Fragrance Allergens

What are fragrance allergens? Do they need to be included in the ingredient declaration for a cosmetic product? (Answer: Yes, in most countries, but not in the US … yet.)

Fragrance Allergens

Fragrance allergens are components in fragrances that are known to be a likely cause of allergic reactions in an appreciable percentage of people. In other words, while it’s possible that any component of a fragrance could cause an allergic reaction in one person, there are some components that have been proven to cause an allergic reaction in a lot of people.

Fragrance allergens can be synthetic fragrance components or components in natural, plant-based fragrances (“natural complex substances”) or essential oils, concretes, absolutes or extracts. For example, linalool is a known fragrance allergen, and lavender essential oil contains about 35% linalool. The list at the bottom of this article shows the possible plant-based sources of some known fragrance allergens.

Ingredient Declaration

Some countries (see list below) have regulations that require that certain fragrance allergens be listed in the ingredient declaration if there is a minimum amount in the product:

• In rinse off products: 0.01%
• In leave on products: 0.001%

In other words, if your lavender cream has 0.001% linalool in it, then in those countries you would need to list linalool in the ingredient declaration.

Europe & the UK

Currently, Europe and the UK require that all of the fragrance allergens in the list below be identified in the ingredient declaration if they are present at the minimum amounts—with the exception of Butylphenyl Methyl Propional and Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde.

However, there is a proposed an amendment that added 54 additional fragrance allergens to the list and they will also need to be declared if they are present. It is unclear if (or when) the proposal will go into effect.

[Update] The EU regulations were finalized and the additional 54 fragrance allergens are now in the regulations. They need to be added to product labels by either July 2026 or July 2028, depending on when the product was placed on the market.

United States

Currently there are no fragrance allergens identified in regulations that must be included in the ingredient declaration.

However, under the new cosmetic law (MoCRA), the FDA must identify fragrance allergens of issue and then create regulations to require them to be included in the ingredient declaration. The FDA has until June 2024 to issue the proposed regulations, and the final regulations must be issued within 180 days of the close of the comment period.

[Update] The FDA missed the June 2024 deadline, but has said that the proposed regulations will be published in October 2024.

It’s likely that the fragrance allergen list will be similar to the list already adopted by other countries (but that’s not definite).

California

California requires that cosmetic products containing fragrance allergens be reported to the through the California Department of Public Health’s Safe Cosmetics Reporting Portal. Currently the same 24 fragrance allergens required on the labels in Eurpoe must be reported. They will require reporting of the additional 54 fragrance allergens at the same time that they must be included on the labels of products in in the EU. For more data on the California requirements see California Allergen Reporting.

Canada

Currently, Canada does not require any specific fragrance allergens that must be included in the ingredient declaration.

However, in February 2023 new rules were proposed to require the same allergens as the EU to be included in the ingredient declaration. As of this writing, they have not yet been finalized nor gone into effect.

[Update] The Canadian regulations were finalized in April, 2024. The 24 fragrance allergens that are already in the EU list must be added to Canadian cosmetic ingredient declarations by April 12, 2026. The additional 50 or so fragrance allergens added to the EU list in 2023 have to be on Canadian labels by August 2026 or August 2028, depending on when the product is or was introduced onto the market.

India & New Zealand

India and New Zealand both require that all of the fragrance allergens on the list below be included in the ingredient declaration if they are present.

S. Korea

South Korea requires all the fragrance allergens on the list below be included in the ingredient declaration—except Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde.

United Arab Emirates (UAE)

The UAE doesn’t have a list of specific fragrance allergens, but they require that any aromatic substance present in perfume at over .001% must be identified in the ingredient declaration.

Hong Kong, China’s Taiwan, Japan, ASEAN¹

There are no requirements for listing fragrance allergens in the ingredient declaration.

What Should You Do Now?

If you sell your product in any of the countries listed above that currently have fragrance allergen requirements, you should be including the correct information in your ingredient declaration (if any of the fragrance allergens are present at the minimum amounts).

If you sell in the United States or Canada, you should determine if any of your products contain the fragrance allergens, and if so, at what amounts. That way you will know if you need to update your ingredient declarations when the regulations are issued or updated. Of course, knowing what fragrance allergens are in your products is a good idea anyway!

