Fragrance formulations are a closely guarded secret for most personal care brands. But changing allergen rules are about to make them a lot more transparent. 

30-40% of the global population is now affected by one or more allergic conditions, with the number of new food allergy cases almost doubling over the last decade in some regions. 

This dramatic rise is prompting industry authorities to tighten allergy labelling rules. Cosmetics regulators in multiple regions are now implementing stricter disclosure requirements for potential allergens in personal care products.

Why is fragrance allergen labelling under scrutiny?  

Fragrance is a huge factor in why consumers choose one cosmetic over another, distinguishing one brand from the next. 

Many fragrances contain extracts from food sources such as aloe, avocado, coconut, peanut, berries and herbs. While these ingredients are typically refined into oils that remove most allergen proteins, more artisanal or "rustic" products may still present risks for sensitive individuals.

Consumers often don't realise they're being exposed to potential allergens. For instance, most shoppers wouldn't know that arachis oil comes from peanuts or that lauric acid is derived from coconuts.

Although food allergens don't always trigger the same reactions through skin contact as ingestion, transparent labelling will help consumers avoid potentially harmful exposures. 

Additionally, cosmetics contain more petrochemicals than food products, and synthetic ingredients can also trigger allergic reactions. However, it’s much harder to understand which synthetic allergens are triggering if they continue to be listed simply as ‘fragrance’ or ‘parfum’ on the label. 

Which regions are updating their fragrance allergen labelling? 

‍European Union

In 2023, the European Commission added 56 new fragrance allergens to its mandatory disclosure list for cosmetic products. This expanded list includes common ingredients like menthol, lemongrass oil and lavendula oil.

All these substances must be declared when they exceed concentrations of 0.001% in leave-on products such as perfume and eau de toilette.

Manufacturers have three years to update their labels or reformulate their products to meet the new allergen disclosure list. Non-compliant products can still enter the EU market until July 2026. 

‍Canada

In April 2024, Health Canada published updates to the country's Cosmetics Regulations, enhancing ingredient disclosure requirements.

The new Canadian framework establishes harmonised definitions for leave-on and rinse-off cosmetics, which align with EU terminology.

For products introduced before August 2026, the original 24 allergens must be listed when they exceed certain thresholds. For products introduced after August 2026, all allergens (both original and new) must be listed at these same thresholds.

Canada's new rules allow fragrance companies with small packaging to list ingredients on their websites instead of trying to fit everything on the label.

‍USA 

The United States is still formulating its approach. The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) directed the FDA to issue regulations on fragrance allergen labelling, with an initial target date of July 2024. But as of March 2025, the FDA has not published draft regulations. 

According to the Office of Information and Regulatory Affairs, the target has been rescheduled to October 2025, though this timeline remains uncertain.

Some states have already taken independent action. For example, California requires any EU-listed fragrance allergen to be reported under The Cosmetic Fragrance and Flavor Ingredient Right to Know Act. However, this allergen information appears on a state website rather than on product packaging, limiting its visibility for consumers.

How can personal care brands prepare for new fragrance allergen disclosures? 

While regulatory changes can be disruptive, forward-thinking cosmetic brands are using these updates to show their commitment to consumer safety and transparency.

Proactive companies are currently: 

• Conducting allergen audits of their entire product portfolio to identify compliance gaps 
• Developing market-specific labelling strategies that accommodate local requirements while maintaining global brand identity
• Considering reformulation where fragrance allergen disclosures might impact consumer perception or sales

‍Expert guidance on changing fragrance regulations

When fragrance is a defining influence on why people choose cosmetics, many brands don’t want to develop unscented products. Instead, they want support with developing formulas and packaging that meet new fragrance allergen frameworks. 

At Hooley Brown, we understand the challenges that cosmetic and personal care companies face in meeting these new regulatory requirements. 

Whether you need support reformatting labels, reformulating products or developing compliance strategies, we can ensure your products meet local allergen laws. We can also act as your UK/EU Responsible Person. 

Want to know more? Book a free 30-minute discovery call with our Director, Clare Daley.

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