On November 11, 2025, the European Commission published a Corrigendum to the Commission Regulation (EU) 2023/1545. Cosmetics Europe has published an explanatory note which is available below.
The Regulation (EU) 2023/1545 uses the chemical name, in addition to the INCI name, to identify the regulated substance. A chemical name should be considered broader than the INCI name itself, as it may encompass multiple INCI names that are not explicitly listed in the respective column. While this does not create interpretation issues within the EU, this corrigendum has been introduced in order to provide greater clarity for stakeholders outside Europe.
For instance, Entry 364, which refers to the chemical name ‘Pelargonium graveolens oil’, should be interpreted as encompassing the INCI names ‘Pelargonium Graveolens Flower Oil, Pelargonium Graveolens Leaf Oil, and Pelargonium Graveolens Oil under column’ (c) of that entry. A similar situation applies to the INCI name ‘Pogostemon Cablin Leaf Oil’.
In the EU corrigendum, despite adding the INCI names in the columns, it does not go as far as formally introducing a Grouping Name (GN) of entries concerned. This discrepancy could lead to confusion and varying interpretations are possible. The CE explanatory note aims to give members instruction on the possible labelling approach when the labelling threshold is exceeded.
For Canada, all the INCI names are already captured in Appendix 1 of the labelling guide as reflected in the EU Corrigendum.
