Fragrances & Perfumes

Fragrance appears in almost every cosmetic and is also a product class in its own right, from eau de parfum to body mist. Its regulatory weight sits in three places: the labelling of fragrance allergens, the restriction of specific fragrance materials, and the high-strength alcohol most fine fragrance is built on.

Allergen labelling and the 2023/1545 expansion

For years, 24 fragrance allergens had to be named individually in the ingredient list when present above a threshold; otherwise a fragrance mixture is declared simply as “Parfum” or “Aroma”. Commission Regulation (EU) 2023/1545 added 56 more to Annex III, taking the list past 80 substances and groups. Each must be named when present above 0.001% in a leave-on product or 0.01% in a rinse-off product. The deadlines are now close: a product placed on the EU market must comply from 31 July 2026, with sell-through of existing stock to 31 July 2028. Crucially, Great Britain has not adopted 2023/1545 and for now keeps the original list, so a fragrance sold in both the EU and GB needs two different ingredient lists. The assessment also considers the cumulative allergen load, not just each allergen in isolation.

Restricted fragrance materials

Beyond labelling, particular fragrance materials are restricted or prohibited outright. Several nitromusks and the sensitisers HICC, atranol and chloroatranol have been banned, and Butylphenyl Methylpropional (Lilial) was prohibited from 1 March 2022. The IFRA Standards, the fragrance industry’s own framework derived from quantitative risk assessment, set usage limits by product category and are the practical reference formulators work to, but they are separate from the law and do not replace the Annex II and III controls. Oxidation-prone terpenes such as limonene and linalool are subject to a peroxide-value limit, because it is their oxidation products, not the fresh material, that drive sensitisation.

The alcohol base and flammability

Fine fragrance is largely high-strength ethanol (alcohol denat.), which makes it flammable and brings the product within CLP and transport classification alongside the Cosmetics Regulation. The safety report addresses the flammability, and the packaging and any aerosol presentation are assessed accordingly.

Phototoxicity

Some natural fragrance materials, particularly citrus oils containing furocoumarins such as bergapten, are phototoxic, so their content is restricted and the assessment considers reactions on sun-exposed skin. A natural or essential-oil-led fragrance is not automatically gentler; it can carry exactly these risks.

How we help

We identify and quantify every allergen for the correct ingredient list in each market, hold the EU and GB versions apart while the lists diverge, check the formula against the Annex II and III restrictions and the relevant IFRA limits, assess phototoxic and oxidation-prone materials, and address the alcohol base. As the allergen list and fragrance restrictions continue to move, we keep a fragrance compliant and correctly labelled in each market it sells in.