The Skincare Loophole No One Talks About: Did You Know 70% of Your Moisturiser Is Water?

After fourteen years of writing about skincare, beauty journalist Aoife Donnelly opened a single email, and ended up reading the back of every bottle in her bathroom for the first time. What she found, and what she now thinks the rest of us deserve to know, is below.

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ByAoife Donnelly

Updated Mon 4 May 2026, 12:14 PM · Dublin · 13 min read

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There is a small, slightly embarrassing confession at the beginning of this piece, and I'd rather get it out of the way now. I have been a beauty journalist for fourteen years. I have written about skincare for almost every weekend supplement in this country. I have interviewed dermatologists in Dublin, Paris, and Seoul. And until a Tuesday evening last month, I had never once turned a moisturiser bottle around and properly read the back.

I read four of them that night. I sat on the kitchen floor in my pyjamas, in the kind of yellow under-cabinet light that makes everything feel slightly forensic, and I read every word printed in size-six type on the back of every jar I had picked up in the last six months. There was a glass of red wine. There was a magnifying glass borrowed from my father. There was, by the end of it, a tightness in my chest I have not quite been able to put down since.

What I read on those labels, on every single one of them, was something I should have known fourteen years ago.

This is the piece I should have written ten years ago. I didn't write it because I didn't know. I didn't know because nobody had ever asked me to look. The whole commercial structure of beauty journalism (including, I am ashamed to say, the particular structure of my own career) has been quietly built around not looking too closely at the back of the bottle.

Last month, a reader asked me to look. So I did.

I started by reading labels. I ended up somewhere I had not expected to go.

The reader who asked

Her name is Mary, and I'm going to keep her surname out of this. She read my piece in this publication on the Prebiotic Moisturising Cream a few months ago and emailed me afterwards. She works in product procurement for a Dublin hotel group. She chooses the bedside coffee, the mini bottles of shampoo, the glasses on the breakfast table. She is forty-nine. Her email was four lines long.

"I love your work," it began. "Can I ask you something I'm too embarrassed to ask anyone else? Why is the first ingredient on every moisturiser I own 'aqua'? Is that just water? I feel a fool for asking."

I sat at my desk for ten minutes before I replied. I could feel something unbalancing slightly. I told her, honestly, that yes, it is just water. I told her I'd write a piece about it. I promised her I would.

That was three months ago.

The piece took three months because I had to learn things I should already have known. I had to ring people. I had to read regulations I had been writing around for fourteen years without ever reading. I had to look at the backs of bottles I had only ever looked at the fronts of. I had, more than once, to put the kettle on and sit with what I was finding out before I could keep going.

I am sorry it took me this long, Mary. This is the answer.

What I learned about labels

I started, as one does, with a phone call.

A friend of mine works in regulatory compliance for a pharmaceutical company in Dublin. We met for university coffee a long time ago and we have, somehow, both ended up in lives that occasionally let us be useful to each other. I rang her on a Wednesday morning and asked her, plainly, how the back of a moisturiser actually works.

She explained the rule in a single phone call, the way a friend explains something simple over coffee. EU cosmetic regulations require ingredients on an INCI list to be in descending order of concentration. That much I knew. The half of the rule I had never been told is the second half. Down to one per cent.

Above one per cent concentration, ingredients have to be in order. Below one per cent, brands can list them in any sequence they like.

I asked her if that was as significant as it sounded.

"Above one per cent, you have to be honest," she said. "Below one per cent, you can put your buzzword active wherever it looks best on the label. That's the rule. It isn't a secret. It's just that nobody who doesn't work in cosmetics has any reason to know it exists."

I didn't say anything for a moment. I have been writing about this industry for fourteen years. I had never been told this. I had never asked.

The order of the first three ingredients on a label, my friend said, tells you the truth. Everything after that is, legally and structurally, marketing copy printed in a smaller font. I wrote that down on a Post-it. I have been thinking about it most days since.

Four bottles

I went home that night and pulled four moisturisers from my bathroom. I lined them up on the kitchen table the way you line up suspects. I poured myself a small glass of red. I picked up the magnifying glass.

