Cosmetic Fragrance Allergen Labelling: Regulatory Trends and Market-Specific Requirements

Fragrance allergens are naturally occurring or synthetic substances that may trigger allergic contact dermatitis in sensitised individuals. Regulatory authorities increasingly require the declaration of specific fragrance allergens to improve transparency and help consumers identify and avoid ingredients that may cause allergic reactions. Nevertheless, requirements are evolving unevenly across jurisdictions, and a label that is compliant in one market may not meet the requirements of another.

This article provides a practical overview of fragrance allergen labelling requirements in the European Union (EU), United Kingdom (UK), Canada, India, United States (US), New Zealand, Australia, ASEAN Member States and China.

At-a-glance regulatory comparison

European Union (EU)

The EU has introduced significant changes through Commission Regulation (EU) 2023/1545, amending Annex III of Regulation (EC) No. 1223/2009. The amendment expands the list of fragrance allergens that require declaration on cosmetic product labels when present above specified concentration thresholds.

Key dates

Q: When do the new EU requirements apply?

A: Cosmetic products placed on the EU market from 31 July 2026 must comply with the expanded allergen labelling requirements. Products already placed on the market before this date may continue to be made available until 31 July 2028, provided they comply with the previous requirements.

Additional considerations

Q: Is allergen labelling the only requirement that companies should assess?

A: No. Commission Regulation (EU) 2026/909 also introduces updated restrictions for certain fragrance-related ingredients, including Benzyl Salicylate and Citral (including Geranial and Neral isomers). Regulatory reviews should therefore consider both allergen declaration requirements and ingredient restrictions.

United Kingdom (UK)

The UK Cosmetics Regulation currently continues to apply the existing fragrance allergen declaration requirements based on the allergen list inherited from the previous EU framework.

Q: Has the UK adopted the EU's expanded allergen list?

A: At the time of writing, no official confirmation has been identified regarding adoption of the expanded fragrance allergen labelling requirements introduced by Regulation (EU) 2023/1545. Businesses supplying both the EU and UK markets should continue monitoring regulatory developments.

Canada

Canada has strengthened cosmetic ingredient disclosure requirements through SOR/2024-63, introducing fragrance allergen labelling requirements aligned with EU principles.

Q: What are the key compliance dates in Canada?

A: The following compliance timeline shall be fulfilled.  

• 12 April 2026: Existing listed fragrance allergens must be declared when present above applicable thresholds.
• 1 August 2026: Expanded requirements apply to new cosmetic products entering the Canadian market.
• 1 August 2028: Expanded requirements apply to all cosmetic products sold in Canada.

As in the EU, fragrance allergens must be declared when concentrations exceed 0.001% in leave-on products or 0.01% in rinse-off products.

India

India has updated its cosmetic ingredient framework through IS 4707 (Part 2): 2025, which includes fragrance allergen-related controls and additional substances such as Camphor and Menthol.

Q: Does India follow the same fragrance allergen restrictions as the EU?

A: Not entirely. India aligns with the EU in prohibiting Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde (HICC) (CAS No. 31906-04-4), a fragrance allergen that has been banned in cosmetic products due to safety concerns. However, there are notable differences between the two frameworks.

Q: Are there any fragrance allergens that are prohibited in the EU but still permitted in India?

A: Yes. Butylphenyl Methylpropional (Lilial) (CAS No. 80-54-6), which is prohibited in the EU, remains permitted under the current Indian requirements. This highlights the importance of assessing market-specific regulatory requirements when developing products for multiple markets.

Q: How many fragrance allergens are covered under India's labelling requirements?

A: India's fragrance allergen declaration framework covers a total of 27 fragrance allergens, including the additional substances Camphor and Menthol.

United States (US)

At present, the United States does not have a final federal requirement mandating the individual disclosure of fragrance allergens on cosmetic labels.

Q: What should companies monitor in the US?

A: Under current cosmetic labelling rules, fragrance/flavor ingredients may generally be declared collectively as ‘Fragrance’ or ‘Flavor’. However, the Modernization of Cosmetics Regulation Act (MoCRA) directs the US Food and Drug Administration (FDA) to establish fragrance allergen labelling requirements. FDA rulemaking is therefore an important development area to monitor.

