Every fact on this site, with its evidence grade, its caveats and a link to the source.
We start you on the strong ones: findings that have been replicated or come from one large, well-controlled study. Moderate and weak facts are here too, labeled for what they are. Use “Link to this fact” to share a single card.
The industry / Lab study (cells or chemistry)
The lab tests that replaced animal testing for setting cosmetic and fragrance allergy safety limits explain only about 62% of how strongly a chemical causes allergy.
Strong evidence.
Caveats
Regression R2 against mouse LLNA, not human outcomes; industry-authored. Natsch 2023 (same author) retrains against human-anchored data: the 62% figure survives on a blended human+LLNA composite (63.4%, n=139), but against strictly human data (n=62) accuracy drops to 32-45%, and even the LLNA itself only reaches 43% predicting human potency — so '62%' should not be read as human-relevant accuracy. Api, Basketter & Lalko 2014 (RIFM's own earlier LLNA-vs-human validation, 57 fragrance chemicals) independently corroborates, by a different metric (categorical concordance, not R2) and seven years earlier, that the LLNA itself is an imperfect human proxy: 76% agreement within half an order of magnitude, but up to ~790-fold mispredicted for salicylates and ~26-42-fold for trans-2-hexenal/methyl-2-nonanoate. Roberts & Api 2018 (same fragrance dataset, direct LLNA-vs-human regression) reports a much higher R2=0.784, but only for a 35-chemical subset that already excludes those 14 known outliers a priori — demonstrating that domain-restricted R2 figures like this one can substantially overstate accuracy on unselected chemistry, a caution that applies to curated NAM training/case-study sets generally, not only to this specific figure.
Source: Natsch & Gerberick 2022, ALTEX Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
Accuracy has not improved: a 2015 model predicted allergy potency about as well as the 2022 one.
Strong evidence.
Caveats
Confirmed by reading the 2015 primary directly, not just inferred from one comparison line in the 2022 paper: Natsch 2015 Equation 7 gives R²(adj)=62.3% (Results, not the abstract's rounded 60%), matching 2022's 62% and 2023's 59-65%.
Source: Natsch & Gerberick 2022, ALTEX Industry-funded Link to this fact
The industry / Review of other studies
The cosmetics industry's own safety panel judged PGME 'safe' only for nail products and calculated only skin absorption; it did not estimate how much users or nail-salon workers breathe in, and relied on the smell to limit inhalation.
Strong evidence: Verdict probably right for occasional home users; the weakness is in the reasoning, not a demonstrated harm.
Source: CIR 2008, International Journal of Toxicology Industry-funded Link to this fact
The industry / Review of other studies
The Cosmetic Ingredient Review is funded by the cosmetics industry trade association, and the use data, exposure survey and safety-margin calculation behind its 2008 PGME verdict were unpublished industry submissions.
Strong evidence: Much of the underlying toxicology is peer-reviewed; industry funding does not by itself make the conclusion wrong.
Source: CIR 2008, International Journal of Toxicology Industry-funded Link to this fact
The industry / Review of other studies
The fragrance industry's own standard caps this one ingredient at 0.003% in lip products and 0.02-0.05% in typical leave-on skin products – about 30 parts per million in the strictest category.
Strong evidence: IFRA Standards are voluntary; the limits apply to rose ketones individually or in combination.
Source: Lalko 2007 (RIFM), Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Review of other studies
For this fragrance ingredient there was no data at all on absorption, repeat-dose toxicity, developmental effects, genetic damage or cancer – the whole safety file is skin testing, and 8 of its 11 studies are unpublished company reports that outsiders cannot check.
Strong evidence: As of the 2006 literature search; later RIFM re-evaluations may have added data.
Source: Lalko 2007 (RIFM), Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Review of other studies
Much of the evidence behind the fragrance industry's 'safe as used' verdict on salicylates is unpublished: about 65 of the cited studies are internal RIFM reports, several submitted by fragrance companies, and no modern cancer bioassay exists for any of the 17 chemicals.
Strong evidence: Counted from the paper's reference list; 'no modern bioassay' means untested, not shown to be carcinogenic.
Source: RIFM Expert Panel / Belsito 2007, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Self-reported survey
The study most often cited to call lavender and tea tree oils 'safe' for children was part-funded by the Australian Tea Tree Industry Association, the Tisserand Institute and an aromatherapy association, while declaring no conflicts of interest.
Strong evidence: Funding is documented in the paper itself; funders are stated to have had no role. The paper's weakness is its power and design, not only its funding.
Source: Hawkins 2021, International Journal of Pediatrics and Adolescent Medicine Industry-funded Link to this fact
The industry / Review of other studies
The tea tree oil industry's trade association (ATTIA) challenged the lavender/tea tree case reports in a medical journal, and the same association later helped fund a survey that called the oils safe for children.
Strong evidence: Documents who argued what; says nothing about whether the oils cause breast growth.
Source: Ramsey et al. 2020 (JCEM reply); Hawkins et al. 2021, The Journal of Clinical Endocrinology & Metabolism Link to this fact
The industry / Animal study
The two molecules that give lavender oil its scent, linalool and linalyl acetate, were put through the full regulatory endocrine test battery (OECD guideline cell assays plus rat uterotrophic, Hershberger and one-generation reproductive studies) and came back negative on estrogen and androgen endpoints — in a study written, run and entirely funded by BASF, the company that manufactures both chemicals, with all five authors BASF employees.
Strong evidence.