The bottles, in order of price, were these. A €38 supermarket cream, the kind sold in pharmacies to women over fifty, with a soft pearlescent label and a promise of "deep nourishment." A €72 mid-tier serum-cream marketed for sensitive skin, in a frosted glass jar that felt much more expensive than it was. A €145 luxury cream stocked at every Brown Thomas counter in the country. And a €185 cream described in its launch press release as "skincare reimagined." (A phrase that means nothing and everything at once.)

I read the first ingredient on each. Aqua. Aqua. Aqua. Aqua.

I read the second ingredient on each. On three of the four bottles, it was glycerin or another humectant. On the fourth, it was butylene glycol. All of them are water-soluble. All of them require water to function in the formula.

I read the third ingredient. On three of the four bottles, it was an emulsifier, usually cetearyl alcohol, sometimes a surfactant, required to bind water and oil into a stable cream. On the fourth, it was a thickener, also water-dependent.

I sat back. I took a longer sip of the wine than was strictly necessary. I did the maths.

Industry-standard moisturiser formulations contain between sixty and eighty per cent water by weight. The €185 cream in front of me, in a 50ml jar, contains roughly thirty-five to forty millilitres of water. At the retail price I had paid, that is somewhere between €110 and €148 of water. Tap water, in a glass jar, with a label.

I have been told for twenty years that I am paying for science. I have been paying, mostly, for water.

The loophole

The rule, in regulatory shorthand, has a name. It is called the down to one per cent rule, and it is not hidden. It is published in the EU's cosmetic ingredient labelling framework. Any cosmetic chemist will explain it to you on a phone call. None of them have any particular reason to bring it up unless asked.

What it means in practice is this. A brand can put a buzzword active on the front of a bottle (vitamin C, peptide complex, hyaluronic acid, niacinamide, the active du jour) and concentrate that ingredient at 0.4 per cent of the formula. That is a low enough dose to deliver minimal measurable benefit on skin. But because 0.4 per cent is below the one per cent threshold, the brand can list the ingredient anywhere it wants on the back of the bottle. Fifth on the INCI. Eighth. Tucked between two ingredients the customer has never heard of and could not pronounce if asked. The reader assumes order means concentration. It doesn't.

The label, technically, is not lying. The label, technically, is also not telling the truth.

I rang a senior cosmetic chemist for this section of the piece. She has worked across multiple European labs over a twenty-five-year career, including stints with several luxury houses I am not going to name, and she has good reasons not to be named here. She agreed to speak to me as a senior formulation chemist who has worked with several European luxury houses. I have respected that. We spoke twice, both times on the phone, both times for over an hour.

I asked her to explain the loophole in her own words, in continuous interview tape. I am going to quote almost the whole answer she gave me, because I think it deserves its own breath:

"The one per cent rule exists for legitimate reasons. At very low concentrations, the precise order of ingredients is harder to verify, and the original framework was not built to police that level. The problem is what the industry has done with the freedom. If you have a serum that uses 0.3 per cent of a marketing-headline active, you can list it fifth on your INCI, between two ingredients the customer doesn't know. The customer reads the label and assumes order means concentration. It does not. Below one per cent, order means whatever the marketing team decided would look most credible on the back of the bottle. If you want to know what is actually in a moisturiser, look at the first three ingredients. After that, you are reading marketing."

I had been reading marketing for fourteen years.

Why the industry has not fixed it

The obvious next question, and the one I asked the chemist on our second call, was this. If water-based formulations are this margin-rich, and the loophole is this widely understood inside the industry, why has nobody quietly moved toward something better?

There are, she told me, three reasons. None of them are very flattering.

The first is the margin model. Water is the cheapest possible filler. Cheaper than glycerin, cheaper than glycols, cheaper than anything that does similar work on skin. Replacing the water in a typical formula with concentrated active ingredients raises the cost of goods between four and ten times. A brand that did this would have to either raise prices further (already optimistic in this category) or accept slimmer margins (a conversation no marketing director wants to have). Neither is commercially attractive. So nobody has it.

