Cosmetic ingredient label: INCI names and descending order

The ingredient list is the most error-prone part of a cosmetic label. The rule is simple to state — each ingredient by its common or usual name, in descending order of predominance — but the order, the 1% line, color additives, and fragrance each have their own twist.

The governing rule

Cosmetics sold on a retail basis to consumers must declare each ingredient on the label, under 21 CFR 701.3 (a requirement FDA enforces under the Fair Packaging and Labeling Act). Each ingredient is named by its common or usual name, in descending order of predominance — most to least by weight.

What "INCI" means and where it fits

INCI stands for the International Nomenclature of Cosmetic Ingredients, the standardized naming system the industry uses for ingredient labels (for example, Aqua/Water, Butyrospermum Parkii (Shea) Butter, Tocopherol). FDA's rule requires the "common or usual name"; INCI names are the practical, widely accepted way to meet that — they are what you see on virtually every U.S. cosmetic. Use the correct INCI name for each ingredient so the declaration is unambiguous.

Descending order — and the 1% rule

List ingredients from the greatest amount to the least, by weight. There is one important relaxation: ingredients present at 1% or less, and color additives, may be listed in any order after the ingredients present at more than 1%. So you must get the order right for everything above 1%; below that line, order no longer matters.

Source: 21 CFR 701.3 (designation of ingredients); enforced under the Fair Packaging and Labeling Act, 15 U.S.C. 1451 et seq.

Fragrance and flavor

You do not have to break out the components of a fragrance or flavor: 21 CFR 701.3 lets you list them simply as Fragrance or Flavor. Note that MoCRA will eventually require certain fragrance allergens to be named once FDA defines them by regulation — a separate, still-pending requirement. See the MoCRA explainer →

Color additives

Color additives may be listed after the 1%-and-under ingredients, regardless of amount. For products (such as some color cosmetics) made in a range of shades, a single label may list all colors used across the line with a prefix such as May Contain / +/- before the color additives.

Where the ingredient list goes

The ingredient declaration generally appears on an information panel where the consumer can find it at the point of purchase. For very small packages and some mail-order or online sales, FDA recognizes off-pack alternatives (for example, a tag, tape, card, or — for mail order — a website or catalog) so the consumer can still access the list. See how this applies to handmade and small cosmetics →

Common mistakes

• Wrong order above 1%. Everything over 1% must be in true descending order by weight.
• Marketing names instead of INCI. "Shea butter blend" is not an ingredient name; Butyrospermum Parkii (Shea) Butter is.
• Omitting water. If the product contains water, it is an ingredient — usually the first one (Aqua/Water).
• Hiding preservatives. Preservatives (e.g. Phenoxyethanol) must be declared like any other ingredient.

Informational only — not legal advice. Verify against the current governing standard before printing. LabelClear generates text from published rule data and does not guarantee regulatory approval.