Global Requirements for Online Ingredient Lists in Cosmetic Products

The demand for transparency in the cosmetics industry has grown significantly in recent years. Consumers are increasingly seeking detailed information about the products they use, driven by concerns about allergies, personal preferences, and the safety of ingredients.¹ This heightened awareness has coincided with a substantial increase in online cosmetic sales. The convenience and accessibility of e-commerce platforms have transformed how consumers shop for beauty and personal care products. This shift towards online retail presents unique challenges and necessitates clear regulatory frameworks to ensure that consumers receive the same level of product information they would expect when shopping in a physical store. Recognizing this evolving landscape, regulatory bodies worldwide have been adapting their requirements for cosmetic product labeling to include the digital space. This report aims to provide a comprehensive overview of the countries where displaying ingredient lists for cosmetic products online is legally mandatory, along with the specific details of these regulations, offering essential guidance for businesses navigating the complexities of the global online cosmetics market.

United States

In the United States, the regulation of cosmetics falls under the purview of the Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Fair Packaging and Labeling Act (FPLA).⁴ The Food and Drug Administration (FDA) is responsible for enforcing these regulations, ensuring that cosmetics marketed within the country, whether manufactured domestically or imported, are safe and properly labeled.⁴ It is important to note that, generally, cosmetics do not require pre-market approval from the FDA, with the exception of color additives. This places the onus on manufacturers to ensure the safety of their products and the accuracy of their labeling, including for those sold online.⁵

For cosmetic products sold at retail, which includes online sales, the FPLA mandates that ingredients must be listed by their common or usual names, generally in descending order of predominance.⁷ This requirement is codified in Title 21 of the Code of Federal Regulations (21 CFR 701.3). Recognizing the specific nature of online commerce, the FDA provides an allowance for products sold on a mail-order basis, which is interpreted to include sales through websites.⁷ In such cases, the package sent to the consumer can include readily visible instructions on how to find the ingredient declaration, such as on the product catalog (which includes a website) or directions for requesting a copy of the ingredient list.

Distributors using this method are obligated to respond promptly to any such requests.⁷ It is crucial to understand that this ingredient listing requirement applies to consumer commodities and does not extend to products distributed solely as free samples, for professional use, or for institutional use.⁷ This indicates that cosmetics offered for general retail sale online in the US are indeed subject to the requirement of making ingredient information available to consumers.

The FDA specifies certain formatting and language requirements for cosmetic labels. Ingredients should be listed on an information panel in a location where consumers can easily find it when making a purchase.⁷ For online display, this would typically be a clearly marked section on the product page. The minimum letter height for ingredient lists is generally 1/16 of an inch, but for packages where the surface area available for labeling is less than 12 square inches, a minimum height of 1/32 of an inch is permitted.⁸ While these dimensions are primarily for physical labels, they underscore the need for online ingredient lists to be presented in a clear and readable format across various digital devices.

Furthermore, all words, statements, and other information mandated by the FD&C Act must appear in English if the product is marketed in the United States.¹⁰ This naturally applies to the ingredient list as well. While the FDA requires the use of common or usual names for ingredients, it does not object to the inclusion of alternative names, such as Latin names for botanicals or Colour Index (CI) numbers for color additives, provided they are placed in parentheses following the common or usual name in English (or Spanish in Puerto Rico).⁷ For instance, “Water (Aqua)” and “FD&C Yellow No. 5 (CI 19140)” are acceptable formats.⁷ This approach ensures that consumers can easily understand the ingredient list while also providing additional information that may be useful for those with specific knowledge or international perspectives.

For cosmetic products imported into the US and sold online, there are additional labeling requirements. Every article of foreign origin must be clearly marked with the country of origin. This marking must be permanent, legible, and conspicuous.⁸ This requirement is also applicable to products offered for sale through online platforms. Moreover, if the label or labeling of a cosmetic product marketed in the US contains any representations in a foreign language, all mandatory information, including the ingredient list, must appear in that foreign language as well as in English.¹⁰ This is particularly relevant for online retailers who may target specific language-speaking communities within the US.

