What 'Fragrance' Actually Means on Your Labels

Parfum. Or Fragrance. One word, no parentheses, nothing after it. That word is doing a lot of work.

Fragrance in products is one word with a lot behind it. By the manufacturer's own industry-association count, that one word covers a stock library of 3,691 fragrance ingredients on the IFRA 2025 Transparency List — 3,312 fragrance substances plus 379 functional ingredients possible ingredients (IFRA 2025). Independent testing of seventeen name-brand perfumes found an average of fourteen of those ingredients per product going completely undisclosed on the label EWG 2010. The EUEuropean Union now requires that any of 80 fragrance allergens that must be individually disclosed on EU cosmetic labels above the threshold under Regulation 2023/1545 listed allergens be named when present above a fixed threshold (EU Disclosure required 2023). The United States requires zero (US No disclosure rule 2026). This article is about that gap — and about the chemicals that interact with your body in ways the label was never built to show.

Fragrance in products is a legal placeholder, not an ingredient. Under FDAFood and Drug Administration cosmetic-labelling rules at 21 CFR 701.3(a), the cosmetic label must declare each ingredient in descending order — except fragrance and flavour, which the regulation explicitly allows to be listed as 'fragrance or flavor.' One word, no breakdown. The exemption was added under the Fair Packaging and Labeling ActA 1966 US law that requires consumer products to bear ingredient and quantity information on labels — the framework that governs cosmetic ingredient disclosure in the US. regulatory framework that took effect in the late 1960s, and it has not been substantively rewritten since.

The rationale is trade-secret protection for the perfume formula. A perfumer's blend can take years to develop and is treated as proprietary intellectual property. The argument made for the exemption — and still made by the IFRAInternational Fragrance Association today — is that requiring full disclosure would force perfumers to hand competitors the recipe. So the recipe goes inside the bottle. The label gets one word.

The bottle has the formula. The label has the word.

The EU works the same way at the surface. Under Regulation (EC) 1223/2009, a cosmetic label can declare 'parfum' or 'aroma' as a single ingredient. But underneath that single word the EU has, since 2003, maintained an annex of fragrance allergens that must additionally be named when present above a concentration threshold. Until 2023, that list contained 24 substances. Then the European Commission updated it.

Commission Regulation (EU) 2023/1545, adopted on 26 July 2023, expanded the EU's mandatory fragrance allergen disclosure list from 24 substances to 80 fragrance allergens that must be individually named on EU cosmetic labels above threshold under Regulation 2023/1545 (EU 2023/1545). Fifty-six new allergens were added. The disclosure threshold stayed where the old version set it: 0.001%the threshold above which a listed allergen must be individually named on an EU cosmetic label that stays on the skin (e.g. perfume, lotion) for leave-on products like perfumes and lotions, 0.01%the threshold for rinse-off products like shampoo and shower gel for rinse-off products like shampoo and shower gel — about half a milligram of one named allergen in a 50 ml bottle of perfume. Above either threshold, the allergen has to come out from behind the word 'parfum' and appear by name.

The compliance window runs through 2028. Products placed on the EU market must comply by 31 July 2026. Products already on shelves can sell through to 31 July 2028. UK retained law mirrors this through the post-Brexit Cosmetic Products Enforcement Regulations — UK manufacturers are working to the same disclosure list. The Rest of the World, including the United States, gets nothing more than the word.

The simplest reading of the EU rule is what it admits about its own subject: there are at least eighty fragrance ingredients with enough evidence of skin sensitisation to require individual labelling. Eighty is not a small number. It is also a long way short of 3,691.

Three categories show up in fragrance formulas more often than any others: phthalate solvents, synthetic musks, and listed allergens. Each has its own evidence base.

The most-used phthalate in modern fragrance is diethyl phthalateA phthalate ester used as a solvent and fixative in fragrance formulas — keeps scent from evaporating too quickly and dissolves the aromatic compounds. CAS 84-66-2. (DEP, C₁₂H₁₄O₄). DEP is not a plasticiser like its cousins — it's a solvent. It dissolves the aromatic compounds and slows evaporation so the scent lasts on skin. When the Environmental Working Group and the Campaign for Safe Cosmetics had an independent laboratory test 17 name-brand fragrance products in 2010, the lab found 12 of 17 fragrance products tested contained diethyl phthalate contained DEP EWG/CSC 2010. The concentrations ranged from 30 ppm at the low end to 32,000 ppm of diethyl phthalate measured in Eternity for Women — the highest DEP concentration in the EWG/Campaign for Safe Cosmetics 2010 testing of 17 name-brand fragrances in Eternity for Women — three percent of the bottle by weight, undeclared on the label. Across the 17 products, an average of 14 secret chemicals went unlisted per product. American Eagle Seventy Seven topped the count at 24 hidden ingredients.

