Practical guide

“May Also Contain” or “Or” on a Cosmetic Ingredient List: What to Check

Read the exact alternative group and any revised-list notice. The checked US rule describes specific ingredient-shortage arrangements; the wording does not prove every alternative is present or that every formula change is shortage-related.

Readers trying to identify the meaning and applicable version of an alternative US cosmetic ingredient declaration · 10 minute read · Published

An alternative list does not confirm that every alternative is present

“May also contain” and “or” can identify alternative ingredients under a specific US cosmetic-labeling provision. They do not, by themselves, establish that every named alternative is present at the same time. Read the whole declaration and its version before turning the wording into a formula.

In the checked § 701.3(m), the arrangement concerns a current or anticipated shortage of a cosmetic ingredient. The provision describes two ways to identify alternatives. It does not say that any missing ingredient, changed scent or different texture proves a shortage, and this article has not examined an actual affected product.

Preserve the exact phrase. “May contain” in a conditional color group has a different context in § 701.3(g). A “new ingredient list” notice in § 701.3(n) points to a revised declaration under another specified arrangement. Those three signals should not be collapsed into one vague label warning.

This guide uses the complete official § 701.3 text available in the 5 November 2026 eCFR snapshot. It explains source wording and a matching-record process, not an individual package’s legal compliance, a product recommendation or the effect of a formulation change.

  1. Keep the wording

    Copy the complete declaration, including “or,” “may also contain” and any new-list notice.

  2. Identify the group

    Distinguish normally used ingredients, named alternatives and conditional colors rather than adding all names together.

  3. Match the revision

    Keep the applicable revised declaration beside the exact product and note any unresolved version.

Original ingredient-record diagram. It is not a tested formulation, manufacturing procedure or compliance certificate.

Read “or” beside an ingredient and “may also contain” as a separate group

The first arrangement in § 701.3(m) identifies an alternative immediately after the ingredient for which it substitutes. The word “or” follows the normally used ingredient and any other alternative ingredient. Read that grouping before deciding which substances a list confirms.

For a deliberately abstract example, a teaching note might say “Ingredient A or Ingredient B.” That structure presents an alternative, not a measured formula containing both. The lettered names here are invented placeholders, not proper ingredient designations or a compliant label for sale.

The second arrangement lists the alternatives after the normally used ingredients, using the phrase “may also contain.” The source describes how that alternative group is ordered, including reference to paragraph (f). Its position is not an explicit quantitative disclosure, and a reader cannot calculate percentages from it.

Keep the ordinary group and the alternatives together in your record, but do not merge them into confirmed simultaneous contents. If the actual declaration or product identity is incomplete, mark it incomplete. A shared brand name does not identify which version or formulation you have.

The provision also excludes an ingredient mentioned in advertising or labeling outside the required ingredient declaration. Do not assume this arrangement explains away a conflict with a highlighted front claim. Preserve the claim and ask for a source-specific clarification rather than certify the substitution.

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Similar-looking phrases point to different arrangements
Exact signalRelevant checked provisionBounded reading
Ordinary ingredient declaration§ 701.3(a), with applicable qualificationsRead the declaration and its actual scope; no percentages inferred
May contain in a color group§ 701.3(g)Specified conditional color-matching or shaded-product arrangement
Ingredient A or Ingredient B§ 701.3(m)An immediately identified alternative under the specified shortage provision
May also contain after the normally used list§ 701.3(m)A separate alternative group under that provision
New ingredient list / new ingredient list inside§ 701.3(n)A notice directing attention to a specified revised declaration

Find the revised declaration behind a “new ingredient list” notice

Section 701.3(n) addresses a formulation change necessitated by an ingredient shortage and the use of packages bearing labels for the old formulation. It describes a revised declaration on firmly affixed labeling, or a specified inside-package arrangement, with conspicuous wording that identifies the new list.

The first arrangement uses an attached tag, tape, card, sticker or similar overlabeling bearing “new ingredient list.” The second concerns labeling inside an unsealed package and a notice such as “new ingredient list inside.” Read the actual matching new declaration; a notice alone does not supply its contents.

Do not conclude that every sticker or every reformulated cosmetic falls under this shortage provision. A price change, retailer label or ordinary design update is not the same evidence. Likewise, a website’s refresh date does not by itself identify the formula in the package in front of you.

