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Perfume Labeling Requirements: US vs. EU
For fragrance brands—whether you’re working with luxury perfumes, natural fragrance oils, or plant-based formulations—labeling is central to both compliance and consumer trust. The United States and the European Union each require ingredient lists, but the EU goes significantly further by mandating detailed fragrance allergen disclosure. This guide explains the key differences and what they mean for your labels and formulations.
U.S. Perfume Labeling Requirements
In the U.S., perfumes are regulated as cosmetics under the Federal Food, Drug, and Cosmetic Act (FD&C Act). At a high level, cosmetic labels must include:
- Identity of the product (e.g., “Perfume,” “Eau de Parfum”).
- Net quantity of contents (e.g., fl. oz., mL).
- Business information (manufacturer, packer, or distributor name and address).
- Ingredient declaration: Components listed in descending order. The fragrance itself can appear simply as “Fragrance” or “Parfum.”
- Warnings and directions, when applicable (flammability, safe use, etc.).
Allergen Disclosure in the U.S.
Currently, U.S. cosmetic regulations do not require brands to list individual fragrance allergens on the label. All allergenic fragrance components—such as limonene, linalool, or citral—may be captured under the single word “Fragrance.”
What’s changing: The Modernization of Cosmetics Regulation Act (MoCRA, 2022) directs FDA to develop rules for fragrance allergen labeling. Over time, certain fragrance allergens (likely overlapping with EU-style lists) will need to be disclosed on U.S. cosmetic labels. Brands that already work with detailed allergen documentation will be better prepared for this shift.
EU Perfume Labeling Requirements
In the European Union, perfumes and fragranced cosmetics are regulated under Cosmetics Regulation (EC) No 1223/2009. As in the U.S., labels must include identity, net contents, responsible person, and ingredient list—but the EU goes further by requiring fragrance allergen disclosure when certain substances are present above specific thresholds.
Thresholds for Allergen Disclosure
- Leave-on products (perfume, lotion): must list allergens present at ≥ 0.001% (10 ppm).
- Rinse-off products (soap, shampoo): must list allergens present at ≥ 0.01% (100 ppm).
These thresholds apply whether the allergens come from natural essential oils or synthetic ingredients.
The 26 “Classic” EU Fragrance Allergens
Historically, the EU required disclosure of 26 named fragrance allergens when present above threshold. These include:
- Alpha-isomethyl ionone
- Amyl cinnamal
- Amylcinnamyl alcohol
- Anise alcohol
- Benzyl alcohol
- Benzyl benzoate
- Benzyl cinnamate
- Benzyl salicylate
- Butylphenyl methylpropional (Lilial)*
- Cinnamal
- Cinnamyl alcohol
- Citral
- Citronellol
- Coumarin
- Eugenol
- Evernia prunastri (oak moss)
- Evernia furfuracea (tree moss)
- Farnesol
- Geraniol
- Hexyl cinnamal
- Hydroxycitronellal
- Hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC / Lyral)*
- Isoeugenol
- Limonene
- Linalool
- Methyl 2-octynoate
*Lilial and HICC/Lyral are now banned but remain part of the historical allergen framework.
The New 80+ EU Fragrance Allergen List
In July 2023, the EU published Regulation (EU) 2023/1545, expanding the allergen list from 26 substances to more than 80. The update includes both new individual allergens and broader grouped entries, especially for essential oils and complex natural extracts.
Examples of Newly Listed Stand-Alone Allergens
- 6-Methylcoumarin
- Acetylcedrene
- Amyl salicylate
- Anethole
- Benzaldehyde
- Camphor
- β-Caryophyllene
- Carvone
- Linalyl acetate
- Menthol
- Salicylaldehyde
- Sclareol
- Terpineol (α, β, γ)
- Tetramethyl acetyloctahydronaphthalenes
- Vanillin
Examples of Grouped Entries (Essential Oils & Extracts)
- Rose ketones (damascones, damascenone, etc.)
- Pinene / terpene group (α-pinene, β-pinene, terpinene, terpinolene)
- Essential oils and absolutes such as:
- Ylang-ylang (Cananga odorata)
- Jasmine (Jasminum spp.)
- Bergamot, lemon, and other citrus oils
- Lavender oils and extracts
- Peppermint and spearmint oils
- Patchouli (Pogostemon cablin)
- Rose oils and absolutes
- Sandalwood (Santalum album)
- Cedarwood oils
- Eucalyptus oil
- Verbena (Lippia citriodora)
Implementation Timeline
- By July 2026: New products placed on the EU market must follow the expanded allergen labeling rules.
- By July 2028: Existing products must be brought into compliance or removed from the market.
Key Differences at a Glance
| Requirement | U.S. | EU |
|---|---|---|
| Ingredient list | Yes; “Fragrance” allowed as a catch-all. | Yes; “Parfum” allowed, but named allergens must appear separately. |
| Allergen disclosure | Not required yet (pending MoCRA allergen rules). | Mandatory: 26 allergens today, expanding to 80+ by 2026–2028. |
| Thresholds | N/A today. | 0.001% in leave-on; 0.01% in rinse-off products. |
How This Affects Fragrance Development & Sourcing
For brands selling in both the U.S. and EU—or planning to expand internationally—fragrance allergen policy directly affects:
- Formula design: Choosing materials and concentrations that respect EU allergen thresholds.
- Label space: Allocating room on packaging for allergen names, especially for smaller components like linalool, limonene, and citral.
- Documentation: Maintaining IFRA Certificates, allergen breakdowns, and regional safety documentation for each fragrance.
Our fragrance oils are designed with documentation in mind. IFRA Certificates, SDS, and EU allergen lists can be downloaded from each fragrance product page, or requested via our Documentation Request page.
Related Fragrance Collections
By Safety & Regulatory Framework
- IFRA Compliant Fragrance Oils
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- EWG Compliant Fragrance Oils
- EPA Safer Choice Compliant Fragrance Oils
- Amazon Chemicals Policy Compliant Fragrance Oils
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By Product Type
- Fragrance Oils for Perfume & Cologne
- Fragrance Oils for Soap & Personal Care
- Candle & Home Fragrance Oils
Frequently Asked Questions
Do I need different labels for the U.S. and EU?
Often yes. The EU requires named allergen disclosure above specific thresholds, while the U.S. is still evolving toward allergen transparency under MoCRA. Many brands use region-specific labels or region-specific outer cartons.
Are natural essential oils exempt from EU allergen rules?
No. Allergen rules apply regardless of whether components are natural or synthetic. Many essential oils contain multiple listed allergens and must be considered in total when calculating thresholds.
How do I know which allergens are in a fragrance?
Your fragrance supplier should provide an EU allergen breakdown alongside the IFRA Certificate and SDS. These documents help you determine which allergens need to appear on your label at the use level in your finished product.
Can you help design fragrances with EU labeling in mind?
Yes. Our Fragrance Design Services team can create or adapt fragrances with EU allergen disclosure, IFRA categories, and retailer standards in mind.
Where can I request documentation for a specific fragrance?
Documentation, including IFRA Certificates, SDS, and EU allergen lists, is available on each fragrance product page under “Technical Info.” For additional formats or consolidated files, use our Documentation Request form.
Have questions about allergen disclosure, regional requirements, or how to plan for future MoCRA changes? Contact us—we’re happy to help.
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