Looking ahead, the regulatory landscape for cosmetic labeling in the US is set to evolve with the implementation of the Modernization of Cosmetics Regulation Act of 2022 (MoCRA).¹¹ This act grants the FDA new authorities and mandates several changes, including the potential for future regulations requiring the labeling of specific fragrance allergens.¹¹ While the specifics of these regulations are still under development, it indicates a move towards greater transparency regarding ingredients that may cause sensitivities. Furthermore, MoCRA requires a responsible person to list each marketed cosmetic product with the FDA, including a comprehensive list of ingredients, and to update this information annually.¹¹

Although this is primarily a registration requirement, it contributes to increased transparency about the ingredients used in cosmetic products sold online and offline. These upcoming changes underscore the ongoing commitment to ensuring that consumers have access to comprehensive and accurate information about the cosmetics they purchase.

In summary, the United States legally requires that ingredient lists are accessible online for cosmetic products offered for retail sale through e-commerce platforms. These lists must use common or usual English names, generally be in descending order of predominance, and adhere to specific formatting guidelines.

European Union

The European Union operates under a comprehensive and harmonized regulatory system for cosmetic products, with Regulation (EC) No 1223/2009 serving as the primary legal framework.¹⁴ This regulation applies to all cosmetic products made available on the EU market, irrespective of their origin or sales channel, including those sold online.¹⁴ The overarching aim of this regulation is to ensure a high level of protection for human health while facilitating the free movement of cosmetic products within the single market.¹⁵ Only cosmetic products that fully comply with the stringent requirements of this regulation are permitted to be placed on the European market.¹⁵

Article 19(1)(g) of Regulation (EC) No 1223/2009 explicitly mandates that the list of ingredients must be indicated on both the container and any packaging of cosmetic products.¹⁵ This requirement is directly applicable to cosmetic products sold online. The ingredient list must be visible to the consumer at the time of purchase, which in the context of e-commerce, typically means it should be clearly displayed on the product page or in a readily accessible section.²¹ Recognizing that there may be instances where providing the full ingredient list directly on the packaging is impractical, for example, due to very small product sizes, the regulation allows for the information to be mentioned on an enclosed or attached leaflet, label, tape, tag, or card. In such cases, the packaging must bear a reference to this information, often through the use of the open book symbol.²⁰

For online sales, this provision would likely translate to the need for a clear digital equivalent, such as a prominent link to a separate page or a pop-up window containing the complete ingredient information. This ensures that consumers shopping online have access to the necessary details before making a purchase decision.

The EU has specific formatting and language requirements for cosmetic ingredient lists. All ingredients must be listed using their International Nomenclature Cosmetic Ingredient (INCI) names.¹⁴ The ingredient list must be preceded by the word ‘ingredients’.²¹ Ingredients must be listed in descending order of weight as they are added during the manufacturing process.⁶ However, ingredients that are present in a concentration of less than 1% can be listed in any order after those present at concentrations of 1% or more.⁶ For colorants that are not intended for hair coloring, the Colour Index (CI) number must be used for identification.²¹ In the case of perfumes and aromatic compositions, the INCI names ‘parfum’ or ‘aroma’ should be used.²¹

If a cosmetic product contains nanomaterials, this must be clearly indicated by including the word ‘nano’ in brackets immediately following the INCI name of the nanomaterial, for example, ‘titanium dioxide [nano]’.²⁰ While the use of INCI names provides a standardized international nomenclature, Article 19(5) of the Regulation grants Member States the authority to require that the labeling information, including the ingredient list, is provided in their national language(s).²⁰ This means that while the ingredient names themselves will be in INCI, the introductory term “Ingredients” and potentially other label elements may need to be translated into the language of the EU member state where the product is being sold online.

In addition to the ingredient list, the name or trade name and the address of the ‘responsible person’ established within the EU must be indicated on the label.¹⁴ This responsible person is legally accountable for ensuring that the cosmetic product complies with all applicable EU regulations.

