The essentials
The EU Cosmetics Directive 76/768/EEC introduced the obligation to declare 26 specific fragrance allergens on cosmetic labels in 2003, with a transitional period through March 2005. The list derived from a 1999 opinion of the Scientific Committee on Cosmetic Products and Non-Food Products (SCCNFP), which identified the most frequently encountered fragrance contact allergens in clinical patch testing across Europe. The declaration became binding under the consolidated EU Regulation 1223/2009 (European Commission, accessed 2026-05-29).
The declaration applies when an allergen is present above the regulatory threshold: 0.001 percent (10 parts per million) in leave-on products, including fine fragrances, and 0.01 percent (100 parts per million) in rinse-off products. When the threshold is exceeded, the INCI name of the allergen must appear in the ingredient list on the carton, allowing patch-tested individuals to identify products to avoid.
The list was substantially expanded by Regulation EU 2023/1545, published in July 2023. The expanded list raises the number of declarable fragrance substances to 81, adding 55 individual allergens and revising the entries for several of the original 26. Implementation applies from July 2026 for new products placed on the market and from July 2028 for products already in the supply chain (European Commission, Regulation EU 2023/1545).
The original 26 allergens
The 2003 list, codified in Annex III of Directive 76/768/EEC and inherited into Annex III of Regulation 1223/2009, comprises 24 individual chemical compounds and 2 natural extracts. The individual compounds are: amyl cinnamal, amylcinnamyl alcohol, anise alcohol, benzyl alcohol, benzyl benzoate, benzyl cinnamate, benzyl salicylate, cinnamal, cinnamyl alcohol, citral, citronellol, coumarin, eugenol, farnesol, geraniol, hexyl cinnamal, hydroxycitronellal, hydroxyisohexyl 3-cyclohexene carboxaldehyde (Lyral or HICC), isoeugenol, butylphenyl methylpropional (Lilial), limonene, linalool, methyl 2-octynoate, and alpha-isomethyl ionone.
The two natural extracts are oakmoss extract (Evernia prunastri) and treemoss extract (Evernia furfuracea). Both are complex mixtures rather than single molecules, and both have been substantially restricted by IFRA since the 43rd Amendment of 2008. The list captures both isolated synthetics widely used in modern compositions and natural raw materials carried over from historical perfumery.
Declaration thresholds and label format
The 0.001 percent threshold for leave-on products corresponds to 10 milligrams of the allergen per kilogram of finished product. For a 100 ml eau de parfum, this means 1 milligram of the allergen per bottle. The threshold is designed to align with the lowest concentrations capable of eliciting allergic reactions in sensitized individuals, based on RIFM and SCCS dose-response data.
The label format requires the allergen to appear in the ingredient list under its INCI name, in descending order of weight for ingredients above 1 percent. The fragrance composition itself appears as "Parfum" or "Fragrance" in the list, with the declarable allergens listed separately when they exceed the threshold. A buyer comparing labels can therefore identify which specific allergens are present above the regulatory threshold without seeing the proprietary fragrance formula (Perfumer & Flavorist, accessed 2026-05-29).
The 2023 expansion to 81 substances
Regulation EU 2023/1545 expanded the declarable list to 81 fragrance substances in response to the SCCS Opinion 1459/11 of 2012, which identified additional materials of concern based on accumulated patch test data. The expansion adds 55 new substances and refines the entries for several of the original 26, while removing Lilial which had already been prohibited in cosmetics by Regulation 2021/1902 effective March 2022.
The new substances include menthol, vanillin, salicylaldehyde, and a number of additional terpene derivatives and aldehydes. The implementation timeline allows the industry to reformulate or relabel: products placed on the EU market from July 2026 must comply, and products manufactured before that date may continue to be sold until July 2028. The expanded list will substantially lengthen INCI declarations on fragrance products manufactured from late 2026 onward (European Commission, Regulation EU 2023/1545).
Allergens since prohibited or restricted
Two of the original 26 have moved from declaration to prohibition or strict restriction. Lyral (HICC, hydroxyisohexyl 3-cyclohexene carboxaldehyde) was prohibited by the IFRA 49th Amendment in 2020, then prohibited in EU cosmetics by Regulation 2017/1410 with implementation through August 2021. Lilial (butylphenyl methylpropional) was prohibited in EU cosmetics by Regulation 2021/1902 effective March 2022, on the basis of reproductive toxicity classification. Both substances should no longer appear in compliant EU products.
Other materials from the original 26 face tightening IFRA restrictions even when not formally prohibited: hydroxycitronellal, isoeugenol, and oakmoss and treemoss extracts have all been progressively restricted by successive IFRA amendments. The trajectory from declaration to restriction to prohibition is characteristic of the regulatory cycle as RIFM and SCCS accumulate evidence on individual materials (IFRA Standards Library, accessed 2026-05-29).
What the declaration means for consumers
For most consumers, the declaration list is a precautionary disclosure rather than a warning of harm. The vast majority of users wear fragrances containing several declared allergens without any reaction. The disclosure is meaningful for the minority of individuals with diagnosed contact dermatitis to specific fragrance materials, who can use the labels to avoid products containing their known triggers.
The expansion to 81 substances will make declaration lists longer and more visually prominent on packaging, which has prompted industry concern that consumers may misread the longer lists as evidence of greater risk rather than greater disclosure. The actual safety profile of compliant fragrances has not changed; only the transparency of disclosure has increased.
Sources
- European Commission, Regulation (EC) 1223/2009 on cosmetic products, Annex III, consolidated text. Accessed 2026-05-29.
- European Commission, Regulation EU 2023/1545 amending Regulation 1223/2009 (expanded fragrance allergens list to 81 substances), 2023.
- SCCS, EU Scientific Committee on Consumer Safety, Opinion 1459/11 on fragrance allergens, 2012. Accessed 2026-05-29.
- IFRA, IFRA Standards Library, restrictions and prohibitions on Lyral, Lilial, hydroxycitronellal, isoeugenol, oakmoss, treemoss. Accessed 2026-05-29.