Why Some Ingredient Lists Now Show 80 Fragrance Allergens, and US Labels Still Don't

Do cosmetic brands have to list every fragrance ingredient now? Not in the US. If you've noticed a long block of unfamiliar chemical names under "fragrance" on a product lately, especially anything also sold in Europe, that's a real rule already in effect. It's just not an American one.

Two rules, two timelines

Fragrance has long been the one ingredient category a brand doesn't have to spell out. A label can say "fragrance" or "parfum" and legally mean a mix of dozens of individual chemicals, none of them named.

Two different governments are closing that gap, on two different schedules.

The EU amended its Cosmetic Products Regulation (Commission Regulation (EU) 2023/1545) to expand the list of fragrance allergens that must be named individually in the ingredient list, from 26 substances to roughly 80. New products placed on the EU market after July 31, 2026 have to comply.

The US passed MoCRA (the Modernization of Cosmetics Regulation Act) back in 2022, which directed the FDA to write a similar disclosure rule, with a deadline of December 29, 2025. The FDA missed that deadline. As of this writing, there is still no finalized US rule, and industry trackers expect a final version in 2027 at the earliest.

What the EU rule actually requires

Once a fragrance allergen is present above a set concentration, it has to appear by name in the ingredient list, not buried inside "fragrance."

• Leave-on products (lotion, perfume, lipstick, deodorant): disclosure required above 0.001% concentration.
• Rinse-off products (shampoo, body wash, soap): disclosure required above 0.01% concentration.

That is a low bar. A trace amount of something like linalool or limonene, both common in essential oils and synthetic fragrance alike, is enough to trigger a listing. Canada has been moving on a similar timeline, expanding its own required allergen list for new products through 2026.

Where that leaves a US shopper

If you buy a product made for the US market only, "fragrance" can still legally hide its full ingredient list. Nothing about MoCRA changes that yet.

If you buy a product also sold in the EU, or a global brand that formulates to the stricter standard everywhere, you may already see a longer allergen list on the same bottle you'd find on a US shelf. That's not the brand being unusually transparent. It's the brand complying with a law that doesn't apply here.

This is a different problem than the one covered in our piece on the fragrance loophole, which is about phthalates that legally never have to appear on any label, anywhere, under trade-secret protection. This is about allergens that are starting to appear, just not yet on products that only answer to US rules.

What to actually do with this

• A long allergen list under "fragrance" on an imported or global-brand product is a compliance artifact, not a red flag. It usually means more disclosure, not more risk.
• A US-only product that just says "fragrance" with nothing else isn't necessarily hiding more, it's just not required to say less.
• If a specific fragrance ingredient is a known irritant for you, "fragrance-free" (nothing added) is still a more reliable filter than reading an ingredient list that may or may not include it.

The takeaway

Fragrance disclosure is moving, but unevenly. Europe already requires it for most allergens as of mid-2026. The US has a law on the books directing the same outcome, and an FDA that has already missed its own deadline to deliver it. Until that changes, "fragrance" on a US label can still mean whatever the brand doesn't have to tell you.

For products already vetted for this kind of transparency, see our beauty picks.