Ingredient statements and compliance labels
What a Regulatory Label carries, where the ingredient names come from, which jurisdiction they follow, and — said plainly — what Hi Ellie has and has not checked.
A Regulatory Label is the informational half of a two-label pair: the lot code, the measured net weight, the business details, the warnings, and — for a cosmetic product — the ingredient statement. This article is about where each of those comes from and how far you can lean on them.
It needs a batch
The Regulatory Label has no meaning without a lot. It is anchored to a completed production run — that's what carries the lot code and the measured weight. A generic label doesn't get one. That's why Label Studio asks you to pick a batch before anything else.
Which products get an ingredient statement
Not all of them, and the difference is legal rather than technical:
| Product | Ingredient statement? |
|---|---|
Cosmetic-classed Bath & Body (a Melt & Pour base classed cosmetic, a lotion) | Yes |
| A true soap bar — cold process, hot process, liquid | No — an FTC-exempt soap carries none |
| Candle | No |
| Resin | No |
A from-scratch bar is always classed as soap by the app, derived server-side rather than chosen, so it correctly carries no statement. If you see none where you expected one, that's usually why.
Where the names come from
The statement is assembled live from what your pantry holds — never frozen at the moment the run completed, so fixing a pantry row fixes the label:
- Your M&P base's INCI list, copied word for word from your supplier's published list.
- Essential-oil INCI names and bath-additive INCI, from your own shelf rows.
- A fragrance's EU Annex III allergen breakout, parented under a
PARFUMtoken — but only where a real supplier document was extracted at high confidence. - Colorant INCI names, from your own shelf rows — copied there from the catalog when you added the colorant.
Most catalog colorants now carry an INCI statement: 741 of the 754 soap-applicable catalog rows. The 13 that don't each have a known reason, and none of them is filled with a partial or guessed list. Eight disclose strontium aluminate, which the EU CosIng inventory snapshot we take names from does not contain. One lists a "D&C Red" with no number — a family of dyes, not one dye. On three, the supplier's own documents disagree about what is in the product: Sunfire Violet (its safety data sheet and its product page list different ingredients, and the sheet prints one ingredient beside another's identifier), Fire Orange (its sheet lists an iron oxide and a Yellow 5 dye that its product page does not, and the supplier's ingredient workbook has no entry for it) and Ora Gold (its sheet lists tin oxide where its product page and the supplier's ingredient workbook both list titanium dioxide). And for one product the supplier states no ingredient list at all. Whether a colorant's names are the supplier's own published list, as they state it, or names checked against the EU CosIng inventory varies from product to product — with one exception, IRON OXIDES, described under the jurisdiction wrinkle below. Proofread your colorant names especially. The app's own colorant map is explicit that this is regulatory label copy: every value it holds "is printed on a cosmetic ingredient statement and read by a consumer who may have an allergy or a pigment sensitivity."
Fragrance INCI is still out of scope — no catalog source exists for that shelf yet, beyond the allergen breakout above.
The ordering, and who did it
The app is precise about this, and worth quoting:
"Inside your melt-and-pour base, the order is your supplier's own — we print their list as they supply it. Where we do order things ourselves (a blend of two bases, and the essential oils on top of them) we sort by descending predominance, the US convention for a cosmetic ingredient declaration (21 CFR 701.3). Bath add-ins, colorants and fragrance sit at the end, without a predominance claim."
In other words: on the common single-base recipe, Hi Ellie ordered nothing — your supplier did. It says so rather than taking credit for a sort that never ran.
The jurisdiction wrinkle
The Regulatory Label targets the US. But the identity vocabulary is mixed, and the app discloses that instead of quietly patching it:
"Your melt-and-pour base contributes its supplier’s own published INCI list, copied word for word. The essential-oil, bath-additive and fragrance-allergen names come from the EU Commission’s CosIng inventory. A colorant name copied from our catalog is one of two things, and which one varies from product to product: the supplier’s own published list, as they state it, or a name from the CosIng inventory. On some Eye Candy micas the name IRON OXIDES is neither — it is the US colour-additive listing name (21 CFR 73.2250), which we chose because the supplier names an iron oxide without saying which one; the EU inventory names each iron oxide by its own Colour Index number and has no collective name. A US declaration draws its names from a different set of references (21 CFR 701.3(c)), which does not include CosIng. Most names are identical either way — a few are not."
The editor scans for three known naming differences — Aqua vs Water, Parfum vs Fragrance, and Colour Index numbers in place of a US listing name — plus two things a supplier's list can carry through. IRON OXIDES is not one of them: it is already the US listing name, so the scan has nothing to flag and the paragraph above is where it is disclosed. And the editor is explicit about the size of that check:
"That is the set we have verified — not a name-by-name review of the whole statement, so finding none of them is one check passing rather than a clean bill of health."
What the statement is not
It is not an exhaustive composition. A shelf row with no stored INCI copy contributes nothing — not a placeholder, not a guess. An allergen is disclosed only where a supplier document was actually extracted, which means a soap scented with an essential oil discloses no allergens while one scented with a documented fragrance does. That asymmetry is honest: the app has a document for one and not the other, and deriving allergens from a botanical's known chemistry is something it deliberately will not do.
The footer says the important part: "Read this statement against your supplier's own documentation before you print. Hi Ellie assembles this statement from what your pantry holds; it does not review or certify a label."
Compliance is yours. What Hi Ellie does is assemble, order where it legitimately can, and tell you exactly which parts of that it has and hasn't checked.
Bath & Body's regulatory slots today
On the Label Studio compliance panel, a Bath & Body label shows Net weight / contents, Regulatory warning and Ingredient / fragrance line as awaiting — "cosmetic labeling — coming soon". The ingredient statement described above renders in the label editor's Regulatory tab where a run's recipe resolves as cosmetic; the Studio's own panel is conservative about promising the full slot set until the rest of it lands.