The EU cosmetic regulatory landscape is subject to ongoing updates and changes. Regulation (EU) 2024/2462, which will take effect on October 10, 2026, introduces specific concentration limits for perfluorohexanoic acid (PFHxA), its salts, and related substances in cosmetic products.²⁴ This will necessitate adjustments to the ingredient lists of affected products to reflect these new restrictions. Furthermore, the EU continuously revises its list of prohibited and restricted substances (Annex II and III of the Regulation) based on the latest scientific findings and safety assessments.⁶

There have also been updates to the labeling requirements for fragrance allergens. Currently, 26 recognized perfume allergens must be specifically labeled if their concentration in the finished product exceeds certain threshold levels (0.01% in rinse-off products and 0.001% in leave-on products).¹⁴ These ongoing changes highlight the need for businesses selling cosmetics online in the EU to stay informed about the latest regulatory developments to ensure continuous compliance.

In conclusion, the European Union legally mandates the display of ingredient lists for cosmetic products sold online. These lists must use INCI names, follow specific formatting guidelines, and may need to be translated into the local language of the member state where the product is offered for sale.

Canada

In Canada, the safety and labeling of cosmetic products are regulated under the Food and Drugs Act and its associated Cosmetic Regulations.¹ Health Canada is the federal authority responsible for administering these regulations.²⁷ Unlike the EU, Canada does not have a pre-market approval system for cosmetics. However, manufacturers and importers are required to notify Health Canada of their cosmetic products within ten days of the first sale by submitting a Cosmetic Notification Form (CNF), which includes detailed product information.²⁷ This notification process, along with post-market surveillance, helps ensure that cosmetics sold in Canada, including those online, meet the required safety and labeling standards.

Section 21.2(1) of the Cosmetic Regulations explicitly states that a list of ingredients must appear on the outer label of a cosmetic product.³⁰ Health Canada interprets the “outer label” to include the information presented on a product’s webpage or through other digital means when sold online.² This ensures that consumers shopping for cosmetics online have access to the ingredient list before making a purchase. Similar to the US and EU, if the immediate container or outside package is too small to accommodate the full ingredient list, the regulations allow for the information to be displayed on a tag, tape, or card affixed to the container or package.³⁰ For online sales, this would necessitate making the ingredient information readily accessible through a clear link or visual representation on the product page.

Canada has specific requirements for the formatting and language of cosmetic ingredient lists. Each ingredient must be listed by its International Nomenclature of Cosmetic Ingredients (INCI) name.³⁰ For botanical ingredients, at least the genus and species portions of the INCI name must be specified.³⁰ Ingredients must be listed in descending order of predominance by weight. However, ingredients present at a concentration of 1% or less, as well as all coloring agents, can be listed in random order after the ingredients present at concentrations greater than 1%.³⁰

For fragrance and flavour, the words “parfum” and “aroma”, respectively, may be inserted at the end of the ingredient list or at the appropriate point according to their concentration.³⁰ A key aspect of Canadian labeling is the requirement for bilingual labeling. All cosmetic labels, including those displayed online, must be in both English and French, Canada’s two official languages. This requirement applies to all mandatory labeling information with the exception of the INCI ingredient names themselves.²⁷ Therefore, while the ingredient names will be in INCI, the heading “Ingredients/Ingrédients” and any other accompanying text on the online listing must be provided in both English and French. Additionally, ingredients included in the Schedule to the Cosmetic Regulations can be listed by their EU trivial name, their English and French equivalents, or all three.³⁰ For example, “Aqua” or “Water/Eau” are acceptable.

Health Canada maintains a Cosmetic Ingredient Hotlist, which is a publicly available list of ingredients that are prohibited or restricted for use in cosmetic products.²⁷ Compliance with this Hotlist is mandatory for all cosmetics sold online in Canada. The Hotlist is regularly updated based on new scientific information and safety assessments.²⁵ Recent updates in 2024 involved ingredients such as retinal and thioglycolic acid esters.³² Additionally, requirements for contact information on internal labels were adjusted in April 2024.³¹ These ongoing updates highlight the need for businesses selling cosmetics online in Canada to stay informed about the latest regulatory changes published by Health Canada.