The phthalates article covers the broader endocrine biology — the suppression of fetal testosterone, the male reproductive findings. DEP sits inside that family but its specific regulatory status is the loophole the family pivots on. REACHRegistration, Evaluation, Authorisation and Restriction of Chemicals — the EU's chemical safety framework Annex XVII restricts DEHPDiethylhexyl phthalate, DBPDibutyl phthalate, BBPButylbenzyl phthalate, and DIBPDiisobutyl phthalate in cosmetics and toys at low limits. DEP is not on the list. California's Toxic-Free Cosmetic Act (AB 2762, signed 30 September 2020) prohibits DEHP and DBP in cosmetics from 1 January 2025 alongside formaldehyde, paraformaldehyde, methylene glycol, and thirteen named PFAS substances (California AB 2762). DEP is not on that list either. The chemical that 12 of 17 mass-market fragrances actually contain is the chemical the regulator did not ban.

The second category is synthetic musks. The natural product — extracted from a gland of the male musk deer — has been functionally unavailable since the 1970s, when the species was listed under CITESConvention on International Trade in Endangered Species. The replacements are entirely synthetic: nitromusks first, then polycyclic musks (galaxolide, tonalide), and now macrocyclic musks. The story is a regulatory cascade. Musk xylene, the most-used nitromusk through the 1980s, was identified as a bioaccumulative substanceA chemical that builds up in body tissues over time because the body cannot efficiently clear it. Often associated with persistence in fat or organ tissue. and was eventually placed on the REACH Authorisation List as a Substance of Very High Concern — effectively phased out from the EU market because no manufacturer applied for authorisation to keep it on shelves. Galaxolide (HHCBHexahydrohexamethylcyclopentabenzopyran — the most-used synthetic musk in modern fragrance and laundry products) and tonalide (AHTNAcetyl hexamethyl tetralin — a polycyclic synthetic musk used in personal care, detergents, and cleaning products) replaced it. Both are persistent in the environment and have been measured in human biomonitoring studies and indoor dust at detection rates approaching universal.

The regrettable substitution, again. The chemistry got safer in some ways and not in others. Both replacement musks are still legal everywhere. Both turn up in laundry products, perfumes, soaps, and the dust on the bathroom floor.

The third category is allergens — the eighty substances on the new EU disclosure list. Some you have heard of: linalool (lavender), limonene (citrus peel), citronellol, geraniol, eugenol (clove). Others you have not: hydroperoxides of linaloolOxidation products of linalool, formed when the lavender-derived ingredient is exposed to air. More allergenic than linalool itself — now the most common positive patch-test reaction in fragrance allergy clinics., the oxidation products that form when linalool sits on a shelf and meets air. Linalool itself is a low-grade allergen. Its hydroperoxides are a different problem entirely, and they are now the single most common positive reaction in fragrance-allergy patch testing in North America.

Fragrance is implicated in three documented routes of harm in the consumer-exposure literature: skin sensitisation (allergic contact dermatitis), migraine triggering, and respiratory irritation including asthma exacerbation. The evidence is strongest for the skin route, where peer-reviewed patch-testing data accumulates across decades.

The NACDGNorth American Contact Dermatitis Group runs pooled patch-testing across dozens of clinics in the US and Canada and publishes biennial reports on which allergens are reacting in which patients. Across the 2019–2020 cycle, fragrance mix I — a standardised eight-ingredient screening mix — produced positive reactions in 12.8% of 4,121 patch-tested patients reacted to fragrance mix I across the NACDG 2019-2020 reporting cycle of 4,121 patients tested (DeKoven et al. 2023) — the most common positive reaction among standardised fragrance markers in that cycle. The 2021–2022 cycle, published in 2025, told a slightly different story: hydroperoxides of linalool jumped to 10.1%, climbing past most of the traditional fragrance markers (Houle et al. 2025). The composition of fragrance allergy is changing — partly because clinics test for what manufacturers actually use now, and what they use now includes the air-oxidation products of common natural ingredients.

On migraine, the cleanest peer-reviewed dataset is from a US headache clinic. Kelman ran a structured questionnaire on 1,207 migraine patients diagnosed under ICHD-2International Classification of Headache Disorders, 2nd edition criteria. He asked them what triggers their attacks. Of the 75.9% who reported at least one consistent trigger, perfume or odour was named by 43.7% of 1,207 migraine patients named perfume or odour as a migraine trigger — Kelman 2007, sixth most common trigger after stress, hormones, missed meals, weather, and sleep disturbance of patients (Kelman 2007). It ranked sixth out of fifteen named triggers, behind stress (79.7%), hormones (65.1% in women), missed meals, weather, and sleep disturbance. Six of every fourteen migraine sufferers in his clinic could trace at least some of their attacks to a smell.

