Guides / Fragrance allergen calculator
Fragrance allergen calculator for soap and cosmetics
Published 26 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.
A fragrance allergen must be named on the label once its share of the finished product passes 0.01% in a rinse-off product such as soap, or 0.001% in a leave-on product such as a lotion. Its share is its percentage in your fragrance, from the supplier's allergen declaration, times the fragrance's percentage of the product. The calculator below does that for each substance and checks the name against the current list for where you sell.
The calculator
The example figures are illustrative: replace them with your supplier's sheet. At exactly the threshold the calculator says to name the substance; Annex III says "exceeds", and naming it at the boundary is the safe side.
How it decides
- The threshold depends on the product type: 0.01% of the finished product for rinse-off, 0.001% for leave-on. Soap counts as rinse-off.
- Cold-process soap loses water as it cures, so a fragrance at 3% of the batch is a little more of the cured bar. When a substance comes out close to the limit, enter the fragrance's share of the cured bar.
- The names are checked against the list for where you sell. Some entries group several names: a supplier sheet that gives Geranial and Neral is counted together as Citral, on both lists, and Citral is the name that goes on the label.
- Substances that are banned outright are flagged rather than calculated: HICC and Lilial were both on the old list of 26, and both are now prohibited in cosmetics in the EU and Great Britain (Annex II, entries 1380 and 1666).
- One fragrance at a time. If the same substance also comes from another oil, add the "of the product" figures before comparing, or use the soap or skincare tool, which does it for the whole recipe.
Some essential oils are on the EU list as substances in their own right since Regulation 2023/1545. Lavender oil, for example, is declared as "Lavandula Oil/Extract". If your fragrance is such an oil, add it as a row at 100% of the fragrance, then its own allergens as further rows. The method in more detail, with a worked example, is in how to list a fragrance oil on a soap label.
Related questions
Where do the percentages come from?
From your supplier's allergen declaration for that fragrance or essential oil: a sheet that lists which declarable substances the oil contains and at what percentage of the oil. Use the sheet for the same oil and, where the supplier gives one, the same batch, because the content varies between suppliers and lots. The second number is yours: how much of the finished product the fragrance makes up.
Two of my oils both contain linalool. How do I count it?
Add the two contributions together before comparing with the threshold: the threshold applies to the substance in the finished product, from every source. Run the calculator once per oil and add the 'of the product' figures, or enter the whole recipe in the soap or skincare tool, which adds them up for you.
Why does it say a substance on my supplier's sheet is not on the list?
Only the substances Annex III lists with the declaration condition have to be named, and Great Britain still uses its older list of 25, so a substance can be declarable in the EU and not in Great Britain. A substance that is not on your list stays inside the word Parfum. If the name should be on the list, check its spelling against the supplier's sheet: the calculator knows every name on both lists, including the grouped ones such as Geranial and Neral, which both lists count as Citral.
Does this apply to products sold in the United States?
Not yet. MoCRA (21 U.S.C. 364e(b)) will require the fragrance allergens FDA identifies by regulation to be named, and that regulation is not in force. Until it is, a US cosmetic declares its fragrance as 'Fragrance' (21 CFR 701.3(a)), with nothing itemised.
Tell me when the allergen list changes
The list and the thresholds are the parts of this page that move. They last changed with Regulation 2023/1545 and were checked again on 25 September 2026. When they change, we will email you.
No spam, no account. One email when a rule behind your labels changes. How we handle your address is in the privacy policy.
Sources
- Regulation (EC) No 1223/2009 on cosmetic products, consolidated 18.05.2026, CELEX 02009R1223: Article 19(1)(g); Annex III, the entries carrying the declaration condition; Annex II, entries 1380 (HICC) and 1666 (Lilial)
- Commission Regulation (EU) 2023/1545 (CELEX 32023R1545): the expanded list, mandatory for products placed on the market from 1 August 2026, and in recital (7) the 0.001 % and 0.01 % thresholds
- Regulation (EC) No 1223/2009 as it applies in Great Britain (assimilated law): Annex III (the 25 entries carrying the declaration condition) and Annex II (entries 1380 and 1666), legislation.gov.uk, checked 25 September 2026
- 21 CFR 701.3(a) and 21 U.S.C. 364e(b) (United States)
The documents this answer rests on. A labelling reference, not legal advice; you remain responsible for your product's labelling.