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.
Laws and loopholes / Review of other studies
As of 2008, no US federal law required companies to list all the chemicals in a consumer product or in its fragrance; air fresheners and laundry products did not even have to say they contained fragrance.
Strong evidence.
Caveats
US law as of 2008; MoCRA (2022) later required FDA-designated fragrance-allergen labeling for cosmetics only (rule pending at enactment); household products still uncovered for cosmetics.
Source: Steinemann 2009, Environmental Impact Assessment Review Link to this fact
Laws and loopholes / Review of other studies
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: Regulatory analysis as of 2010 (pre-MoCRA).
Source: Steinemann 2011, Environmental Impact Assessment Review Link to this fact
Laws and loopholes / Review of other studies
When US EPA scientists built a database of chemicals in 8,921 consumer products from their safety data sheets, they could not record fragrance ingredients at all: more than 3,060 fragrance materials can legally be listed as 'trade secret' with no name, so those entries had to be thrown out.
Strong evidence: Document analysis of one US retailer's MSDSs (2012).
Source: Goldsmith 2014, Food and Chemical Toxicology Link to this fact
Laws and loopholes / Review of other studies
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: 'Most fragrance chemicals below 1%' is general formulation knowledge, not measured in this paper.
Source: Goldsmith 2014, Food and Chemical Toxicology Link to this fact
Laws and loopholes / Review of other studies
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: Only above threshold concentrations; cosmetics only.
Source: Sukakul 2024, Acta Dermato-Venereologica Industry-funded Link to this fact
Laws and loopholes / Review of other studies
Since the 2022 MoCRA law, most cosmetic makers must list their products with the FDA; in its December 2025 report the FDA found PFAS ("forever chemicals") intentionally added to about 0.4% of listed US cosmetics (1,744 of 430,134), mostly eye and face makeup, and had too little data to judge the safety of 19 of the 25 most-used PFAS.
Strong evidence.
Caveats
Manufacturer listings, not product testing; small businesses and drug-cosmetics do not list; corrected 2026-09-26 from 0.03%/no fragrances (EU KEMI figures). Independently corroborated 2026-09-27: Balan et al. 2024 (10.1021/acs.est.3c06539, California DTSC) estimated PFAS-containing-product prevalence from a different, non-federal dataset (Mintel Global New Product Database + EWG Skin Deep, ~65,000+ formulations) and found prevalence under 3% in every one of 16 product subcategories studied (range 0.00-2.68%), consistent with FDA's 0.41% aggregate figure. Both remain database/listing-based estimates, not chemical measurements, and the two studies measure slightly different things (an economy-wide aggregate vs. per-subcategory prevalence in 16 categories), so this is convergence of two independent large datasets rather than a replication of the identical statistic.
Source: FDA 2025, FDA report published under MoCRA §3506(b) (FDA website) Link to this fact
Laws and loopholes / Review of other studies
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.
Source: Pinkas 2017, Environmental Research Link to this fact
Laws and loopholes / Government agency
There are no federally enforceable US standards for volatile organic compounds in homes, schools or other non-industrial indoor settings.
Strong evidence.
Source: US EPA 2026 Link to this fact
Laws and loopholes / Review of other studies
Linalool and linalyl acetate are registered in the EU at over 1,000 tonnes a year each for fragrance use in home-care and air-care products; the study states its purpose as adding to the dataset for future hazard-classification decisions as the EU adds endocrine disruption to its classification rules.
Strong evidence: Registration tonnage and regulatory context as stated by the paper; dossier-building and scientific inquiry are not separable here.
Source: Hareng 2024, Archives of Toxicology Industry-funded Link to this fact
Laws and loopholes / Review of other studies
The US Microbead-Free Waters Act (2015) bans plastic microbeads only in rinse-off cosmetics, not in makeup that stays on the skin.
Strong evidence: Statement of US law as summarized in the review.
Laws and loopholes / Review of other studies
Because PTFE is a polymer, the EU's REACH law never required companies to register it or submit safety data, and a planned change to cover polymers was postponed.
Strong evidence: Describes EU law only; the EU universal PFAS restriction proposal may change this.
Source: Jomaa 2024, Journal of the Netherlands Society of Toxicology (JNST) Industry-funded Link to this fact
Laws and loopholes / Industry source
In 1994 a scientist at the fragrance industry's own research institute wrote that no country required fragrance ingredients to be approved, safety-tested for consumer use, or listed on product labels, and called this "of great benefit to the industry".
Strong evidence: Describes 1994; EU labeling of 26 (now more) allergens and US MoCRA came later.
