Guides / Fragrance oil on a soap label
How do I list a fragrance oil on a soap label?
Published 22 September 2026; rules last checked 25 September 2026. A labelling reference, not legal advice.
Write "Parfum" where the fragrance falls by weight, then add each declarable allergen the oil brings above the threshold, by the name Annex III gives it. Article 19(1)(g) of the cosmetics regulation says perfume and aromatic compositions "shall be referred to by the terms 'parfum' or 'aroma'", and that the substances the Annex III "Other" column requires you to mention "shall be indicated in the list of ingredients in addition to the terms parfum or aroma". The blend inside the oil stays a trade secret; the allergens do not. For a bar of soap the threshold is 0,01 % of the finished product, and the list you check against depends on where you sell.
Step one: the word
Whatever the bottle is called, on the label it is "Parfum" (or "Aroma"; "Parfum" is the usual choice for soap). It is one ingredient among the others, placed in descending order of weight at the time it was added, with the reminder that ingredients under 1 % may be listed in any order after those over 1 %. A fragrance at 3 % of a batch goes after every ingredient heavier than 3 % and ahead of any lighter one that is still above 1 %; colourants may follow the rest in any order. Article 19(6) requires the glossary's common ingredient names, and "Parfum" is entry 19071 in the EU glossary (16644 in the older one Great Britain still uses).
Step two: the allergens
Your fragrance supplier gives an allergen declaration for the oil: a sheet listing which of the declarable substances it contains and at what percentage of the oil. That sheet is the input. For each substance, the percentage in your soap is the percentage in the oil multiplied by the oil's share of the batch:
| Substance in the oil | Share of the oil | Oil at 3 % of the batch | Above 0,01 %? |
|---|---|---|---|
| Linalool | 12 % | 0,36 % | yes, declare |
| Limonene | 2 % | 0,06 % | yes, declare |
| Geraniol | 0,2 % | 0,006 % | no, stays inside Parfum |
The label for that batch ends "..., Parfum, Linalool, Limonene". The figures are illustrative; the method is the regulation's. Two habits keep the figures right: use the supplier's sheet for that oil and that batch, because allergen content varies between suppliers and between lots, and if the same substance arrives from two sources (a fragrance oil and an essential oil, say) add the two contributions together before comparing with the threshold.
Cold-process soap needs one more step when a substance is close to the limit. The bar you sell has lost water while it cured, so it weighs less than the batch did and every substance is a larger share of it: one just under 0,01 % of the batch can be over it in the cured bar. Work its share out from the cured weight. The soap tool does this when you add the batch's cured weight to the recipe, and names any substance close enough to cross.
Which list you check against
- EU and Northern Ireland. Annex III as amended by Regulation (EU) 2023/1545: more than 80 declarable substances, up from the familiar 26 (24 still in force by 2023). The new declarations are mandatory for products placed on the market from 1 August 2026; products already on the market may be made available until 31 July 2028. Many supplier sheets and many free label tools still stop at the old 26, so check that the sheet you are given covers the current list.
- Great Britain. The assimilated Annex III has not been amended by 2023/1545, so the GB list is the older 25-entry one, with one substance of its own: Hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC), whose old row Great Britain never deleted, although the GB Annex II, like the EU one, prohibits HICC in cosmetics altogether (entry 1380), so an oil that contains it cannot go into a soap sold in either market. Selling in both places means checking against both lists. The full comparison is on the allergen reference index.
- United States. "Fragrance", and no allergen list, under 21 CFR 701.3(a); and true soap under 21 CFR 701.20 needs no ingredient list at all.
What the names must look like
The declarable substances are listed by the name in Annex III, which is the glossary name: "Linalool", "Limonene", "Citral", not the CAS number and not the supplier's shorthand. Some entries cover more than one name and tell you which to print: the citral entry, for example, covers the isomers geranial and neral, and the label says "Citral". Our tool holds those mappings so that a supplier sheet written in isomer names still produces the label name.
Related questions
My supplier's sheet lists allergens I cannot find on the EU list. Do I list them?
Only substances on the list in Annex III carry the declaration condition, so an allergen that is not on your region's list stays inside the word Parfum. Our tool checks every name you enter against the sourced list for the region you choose and tells you which ones are declarable, which are declarable elsewhere, and which it does not recognise.
Does an essential oil count as fragrance?
Article 19(1)(g) says perfume and aromatic compositions and their raw materials are referred to by the terms parfum or aroma, and lists the declarable substances they contain alongside. An essential oil added for its scent is such a raw material, so our tool declares it as Parfum plus its declarable allergens, and keeps the oil's glossary name in a note for your records. Since Regulation (EU) 2023/1545 some essential oils are declarable substances themselves: for lavender, sweet orange, peppermint and lemongrass oil the tool also names the oil, in the EU and Northern Ireland, by its Annex III name (lavender is "Lavandula Oil/Extract") once it is over the threshold. For another listed oil, add its Annex III name to the allergen figures at 100 %. Makers who also list the oil's botanical name are adding information, not replacing the term.
What is the rinse-off threshold for soap, and why is it ten times higher than for a lotion?
The Annex III entries set the declaration condition at a concentration exceeding 0,001 % in leave-on products and 0,01 % in rinse-off products. Soap is rinsed off, so the 0,01 % figure applies; a lotion stays on the skin, so the stricter 0,001 % applies to it.
What do I write in the United States?
If the product is a cosmetic, 21 CFR 701.3(a) allows fragrance to be listed as "fragrance", and there is no list of individual allergens to add; the FDA's rulemaking on fragrance allergens under MoCRA had not produced a rule at our last check. If the bar meets the FDA's definition of soap in 21 CFR 701.20 and is sold only as soap, no ingredient list is required at all.
Tell me when the allergen list changes
The declarable list is the part of this answer that moves. It last changed with Regulation 2023/1545 and was checked again in August 2026. When it changes next, 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: Articles 14(1)(a), 19(1)(g) and 19(6); Annex II, entry 1380 (HICC, prohibited); Annex III, the entries carrying the declaration condition in the column "Other"
- Commission Regulation (EU) 2023/1545 (CELEX 32023R1545), whose recital (5) counts 24 individually labelled before it, which replaced and added the fragrance-allergen entries of Annex III and set the transition: products placed on the market from 1 August 2026 must carry the new declarations, products already placed may be made available until 31 July 2028; and Commission Regulation (EU) 2026/909, checked 21 August 2026, which left the declarable list unchanged
- 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 (entry 1380, HICC, prohibited), legislation.gov.uk, text current to 15 August 2026
- Commission Implementing Decision (EU) 2025/1175, the glossary of common ingredient names (in application from 30 July 2026): entry 19071 (Parfum)
- Commission Decision (EU) 2019/701, the glossary of common ingredient names as it applies in Great Britain (assimilated law), legislation.gov.uk: entry 16644 (Parfum)
- 21 CFR 701.3(a) (ingredient declaration; "fragrance") and 21 CFR 701.20 (the soap definition), eCFR, title 21 current to 30 June 2026; FDA, fragrance-allergen labelling under MoCRA, no final rule at 10 August 2026
The documents this answer rests on. A labelling reference, not legal advice; you remain responsible for your product's labelling.