Blended Fragrances in the Ingredient Declaration

One of the options available for your cosmetic ingredient list is to use the term “fragrance” to cover any ingredient(s), blended or not, that are used to scent your product. But what if you use a blend of plant-based essential oils to provide scent, not synthetic “fragrance oils”? The rule still applies, but you have some additional options.

The Regulations

The actual regulations for cosmetics say that you must provide an ingredient declaration that includes all of the ingredients listed in descending order of predominance.  Unlike foods, where sometimes the label lists the ingredients of an ingredient in parenthesis, on cosmetic labels ALL the ingredients must be listed separately, including the individual components of a blended ingredient.  For example, if you add a preservative that is a blend of several components, EACH of the components must be listed separately on the list.

That is, except for fragrances.

The label on each package of a cosmetic shall bear a declaration of the name of each ingredient in descending order of predominance, except that fragrance or flavor may be listed as fragrance or flavor. … No ingredient may be designated as fragrance or flavor unless it is within the meaning of such term as commonly understood by consumers. [Emphasis added.]1

Apparently the fragrance (and flavor) industry had some considerable sway when the regulations were being created.  Unlike other blended ingredients, they don’t need to disclose the components in their fragrances.

Using Proprietary Fragrance Oils

If you are using proprietary fragrances (typically, but not always blends of synthetic fragrance substances), the regulations are pretty handy because the manufacturer won’t (and doesn’t have to) tell you all the components.

Just calculate where the fragrance oil goes in the ingredient declaration and place the word “fragrance” there.

Remember, it’s just the single word “fragrance,” not the name or scent.

Using Essential Oils

Essential oils are usually purchased individually and then combined to make unique fragrances.

Considered one way, when you put several different essential oils into your cosmetic, you are adding individual ingredients, which would need to be listed in the ingredient declaration.

Considered the other way, when you combine the essential oils, you are making your own blended fragrance, which falls under the exemption for disclosing the ingredients – so you could list the whole as “fragrance”.

Either way would be correct – so how do you decide which to use?

Listing the oils individually

Listing the oils individually, particularly if you actually add them one at a time, is generally pretty easy.  You know the exact percentage as part of your master recipe, so can easily place it in the ingredient declaration (and remember that ingredients present at 1% or less may be listed in any order after ingredients present at more than 1%).

In addition, since botanical ingredients (which includes plant-based essential oils) should be listed by the common name, it’s pretty easy to list them.

So if you had .5% lavender essential oil, .4% rosemary essential oil and .3% peppermint essential oil, each one would be listed in any order after the ingredients present at more than 1%.  Being a little tricky, you could scramble the order which would help protect your formula (not much, but a little, anyway).

This method also has the advantage (or possibly disadvantage) of telling the consumer exactly what is in the cosmetic product.

Using “Fragrance” in the ingredient declaration

Using “fragrance” to encompass the entire essential oils blend is the easiest, especially if you mix up your essential oil blend in advance.  It also makes for the shortest ingredient declaration if space is an issue.

In using this method, when placing the word “fragrance” in the ingredient declaration, you do it based on the total amount of the blend used.  Taking the above example, the total blend is 1.2% of the whole. Placing it means that it goes with the ingredients present at more than 1%.

What if it’s important that it’s essential oils?

In some markets, consumers don’t know and don’t care about the different between a synthetic fragrance oil and a plant-based essential oil; they only care if it smells like watermelon, or peppermint or just something they really like.

In other markets, simply the idea of using a synthetic is abhorrent; synthetic fragrances must be avoided at all costs.  In that case, you might think the word “fragrance” in the ingredient declaration could be a purchasing deterrent.  There are, however, ways to mitigate the down-sides, and maybe even turn it to your advantage.

How? With marketing text.

Remember, in addition to the required items on cosmetic labels, there should be plenty of room for other content … marketing text to sell your product.  For example:

  • Under the ingredient declaration, say something like “We only use pure plant-based essential oils to scent this lotion.” (Or whatever works for you).
  • On the front, say “Scented with plant-based essential oils”
  • If you don’t mind telling which essential oils you’re using, you could include that information in any description you have on the product label.

And there are probably plenty of other ways to get the data to your customers.

Whether you list the oils individually or used the term “fragrance” and provide additional information in marketing text, you can still provide your customers with the information they need to decide to purchase your product above all others.

A note about the future

It is not surprising that closing this “disclosure loophole” (as some perceive it) is one of the issues being bandied around in the discussions for additional cosmetic regulations.  Over the years, wording requiring the disclosure of fragrance components has come and gone in proposed legislation (none of which has been approved).

Meantime, no doubt the flavor and fragrance industry is working hard to protect their proprietary blends from disclosure, and the truth-in-labeling folks are working hard to require full information on labels.

