Fragrance Ingredient Disclosure: Transparency Trends and Requirements

The fragrance industry has historically operated behind trade secret protection. The word “Parfum” on an ingredient list could conceal dozens of individual chemicals. That era is ending. Regulatory bodies in the EU, US, and Asia are expanding disclosure requirements, and consumer demand for transparency is accelerating the shift. For B2B buyers, understanding current and upcoming rules is essential for label compliance, retailer acceptance, and brand positioning.

The EU: From 26 Allergens to Over 80

Current Requirements

Under Regulation (EC) No 1223/2009 Annex III, 26 fragrance allergens must be individually declared on cosmetic labels when concentration exceeds:

• 0.001% (10 ppm) in leave-on products (perfumes, lotions)
• 0.01% (100 ppm) in rinse-off products (soaps, shampoos)

These include Linalool, Limonene, Citronellol, Geraniol, Eugenol, Cinnamal, Coumarin, and Benzyl Benzoate, declared using INCI nomenclature within the ingredient list.

Upcoming Expansion (Regulation (EU) 2023/1545)

Published July 2023, this regulation expands the allergen list from 26 to over 80 substances. Compliance deadlines:

• July 31, 2026 - Products placed on the market after this date must comply.
• July 31, 2028 - Products already on the market must be withdrawn or relabeled.

Newly added substances include Pinene, Terpinolene, Myrcene, Carvone, and Menthol, many abundant in essential oils. A single lavender oil may trigger declaration of 5-10 individual allergens under the expanded list.

Label Design Impact

With 80+ potential declarations, ingredient lists grow substantially. Plan label redesigns before the 2026 deadline. Minimum font size is 1.2 mm x-height per Article 19(2), or 0.9 mm for packaging under 20 cm squared. Evaluate whether multi-language labels remain feasible.

The United States: MoCRA and State Rules

Federal: MoCRA (2022)

The Modernization of Cosmetics Regulation Act (MoCRA), part of the Consolidated Appropriations Act 2023, expanded FDA cosmetics authority significantly:

• Section 607 - Facility registration with FDA, renewed every two years.
• Section 608 - Product listing including complete ingredient list.
• Section 606 - Serious adverse event reporting within 15 business days, records retained 6 years.
• Section 610 - Directs FDA to establish fragrance allergen labeling regulations. The proposed rule is expected to partially align with the EU list but may differ in thresholds.

California: SB 312 (2020)

The Cosmetic Fragrance and Flavor Ingredient Right to Know Act, effective January 1, 2022, requires reporting fragrance ingredients on the California Safe Cosmetics Reporting Portal if they appear on Proposition 65, EU CMR lists, or EPA hazard categories. Applies to products sold in California regardless of manufacturing location.

Asia: China and South Korea

China: NMPA

Under the Cosmetic Supervision and Administration Regulation (CSAR, effective January 1, 2021):

• Full ingredient lists must be submitted during registration via the NMPA portal.
• Individual allergen labeling is not currently required on Chinese consumer labels, but full formulations are disclosed to regulators.
• New ingredients require safety dossiers including toxicological profiles.

South Korea: MFDS

South Korea’s Cosmetics Act requires:

• Full ingredient listing on labels.
• Individual declaration of 26 allergens (aligned with EU) above 0.001% leave-on / 0.01% rinse-off.
• Complete formulation submission during product notification.

What This Means for B2B Buyers

Documentation Requirements Are Expanding

Maintain a complete formulation disclosure file for every SKU:

• Full quantitative composition with CAS numbers
• Allergen declarations mapped to each target market’s current and upcoming lists
• IFRA Certificate with product category classification
• SDS with full Section 3 composition data

Supplier Transparency Is Non-Negotiable

Your fragrance supplier must provide complete compositional data, not just “fragrance.” Without it, you cannot generate compliant labels for any major market. Include full disclosure as a contractual requirement.

Plan for Divergence

Markets are not converging on a single list. The EU is expanding to 80+. The US FDA is developing its own. China requires regulatory disclosure but limited consumer labeling. South Korea follows the EU model. You may need market-specific label variants.

Digital Disclosure Is Emerging

The EU’s Digital Product Passport initiative may eventually permit QR-code ingredient disclosure. However, as of 2025, physical label declaration remains mandatory in all major markets. Do not rely on digital-only disclosure until explicitly permitted.

How Aromiso Supports Disclosure Compliance

Aromiso provides complete compositional data packages for every product:

• Full ingredient breakdown with CAS numbers and concentration ranges
• Allergen declarations mapped to EU (current and upcoming 80+), US, and Asian requirements
• IFRA Certificates with category classification
• SDS documents with complete Section 3 data
• Support for regulatory submissions (CPNP, FDA listing, NMPA notification)

For private-label clients, our regulatory team prepares market-specific ingredient lists and allergen declarations during label artwork approval.

Looking Ahead

Full fragrance transparency is becoming the global norm. Businesses investing now in data infrastructure, supplier agreements requiring disclosure, and flexible label systems will adapt smoothly. Those relying on opacity face increasing costs and market access barriers.

Start by auditing your documentation against the most stringent requirement (the EU 2026 expanded allergen list). If you can comply with that, you can comply with any market.