What Makes a Concentration Marker Usable

A reference on which preservatives qualify as EU concentration markers — Phenoxyethanol and Potassium Sorbate, and where Sodium Benzoate's split ceiling limits it.

A preservative works as a concentration marker only if two conditions hold: its legal ceiling is a single figure, and that figure sits below 1%. Both matter. A ceiling that varies by product type gives no fixed number to read a label against. A ceiling above 1% marks a point the ordering rule in Article 19 of Regulation (EC) No 1223/2009 has already stopped governing. That rule only fixes order for ingredients at 1% or above.

Phenoxyethanol. One value, 1.0%, applying across all cosmetic product categories, under entry 29 of Annex V. The most common marker, because it appears in a large share of formulas.

Potassium Sorbate. Covered along with sodium sorbate and calcium sorbate under Annex V entry 4, which sets 0.6% expressed as the acid, again across all product categories. A tighter threshold than Phenoxyethanol, useful when a formula lists both.

Sodium Benzoate — conditional. Annex V entry 1 permits 0.5% in leave-on products and 2.5% in rinse-off products. This isn’t a single ceiling, so it works as a marker only once the product type is known — usually obvious from holding the product, but worth stating rather than assuming.

Two markers, one conditional. That’s the current usable set for skincare and personal care formulas under EU rules. See Where Marker-Based Reasoning Depends on Product Type for how the Sodium Benzoate case actually plays out, and for the limits that apply even to a fully usable marker.

Read the full explainer: “How INCI List Position Works”

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