Fragrance allergens and IFRA: what the label really tells you

On a cosmetic product sold in the European Union, the word "parfum" in the ingredients list stands for the whole fragrance formula and its raw materials, without naming them. Regulation (EC) No 1223/2009 on cosmetic products adds one exception: certain fragrance allergens must also be listed by name once they exceed 0.001% in a leave-on product (a perfume, a body cream) or 0.01% in a rinse-off product (a shampoo, a shower gel).

That list is getting longer. In 2023, 24 fragrance allergens had to be named; Commission Regulation (EU) 2023/1545 extends the rule to 56 more, with deadlines running to 2028. The IFRA Standards work further upstream, inside the formula: they ban, cap or set conditions on materials, and you will never read them on a bottle.

What does "parfum" mean in an ingredients list?

"Parfum" is a collective name set by law. Article 19 of the EU cosmetics regulation says that perfume and aromatic compositions and their raw materials are referred to as "parfum" or "aroma", followed by any substance whose mention is required in the "Other" column of Annex III. A whole formula fits into one word, plus a handful of separate names.

The same article sets the order. Ingredients are listed in descending order of weight at the moment they go into the product, but anything under 1% may follow in any order. An allergen near the end of the list tells you almost nothing about its dose, only that it is there, above the threshold.

The list also ignores the language of notes. Perfume guides, in beauty magazines such as Mademoiselle Bulle and elsewhere, describe a scent by its top, heart and base notes; the label only knows "parfum" and the allergens above the threshold. The Class on reading a perfume label, from the batch number to the period-after-opening symbol covers the rest of the box.

Which allergens must appear on a perfume label?

The allergens that must appear are the ones Annex III of the cosmetics regulation flags for mention. The original list includes names any perfume lover will run into: Limonene (entry 88), Coumarin (entry 77), Citral (entry 70) and Evernia Prunastri Extract, which is oakmoss extract (entry 91). Each must be named above 0.001% in leave-on products and 0.01% in rinse-off products.

The point is not to warn everyone. The 2023 regulation explains that limiting a substance protects people from developing an allergy in the first place, but someone already sensitised can react below the permitted levels, so the label lets them avoid the culprit. The same text estimates that between 1 and 9% of people in the EU are allergic to fragrance allergens.

Therefore, as a measure of secondary prevention, it is important to provide information on the presence of individual fragrance allergens in cosmetic products so that sensitised persons can avoid contact with the substance to which they are allergic.

What did Regulation (EU) 2023/1545 change, and when?

Adopted on 26 July 2023, Regulation (EU) 2023/1545 extends mandatory labelling to the 56 extra allergens identified by the EU Scientific Committee on Consumer Safety (SCCS) in its June 2012 opinion, with the same 0.001% and 0.01% thresholds. It also groups similar substances under one entry and sometimes specifies the exact name to print, to keep labels readable.

Two dates matter, both set out in the annex footnotes of Regulation (EU) 2023/1545. A product that does not meet the new rules can no longer be placed on the EU market after 31 July 2026, but it may still be made available until 31 July 2028. Until then, the same product can sit on a shelf with the old list and with the new one.

Many of the new names are whole natural materials. The annex now names lemon oil (Citrus Limon Peel Oil), bergamot oil, the oils and extracts of several roses, Damask and centifolia among them, all labelled "Rose Flower Oil/Extract", jasmine ("Jasmine Oil/Extract"), lavender, ylang-ylang and sandalwood, alongside molecules such as vanillin and sclareol. An essential oil is not an allergen-free material, as the Class on what chemistry brought to perfume, and what "natural" does not guarantee explains.

What are the IFRA Standards, and how do they differ from EU law?

The IFRA Standards are rules the fragrance industry sets for itself through the International Fragrance Association. IFRA's own explanation of its Standards describes three types: a prohibition bans a material, a restriction caps the quantity used or the products it may go into, and a specification sets other conditions, such as purity criteria.

