Shampoo bars are rinse-off cosmetics in most major markets, so ingredient disclosure must follow the same INCI-based rules used for liquid shampoos and other cosmetics. The ingredient list should describe the final solid bar, not just the raw materials you started with.
1. Use INCI names, not common names
INCI stands for International Nomenclature of Cosmetic Ingredients. In the US, EU, UK, Canada, and many other regions, you must use INCI names. For example, write Butyrospermum Parkii (Shea) Butter, not “shea butter,” and Sodium Cocoyl Isethionate, not “SCI noodles.” Use the exact INCI name from your supplier’s documentation or an official INCI database.
2. List ingredients in descending order of concentration
Ingredients must appear in descending order by weight in the final bar. Ingredients present at 1% or less can be listed in any order after those present at more than 1%. This is often called the “1% rule.” Color additives may be listed after all other ingredients.
Example syndet shampoo bar ingredient list
Ingredients: Sodium Cocoyl Isethionate, Sodium Coco-Sulfate, Cocamidopropyl Betaine, Cetearyl Alcohol, Butyrospermum Parkii (Shea) Butter, Cocos Nucifera (Coconut) Oil, Glycerin, Stearic Acid, Parfum (Fragrance), Limonene*, Linalool*, CI 77019, CI 77891.
*Allergen component of the fragrance.
3. Label what is actually in the finished bar
This is especially important for shampoo bars made by saponifying oils with lye. Do not list “sodium hydroxide and olive oil” as if they remain as such. List the soap salts that are formed, such as Sodium Olivate, Sodium Cocoate, and Sodium Castorate, along with any unreacted oils or additives. For syndet bars, list the surfactants and conditioning ingredients that remain in the solid product.
Similarly, if you add water as a processing aid and then evaporate most of it, water should not automatically be the first ingredient. Base the order on the final bar composition.
4. Declare fragrance and essential oil allergens
In the EU and UK, rinse-off cosmetics such as shampoo bars must list specific fragrance allergens from Annex III of the Cosmetics Regulation when they are present above 0.01% in the final product. Common examples include Limonene, Linalool, Citral, Geraniol, and Eugenol. The US allows the term “fragrance” to cover fragrance components, but many small brands voluntarily list known allergens.
Essential oils should be listed by their INCI name, such as Lavandula Angustifolia (Lavender) Oil, plus any required allergen constituents. Ask your fragrance or essential oil supplier for an allergen breakdown and calculate the percentage in the finished bar.
5. Apply the 1% rule correctly
After listing ingredients above 1% in descending order, you can list ingredients at 1% or less in any order. That includes many preservatives, chelators, antioxidants, and low-use botanicals. Do not place a 0.2% preservative above a 15% surfactant because it sounds more “active.”
6. Make the ingredient list legible and accessible
The ingredient list should be on the outer packaging or, if there is no outer packaging, on the immediate container or label. Print it in a legible font size. A website or QR code is a helpful extra, but it does not replace the mandatory on-package ingredient disclosure in most markets.
Common shampoo bar labeling mistakes
- Using common or marketing names instead of INCI names.
- Listing the input oils instead of the saponified soap salts in lye-based bars.
- Listing water first when most of it has evaporated.
- Forgetting fragrance allergen declarations in the EU/UK.
- Placing ingredients below 1% in descending order and accidentally implying a different concentration profile.
- Failing to update the label after reformulation.
Always verify your final ingredient list against the current cosmetic labeling regulations in each market where you sell. If you are unsure, have a cosmetic chemist or regulatory consultant review the label before printing.