The Fundamental Principle: Descending Order of Predominance
At the heart of most ingredient labeling regulations, particularly for food products, is the rule of descending order of predominance by weight. This principle dictates that the ingredient used in the largest amount during the manufacturing process must be listed first. Subsequent ingredients follow in order, with the ingredient present in the smallest quantity appearing last. This provides consumers with an immediate understanding of the product's primary composition.
For example, a list starting "Potatoes, vegetable oil, salt" means potatoes are the main component. This rule applies to all ingredients, including additives.
How to Handle Compound Ingredients
A compound ingredient, like chocolate chips, requires its sub-ingredients to be declared in parentheses, also by descending order of predominance. Example: "Chocolate chips (sugar, chocolate liquor...)". Some regions have exceptions for small percentages, but allergens must always be declared.
Mandatory Allergen Declarations
Allergen labeling is critical for consumer safety. Regulatory bodies like the FDA mandate clear declaration of major allergens.
Lists vary by region, but the US requires disclosure of the “Big 9”: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame.
Highlighting Allergens for Visibility
Allergens must be emphasized within the list, often through bolding.
The "Contains" Statement and Precautionary Labels
A "Contains" statement after the list summarizes allergens. Precautionary statements like "May contain..." are used for potential cross-contamination risks but don't replace good manufacturing practices.
Comparison of Food vs. Cosmetic Labeling
Food and cosmetic labeling differ significantly in rules and terminology.
| Feature | Food Labeling | Cosmetic Labeling |
|---|---|---|
| Ordering | Descending order by weight. | Descending order for ingredients over 1%; others and color additives can be in any order at the end. |
| Nomenclature | Common names (e.g., "sugar"). Compound ingredients list sub-ingredients. | International Nomenclature of Cosmetic Ingredients (INCI) system (e.g., Aqua). |
| Required Panel | Nutrition Facts panel. | Supplement Facts panel for dietary supplements. |
| Allergens | Major allergens listed and emphasized. | Fragrance allergens listed. MoCRA introduced specific requirements in the US. |
Specific Regulatory Requirements for Other Product Types
Dietary Supplement Labeling
Dietary supplements use a "Supplement Facts" panel. Dietary ingredients with established daily values are grouped, others listed below. Serving size and quantities are included. A domestic contact for adverse events is required.
Cosmetic Labeling (INCI Nomenclature)
Cosmetics use the global INCI system. Ingredients, except color additives and those under 1%, are in descending order. Those under 1% and color additives can be listed last in any order. The list must be available at point of sale. The FDA provides guidance.
Other Important Labeling Considerations
- Legibility: Text must be prominent and easy to read, with minimum font sizes in some regions.
- Clarity: Common names are used, unless following the INCI standard.
- Placement: The list is typically on the information panel with other key details.
- Additives: Food additives are declared, often with their functional class.
Conclusion
Adhering to ingredient listing rules is vital for manufacturers. While the descending order by weight is a core principle for food, specific rules for allergens, compound ingredients, cosmetics, and dietary supplements add complexity. Compliance ensures consumer safety, prevents misleading information, and builds trust. Clarity, accuracy, and regulatory compliance are essential for packaged products.