Each Standard starts from a safety assessment written by scientists at the Research Institute for Fragrance Materials (RIFM) and reviewed by an independent Expert Panel drawn from dermatology, toxicology, pathology and environmental science. IFRA says the Standards are compulsory for its members, who produce around 80 per cent of the world's fragrance by volume, that they form a voluntary, self-regulating system, and that they never exempt a company from local law. Final Standards are published as amendments to the IFRA Code of Practice.

The difference from EU law is easy to state: the regulation bans, limits and dictates the label; an IFRA Standard bans, limits or specifies inside the formula and prints nothing on the bottle. A Standard also covers a substance brought in indirectly, for instance by an essential oil that contains it. As for proof that a fragrance complies, suppliers hand their customers a certificate of conformity, and IFRA itself issues none.

Oakmoss, coumarin and lemon: how do EU law and IFRA handle them?

Oakmoss shows best how the two systems overlap. Commission Regulation (EU) 2017/1410 banned atranol and chloroatranol, natural components of oakmoss and treemoss extracts, after the SCCS named them among the fragrance allergens behind the highest number of contact allergy cases; since 23 August 2019, a cosmetic containing them cannot be placed on the EU market. The extract itself must still be labelled, and IFRA gives it a separate Standard, published in January 2020. The oakmoss note page and the chypre family describe the smell behind these rules.

Coumarin is on the original list (entry 77 of Annex III), and the IFRA Standards library lists it as a restriction, in a version published in January 2020 with the 49th Amendment. Lemon falls under both systems in another way: limonene, the major component of the essential oil of citrus peel and named after the Italian for lemon according to Wikipedia's article on limonene, has been labelled since the original list, and lemon oil itself joins it under the 2023 regulation. On the IFRA side, limonene carries a specification and cold-pressed lemon oil a restriction.

Name on the label	Material	EU cosmetics regulation	IFRA Standard (type, published)
Evernia Prunastri Extract	Oakmoss extract	Entry 91, labelled before 2023; atranol and chloroatranol banned	"Oakmoss extracts" Standard, January 2020
Coumarin	Coumarin	Entry 77, labelled before 2023	Restriction, January 2020
Limonene	Limonene	Entry 88, labelled before 2023, rewritten in 2023	Specification, January 1995
Citrus Limon Peel Oil	Lemon essential oil	Entry 353, added in 2023	Restriction, "Lemon oil cold pressed", January 2020
Jasmine Oil/Extract	Jasmine oil or extract	Entry 357, added in 2023	Restriction on jasmine absolute (grandiflorum), January 2020
Cananga Odorata Oil/Extract	Ylang-ylang oil or extract	Entry 347, added in 2023	Restriction, "Ylang ylang extracts", January 2020

What an allergen on the label does not tell you

An allergen on the label signals presence, not a risk to you personally. It gives no dose beyond the threshold and no origin: limonene, also found in the scent of many conifers and broadleaved trees, can come from lemon peel or from another plant. A product with nothing after "parfum" is not allergen-free either; it may contain some below the threshold.

The label is not medical advice. If your skin reacts to a scented product, a GP or a pharmacist is the person to work out which substance is involved, and the packaging you kept will help them.

Exercise: read three labels from your bathroom

You need three products you already own, and nothing goes on your skin. The aim is to link a name on a label to an impression of smell, then check it.

1. Pick a rinse-off product (shampoo, shower gel), a leave-on product (body cream, deodorant) and a perfume or eau de toilette.
2. Before reading anything, smell each one at the neck of the bottle or on a paper blotter, and write down three words: zest, hay, flower, wood, soap, whatever comes.
3. Now read the list. Find "parfum", then the allergen names, such as Limonene, Linalool, Coumarin, Citrus Limon Peel Oil or Jasmine Oil/Extract.
4. Set your three words against those names. Does a Limonene go with your zesty impression? A flower name with your floral one? The club's note pages help you check.
5. Count the allergen names on each product. If two copies of the same product carry different lists, one may have been placed on the market before 31 July 2026.

Share what you find in the Learning to Smell circle: putting everyone's labels side by side shows quickly how much the lists vary.