What Law Requires Products to Include a List of All Ingredients?

October 27, 2025 •

3 min read

Did you know that no single law requires a list of all ingredients for every product category? A complex web of federal regulations, like the FD&C Act and FPLA, determines what law requires products to include a list of all ingredients, depending on whether it's food, cosmetics, or another consumer item.

Quick Summary

Ingredient disclosure is mandated not by a single law but by several federal regulations specific to product categories. Laws enforced by the FDA, FTC, and CPSC dictate labeling rules for everything from food and cosmetics to children's products.

Key Points

No Single Law: Ingredient disclosure is mandated by various federal acts, not one universal law covering all product types.
FDA's Role: The FDA regulates labeling for food, drugs, and cosmetics under the FD&C Act, enforcing specific ingredient listing rules.
Food Regulations: For food, the NLEA and FALCPA amend the FD&C Act, requiring specific formats for nutrition facts and mandating major allergen declarations.
Cosmetic Rules: Cosmetic labeling is covered by the FPLA and, more recently, the Modernization of Cosmetics Regulation Act (MoCRA), which strengthens requirements for transparency.
Children's Product Safety: The CPSIA, enforced by the CPSC, mandates tracking and content restrictions (like lead and phthalates) for children's items.
Ingredient Order: Ingredients on both food and cosmetic labels are typically listed in descending order by weight, providing a clear indication of their quantity.
Truth in Labeling: The overarching principle of "truth in labeling" ensures all claims and information on product packaging are accurate and not misleading.

Navigating the world of product labeling can be confusing, but understanding the foundational laws behind ingredient disclosure empowers consumers and ensures manufacturer compliance. There is no single universal law, but rather a set of regulations enforced by different government agencies, primarily the Food and Drug Administration (FDA) and the Federal Trade Commission (FTC).

Food Labeling: The FD&C Act and NLEA

For food products, the primary legislation requiring ingredient lists is the Federal Food, Drug, and Cosmetic (FD&C) Act. This act, dating back to 1938, gives the FDA authority over the safety and labeling of food, drugs, and cosmetics. A significant update came with the Nutrition Labeling and Education Act (NLEA) of 1990, which standardized the format and content of nutrition information and ingredient lists on most packaged foods. Key provisions under these laws include:

Ingredient List: Requires a complete list of all ingredients by their common or usual name.
Descending Order: Ingredients must be listed in descending order of predominance by weight.
Major Allergens: The Food Allergen Labeling and Consumer Protection Act (FALCPA) mandates that food labels clearly state the presence of the nine major food allergens (milk, egg, fish, shellfish, tree nuts, wheat, peanuts, soybeans, and sesame).

The Impact of Food Labeling Regulations

Accurate and comprehensive food labeling has a direct impact on public health. For individuals with allergies, an ingredient list can be a life-saving tool. For the general consumer, it offers transparency about what is in their food, enabling them to make healthier choices and avoid unwanted additives.

Cosmetic and Household Product Regulations

Ingredient labeling for cosmetics is governed by a combination of the FD&C Act and the Fair Packaging and Labeling Act (FPLA). The FPLA requires cosmetics and many household goods to list their ingredients on the product or packaging. A more recent and powerful piece of legislation is the Modernization of Cosmetics Regulation Act (MoCRA) of 2022, which strengthened the FDA's authority over cosmetics and introduced new labeling requirements, such as including a U.S. contact for adverse event reports.

INCI System: For cosmetics, many countries follow the International Nomenclature of Cosmetic Ingredients (INCI) system, which provides standardized names for ingredients. The U.S. generally requires common or usual English names but recognizes the INCI system for consistency.
Fragrance Disclosure: A notable point is that fragrances and flavors can often be listed simply as "fragrance" or "flavor," rather than detailing every chemical component. However, MoCRA indicates a move toward greater transparency regarding fragrance allergens.

Children's Product Safety

For products designed for children 12 or younger, an additional layer of regulation comes from the Consumer Product Safety Improvement Act (CPSIA), enforced by the Consumer Product Safety Commission (CPSC). While not strictly an ingredient labeling law in the same way as for food or cosmetics, CPSIA mandates comprehensive tracking labels to facilitate recalls and ensures products do not contain hazardous substances like specific phthalates or lead.

Comparing Key Labeling Requirements by Product Type


Feature	Food	Cosmetics	Children's Products
Primary Governing Law	FD&C Act, NLEA, FALCPA	FD&C Act, FPLA, MoCRA	CPSIA
Enforcement Agency	Food and Drug Administration (FDA)	Food and Drug Administration (FDA)	Consumer Product Safety Commission (CPSC)
Ingredient Listing Rule	Descending order of predominance by weight	Descending order of predominance; less than 1% can be in any order	Not ingredient list, but chemical content restrictions and tracking labels
Special Disclosure	Major allergens, nutritional information	May need to disclose certain fragrance allergens (emerging)	Restrictions on lead, phthalates, and other hazards

Conclusion

In the U.S., the requirement for a product to list all its ingredients is not covered by a single, blanket law but is instead a function of the specific product category. The FDA, FTC, and CPSC all play roles in regulating different types of consumer goods, ensuring that food, cosmetics, and children's products meet distinct labeling standards designed for consumer safety and transparency. For detailed information on specific regulations, consulting the relevant agency website is the best course of action. For example, the FDA's website offers comprehensive guidance on labeling requirements for various products FDA Regulations.

Frequently Asked Questions

The ingredient labeling for food products is primarily governed by the Federal Food, Drug, and Cosmetic (FD&C) Act, with additional requirements set by the Nutrition Labeling and Education Act (NLEA) and the Food Allergen Labeling and Consumer Protection Act (FALCPA).

The Fair Packaging and Labeling Act (FPLA) and the Federal Food, Drug, and Cosmetic (FD&C) Act require cosmetic products to list their ingredients. The newer Modernization of Cosmetics Regulation Act (MoCRA) further enhances these regulations.

Yes, ingredients for both food and cosmetics must generally be listed in descending order of predominance by weight. This means the ingredient that makes up the largest proportion of the product is listed first.

The Food Allergen Labeling and Consumer Protection Act (FALCPA) is crucial for protecting consumers with food allergies by requiring food labels to clearly identify the presence of major food allergens.

The Food and Drug Administration (FDA) is the government agency responsible for overseeing and enforcing labeling requirements for cosmetics.

No, the specific laws and regulations for ingredient disclosure vary significantly depending on the product category. While food and cosmetics have specific rules, other consumer goods may have different labeling standards governed by agencies like the CPSC or FTC.

MoCRA is a law enacted in 2022 that gives the FDA new authorities over cosmetic products. It introduces stricter labeling requirements and modernizes the regulatory framework for cosmetics in the U.S..