Most cosmetic labels that fail a compliance check do not fail on claims or warnings. They fail on the ingredient list. INCI list preparation is the least glamorous step in a cosmetic dossier and the one most often left to whoever is building the artwork — which is exactly why trade names, wrong ordering and undeclared fragrance allergens end up printed on 10,000 units.
This guide covers what Article 19 of the EU Cosmetic Regulation actually requires of your ingredient declaration, the five mistakes we see most often, and how to get the list right before it reaches your printer rather than after.
Key takeaways
- Ingredients must be declared using INCI names, in descending order of weight at the time they were added to the formulation.
- Below 1%, ingredients may appear in any order — but only after every ingredient above 1% has been listed in strict descending order.
- Fragrance allergens must be named individually once they pass 0.001% in leave-on or 0.01% in rinse-off products. That list has grown from 26 to over 80.
- Colourants are grouped at the end of the list and expressed as CI numbers, with a “may contain” convention for shade ranges.
- Compound raw materials must be broken down into their constituents — you cannot declare a supplier’s trade name.
- An error here means a reprint, or a market-surveillance finding after launch. It is the cheapest thing in your file to get right.
What the law actually requires
The obligation sits in Article 19(1)(g) of Regulation (EC) No 1223/2009: the list of ingredients must be preceded by the word “Ingredients” and given in descending order of weight at the time the ingredients were added to the cosmetic product. Names must follow the common ingredient nomenclature — in practice, the International Nomenclature of Cosmetic Ingredients, or INCI.
Two phrases in that sentence do most of the work. “At the time they were added” means you order by input weight, not by what survives in the finished product — so water lost during processing is still declared at its input quantity. And “descending order of weight” is not a suggestion; a list that reorders ingredients for marketing reasons, putting a hero botanical near the top, is non-compliant.
Our broader walkthrough of EU cosmetic ingredient labelling covers the legal framing in more depth. What follows is the practical side: where lists actually go wrong.
The five mistakes we see most often
1. Supplier trade names instead of INCI names
A contract manufacturer hands over a formulation sheet listing “Emulgade SE-PF” or “Sepigel 305”. Those are commercial names for blended raw materials, not INCI names. Each has to be resolved into its constituent INCI names, which are then merged into the master list at their individual concentrations. A blend contributing four ingredients at 3% total does not appear once at 3% — it appears as four entries in their correct positions.
2. Ordering by the formulation sheet
Formulation sheets are usually organised by phase — water phase, oil phase, cool-down phase — not by weight. Copying that order onto a label produces a list that is wrong from the second line down.
3. Treating the 1% rule too loosely
The below-1% flexibility is real but narrow. Everything at or above 1% must be in strict descending order first. Only then may the sub-1% ingredients follow in any sequence. Brands frequently push an ingredient up the list on the assumption that “it’s all under 1% anyway” when it is not.
4. Fragrance allergens hidden inside “parfum”
Declaring “Parfum” covers the fragrance compound itself, but individual allergens within it must be named once they exceed the thresholds. This requires the allergen breakdown from your fragrance house — which they will supply if asked, and which brands routinely forget to request. See our guide to the 80+ allergens now requiring declaration and the wider rules on EU cosmetic allergen labelling.
5. Colourants scattered through the list
Colourants are declared at the end, after the other ingredients, expressed as Colour Index numbers. For decorative ranges sold in multiple shades, the “may contain” or “+/-” convention lets a single artwork cover the whole range.
| What the label says | Why it fails | What it should be |
|---|---|---|
| “Emulgade SE-PF” | Supplier trade name, not INCI | Each constituent listed under its own INCI name, at its own concentration |
| Aqua, Rosa Damascena Flower Water, Glycerin… (rose water at 2%) | Ordered for marketing, not by weight | Strict descending order by input weight |
| “Parfum” only, with 0.01% limonene in a leave-on cream | Allergen above the 0.001% leave-on threshold | Parfum, Limonene |
| CI 77491 listed between two actives | Colourants belong at the end | Grouped after other ingredients, or under “may contain” |
| “Vitamin E” | Common name, not INCI | Tocopherol, or Tocopheryl Acetate — whichever you actually used |
Where the ingredient list touches the rest of your dossier
The ingredient declaration is not an isolated labelling task. It is the same data your Safety Assessor works from when preparing your Cosmetic Product Safety Report, and it is one of the first documents requested when you order one — as set out in our list of documents needed to order a CPSR.
