Labeling

The ingredient list

On this page10

The basic rule The grouping alternative Why that matters at this scale Fragrance and flavor Allergens are a separate question Prominence is part of the requirement Common or usual names Order is a statement about the formula Write it once, for the range References

The rule that saves a small maker real trouble is that ingredients at 1 percent or less need not be in order.

The basic rule

Each ingredient, by name, in descending order of predominance. For a beard oil that is the carrier oils first, largest to smallest, and the fragrance or essential oils after them.

The grouping alternative

Ingredients other than color additives present above 1 percent in descending order; then ingredients at not more than 1 percent without respect to order; then color additives without respect to order. This is an allowance in the regulation, not a shortcut.

Why that matters at this scale

It means the handful of things dosed at a fraction of a percent, which are exactly the ones whose relative order you are least certain of, do not have to be ranked against each other.

Fragrance and flavor

May be declared as "fragrance" and "flavor" rather than broken out into their components. That is how a proprietary scent blend is handled, and it is in the regulation rather than being an industry habit.

Allergens are a separate question

MoCRA requires FDA to issue regulations on fragrance allergen labeling. Those rules were not final when this page was written, so this is a part of the label worth re-checking rather than setting and forgetting.

Prominence is part of the requirement

The declaration has to be likely to be read and understood by ordinary individuals under normal conditions of purchase. Five point type wrapped around the back of a 30 mL bottle is a compliance question, not just a design one.

Common or usual names

FDA tells small makers to use common or usual names without additional description. The place to be creative is the front panel.

Order is a statement about the formula

Descending order of predominance means the list discloses your formula in outline to anybody who reads it, which is true of every cosmetic on every shelf and is not a reason to get the order wrong. The 1 percent rule is the only latitude the regulation gives, and it is latitude about ordering rather than about disclosure.

Write it once, for the range

Four products sharing a scent share part of an ingredient list. Building those lists together, from the same batch sheet, is how they stay consistent, and inconsistency between two of your own labels is the kind of thing a careful customer notices and a regulator reads as sloppiness.

References

21 CFR 701.3, the cosmetic ingredient declaration: the label "shall bear a declaration of the name of each ingredient in descending order of predominance", with the alternative grouping at (f) allowing ingredients at not more than 1 percent, and color additives, to be listed without respect to order; and at (b) a requirement that the declaration appear with such prominence "as to render it likely to be read and understood by ordinary individuals under normal conditions of purchase". law.cornell.edu

FDA, Small Businesses & Homemade Cosmetics: Fact Sheet. Cosmetics and their ingredients, other than color additives, do not need FDA approval before sale, and the manufacturer is "legally responsible for making sure your cosmetics are safe and properly labeled". Manufacturing at home is not against the law, but the product must not be adulterated by the conditions it is made in. fda.gov

FDA, Modernization of Cosmetics Regulation Act of 2022 (MoCRA). Facility registration renewed every two years; product listing by the responsible person with annual updates; records supporting adequate safety substantiation derived from scientifically robust methods; serious adverse events reported within 15 business days, with new medical information received within one year reported within a further 15 business days. Certain small businesses are exempt from GMP, registration and listing, except for products that contact mucous membranes, are injected, are intended for internal use, or alter appearance for more than 24 hours. fda.gov

Written from the FD&C Act and 21 CFR parts 701 and 740, and from the catalog as it stood on 17 October 2026. Whether a particular product is a cosmetic or a drug turns on its claims and its ingredients, and that determination has consequences; nothing here substitutes for getting it right for a specific formula and a specific label.