Answer in brief
Read the back first. Under EU rules the ingredient list runs in descending order of weight down to 1%, and below that line the order means nothing. “Hypoallergenic” has no federal definition in the United States and is never a guarantee in the EU; “dermatologically tested” says who supervised a test, not that the product suits you. The hourglass marks a best-before date, the open jar a period after opening. Try a new product on a small area first.
The back of the pack is written to a rulebook
The front of a cosmetic pack exists to sell. The back exists because the law requires it. In the European Union, Article 19 of the Cosmetics Regulation, Regulation (EC) No 1223/2009, lists what must appear in indelible, easily legible and visible lettering: the name and address of the responsible person, the quantity, a date or period of use, precautions, a batch number, the function of the product if it is not obvious, and the ingredients.
Read an unfamiliar product in that order. Who answers for it, and at what address. How much there is. How long it keeps. What to avoid while using it. What it contains. The batch number looks like noise, but it identifies the production run, which is what makes a complaint traceable.
The front is not lawless either. Article 20 of the same regulation says that text, names, trade marks, pictures and other signs must not imply characteristics or functions which the product does not have. Even so, a claim is the brand’s summary of its own product. Treat it as a statement to check against the back.
Ingredient order holds until the one per cent line
On an EU pack the ingredients appear under common names from an official glossary that draws on the international nomenclature known as INCI, so the list reads the same in every member state. The regulation requires descending order of weight at the time the ingredients are added. It then makes an exception that changes how the list should be read: ingredients present at less than 1% may follow in any order.
The top of the list therefore tells you what the product mostly is. Further down, position stops carrying information, and the label does not mark where the 1% line falls. An extract pictured on the front may sit in that final group, where ninth place instead of nineteenth says nothing about the amount.
A few conventions explain the rest. Perfume compositions are written as parfum or aroma, with certain fragrance substances named separately where the regulation requires it. A nanomaterial is followed by the word nano in brackets. Colourants may come last in any order under CI numbers, and make-up sold in several shades may list the whole range after “may contain” or “+/-”. The list may appear on the outer packaging alone, so photograph the box before it goes into the recycling.
Hypoallergenic has no legal definition in the United States
The US Food and Drug Administration is direct about the word. Its consumer page states that there are no federal standards or definitions governing the use of “hypoallergenic”, that the term means whatever a particular company wants it to mean, and that manufacturers are not required to submit evidence for the claim to the agency.
This is not for want of trying. The same page reproduces a 1978 FDA article recounting how the agency issued a regulation in 1975 requiring comparative tests on people before a product could be called hypoallergenic. Two manufacturers challenged the rule, and the US Court of Appeals for the District of Columbia declared it invalid.
That article says there is no such thing as a non-allergenic cosmetic, one guaranteed never to cause a reaction, and it points readers who know they are allergic to particular ingredients towards the ingredient list. In an American shop, the word on the front tells you what a brand intends. The list on the back tells you what is in the bottle.
In the EU the word carries conditions, but no guarantee
European law does not define “hypoallergenic” either. It has common criteria that every claim must meet, laid down in Commission Regulation (EU) No 655/2013, and a technical document on cosmetic claims endorsed in 2017 by a working group that the European Commission chairs. The document states that it is not legally binding and that national authorities and courts judge claims case by case. Its guidance on this word has applied since 1 July 2019.
According to that guidance, the claim can be used only where a product has been designed to minimise its allergenic potential. The responsible person should hold scientifically robust and statistically reliable data confirming a very low allergenic potential, and keep the assessment up to date. Known allergens and their precursors should be avoided altogether.
Then comes the limit. The document states that the claim does not guarantee a complete absence of risk of an allergic reaction, and that the product should not give the impression that it does. For the same reason it rules out the claim “free from allergenic substances”. For someone with a diagnosed allergy, the word narrows the field and the ingredient list makes the decision.
Dermatologically tested names the supervisor, not the result
The same document explains what a reader may understand from the phrase. “Dermatologically tested” implies that the product was tested on humans under the supervision of a dermatologist. Depending on how the claim is presented, the test may concern skin tolerance or a specific effect. Studies in which consumers merely report their own impressions are not adequate support.
The document adds that consumers will expect such claims to be made only when the tested effects are favourable. It cites a judgment of the EU Court of Justice, Case C-99/01, on this very phrase: the average consumer expects that the product underwent tests intended to study its effects on the skin, and that the results were positive and showed it to be well tolerated.
What the words leave out is everything that would let you judge the test: how many people took part, what kind of skin they had, how long it lasted. “Clinically tested” means testing on humans under a medically or scientifically qualified professional, following a clinical protocol or in a clinical setting. “Tolerance tested” means a supervised study found the product well tolerated by a target group. None of these describes your skin.
