EU fragrance allergen labels: what changed in 2023

The rule: Parfum, plus named allergens

EU law lists a perfume or aromatic composition as Parfum or Aroma, and adds to the same ingredient list the substances that Annex III of the cosmetics regulation says must be mentioned.¹ For fragrance allergens the trigger is 0.001% in a leave-on product and 0.01% in a rinse-off product.²

A rinse-off product is one meant to be removed after application, such as a shampoo; a leave-on product is meant to stay in prolonged contact with the skin, hair or mucous membranes, such as a moisturiser.³

The purpose is information. The regulation explains that people who are already sensitised can react to concentrations below the permitted maximum, and that naming each allergen lets them avoid the one they react to.² The threshold decides when a name must appear, not how much may be used; a few entries also set a separate maximum amount.²

What Regulation (EU) 2023/1545 changed

Until this amendment, 24 fragrance allergens had to be named. In 2012 the EU's Scientific Committee on Consumer Safety (SCCS) confirmed those were still relevant and identified 56 more that had clearly caused allergies in people.² The amendment turned that advice into law in Annex III:

• 44 new entries, numbered 328 to 371, running from Amyl Salicylate to Pinene. Several cover a group of related substances or a plant's oils and extracts.²
• 17 existing entries rewritten, among them Citral and Limonene, to align names with the EU glossary, group similar substances and add isomers.²
• One name per group. Where an entry covers several substances, it says which name goes on the label: geranial and neral appear as Citral, the damascones as Rose Ketones, and several lavender oils and extracts as Lavandula Oil/Extract.²
• Substances that turn into allergens. Fragrance substances that become known contact allergens through air oxidation, or once in the body, are treated the same as the allergens themselves.²
• Peroxide limits. Some entries cap how oxidised the raw material may be: for limonene the peroxide value must be below 20 mmol/L, a limit on the substance, not on the finished product.²³

Names you may now see after Parfum

So a scented product can now name a plant oil and some of its own components side by side: Citrus Limon Peel Oil next to Limonene, or a lavender oil next to Linalool.

The transition dates

The regulation entered into force in August 2023 and gave companies two periods, of three and five years, to adapt.² Obligations that already existed, such as naming linalool, continued throughout; the periods apply to the new requirements.²

• Until 31 July 2026, products that did not yet follow the new entries could still be placed on the EU market.²
• From 1 August 2026, a product placed on the market, which means made available there for the first time, must follow them.²³
• Until 31 July 2028, products placed on the market before that cut-off may still be supplied and sold. After it, every product on sale must comply.²

So until mid-2028 one shelf can hold packs printed under both lists. A shorter list of named allergens on an older pack may reflect the old rules rather than a different formula.

In the US

US labels may list a scent mixture simply as Fragrance, without naming its components.⁴⁵ The Modernization of Cosmetics Regulation Act of 2022 requires the FDA to establish fragrance allergen labelling requirements by regulation; the FDA's page on the law is the place to check their status.⁶ Under the current US rule, the same scent can show named allergens on an EU pack and only Fragrance on a US one.

What shoppers see on the label

• Where the names sit. At 0.001% or 0.01% these substances are far below 1%, so they fall in the part of the list where order is free, usually near the end.
• A name means presence above the threshold, not a large amount.
• No name means the substance is absent or below the threshold, so it is not a guarantee of absence.
• Plant oils can now be named allergens in their own right.
• If you know you are allergic to a substance, look for its label name, including group names such as Citral or Rose Ketones.

The ingredient checker marks each named fragrance allergen in a list you paste. For what fragrance free and unscented do and do not promise, see fragrance free vs unscented.