Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 I have a question on the use of herbs and INCI. This is more of something that just bugs me. I notice that when the plant genus and species are used for naming. Most references use something along these lines: Cedrus Atlantica (Cedarwood) Bark Oil Being a biologist, I have had binomial nomenclature beaten into my brain and the actual written form should be : Cedrus atlantica (Cedarwood) Bark Oil or Cedrus atlantica (Cedarwood) Bark Oil This is how I label my ingredients, anyone have any input? Thanks, Robin Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 In a message dated 4/3/03 8:06:07 AM Pacific Standard Time, maurice@... writes: > > >I have a question on the use of herbs and INCI. This is more of something > > >that just bugs me. I notice that when the plant genus and species are > used > >for naming. Most references use something along these lines: Cedrus > >Atlantica (Cedarwood) Bark Oil > > > >Being a biologist, I have had binomial nomenclature beaten into my brain > and > >the actual written form should be : Cedrus atlantica (Cedarwood) Bark Oil > > >or Cedrus atlantica (Cedarwood) Bark Oil > > > >This is how I label my ingredients, anyone have any input? > > I think you are correct. However the CTFA started using this type of > nomenclature with the 7th Edition. > > Cedarwood Oil is used in the 6th Edition, Cedarwood (Cedrus Atlantica) Oil > is used in the 7th Edition and Cedrus Atlantica (Cedarwood) Bark Oil is > found the 8th and 9th > editions. > > When I added the volatile oil obtained from the bark of Cedrus atlantica to > one of my formulas, I used Cedarwood Bark Oil. Hi Robin, Maurice and All, I thought the general consensus is that we are not supposed to use the botanical names (genus/species) of herbs/flowers/plants in order to comply with the FDA (for now anyway)? Maybe I misunderstood. I hope so, because the most accurate way to describe a particular plant is by genus/species and to do otherwise can be misleading and in my herbalist's opinion can be downright dangerous. The common name 'Marigold' can refer to several different plants/different genus/species, but Calendula officinalis is accurate and specific. There are many, many other examples. But, my understanding is that the common name is the one they want us to use?? But alas, I don't make the rules, I just try to understand and follow them--a challenge in itself So, what's the story, folks? Angie The Herbarie - Botanicals and Body Care Natural Source & Specialty Bulk Ingredients...Exceptional Quality at Wholesale Prices...visit us at http://www.theherbarie.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 > > >>I'm >>assuming those names would be used if you were using an alcohol or water >>extract of the herb in your product.ÿ I'm using either whole or powdered >>herbs, how would I change the names?ÿ Just leave off the word extract? > >Quoting from the CTFA Dictionary > > " The INCI names for extracts represent the " material extracted " . Many extracts are supplied with the extracting solvent and/or other diluents. The solvents and/or diluents in >extracts must be listed in their proper order of predominance, along with all other ingredients in the formulation, on the package label. Information on the concentration of >solvents and/or diluents in a specific extract must be obtained from the supplier. " > >So in your case, you would use the word " extract " . I gave you incorrect information. If you are using the whole herb, I would just leave off the word extact as you suggested. If you are using the whole herb in a powdered form, I'd replace the word extract with powder. Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 >I have a question on the use of herbs and INCI. This is more of something >that just bugs me. I notice that when the plant genus and species are used >for naming. Most references use something along these lines: Cedrus >Atlantica (Cedarwood) Bark Oil > >Being a biologist, I have had binomial nomenclature beaten into my brain and >the actual written form should be : Cedrus atlantica (Cedarwood) Bark Oil >or Cedrus atlantica (Cedarwood) Bark Oil > >This is how I label my ingredients, anyone have any input? I think you are correct. However the CTFA started using this type of nomenclature with the 7th Edition. Cedarwood Oil is used in the 6th Edition, Cedarwood (Cedrus Atlantica) Oil is used in the 7th Edition and Cedrus Atlantica (Cedarwood) Bark Oil is found the 8th and 9th editions. When I added the volatile oil obtained from the bark of Cedrus atlantica to one of my formulas, I used Cedarwood Bark Oil. Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 >In order to be consistant with 2nd edition INCI I'd leave out the latin name which would leave me with " lavender extract " . ÿThen, if I'm using the whole herb, I'd leave off the word extract which would leave me with the word " lavender " only. ÿIs this correct? Yes, that is what I would do. If I were using whole botanicals in my cosmetic product, I would make sure that the botanical had been treated to minimize potential preservation problems. Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 > >In order to be consistant with 2nd edition INCI I'd leave out the latin name which would leave me with " lavender extract " . ÿThen, if I'm using the whole herb, I'd leave off the word > extract which would leave me with the word " lavender " only. ÿIs this correct? > > Yes, that is what I would do. If I were using whole botanicals in my cosmetic product, I would make sure that the botanical had been treated to minimize potential preservation > problems. Maurice, simply stating Lavender as an ingredient is not very explanatory of what the ingredient is. It could be Lavender essential oil, fragrance, flower petal, root, herb, etc.? I believe you need to be more specific than that to meet the intent of the labeling rules. Pat. Peace, Joy, Serenity House of Scents tm. Body Oils, Fragrance Oils, Incense, Candles, Soap, Etc. pat@... http://www.houseofscents.com/ Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 >Maurice, simply stating Lavender as an ingredient is not very explanatory of >what the ingredient is. It could be Lavender essential oil, fragrance, >flower petal, root, herb, etc.? I believe you need to be more specific than >that to meet the intent of the labeling rules. I agree. Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 3, 2003 Report Share Posted April 3, 2003 In a message dated 4/3/2003 12:37:45 PM Eastern Standard Time, AngiesHerbarie@... writes: > In a message dated 4/3/03 8:06:07 AM Pacific Standard Time, > maurice@... writes: > > > > >>I have a question on the use of herbs and INCI. This is more of > something > > > >>that just bugs me. I notice that when the plant genus and species are > >used > >>for naming. Most references use something along these lines: Cedrus > >>Atlantica (Cedarwood) Bark Oil > >> > >>Being a biologist, I have had binomial nomenclature beaten into my brain > >and > >>the actual written form should be : Cedrus atlantica (Cedarwood) Bark Oil > > > > >>or Cedrus atlantica (Cedarwood) Bark Oil > >> > >>This is how I label my ingredients, anyone have any input? > > > >I think you are correct. However the CTFA started using this type of > >nomenclature with the 7th Edition. > > > >Cedarwood Oil is used in the 6th Edition, Cedarwood (Cedrus Atlantica) Oil > > >is used in the 7th Edition and Cedrus Atlantica (Cedarwood) Bark Oil is > >found the 8th and 9th > >editions. > > > >When I added the volatile oil obtained from the bark of Cedrus atlantica > to > >one of my formulas, I used Cedarwood Bark Oil. > > Hi Robin, Maurice and All, > I thought the general consensus is that we are not supposed to use the > botanical names (genus/species) of herbs/flowers/plants in order to comply > with the FDA (for now anyway)? Maybe I misunderstood. I hope so, because > the most accurate way to describe a particular plant is by genus/species > and > to do otherwise can be misleading and in my herbalist's opinion can be > downright dangerous. The common name 'Marigold' can refer to several > different plants/different genus/species, but Calendula officinalis is > accurate and specific. There are many, many other examples. But, my > understanding is that the common name is the one they want us to use?? > > But alas, I don't make the rules, I just try to understand and follow > them--a > challenge in itself So, what's the story, folks? > > Angie > Hi All, Guess the jury is still out on this? I could have sworn I heard someone say the 6th edition is the one we are supposed to use?? Oh well. Someone let me know went the FDA makes up it's mind which edition is the winner. For my own herbs, botanicals and such, I do think I will use the genus/species...my conscience tells me this is correct and the least misleading. Angie The Herbarie - Botanicals and Body Care Natural Source & Specialty Bulk Ingredients...Exceptional Quality at Wholesale Prices...visit us at http://www.theherbarie.