How to read a cream label: the INCI order, what the law requires and what you will not find there

In Europe, a cosmetic’s ingredients list is not a brand’s gesture of transparency: it is a legal obligation, and it is written to rules you can read. The order is not random, there is an invisible boundary at 1%, fragrances have a regime of their own and some ingredients carry a word in brackets that almost nobody knows how to interpret.

Knowing how to read it is good for two things: for ruling out in the shop what does not suit you, and for realising that the four things that decide whether a cream works are not on the label. Both halves are on this page.

It sits inside the dermocosmetics guide, where the legal definition of a cosmetic and what it can promise are set out. And if what you want is for someone to read the INCI for you, that is exactly what the skincare routine tool does: it classifies each product by its composition, not by its advertising.

What the law requires, letter by letter

Article 19 of the European Cosmetics Regulation lists what has to appear on the pack. Translated into what you see when you turn the box over:

One detail that is misread daily: a product having no expiry date does not mean it is eternal or that the brand forgot it. It means it lasts more than thirty months unopened, and that is why the law asks it instead for the period after opening.

The four rules of the INCI

1. Order holds down to 1%

Ingredients are declared in decreasing order of weight at the time they are added to the product. But there is an exception that changes the reading completely: those at a concentration below 1% may be listed in any order, after those above 1%.

Practical consequence: if the headline active appears in the second half of a long list, it is below 1% and you cannot tell whether it is at 0.9% or 0.01%. And the actives with evidence were tested at specific concentrations — niacinamide at 5%, retinol at 0.3-0.4% — so seeing it at the end is information: not the information we would like, but information.

2. Fragrance is one word

Perfume and aromatic compounds are declared with the terms parfum or aroma, without a breakdown. The exception is the allergens the rules themselves require to be named: those also appear by their own name in the list.

And here there is a recent change worth knowing about, because it is happening right now: until recently there were twenty-four fragrance allergens requiring individual naming. The European scientific committee identified fifty-six more, and the 2023 Regulation brought them in. They are declared when they exceed 0.001% in leave-on products and 0.01% in rinse-off products.

⚠️ We are in the transition period. Products not complying with the new labelling could be placed on the market until 31 July 2026 and can continue to be sold until 31 July 2028. In other words: two different labels are going to sit on the same shelf for two years. If you are allergic to a particular fragrance, a short list does not mean it is absent.

To put it in scale: the Commission itself estimates that between 1% and 9% of the European population is allergic to some fragrance allergen.

3. (nano), in brackets

All ingredients present in nanomaterial form must be clearly indicated, and their name is followed by the term “nano” in brackets. You see it above all in mineral sunscreens: Titanium Dioxide (nano).

It is not a hazard warning: it is a declaration of physical form. A mineral filter in nano form spreads better and leaves less of a white cast, and that is why it is used.

4. The colourants, at the end

Colourants other than hair dyes may be listed in any order after the rest. They are the CI codes followed by five digits. Their being at the end says nothing about their quantity.

The four things that decide the result and that you will not find

This is the part no brand writes on the box, and the reason we do not choose a product at the clinic by reading its label alone:

1. The concentration of the active. Unless the manufacturer declares it voluntarily, it is not there. And it is the first thing that matters.
2. The pH. It is not a compulsory item, and it decides whether an active works: L-ascorbic acid only penetrates when formulated at a pH below 3.5.
3. Stability and packaging. An antioxidant in a jar opened daily, with light and air getting in, degrades. The label does not say whether the formula holds up.
4. What was tested. An ingredient with evidence is not the same as a product with evidence: trials are done with specific formulations, at specific concentrations and in specific populations.

What you can do with a label in your hand

• Rule things out by what you do not want. If your skin does not tolerate exfoliating acids, seeing them in the first half of the list is reason enough to put the bottle down.
• Spot a retinoid. Retinol, Retinal, Retinaldehyde, Hydroxypinacolone Retinoate. And tell them apart from the esters — Retinyl Palmitate, Retinyl Acetate — which go in at antioxidant doses across half the market and are not the same thing.
• See whether fragrance is declared. Parfum in the list means fragrance; its absence means there is none.
• Compare two products of the same kind. Between two moisturisers, the order of the first five or six ingredients says a good deal about the texture and the character of the formula.
• Read the legal warning. If a pack carries the compulsory retinol warning, it contains retinol in a relevant amount.

And what is best not done: judging a formula by the length of the list, or by whether an ingredient has a chemical name. Everything has a chemical name, water included, which in an INCI is called Aqua.

