Fragrance Allergen Update

There is some news on the Fragrance Allergen front! Finally.

MoCRA Fragrance Allergens

If you’ve been following me or keeping track of the MoCRA requirements, then you know that one of the pieces of MoCRA was that fragrance allergens are supposed to be declared on the product label.

Which fragrance allergens? Well, the FDA was supposed to have issued proposed regulations within 18 months of MoCRA’s approval — that would have been June 22, 2024. So, two years ago. Obviously, that didn’t happen. They kept putting off the date.

Well, the Unified Agenda was just issued for 2026. It’s the list of all the proposed upcoming regulations and deregulations in the whole federal government. Our fragrance allergen regulations are in there — and the current summary says they are moving the date to November, 2026.

We’ll see. Hopefully this is the last time they move the date.

EU Fragrance Allergen List

Several years back, the EU expanded its list of fragrance allergens that must be declared on a cosmetic label if they were present in more than 0.001% in a leave-on product or more than 0.01% in a rinse-off product. They added 57 new reportable allergens, taking the list from 24 to 81.

A phase-in period was allowed … and that’s up July 31, 2026. As of August 12, 2026, the product label of a cosmetic introduced in the EU must declare any of the 81 fragrance allergens present in the product.

I expect that most of my readers are making and selling products in the United States, so that’s not too big a deal. If you’re in the US, you don’t need to declare all the EU allergens.

But, if you sell products into California or to California residents …

California Product Registration

California has regulations that cover products containing fragrance allergens that are sold in California or California residents. That means that if you have a website and you ship your products to a person in California, the regulations apply to you.

The California regulations require that you report any cosmetic products containing fragrance allergens (if you sell them in California or to California residents). They follow the EU standards for fragrance allergens. Since those are going into effect July 31, that means that the list of reportable fragrance allergens in California jumps to the full 81 allergens on the same day. Boom.