In conclusion, Canada legally requires the display of ingredient lists, using INCI names, for cosmetic products sold online. Furthermore, all other mandatory labeling information on the online listing must be presented in both English and French.

Australia

The labeling of cosmetic products in Australia is primarily governed by the Australian Consumer Law (ACL) and the Consumer Goods (Cosmetics) Information Standard 2020.² While the Therapeutic Goods Administration (TGA) regulates cosmetics with therapeutic claims, the ACL and the Information Standard apply to general cosmetic products.³⁵ The ingredients used in cosmetics are also regulated as industrial chemicals under the Australian Industrial Chemicals Introduction Scheme (AICIS).³⁷ This multi-faceted regulatory framework ensures that cosmetic products sold in Australia, including online, are safe and accurately labeled.

The Consumer Goods (Cosmetics) Information Standard 2020 explicitly states that ingredient information must be available to consumers at the point of sale.² For products sold online, this requirement is met by providing the ingredient information on the product’s webpage, ensuring that online shoppers have access to this information before making a purchase.² If the product’s size or shape prevents direct labeling on the container, the ingredient list must still be accessible. For online sales, a clearly displayed list on the product page fulfills this requirement. Other methods for physical products include displaying the list nearby, providing leaflets, or using QR codes or barcodes that link to the ingredient information online.²

Australia has specific guidelines for formatting ingredient lists. All ingredients must be listed in descending order of weight or volume at the time of manufacture.² Alternatively, the standard allows for a tiered listing order: ingredients (except color additives) at a concentration of 1% or more should be listed first in descending order by volume or mass, followed by ingredients (except color additives) at concentrations less than 1% in any order, and finally, color additives in any order.³³ For consistency and to align with international practices, the use of the International Nomenclature of Cosmetic Ingredients (INCI) is strongly encouraged.²

While not always explicitly mandated, using INCI names is considered best practice for clear and consistent communication of ingredient information. Although not explicitly stated in the snippets, it is implied that the ingredient list should be in English, as Australia’s official language, for consumer understanding.² In addition to the ingredient list, the online product listing must include any necessary warnings and precautions if the product poses a health risk.² The name and address of the manufacturer or importer must also be provided, allowing consumers to contact the responsible party if needed.² Cosmetics manufactured in Australia for export are exempt from the mandatory labeling standard.³⁵

However, these products would need to comply with the labeling regulations of the countries to which they are exported.³³ The provided research does not indicate any significant upcoming changes to cosmetic ingredient list requirements in Australia that would specifically affect online sales.

In conclusion, Australia legally requires ingredient lists to be available online for cosmetic products sold through e-commerce platforms, with specific guidelines on the order of listing and a strong recommendation to use INCI names, presented in English.

Japan

The regulation of cosmetics in Japan falls under the purview of the Pharmaceuticals and Medical Devices Law (PMDL), with the Ministry of Health, Labour and Welfare (MHLW) as the competent authority.³⁸ Japan distinguishes between “cosmetics” and “quasi-drugs,” with quasi-drugs, which have mild medicinal effects, subject to more stringent regulations.³⁸ Selling cosmetics or quasi-drug products in Japan typically requires obtaining a manufacturing license and a marketing license, and foreign businesses often partner with local entities that already possess these licenses.³⁹

This dual regulatory system necessitates accurate product classification, as the labeling requirements, including those for ingredient lists, differ between the two categories.

Full ingredient labeling in Japanese is legally mandatory on the outer packaging of cosmetic products sold in Japan.⁴⁰ While the primary packaging can omit the full ingredient list, both the outer and primary packaging must contain the same information, with the exception of the complete ingredient list.⁴⁰ For online sales, this regulation necessitates that the full ingredient list, written in Japanese, must be clearly and prominently displayed on the product’s webpage or in a designated section accessible to consumers before they make a purchase.² This ensures that consumers shopping online have access to the same comprehensive ingredient information as those purchasing in physical stores.

