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Compliance

How to write a compliant ingredient list

The ingredient list looks simple — just list what's in the product — but it's one of the most-cited areas in FDA warning letters. The rules under 21 CFR 101.4 govern the order, the names, and a handful of details that trip up new brands. Here's how to get it right.

Updated August 6, 2026 · 4 min read · Sourced from FDA guidance

The core rule: common names, heaviest first

Under [21 CFR 101.4](https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.4), list every ingredient by its common or usual name, in descending order of predominance by weight — heaviest first — in one statement on the principal display panel or the information panel. Use the recognizable common name, not a trade or brand name, a supplier code, or a chemical (IUPAC) name. The broad exception: ingredients exempt under § 101.100 don't have to be declared.

The 2% rule

Getting the exact order of tiny ingredients right is hard, so the rule lets you group ingredients present at 2% or less by weight at the end of the list, out of strict order, after a phrase like 'Contains 2 percent or less of:' or 'Less than 2 percent of:' (the threshold you state can be 2%, 1.5%, 1.0%, or 0.5%). Everything above that line still has to be in true descending order.

Sub-ingredients: don't hide the compound

When one of your ingredients is itself made of several ingredients — a seasoning blend, a chocolate chip, a sauce — you must reveal its sub-ingredients, in one of two ways:

  • Parenthetically — name the compound ingredient, then list its parts in descending order: 'chocolate chips (sugar, chocolate liquor, cocoa butter, soy lecithin).'
  • Dispersed — drop the compound name and fold each sub-ingredient into the main list in its correct descending-by-weight position.
Important

This is where allergens hide. If a compound ingredient — a 'natural flavor,' a spice blend, a glaze — contains milk, wheat, soy, or sesame, that allergen source must still appear, in the ingredient list or a 'Contains' statement. A sesame-containing natural flavor that isn't declared is a classic post-FASTER Act violation. See allergen labeling.

Spices, flavors, colors, and preservatives

These four categories have their own rules under 21 CFR 101.22:

  • Spices may be grouped as 'spices,' and flavors as 'natural flavor,' 'artificial flavor,' or 'flavor' — you don't have to name each one (though allergen sources inside them still must be revealed).
  • Certified color additives must be named — 'FD&C Yellow No. 5' (or 'Yellow 5'), not the vague 'artificial color.'
  • Chemical preservatives need a function statement — the common name and what it does: 'sodium benzoate (preservative),' 'BHA (to protect flavor),' 'ascorbic acid (to preserve freshness).'

What you can leave off: incidental additives

A short set of incidental additives — substances present at insignificant levels with no functional effect in the finished food, such as processing aids and sub-components of another ingredient — are exempt from declaration under § 101.100. Allergens are never incidental, though: if a major allergen is present at any level, it must be declared.

The mistakes FDA cites most

  • A compound ingredient's sub-ingredients left out.
  • A certified color declared only as 'artificial color.'
  • A preservative listed with no function statement.
  • Ingredients in the wrong order — usually from inaccurate formulation records.
  • A major allergen buried in a flavor or sub-ingredient.

Building it from your recipe

Because the order depends on weight, an accurate recipe is the foundation. The recipe nutrition calculator works from your ingredient weights, and the Nutrition Facts label generator sits alongside the ingredient statement on the panel. For the other required elements around it — statement of identity, net quantity, the allergen 'Contains' line — see the required label elements.

Frequently asked questions

In what order do ingredients go on a food label?
In descending order of predominance by weight — the heaviest ingredient first — by common or usual name (21 CFR 101.4). Ingredients at 2% or less may be grouped at the end after a 'Contains 2 percent or less of' statement.
Do I have to list sub-ingredients?
Yes. A compound ingredient made of several ingredients must reveal its sub-ingredients, either in parentheses after the compound's name or dispersed into the main list in descending order.
Can I just write 'artificial color'?
Not for certified colors. Certified color additives (the FD&C colors) must be listed by name, such as 'FD&C Yellow No. 5' or 'Yellow 5.' Only non-certified colors may use 'artificial color.'
How do I list a preservative in the ingredients?
With both its common name and a statement of its function — for example 'sodium benzoate (preservative)' or 'BHA (to protect flavor)' — under 21 CFR 101.22.
What is the 2% rule on ingredient lists?
Ingredients present at 2% or less by weight may be grouped at the end of the list, out of strict descending order, following a phrase like 'Contains 2 percent or less of.'

Sources

Related tools & guides

This guide is general educational information, not legal advice, and labeling rules can change. Your obligations depend on your specific products, claims, sales, and state. Verify your situation against the current FDA guidance and eCFR linked above, or consult a qualified food-labeling professional, before printing a label.