An ingredient list ranks weight only down to 1%
Most brands screenshot a competitor's ingredient list and try to reverse-engineer the formula. The window where that works is narrower than it looks. Korea, the EU and the US all stop requiring descending order at 1%, and the Korean rule does not even require the boundary to be visible.
An ingredient list is only ranked by weight down to 1%. Korea's labelling standard lets ingredients used at 1% or less, along with fragrance and colourants, be listed in any order, and the EU and US draw the same 1% line. The difference is placement: the EU and US require the sub-1% group to sit after everything above 1%, while the Korean rule sets no position condition, so a Korean label never shows you where the boundary falls.
The ranked part of the list ends at 1%
Every brand reads competitor ingredient lists. Fewer know exactly where the reading stops being reliable. Korea's labelling standard under the Cosmetics Act requires ingredients in descending order of content, and in the same breath exempts ingredients used at 1% or less, together with fragrance and colourants, from that order.
That one exemption splits every ingredient list into two blocks. Above 1%, names are queued from most to least. Below 1%, there is no queue. The label does not tell you where the queue ends, which means the tenth name is not necessarily present in a smaller amount than the ninth.
On a Korean label the 1% boundary is invisible
This is where the three major markets diverge. Article 19 of EU Regulation 1223/2009 allows ingredients at 1% or less to be listed in any order after those above 1%. 21 CFR 701.3(f) builds the same structure in three groups: non-colour ingredients above 1% in descending order, then non-colour ingredients at 1% or less in any order, then colour additives. You still cannot see the exact cut, but nothing from behind the cut can jump ahead of it.
The Korean provision carries no such position condition. It says only that sub-1% ingredients, fragrance and colourants may be listed without regard to order. A label that places a 0.5% active in the fourth position is therefore compliant. Reading "it is in the top five, so there must be a meaningful amount" is the specific inference that breaks on Korean labels.
| Point | Korea | EU | US |
|---|---|---|---|
| Instrument | Labelling standard, Cosmetics Act Enforcement Rule | Regulation 1223/2009 Art. 19 | 21 CFR 701.3 |
| Ingredients ≤ 1% | Any order | Any order, after those above 1% | Any order, after those above 1% |
| Position condition | None | Yes | Yes |
| Colourants | Any order; ±/+/- across shades | After other ingredients; may contain / +/- | Final group, any order |
| Fragrance | May be grouped as one entry | parfum / aroma | fragrance / flavor |
| Trade secret | "Other ingredients" if MFDS accepts | No equivalent provision | "and other ingredients" under 720.8(a) |
If one row is worth remembering, it is the position condition. The same 1% rule yields different amounts of readable information depending on which market printed the label.
What the word "fragrance" hides, and what it cannot
A fragrance composition may be declared as a single entry. How many materials sit inside it is not disclosed, and the house that supplies it treats that as its own trade secret. The cover is not total, though.
Korea's 25 notified fragrance allergens must be named individually once they exceed 0.01% in a rinse-off product or 0.001% in a leave-on product, rather than being folded into "fragrance". The rule took effect on 1 January 2020. The EU uses those same two thresholds and raised the number of substances in scope from 26 to 81 under Regulation (EU) 2023/1545; the labelling deadline for newly placed products was 31 July 2026 and has now passed, while stock already on the market is allowed until 31 July 2028.
So when an EU-bound product shows a long tail of unfamiliar chemical names, the formula has not necessarily become more complex. The declaration obligation grew. Comparing the raw ingredient count on a Korean domestic label with an EU label is not a like-for-like comparison.
Four things a label will never tell you
The first is the formula. Order carries no information below 1%, and no percentage is printed above it either. The second is the ratio inside a blended raw material. Because blends are declared by component, an extract's position reflects the volume of the whole solution; the solids content of that solution lives outside the label.
The third is grade and origin. A single INCI name can cover materials of different purity, molecular weight and price, and those differences rarely show up anywhere a buyer can see. The fourth is process. Korea allows pH adjusters to be declared as the products of the neutralisation reaction and saponified materials as the products of saponification, so what went into the tank and what appears on the carton need not match name for name.
| What you want | From the label | Ask for instead |
|---|---|---|
| Ranking above 1% | Available | — |
| Exact percentages | Not available | Formula breakdown under NDA |
| Extract solids content | Not available | Raw material TDS |
| Grade and origin | Not available | COA and MSDS |
| Fragrance composition | Not available | Allergen declaration from the fragrance house |
Three lines to put in a sourcing brief
None of this makes ingredient lists useless. For reading base architecture — the water, humectant, emulsifier and thickener system — the list is still the fastest document available. The above-1% block alone tells you whether a product is water-led or carries a heavy oil phase.
When you request a sample, though, three lines move faster than a screenshot: the actives you want with a target concentration range, the ingredients that must be excluded, and the destination markets. That third line lets a formulator screen allergen declarations and restricted substances before the formula is locked, which is considerably cheaper than redrawing artwork later.
For which ingredients are moving right now, see today's ingredient signal, and for category price bands and cost structure, try the product planner.
In short
- Weight order is guaranteed only for ingredients above 1%. Below that, the fifth and twentieth names can sit at the same concentration.
- The EU and US require the sub-1% group to follow the above-1% group; the Korean provision sets no position condition, so a Korean label hides the boundary.
- Fragrance may be one entry, but allergens surface above 0.01% rinse-off and 0.001% leave-on. Korea lists 25 substances, the EU now 81.
- Percentages, extract solids, raw material grade and fragrance composition are all off-label. Request the formula breakdown and supplier specs separately.
*Sources: Korea Ministry of Government Legislation, Easy Law — Cosmetics labelling standards and methods, as of 15 September 2026 / Regulation (EC) No 1223/2009, Article 19, revised text on legislation.gov.uk / 21 CFR 701.3, US Code of Federal Regulations / ChemLinked, South Korea Clarifies 25 Fragrance Allergens Need to Be Labeled on Packaging (notified 11 September 2019, effective 1 January 2020) / CIRS Group, Compliance Countdown for Companies: EU Fragrance Allergens Expanded to 81 Substances — Regulation (EU) 2023/1545*
Questions people ask
You can read the relative weight of everything above 1%. Below that line order carries no meaning, so the fifth name and the twentieth name may both sit at 0.9%. The actual percentages are not recoverable from a label.
Yes. The Korean standard says only that ingredients at 1% or less, fragrance and colourants may be listed without regard to order, and attaches no requirement to group them at the end. Article 19 of EU Regulation 1223/2009 and 21 CFR 701.3(f) both place that group after the above-1% ingredients, which makes the boundary visible.
The count never appears on the label. What does appear are the 25 fragrance allergens notified by Korea's MFDS, which must be named individually above 0.01% in rinse-off products and 0.001% in leave-on products. The EU kept the same two thresholds and expanded its list from 26 substances to 81.
Blended raw materials are declared by their individual components, not by the trade or blend name. So the position of "Centella Asiatica Extract" reflects the whole extract solution, and the solids content of that solution is not on the label.
In Korea, where full disclosure would substantially harm a legitimate business interest, a company can submit supporting evidence and, if the MFDS accepts it, label the ingredient as "other ingredients". The US allows the same thing as "and other ingredients" for exemptions granted under 21 CFR 720.8(a).