Q: Is there any state law requirement on fragrance ingredients?

A: California's Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 (SB 312) requires manufacturers to report certain fragrance ingredients and fragrance allergens to the California Safe Cosmetics Program (CSCP).

Q: Does California require fragrance allergen disclosure on cosmetic label?

A: No. California's SB 312 is primarily a reporting and public disclosure requirement to the California Safe Cosmetics Program, rather than a cosmetic product label declaration requirement. Products are reported to the state database, but individual fragrance allergens are not currently required to appear on cosmetic labels under California cosmetic law.

New Zealand

New Zealand regulates cosmetic ingredients through the Cosmetic Products Group Standard 2020 (CPGS). Current requirements continue to reflect the established fragrance allergen framework, in total 24-fragrance allergen labeling, and no formal adoption of the EU expanded fragrance allergen list has been identified.

Cosmetic products must comply with prohibited and restricted ingredient requirements and ingredient listing obligations under the CPGS framework. Exporters should check the latest consolidated schedules and updates before placing products on the New Zealand market.

Australia

Australia requires cosmetic ingredient disclosure under the Consumer Goods (Cosmetics) Information Standard 2020. Fragrance/flavor components in cosmetic products could be collectively declared by ‘fragrance’, ‘parfum’, ‘flavour’, or ‘aroma’.

Q: Does Australia currently require fragrance allergen labelling?

A: No specific fragrance allergen disclosure requirement currently applies. Businesses should distinguish general ingredient listing obligations from fragrance allergen declaration requirements and continue monitoring future developments.

ASEAN Member States

The ASEAN Cosmetic Directive (ACD) does not currently require individual fragrance allergen declaration on cosmetic labels at the regional level.

Under ASEAN Cosmetic Labelling Requirements, perfume and aromatic compositions and their raw materials may be declared using generic terms such as “perfume”, “fragrance”, “aroma” or “flavor”. As a result, fragrance allergens disclosure is therefore not a mandatory requirement under the regional ASEAN framework, although companies should verify local country requirements where relevant.

China

China currently adopts a more targeted approach to fragrance allergen disclosure.

Q: Are fragrance allergens required to be declared in China?

A: For children's cosmetics, the Technical Guidelines for Children’s Cosmetics issued by the National Institutes for Food and Drug Control (NIFDC) on 31 August 2023 encourages minimizing fragrance use and require fragrance allergens exceeding the applicable labelling threshold to be disclosed. For cosmetics outside the children's category, no equivalent nationwide fragrance allergen disclosure requirement has been identified.

Manufacturers supplying children’s cosmetics to China should carefully review fragrance compositions and applicable labelling expectations for this product category.

Key considerations for cosmetic manufacturers

• Review fragrance supplier allergen declarations regularly, including updated IFRA certificates and allergen  
• Verify allergen concentrations against market-specific thresholds for leave-on and rinse-off products.
• Assess both allergen declaration requirements and substance-specific restrictions or prohibitions.

  Confirm correct ingredient nomenclature and market-specific label declaration rules.

• Monitor implementation timelines and regulatory updates in export markets.

• Update artwork and packaging early to avoid relabelling, import delays or non-compliance during market entry. 

Is your product portfolio ready for the new fragrance allergen labeling requirements? 

Fragrance allergen transparency is becoming a growing regulatory focus in the global cosmetics industry. While the EU and Canada are moving towards expanded allergen disclosure frameworks, many other markets continue to follow existing allergen lists or do not yet require individual fragrance allergen declaration.

Understanding these regional differences and preparing for upcoming compliance deadlines will help cosmetic manufacturers and brand owners maintain regulatory compliance, reduce market access risks and support consumer safety across international markets.

Early label reviews, formulation assessments and supplier documentation checks can help identify potential compliance gaps before products enter the market. SGS can support fragrance allergen assessments, label reviews and regulatory compliance evaluations for global cosmetic markets.

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