Caveats
Guideline designs with working positive controls, so the negative is real; the conflict of interest is disclosed in the paper and should be stated whenever the result is cited. Scope: two constituents, not lavender or tea tree oil.
Source: Hareng 2024, Archives of Toxicology Industry-funded Link to this fact
The industry / Animal study
Nothing in the industry's endocrine testing program covers tea tree oil, whose main constituent, terpinen-4-ol, was never tested.
Strong evidence: A statement about the study's scope, not about tea tree oil's safety either way.
Source: Hareng 2024, Archives of Toxicology Industry-funded Link to this fact
The industry / Review of other studies
The fragrance industry's safety system is self-run: by its own 2003 description, companies fund the Research Institute for Fragrance Materials through dues, its expert panel reviews ingredient safety, and conclusions go to the industry's trade body IFRA, which sets voluntary standards for those same companies. No regulator appears in the loop.
Strong evidence: Industry's own description (2003); panel members are required to be independent of the industry; later governance changes not covered.
Source: Bickers 2003 (RIFM Expert Panel), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
By the industry's own figures, about 60% of fragrance goes into soaps, fabric softeners, cleaners and detergents, yet its 2003 method for estimating people's exposure counted only 10 personal-care products applied to skin, and breathing fragrance in was not part of the calculation.
Strong evidence: Describes the 2003 process; later RIFM aggregate-exposure work may differ. Shows the route was not assessed, not that it causes harm.
Source: Bickers 2003 (RIFM Expert Panel), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Other evidence
By 1994 the fragrance industry itself had banned or restricted 82 fragrance materials, most because they cause skin allergy and a dozen because they cause skin reactions in sunlight.
Strong evidence: Counts restrictions, not harm rates; limits not printed.
Source: Ford 1994 (RIFM) Industry-funded Link to this fact
The industry / Government agency
In 2000 the EU's scientific advisers recommended banning 36 fragrance materials from cosmetics, and the list they endorsed was the fragrance industry's own list of materials it had already prohibited (IFRA); the committee added no testing of its own and deferred all industry restrictions to later.
Strong evidence: Describes the 2000 procedure; later EU opinions (SCCS 2012) did independent hazard classification.
Source: SCCNFP 2000 Link to this fact
The industry / Review of other studies
A trade consortium of 11 French essential-oil companies funded and employed the authors of the journal letter disputing the lavender breast-growth case reports; together with the tea tree oil trade association's letter, the published rebuttals to those case reports came from industry.
Strong evidence: Documents who argued what (disclosed in the letter); says nothing about whether the oils cause breast growth.
Source: Giroux & Orjubin 2020 (JCEM letter; Consortium Huiles Essentielles), The Journal of Clinical Endocrinology & Metabolism Industry-funded Link to this fact
The industry / Review of other studies
In 1997 the cosmetics industry's own safety panel (CIR) formally asked for inhalation-toxicity data on benzyl alcohol, benzoic acid and sodium benzoate, received none, and still published a 2001 "safe" conclusion that explicitly excludes any product where inhalation is a route of exposure (colognes, hairsprays, deodorants, aerosol fixatives).
Strong evidence: The gap is documented in the report's own text (Notice of Insufficient Data, no comments received); no later CIR report closing it was found in this pass.
Source: Nair 2001 (CIR Expert Panel), International Journal of Toxicology Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
The lab tests that replaced animal testing for fragrance and cosmetic allergy limits have been stuck at explaining about 62% of allergy potency since 2015 — the 2015 model and the 2022 model perform the same.
Strong evidence: Regression R2(adj) against mouse LLNA potency, not human outcomes; industry-funded (Givaudan).
Source: Natsch 2015, Toxicological Sciences Industry-funded Link to this fact
The industry / Measured in people or real products
The independent dermatologists who ran this study concluded deodorants should contain cinnamal at less than 0.01% to protect people already sensitized, a stricter limit than the fragrance industry's later 0.05% IFRA standard.
Strong evidence: Authors' own recommendation, not a regulatory outcome; the 0.05% IFRA cap was set afterward using the induction NOEL, not this elicitation data.
Source: Bruze et al. 2003, Journal of the American Academy of Dermatology Link to this fact
The industry / Review of other studies
The fragrance industry's own risk-assessment methodology (QRA1, then QRA2) has set enforceable safety limits for fragrance materials since 2008, but by its own authors' admission has never been tested against real-world clinical outcomes.
Strong evidence: Industry-authored methodology paper; the paper itself calls for the longitudinal clinical studies that would settle this, and states they have not been done.
Source: Api 2020 (RIFM/IFRA), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The industry's fragrance safety-limit system (QRA/IFRA Standards) is explicitly designed to prevent new fragrance allergies from developing, not to protect people who are already allergic from reacting to a compliant product.
Strong evidence.
Caveats
Confirmed as the framework's own stated design intent (Section 2.2), not inferred from a single ingredient's numbers; does not itself test whether existing limits provoke reactions in sensitized people.
Source: Api 2020 (RIFM/IFRA), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Government agency
A population study widely treated in dermatology literature as independent, EU-style evidence that confirmed dermatologists' fragrance-allergy estimates over the industry's own claims was itself funded by the fragrance industry's own research body, the Research Institute for Fragrance Materials (RIFM) — a funding fact omitted by every earlier secondhand citation of this study.
Strong evidence.