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 4, 2003 Report Share Posted April 4, 2003 In a message dated 4/4/2003 12:41:17 PM Eastern Standard Time, maurice@... writes: > Use whichever edition that makes sense to you and your marketplace. > Thanks Pat and Maurice for your excellent explanations! So, now I won't worry about it anymore. This is the time of year for harvesting and planting herbs/flowers, so the botanical/scientific names are on my mind. By the way, we are planting our spring/summer garden today and I highly recommend tilling for stress management at the end of a long week. I just love my little Mantis tiller...it's a lean, mean machine! Works me and the garden right into shape Happy Friday Angie The Herbarie - Botanicals and Body Care Natural Source & Specialty Bulk Ingredients...Exceptional Quality at Wholesale Prices...visit us at http://www.theherbarie.com Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 4, 2003 Report Share Posted April 4, 2003 Hi Angie. > Guess the jury is still out on this? I could have sworn I heard someone say > the 6th edition is the one we are supposed to use?? Oh well. Someone let me > know went the FDA makes up it's mind which edition is the winner. Actually the only one officially approved by the FDA is the 2nd addition. Lots of luck finding one though as it is probably considered a rare book these days. I think the confusion arises over a letter that the FDA wrote concerning the 6th edition where they said that as long as it was under review a manufacturer didn't have to worry about the FDA finding a companies products misbranded for using the later editions. Personally, I believe that the 7th, 8th, and 9th, are covered under a similar agreement, otherwise the major manufacturers could find their products misbranded. I did write to this Halper that was quoted on this list some time ago. He directed me to the FDA pages that we have all read. I wrote back to him and pointed out that the dialog between the FDA and the CTFA seemed to end several years ago according to their website. Since I doubt that actually happened I asked about updates. I also asked him for a yes or no answer if using the 9th edition would get my products misbranded by the FDA. I sent this email on March 11, and to date I have not received a reply. If you recall, about the same time Maurice also contacted the CTFA regarding the nomenclature in the 9th edition, specifically that about botanicals. It was my understanding that he would publish that information to the list when he heard back. You think he has the same problem with them as I have with Mr. Halper? For my own > herbs, botanicals and such, I do think I will use the genus/species...my > conscience tells me this is correct and the least misleading. I agree completely. BTW guys, please take a minute to trim off " all " unnecessary material when you are answering a message. You should only need a few lines to remind people about the subject and what exactly you are responding to. Everything else is litter. Please don't litter. Pat. Peace, Joy, Serenity House of Scents tm. Body Oils, Fragrance Oils, Incense, Candles, Soap, Etc. pat@... http://www.houseofscents.com/ ----- Original Message ----- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 4, 2003 Report Share Posted April 4, 2003 >Guess the jury is still out on this? I could have sworn I heard someone say >the 6th edition is the one we are supposed to use?? As far as I can see, based on documents available on the internet and my conversations with the CFTA's VP of Science and editor of the International Cosmetic Ingredient Dictionary, Gerald N. McEwen, Jr. Ph.D., J.D., you can use the 2nd, 3rd, 4th, 5th, 6th, 7th, 8th and 9th editions. Technically speaking, the only FDA approved CTFA's Cosmetic Ingredient Dictionary, Second Edition: (i) CTFA (Cosmetic, Toiletry and Fragrance Association, Inc.) Cosmetic Ingredient Dictionary, Second Ed., 1977 (available from the Cosmetic, Toiletry and Fragrance Association, Inc. 1110 Vermont Ave. NW., Suite 800, Washington, DC 20005, or available for inspection at the Office of the Federal Register, 800 North Capitol Street, NW., suite 700, Washington, DC 20408), http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?FR=701.3 and " The currently recognized edition of the CTFA (Cosmetic, Toiletry and Fragrance Association, Inc.) Cosmetic Ingredient Dictionary is the second edition published in 1977. This edition is recognized only in part, i.e., not all names listed in the second edition have been adopted. " http://vm.cfsan.fda.gov/~dms/cos-lab3.html But with an increasing number or raw materials becoming available to cosmetic chemists and the need for newer editions became important. " The third edition of the CTFA Cosmetic Ingredient Dictionary published in 1982 and the Supplement published in 1985 have not yet been recognized. However, FDA HAS INFORMED THE CTFA THAT THE AGENCY WILL NOT TAKE REGULATORY ACTION AGAINST PRODUCTS LABELED IN ACCORDANCE WITH THESE EDITIONS WHILE THEIR REVIEW IS IN PROGRESS. " http://vm.cfsan.fda.gov/~dms/cos-lab3.html EU Latin names started to appear in the 