Source: Ford 1994 (RIFM) Industry-funded Link to this fact
Laws and loopholes / Government agency
In 2000, EU cosmetics could declare an entire fragrance as the single word 'parfum'; the EU committee noted dermatologists' estimate that up to 2% of people have perfume allergy, against industry's claim that the true figure was 'far lower'. The EDEN population-based patch-test study (Diepgen 2015; n=3,119 patch-tested across 5 European countries) directly confirmed the dermatologists' estimate: 1.9% (95% CI 1.5-2.5) clinically relevant fragrance contact allergy, and 1.8-2.6% for fragrance mix I alone.
Strong evidence.
Caveats
EDEN is the largest general-population patch-test study of fragrance allergy to date and a large, well-controlled multi-country primary (not a single-lab or single-cohort study), which is why this moves to strong. Note EDEN was itself funded by the Research Institute for Fragrance Materials (RIFM), the fragrance industry's own body — the industry-funded study still confirmed the higher, consumer-relevant estimate over the industry's own 'far lower' claim.
Source: SCCNFP 2000 Link to this fact
Laws and loopholes / Government agency
Since the 2022 Modernization of Cosmetics Regulation Act, cosmetic companies must send the FDA any report they receive of a serious reaction to their product, including serious and persistent rashes, within 15 business days, and the FDA can now order a recall.
Strong evidence: Statute text (FFDCA §§604-605, 611); 'serious' threshold excludes most transient reactions; enforcement from 2023-12-29.
Source: MoCRA 2022 Link to this fact
Laws and loopholes / Government agency
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: Statute §608; substantiation judged by 'qualified experts', no required tests, no inhalation requirement.
Source: MoCRA 2022 Link to this fact
Laws and loopholes / Government agency
The 2022 US cosmetics law does not cover air fresheners, cleaning products or laundry products at all.
Strong evidence: MoCRA amends the FFDCA cosmetics chapter only; household products fall under CPSC/EPA law.
Source: MoCRA 2022 Link to this fact
Laws and loopholes / Government agency
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: EU Regulation 2023/1545 expanded the list; say 'until 2023' or name the new list.
Source: Pastor-Nieto 2021, Current Treatment Options in Allergy Link to this fact
Laws and loopholes / Review of other studies
In the EU, chemical mixtures containing a skin sensitizer must carry the warning 'May produce an allergic reaction' (EUH208), but cosmetics are exempt from that warning and from CLP hazard symbols.
Strong evidence: Legal analysis as of 2016 (CLP Art. 1(5), Annex II 2.8); cosmetics do have to name listed allergens in the ingredient list.
Source: Klaschka 2016, Environmental Sciences Europe Link to this fact
Laws and loopholes / Government agency
In the EU, tampons and pads are not cosmetics: as of 2020 only general product-safety law applied, so manufacturers could add fragrance allergens without restriction or labeling, signaling scent only with words like "fresh".
Strong evidence: Legal status as of 2020 (GPSD 2001/95/EC, since replaced by GPSR 2023/988); no product-level exposure data.
Laws and loopholes / Measured in people or real products
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: The regulatory point (no FDA directive) is a stated fact, not itself a measured statistic; the 88.2% figure is from a single-region convenience sample of 135 products.
Source: Hamann 2015, Journal of Allergy and Clinical Immunology Link to this fact
Laws and loopholes / Measured in people or real products
No EU or Belgian law requires fragrance ingredients in topical medicines to be named on the label, or restricts which fragrance chemicals they may contain — unlike cosmetics, where the EU has required disclosure of major fragrance allergens since 2005.
Strong evidence: Regulatory statement as described in a 2009 paper; check current EU medicines regulation for any changes since.
Laws and loopholes / Government agency
A systematic comparison of occupational exposure limits from 18 countries and agencies found that only 25 of 1,341 chemicals studied have a limit set by every agency, and more than a third of the chemicals are regulated by only one of the 18.
Strong evidence: Workplace limits only, not consumer or indoor-air limits. A single (if large and systematic) comparative study; the paper does not analyze why the differences exist.
Source: Schenk et al. 2008, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
Laws and loopholes / Government agency
In the EU and UK, any cosmetic claim – including 'fragrance-free,' 'unscented,' 'free from X' or 'hypoallergenic' – is legally required to meet six common criteria (legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making) and must be backed by evidence the company holds on file, under a binding, directly applicable EU regulation in force since 2013.
Strong evidence.
Caveats
The regulation sets these six generic criteria but does not itself specify what evidence threshold applies to any particular claim wording; that level of detail sits in separate, unacquired Commission and industry guidance.
Source: Commission Regulation (EU) No 655/2013 Link to this fact
Laws and loopholes / Government agency
The EU regulation that governs cosmetic claims deliberately declines to define the terms 'free from,' 'hypoallergenic,' 'fragrance-free,' or 'unscented' – it states outright that the common criteria are not meant to define or specify permitted or forbidden claim wording, leaving that to case-by-case enforcement and separate guidance.
