In 2013, cosmetics containing Siberian sturgeon caviar were at the centre of a US guilty plea: they had been imported without the required wildlife permits. Even in a beauty product, sturgeon roe can carry obligations that reach far beyond the bathroom shelf.
What reaches the skin, however, is a processed ingredient. The European Commission’s CosIng inventory defines Caviar Extract as an extract of sturgeon eggs. The name promises neither whole roe in the finished cream nor a particular amount. For the broader picture, see caviar in beauty.
What caviar extract means
Caviar Extract starts with sturgeon eggs. CosIng identifies the fish as members of the family Acipenseridae, distinguishing this ingredient from other roe extracts and plants with caviar-inspired names.
INCI stands for International Nomenclature of Cosmetic Ingredients, the naming system used to identify ingredients on cosmetic labels. It helps distinguish one material from another; it does not certify origin or performance.
The related CosIng entry Hydrolyzed Caviar Extract describes material obtained by acid, enzyme or another method of hydrolysis. That process breaks larger molecules into smaller components.
Salmon roe has its own identity: Salmo Ovum Extract is defined as an extract of salmon eggs. Publicity calling it “caviar” does not make it interchangeable with the sturgeon-derived ingredient.
Then there is “caviar lime”. Microcitrus Australasica Fruit Extract comes from finger lime fruit, not fish eggs. The caviar connection is the fruit’s bead-like pulp, explored in finger lime and other citrus caviar.
From roe to cosmetic ingredient
The journey from egg to extract can involve grinding, enzymes and freeze-drying. One documented example appears in patent application CN111803434A, which Google Patents records as rejected.
The application describes pretreating roe to reduce colour, odour and sodium, then cleaning and grinding it. Water and enzymes are added before hydrolysis, filtration, centrifugation and freeze-drying. It illustrates a process, rather than a recipe shared by every manufacturer.
Caviar Extract has no single manufacturing recipe specified by its name. To establish how a particular extract was produced and what it contains, consult the raw material supplier’s technical documentation.
The distinction matters: extracted or hydrolysed material is chemically different from intact eggs. The INCI name alone gives no protein content, molecular size or extraction yield.

What the ingredient list tells you
The label will usually name the extract, but leave its percentage unstated. Ingredient order offers a broad guide, not a calculation of caviar content.
In the EU, Regulation (EC) No 1223/2009 requires ingredients to appear in descending order by weight when added. Ingredients below 1% may appear in any order after those above 1%.
Great Britain has the corresponding rule under its amended cosmetics legislation. Northern Ireland follows the EU Cosmetics Regulation under the Windsor Framework. In the US, 21 CFR 701.3 requires ingredients above 1% in descending order, with those at 1% or less allowed in any order afterwards.
A low position therefore reveals no exact concentration. Nor can neighbouring ingredients tell you where the list crosses the 1% threshold.
Effectiveness is a separate question. CosIng is an information resource, not a product endorsement. In the US, facility registration and product listing under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) likewise do not mean FDA approval. For results, turn to the skincare evidence review.
Can a plant product be called caviar?
A plant can lend a cosmetic its caviar name, but the presentation must not misleadingly suggest fish roe. The EU, Great Britain and US provisions checked do not reserve a caviar-specific cosmetic marketing name.
In the EU, Article 20 of Regulation (EC) No 1223/2009 prohibits wording or imagery suggesting characteristics a cosmetic does not have. Regulation (EU) No 655/2013 also requires an ingredient claimed to be present to be deliberately present. Great Britain’s official guidance applies the same central claims principles.
US law treats false or misleading cosmetic labelling as misbranding under the Federal Food, Drug, and Cosmetic Act. With a plant-based product, look at the full presentation: does it clearly identify the plant, or imply fish roe? Food naming rules and customs headings do not settle that cosmetic question.
When wildlife-trade permits apply
Putting sturgeon roe into a cosmetic does not automatically take it outside wildlife-trade controls. Special rules for containers of edible caviar sit alongside wider rules covering listed animals’ parts and derivatives.
The journey from egg to extract can involve grinding, enzymes and freeze-drying.