Retain the original package identity and the revised source so that the relationship is traceable. Do not join the old and revised ingredient lists into one long formula or assume that both versions’ ingredients are present. If the notice or enclosed declaration is missing, the applicable information remains unresolved.

This article does not prescribe opening a retail package, removing an overlabel or altering a cosmetic. Its task is reading the available product labeling and asking for information that can be matched to the item.

Keep product identity, alternatives and unknowns in separate fields

Copy the exact product name, shade or variant, market, available version information and any legible lot reference. Keep the phrase and its complete ingredient group, including the ordinary group it follows or the ingredient it immediately replaces.

Then identify any revised-list notice and where the actual revised declaration appears. Label the source as the received package, attached label, accompanying information or matching maker source. Keep an older photograph or web list separately when it differs.

A lot reference is not a decoded date. A source date is not necessarily a manufacturing date. The opening-date and cost record handles those separate fields without reconstructing unknown history.

Do not use an ingredient alternative as evidence that a formula has become stronger, weaker or suitable for another purpose. A label can identify an alternative without supplying a performance comparison. Finding a familiar name does not establish its amount or authorize replacing directions from another product.

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Save enough information to make the question answerable
Record fieldWhat to preserveWhat to leave unresolved
Exact product and sourceProduct, variant, market and the source actually received or readA version inferred only from a similar name
Alternative groupOriginal “or” or “may also contain” wording and all its contextWhich alternatives are actually used without a matching confirmation
New-list noticeNotice wording and the complete revised declaration it identifiesA new formula guessed from a sticker or refresh date
ConflictBoth sources and the precise field that differsA silent correction that merges old and new records

Ask which declaration applies, rather than guess the formula

A useful question for the label firm is: “Which ingredient declaration applies to this exact product and package version? The label includes these alternatives or this new-list notice; this information remains unclear.” Include the details actually available, with unknown fields plainly marked.

Download the blank alternatives-and-version note. It is a private source worksheet, submits nothing through this site and asks for no health information. Its purpose is to preserve wording and identity, not choose a product or diagnose a reaction.

For a missing declaration, use the retail-package label-location guide. For a color group, use the separate conditional-color guide. For the product’s US cosmetic/drug category and complete instructions, use the existing personal-care label guide.

Finish with the conclusion the source supports: a matched declaration, a stated alternative whose actual use is not confirmed, or a missing version relationship. A longer list of possible ingredients does not resolve the last two outcomes.

Check four complete alternative-list cases

These invented examples use abstract ingredient placeholders and the checked rule’s wording. They are not real labels, product trials or judgments about a particular package.

Case 1

A teaching declaration says “Ingredient A or Ingredient B.” Have you established a formula containing both A and B?

Show answer and explanation for case 1

No. Preserve the stated alternative rather than add both as confirmed contents.

Section 701.3(m) describes a particular alternative arrangement under its shortage conditions. The abstract wording does not supply a tested formulation. Match the actual item and declaration before making an exact-presence statement.

Case 2

A makeup color group begins “may contain.” Should it automatically be read as the same group as “may also contain” under the ingredient-shortage provision?

Show answer and explanation for case 2

No. Read the exact phrase, ingredient type and full context.

The checked § 701.3(g) color arrangement and § 701.3(m) alternative arrangement have different conditions. Similar everyday wording is not evidence that the label uses the same provision.

Case 3

A front claim highlights Ingredient A, while an incomplete copied list suggests an alternative. Can you assert that § 701.3(m) automatically permits that change?

Show answer and explanation for case 3

No. Preserve the conflict and obtain the complete source.

The paragraph excludes an ingredient mentioned in advertising or labeling outside the required declaration. This guide does not certify the package or infer the manufacturer’s actual situation. A highlighted claim is information to retain, not erase.

Case 4

The package says “new ingredient list inside,” but the revised declaration is unavailable. Can an old retailer transcription fill the gap?

Show answer and explanation for case 4

No. Obtain the matching revised declaration.

Section 701.3(n) describes a particular revised-list arrangement, not permission to reconstruct a new formula from unrelated records. Keep the notice, product identity and missing information visible; do not merge old and new lists.

Sources and further reading

  • eCFR: complete §701.3, checked snapshot of 5 November 2026Paragraphs (m) and (n) support the shortage-related alternative and revised-list explanations; paragraph (g) is the separate conditional-color context. Complete section read from official XML. No actual shortage, package compliance or product performance was assessed.