Japan has highly specific requirements for the formatting and language of cosmetic ingredient lists. The language must be Japanese.⁴⁰ All non-color ingredients must be listed in descending order of predominance by weight or volume.⁴⁰ Following the non-color ingredients, all colors and non-color ingredients present at a concentration of 1% or less can be listed in random order.⁴⁰ There is no legal requirement to indicate incidental ingredients.⁴⁰ If a product contains a mixed ingredient, each individual ingredient within that mixture must be listed separately.⁴⁰

For extracts, the labeling should indicate both the extract itself and the solvent or diluted solution used.⁴⁰ Perfume or fragrance can be simply indicated as “perfume” (香料) in Japanese.⁴⁰ To assist companies in complying with these regulations, the Japan Cosmetic Industry Association (JCIA) has developed a Japanese version of the “List of Cosmetic Ingredient Label Names”.⁴⁰ Quasi-drugs have their own distinct labeling requirements, which include the name and concentration of active ingredients.³⁸ While full ingredient lists might be provided voluntarily for quasi-drugs, they are not always legally mandated to the same extent as for cosmetics.⁴² The provided research does not indicate any significant upcoming changes to cosmetic ingredient list requirements in Japan that would specifically affect online sales.

In conclusion, Japan legally mandates the display of a full ingredient list written in Japanese for cosmetic products sold online, adhering to specific formatting and ordering guidelines.

South Korea

The regulation of cosmetics in South Korea falls under the purview of the Cosmetics Act, with the Ministry of Food and Drug Safety (MFDS) as the primary regulatory body.³ South Korea employs a “negative list” system for cosmetic ingredients, prohibiting the use of specified substances while allowing all others under the manufacturer’s responsibility for safety.²⁵ Preservatives, UV filters, and colorants have their own permitted lists.⁴⁷ The MFDS also regulates “functional cosmetics,” which include products aimed at skin whitening, wrinkle reduction, UV protection, and hair loss prevention, often requiring additional testing and labeling.³

For cosmetic products marketed within South Korea, the labels must include a list of all ingredients, generally in descending order of concentration.³ This requirement logically extends to online sales, as the principle of providing essential labeling information at the point of sale applies to e-commerce platforms as well. Online product listings should clearly display the ingredient list. While the physical product label must be in Korean, bilingual labeling (e.g., English and Korean) is acceptable for products intended for export.³ For online sales within South Korea, the primary language for the ingredient list should be Korean.

The ingredient list on cosmetic labels in South Korea must be written in Korean.³ Ingredients must be listed in descending order of predominance based on their concentration in the product.³ However, ingredients used in concentrations of 1% or less, as well as flavorings and coloring agents, may be listed in any order after the ingredients present at concentrations exceeding 1%.⁴⁵

If a product contains a compound ingredient (a mixture of multiple ingredients), each individual ingredient within that compound must be listed separately.⁴⁸ For products intended for export and sold online internationally, bilingual labeling including English is acceptable.³ The MFDS provides an online cosmetic ingredient dictionary with standardized Korean names to facilitate accurate labeling.⁴⁹ Functional cosmetics have additional labeling requirements, including the specific functional ingredients and their concentration.³ These requirements also apply to online listings. The MFDS frequently proposes revisions to the regulations regarding cosmetic ingredient usage standards.⁴⁴ Regulations for “personalized cosmetics,” which are customized for individual consumers, were introduced in 2020 and require specific reporting of ingredient lists.⁴⁷

In conclusion, South Korea legally requires ingredient lists written in Korean to be displayed online for cosmetic products sold within the country, following specific guidelines for order and content.