Caveats
The industry-funded study still confirmed the higher, consumer-relevant estimate (1.9% clinically relevant, up from a disputed 'up to 2%') over industry's own 2000 'far lower' claim — the funding did not appear to weaken the result in this case.
Source: Diepgen 2015 (EDEN), British Journal of Dermatology Industry-funded Link to this fact
The industry / Government agency
The EU guidance that defines what 'free from' and 'hypoallergenic' cosmetic claims are allowed to mean was jointly agreed by the European Commission, all EU/EFTA member states, the main EU cosmetics trade body (Cosmetics Europe) and the fragrance industry's own trade association (IFRA).
Strong evidence: Stated on the document's own cover page (footnote 1); this describes who wrote the guidance, not an independent audit of its content.
Source: EC Technical Document on Cosmetic Claims 2017 Industry-funded Link to this fact
The industry / Self-reported survey
Even the companies selling products often don't know everything in them: all 20 'leader' consumer-product companies interviewed said ingredient or hazard information could be hard to get from suppliers, and 7 named suppliers' trade-secret claims as a major obstacle.
Moderate evidence: Interview study, 20 self-selected companies, 2009; no fragrance firms identified.
Source: Scruggs 2011, Environmental Science & Policy Link to this fact
The industry / Self-reported survey
Only 1 of 20 leading consumer-product companies could test its own products' chemistry in-house; most relied on suppliers' signed promises (18 of 20).
Moderate evidence: Counts are interview mentions.
Source: Scruggs 2011, Environmental Science & Policy Link to this fact
The industry / Lab study (cells or chemistry)
The fragrance industry's own data show its main explanation for how fragrance chemicals cause allergy doesn't cover most of them: 34 of 62 ingredients (55%) sensitize despite having no predicted protein-binding alert.
Moderate evidence.
Caveats
Structural-alert software limitation; metabolic activation explains some. Roberts & Api 2018 (different 57-chemical fragrance dataset, no direct overlap confirmed with this claim's 62-chemical set) adds two further indirect-activation routes the alert software here evidently does not capture — slow autoxidation of tertiary allylic/benzylic C-H compounds to allergenic hydroperoxides/epoxides, and a proposed bio-sulfation route for benzylic alcohols — which could explain part of the unexplained 55% for chemicals with those structural motifs. The same paper separately proposes that some LLNA-positive, alert-free fragrance chemicals (hexyl/benzyl salicylate) may be LLNA false positives rather than true sensitizers at all, which would pull in the opposite direction (shrinking, not explaining, the true no-mechanism fraction) if any such chemicals are present in this claim's 62-ingredient set — not checked here, so the net effect on the 55% figure is unresolved and the grade is left unchanged.
Source: Lee 2024, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
The non-animal tests now used to set fragrance safety levels are typically off by about 2 to 3 times when predicting how potent an ingredient is.
Moderate evidence.
Caveats
Median absolute fold-misprediction 1.8-3.4; errors tend to be conservative. Natsch 2023 (same regression framework, non-fragrance-specific dataset) finds the underlying models are robust to retraining against human rather than LLNA data (only 6/139 chemicals shift >3.3-fold) — weak indirect support that this fold-error range is a stable property of the method, not an LLNA-fitting artifact, though the 62-fragrance-ingredient set itself is not retested against human data.
Source: Lee 2024, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
Those models underestimated allergy potency by more than fivefold for 18% of the 188 chemicals tested, and more than tenfold for 11%.
Moderate evidence.
Caveats
Prediction error, not a safety-limit error; worst outliers are non-fragrance chemicals. Natsch 2023 (same author, human-anchored retraining) shows this outlier structure is not simply an artifact of fitting to mouse data: only 6/139 chemicals (4.3%) shift by more than 3.3-fold when the same models are retrained against human-anchored potency values instead of LLNA.
Source: Natsch & Gerberick 2022, ALTEX Industry-funded Link to this fact
The industry / Animal study
Older synthetic musks (musk ambrette, AETT) caused nerve damage in animal studies and were later restricted.
Moderate evidence.
Caveats
Both primaries now read directly (2026-09-26): Spencer 1979 (AETT, N=16, single lab, single route) and Spencer 1984 (musk ambrette, N=220, dual route, dose-ranging). The musk-ambrette evidence alone is large and well-controlled enough to support 'strong', but the claim bundles it with the smaller AETT study, which keeps the combined claim at moderate under the grading rule.
Source: Pinkas 2017, Environmental Research Link to this fact
The industry / Journalism
A perfumer writing in a chemistry journal said a natural ingredient such as rose oil is sometimes added in a "negligible quantity only to be able to say that you have rose oil in your formula", which "will please the marketing people" but does nothing for the scent.
Moderate evidence: Opinion; she advises against the practice and gives no frequency.
Source: Ellena 2008, Chemistry & Biodiversity Industry-funded Link to this fact
The industry / Animal study
Citronellol is treated as safe by default – GRAS at the US FDA, a 'non-toxic' biopesticide at the US EPA, and limited only by the fragrance industry's own voluntary IFRA standard – yet this government-funded study found it is brain-penetrant and calls for its content in consumer products to be regulated.
Moderate evidence: The call for regulation is the authors' conclusion from high-dose animal data; funded by the Korean Ministry of Environment, no industry money.
Source: Kim 2024, Journal of Hazardous Materials Link to this fact
The industry / Review of other studies
The industry's permitted levels for rose ketones (up to 0.07-0.8% depending on product type) overlap the concentrations at which already-sensitized volunteers reacted (0.05-0.1%), because the risk assessment is designed to prevent new allergies rather than to protect people who already have one.
