on cosmetic labels to match the Commission's official list.

Why a formula that hasn't changed can still fail

This is the part worth sitting with. If your product's formula is identical to what it was last year, you might assume your label is still fine. Two things can break that assumption. First, if any ingredient name in your list is one the Commission corrected in this revision, your label is now referencing a name the current glossary no longer recognises — even though nothing in the bottle changed. Second, if you name a colorant (other than a hair dye) by a trade term or descriptive name instead of its CI number, and a CI number exists for it, that label text is now non-compliant under Article 19(1)(g). Neither gap is visible from the product itself. It only shows up when someone checks the label text, ingredient by ingredient, against the current edition of the glossary — not the edition you checked against when you first wrote the label.

Three mistakes we're seeing

Checking only the "new" entries. The 348 new names are the easiest part of this update to audit, so that's where most brands stop. The higher-risk exposure is in the entries that were revised, because those are the ones a brand reasonably assumes it already got right.

Treating CI nomenclature as a style choice. Some brands still list colorants by trade name because that's what the supplier's spec sheet uses, or because it reads better on packaging. Where a CI number exists, it is no longer optional — it is the name the regulation requires on the label.

Bundling this with the fragrance allergen deadline. The updated glossary becomes mandatory on 30 July 2026; the expanded Annex III fragrance allergen list under Regulation (EU) 2023/1545 becomes mandatory the following day, 31 July 2026. They are two separate legal instruments with two separate obligations. Brands that treat "the July deadlines" as one project sometimes clear the allergen list — the more visible, more discussed one — and let the glossary check slide.

The pattern behind the date

30 July is not really about that one date, and it will not be the last time this shape of deadline shows up. A decision or regulation is adopted, a transitional period opens for a year or more while attention moves on to other things, and then the window closes quietly — at which point the underlying rule, not the adoption date, actually starts to bite. The fragrance allergen list worked the same way (adopted in 2023, mandatory from 31 July 2026). So did the Packaging and Packaging Waste Regulation, whose main obligations only started applying from 12 August 2026, more than a year after it entered into force. And Omnibus VI, the chemicals-simplification package covering cosmetics, reached political agreement between the Parliament and Council on 16 June 2026 — formal adoption is still pending, which means its implementing measures, once adopted, will very likely open transitional windows of their own. The durable habit worth building from this is tracking "end of transitional period" as its own line on your compliance calendar, separate from "entry into force" of the underlying act — because it's the former, not the latter, that actually re-arms the rule against your labels.

Checklist: before your next label print run

Pull the current INCI list for every SKU you sell in the EU — not only products launched in the last year.
Cross-check every ingredient name, including ones already on your labels, against the current Glossary of Common Ingredient Names — not the edition you last checked against.
For colorants other than hair dyes, confirm you're using the CI number where one exists, not a trade or descriptive name.
Record which glossary edition each label was verified against in your Product Information File's labelling section.
Hold print runs on any affected SKU until the check is complete — a short reprint delay now is cheaper than a market-surveillance finding later.

If you'd like a second set of eyes on your INCI lists and colorant naming before your next print run, Cláritas Regulatory can run that check against the current glossary for you — get in touch.