Answer in brief
Under Commission Regulation (EU) 2023/1545, EU cosmetic labels must name 56 additional fragrance allergens when they exceed 0.001% in leave-on or 0.01% in rinse-off products. New stock has had to comply since 31 July 2026, and older stock may be sold until 31 July 2028. In the United States, MoCRA requires the FDA to write such rules, but a label may still say only “fragrance”. If you know your allergen, search the whole ingredient list for its name.
Why the single word parfum stopped being enough
On a European label a whole perfume composition may appear as one word, parfum or aroma. For most buyers that is enough. For someone who has become sensitised to a fragrance substance it is not, because the word does not say whether that substance is inside. This guide is written for that reader, and for anyone who shops for them.
The recitals of the EU regulation on the subject explain what is at stake. They describe contact allergy as a lifelong change in the way the immune system reacts. On renewed exposure to enough of the allergen, eczema, known as allergic contact dermatitis, may develop, and once a person is sensitised a much lower concentration is sufficient to trigger symptoms. The same text estimates that 1–9% of the EU population is allergic to fragrance allergens.
The law therefore works in two ways. Limits on substances aim to stop people becoming allergic in the first place. Information on the label is for those who already are: the regulation calls it secondary prevention, and its purpose is to let a sensitised person avoid contact with the substance concerned. Naming allergens one by one belongs to that second kind of protection.
What Regulation (EU) 2023/1545 added to the list
Commission Regulation (EU) 2023/1545 was adopted on 26 July 2023 and amends Annex III to the Cosmetics Regulation, (EC) No 1223/2009. Before it, 24 fragrance allergens had to be mentioned individually in the ingredient list. The Scientific Committee on Consumer Safety, in an opinion adopted in June 2012, confirmed that these were still relevant and identified 56 more that had clearly caused allergies in humans.
The European Commission’s summary of the change is short. The regulation introduces individual labelling requirements for 56 additional fragrance allergens and updates the existing entries, among other things by grouping certain substances. It also treats substances that can be transformed into known contact allergens through air oxidation or bioactivation, called prehaptens and prohaptens, as equivalent to fragrance allergens.
Two things did not change. The words parfum and aroma remain, and the named allergens are listed in addition to them. And the rule is about information, not prohibition: the Commission’s page states that an ingredient appearing in the list does not mean that the product is unsafe.
Two thresholds decide whether a name is printed
A fragrance allergen covered by Annex III has to be indicated in the list of ingredients when its concentration exceeds 0.001% in leave-on products or 0.01% in rinse-off products. Both figures appear in the regulation and on the Commission’s page. A leave-on product stays on the skin or hair; a rinse-off product is washed away after use.
The difference is tenfold. A rinse-off product can contain ten times as much of the same allergen as a leave-on product before the name has to be printed. If you react to a substance, a shampoo or shower gel whose list does not mention it is telling you less than a cream whose list does not mention it.
It follows that the absence of a name is not proof that the substance is absent. It means only that the substance is either not there or present below the threshold for that type of product. Whether amounts below the threshold matter in your case is a medical question, and the person to ask is the dermatologist who diagnosed the allergy.
31 July 2026 and 31 July 2028, and the shelf in between
The regulation gave the industry time. According to the European Commission, cosmetic products that do not comply with the new requirements may no longer be placed on the EU market since 31 July 2026. Products placed on the market before that date may continue to be made available until 31 July 2028. The recitals describe these as transition periods of three and five years, justified by the large number of products concerned.
For a shopper this means that, until the second date, shops in the EU can hold two generations of labels. One pack may carry a list written under the earlier rule, and a newer pack of the same product a list written under the new one. Nothing on the pack says which generation you are holding.
Read both with care. A longer list on a familiar product may simply mean that substances once covered by the word parfum are now named; the Commission tells consumers to expect more individual fragrance ingredients on packaging. A short list, on the other hand, is not evidence that a newly added allergen is missing until the older stock has gone. If your allergen is among the additions, ask the brand which rule the label follows.
The new names include familiar plants
The entries added to Annex III include single substances with everyday names: menthol, camphor, vanillin, benzaldehyde, linalyl acetate, terpineol and pinene among them. Each is printed under the common ingredient name given in the annex.
Many of the additions are plant oils and extracts, and for several the annex prescribes the exact words to print: “Lavandula Oil/Extract”, “Jasmine Oil/Extract”, “Rose Flower Oil/Extract”, “Lemongrass Oil”, “Eucalyptus Globulus Oil”. Peppermint, lemon peel and bergamot oils, ylang-ylang, clove, sandalwood and patchouli are on the list as well. A product scented only with essential oils is therefore not, for that reason, free of declarable allergens.
Related substances now share a label name. Geranial and neral are both declared as “Citral”, the different forms of limonene sit in one entry, and several rose species are declared together. If your test result names a specific form or species, match it to the group name. The legally binding list is Annex III to Regulation (EC) No 1223/2009. The Commission’s CosIng database lets you look up an ingredient, though the Commission describes it as informative only.