It also feeds your Product Information File, your CPNP notification, and any retailer or marketplace compliance check. Marketplaces such as Amazon EU increasingly request ingredient declarations as a listing condition. An inconsistency between the list on your pack, the list in your PIF and the list in your notification is the kind of discrepancy an inspector notices immediately.
Restricted substances: the check that saves reprints
Preparing the list properly means passing every ingredient against the Regulation’s annexes. Annex II prohibits substances outright. Annexes III to VI restrict others by concentration, by product type, or by the population using the product, and several carry mandatory label warnings that must appear alongside the ingredient list.
Getting it right the first time
A compliant ingredient list needs three inputs: your full formulation with percentages, the constituent breakdown for every compound raw material, and the allergen breakdown from your fragrance supplier. With those in hand, preparation is a mechanical exercise — and one worth having done by the same people who will assess the product’s safety, so that the list on your pack and the list in your safety file are identical.
Our INCI List Preparation & Review service does exactly that: nomenclature resolved, order verified, allergens declared against the expanded list, colourants grouped, and any Annex restriction flagged with its limit and required warning. If you want the whole artwork checked rather than just the ingredient line, a Cosmetic Label Review covers claims, warnings, symbols, responsible-person details, batch code and period after opening.
Bringing it all together
The ingredient list is the most scrutinised line on a cosmetic label and the easiest to get wrong, because it looks like a transcription job when it is actually a regulatory one. Order by input weight, resolve every trade name, respect the 1% boundary, declare your fragrance allergens against the current list, group your colourants, and check every ingredient against the annexes before artwork goes to print.
Do that once, properly, and the same list carries cleanly through your CPSR, your PIF and your CPNP notification. Get it wrong and you will meet it again — on a reprint invoice, or in a letter from a market-surveillance authority.
Frequently asked questions
What is an INCI list?
An INCI list is the ingredient declaration on a cosmetic label, written using International Nomenclature of Cosmetic Ingredients names and ordered by descending weight at the time of addition. It is mandatory under Article 19 of Regulation (EC) No 1223/2009 and must be preceded by the word “Ingredients”.
Do ingredients under 1% have to be in order?
No. Once every ingredient at or above 1% has been listed in strict descending order, the remaining sub-1% ingredients may appear in any order. The common mistake is applying that flexibility to ingredients that are actually above 1%.
Can I use my supplier’s trade name on the label?
No. Compound raw materials must be broken down into their constituent INCI names, each positioned according to its own concentration in the finished product. Ask your supplier for the constituent breakdown with percentages — they are expected to provide it.
Which fragrance allergens do I have to name individually?
Any declarable allergen present above 0.001% in a leave-on product or 0.01% in a rinse-off product. Regulation (EU) 2023/1545 expanded that set from 26 substances to more than 80, so artwork written against the old list is already out of date. Our guide to the expanded allergen list explains the transition.
Where does water go in the list?
Water is declared as “Aqua” and, in most emulsions, sits first because it is the largest component by input weight. It is ordered by the quantity added during manufacture, not by what remains after processing losses.
Does a correct ingredient list mean my product is compliant?
No. It satisfies one part of the labelling requirements. You also need a CPSR, a Product Information File, a CPNP notification and an appointed EU Responsible Person before the product can legally be placed on the EU market. See our guide to legally selling cosmetics in the EU.