The respiratory and general-irritation evidence comes from population surveys conducted by Anne Steinemann at the University of Melbourne. In 2016 she ran a US national survey of 1,136 adults: 34.7% of 1,136 US adults reported adverse health effects from fragranced products in the Steinemann 2016 national survey — Air Quality, Atmosphere & Health reported adverse health effects from one or more fragranced products, 12.5% reported health problems specifically from fragrance vented out of a dryer, and 15.1% reported lost workdays or a job from workplace fragrance exposure (Steinemann 2016). In 2019 she replicated the design across the US, UK, Australia, and Sweden — 4,435 adults pooled. The headline finding: an average of 32.2% reported adverse health effects, with the UK at the lower end (27.8%) and the US at the higher end (34.7%). About one in three. Across four countries, four years apart, with the same instrument.

Self-report surveys have known limits — symptoms are not clinically confirmed, exposure is not measured directly, the design cannot establish causation. What they can do is establish prevalence. And the prevalence here, replicated across continents and across asthmatic and non-asthmatic populations, is high enough that it is no longer a niche complaint. The regulatory response has not caught up with the data.

Fragrance is not a single regulated chemical. The regulatory question is whether the constituents inside the word 'fragrance' must be disclosed on the label. Different jurisdictions answer this differently.

The pattern is the EU and UK on one trajectory, the US on another, and California carving out a partial regime in cleaning products and a chemical-by-chemical regime in cosmetics. The Modernization of Cosmetics Regulation Act of 2022 (MoCRAthe 2022 US law that gave FDA significant new authority over cosmetic ingredient safety, recall powers, and labelling — including a fragrance allergen disclosure provision in Section 609(b)) handed FDA the authority to write a federal fragrance allergen rule and required it within eighteen months — by 29 June 2024. FDA missed that deadline. A revised target of January 2025 also passed without a final rule. The proposed rule's public comment period closed at the end of March 2025, and as of April 2026 nothing has been finalised. The federal exemption for fragrance under 21 CFR 701.3(a) — the line that allows a US perfume label to read 'fragrance' and stop there — remains in force (FDA RIN 0910-AI90).

And the regulator acknowledges the loophole on the same page that creates it. MoCRA was the federal law that was supposed to close it. The rule that would actually close it has not arrived.

Neither term has a legal definition in the United States. In the EU, the term 'parfum-free' is loosely understood through industry guidance but not codified. What the terms have come to mean in industry practice diverges sharply.

'Fragrance-free' is the more reliable phrase but still imperfect. In conventional industry use it means no fragrance ingredients have been added to scent the product. It does not mean the product is odourless — natural plant extracts, fatty acids, and certain functional ingredients have inherent smells. 'Unscented' is closer to a marketing claim: the product is designed to read as having no scent, and the manufacturer can use other fragrance materials (often called 'masking fragrances') to achieve that.

In 2007 the NRDCNatural Resources Defense Council pulled fourteen air freshener products off store shelves — sprays, solid disks, plug-ins, including products marketed as 'all-natural' or 'unscented' — and sent them to an independent laboratory for phthalate testing. Twelve of the fourteen came back positive (Cohen et al. NRDC 2007). The concentrations spread across three orders of magnitude. The lab measured one product at over 7,300 ppm total phthalate content in one of the air fresheners independently tested by NRDC in 2007 — the highest concentration measured total phthalates — about seven grams of phthalate per kilogram of product, none of it on the label. The 'all-natural' label was on the front. The phthalates were inside.

Three things make the difference. The first is recognising that 'fragrance,' 'parfum,' and 'aroma' all signal the same trade-secret line on a US ingredient list. Where you see one, the formula behind it is undisclosed. The second is reading the EU disclosure list when you see it — the eighty allergens are individually named when present above threshold, and you do not need to know the chemistry to recognise the names. The third is treating 'fragrance-free' as a useful but imperfect signal: it lowers your odds of an undisclosed chemical, but does not eliminate them.

The eso-friendly approach on fragrance is plain: where the regulator allows silence and the chemistry includes plausible mechanisms of harm, the precautionary call is to treat 'fragrance' as a flag rather than a feature. The bottle that doesn't list it has fewer questions to answer than the bottle that hides it.

Twenty-four to eighty in one regulation. Zero to anywhere is what the United States Code of Federal Regulations still says. The bottle on the dressing table will outlast the rule that could have changed what it discloses. Until that rule arrives, the word stays on the back of the box, doing the same work it has done since 1973 — standing in for a list nobody on the buying end of the transaction is allowed to see.

The phthalates article covers the chemistry of one of the most common things hidden behind that word. The endocrine disruptors guide covers why the testing model that approved most of these ingredients was never built for them. Start with the bottle. Turn it around. Read the back. Notice what the label tells you and what it doesn't.