China

Cosmetic labeling in China is primarily regulated by the “Regulations on the Supervision and Administration of Cosmetics” (CSAR) and the “Administrative Measures for Cosmetic Labeling,” with the National Medical Products Administration (NMPA) overseeing enforcement.⁵⁰ China classifies cosmetics into “special cosmetics” (e.g., hair dyes, sunscreens, whitening products) which require registration with the NMPA, and “ordinary cosmetics” which require filing.⁵⁰ This classification impacts labeling requirements. All cosmetics placed on the Chinese market must comply with the Safety and Technical Standards for Cosmetics (STSC), which includes lists of prohibited and restricted ingredients.⁵²

When selling cosmetics online in China, the product listing must include all the information that would be found on the physical product’s label, including a complete list of all ingredients.⁵⁰ This requirement is strictly enforced, and non-compliance can result in penalties, including fines and removal of products from the market.⁵⁰

Simplified Chinese must be used for all mandatory labeling information on cosmetic products sold in China, including the ingredient list.⁵⁰ Other languages can be included on the label, but the Chinese text must be more prominent.⁵⁰ The ingredient list should typically follow the International Nomenclature of Cosmetic Ingredients (INCI) names, with their corresponding standard Chinese names.⁶ The Chinese label must also include the product name in Chinese, the registration certificate number for special cosmetics, registrant and manufacturer information, net content, expiration date, usage instructions, safety warnings, and the product standard number.⁵⁰ For imported cosmetics, the label must also include the country of origin and the name and address of the distributor in China.⁵¹

Since January 1, 2023, the NMPA requires ingredient safety information or an ingredient code to be provided for all ingredients during the cosmetic filing and registration process.⁵⁷ All ingredients used in cosmetic products sold in China must be listed in the Inventory of Existing Cosmetic Ingredients in China (IECIC). New ingredients require a separate registration process.⁵⁴ China’s cosmetic regulatory framework has undergone significant modernization with the implementation of CSAR in 2021, and the regulatory landscape continues to evolve with the release of subsidiary regulations and technical guidelines.²⁵

In conclusion, China legally mandates the display of a full ingredient list written in Simplified Chinese for cosmetic products sold online, along with numerous other specific labeling requirements.

India

Cosmetics in India are regulated under the Drugs & Cosmetics Act 1940 and the Cosmetics Rules 2020, with the Central Drugs Standard Control Organisation (CDSCO) being the primary regulatory authority.⁵⁸ The import of cosmetics into India requires registration with the CDSCO.⁶⁰ The Cosmetics Rules 2020 outline detailed requirements for the manufacture, testing, labeling, import, registration, sale, and distribution of cosmetics in India.⁵⁹

The Cosmetics Rules 2020 mandate that a list of all ingredients must be displayed on both the inner and outer labels of cosmetic products sold in India.⁵⁸ For cosmetics sold online in India, this requirement necessitates that the product page clearly and accurately displays the ingredient list as it appears on the physical product labels.⁵⁸ While there are some exemptions for small-sized cosmetic products regarding ingredient listing on physical labels, it is advisable to include the ingredient list online regardless of the product size to ensure full transparency and compliance.⁵⁸

The ingredient list on cosmetic labels in India must be preceded by the word “INGREDIENTS”.⁵⁸ Ingredients with a concentration of more than 1% must be listed in descending order of weight or volume at the time they were added during manufacturing.⁵⁸ Following the ingredients above 1%, components with a concentration of less than or equal to 1% should be listed in any order.⁵⁸ The language for the ingredient list is generally expected to be English for products sold in India.⁵⁹ While there was a recent proposal to mandate the use of International Nomenclature of Cosmetic Ingredients (INCI) names, it was not adopted due to space constraints, and the industry continues to follow the existing Bureau of Indian Standards (BIS) for ingredient labeling.⁶¹

For imported cosmetics, the label must include the importer’s name and complete address, as well as the import registration certificate number.⁵⁸ The country of manufacture must also be declared on the label.⁵⁸ During a meeting in June 2024, India’s Drugs Consultative Committee (DCC) reviewed a proposal to mandate the inclusion of International Nomenclature of Cosmetic Ingredients (INCI) names on cosmetic product labels. However, the DCC concluded that incorporating INCI names would not be feasible due to space constraints and recommended that the cosmetics industry continue to follow the existing Bureau of Indian Standards (BIS) standards for ingredient labeling.⁶¹

In conclusion, India legally requires the display of ingredient lists (preceded by “INGREDIENTS” and following specific ordering rules) for cosmetic products sold online, generally using English names according to the Bureau of Indian Standards.

