Canadian labeling: trivial names, botanicals, etc...

[Karri]

I have been studying the following document from Health Canada, specifically Section 6 (Botanical ingr.) and Section 7 (Trivial Names):

http://www.hc-sc.gc.ca/cps-spc/pubs/ind ... ex-eng.php

A few questions have come up for me:

=> Infusions (alkanet/olive oil or green tea/water for example): would these fall under Section 6 for botanicals? I'd love to see an example of how these have been properly incorporated into ingredient lists.

=> I don't see a Trivial Name for cream (from cow's milk)? There is a Trivial Name for goats milk and just milk, but not cream.

Sidebar: the use of "Half n Half" cream gets a little tricky yes? Here in Cda it's 10% milk fat which is less than goats "milk" sooo... maybe it's just milk.

=> Is it true that one shouldn't go "off INCI" and add plain English descriptions in brackets after each ingredient? (It doesn't explicitly say DO NOT DO THIS except in the case of Trivial Names where there are very very specific rules.

To my mind, just stick with INCI and forget everything else in order to keep things simple. That said, I see this practice (of putting the plain English phrase in brackets) on I dunno, most of my toiletries? (I'm in Canada).

=> The same Health Canada site also says one can have a "consultant" from the CCTFA conduct a pre-label review. I guess HC thinks this is helpful or?? Has anyone bothered to do this? Most of the members of the CCTFA are big companies who probably have better things to do! (FWIW, membership starts at around $2k/year so I might pass for now. LOL)

Anyone else have these questions or concerns ... or answers to them?

Thanks!
Karri

 

[AmyW]

I'll add another question (I don't know the answers, it's still all greek to me):

Proper INCI labeling is (example):

Sodium Tallowate, other ingredients (list each oil as it's saponified name)

NOT:
Tallow, Sodium Hydroxide, other ingredients

So how do we list Lard? Lard is just.... Lard. I've seen some reference to "Sodium Lardate" but that's not official is it?

And I am not getting the "trivial name" thing. - nevermind, I found it:
http://www.hc-sc.gc.ca/cps-spc/cosmet-p ... ng.php#a25

 

[Lindy]

Here is how I understand to do it:

=> Infusions (alkanet/olive oil or green tea/water for example): would these fall under Section 6 for botanicals? I'd love to see an example of how these have been properly incorporated into ingredient lists. The olive oil is still going to become a soap so it would be Sodium Olivate and the alkanet would be listed mus further down your ingredient list as the percentage would indicate and then show the INCI name for it. Break it down to the ingredients. The only exceptions I've found are the preservatives where you list it as xxxx (and) yyyy (and) aaaa and then that is in a lotion rather than soap since you're not using preservatives in soap.

=> I don't see a Trivial Name for cream (from cow's milk)? There is a Trivial Name for goats milk and just milk, but not cream. Lac

Sidebar: the use of "Half n Half" cream gets a little tricky yes? Here in Cda it's 10% milk fat which is less than goats "milk" sooo... maybe it's just milk. Goat Milk is Caprae Lac

=> Is it true that one shouldn't go "off INCI" and add plain English descriptions in brackets after each ingredient? (It doesn't explicitly say DO NOT DO THIS except in the case of Trivial Names where there are very very specific rules.

To my mind, just stick with INCI and forget everything else in order to keep things simple. That said, I see this practice (of putting the plain English phrase in brackets) on I dunno, most of my toiletries? (I'm in Canada).

Stick to INCI as much as you can. If you list the english names then you must list french as well.


Lard is Sodium Lardate......

Hope this helps. I can't even begin to imagine me being able to afford a consultant @ $2K to do the wording on my label. Perhaps I should offer my services for half that?

 

[AmyW]

Wow, so much to take in. Thank you Lindy, you're such a big help

 

[Lindy]

Amy it looks so much more intimidating than it really is. Once you start doing it you will find it becomes second nature. The government really doesn't get intrusive and I like that they have made it easy to comply.

I'm glad to help because I know how intimidating it can be when you're just learning the ropes here.

 

[Karri]

Thanks Lindy!

So I suppose at some point the soap maker has to make some assumptions around the actual concentration of the botanical/infused ingredient? This is where I think it gets a little dicey ... though if we can safely assume a concentration of 1% or less than we're safe to put it at the END of the ingredient list, per this section of the guidelines (thinking out loud here):

9. Ingredients Less than 1% Concentration--section 21.4(2)

Ingredients at a concentration less than 1%, and colouring agents may be listed in random order after the ingredients present at greater than 1%. Flavouring and fragrance agents in products at levels greater than 1% may be listed as "aroma" and "parfum" at the end of the ingredient list, or can be placed in descending order of concentration.

Re trivial names: I still don't see anything for cream (fr. cow's milk). Or is that just listed as milk??

Also re trivial names: I'm realizing it would probably be wise to pick one method (the EU trivial name OR french/english trivial name) and then use that for all ingredient lists. Rather than flip flopping between the different methods.

Re pre-label reviews from a consultant at the CCTFA: to be clear, HC doesn't say you have to be a member in order to snag one of their "consultants" but when I scanned their member list I didn't exactly feel encouraged. These are what appear to mostly be big businesses serving big businesses or serving those with more complex business models.

Moreover, I'm not sure why I would pay $2k for a membership when the benefits to SMALL business aren't that obvious ... specifically the handmade soaper.

This is why we NEED people like you Lindy! Of all the forums and online networking I've participated in so far, you're literally the only Canuck who has stepped forward with advice.

We need the equivalent of a Guild here in Canada so badly. I consider myself a very smart person with enough drive to find answers to my questions any way I can. Yet I've never felt so intimidated as with this venture ... when I started my consulting business years ago now, it wasn't NEARLY this complex. Though I do expect some complexity of course when offering a consumer good ... different kinds of risk involved, but learning how to make great soap is only one piece of the puzzle.

FWIW I've started making my own labels, even just for the soap I'm giving away to friends and family. Just to get the hang of it and see where my knowledge gaps are. This has made a big difference in my confidence levels.

But yes, you probably COULD charge a pretty penny or two for some consulting Lindy :wink:

Karri

 

[Lindy]

Aw thank you Kerri.

Milk is one of those that is the devils own to find the INCI for because a lot just list it as Milk. I would love to buy the book itself for all the INCI listings but it's a couple of thousand dollars.

I know when I first started out I had a lot of advice being given to me but it was all from our American friends who don't fully understand our (Canadian) system so there really was a lot of research to be done. Trust me when I tell you that it gets easier as you get used to the regs. I'm glad I've been able to help.

Cheers

 

[AmyW]

When sending the government your formulas, is it ok to use "fragrance(parfum)" for soap with FOs but list the EO used for soaps with those? I want a distinction for people looking for avoid lab created fragrances. I think that makes sense?

Oh great, another question, do we have to send a formula for each soap that has a different EO?

Sorry Karri, I hijacked your thread!

Thought of another one: sea salt

I've seen Sodium Chloride and "Sea Salt, Magnesium Carbonate"

 

[Lindy]

Amy - no don't have to send in a new formula for soap when changing the essential oils. When you are labeling your soaps you just use Parfum for your fragrance oils but you need to list each essential oil by the INCI name since they are actives and allergens.

HERE is a great INCI reference site.

Sea Salt = Sodium Cloride but that is from a different location. That's one of the things that makes it so difficult on labeling using INCI.

 

[AmyW]

I think I've got it. You are invaluable Lindy!