What are fragrance allergens? Do they need to be included in the ingredient declaration for a cosmetic product? (Answer: Yes, in some countries, but not in the US or Canada… 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 in fragrances could cause an allergic reaction in one person, there are some components that have 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 the post shows the possible plant-based sources of the 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.

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), FDA must identify fragrance allergens of issue and then create regulations to require them to be included in the ingredient declaration. 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.

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

Canada

Currently, Canada does not require any specific fragrance allergens to 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.

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 amendment that will add 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.

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 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, ASEAN¹Association of Southeast Asian Nations, which includes Brunei, Cambodia, Indonesia, Laos, Malaysia, Muyanmar, Phillippines, Singapore, Thailand and Vietnam

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. 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 fraagrance/essential oils, and whether it meets the minimum to require inclusion in the ingredient declaration.

Regulated Fragrance Allergens

Fragrance Allergen	Source	Plant Sources
Alpha-Isomethyl Ionone	Synthetic	n/a
Amy 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, Flouves, 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