5th Edition of the CTFA's Cosmetic Ingredient Dictionary (CID-5). Quoting from the Preface of the 9th Edition of the International Cosmetic Ingredient Dictionary (ICID-9); " CTFA's International Nomenclature Committee and Colipa's Liaison Committee Labeling Nomenclature began working closely together in 1993 to ensure that INCI labeling names would, to the extent possible, be acceptable in both the United States and the EU. In the Fifth Edition (1993), some alternate INCI labeling names for the United States and the EU were first identified, as national regulations required different names for their approved colorants, and certain new conventions were being developed to address some U.S. parochial nomenclature. Based on the nomenclature in the Sixth Edition (1995), Colipa prepared an inventory of cosmetic ingredients, assigning different names to color additives, botanicals, and certain " trivial " names. The European Commission published this inventory on June 1, 1996 (Commission Decision 96/335/EEC). The EU Inventory is intended to provide greater awareness regarding ingredients used in cosmetic products and also to serve as a reference document for common nomenclature for cosmetic ingredient labeling for the EU Member States. " In May of 1995, the CTFA petitioned the FDA regarding harmonization of ingredient labeling names and recognition of the International Cosmetic Ingredient Dictionary Sixth Edition http://www.cfsan.fda.gov/~acrobat/cosltr06.pdf The FDA responded to that they " have not been able to reach a decision on your petition within the first 180 days of filing the petition, because of the limited availability of resources and other agency priorities. Please be assured that your Petition is under active review at the present time, and a more substantial response will be forthcoming as soon as possible " http://www.cfsan.fda.gov/~acrobat/cosltr07.pdf The use of the common name botanical with the Latin name in parenthesis became more noticeable in the 7th edition (ICID-7). The Latin names in parenthesis were optional if the cosmetic was being sold in the USA. A significant changed with the publication of ICID-8. Now the Latin names came first, followed by the " common name " in parenthesis. A comparison of ICID-7 and ICID-8 can be found in the CosmeticInfo files area: http://groups.yahoo.com/group/Cosmeticinfo/files/US_Regs/INCI_Changes.txt In 1995, the CFTA petitioned the FDA to put the Latin name on the outside with the " common name " in parenthesis. http://www.cfsan.fda.gov/~acrobat/cosltr02.pdf The FDA responded http://www.cfsan.fda.gov/~acrobat/cosltr03.pdf by saying that [t]he use of Latin names as the primary identifying term for a plant extract ingredients, with the current common name appearing imbedded in parenthesis, would not be consistent with the FPLA [Fair Packaging and Labeling Act]. The statute requires the use the use of the common or usual name, and there is no way that such requirement can be considered to be met by placement of the recognized common or usual name in parenthesis after the Latin name. Nor is the agency willing to accept the Latin names as common or usual name of such ingredients. Such a change would be confusing to the consumer and would not prevent or facilitate value comparison. " According to the CFTA's VP of Science and editor of the International Cosmetic Ingredient Dictionary, Gerald N. McEwen, Jr. Ph.D., J.D., the CTFA has petitioned the FDA with each introduction of new editions of the International Cosmetic Ingredient Dictionary. I have been able to find copies of these petitions online nor have I been able to find any FDA response to a CTFA petition that says that ICID-7, ICID-8 or ICID-9 have been formally denied by the CTFA. I see no reason why Dr. McEwen should lie to me or why the CFTA wouldn't petition the FDA with the introduction of new volumes of the International Cosmetic Ingredient Dictionary. In my conversation with Dr. McEwen, he said that he was unaware of any cosmetic company ever being " pick up " by the FDA for improper labeling only. Use whichever edition that makes sense to you and your marketplace. Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 4, 2003 Report Share Posted April 4, 2003 >Use whichever edition that makes sense to you and your marketplace. As an addendum, the FDA also states that the " CTFA Cosmetic Ingredient Dictionary, Ninth Edition, (2002) " " [p]rovides a common nomenclature for use in preparing ingredient labels and in disclosing product trade and chemical names are cross-referenced to CTFA adopted names. " http://www.cfsan.fda.gov/~dms/industry.html Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
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