Six tests every claim is supposed to pass
The six common criteria are legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. The technical document illustrates them. A claim of “48-hour hydration” is not allowed if the evidence supports only a shorter period. A product that says it contains honey must contain honey and not merely honey flavour.
Two examples correct common assumptions. A product may not claim to be authorised or approved by an authority, because cosmetics are placed on the EU market without governmental approval. Nor may it present compliance with the law as a benefit, since every product must comply. An obvious exaggeration that nobody would take literally needs no proof.
“Free from” claims receive their own guidance. They should not concern an ingredient that is banned anyway, and “free from parabens” should not be accepted, because it disparages a whole group that includes ingredients considered safe when used as the regulation allows. The claim is appropriate when it helps a particular group to choose: an alcohol-free mouthwash for a family, or a product without animal-derived ingredients for vegans.
The hourglass and the open jar measure different things
The date of minimum durability is the date until which a product, stored under appropriate conditions, continues to fulfil its initial function. Article 19 requires it to follow either an hourglass symbol or the words “best used before the end of”, and to be written as month and year or as day, month and year.
That date is not mandatory for products with a minimum durability of more than 30 months. They carry instead a drawing of an open jar followed by a period in months or years, printed for instance as “12 M”. The regulation defines it as the time after opening for which the product is safe and can be used without any harm to the consumer.
The jar’s clock starts when you break the seal, and the pack will not remember the day for you, so write the month of opening on the base. A third symbol, a hand pointing at an open book, means that the precautions or the ingredient list did not fit on the container and are printed on a leaflet, tag or card.
Test on a small area, and know when to stop
No label can say how your own skin will respond. The American Academy of Dermatology recommends trying a product first: apply the amount you would normally use to a coin-sized spot where it will not be rubbed or washed away, such as the underside of the arm or the bend of the elbow, twice a day for seven to ten days. Leave a rinse-off product on for five minutes, or as long as its directions say.
If the spot shows no redness, itching or swelling after that time, the Academy says to go ahead. It notes that some ingredients, retinol and glycolic acid among them, can irritate, particularly on sensitive skin, and that this is normal and temporary. If the skin does react, wash the product off gently and do not use it again; a cool compress or petroleum jelly can relieve the area.
A home trial is a precaution, not a diagnosis, and nothing in this article is medical advice. The Academy’s guidance is to see a dermatologist if a reaction is severe and does not settle, or if you cannot identify which ingredient is responsible. A dermatologist can arrange patch testing, a medical test that finds the cause. Once you have a name, the ingredient list becomes a precise tool.
Practical checklist
- Turn the pack over and find the responsible person, the batch number, the precautions and the ingredient list before reading any claim.
- Scan the whole ingredient list for anything you already know you react to, not only the first few names.
- Treat “hypoallergenic” and “dermatologically tested” as a reason to look closer, never as proof that a product suits your skin.
- Find the hourglass date or the open-jar period and write the month of opening on the container.
- Try a new product on a coin-sized area twice a day for seven to ten days before putting it on your face.
Questions and answers
Are cosmetic ingredients listed in order of concentration?
Under the EU Cosmetics Regulation they are listed in descending order of weight at the time they are added to the product, but only down to 1%. Ingredients below that level may appear in any order after the others, and colourants may be grouped at the end. Position therefore compares the main ingredients with one another and says little about the minor ones.
Does hypoallergenic mean a product cannot cause an allergy?
No. The US Food and Drug Administration says there is no federal standard or definition for the term and that it means whatever a company wants it to mean. EU guidance allows the claim only for products designed to minimise allergenic potential, with evidence, and states that it does not guarantee a complete absence of risk. Anyone with a diagnosed allergy should still read the ingredient list.
What does the open jar symbol with a number mean?
It is the period after opening: the time, in months or years, during which the product is safe to use once it has been opened. EU rules require it on products that keep for more than 30 months unopened, which do not have to carry a best-before date. The count starts on the day you first open the container, so it helps to note that date on the pack.
What does dermatologically tested mean on a cosmetic?
According to the EU technical document on cosmetic claims, it implies that the product was tested on people under the supervision of a dermatologist, for tolerance or for a specific effect. Consumers are entitled to expect that the results were favourable. The label does not have to state the number of volunteers, their skin type or the length of the test, so the claim cannot predict your own reaction.
How can I test a new skin care product at home?
The American Academy of Dermatology advises applying the normal amount to a coin-sized spot on the underside of the arm or the bend of the elbow twice a day for seven to ten days. If the skin stays calm, start using the product. If it becomes red, itchy or swollen, wash the product off and stop, and see a dermatologist if the reaction is severe or you cannot work out the cause.