Fragrance Allergen Labeling Cosmetics Rule Will Replace "Fragrance" With Named Ingredients

The Modernization of Cosmetics Regulation Act of 2022 requires the FDA to issue regulations that turn the single word "fragrance" into a list of specific allergens on cosmetic labels. That rule has not been finalized, and the statutory deadline for a proposed rulemaking—June 29, 2024—passed without a Federal Register action anyone can point to.

MoCRA Gave FDA Its Biggest Cosmetics Powers Since 1938

The FDA describes MoCRA as the most significant expansion of its cosmetics authority since the Federal Food, Drug, and Cosmetic Act became law in 1938. The statute added section 609(b) to the FD&C Act, which mandates fragrance allergen labeling regulations. The agency's public agenda entry for regulatory identifier RIN 0910-AI90 confirms this obligation.

Current FDA labeling authority rests on two statutes: the FD&C Act and the Fair Packaging and Labeling Act. Under existing rules, fragrance and flavor compounds may be declared in descending order of predominance simply as "fragrance" and "flavor." The components may also be declared individually by their appropriate label names, but the generic option remains available. A masking agent—an ingredient used to cover the scent of other materials—can be declared by its individual name or as "fragrance" if that designation is more accurate.

The Loophole That Hides Dozens of Ingredients

The FDA acknowledges that some fragrance components may cause allergic reactions or sensitivities for some people. Yet the agency does not have the same legal authority to require allergen labeling for cosmetics as it has for food. Under current practice, ingredients may be listed generally as "fragrance" or "perfume" without identifying the specific chemicals involved.

This matters for consumers with reactive skin, sensitive scalps, or documented fragrance allergies. A single cosmetic product may contain dozens of fragrance materials—synthetic molecules, essential oil fractions, fixatives, solvents—compressed into one word on the back of the bottle. The consumer sees "fragrance." The dermatologist sees an unlabeled variable.

The Rule Congress Ordered, and the Deadline It Set

Section 609(b) of the FD&C Act required a notice of proposed rulemaking not later than 18 months after MoCRA's enactment. That deadline was June 29, 2024. The FDA's regulatory agenda states the proposed rule would identify substances as fragrance allergens and require the labeling of these individual fragrance allergens on finished cosmetic products.

The agency must consider international, state, and local allergen-disclosure requirements in developing the rule, including the European Union's approach. The FDA may establish threshold levels for substances subject to disclosure—concentrations below which an allergen need not be named. This framework was noted in a 2023 report.

Whether the agency met that deadline, and where the rulemaking stands now, is not on the public record in any citable form.

What Disclosure Will Actually Look Like on the Label

When the rule takes effect, consumers should expect to see named fragrance allergens listed individually rather than folded into the generic "fragrance" designation. The exact format is not settled: whether allergens appear in the main ingredient list, in a separate allergen box, or in some other presentation is still open.

Current regulations already permit manufacturers to name fragrance components individually. Some brands do this now, particularly those marketing to sensitive-skin consumers. The new mandate will make this practice universal for allergenic materials, removing the option to hide them behind a collective term.

Masking agents present a specific case. Under current rules, they can already be named individually. The allergen rule will likely extend this transparency requirement to the full set of fragrance allergens, not just masking materials.

Reading Labels Before and After

Today's shopper with fragrance sensitivity faces a guessing game. The label says "fragrance." The product may contain limonene, linalool, citronellol, geraniol, eugenol, or none of these—there is no way to tell without contacting the manufacturer. Some consumers develop patch-test results naming specific molecules, then find those molecules impossible to avoid because they do not appear on cosmetic packaging.

The FDA's allergen disclosure rule, once implemented, will make specific triggers visible. A consumer who reacts to hydroxycitronellal or isoeugenol will be able to scan for those names directly.

The agency offers no federal guarantee for terms like "fragrance-free" or "hypoallergenic." These are marketing claims without standardized definitions. The allergen labeling rule addresses ingredient transparency, not product safety claims.

What Remains Unknown

The final list of fragrance allergens subject to disclosure has not been verified. The threshold concentrations, if any, remain unspecified. The label format—whether allergens appear in parentheses after "fragrance," in a separate section, or integrated alphabetically into the full ingredient list—is not confirmed. The timing of final implementation is unclear, given the unverified status of the proposed rule.

The gap between today's opaque "fragrance" line and a named-allergen requirement is real, but no transition date has been fixed.

What Skin costs 40 priced entries · prices as recorded

• $0–$1017
• $10–$2518
• $25–$505
• $50–$1000
• $100 and up0

Least expensiveFull Body Sponge$4.99

Most expensiveFace Glow Collection$35

Median here is $12.99 against $24.99 across the whole catalogue.