Where the United States stands under MoCRA
American law is at an earlier stage. The Modernization of Cosmetics Regulation Act of 2022, which the Food and Drug Administration calls the most significant expansion of its authority over cosmetics since 1938, requires the agency to establish regulations for fragrance allergen labelling. That is an instruction to write a rule. It is not yet a rule that changes what a pack says.
The place to follow progress is the FDA’s own MoCRA page. When it was read for this article it showed 10 August 2026 as the date of its last update and listed the fragrance allergen requirement with no proposed or final rule beside it. For the talc testing rule required by the same law, by contrast, the page links a proposal from December 2024 and its withdrawal in November 2025.
Until a rule exists, the older practice applies. The FDA’s consumer page on allergens explains that an ingredient declaration is required on cosmetics sold at retail, but that certain ingredients may be listed generally as “fragrance” or “perfume” without identifying the specific ingredients. A pack labelled for the American market can therefore show one word where a European label would name the allergens above the thresholds.
Reading a list when you already know your allergen
Begin with the diagnosis, not the shelf. Ask the clinic for your patch test results in writing and note each allergen under the name used in ingredient lists, including any group name it now falls under. Keep the note on your phone. Without the exact name, no label can be searched.
On a pack labelled for the EU, the word parfum or aroma tells you that a fragrance composition is present. Read on through the entire list for your allergen’s name, bearing in mind the two thresholds and, until 31 July 2028, the possibility of an older label. On a pack labelled for the US, the word fragrance on its own leaves the question open, and the FDA’s advice is to contact the manufacturer named on the label.
Do not let the front of the pack answer for the back. The FDA states that it is not enough to check for terms such as “hypoallergenic”, “fragrance-free” or “for sensitive skin”, because no federal standard or definition governs their use in the United States. Read the list again each time you buy, since labels are being rewritten during the transition.
What a label cannot do, and when to see a dermatologist
A label can help you avoid a substance. It cannot tell you which substance you react to. The FDA describes the usual way of finding out: in a patch test, small amounts of allergens are placed on the skin and covered for 48 hours, a doctor examines the skin after 72 to 96 hours, and the process takes two to three visits.
The same page advises consulting a healthcare professional about symptoms you suspect are an allergic reaction, noting that sensitivity to allergens can become more severe over time. Reactions to cosmetics most often appear as an itchy, red rash. Shortness of breath or trouble swallowing are different: the FDA lists them among the signs of anaphylaxis and says to seek medical attention immediately.
Nothing in this article is medical advice, and no reading of labels replaces a diagnosis. If a rash keeps returning, see a dermatologist and take the products you use, with their packaging, to the appointment. In the United States you can also report a reaction to the FDA, and MoCRA requires the company responsible for a product to report serious adverse events to the agency within 15 business days.
Practical checklist
- Ask the clinic for your patch test results in writing and note each allergen under the name used in ingredient lists.
- On an EU pack, read past the word parfum and scan the whole ingredient list for your allergen and its group name.
- Until 31 July 2028, do not take a short EU ingredient list as proof that a newly added allergen is absent; ask the brand.
- On a US pack that says only “fragrance”, contact the manufacturer named on the label before you use the product.
- See a dermatologist about any rash you suspect is allergic, and seek urgent care for difficulty breathing or swallowing.
Questions and answers
How many fragrance allergens must be named on EU cosmetic labels?
The regulation’s recitals say that 24 fragrance allergens already had to be named individually and that the EU’s scientific committee identified 56 more; the European Commission states that the new rule introduces individual labelling for those 56. Because related substances are grouped under shared names, counting printed names gives a different figure. The binding list is Annex III to Regulation (EC) No 1223/2009.
When do the new EU rules on fragrance allergens apply?
Commission Regulation (EU) 2023/1545 was adopted on 26 July 2023. According to the European Commission, products that do not comply may no longer be placed on the EU market since 31 July 2026, and products placed on the market before that date may continue to be made available until 31 July 2028. Until then, a pack on sale may still follow the earlier list.
Does the United States require fragrance allergens to be listed?
Not as individual names at the time this article was checked. The FDA’s MoCRA page says the 2022 law requires the agency to establish regulations for fragrance allergen labelling, and it listed no proposed or final rule on 5 October 2026. Meanwhile the FDA says certain ingredients may be declared generally as “fragrance” or “perfume”. Check the FDA page for the current position.
Does “fragrance-free” mean a product has no fragrance allergens?
You cannot rely on the phrase alone. The FDA says no federal standard or definition governs terms such as “fragrance-free”, “hypoallergenic” or “for sensitive skin” in the United States, and that checking for them is not enough. Read the ingredient list instead, and remember that plant oils and extracts such as lavender, rose and peppermint are among the allergens the EU requires to be named.
What is the difference between the leave-on and rinse-off thresholds?
The regulation sets the labelling threshold at 0.001% for leave-on products and 0.01% for rinse-off products. A product that is washed off may therefore contain ten times as much of an allergen as one that stays on the skin before the name has to appear. A missing name on a shampoo tells you less than a missing name on a cream, which matters if you already react to the substance.