Whatever the result, if/when legislation is actually passed, you’ll have plenty of time to make any necessary changes to your labels.

References   [ + ]

1. 21 CFR 701.3(a)


  1. Marie, Is it OK to put Oils, water, sodium hydroxide, etc, Fragrance *, whatever colors, and then after all of the other ingredients put (* Essential oils)

    Thanks for another informative article!

  2. Author

    I have seen that done (the * for additional information). Typically, it’s done for organic ingredients. I haven’t seen anything that says that it CAN’T be done … so it might be a decent solution. I would be sure to clarify what you mean by “essential oils” if you are selling to a less informed customer base. Maybe “plant-based essential oils” or something like that.

  3. Marie, what about listing specific compounds found in essential oils like linalool and eugenol. I see many companies listing these based in IFRA guidelines. Is this required or optional?

    1. Author

      There are no regulations in the US that certain compounds must be listed if present at particular levels; the only requirement is that the ingredient is listed correctly in the ingredient declaration.

      However, the European Union has Regulations EC No 1223/2009 on Cosmetic Products (found here) contains Annex 3 “List of Substances which comsmetic products must not contain except subject to the restrictions laid down”. Linalool, for example, is in Annex 3 (#84) with the restriction that it must be indicated in the list of ingredients if it’s present at more that 0.001% in leave-on products or 0.01% in rinse-off products.

      Companies that sell in the EU and US tend to try to follow both sets of regulations.

  4. Hello Marie,

    I am considering buying “Natural aromas/scents” for production of skin care. According to the small supplier, they do not contain essential oils but contain natural essence or extractives obtained from plants. Therefore, products can be advertised as “fragrance free” .

    Basically, they say they are made of Sunflower seed oil with natural and organic flavorings.

    When I asked how to list this kind of material in an INCI, this is the reply I got:

    “Use the word flavor if it is a product for the flavor (lip balm) and use the word scent or aroma if it is in the product for the scent.
    Any item used at 1 % or less can be listed in any order below the 1% cut off. If you are using the scent above 1% list the sunflower at the percent you are using and the scent at the end of the list.”

    So, in few words, if for example I use 2% of it my INCI will be something like:
    Water (Aqua), bla bla bla, Helianthus Annuus (Sunflower) Seed Oil, bla bla bla , AROMA.

    My question is: can I use the word Aroma or Scent, as they suggest?

    Many thanks for clearing this up.. I am very confused!

    1. Author

      In the US, the word “fragrance” must be used (not “aroma”). Also note that just because they are “natural” it doesn’t mean that the product can be advetised or characterized as “fragrance free”. Generally, “fragrance free” means that the product doesn’t have a SMELL, not that it is free of “fragrance oils” (ie synthetic aroma blends).

      1. Thank you Marie!

        So, how do you differentiate in an INCI between Fragrance, as in synthetic aroma blends/fragrance oils, and Fragrance as in natural aromatic extracts (it is clear they don’t want to release the info on what kind of extracts are in the blends. They only say they are not essential oils)

        Thank you again

      2. Author

        You would have to rely on the information provided by your supplier if you wanted to identify the ingredients of the fragrance. For the ingredient declaration, you would be compliant with “fragrance” in the declaration.

  5. Ok, thank you …I understand. Since they will not release that info I will just look for another small supplier. I find the whole “write aroma in your INCI” very shady…but yet I was hoping for it to be legit, as I am looking for aromatic plant extracts that are not considered “fragrance”, from an INCI point of view.
    Ps, I bought your book on GMP and it is great! Thank you!!

  6. I’m happy that I found this article – very clear and informative – thank you! I’m currently formulating my own essential oil blends for a skin and hair care line that I’m coming out with. Not only would I like to keep some of the blends a secret (as it’s been a work in progress to come up with something unique), but space is so limited on some of my tiny containers! For example, I will have tiny dram bottles to sell along with some diffuser jewelry that I’ve created. I will also use these for sample/trial sizes of beard oils. I can barely fit my brand label on these as it is! I’m curious if it’s ok use the newer SmartLabel on packaging? a QR code? as an alternative to trying to squeeze in the ingredients. This way the consumer can scan to get all the information – ingredients, usage instructions, and additional information on the product! Is it ok to have the dram bottle attached to a biz card for example, that could either list ingredients, or have the QR code to direct to them to the website for information?

    Thanks for you time, and sharing your knowledge!

    1. Author

      I believe that a newer SmartLabel might work, but you will have very high costs to do it. I don’t know what the requirements are for being able to open and look at the ingredients.

      Small packages can be attached to a card which has all the required information. QR codes are not an acceptable alternative, unfortunately.