Moderate evidence.
Caveats
The loosest categories are rinse-off/incidental contact where dose per area is far lower than a patch test. The design intent (induction only, not elicitation) is now confirmed by the framework's own current methodology paper (Api 2020, QRA2 §2.2); the numeric overlap still rests on the single 2007 dossier.
Source: Lalko 2007 (RIFM), Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Review of other studies
The fragrance industry's safety assessment of 17 salicylates counted exposure from 10 personal-care product types only. Household cleaners and detergents, which the same report lists as uses, and breathing fragrance in were not included.
Moderate evidence.
Caveats
As of 2024, RIFM/Creme Global's aggregate exposure model (Lee 2024) does now cover household care, air care and inhalation industry-wide, but that 2024 paper does not report salicylate-specific numbers, so it is unconfirmed whether this specific 2007 dossier's gap has since been closed for these 17 materials. A decade after this 2007 dossier, RIFM's own broader exposure model (Comiskey et al. 2017, Phase 2) had still not reached household cleaning or laundry products either — explicitly named as future work — confirming the product-type gap this claim describes persisted within the industry's own more advanced modeling program well past 2007, closing only with Lee 2024 industry-wide (still not salicylate-specific).
Source: RIFM Expert Panel / Belsito 2007, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Review of other studies
The industry panel judged each salicylate's safety one chemical at a time, although the same report says all 17 are broken down in the body to the same substance, salicylic acid.
Moderate evidence.
Caveats
The combined-exposure figure (about 1.05 mg/kg/day, group margin roughly 48-69 at the panel's own 100%-absorption default) is a evidence base calculation on the paper's Table 1, not a published number, and sums high-end maxima.
Source: RIFM Expert Panel / Belsito 2007, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Measured in people or real products
In a French fragrance-and-flavor factory, the company's own measurements found the butter-flavor chemical diacetyl (linked to 'popcorn lung' in US factory workers) in workers' breathing air at 0.05–9 ppm during short tasks; 29 of 31 samples were above the 15-minute limit of 0.1 ppm recommended by the EU's scientific committee on occupational limits.
Moderate evidence.
Caveats
Limit comparison is our (paper makes none); samplers on clothing, respirator use per task not reported; flavor chemical, factory workers, not consumers; industry-funded (V. Mane Fils).
Source: Angelini 2016, PLoS ONE Industry-funded Link to this fact
The industry / Measured in people or real products
The standard EU (REACH) screening tool for estimating workers' chemical exposure predicted lower levels than were actually measured in 61% of 431 measurements in a fragrance-and-flavor factory, sometimes by more than 100-fold.
Moderate evidence: One plant; evidence base count from the paper's S4 table (paper: 37% of tool predictions were above the measurement); short task samples.
Source: Angelini 2016, PLoS ONE Industry-funded Link to this fact
The industry / Self-reported survey
More than a third of Germans (37.8%) think people who wear perfume are more hygiene-conscious; fragrance can mask a smell but does not clean.
Moderate evidence: Attitude item; the 'does not clean' half is the author's argument, not a measurement.
Source: Klaschka 2020, Environmental Sciences Europe Link to this fact
The industry / Animal study
This lavender study was funded by a university with no declared industry involvement, unlike much of the evidence used to argue these oils are safe for children, which comes from the essential-oil trade or from a manufacturer of lavender's main constituents.
Moderate evidence.
Caveats
Funding source is not evidence quality: this study is small (n = 5 per group) and the industry studies it contrasts with are larger and guideline-compliant, though narrower in scope.
Source: Kim & Lim 2022, Journal of Korean Medical Science Link to this fact
The industry / Animal study
The industry's guideline testing cleared the two lavender molecules that were NOT the most active ones: in the study it was answering, alpha-terpineol and terpinen-4-ol were the strongest on both the estrogen and androgen receptors, and BASF tested neither.
Moderate evidence: Comparison across two papers (Hareng 2024 vs Ramsey 2019) using different assay systems; the point is the untested molecules, not a disagreement about the tested ones.
Source: Hareng 2024, Archives of Toxicology Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
The hormone safety testing on lavender and tea tree oil constituents is incomplete: no regulatory steroidogenesis assay (OECD Test Guideline 456) has been published for any of the eight internationally defined constituents of either oil — including the two that an industry laboratory reported as clear on hormone receptors.
Moderate evidence: An absence-of-evidence claim about the published record as of 2026-09; states a testing gap, not a harm. Say 'not tested', never 'found unsafe'.
The industry / Review of other studies
Fragrance safety is self-regulated: IFRA, which represents about 90% of fragrance suppliers, issues voluntary guidelines, and much of the safety research it relies on is done by the industry's own institute (RIFM) and is unpublished.
Moderate evidence: Secondary figures; the unpublished-studies point is better sourced from RIFM dossiers themselves.
Source: BCPP 2018 Link to this fact
The industry / Industry source
The industry's standard safety package for a fragrance ingredient in 1994 covered acute poisoning and skin effects (irritation, allergy, sun reactions); breathing it in was not tested, because the industry judged inhalation 'not a route of toxicological concern'.
Moderate evidence.
