Ingredients present at 1% or more must be listed in descending order by weight. Below 1%, any order is permitted. That rule is set out in Article 19 of Regulation (EC) No 1223/2009. Order tells you which side of the 1% line an ingredient falls on; it does not tell you the amount.
To read it, look for a preservative with a fixed legal ceiling below 1%. Phenoxyethanol is the most common. Its maximum permitted concentration is 1.0%, under entry 29 of Annex V to the same regulation. Everything listed before it sits at a higher weight. Everything after it sits at a lower weight, and therefore below 1%.
Here is the mechanism against a real label. The Ordinary Niacinamide 10% + Zinc 1% lists Phenoxyethanol tenth of eleven ingredients. Niacinamide sits second, directly after water, well before it. That position places Niacinamide above 1%. The front of the pack states 10%, so the position and the declared number align.
Phenoxyethanol is not the only marker that works this way. Potassium Sorbate does too, capped at 0.6% under Annex V entry 4, and it gives a tighter threshold than Phenoxyethanol’s 1%. Not every preservative qualifies, though. Sodium Benzoate’s ceiling is split — 0.5% in leave-on products and 2.5% in rinse-off. It only works as a marker once the reader knows which type of product they are holding. In practice that is rarely a gap, since the product itself usually makes that obvious. For the full picture of which markers hold and why, see “What Makes a Concentration Marker Usable”.
The method has one further structural limit. It only estimates a range, not an exact figure, and it says nothing about ingredients formulated to work at trace levels, such as hyaluronic acid or most peptides.
Retinol shows this limit clearly. It is formulated below 1% in every leave-on product, at any strength or price. Under Commission Regulation (EU) 2024/996, EU rules cap it at 0.3% retinol equivalent in leave-on and rinse-off products, and 0.05% in body lotions, effective from 1 November 2025. A retinol serum lists retinol after the Phenoxyethanol marker whether the formula is strong or weak. Position cannot distinguish a strong formula from a weak one. The regulatory cap sets the legal maximum, not what any single product actually contains. That maximum is not printed on the pack, so list position cannot reveal a product’s true retinol concentration.
FG Audit is a tool built on this methodology. To be notified when it opens, join the list below.