International Standards and Harmonization

The International Nomenclature Cosmetic Ingredient (INCI) system provides internationally recognized systematic names to identify cosmetic ingredients, aiming for consistency on product labels worldwide.² Used in numerous countries including the US, EU, Canada, and Japan, INCI benefits consumers by facilitating the identification of allergens, assists scientists and the medical community, and helps the industry track ingredient safety globally.²³ The International Cooperation on Cosmetics Regulation (ICCR) plays a vital role in promoting the harmonization of cosmetic regulations across different countries.

Regulatory authorities from the US, Canada, Japan, Brazil, and the European Union meet annually to work towards similar regulations, including labeling requirements.⁶⁶ This collaboration aims to reduce trade barriers and ensure a high level of consumer protection through consistent international standards. ISO 22716 provides guidelines for Good Manufacturing Practices (GMP) in the cosmetics industry. While primarily focused on production, adherence to GMP standards can contribute to the accuracy and reliability of product labeling information.¹⁴ The following table summarizes the mandatory ingredient list nomenclature in the identified countries:

Country	Mandatory Nomenclature
United States	Common or Usual Names (English)
European Union	INCI Names
Canada	INCI Names (Bilingual Labeling Required)
Australia	INCI Names (Recommended, English Implied)
Japan	Japanese Names
South Korea	Korean Names
China	Simplified Chinese Names (Often with INCI in brackets)
India	English Names (Following BIS Standards)

Differences Between Domestic and International Online Sales

Language requirements often present a significant difference between domestic and international online sales of cosmetics. While domestic sales require labeling in the country’s official language(s), international sales necessitate adapting the online product information, including ingredient lists, to meet the linguistic needs and regulations of each target market.¹⁰ For instance, a product sold domestically in Japan requires Japanese labeling, but the same product sold online in the US would need to be labeled primarily in English. In the US, if a domestically marketed cosmetic includes foreign language, all mandatory information must also appear in that language alongside English.¹⁰ This becomes even more pertinent for international online sales. Australian labeling laws apply specifically to products sold within Australia; for exports, compliance with the destination country’s laws is essential.³³

Cosmetic regulations regarding ingredient restrictions and safety standards can also vary substantially between countries. A product compliant for domestic online sale might not meet the requirements for international sale in another jurisdiction.⁶ The differences in banned substances between the US and the EU ⁶, and the broader regulatory distinctions between these regions ⁶⁹, illustrate this point. Businesses engaging in international online sales must thoroughly research and comply with the specific cosmetic regulations of each target market, as these often differ significantly from domestic standards, impacting both product formulation and labeling.

Furthermore, clearly indicating the country of origin is typically mandatory for international online sales of cosmetic products. This provides transparency to consumers and complies with import regulations.⁸ The US requires imported products to state their country of origin in English ⁹, and China has a similar requirement for imported cosmetics sold online.⁵⁴

Finally, many countries require the designation of a local “responsible person” or importer for cosmetic products being sold online internationally. This entity is accountable for ensuring the product’s compliance with local regulations.¹⁵ The EU mandates a responsible person established within its economic community ¹⁵, and China requires foreign companies selling cosmetics online to appoint a domestic responsible person.⁵³ These requirements underscore the need for international online sellers to establish a formal link with their target markets to ensure regulatory compliance and facilitate communication with local authorities.

Upcoming Changes in Cosmetic Labeling Laws

Several countries are anticipating changes to their cosmetic labeling laws that may affect online sales. In the United States, the FDA is developing regulations for mandatory fragrance allergen labeling under MoCRA.¹¹ MoCRA also mandates the development of GMP requirements for cosmetic facilities.¹¹ Additionally, a proposed rule for standardized testing methods for asbestos in talc-containing products could potentially lead to new labeling requirements.¹¹ The European Union will implement restrictions on PFHxA and related substances in 2026 ²⁴ and continues to update its lists of prohibited and restricted substances and fragrance allergen labeling requirements.¹⁴ Health Canada regularly updates its Cosmetic Ingredient Hotlist.²⁵

