Blended Fragrances in the Ingredient Declaration

Blended Fragrance

One of the options available for your cosmetic ingredient list is to use the term “fragrance” to cover any ingredients (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 within 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]

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 of 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 isn’t required 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. Remember also 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 possible 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 on your label 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 example above, the total blend is 1.2% of the whole. That means it gets listed with the ingredients present at more than 1%.

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

In some markets, consumers don’t know and don’t care about the difference 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 downsides, 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 use 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.

Soap and Cosmetic Labeling cover

To really be able to create your own labels that comply with the regulations, get my book from Amazon and use it.


35 responses to “Blended Fragrances in the Ingredient Declaration”

  1. If manufacture supplying me following oil for cold diffusers.
    (1) lavender diffuser oil
    (2) Ylang Ylang diffuser oil
    (3) Geranium diffuser oil.
    I want to know do they mix other oils for dialuation? Or ther supply 100% pure oil.
    They told me that these oils are ready to use in diffusers.

    1. You would need to find out from your supplier what exactly they are selling as “diffuser oil”.

      Keep in mind that diffuser oil is NOT a cosmetic (it is not applied to the human body) so they are not REQUIRED to provide the ingredient declaration. However, a good supplier would definitely provide you with the necessary information to create a label and write safe directions for use.

  2. Hi Marie, I am making Fenugreek Oil for Hair, can you advise if i listed the ingredients in the correct way?
    Fenugreek, castor oil, olive oil and essential oils

    1. Marie Gale

      List the ingredients in descending order based on the amount in the product. Essential oils should either be listed out individually or stated as “fragrance.”

  3. I don’t know why I’m having such a hard time finding a quick answer to this question. I have essential oils of lavender, tea tree, and peppermint in my product. How do I list these on the ingredient label the right way? Just by their common names? (lavender, tea tree, peppermint)? I simplify things by including only the common names for everything else, as per the FDA website.

    You are a wealth of helpful information. Thank you.

    1. Marie Gale

      You have options.

      Simplest is just lavender oil, tea tree oil, and peppermint oil. If you know the plant part, you can include that; “lavender stem/leaf oil” or “peppermint leaf oil” etc.

      If you WANT, you can include the scientific name in parentheses.

      Example: lavender (lavandula angustifolia) leaf oil.

      Or you can just say “fragrance” in the ingredient declaration. If you do that, you can always say which essential oils are in the product elsewhere on the label.

  4. Hi Marie, Not sure if you can answer this, but reading stuff about cosmetics, starts getting confusing.

    I hope you can help. I’m presently making beard balm and beard oil and I’m confused on allowed usage ratios. I’ve learned (I believe) each essential oil and fragrance oils have certain IFRA standards that allow only so much of that in your product based on weight. (hope I explained that correctly). I understand that concept, but I’m confused on the over all allowance that is allowed in your end product as a whole. Basically, a total of all essential oils used and what percent can that add up to be. I’ve read it can be 1%-5% and can’t seem to get an answer or people don’t want to give away secrets LOL.

    See if this makes better sense: example recipe 4 oz recipe

    Carrier oils

    4 different essential oils/fragrance oils-

    What is the total allowed percentage of essential oils/fragranc that can be used in a 4 oz recipe as long as each e/o IFRA standard is met. As stated I’ve read between 1-5% and not sure where that number is coming from. Some of my end products seem much milder in smell than commercial products that I have purchased. Any help would be great and I appreciate your time. Not sure if this is your expertise. Thank you Mark

    1. I did some research to answer your question. The most recent version of the IFRA standards (49th, 2020) was updated to include a new risk assessment model and a new way to assess systemic toxicity based on an “aggregate exposure model”. As a result, there were a lot of changes. So if you are looking at information or recommendations from the older IFRA publications (prior to January 2020), the data will be incomplete or incorrect.

      IFRA standards are based on the chemical fragrance components, although some essential oils have their own stand-alone standards. Every EO has different fragrance components, usually in pretty small amounts. Some of those fragrance components may be restricted (or prohibited). So FIRST you have to determine WHICH restricted components (if any) are in the essential oil(s) you want to use, and at what percentage.

      SECOND, you have to determine the maximum allowed amount of the restricted fragrance components. That differs depending on the type of product. A leave-on cream has a lower limit than, say, rinse-off soap. Beard oil could fall under Category 5 (facial products, leave-on) or Category 7 (hair products, leave-on). But the IFRA standard says to use the most restictive category, so it would be Category 5.