Your fragrance oil provider should be able to provide you with the amount of any of these fragrance allergens in the fragrance oils you purchase. For plant-based essential oils, concretes, absolutes, or extracts, you can ask your essential oil provider or check the “Natural Complex Substances” list. (On that page you’ll need to click on “IFRA 51st Amendment – Annex on contributions from other sources“, which will download to your cmoputer an Excel spreadsheet with the list. It’s the only way to view it.) You’ll have to do the math based on the amount of the fragrance/essential oil you use, the percentage of the allergen in the fragrance/essential oils, and whether your usage meets the minimum which would require inclusion in the ingredient declaration.

Regulated Fragrance Allergens

Fragrance Allergen	Source	Plant Sources
Alpha-Isomethyl Ionone	Synthetic	n/a
Amyl cinnamal	Synthetic	n/a
Amyl cinnamyl alcohol	Synthetic	n/a
Anisyl (Anise) alcohol	Synthetic or Natural	Honey, Anise, Tomatoes, Tahiti Vanilla
Benzyl alcohol	Synthetic or Natural	Peru Balsam, Tolu Balsam, Jasmin, Apricot, Almond, Apple, Asparagus, Banana, Black Currant, Blackberry
Benzyl benzoate	Synthetic or Natural	Peru Balsam, Tolu Balsam, Jasmin, Ylang-Ylang
Benzyl cinnamate	Synthetic or Natural	Peru Balsam, Tolu Balsam, Copahu
Benzyl salicylate	Synthetic or Natural	Propolis
Butylphenyl methyl propional	Synthetic	n/a
Cinnamal	Synthetic or Natural	Cinnamon, Hyacinth, Patchouli, Nutmeg
Cinnamyl alcohol	Synthetic or Natural	Hyacinth
Citral	Synthetic or Natural	Lemon, Orange Peel, Eucalyptus, Grapefruit, Orange, Celeris, Apricot, Blackcurrant, Grape, Kiwi, Mango, Ginger, Melon, Plum, Raspberry, Rose
Citronellol	Synthetic or Natural	Lemongrass, Ceylon, Apple, Apricot, Cassis, Blackberry, Blueberry, Orange, Passion Fruit, Peach, Rose
Coumarin	Synthetic or Natural	Woodruff, Clouves, Sweet clover, Angelique, Berce
Eugenol	Synthetic or Natural	Clove, Allspice, Bay (Myrcia acris), Avens, Ceylon Cinnamon, Laurel, Cistus, Labdanifere, Basil Sassafras, Basil Java, Cassie, Sweet Flag, Carnation, Boldo, Cascarille, Galangal, Bay Leaves, Nutmeg, Pale Rose, Ylang-Ylang, Marjoram, Calamus, Camphor, Lemongrass, Patchouli
Farnesol	Synthetic or Natural	Rose, Neroli, Ylang-Ylang, Lime, Tolu Balsam
Geraniol	Synthetic or Natural	Rose oil, Orange, Palmarosa, Verbena, Neroli, Lemongrass, Hyssop, Laurel, Lavender, Mandarine, Melissa, Myrtle, Apple, Apricot, Black Cranberries, Blackcurrant, Blackberry, Coriander, Ginger, Nutmeg, Thyme, Geranium, Rose, Palmarosa, Ylang-Ylang
Hexyl Cinnamal (Cinnamaldehyde)	Synthetic	n/a
Hydroxycitronellal	Synthetic	n/a
Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde (Hydroxy -methylpentyl-cyclohexenecarbox aldehyde)	Synthetic	n/a
Hydroxycitronellal	Synthetic	n/a
Isoeugenol	Synthetic or Natural	Citronella, Essential Oils of Ceylon, Essential Oils of Ylang-ylang
d-Limonene	Synthetic or Natural	Lemon, Dill, Common Juniper, Orange, Verbena, Neroli, Niaouli, Melaleuca, Lemon Balsam, Peppermint, Nutmeg, Myrrh, Angelique, Aspic, Badiane, Bergamot, Mandarin, Bigaradier, Caraway, Celery, Lavender, Lime
Linalool	Synthetic or Natural	Lavender, Pine, Laurel, Sour Orange, Marjoram, Peppermint, Lemon, Orange, Ylang Ylang, Verbena, Myrtle, Neroli, Coriander, Geranium, Lime, Lemon Balsam, Nutmeg, Lemongrass, Basil, Bergamot, Rosewood, Banana, Blackberry, Bean, Blueberry, Apple, Apricot, Artichoke, Thyme, Rose, Palmarosa
Methyl 2-Octynoate	Synthetic	n/a
Oakmoss Extract	Natural	Oak moss extract
Tree moss extract	Natural	Tree moss extract

1. Association of Southeast Asian Nations, which includes Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, Phillippines, Singapore, Thailand and Vietnam ↩︎