On a US label, “fragrance” is a closed door, and the law lets companies keep it shut. The 2022 reform changed less than you might hope, and Europe handles it differently.
Evidence key Strong Moderate Weak How we grade
One word, many chemicals
In the US, "fragrance" can be listed as a single word because the mixture is protected as a trade secret, so the individual chemicals are rarely named on the label. Strong evidence. Pinkas 2017
The industry’s own safety panel has put a number on it. The industry's own safety panel wrote that a single fragrance can contain 50-300 ingredients, that formulas are 'carefully guarded', and that the industry 'is often perceived as rather less than forthcoming by consumers and their physicians'. Strong evidence. Bickers 2003 (RIFM Expert Panel) Industry-funded
Household products don’t even need a list
Cosmetics at least have to print ingredients. Cleaners, detergents and air fresheners don’t. This non-disclosure was legal: US law doesn't require household products to list ingredients, and lets 'fragrance' stand in for a whole undisclosed mixture. Strong evidence. Steinemann 2011
When researchers tested 25 best-selling US laundry, cleaning, personal-care and air-freshener products, they found 133 different chemicals released into the air, but only 1 of them was listed on any product label. Moderate evidence. Steinemann 2011
Safety data sheets don’t fill the gap either. Product safety data sheets are written for workers, not shoppers, and only have to list hazardous ingredients present above 1% (0.1% for cancer-causing ones), a level most individual fragrance chemicals fall below. Strong evidence. Goldsmith 2014
What the 2022 law changed, and what it didn’t
The Modernization of Cosmetics Regulation Act (MoCRA), passed in 2022, changed some of this. It helps, but less than its name suggests.
- US cosmetic labels can still say just "fragrance". The 2022 law requires companies to name fragrance allergens on the label, but only the ones the FDA lists in a regulation, which the law told the FDA to propose by June 2024. Strong evidence. MoCRA 2022
- Even the FDA can only ask what is in a cosmetic's fragrance after a serious adverse event it has reason to blame on the fragrance; the company may answer with "categories of ingredients", and the answer is exempt from public-records requests. Strong evidence. MoCRA 2022
- US cosmetics still need no FDA approval before sale: the company itself must keep records showing the product is safe, and the law says "minor and transient reactions" do not make a product unsafe. Strong evidence. MoCRA 2022
- The 2022 US cosmetics law does not cover air fresheners, cleaning products or laundry products at all. Strong evidence. MoCRA 2022
How Europe compares
Until 2023 EU labels only had to name 26 fragrance allergens (above 10 ppm in leave-on and 100 ppm in rinse-off products); every other fragrance ingredient could be hidden under 'parfum'. Strong evidence. Pastor-Nieto 2021
A 2023 EU rule expands the list of fragrance allergens that must be named on cosmetic labels from 26 to about 80 entries (56 substances plus related forms), phasing in from 2026 to 2028, above set concentration limits. Strong evidence. Sukakul 2024 Industry-funded Our label decoder checks for every name on that list.
An older comparison, from before the 2022 law, shows how wide the gap was beyond fragrance. The EU bans or restricts more than 1,500 chemicals in personal care products and Canada about 800, while the US restricted 11. Moderate evidence. Khalid & Abdollahi 2021
Words that sound regulated but aren’t
In the US, "fragrance free", "unscented" and "free and clear" have no legal definition, so each company picks its own meaning; some "unscented" products contain a masking fragrance added to hide the product's smell. Strong evidence. Rodriguez 2024
The US FDA has no directive at all regulating the use of the word 'hypoallergenic' on a cosmetic product, and in a 2015 survey the products so labeled had the highest contact-allergen rate (88.2%) of any of four marketing terms tested (hypoallergenic, dermatologist recommended, fragrance free, paraben free). Strong evidence. Hamann 2015
What disclosure advocates say a fix needs
One advocacy group argues that a disclosure law has to reach the companies that make fragrances, not just the brands that buy them. An advocacy group that pushes for fragrance disclosure itself says many brand owners are not told by their fragrance suppliers what their fragrances contain, so a disclosure law has to reach the fragrance supplier. Moderate evidence. BCPP 2018
Until that happens, the label can’t tell you everything. Read it anyway, choose products with no fragrance listed, and use the decoder to spot the fragrance names and allergens that do appear on the list.
Every claim above shows its evidence grade and names its source, with a link wherever one exists. See all the laws and loopholes facts. Information, not legal advice.