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diff --git a/51.md b/51.md
index f5a9a74..507c515 100644
--- a/51.md
+++ b/51.md
@@ -10,6 +10,8 @@ This NIP defines lists of things that users can create. Lists can contain refere
 
 Public items in a list are specified in the event `tags` array, while private items are specified in a JSON array that mimics the structure of the event `tags` array, but stringified and encrypted using the same scheme from [NIP-04](04.md) (the shared key is computed using the author's public and private key) and stored in the `.content`.
 
+When new items are added to an existing list, clients SHOULD append them to the end of the list, so they are stored in chronological order.
+
 ## Types of lists
 
 ## Standard lists