FDA labeling regulations require that ingredients must be listed in descending order of predominance. However, there are a few exceptions to this requirement.
  • 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)]
  • 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)]
  • 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)].
  • 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)].
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