We present a description of saturation in small x deep inelastic scattering from power counting in a top-down effective theory derived from quantum chromodynamics (QCD). A factorization formula isolates the universal physics of the nucleus at leading power in x. The onset of saturation is then understood as a breakdown in the expansion in an emergent power counting parameter, which is defined by the matrix element of a gauge invariant operator. We identify a new radiation mode, which enables us to extend previous literature by distinguishing the appearance of the saturation scale from the transition to nonlinear evolution. Published by the American Physical Society 2024