Did You Know? Fragrance Allergen Edition

The EU Commission has formally published the list of 56 additional fragrance allergens to be added to the current 26 allergens for declaration on product labels. The regulation includes a provision to group multiple allergens under a single INCI grouping name. It is expected that there will be 15 grouping names to be released before the end of 2023. After July 31, 2026, all products containing these new allergens need to be relabeled, and all non-compliant packaging removed from commerce by July 31, 2028. The UK has not yet passed a similar regulation.

Under MoCRA, the US FDA will issue a notice of proposed rulemaking in June 2024 outlining which fragrance allergens will be required to be listed on product labels. Final rulemaking will likely be issued by the end of 2024. MoCRA references the EU framework as an option when establishing the threshold levels and the list of allergens to be disclosed on the label.

Not to be outdone, the state of California’s Cosmetic Fragrance and Flavor Ingredient Right to Know Act will likely require the reporting of these 56 fragrance allergens in early 2024.