The factory sends the final ingredient list, and it is in Japanese. Your designer needs an INCI list for the export label by Friday. Someone runs the Japanese names through a translation tool, the list goes to print, and later your importer finds that two lines do not match the formula documents. The problem is not the translation. Japanese ingredient labelling is its own system, with its own names and its own rules about what is listed and how, and converting it to INCI is a checking job, not a translating job.
This article explains Japan’s full-ingredient labelling rules and gives you a procedure for producing an INCI list you can stand behind.
💬 Sunsho Trade manages own-brand cosmetics made at a GMP-certified partner factory in Japan for brands outside Japan, including the ingredient lists for export labels. Ask us how we prepare and check INCI lists, or see the Japan cosmetics OEM guide.
Japan’s full-ingredient rule and where it came from
Since April 2001 every cosmetic in Japan must list all of its ingredients, using Japanese label names from the industry’s standard name list, in an order set by a 2001 ministry notice.
When the Standards for Cosmetics replaced approvals by product type in April 2001, Japan moved to full-ingredient labelling for all cosmetics. The Ministry of Health, Labour and Welfare issued a notice in 2001 on how to do it. Quasi-drugs are not under the same full-listing obligation; under the industry’s voluntary standard, they list active ingredients and other ingredients separately. If you are unsure which category your product is in, read cosmetic or quasi-drug first.
Separately, Article 61 of the PMD Act requires certain items on the immediate container or wrapping. Among them are the name and address of the marketing authorisation holder, the product name, the batch number or code, ingredient names, and an expiry date where one is required. Confirm the full list against the current text before you rely on it for a Japanese-market label.
Checked against the published texts of the Ministry of Health, Labour and Welfare and the Japan Cosmetic Industry Association on 17 October 2026.
The seven labelling rules that change your list
Seven rules from the 2001 notice decide what appears on a Japanese ingredient list: Japanese names from the JCIA list, descending order, a free-order zone at 1% and below, carry-over, premixes, extracts and fragrance.
| Rule | What the 2001 notice says | Why it matters for an INCI list |
|---|---|---|
| Names | Ingredients are named in Japanese, using the Japan Cosmetic Industry Association’s (JCIA) list of labelling names, to avoid confusion | The Japanese name is not an INCI name; each line needs matching, not translating |
| Order | Descending order of amount | The INCI list should follow the same quantities, so the order is checked against the formula |
| 1% and below, and colourants | Ingredients at 1% or less, and colourants, may be listed in any order among themselves | The Japanese order below 1% tells you nothing about relative amounts |
| Carry-over | Ingredients present at levels where they have no effect need not be listed | Your destination may treat carry-over differently; ask your importer |
| Premixes | Premixed raw materials are listed ingredient by ingredient | One raw material can become several lines |
| Extracts | The extracted substance and the extraction or dilution solvents are listed separately, unless the solvent does not remain in the finished product | Solvents may appear as separate lines, or not at all |
| Fragrance | Ingredients used for fragrance may be listed collectively as “fragrance” (香料) | Your destination may require some fragrance components to be named; ask your importer |
Three of these deserve a closer look.
The free-order zone. Above 1%, the order tells you which ingredient is present in a greater amount. At 1% and below, it does not. A Japanese list may put a minor ingredient before a more plentiful one in that zone. When you build an INCI list, you need the formula percentages to decide the order your destination expects. The Japanese list alone is not enough.
Carry-over. A preservative that came in with a raw material, at a level where it has no effect in the finished product, may be left off a Japanese list. That is allowed by the Japanese notice. Your destination market may have its own view. Your importer should tell you whether carry-over ingredients must appear on your label.
Fragrance. Japan allows “fragrance” as one collective line. Some markets require certain fragrance components to be named on the label. That is a destination rule, not a Japanese one, and the fragrance supplier’s documentation is where the component data comes from.
Japanese label names and INCI are two systems
Japanese label names come from the JCIA’s name list and INCI names come from the international nomenclature; they often correspond, but you cannot assume a one-to-one match, so every line is checked against the raw-material data.
INCI is the naming system most export markets use on cosmetic labels. Japan’s label names are a separate Japanese-language system, maintained through the JCIA’s list. Many ingredients have a clear counterpart in both systems. But the two lists were built for different purposes, and a name in one does not always map neatly onto a single name in the other.
That is why converting the factory’s Japanese list by translation is risky. A translation tool will produce an English word, but not necessarily the INCI name. Two Japanese label names can look alike in translation and be different substances. A botanical extract may need its INCI name built from the plant part and the solvent, which the Japanese line may not show in the same way.
