Why does an EU label name more fragrance ingredients?

Buy the same shampoo in London and in Chicago and turn both bottles over. The European one may name half a dozen substances the American one does not. Neither is lying, and the formula may be identical.

The US position

One clause does the work. A US cosmetic must declare each ingredient by name, “except that fragrance or flavor may be listed as fragrance or flavor”.

So a composition of many substances may appear as one word, and there is no threshold at which that stops being permitted.

The EU position

The starting point is the same. The Commission’s guidance notes that “Perfume and aromatic compositions and their raw materials can generally be listed as ‘parfum’ or ‘aroma’ in the list of ingredients.”

Then it diverges: “However, certain fragrance allergens must be identified individually on the label when they are present above specified concentration thresholds.”

Those thresholds are specific. Disclosure is required “when its concentration exceeds 0.001% in leave-on products or 0.01% in rinse-off products”.

What changed, and when

This is not a settled old rule. Commission Regulation (EU) 2023/1545 “amended Annex III to the Cosmetics Regulation to strengthen the individual labelling of fragrance allergens”, and it “introduces individual labelling requirements for 56 additional fragrance allergens”.

The compliance date has passed. Products that do not comply “may no longer be placed on the EU market” since 31 July 2026, and stock placed on the market before that date “may continue to be made available on the EU market until 31 July 2028”.

So for the next two years an EU shelf will hold both kinds of label, and the longer list is the newer one.

What it means for you

If you know you react to a particular fragrance material, an EU label is more likely to tell you it is there. Limonene, Linalool and Geraniol are the ones most people meet first, and all three are common enough that seeing them named is not a signal that a product is unusually perfumed.

On a US label the same materials may sit inside the word fragrance, which is one of three ways an ingredient can legally be absent from a US list. The other two are here.

The stated purpose of the EU rule is narrow and worth quoting for what it does not claim: the requirements “allow consumers who are sensitised to particular fragrance allergens to identify and avoid products containing those substances”. It is a rule about information for people who already know they react, not a finding that these substances are dangerous to everyone.