Why the old 26 matter
The old 26 fragrance allergens were a familiar set of fragrance substances that had to be declared on cosmetic ingredient lists when present above the applicable threshold. They include names makers often see on supplier allergen declarations, such as Linalool, Limonene, Citral, Geraniol, Citronellol, Coumarin and Benzyl Alcohol.
The purpose is consumer information. A person with a known fragrance allergy can scan the ingredient list and avoid a substance they react to. The allergen line is not a marketing statement and it is not the same as a candle CLP contains line.
- Old supplier sheets may still say 26 allergens.
- Cosmetic allergens are listed inside the ingredients list.
- The calculation uses the finished cosmetic formula.
EU rules have expanded
Commission Regulation (EU) 2023/1545 expanded EU cosmetic fragrance allergen labelling beyond the old familiar group. It added many additional fragrance allergens and set transition periods so businesses can update formulas, artwork and products already on the market.
This means an old 26-allergen calculator or supplier document can be incomplete for future EU compliance. Makers selling into the EU should ask fragrance suppliers for current cosmetic allergen declarations that support the expanded list and should confirm timing with their Responsible Person or assessor.
Thresholds are different for leave-on and rinse-off
The common cosmetic declaration thresholds are 0.001% in leave-on products and 0.01% in rinse-off products for allergens that are required to be declared. A body butter, perfume oil or lip balm is generally leave-on. Soap and shower gel are generally rinse-off.
Always calculate the allergen amount in the finished product. If a fragrance is used at 2% and contains 0.8% Linalool, the finished cosmetic contains 0.016% Linalool. That exceeds both common thresholds, so Linalool would normally appear in the ingredients list where the rule applies.
- Leave-on threshold: commonly 0.001%.
- Rinse-off threshold: commonly 0.01%.
- Use the allergen percentage in the fragrance, then multiply by fragrance use level.
Do not confuse cosmetics with candles
Many indie makers sell both soap and candles, and this creates mistakes. Candle labels use chemical hazard classification and CLP rules when the mixture is hazardous. Cosmetic labels use cosmetic ingredient labelling, safety assessment and fragrance allergen declarations.
A candle SDS or CLP label is not a cosmetic allergen declaration. An IFRA certificate is helpful for checking use limits, but it is not the finished product INCI list. Keep separate folders for cosmetic fragrance documents and home-fragrance hazard documents.
Where allergens appear on the label
Declared cosmetic fragrance allergens appear in the ingredients list using their required ingredient names. They usually sit after Parfum or Aroma and among other lower-level ingredients, depending on the finished formula and ordering rules.
Do not write a separate warning such as contains Linalool unless your assessor specifically requires wording for another reason. For normal cosmetic allergen declaration, the consumer expects to find these names in the INCI ingredient list.
A practical update workflow
First, identify every fragrance, essential oil, flavour and aromatic extract used in each cosmetic. Second, obtain current cosmetic allergen data from the supplier. Third, calculate each allergen against the finished formula and product type. Fourth, update the ingredients list and artwork where thresholds are exceeded.
Finally, record which allergen document and rule version you used. When a supplier reformulates a fragrance, the scent name may stay the same but the allergen profile can change. Treat fragrance document updates as label review triggers.
Frequently asked questions
Are there still only 26 cosmetic fragrance allergens?
No for EU planning. The old 26 remain familiar, but EU Regulation 2023/1545 expanded the list of declarable fragrance allergens with transition periods.
Do fragrance allergens go in a separate contains statement?
For cosmetics, they normally go in the ingredients list using the required ingredient names.
Are essential oils exempt from allergen labelling?
No. Essential oils can contain declarable fragrance allergens and need the same finished-product calculation.
Is soap leave-on or rinse-off?
Body-cleansing soap is generally rinse-off, so the rinse-off threshold is normally the relevant cosmetic allergen threshold.
Can an IFRA certificate replace allergen calculation?
No. IFRA certificates help with safe use limits by category. You still need allergen data and finished-formula calculations for the ingredient list.