      To keep the amount of text down, you can use the term “fragrance” to cover all of the fragrance components ( so you wouldn’t have to list the essential oils used for the scent individually). Also remember that in the US the Latin names for botanicals are not required, only the English Common Name, so that can reduce down the amount of text as well.

      There are some uncommon execptions to the labeling rules if the product is ONLY sold mail order (never face-to-face).

  7. What does it really mean when ingredient listing says, “Fragrance (Essential oil blend)?” Does that mean synthetic oil or real essential oils being used?

    1. Author

      “Fragrance” is the term official used in the ingredient declaration to identify any/all “fragrance components”. Generally “blended” cosmetic ingredients require that the individual components are listed separately in the ingredient declaration. However, for fragrances, there is a special rule, which allows the use of the term “fragrance” in the ingredient declaration; all of the individual components do not need to be listed (and usually fragrance companies won’t say what is in the fragrance anyway).

      A fragrance can be made of up synthetic, plant-based, or “nature idential” components. If the company labeling the product clarifies that it is “an essential oil blend” then you could assume that it’s made with essential oils.

      The FDA doesn’t like “descriptive” terms in the ingredient declaration – so actually putting “(essential oil blend)” in the ingredient declaration is incorrect. The statement should be made elsewhere on the package.

  8. Can I use the “Fragrance” for the synthetic part and the name of essential oils that are in the same fragrance separately on the IL?

    1. Author

      You can list the essential oils as “ingredients” and also list “fragrance” to cover all the other fragrance components.

    1. Author

      In the US, allergens (peanuts, soy, milk, etc) are not required on cosmetics. Outside the US, the regulations are different — there are certain allergens that must be listed, but they don’t generally include the same allergens as in food.

  9. Great article! Thabks Marie. Just wanting to clarify – essential oils used therapeutically in skincare need to be listed individually. Only those used SOLELY for fragrance can be listed as “fragrance” ? I would like to transition into perfume blends. I was looking at a brand the other day that basically ĺlsted it’s perfume fragrance as “proprietary blend of essential oils”. So that is acceptable for a natural perfume? Thanks

    1. Author

      Good questions.

      Firstly, in COSMETICS, essential oils cannot be used therapeutically … there is no therapy in cosmetics. So in cosmetics, the smelly essential oils are always for the scent. They may be listed individually as ingredients, or lumped under the name “fragrance”.

      “Proprietary blend of essential oils” is not a valid ingredient name — in the ingredient declaration. In the declaration it is “fragrance” … that IS a proprietary blend of fragrance components.

      If the fact that tthe fragrance is made up of only plant-based fragrance components is important for your marketing, that can be stated anywhere on the label or in the labeling – as marketing. It shouldn’t be part of the ingredient declaration. (Although you could do it with an asterisk and a footnote.)

  10. Hi Marie, thanks so much for the write-up. I’ve seen some beard oils with the term “essential fragrance blend” or “essential fragrance oil blend” or ” essential/fragrance oil blend” written at the end of their IL. Are any of these labelings appropriate? Thanks!

    1. Author

      No, those are not correct according to the regulations. Cosmetics require all of the ingredients to be listed in the ingredient declaration. The ONLY exemption is that components of the fragrance or flavor do not need to be listed BUT the fragrance or flavor must be listed as “fragrance” or “flavor” (as applicable) …. nothing else.

      Usually people use the phrases “essential oil blend” or “essential frangrance oil blend” or “essential/fragrance oil blend” when they are trying to promote that the product contains essential oils. The correct way to do so would be to either list the individual essential oils OR to state “fragrance” in the ingredient declaration and then say – somewhere else on the label – that the product is scented with essential oils or “plant based fragrance components” or whatever. That should be MARKETING text, not part of the ingredient declaration.

  11. Thank you Marie for answering all of our questions, even if repetitive, so patiently :<). So, I now have a definite understanding that you can avoid disclosing your Essential Oil (EO) recipe/blend, in even body butters by deeming it as "Fragrance" in the ingredients making it cosmetic, avoiding the disclosure requirements for drug or therapeutic products- if that’s right. So now, If you still want to draw attention to the possible therapeutic benefits from the "fragrance" made from "plant based EO" can you include in the "Marketing text" for let’s say, a blend that’s helps with congestion, “Scented with plant-based essential oils that may help you Breath Easier"?
    Thanks so much for your time!

    1. Author

      No – marketingtext for cosmetics may only promote that the product (or the ingredients) are intended to beautify, cleanse or promote attractiveness. You can say that the product contains eucalyptus essential oil, but you can’t say that eucalyptus oil does (or may) affect anything having to do with the function or structure of the body (drug claims).

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