The second is texture. Customers have been trained, over forty years of advertising, to expect a moisturiser to spread, absorb quickly, and feel weightless on the skin. Achieving those properties without water requires expensive lipid carrier ingredients with long names: squalane, caprylic and capric triglyceride, olive ester compounds. All of them are several times the cost of water by weight, and none of them deliver the silk-into-cotton skin feel of a well-formulated water-based emulsion. There is, as the chemist put it dryly, "a reason every cream feels the same when you put it on."

The third is preservation. Water-based products require preservatives to stop bacterial growth in the bottle, but preservatives are cheap. Waterless products often do not require preservatives at all, which sounds like a clean win until you realise they require airless or glass packaging instead, which is more expensive at scale. The maths still ends up favouring water.

None of these are formulation problems. There is no scientific reason a major luxury house could not have launched a beautifully formulated waterless moisturiser fifteen years ago. The science was available. The capability existed. The will did not.

I have written, over the course of fourteen years, several thousand words praising creams that the people who made them would not, on close questioning, have used themselves. That sentence is not designed to be punchy. It is just true.

The category they had been avoiding

Waterless skincare, in plain terms, is exactly what it sounds like. A formula made without water as its base ingredient. Oils, balms, solid serums, dry oils. The category has been around for years (Korean and French formulators have been doing meaningful work in it since at least 2018) but it has only become visible in the European mainstream in the last eighteen months.

It is, as of this year, the fastest-growing segment of the European skincare market. The global waterless cosmetics market grew from $11.73 billion in 2025 to $13.26 billion in 2026, a 13 per cent compound annual growth rate. The growth is being led, almost without exception, by small independent and biotech-led brands. The major luxury houses are largely not part of it.

I rang the chemist a third time to ask her about this. She answered briefly, almost impatiently:

"The major brands could have launched waterless products fifteen years ago. The science was there. They didn't, because the margins on water-based products are higher. The current waterless trend is small brands forcing the issue. I find it slightly funny, and slightly sad."

I sat with that on the phone for a moment after she'd said it.

And then I noticed, while I was sitting with it, the thing I had not put together until that exact moment. A product without water cannot exploit the down to one per cent rule. There is no aqua sitting at the top of the INCI list, displacing the actives below it. Every ingredient in a waterless formula is doing measurable work. The label tells the truth in a way a water-based label structurally cannot.

The waterless category is not just a marketing trend. It is the only category of moisturiser whose label does not lie to you.

I had spent fourteen years writing about skincare. I now had two weeks to find out what skincare looked like when it was honest.

What the chemist had been using

I asked the chemist, near the end of our second phone call, whether there was a finished product on the European market that demonstrated the principle. Whether there was a moisturiser she had personally tested, in her own home, that she would recommend to a friend.

She paused. (She had, I think, been waiting to be asked.) And then she told me about a small Bulgarian brand. Family-owned. Run out of Sofia. They had reformulated their face oil as a waterless moisturiser. A slightly unusual category move, but one she had found genuinely interesting. She had been using it for four months herself. She had quietly recommended it to two of her own colleagues. She had not been paid by anyone to mention it.

The brand was Gentle & Rose. The product was called Hydrate & Balance Face Oil.

I noticed the name. I asked her about it.

"It's a face oil," she said. "But the way it functions on skin is as a moisturiser. They named it for what it does. The category it belongs to is something else again. They could probably do with renaming it. The product is good."

I ordered a bottle that night.

It arrived four days later. A small glass pipette bottle, not heavy, the kind of weight that signals real glass and considered packaging without straining for opulence. Ten ingredients on the label. No surfactants. No emulsifiers. No preservatives. No alcohol. No silicones. The list, when I read it, was so short that I read it twice in case I had missed something.

The first ingredient was caprylic and capric triglyceride, an olive-derived ester carrier that gives the oil its characteristic dry-touch finish. The second was octyldodecyl olivate. Also olive-derived. A light, fast-absorbing emollient. The third was rosehip seed oil, the active ingredient on the front of every "anti-pigmentation" cream I had ever written about, here at meaningful concentration.

The first ingredient, in other words, was a moisturising agent. Not water.