The reliable source is the raw-material data itself. For each raw material, the supplier’s specification normally states the INCI name. Matching each Japanese line back to the raw material, and then to the INCI name the supplier gives, is the check that holds up.
A procedure for a checked export INCI list
Build the INCI list from the frozen formula and the raw-material specifications, use the Japanese label list as a cross-check, apply your destination’s rules with your importer, and freeze the list before artwork.
- Freeze the formula. The ingredient list follows the formula. If the formula is still changing after the check against Japan’s Standards, the list will change too. See checking a formula against the Standards.
- Collect the raw-material data. For each raw material: its INCI name or names, and for premixes and extracts, each component and solvent.
- Break premixes and extracts down. List each component, following the same logic as the Japanese notice, and note whether extraction solvents remain in the finished product.
- Order by amount. Use the formula percentages, not the Japanese list order, for anything at 1% and below.
- Match against the Japanese list. Every line on the Japanese list should have a counterpart on the INCI list, and the reverse. Where they differ, find out why. Usually the reason is a carry-over decision, a fragrance treatment or a premix breakdown.
- Apply destination rules. Ask your importer how the destination handles carry-over, fragrance components, and the order of minor ingredients. Adjust the export list accordingly and record why.
- Review and sign off. One person from the brand and one from the factory side confirm the final list against the formula.
- Freeze and print. Only then does the list go into artwork.
| Document | Who provides it | What it is for |
|---|---|---|
| Final formula with percentages | Factory, shared under agreed terms | The source of truth for order |
| Raw-material specifications with INCI names | Raw-material suppliers, through the factory | The source of truth for names |
| Japanese ingredient list | Factory | Cross-check; Japanese labels if sold in Japan |
| Export INCI list | Built from the above, checked by both sides | The export label |
| Importer’s notes on destination rules | Your importer | Carry-over, fragrance and format decisions |
The same INCI list is often needed in the export documents as well as on the label. That document set is covered in Japan-side export documents and certificates.
💬 Received a Japanese ingredient list and need a checked INCI version for your label? Send us the list and the formula reference and we will arrange the cross-check with the factory.
Where export labels go wrong, and how to prevent it
Most label errors come from changes made after the list was frozen, and from losing track of which version of the list matches which version of the formula.
These are the common patterns:
- Artwork made from an early list. The formula changed after the Standards check, but the designer kept the first list. Keep one version number on the formula and the same version number on the ingredient list.
- A premix supplier changed. A replacement raw material can carry different components. Any raw-material change should trigger a list check.
- Two lists in two languages that do not match. If the product carries both a Japanese list and an INCI list, they must describe the same formula, even if their rules differ.
- Space. A long INCI list in a small font on a small container is a design problem that appears late. Plan label space early. Container and print choices are covered in containers and packaging.
- Labelling done in Japan counts as manufacturing. If export-specific labels or boxes are applied in Japan, that work is manufacturing under Japanese rules and needs a cosmetics manufacturing licence and an export manufacturing notification (輸出用化粧品製造届) filed before manufacture starts. Plan the label content before that filing, not after.
If you also want to sell in Japan, the Japanese label has its own requirements. See importing cosmetics into Japan.
💬 Want the formula check, ingredient lists, labels and export documents handled together in English? See our own-brand OEM service, or tell us about your product.
Frequently asked questions
1. Can I translate the Japanese ingredient list into INCI with a translation tool?
It is risky. Japanese label names come from the JCIA’s name list, and INCI is a separate system. Build the INCI list from the raw-material specifications and use the Japanese list as a cross-check.
2. Why is the order of minor ingredients different between lists?
Japan allows ingredients at 1% or less, and colourants, to be listed in any order among themselves. Use the formula percentages to decide the order your destination expects.
3. Does Japan require each fragrance component to be named?
Under the 2001 notice, ingredients used for fragrance may be listed collectively as “fragrance”. Some destination markets require certain components to be named. Ask your importer and get the data from the fragrance supplier.
4. Do quasi-drugs follow the same ingredient-labelling rule?
No. Quasi-drugs are not under the same full-listing obligation. Under the industry’s voluntary standard, they list active ingredients and other ingredients separately.
5. When should the INCI list be frozen?
After the formula has passed the check against Japan’s Standards and any changes have been agreed, and before artwork is finalised. Any later raw-material or formula change should trigger a new check of the list.