Ingredient label order: how the list legally has to read
The ingredient list is where most handmade labels quietly go wrong — not because makers hide anything, but because they copy the recipe in recipe order, use common names, or tuck the colorant wherever it fits. The federal rule (21 CFR 701.3) is strict about exactly three things: the names, the order, and where colorants go.
1. The order: descending predominance
Ingredients are listed in descending order of predominance by weight. Whatever you used most of goes first. For most cold-process soap that's the main oil or water; for a sugar scrub it's Sucrose; for a lotion it's usually Aqua/Water.
2. The ≤1% rule — your flexibility zone
Ingredients present at 1% or less may be listed in any order, as long as they come after everything above 1%. This is why two correct labels for the same recipe can differ: the essential oil at 0.8% and the vitamin E at 0.2% can legally swap places. What you can't do is promote a 0.5% “hero ingredient” up the list.
3. Colorants: always last
Color additives may be listed last, in any order, regardless of amount — Mica, Iron Oxides, Titanium Dioxide belong at the end. They also must be FDA-approved color additives (21 CFR Part 73 / certified colors); botanical powders used “for color” are not on the list, and some approved colorants are still illegal in lip or eye-area products.
4. The names: INCI, not the recipe card
Declare each ingredient by its established name — in practice the INCI name: Butyrospermum Parkii (Shea) Butter, not “shea butter”; Lavandula Angustifolia (Lavender) Oil, not “lavender EO.” Parenthetical common names, as in those examples, are the readable and customary format. A fragrance blend may be declared simply as “Fragrance” (essential oils are declared by their own INCI names).
5. Soap's special choice: “as added” vs. “as made”
Saponified soap may be declared two ways:
- As added: Olive Oil, Water, Sodium Hydroxide, Fragrance, Iron Oxides — yes, the lye is listed, even though none survives saponification;
- As made (resulting compounds): Sodium Olivate, Glycerin, Fragrance, Iron Oxides.
Both are accepted; pick one style and use it consistently. “Saponified oils of olive and coconut” is popular but is neither style — it's tolerated in the market, not what the rule describes.
A worked example
Recipe: olive oil 40%, coconut oil 30%, water 20%, lye 8%, lavender EO 1.5%, mica 0.5%. Correct list (as added):
Olea Europaea (Olive) Fruit Oil, Cocos Nucifera (Coconut) Oil, Water, Sodium Hydroxide, Lavandula Angustifolia (Lavender) Oil, Mica.
The lavender (1.5%) must stay in weight position; the mica goes last as a colorant regardless of amount.
Or let the generator order it for you
The free Inkurate generator is an INCI list generator built on this rule: type your recipe with rough percentages and it converts names to INCI, applies descending order and the ≤1% rule, moves colorants last, handles “Fragrance,” and offers both soap declaration styles — with the regulation cited on every element. Free preview, no signup, and your recipe never leaves your browser.