I want to be honest about what happened next, because if I'm not honest at this point in the piece, the rest of it falls apart. I did not expect, when I started writing this article, to find a finished product I would actually recommend at the end of it. I have one anyway. I'm telling you about it because I told Mary I would. The fact that I now have to write a paragraph defending why I'm doing that is, I think, part of the problem the piece has been trying to describe.

What is actually in the bottle

I want to write down everything that is in Hydrate & Balance, in order, with what each ingredient does on skin. The list is short enough that this is genuinely possible. Which is, in itself, the most editorial thing I will write in this piece.

That is everything in the bottle. There is nothing else. The brand could not list aqua as the first ingredient even if they wanted to.

Three women who switched

I asked Gentle & Rose, while I was reporting this piece, to put me in touch with three Irish women who had been using Hydrate & Balance for at least four months. They sent me three the next day. I rang each of them, in the evenings, the way I always do these calls. With a cup of tea and a notebook and the freedom to ask the questions a press release will not let you ask. The surnames are changed at the women's request. Everything else, including the silences when there were silences, is theirs.

If you ticked five, you have spent the last decade buying water at luxury prices. The good news is that you now know.

What it costs and how it ships

The bottle costs €35 for 30ml, retail. That price is direct from Gentle & Rose, in Ireland, at the time of writing. One bottle, at two to three drops twice a day, lasts approximately three months. That puts the per-day cost somewhere south of the price of a takeaway coffee.

There is a two-bottle bundle on the brand's site at a reduced rate. It includes free Irish delivery. The product ships from Sofia. Irish delivery takes between five and nine business days, which is longer than an Amazon Prime habit will tolerate, but not by enough to be a real problem. There is a sixty-day money-back guarantee. If the formula is wrong for you, the brand has built the option to return it into the way they sell it. I appreciated this.

The maths I want to leave you with, though, is not the per-bottle calculation. The €185 cream on my kitchen table the night I started this piece contained roughly €130 of water and a small handful of euros' worth of actual actives, plus packaging and margin and the marketing budget that sold it to me. Hydrate & Balance, at €35, contains €35 worth of ingredients, every one of which is doing measurable work on skin. The price per active ingredient sits somewhere quite different from the price per active ingredient in the cream I had been using.

That, in the end, is the calculation that mattered to me. It is, I think, the calculation that will matter to you.

What I told Mary

I sent Mary a draft of this piece last week. I asked her, by way of a thank-you for the question that started it, whether she was happy to be quoted by name, and she said yes, on condition that I changed her surname. (We agreed on a small thing. She gets to remain anonymous to her colleagues. I get to keep her, in the piece, as a real human being.) She told me she had been using Hydrate & Balance for two months by the time the draft arrived. She told me it had not changed her life. She told me her skin was better.

And then she told me she had sent the draft to her mother.

Mary's mother is in her seventies. She lives in a small town in County Kerry, in a house with a small kitchen, in front of a small wooden table, with a small jar of moisturiser she has been buying since the 1980s. The first ingredient on the back of her jar is, of course, aqua.

Mary's mother rang her three days after the draft arrived. She had taken the jar off the bathroom shelf and brought it to the kitchen and sat down with it. She had read the back of it, in proper light, for the first time. She had then rung Mary, in something between irritation and a much quieter feeling, and asked her one question.

"Mary," she said. "Why has nobody told us this?"

I do not have a good answer to that question. I have been thinking about it since Mary forwarded me the call. The honest version is that nobody told her because nobody had a commercial reason to tell her. Beauty journalism, including mine (especially mine) is not structured to ask the kinds of questions Mary's mother is now asking from her kitchen table in Kerry. It never has been. It probably never will be, unless a great many readers like Mary keep asking the kinds of questions Mary asked me.

The four bottles on my own kitchen table are still there. I have not yet decided what to do with them. I know I will not be replacing any of them. Not because Gentle & Rose has paid me to write this piece. Because I have, after fourteen years, finally read the labels.

You have, as of finishing this piece, the same information I had at the end of three months of reporting. What you do with it tomorrow morning is your decision.

Mary's mother has, I suspect, already made hers.

"Mary. Why has nobody told us this?"