This English document was not actually used for guideline and just for translation of original
JCIA guideline.
February 1, 2018
To members of Japan Cosmetic Industry Association

The Natural/organic cosmetic subcommittee of the Distribution Committee,
Japan Cosmetic Industry Association (JCIA)

Q&A about guideline on labelling of Natural and Organic Contents for Cosmetics
According to ISO 16128
A document, “Guideline on Labelling of Natural, Natural-origin, Organic and Organic-origin
contents According to ISO 16128” was established by JCIA on February 1, 2018. We, JCIA, alsoestablished the following Q&A to help our members follow the guideline.
We appreciate your understanding of the guideline mentioned above as well as implementing theappropriate label in accordance with the Pharmaceuticals and Medical Devices Act, the Act against
Unjustifiable Premiums and Misleading Representations, the Standards for Fair Advertising
Practices of Drugs, Quasi-drugs, Cosmetics and Medical Devices , the Codes of Fair Competition
with Respect to the Representations of Cosmetics, and the guidelines for fair advertising practices ofcosmetics.

Q1: Is the label of the content on product compulsory?
A1: No. The label of the content is voluntary. You can label the content if you would like to do so.

Q2: Where should the content be labeled on a product?
A2: The place of label on a product is not provided by the guideline. Please make your decision
based on your own corporate responsibility.

Q3: What should be the size of the letters used to label the content?
A3: The size of the letters used to label the content is not provided by the guideline. Please makeyour decision based on your own corporate responsibility.
It should be noted that you might have consumers misunderstand the contents, if you emphasize
words such as “natural” and “organic” and figures of the content by, for example, increasing the sizeor changing the color of the letters, as compared to other labels.

Q4: When we show the content of a product in percentage form, how should we round the digit
number of figures? For example, can we round off the first decimal place of the digit number
and label it in an integer?
A4: ISO 16128 does not provide the digit number of figures of the content and by what method theyshould be rounded off. JCIA also does not provide them in our guideline, to avoid Japaneseindividual rule which possibly induces a disagreement with foreign-made products. Please makeyour decision based on your own corporate responsibility.
Although it is acceptable to label the content in integers, you should make efforts to avoid providing
misleading labels to consumers when you round off the number (e.g., rounding off 99.5% to 100%can mislead consumers).
Q5: We want to label “derived plant ingredients XX%” on our products. In this case, should
we follow ISO 16128 in the calculation procedure?
A5: ISO 16128 does not contain labels about derived plant ingredients. Please make your decision
based on your own corporate responsibility while taking into account the relevant laws andguidelines for fair advertising practices of cosmetics.
Q6: Is it acceptable to add a phrase such as “The product contains 80% of natural ingredients”
to the label of products with “Natural content 80%” in order to communicate with consumers
in an easy-to-understand manner.
A6: It is acceptable to do so.

Q7: Is it acceptable to claim ingredients with less than 50% natural origin components as“derived natural ingredients”, without any label of content according to ISO 16128?
A7: ISO 16128 and JCIA guideline provide the calculation of the contents and their label on
products, only according to ISO 16128. In case of not according to ISO 16128, please make yourdecision based on your own corporate responsibility while taking into account the relevant laws andguidelines for fair advertising practices of cosmetics. However, such ingredients do not correspondto derived natural ingredients in calculations of natural origin content. You cannot label suchingredients as derived natural ingredients on a product with natural origin content.

Q8: We have imported a plant extract certified as organic by some organization. The organic
plant extract was obtained by using chemically-synthesized butylene glycol as a solvent. Can
we treat this extract as a derived organic ingredient in calculations of organic origin content?
Can we label “containing an organic plant ingredient” on the product containing theingredient?
A8: In calculations of organic origin contents in ISO 16128, an extract that was obtained by using achemically-synthesized solvent cannot be treated as derived organic ingredients even if the extract
was certified as organic.
ISO 16128 and JCIA guideline provide the calculation of the contents and their label on products,
only according to ISO 16128. For labels of “containing derived organic plant ingredients”, please
make your decision based on your own corporate responsibility while taking into account therelevant laws and guidelines for fair advertising practices of cosmetics. However, you cannot label
the extract as “organic plant ingredient” on a product with a label of organic origin content according
to ISO 16128.
Q9: Is it acceptable to use “天然由来指数” (Tennen-yurai shisuu) instead of “自然由来指数”(Shizen-yurai shisuu) to indicate a natural origin content calculated following ISO 16128?
A9: You cannot use “天然由来指数”. Please use a term that JCIA has determined in its guideline
when you label the content according to ISO 16128.
*This question and answer is Japanese language specificQ10: Although free samples are also included within the scope of the guideline, it is difficult tolabel the contents because of limitations of space on samples. How should this be done?
A10: The label of the contents is voluntary, so free samples should not necessarily label the contents,
even if the corresponding products label the contents. It should be noted that when you provide anlabel of the contents on free samples, you cannot provide only the contents without “including orexcluding water”, by the reason of the limited label space.

Q11: Please give specific examples of labels on products.
A11: The guideline shows labeling requirements but do not provide how to label on products. Please
make your decision based on your own corporate responsibility. However, we will provide someexamples just for reference as follows:(Example 1) Natural content 32% (excluding water) ISO 16128(Example 2) Natural origin content 68% (including 52% water) conforming to ISO 16128(Example 3) Natural content 68%
Natural content conforms to ISO 16128 and represents the proportion of naturalingredients in the product. The natural ingredients contain 52% water.
(Example 4) Organic origin content 20% (excluding water) (conforming to ISO 16128)(Example 5) Organic content 32%

The organic content is a figure that shows the proportion of ingredients cultivatedthrough organic farming in the product, and expressed in a manner provided by ISO16128. The calculation of the organic content does not contain water.

(Supplementary explanation for above examples)
For the product with label of “derived natural plant ingredients: 90% or more ” and the phrase “90%or more of this product is made with derived plant ingredients and clean water” in the note, anauthorized nonprofit organization in Japan pointed out such label would possibly induce consumer
misleading. Because general consumers could not have a way of knowing how many percentages of
the “90%” the derived plant ingredients are contained and would receive the impression that theproduct contains much plenty of derived plant ingredients.
The label of the natural/natural origin contents including water, is not exactly similar to theabove-mentioned example. This is why some examples indicating how much water the productcontains are shown here.