Caveats
As of 2024, RIFM/Creme Global's aggregate exposure model (Lee 2024) does now include a full inhalation-TTC branch across ~3,000 fragrance ingredients (99% below the inhalation TTC), so the industry itself has since closed this specific 1994 scope gap methodologically — though whether ingredients assessed only under the older dermal-only dossiers were individually revisited is not stated. The gap's closure was gradual, not a single 2024 event: Comiskey et al. 2017 (Phase 2 of the same RIFM/Creme model) added the model's first-ever inhalation branch, 23 years after this 1994 dismissal, but only for air-care and personal-care spray products — household cleaning and laundry products were explicitly still excluded and named as future work in 2017, closing only in the 2024 paper.
Source: Ford 1994 (RIFM) Industry-funded Link to this fact
The industry / Review of other studies
EPA's reviewers warned that replacing one phthalate with a close relative (DINP for DEHP, DIBP for DBP) should not be assumed to be safer.
Moderate evidence: Based on weaker data for the substitutes (fewer studies, lower exposures), not on evidence they are equally harmful.
Source: Radke 2018 (US EPA), Environment International Link to this fact
The industry / Measured in people or real products
The essential-oil industry's published defense of lavender oil in a child's breast-growth case rested on showing the child's cologne was synthetic fragrance containing a phthalate: that clears lavender oil, not the cologne.
Moderate evidence: Describes the letter's argument; one case, no dose, no biomarker; does not show the phthalate or anything else caused the breast growth.
Source: Giroux & Orjubin 2020 (JCEM letter; Consortium Huiles Essentielles), The Journal of Clinical Endocrinology & Metabolism Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
A 2026 lab test that adds simulated human liver metabolism to a DNA-damage (Ames mutagenicity) test found MORE mutagenic activity in skin creams and lotions than the conventional animal (rat) version of the same test — the opposite of metabolism detoxifying the product. Standard safety testing, including industry fragrance-material dossiers, defaults to the rat version.
Moderate evidence.
Caveats
One paper, 11 unnamed cosmetic/skin-care-cream extracts, no compound identified; not tested on perfumes or on named fragrance materials; species differences in metabolism can go either direction depending on the chemical.
Source: Schmidtmann 2026, Analytical Chemistry Link to this fact
The industry / Review of other studies
The cosmetics industry's own safety panel found that 5% benzyl alcohol and 2% benzoic acid provoke a non-allergic skin reaction (redness, swelling, itching) in most people tested with no prior sensitization needed, yet concluded both are "safe" up to 5% in cosmetics because it judged typical exposure limited, not because the reaction is rare.
Moderate evidence.
Caveats
The exposure-limited reasoning was built around occasional hair-dye use; the same industry data table lists benzyl alcohol and benzoic acid in daily leave-on products (moisturizers, body/hand skin care) without a separate exposure justification for that pattern.
Source: Nair 2001 (CIR Expert Panel), International Journal of Toxicology Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
The replacement tests are least accurate for the strongest allergens: they were wrong by about 6-fold for strong sensitizers and about 18-fold for the most extreme ones, almost always guessing them weaker than they are.
Moderate evidence: Geometric-mean fold error by LLNA potency class (Table 4); no human-outcome validation for this specific breakdown.
Source: Natsch 2015, Toxicological Sciences Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
When the same lab-dish tests that replace animal testing are checked against real human allergy-test panels instead of mouse data, they explain only about 32-45% of how strongly a chemical causes allergy in people, and the mouse test itself does barely better, explaining only 43%.
Moderate evidence: The strictly-human comparison dataset (n=62) is small and the author flags it as biased/non-representative; a larger human dataset might do better.
Source: Natsch 2023, ALTEX Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
Neither the animal test nor its lab-dish replacements are strong predictors of real human allergy thresholds; they are about equally weak, shown independently in 2015 and again in 2023.
Moderate evidence: Both comparisons reuse overlapping historical human patch-test literature (HRIPT/HMT), not independent new human data.
Source: Natsch 2023, ALTEX Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
Whether a chemical is irritating to cells in a dish, not just whether it reacts with proteins, drives a lot of the mouse allergy test's readout in ways that don't reflect real human allergy.
Moderate evidence: Statistical inference from regression coefficients across three chemical subsets, not a direct mechanistic experiment.
Source: Natsch 2023, ALTEX Industry-funded Link to this fact
The industry / Review of other studies
AETT was in fragrance use for 22 years before its neurotoxicity was documented, and cosmetic color additives are the only ingredient class the FDA actually regulates.
Moderate evidence: Regulatory-gap claim is accurate for the 1979 US framework described in the paper; verify current FDA cosmetic regulation status before using as a present-tense claim.
Source: Spencer 1979, Science Industry-funded Link to this fact
The industry / Animal study
The study's own authors, including two Research Institute for Fragrance Materials scientists, stated that the doses causing clear nerve damage in rats were 50 to 250 times their own estimate of maximum human fragrance exposure to musk ambrette, and that the lower-dose, longer-term study needed to assess real human risk was never done.
Moderate evidence: This is the study authors' own stated limitation, not an independent follow-up; no lifetime low-dose study has been conducted since (as far as this evidence base has found).
Source: Spencer 1984, Toxicology and Applied Pharmacology Industry-funded Link to this fact
The industry / Animal study
Musk ambrette is no longer used in fragrances; it was withdrawn from all skin-contact products in the 1980s, following both this neurotoxicity finding and separate reports of photoallergic skin reactions in real-world cologne use.
Moderate evidence.
Caveats
The proximate cause of the total skin-contact ban was photoallergy (Cronin 1984), not the neurotoxicity finding directly, which RIFM had already argued had an adequate safety margin via absorption data.