      Then you have to do the math to calculate the amount of combined restricted components in the EO blend you want to use and compare that with the amount of product, and make sure the total amount of restricted components that winds up in the product is LESS than the maximum amount allowed.

      For example (using just Lavender oil):

      According to the IFRA information (Annex 2) Lavender (Lavandula angustfolia) contains several components that have IFRA standards:

      1-Octen-3-yl acetate at 0.9%
      Geraniol at 0.2%
      7-Methoxycoumarin at 0.01%.

      Category 5 products allow:
      1-Octen-3-yl at maximum of 0.38% as a dermal sensitizer
      Geraniol at maximum of 1.2% as a dermal sensitizer
      7-Methoxycoumarin at 0.01% is allowed so long as it is not more than 0.01 in the finished product. Since it’s only present at 0.01%, we don’t have to calculate it (lavender oil straight would be okay based on those numbers).

      The lowest other one is 1-Octen-3-yl, so we work with that.
      .38% allowed, .9% in lavender oil.
      Using 100 ounces of product (since 100’s are easier to deal with), the final product batch could contain .38 oz of 1-Octen-3-yl.
      42.22 ounces of Lavender Oil contains .38 ounces of 1-Octen-3-yl (.38 ÷ .9% = 42.22) (NOTE .9% = .009)

      So, based on SAFETY considerations, your product could be 42% lavender oil! Not that I recommend that, but even using that much it would still be safe.

      You mentioned you have 4 essential oils in your formulation, so you’d have to adjust the math accordingly.

      The sources for this information can be found on the IFRA Standards Documentation. The Annex I to the IFRA Standards – 49th Amendment (XLSX) is a spreadsheet of natural component substances and the IFRA Standards overview – 49th Amendment (XLSX) is a spreadsheet of the restrictions. You can also download the whole library of standards, but they are individual pdf documents and a bit harder to navigate, although they do contain more information on each standard.

      And finally: a last comment about the amount of smell that you have in your final product. Make sure to check the fragrance components you are purchasing. Some essential oils (especially those called “skin safe”) are already diluted. Check the ingredients and make sure you go to a reliable essential oil supplier.

  5. Thank you, Marie, for sharing your knowledge! We are about to order labels for a skincare oil that comes in a single-ingredient unscented option, as well as EO-scented versions. We’d prefer to have one IL that applies across the board, since our production runs are not yet large enough to justify the cost of unique labels for each scent (they’ll have a small sticker indicating the fragrance). The current idea is to list as (Primary Oil), Fragrance* with a separate line that states “*plant-based essential oil/s” or “*therapeutic grade essential oils”. However, that means our unscented would indicate that it contains EO, when it does not. Does that run us afoul of FDA regulations? Is it possible to quality the IL with something like “May contain: Fragrance”?
    Thank you in advance for your time!

    1. Marie Gale

      As you have described it, it is a correct way to do it for the scented products. You will need a different label for the unfragranced one. There is no option for “may contain” in this context. (“May contain” is used in a different way in the regulations.)

      1. Jess Roth

        Thanks for the clarification!

  6. 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. Marie Gale

      No. Marketing text 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 (those would be drug claims).

  7. 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. Marie Gale

      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.

  8. Veronica Perez

    Great article! Thanks 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. 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 should be listed as “fragrance.” That IS a proprietary blend of fragrance components.

      If the fact that the 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 text. It shouldn’t be part of the ingredient declaration. (Although you could qualify it with an asterisk and a footnote.)

  9. In Food Reg. we list allergens. Is allergens must be listed in cosmetics?

    1. Marie Gale

      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.

  10. Thank you for the clarification on labeling essential oils “fragrance”

  11. 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. Marie Gale

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

  12. Tania Segovia

    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. “Fragrance” is the official term used in the ingredient declaration to identify any and 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 their fragrance anyway!).

      A fragrance can be made of up synthetic, plant-based, or “nature identical” 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. That statement should be made elsewhere on the package as marketing text.

  13. 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. Marie Gale

      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 exceptions to the labeling rules if the product is ONLY sold mail order (never face-to-face).

  14. 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!!

  15. 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. 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 advertised 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” (e.g., 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. 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.

  16. 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. 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 cosmetic 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 is 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.

  17. 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?

  18. Lauri Strain

    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!

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