Labeling ingredients - Laws regarding ingredient order


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Well-Known Member
Aug 5, 2014
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I know that there is a custom to list ingredients in an order of highest to lowest percentage (I've also seen some products listed alphabetically but don't remember if they were cosmetic) but what I want to know is if this is really LEGALLY required in the US.

Also, if tallow is added, must it be listed as beef tallow, or deer tallow? Since the contents of the soap are no longer tallow, should it be listed as sodium/potassium tallowate? This can also be said for oils as once they are saponified, they are no longer the standard acids within oils.

If a bar is 50% tallow with a 10% SF, then the ingredients would be 50% tallowate and 5% tallow (as 1/2 of the SF content would = 5% and tallow is that 5%).

So is there a US law that requires ingredients to be listed in any specific order?


Well-Known Member
Jun 17, 2014
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Buckeye, Arizona
In a word, yes. It is required you list from highest percentage to lowest, however any item using a very small percent (I believe less than 1 ) can be listed at the end in any order. This includes color and fragrances. Tallow is simply tallow - no matter the animal. Only if you are listing what comes out of the pot do you list as tallowate. Normally you list what went into the pot, not what comes out. This is how you get around not knowing what oil is the superfat as there is no way to be sure with CP soap.

Here is the regulation:

Order of Ingredient Declaration
Descending order of predominance

Active drug ingredients
Ingredients with less than 1% concentration
Color additives
"And other ingredients"

21 CFR 701.3(a), (d), (f) (2), (f) (3)

The ingredients must be listed in descending order of predominance. However, there are a few exceptions to this requirement.

1. If the cosmetic is also a drug, section 502(c) of the FD&C Act requires that the active drug ingredient(s) be declared before declaration of the cosmetic ingredients. A declaration, thus, would read as follows: "Active Ingredient: ... (Name of drug ingredient). Other (or Cosmetic) Ingredients: ... (Names of cosmetic ingredients in descending order)." [§ 701.3(d)]

2. Ingredients present at a concentration not exceeding 1% may be listed in any order after the listing of the ingredients present at more than 1% in descending order of predominance. [§ 701.3(f)(2)]

3. Color additives of any concentration may be listed in any order after the listing of the ingredients which are not color additives [§ 701.3(f)(3)].

4. The name of an ingredient accepted by FDA in accordance with the procedure established in § 720.8 as a trade secret need not be disclosed on the label. In lieu of declaring the name of that ingredient, the phrase "and other ingredients" may be used at the end of the ingredient declaration [§ 701.3(a)].