Do these products try to trick you with their ingredient lists?

While working on our new concentration estimation tool, we have noticed that some products mention a retinoid (hydroxypinacolone retinoate, or HPR) suspiciously high on their ingredient lists. In fact, it is listed higher than the solvent it is usually comes in (the ratio of the solvent to the retinoid is usually (9:1). All of these products contain less than 1% of HPR, and this can allow the brands to put it in the beginning of the ingredient list - without necessarily violating regulators' requirements of listing ingredients in order of concentration. Still, we feel that this practice is not transparent. In case you'd like to check out these products yourself, here is the list. (Luckily, most brands do not seem to use this questionable tactic, so the list is short).