Rising INCI scrutiny leaves consumers short on ingredient context

Eastman's argument that ingredient-scanning apps leave shoppers without context lands at an odd moment for the INCI system itself: the master glossary those apps read from is mid-overhaul, and regulators on both sides of the Atlantic are quietly rewriting what a label is required to say.

The specialty materials company's case, built on a global formulation study unveiled at NYSCC Suppliers' Day in New York in May, is mostly about formulators, not shoppers. Eastman surveyed 150 R&D and formulation professionals across Europe, Asia and the US and found that 85% call sustainability important to their ingredient choices, while only 52% are satisfied with the options available to meet that standard. Eastman frames that gap as a case for multifunctional ingredients that can shorten an INCI list while doing several jobs at once. The framing deserves the obvious caveat: Eastman sells the multifunctional ingredients it says solve the problem.

The INCI list that formulators and scanning apps both work from is being rewritten under them. The European Commission's Implementing Decision (EU) 2025/1175 updated the official INCI glossary with 348 new ingredient entries and renamed a number of existing ones, and companies selling into the EU have until July 30, 2026 to bring labels into line. That deadline is measured in months, meaning some ingredient names a scanning app parses today may already be superseded on shelves by next summer.

The US is moving on a slower, separate track. The Modernization of Cosmetics Regulation Act has pushed the FDA's product-listing database past roughly a million entries, and the agency is expected to propose new fragrance-allergen disclosure rules, reportedly adding on the order of 60 named allergens to labels, up from the 26 currently called out. A notice of proposed rulemaking is anticipated around May 2026, with phased enforcement unlikely to arrive before 2027 or 2028. Canada, the UK, India, New Zealand and South Korea already mandate fragrance-allergen disclosure using overlapping but not identical substance lists, so a product reformulated for one market's allergen rules will not automatically satisfy another's.

That patchwork is the real context gap behind Eastman's complaint, and it predates any scanning app. The INCI naming system, maintained through the International Cosmetic Ingredient Nomenclature Committee, was built so a chemist in one country could recognize an ingredient listed in another, not so a shopper could judge whether it was safe. "Aqua" on a label is a correct answer to that design goal and a useless one to someone standing in a drugstore aisle.

Consumers have not waited for regulators to close that gap; they built their own substitute, and it is now part of the story Eastman is telling. The Environmental Working Group's Skin Deep database is the most widely used consumer tool for translating INCI names into a judgment, but cosmetic chemists and toxicologists have repeatedly criticized its methodology for scoring hazard rather than exposure-adjusted risk. One frequently cited example: Skin Deep has rated 2,6-diaminopyridine favorably even though the EU classifies it as an extreme sensitizer. A tool built to fill the context vacuum can end up adding its own layer of noise on top of it.

None of this means Eastman's underlying point is wrong. A shopper who scans a label and gets back a string of INCI names has learned what is inside a formula without learning why it is there, what it replaced, or what standard it was chosen to meet. The harder question the coverage of Eastman's report leaves unresolved is who is supposed to supply that missing layer. If it is retailers or app developers, they are working against ingredient nomenclature that two major regulatory regimes are actively changing on incompatible calendars. If it is brands themselves, shorter, multifunctional formulations of the kind Eastman sells would reduce the number of names a consumer has to interpret in the first place, but would not change what any single name means.

For now, the clearest thing on a US or EU label by 2027 will not be a plain-language explanation of an ingredient's purpose. It will be a longer, more precisely named allergen disclosure, arriving on a different schedule depending on which country's shelf the product sits on.