Do you have to list ingredients on products?

October 13, 2025 •

3 min read

According to the U.S. Food and Drug Administration (FDA), the majority of packaged food and cosmetic products require an ingredient list to be visible to the consumer. Manufacturers often wonder, do you have to list ingredients on products, and the short answer is usually yes, but with specific rules that vary by product type and region.

Quick Summary

This article explains the mandatory ingredient labeling requirements for various products, including food, cosmetics, and over-the-counter drugs, covering regulations in the U.S. and E.U. It details key legal obligations, such as descending order of predominance and allergen disclosure, highlighting specific exemptions and considerations for compliance.

Key Points

Legal Mandate: Most packaged products, including food, cosmetics, and drugs, must have an ingredient list due to regulations in the U.S., EU, and other regions.
Order of Predominance: Ingredients must typically be listed in descending order by weight, from most to least prevalent.
Allergen Disclosure: Strict rules require clear and prominent labeling of major allergens to protect consumer health.
Product-Specific Rules: Labeling requirements vary significantly by product type; for example, OTC drugs require a 'Drug Facts' panel, while cosmetics have different formatting standards.
Geographic Differences: Regulations differ between regions, such as the U.S. FDA and the EU's FIC, particularly regarding how allergens are emphasized.
Exemptions: Certain products, like single-ingredient foods or very small packages, may have exemptions from full ingredient listing.

Mandatory Ingredient Labeling for Food Products

Most packaged food products in the United States must list ingredients as required by the FDA. This list should be in descending order by weight, with the most prevalent ingredient listed first. Added water must be included unless lost during processing or an incidental additive.

U.S. regulations also require clear labeling of the 'Big 9' major food allergens: milk, egg, fish, crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame. This can appear in parentheses after the ingredient or in a separate 'Contains' statement.

EU Regulations for Food Ingredient Disclosure

The EU's Food Information to Consumers (FIC) Regulation mandates ingredient lists in descending order of weight. A key difference from the U.S. is the requirement to emphasize allergens within the ingredient list itself, often using bold font. The EU also requires Quantitative Ingredient Declaration (QUID) for ingredients highlighted on the packaging.

Labeling Requirements for Cosmetics and Personal Care Products

Ingredient disclosure is mandatory for cosmetics in both the U.S. and EU to protect consumers. The FDA in the U.S. requires ingredients in cosmetics to be listed on an information panel in descending order of predominance. The Modernization of Cosmetics Regulation Act (MoCRA) has added further labeling requirements, including for fragrance allergens.

Similarly, the EU Cosmetics Regulation requires ingredients to be listed in descending order of weight, with color additives allowed to be listed last. Ingredient information must be easily accessible at the point of sale.

OTC Drugs vs. Dietary Supplements

Over-the-counter (OTC) drugs require a 'Drug Facts' panel with active and inactive ingredients, warnings, and usage instructions. Ingredients are listed by their common name. Dietary supplements, however, use a 'Supplement Facts' panel detailing dietary ingredients and amounts per serving, along with a potential FDA disclaimer for structure/function claims.

Comparison of Ingredient Labeling Requirements


Feature	U.S. (FDA)	E.U. (FIC Regulation)
General Requirement	Ingredients listed in descending order by weight.	Ingredients listed in descending order by weight, by common name.
Allergen Emphasis	Listed in parentheses after the ingredient or in a separate 'Contains' statement.	Must be emphasized within the ingredient list, e.g., using bolding or contrasting colors.
Special Ingredients	Specific rules for collective terms like "flavors" or "spices".	Mandatory QUID (Quantitative Ingredient Declaration) for emphasized ingredients.
Cosmetics	Ingredients listed by common name in descending order. MoCRA requires additional reporting for fragrance allergens.	Ingredients listed by INCI name in descending order. Color additives can be listed last.
Location on Packaging	Generally on an information panel.	Easily visible, legible, and indelible on packaging. For online sales, info must be available pre-purchase.

Exemptions and Common Labeling Mistakes

While most products need ingredient lists, some have exemptions, such as certain single-ingredient foods in the EU or products where water is lost during processing. However, assuming an exemption without research is risky. Common errors include omitting sub-ingredients, incorrect ingredient order, or failing to properly emphasize allergens. Resources from regulatory bodies can assist businesses in navigating these complex rules.

Conclusion: Navigating the Legal Landscape of Ingredient Disclosure

Listing ingredients on products is essential for consumer protection and transparency. Though rules vary by product type and region (U.S., EU), the goal is to provide clear, accurate information to consumers. Non-compliance can lead to penalties and reputational damage. Staying current on regulations, especially concerning allergens and additives, is vital for manufacturers.

Helpful Resources

FDA Food Labeling Guide: https://www.fda.gov/files/food/published/Food-Labeling-Guide-(PDF).pdf
EU Food Information to Consumers Regulation: https://eur-lex.europa.eu/EN/legal-content/summary/labelling-of-foodstuffs.html

Frequently Asked Questions

Yes, some products are exempt. Examples include certain single-ingredient foods like fresh fruit and vegetables, solid sugars, carbonated water, and some types of cheeses and butters. Regulations specify these exemptions carefully, so manufacturers must confirm their product's eligibility.

Ingredients must be listed in descending order of their weight or volume. The ingredient that makes up the largest proportion of the product is listed first, and the rest follow in decreasing order.

Both US and EU laws require major allergens to be declared. In the US, this can be in parentheses next to the ingredient or in a separate 'Contains' statement. The EU requires allergens to be emphasized within the main ingredient list, often with bold lettering.

Yes. Even small-batch and handmade products, if sold to consumers, are generally subject to the same labeling laws as mass-produced goods, especially concerning ingredients and allergens. The specific requirements may depend on the product type and sales channel.

No. Regulations in regions like the US and EU require all ingredients to be listed, even if they are part of a proprietary formula. While specific flavoring or fragrance formulas might have some leeway in how they are described (e.g., as 'natural flavors'), the presence of all ingredients must be disclosed.

Mislabeled products can face serious consequences, including regulatory enforcement, product recalls, fines, and lawsuits. For allergens, mislabeling can cause severe health risks to consumers and result in legal action.

For online sales in the EU, the mandatory ingredient information must be made available to the consumer before the purchase is concluded, typically on the website. The physical product must also be correctly labeled upon delivery.

Additives are considered ingredients and must be listed. In the EU, they must be listed by their functional category (e.g., 'Color') followed by their specific name or E-number. In the US, certified color additives must also be listed by their common name.