Source: Spencer 1984; Ford 1994, Toxicology and Applied Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The 2020 update to the industry's fragrance safety-assessment methodology exists because an independent EU regulatory body (the SCCS), not the industry itself, found the original 2008 version's exposure assumptions and safety factors inadequately justified.
Moderate evidence: The SCCS opinions themselves are not yet ingested as primary sources in this evidence base; described via the industry paper's own account of the critique.
Source: Api 2020 (RIFM/IFRA), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The fragrance industry's own most detailed exposure model to date estimates that about three-quarters of roughly 3,000 fragrance ingredients fall below a conservative safety threshold (TTC) for long-term systemic exposure, and 99% fall below it for inhalation — but by the same industry analysis, about a quarter of ingredients (777) are above their own systemic threshold and about half are above the skin-sensitization threshold (DST).
Moderate evidence.
Caveats
Industry-funded, self-run model (RIFM/Creme Global) using industry-supplied, largely unpublished concentration and habits-and-practices survey data. The DST gap is driven mostly by natural complex substances (essential oils etc.), which are conservatively defaulted to the more hazardous 'reactive' category without analyzing their actual components — only 19% of these clear the DST versus 65% of single, chemically-defined ingredients.
Source: Lee 2024 (RIFM/Creme Global), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
As of 2024, the fragrance industry's aggregate exposure model finally covers household-care, air-care and oral-care products and the inhalation route for its full ~3,000-ingredient inventory — a scope earlier industry safety dossiers from 1994, 2003 and 2007 explicitly left out or dismissed by a single-ingredient calculation.
Moderate evidence.
Caveats
Whole-inventory average from an industry-run model; the paper does not show that any specific earlier dossier (e.g. the 2007 salicylates group review) was individually re-run through the expanded model, so whether that scope gap has closed for those specific materials is unconfirmed.
Source: Lee 2024 (RIFM/Creme Global), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The industry's own model finds fragrance exposure from household-care and air-care products is far lower than from cosmetics and personal-care products, and almost entirely by inhalation rather than skin contact (household 95th percentile 0.2 ug/kg/day, air care 5 ug/kg/day, versus cosmetics/personal care about 50 ug/kg/day, nearly all dermal).
Moderate evidence: Based on a 350-ingredient sample modeled from industry-supplied concentration and use-frequency survey data, not measured breathing-zone concentrations.
Source: Lee 2024 (RIFM/Creme Global), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Government agency
FDA's own 2006 testing concluded there was insufficient data to find a human health hazard from phthalate esters in cosmetics and took no regulatory action, even though the phthalates were already known to be common and concentrated in fragrance and nail products.
Moderate evidence: This is the regulator's own stated position at the time (2006), not a new toxicity finding; FDA said it would continue to monitor and could revisit if new hazard data emerged.
Source: Hubinger & Havery 2006, Journal of Cosmetic Science Link to this fact
The industry / Industry source
The fragrance industry's aggregate consumer exposure model did not include any estimate of inhaled fragrance exposure until 2017, when it added an inhalation route for air fresheners, scented candles and personal-care sprays only — 23 years after the industry's 1994 safety package dismissed inhalation testing.
Moderate evidence.
Caveats
This is a modeled inhalation exposure fraction from a compartmental model run at single default parameter values, not measured breathing-zone data; the model's own validation against real chemical concentrations is reported in a companion paper (Safford et al. 2017) not yet in this evidence base.
Source: Comiskey 2017 (RIFM/Creme Global), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Industry source
Even after this 2017 update, the fragrance industry's own aggregate exposure model still explicitly excluded household cleaning and laundry products — the product category the industry's own 2003 safety-process paper says accounts for about 60% of fragrance volume — and named their inclusion as future work.
Moderate evidence.
Caveats
Single industry methods paper describing its own model's scope; the gap was closed industry-wide only in a later 2024 paper (Lee et al.), which this claim's caveat should be read alongside.
Source: Comiskey 2017 (RIFM/Creme Global), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Industry source
To build this exposure model, the fragrance industry combined three surveys that were never designed to work together — a 7-day product diary, a monthly recall survey, and a categorical daily-frequency questionnaire — by matching subjects only on age and gender and assuming they share the same habits for entirely unrelated products.
Moderate evidence.
Caveats
The paper's authors are explicit about this assumption's uncertainty and do not test it directly; a companion validation paper (Safford et al. 2017) is not yet in this evidence base to check how much this integration step affects final exposure estimates.
Source: Comiskey 2017 (RIFM/Creme Global), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Industry source
Some of the amount-per-use values feeding this industry exposure model come from very small studies — 10 Dutch adults for bar-soap-in-the-shower amounts, and a single non-distributional value for scented-candle amount per day — rather than large, representative samples.
Moderate evidence.
Caveats
Small external studies feeding a large aggregate model is a data-provenance observation, not itself evidence the resulting exposure estimates are biased in a particular direction; the paper does not report sensitivity analysis on these specific inputs.
Source: Comiskey 2017 (RIFM/Creme Global), Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Lab study (cells or chemistry)
The fragrance industry's own 2007 safety review of benzyl salicylate assessed allergy, toxicity and cancer risk in detail but never tested it for hormone-like activity at all; the first test came two years later, from an independent lab with no fragrance-industry funding.
Moderate evidence.
Caveats
The independent test found only a weak, partial effect, at concentrations well above the industry's own worst-case exposure estimate, so this closes a testing gap rather than reversing the 2007 review's 'safe as used' conclusion.
