Perfume Labeling Requirements: US vs. EU

U.S. and EU perfume labels diverge on one requirement above all others: the EU makes you name individual fragrance allergens in the ingredient list, and the U.S. does not. The original EU list named 26 fragrance allergens, and Regulation (EU) 2023/1545 expanded it to more than 80 entries — a list that has applied to every product placed on the EU market since 31 July 2026, and that products already on the market must meet, or be withdrawn to meet, by 31 July 2028. In the U.S., the entire fragrance may still appear as the single word "Fragrance" — MoCRA directs FDA to write allergen-disclosure rules, but no proposed rule has been published and no effective date is set.

The same bottle, two ingredient lists — an EU label must name individual fragrance allergens; a U.S. label may still say only “Fragrance.”

How Do U.S. and EU Perfume Labels Differ?

What Does the Same Fragrance Look Like on a U.S. vs. EU Label?

Same product, same fragrance — two different ingredient lists depending on the market. The examples below illustrate the practical effect of the rules.

The ingredient lists above are illustrative. The exact allergens that appear on any label depend on the specific fragrance composition and the use level in the finished product. Your supplier's EU allergen breakdown is what determines the named allergens for your label.

For fragrance brands selling in both regions — or planning to expand internationally — labeling sits at the intersection of compliance, supply-chain documentation, and consumer trust. The rest of this guide walks through each requirement in detail, with the long allergen lists tucked into expandable drawers for reference.

One product, many markets — the label rules that apply are the rules of the market where the product is sold.

What Does Each Region Require on the Label?

What Must a U.S. Cosmetic Label Include?

In the U.S., perfumes are regulated as cosmetics under the Federal Food, Drug, and Cosmetic Act (FD&C Act). 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)
• Ingredient declaration in descending order — the fragrance itself may appear simply as "Fragrance" or "Parfum"
• Warnings and directions, when applicable (flammability, safe use)
• Adverse-event contact information — since 29 December 2024, MoCRA requires every cosmetic label to carry a domestic address, domestic phone number, or electronic contact through which the responsible person can receive adverse event reports

Currently, U.S. cosmetic regulations do not require brands to list individual fragrance allergens on the label. Allergenic components like 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 identify which substances count as fragrance allergens, to require them on cosmetic labels, and to consider existing international requirements — the EU's included — when it does (21 U.S.C. 364e(b)). The statute set an 18-month deadline for a proposed rule from its 29 December 2022 enactment; as of September 2026 no proposed rule has appeared in the Federal Register, so U.S. labels carry no allergen-disclosure obligation yet. FDA’s 2026 Unified Agenda now targets a proposed rule for November 2026 — an agenda projection, not a binding date. Brands that already maintain detailed allergen documentation today will be better positioned when those rules land.

What Does the EU Require Beyond That?

In the European Union, perfumes and fragranced cosmetics are regulated under Cosmetics Regulation (EC) No 1223/2009. The label requirements are similar to the U.S. — identity, net contents, responsible person, ingredient list — but the EU adds mandatory fragrance allergen disclosure above set thresholds.

These thresholds apply whether the allergens come from natural essential oils or synthetic ingredients. Many naturals contain several listed allergens at once — which is why supplier documentation matters.

Which Allergens Must an EU Label Name?

The EU's allergen list has two layers. The original list of 26 named fragrance allergens is what cosmetic labels declared for two decades; two of those, Lilial (butylphenyl methylpropional) and HICC (Lyral), have since been banned from EU cosmetics outright, leaving 24 in active use. Regulation (EU) 2023/1545, in force since 16 August 2023, expands the list to more than 80 entries, adding individual chemical substances and named plant species and extracts whose composition makes them inherent allergen carriers.

That expansion is now in force for new product: anything placed on the EU market since 31 July 2026 has had to carry the expanded declarations, and stock placed before that date must comply, or be withdrawn, by 31 July 2028.

The two banned substances are starting to fall in the U.S. as well: California’s AB 496 bans butylphenyl methylpropional (Lilial — listed there as lily aldehyde, CAS 80-54-6) from cosmetics sold in the state beginning 1 January 2027.

Are Essential Oils and Naturals Covered Too?

The expansion's biggest practical impact is on natural fragrance work: many widely used essential oils and extracts now appear in Annex III by name. A single oil can trigger several allergens at once because of its inherent chemical composition.

Lavender (Lavandula angustifolia) is one of the botanical species Regulation (EU) 2023/1545 names directly — the oil itself is a disclosure trigger.

Headline categories — visible to anyone formulating with naturals:

• Rose ketones (damascones, damascenone)
• Pinene / terpene group
• Rose oils & absolutes (Rosa centifolia, damascena, gallica)
• Jasmine (Jasminum spp.)
• Ylang-ylang (Cananga odorata)
• Citrus oils (bergamot, lemon, sweet/bitter orange)
• Lavender (Lavandula angustifolia, hybrida)
• Mint (Mentha piperita, spicata)
• Patchouli (Pogostemon cablin)
• Sandalwood (Santalum album)
• Cedarwood (Cedrus atlantica, Juniperus virginiana)
• Eucalyptus (E. globulus, E. radiata)
• Verbena (Lippia citriodora)

For the authoritative complete enumeration — including exact substance forms, CAS numbers, and specific isomer designations — refer to Regulation (EU) 2023/1545 on EUR-Lex and Annex III of Cosmetics Regulation (EC) No 1223/2009.

When Do the New EU Allergen Rules Apply?

Where the Rules Stand Right Now

The first of the two EU dates is behind us. That changes what this page is for: it is no longer a warning about a deadline, it is a description of the rules a product is being judged against today.

The FDA position was re-checked against the Federal Register as this page was updated in September 2026: no proposed rule identifying fragrance allergens has been published, so nothing has changed on the U.S. side of this comparison since the page was written. The agency’s own regulatory agenda still carries the proposed rule as a projection rather than a commitment.

The practical consequence for anyone formulating: the document that decides your EU label is not the regulation, it is your fragrance supplier’s allergen breakdown at your use level. The regulation names what must be declared above threshold; only the breakdown tells you which of those entries your formula actually crosses.

U.S. vs. EU Label Requirements, Side by Side

Browse by Compliance Need

Every Stock Fragrance oil is backed by an IFRA 51 Regulatory Data Sheet, SDS, and EU allergen breakdown — posted on its product page or available on request. The collections below filter by the regulatory framework or product application that fits your project.

By Regulatory Framework

By Product Type

Use level decides which allergens cross the disclosure thresholds, so the label follows the formula. Our fragrance oil calculator turns a container size, a target dosage percentage and a unit count into the fragrance weight a batch needs, and the fragrance oil knowledge center gathers our regulatory and formulation guides in one place.

Frequently Asked Questions

Have questions about allergen disclosure, regional requirements, or how to plan for the MoCRA changes ahead? Contact us — we answer every inquiry personally.

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