While Australia and Japan do not have significant upcoming changes mentioned in the research, South Korea frequently amends its cosmetic ingredient usage standards and has regulations for personalized cosmetics.⁴⁴ China’s cosmetic regulations have been undergoing modernization since 2021, with ongoing updates expected.²⁵ India recently reviewed a proposal for mandatory INCI names but decided to continue with BIS standards for now.⁶¹

Conclusion and Recommendations

In conclusion, the United States, European Union, Canada, Australia, Japan, South Korea, China, and India all legally require the display of ingredient lists for cosmetic products sold online. However, the specific regulations regarding nomenclature, language, formatting, and the order of listing ingredients vary considerably between these countries. While the International Nomenclature of Cosmetic Ingredients (INCI) is widely used and beneficial for international understanding, not all countries mandate its use.

For businesses involved in the online sale of cosmetic products, the following recommendations are crucial for ensuring compliance:

1 Conduct thorough research on the specific cosmetic regulations of each country where you intend to sell products online.

2 Ensure that ingredient lists are clearly and prominently displayed on product pages, making them easily accessible to consumers before purchase.

3 Adhere strictly to the required nomenclature (e.g., common names, INCI, local language) and language requirements for each target market to avoid regulatory penalties.

4 Follow the specific guidelines for the order of listing ingredients (e.g., descending order of predominance) as mandated by the regulations of each country.

5 Pay close attention to any specific formatting guidelines, such as minimum font size, contrast, and placement of the ingredient list on the online product page.

6 Stay diligently informed about any upcoming changes and updates to cosmetic regulations in their target markets by regularly monitoring official government websites and regulatory news sources.

7 Consider using INCI names on their online ingredient lists, even if not strictly required, as a best practice to enhance transparency and facilitate understanding for a broader international audience.

8 For international sales, ensure full compliance with country of origin labeling requirements and any regulations regarding the appointment of a local responsible person or importer.

The following table summarizes the key mandatory requirements for online ingredient lists in each of the identified countries:

Country	Online Ingredient List Mandatory?	Required Nomenclature	Language Requirements	Order of Listing	Specific Formatting Notes	Relevant Regulatory Body/Legislation
United States	Yes	Common or Usual Names (English)	English	Descending Order of Predominance (Generally)	Minimum font size guidelines	FDA (FD&C Act, FPLA)
European Union	Yes	INCI Names	INCI; Potentially Local Language	Descending Order of Weight	Preceded by “Ingredients”; Nanomaterials indicated	Regulation (EC) No 1223/2009
Canada	Yes	INCI Names	English and French (Except INCI)	Descending Order of Predominance (Generally)	May be preceded by “Ingredient/Ingrédients”	Health Canada (Food and Drugs Act, Cosmetic Regulations)
Australia	Yes	INCI Names (Recommended, English Implied)	English (Implied)	Descending Order of Weight/Volume (with Alternatives)	Information available at point of sale (online)	Australian Consumer Law, Consumer Goods (Cosmetics) Information Standard 2020
Japan	Yes	Japanese Names	Japanese	Descending Order (Non-Color), Random (<1% & Color)	Full ingredient labeling on outer package (online equivalent)	Ministry of Health, Labour and Welfare (Pharmaceuticals and Medical Devices Law)
South Korea	Yes	Korean Names	Korean	Descending Order of Concentration (Generally)	Low concentration ingredients can be in any order	Ministry of Food and Drug Safety (Cosmetics Act)
China	Yes	Simplified Chinese Names (Often with INCI in brackets)	Simplified Chinese	Generally Descending Order	Clear and legible; Prominent Chinese text	National Medical Products Administration (Regulations on Supervision and Administration of Cosmetics, Administrative Measures)
India	Yes	English Names (Following BIS Standards)	English	Descending Order (>1%), Any Order (≤1%)	Preceded by “INGREDIENTS”	Central Drugs Standard Control Organisation (Drugs & Cosmetics Act 1940, Cosmetics Rules 2020)