Source: Charles & Darbre 2009, Journal of Applied Toxicology Link to this fact
The industry / Measured in people or real products
In RIFM's own comparison of 57 fragrance chemicals, the mouse test used to set fragrance skin-allergy safety limits agreed with real human sensitization thresholds within about 3-fold for 76% of the chemicals tested, but was off by up to nearly 800-fold for others, including hexyl and benzyl salicylate.
Moderate evidence.
Caveats
Single paper/author group (RIFM staff plus an industry consultant), though a large (57-chemical), systematically protocolled primary dataset; the authors themselves call the outlier groups 'an alert for consideration, rather than… a general rule' given only 7 materials populate each. Corroborates, from a different metric and era, the LLNA-human accuracy gap C230 documents for the newer non-animal replacement tests.
Source: Api, Basketter & Lalko 2014, Cutaneous and Ocular Toxicology Industry-funded Link to this fact
The industry / Measured in people or real products
The older claim that PGME solvent vapor irritates the eyes and throat at 250 ppm comes from an unblinded 1970 study without objective eye measurements (20 of 23 subjects reported eye irritation at 250 ppm); a later double-blind study with objective eye tests found no effect at 100-150 ppm.
Moderate evidence.
Caveats
The double-blind study only tested up to 150 ppm, so it does not directly re-test the 250 ppm figure; it undermines confidence in the method that produced it, not the number itself.
Source: Emmen et al. 2003, Toxicology Letters Industry-funded Link to this fact
The industry / Government agency
California's 2022 law banning intentionally added PFAS in cosmetics (AB 2771), effective January 1, 2025, is expected by state toxicologists' own modeling to reduce PFAS reaching California wastewater treatment plants, particularly from shaving creams and gels, hair care products, and facial cleansers rather than from makeup.
Moderate evidence.
Caveats
This is a projection from the same modeled estimate, not a before/after measurement; the ban had not yet taken effect when the paper was published, and DTSC has an institutional interest in the policy it also administers.
Source: Balan 2024, Environmental Science & Technology Link to this fact
The industry / Measured in people or real products
The study's own authors note that current diagnostic patch-test concentrations for oxidized linalool allergy are more than 500 times higher than the hydroperoxide levels they actually found in consumer products.
Moderate evidence: Industry-funded interpretation; does not itself prove patch tests over-diagnose, since already-sensitized skin can react to much lower doses than the diagnostic test threshold.
Source: Kern 2014, Analytical and Bioanalytical Chemistry Industry-funded Link to this fact
The industry / Other evidence
RIFM's founding scientific director personally authored the sole primary study behind the fragrance industry's 'quenching' safety exception; IFRA later codified it into a formal use-with-limonene rule (≥25% d-limonene) that required a higher proportion of the 'quenching' terpene than Opdyke's own 1976 test (~20% d-limonene) actually used.
Moderate evidence: The evidence base does not have IFRA's own documentation of why 25% (rather than the tested ~20%) was chosen, or of when/why the quenching exception was later withdrawn.
Source: Ford 1994 (RIFM), citing Opdyke 1976 Industry-funded Link to this fact
The industry / Measured in people or real products
Despite thousands of positive allergy-test reactions to oxidized limonene and linalool reported worldwide, the fragrance industry's own market-testing program concluded that where people are actually getting exposed to these allergens "remains elusive" — the industry itself has not identified the real-world consumer-product source of a widely documented skin allergy.
Moderate evidence.
Caveats
This is the industry's own conclusion, from an industry-funded study; it does not mean the allergy is not real or not caused by fragrance chemicals — only that the specific consumer-product exposure route has not been chemically confirmed even by the party with the strongest incentive to find an innocuous explanation.
Source: Natsch 2019, Food and Chemical Toxicology Industry-funded Link to this fact
The industry / Measured in people or real products
A musk fragrance chemical called ATTN (Versalide) disappeared entirely from human tissue in this 1996 study because industry had already stopped making it in 1980, after animal testing showed it damaged nerves – a real-world example of a musk being phased out after a toxicity finding.
Moderate evidence: Absence in 19 samples is consistent with, but does not by itself prove, the discontinued-production explanation the authors give; based on a small single-country sample.
The industry / Measured in people or real products
SC Johnson funded and co-authored a study that tested what was apparently its own newly developed fragranced air-sanitizer product in asthmatics and found no adverse ocular, nasal or lung effects.
Moderate evidence.
Caveats
Record as the industry's own finding, not independent confirmation of safety; the null is broadly consistent with independent Elberling 2006/Millqvist findings but was not independently replicated.
Source: Opiekun 2003, Clinical and Experimental Allergy Industry-funded Link to this fact
The industry / Animal study
When RIFM's own scientists restrict the comparison to fragrance chemicals without known problematic chemistry, the mouse test used to set fragrance safety limits correlates strongly with real human sensitization thresholds (R-squared = 0.78 for 35 chemicals).
Moderate evidence.
Caveats
This correlation excludes, by design, the 14/57 chemicals already known (from the same underlying RIFM dataset) to disagree badly between mouse and human data, some by up to ~790-fold (Api 2014). Only 2 of those 14 exclusions could have been identified before seeing the human data; the other 12 were fit to the very outliers they exclude.