In the EU, Regulation (EC) No 338/97 defines specimens to include derivatives contained in other goods. Commercial imports of covered sturgeon derivatives generally need EU import permission alongside the appropriate exporting or re-exporting country’s documentation. Exact requirements depend on the listing and transaction.
For Great Britain, GOV.UK explicitly includes beauty products containing caviar extract among goods that may require CITES permits. For Northern Ireland, check the applicable wildlife trade rules and the route’s requirements with the relevant authority.
In the US, 50 CFR 23.71(a) excludes eggs in cosmetics from that section’s definition of caviar. Other wildlife trade rules still apply. International shipments may require CITES documentation or other permits, depending on species and route; check with the US Fish and Wildlife Service.
The guilty plea recorded in a US CITES report, described above, shows the practical stakes. Before sending such products internationally, establish the species, source and route with the relevant wildlife authority. CITES and caviar explains the wider system.

What sourcing claims should tell you
A useful sourcing account follows the eggs back to their origin. The ingredient name alone identifies no farm, harvest method or country of roe origin. Ask for the species, whether the source is farmed or wild, the country where the eggs were produced, and documentation linking the extract to that supply.
“Sustainable”, “responsibly sourced” and “upcycled” need supporting evidence. Without it, treat them as the company’s claims. A useful explanation says what was assessed, who assessed it and whether the claim concerns the fishery or farm, the extraction process or the finished cosmetic.
Apply the same precision to “by-product”. Which existing production process supplies the material? What would otherwise happen to it? Those answers matter: the word alone establishes no conservation or welfare benefit.
Sources
- European Commission. CosIng: Ingredients and Fragrance Inventory, official online database, individual ingredient records checked November 2026. Inventory.
- European Commission. Cosmetic ingredient database, online information page, accessed November 2026. Database description.
- China National Intellectual Property Administration. Preparation method of sturgeon caviar extract, patent application CN111803434A, 2020; published text and English machine translation reproduced by Google Patents. Patent application.
- European Parliament and Council. Regulation (EC) No 1223/2009 on cosmetic products, 2009, particularly Articles 19 to 21 and 33. EUR-Lex record. Read alongside the official implementation guidance below.
- Office for Product Safety and Standards. Regulation 1223/2009 and the Cosmetic Products Enforcement Regulations 2013: Great Britain and Northern Ireland, online guidance, accessed November 2026; Northern Ireland page updated June 2026. Great Britain guidance; Northern Ireland guidance.
- US Food and Drug Administration. Cosmetic Ingredient Names and Cosmetics Labeling Guide, online guidance, accessed November 2026. Ingredient names; labelling guide.
- US Food and Drug Administration. Registration & Listing of Cosmetic Product Facilities and Products, online MoCRA guidance, accessed November 2026. Registration and listing guidance.
- European Commission. Regulation (EU) No 655/2013 laying down common criteria for the justification of claims used in relation to cosmetic products, 2013, Annex, particularly truthfulness. EUR-Lex text.
- US Food and Drug Administration. FDA Authority Over Cosmetics: How Cosmetics Are Not FDA-Approved, but Are FDA-Regulated, online guidance, accessed November 2026. FDA explanation.
- Council of the European Union. Regulation (EC) No 338/97 on the protection of species of wild fauna and flora by regulating trade therein, 1997; consolidation dated 10 August 2013, particularly Articles 2(t) and 4. Legal text.
- UK Government. Bringing food into Great Britain: Check if you need a CITES permit, online guidance, accessed November 2026. CITES guidance including beauty products.
- US Fish and Wildlife Service. 50 CFR 23.71: How can I trade internationally in sturgeon caviar?, online regulatory text reproduced by the Legal Information Institute, accessed November 2026. Section 23.71.
- United States Government. U.S. CITES Implementation Report, reporting period 2013 to 2015, enforcement section, “Caviar Cosmetics Imported in Violation of CITES”. Implementation report.
This piece was researched using ingredient-inventory records, a published manufacturing patent, official cosmetics guidance and wildlife-trade legislation.
Last checked: November 2026