How we read a product

Our tool classifies the shop’s products by reading their ingredients list, not their advertising: that is where it gets whether something counts as a retinoid or as an exfoliating acid, and therefore who it cannot be given to. On top of that reading sit the rules the signatories set product by product, each manufacturer’s official literature and the published evidence.

It is work done once and drawn on every time the tool is used, and it is the reason it can tell you that a product is not right for you.

Frequently asked questions

If an ingredient appears at the end of the list, is it present in a small amount?

It is below 1%, and there is no way of knowing how much: the law allows everything below that threshold to be placed in any order. For actives tested at 5% or 10%, appearing at the end is a relevant fact.

What does the number inside the open jar mean?

The number of months the product stays safe and usable after opening. It is only required of cosmetics whose minimum durability exceeds thirty months; those lasting less carry a best-before date instead.

Is Parfum bad?

It is not a quality category: it is the legal way of declaring fragrance without breaking down the formula. What matters is whether you are allergic to a particular component, and for that the law requires the listed allergens to be named separately — twenty-four until now, eighty with the extension under way.

Can I tell the retinol concentration from the label?

Only if the manufacturer declares it, which is usual in professional dispensing and rare in mass retail. What you do know by law is that in Europe the cap is 0.3% retinol equivalent in a facial product, so no legal cream can contain more.

Are preservatives a problem?

A cosmetic without adequate preservatives is a bigger problem: an emulsion containing water is a medium in which micro-organisms grow. Permitted preservatives are regulated with their maximum concentrations, and their presence in an INCI is a sign that the formula is protected.

And if the product says “hypoallergenic” or “dermatologically tested”?

They are claims, and like all of them they are subject to the European common criteria: they must be truthful, evidenced and allow an informed choice. Neither of the two means you cannot react: they mean tests have been done.

Is it worth using an app to analyse the INCI?

It helps identify ingredients, and there it gets things right. Where it fails is the next step: scoring a formula as “good” or “bad” without knowing the concentration, the pH or the stability, which are precisely the data that are not on the label.

Sources

• Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products. Consolidated text on EUR-Lex. — Article 19.1: nominal content; date of minimum durability with its symbol or the wording “best used before the end of…”, not compulsory where durability exceeds thirty months, in which case the period after opening is indicated with the open-jar symbol; precautions for use; batch number; function of the product; and ingredients list. On the INCI: decreasing order of weight, those at a concentration below 1% may be listed in any order, fragrances as parfum or aroma, nanomaterials with the term “nano” in brackets and colourants in any order at the end. Verified against the consolidated text on 08-09-2026.
• Commission Regulation (EU) 2023/1545 amending Regulation (EC) No 1223/2009 as regards labelling of fragrance allergens in cosmetic products. OJ L 188 of 27.7.2023. EUR-Lex. — Until now there were twenty-four fragrance allergens requiring individual labelling (entries 45 and 67 to 92 of Annex III); the Scientific Committee on Consumer Safety identified fifty-six more, which are brought in with thresholds of 0.001% in leave-on products and 0.01% in rinse-off products. It estimates that between 1% and 9% of the Union’s population is allergic to fragrance allergens. Transition: non-compliant products could be placed on the market until 31 July 2026 and made available until 31 July 2028. Verified against EUR-Lex on 08-09-2026.
• Commission Regulation (EU) 2024/996 (vitamin A, alpha-arbutin, arbutin and other substances). EUR-Lex. — Annex III, entry 376: a cap of 0.3% retinol equivalent in a facial product and 0.05% in a body lotion, with a compulsory warning on the pack. It is an example of a figure that does reach the label by legal obligation.
• Commission Regulation (EU) No 655/2013 laying down common criteria for the justification of claims used in relation to cosmetic products. EUR-Lex. — Six criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. It is what can be demanded of a “hypoallergenic” or a “dermatologically tested”.
• Pinnell SR, Yang H, Omar M, et al. Topical L-ascorbic acid: percutaneous absorption studies. Dermatologic Surgery, 2001;27(2):137-142. PMID 11207686. — L-ascorbic acid only penetrates when formulated at a pH below 3.5, with maximum absorption at 20%. It is the clearest example of a figure that decides efficacy and that is not on the label.

Book your consultation

If you would rather not have to read labels, the skincare routine tool does it for you: it classifies each product by its composition and suggests the routine that fits your skin, in two budgets. And if you have questions or want to fine-tune it, write to us: the medical team will go through it with you, free and with no obligation.

Clinical confirmation by the surgeon

Dr Enrique Salmerón González

Specialist in Plastic, Aesthetic and Reconstructive Surgery
Registration no. 46/4624077

Dr Elena García Vilariño

Specialist in Plastic, Aesthetic and Reconstructive Surgery
Registration no. 46/4624503