Source: Roberts & Api 2018, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Measured in people or real products
This foundational human PGME irritation study has a direct Dow Chemical link stronger than later PGME papers in the wiki: one author was a Dow Chemical employee and the test material was Dow-supplied ('Dowtherm 209'), yet the study documents substantial irritation at concentrations relevant to Dow's own radiator-coolant product rather than minimizing it.
Moderate evidence: A single industry-linked study reporting an adverse finding is still one study; the funding link is recorded for transparency, not as proof the finding is unbiased in general.
Source: Stewart 1970 (Arch Environ Health), Archives of Environmental Health: An International Journal Industry-funded Link to this fact
The industry / Animal study
A commercial testing laboratory's mouse-bioassay claims of consumer-product toxicity (the same ASTM E-981/FOB method the lab later applied to air fresheners and colognes) failed an independent, blinded EPA/ManTech replication attempt when applied to carpets; the largest toxicity-looking signals traced instead to stress from the restrained-exposure test procedure itself, present even in air-only control animals.
Moderate evidence.
Caveats
Applies to carpets specifically (2 CPSC-complaint carpets, one lab-replication attempt); the fragrance papers' headline airflow-limitation (mid-expiratory flow) endpoint was never measured by this study, so it is method/lab-level caution about the testing program, not a direct refutation of the fragrance-specific findings.
Source: Tepper et al. 1995, American Industrial Hygiene Association Journal Link to this fact
The industry / Review of other studies
Modern (post-1980s) European fabric conditioners almost all use esterquats, a cationic surfactant class engineered with a hydrolyzable ester linkage to biodegrade faster than the older DHTDMAC/DSDMAC softeners it replaced; the industry's own account frames the switch as environmental (biodegradability), not human-health, driven.
Moderate evidence.
Caveats
Industry source, coi/industry-funded, unnamed underlying studies; the chemistry/history claim itself (ester linkage -> faster hydrolysis/biodegradation) is basic, uncontested chemistry, but the framing and any 'therefore always safer' inference is the industry's own.
Source: HERA Project 2008 (A.I.S.E./CEFIC) Industry-funded Link to this fact
The industry / Measured in people or real products
Tumble dryer manufacturers give directly conflicting instructions on cleaning the lint filter: some tell consumers to rinse it under water, others recommend a dishwasher, others dry methods only, and one (John Lewis) explicitly says never use water, for environmental reasons.
Moderate evidence: One UK market snapshot (24 brands, January 2023), not checked against other countries or against what consumers actually do.
Source: Cummins 2023, PLOS ONE Industry-funded Link to this fact
The industry / Other evidence
The clinical safety testing (HRIPT, CIT or SIU) required to earn the NEA Seal is arranged and paid for by the manufacturer through a testing company of its own choosing; NEA states it "does not endorse or have a relationship with any clinical safety testing company" and instead reviews the submitted reports on paper through an independent physician panel.
Moderate evidence.
Caveats
This is a structural/COI description from the criteria page itself, not a finding that any specific product's submitted testing was inadequate; whether NEA audits the chosen labs is unknown from this page (see linked-but-uncaptured testing-requirements PDF).
Source: NEA 2026 Link to this fact
The industry / Journalism
The first press coverage of a 2011 study finding 133 undisclosed chemicals in 25 best-selling scented products, in the US government's environmental-health journal, quoted no manufacturer or industry group; the underlying numbers should be cited from the study itself (Steinemann 2011).
Weak evidence: Media-coverage note only; all product numbers belong to the primary src-2011-fragranced-consumer-products-chemicals-emitted-ingredients-unlisted.
Source: Potera 2011 (EHP news), Environmental Health Perspectives Link to this fact
The industry / Review of other studies
The fragrance industry's answer to autoxidation is to add antioxidants to linalool and linalool-rich natural extracts, but the Gothenburg researchers say that protection is hard to control.
Weak evidence: Industry practice via personal communication from a RIFM scientist (A. M. Api) in a RIFM co-funded paper; no data on effectiveness.
Source: Hagvall 2008, Contact Dermatitis Industry-funded Link to this fact
The industry / Animal study
Two common fragrance ingredients, hexyl and benzyl salicylate, may test positive in the mouse skin-allergy assay not because they are true human sensitizers, but because of a mouse-specific irritant/pharmacological effect, similar to a known false-positive detergent (sodium lauryl sulfate).
Weak evidence.
Caveats
A hypothesis proposed by structural-alert absence and analogy only; the paper offers no direct evidence (e.g., a biomarker distinguishing true haptenation from irritant-driven lymph node activity) and the underlying data are RIFM's own unpublished proprietary dataset.
Source: Roberts & Api 2018, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
The industry / Review of other studies
The detergent industry's own risk assessment for esterquat fabric softeners sets a margin of exposure of about 8,100 (NOAEL 300 mg/kg bw/day vs. an aggregate consumer exposure estimate of 36.9 micrograms/kg bw/day) and concludes esterquats in fabric conditioner are safe for consumer use.
Weak evidence.
Caveats
Every number comes from the industry's own unpublished, unnamed studies with no independent citation trail; the exposure model covers only dermal and minor oral routes (no inhalation route at all, despite fabric conditioner being used in heated dryers); no carcinogenicity study and no multigeneration reproductive study exist for esterquats — the 'safe' conclusion infers these endpoints are unnecessary from adjacent negative results rather than testing them directly.
Source: HERA Project 2008 (A.I.S.E./CEFIC) Industry-funded Link to this fact
Information, not medical advice. See also: myths we won’t tell you.