Cosmetic ingredient list order: what position tells you

The main rule: most to least

EU law says the list "shall be established in descending order of weight of the ingredients at the time they are added to the cosmetic product", and that it starts with the word Ingredients.¹ US rules ask for the same thing in different words: each ingredient in "descending order of predominance".²

So the first names are the largest ingredients by weight. In a cream or a shampoo that is often water, followed by the ingredients that form its base. Impurities in raw materials, and processing aids that do not remain in the finished product, are not counted as ingredients at all.¹

The 1% exception

In the EU, "ingredients in concentrations of less than 1 % may be listed in any order after those in concentrations of more than 1 %".¹ The US rule allows the same grouping: ingredients above 1% in descending order, then those at 1% or less in any order, then colour additives in any order.²

The label does not mark where the 1% line falls. Everything after it is small, but in no particular order, so a name in tenth place can be present at more than the name in eighth.

There is one clue in EU products. Some ingredients have a legal maximum: Phenoxyethanol, a common preservative, is allowed at up to 1.0%.³ Because anything above 1% must come before anything below it, names listed after phenoxyethanol are, in practice, at or below about 1%. It tells you nothing about how far below.

An example from the FDA

The FDA's labelling guide shows a pressed powder with its amounts, and two lists that are both correct for it.⁴ This is the second, using the grouping rule. Read it the way most of us read a label and you would guess that Titanium Dioxide, ninth, is a trace.

Titanium Dioxide, in ninth place, is as large as Zinc Stearate in third. Lanolin, in fifth, is at 0.2%, less than Isopropyl Myristate and Lanolin Oil listed after it. The FDA notes that the amounts are not required on the label; it prints them only to explain the rule.⁴

Colourants and shade ranges

In the EU, colourants other than hair dyes may be listed in any order after the other ingredients, named by their Colour Index (CI) number where one applies.¹ A make-up range sold in several shades may print every colourant used across the range after the words may contain or the symbol +/-.¹ So a CI number after +/- may not be in the shade you are holding.

US labels have a similar "may contain" for colour additives in shaded products that share one list, and for colours added to some batches only, to match the shade.²⁴

Other things that move names around

• Scent counts as one entry. Parfum or Fragrance takes one place in the list, however many substances the mixture contains.¹⁴ In the EU, certain fragrance allergens must be named as well, once they pass 0.001% in a leave-on or 0.01% in a rinse-off product, levels far below the 1% line.⁵
• US drug-cosmetics list actives first. If a US product is also a drug, its active ingredients are declared before the cosmetic ones.⁴
• Trade secrets, in the US. An ingredient the FDA accepts as a trade secret can be replaced by the words "and other ingredients" at the end of the list.²
• Nanomaterials, in the EU. An ingredient present as a nanomaterial is followed by the word (nano).¹

What to look for on the label

• The first few names are the base of the product. Two products that share them are built on a similar base.
• An ingredient a product is sold on that appears near the top is likely present above 1%. Near the end, it may be at any level up to about 1%, and the list cannot say which.
• Names after an ingredient with a 1% cap, such as phenoxyethanol, are small in EU products.
• Colourants at the end, whether CI numbers or names, say nothing about amount: in the FDA's example, Titanium Dioxide makes up 5% of the powder.⁴
• A percentage on the front of a pack is the brand's own statement. The ingredient list carries none.

The ingredient checker keeps each name in the order the label gives it and shows what it does, but it cannot recover amounts the label does not state. For what the names themselves mean, see What is INCI?.