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A closer look at fragrance allergens in cosmetic products

Fragrance substances are compounds with characteristic, usually pleasant, odours that are ubiquitously present not only in cosmetic products, especially perfumes, but also in other products, such as detergents, fabric softeners, and other household products. 

These substances have the power to add a sensory appeal that enhances the consumer experience, but the attraction of pleasant scents comes with a potential downside, as they may contain allergens that pose a risk to the consumer. 

What are fragrance allergens? 

Fragrance allergens are organic compounds that have the potential to induce allergic reactions in sensitive individuals. These reactions can range from mild skin irritation to more severe responses like dermatitis. The percentage of the population allergic to fragrance allergens in the European Union (EU) can be estimated to be 1-9%. 

Common fragrance allergens 

Several fragrance ingredients are known to be common culprits in allergic reactions. Among the most frequently reported and well-recognised consumer allergens are citral, coumarin and geraniol, which are often found in essential oils. 

Regulatory measures 

Recognising the potential risks associated with fragrance allergens, regulatory authorities have implemented measures to protect consumers. In the European Union, Regulation (EC) No 1223/2009 mandates the labelling of identified fragrance allergens if they are present in concentrations exceeding 0.01% in rinse-off products or 0.001% in leave-on products. 

In 1999, the Scientific Committee on Cosmetic Products and Non-food Products intended for Consumers (SCCNFP) identified an initial set of 26 fragrance allergens (two of them are banned now) with a well-recognised potential to cause allergy, for which information should be provided to consumers about their presence in cosmetic products. 

In 2012, in response to a request from the European Commission for an update on this list, the Scientific Committee on Consumer Safety (SCCS) issued an opinion on fragrance allergens in cosmetic products stating that consumers should be informed about additional fragrance ingredients in cosmetic products, on top of those already identified. 

In 2023, Regulation (EU) 2023/1545 amending Regulation (EC) No 1223/2009 as regards labelling of fragrance allergens in cosmetic products is published, expanding the list of recognised fragrance allergens. This means that manufacturers must now disclose an even wider range of potential allergens, enhancing consumer protection.   

As of September 2023, about 50 countries were either directly referring to the EU regulatory restrictions on ingredients in their local cosmetic regulation, or continuously adapting their requirements to mirror EU ingredients regulation locally. Consequently, at least 27 countries have implemented similar allergens labelling requirements for 24/26 substances, like it was done initially in the EU. It can therefore be anticipated that many countries will either automatically adopt the new EU labelling requirements on fragrance allergens or will mirror them sooner or later in their own regulation. 

Fragrance substances in cosmetic products are a nuanced challenge, balancing the desire for pleasant scents with the need to protect consumers from undesirable effects. As consumers become more discerning and demand transparency, the cosmetic industry is likely to continue adapting to meet the evolving expectations of a fragrance-conscious yet allergy-aware market. 

References:

European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, Impact assessment study on fragrance labelling on cosmetic products – Final report, Publications Office of the European Union, 2020 

Scientific Committee on Consumer Safety (SCCS). Opinion on fragrance allergens in cosmetic products, 13-14 December 2011 

Commission Regulation (EU) 2023/1545 of 26 July 2023 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards labelling of fragrance allergens in cosmetic products 

Cosmetics Europe. Guidelines On The ‘Fragrance Allergens’ Requirements. 2023 

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