Strong evidence: Read from the regulation's own Recital 7 and confirmed by the absence of any of these terms anywhere in its text.
Source: Commission Regulation (EU) No 655/2013 Link to this fact
Laws and loopholes / Government agency
Under US regulations, fragrance and flavor ingredients in a cosmetic can be listed simply as "Fragrance" or "Flavor" on the label, because the Fair Packaging and Labeling Act cannot be used to force a company to disclose trade secrets, and fragrance/flavor formulas are the cosmetic components FDA itself identifies as most likely to qualify.
Strong evidence.
Caveats
This is the legal rule itself, quoted from FDA's own page (captured 2026-09-27); it says nothing about how many or which chemicals this hides in practice (see Steinemann/Dodson/Goldsmith measurements for that).
Source: FDA 2026 (Fragrances in Cosmetics) Link to this fact
Laws and loopholes / Government agency
FDA names laundry detergents, fabric softeners, dryer sheets, and room and carpet fresheners as fragranced products that fall under the Consumer Product Safety Commission rather than FDA cosmetics regulation.
Strong evidence: Statement of jurisdiction only; says nothing about what CPSC does or does not require of these products.
Source: FDA 2026 (Fragrances in Cosmetics) Link to this fact
Laws and loopholes / Government agency
Starting April 12, 2026, Canadian cosmetics must individually name 24 specific fragrance allergens (expanding to 81 by August 2026 for new products and August 2028 for existing products) when present above 0.001% in leave-on products or 0.01% in rinse-off products — a named, dated, threshold-based mandate the parallel US MoCRA fragrance-allergen provision (FFDCA section 609(b)) still lacks.
Strong evidence.
Caveats
The allergen list and thresholds are incorporated by reference from the EU's Annex III list, so Canada's implementation tracks the EU rather than being independently derived; it covers only named allergens, not the rest of any fragrance mixture. The MoCRA comparison is based on the statute's own text (no confirmed final rule as of this evidence base's last check) and FDA's own current consumer page, which as of the same 2026-09-27 capture date states FDA lacks cosmetic allergen-labeling authority and does not mention MoCRA at all.
Source: Health Canada 2026 Link to this fact
Laws and loopholes / Government agency
Canada requires cosmetic fragrance ingredients to be declared as 'parfum' (the word 'fragrance' alone is not acceptable), but does not require disclosure of the fragrance mixture's non-allergen constituents.
Strong evidence: A labeling-word requirement, not a composition disclosure requirement; a full fragrance ingredient list is legally optional, not mandatory, in Canada.
Source: Health Canada 2026 Link to this fact
Laws and loopholes / Other evidence
NEA enters into a paid, annually renewed license agreement with a brand/manufacturer to allow use of the Seal logo once a product is accepted; renewal depends on the manufacturer's own attestation that the formula has not changed, and any formula change requires restarting the application with new clinical testing.
Strong evidence: No fee amount is disclosed on this page; ongoing compliance between renewals relies on manufacturer self-report, not NEA-initiated re-testing.
Source: NEA 2026 Link to this fact
Laws and loopholes / Measured in people or real products
More than 70% of the chemicals measured in childcare air had no health-based safety limit; several fragrance compounds were among 12 the authors flagged for further study.
Moderate evidence: Flags come from database/QSAR hazard scores, not measured effects.
Laws and loopholes / Review of other studies
No law in the US, the EU or Australia requires air-freshener makers to list all their ingredients; a label can simply say 'fragrance'.
Moderate evidence: Review's legal summary (2016); EU cosmetics allergen labeling does not cover air fresheners.
Source: Steinemann 2017, Building and Environment Link to this fact
Laws and loopholes / Measured in people or real products
US product rules written to limit smog (ozone) exempt several chemicals that still form fine particles, and fragrance ingredients do not have to be disclosed.
Moderate evidence: Regulatory analysis in the paper.
Laws and loopholes / Review of other studies
The EU bans more than 1,400 substances from cosmetics, while US rules restrict only a handful.
Moderate evidence: EU list includes never-used substances; US rules changing under MoCRA 2022; verify against a regulatory source.
Source: Alblooshi 2025, Frontiers in Toxicology Link to this fact
Laws and loopholes / Journalism
In a 2010 undercover test by the US Government Accountability Office, the Energy Star program certified 15 fake products, including a gas-powered alarm clock the size of a generator.
Moderate evidence: Energy efficiency label, not chemical safety; EPA/DOE promised reform.
Source: Dahl 2010, Environmental Health Perspectives Link to this fact
Laws and loopholes / Measured in people or real products
Trace benzene was found in 83% of 79 US feminine hygiene products and 1,4-dioxane in 50%, yet these products are regulated as medical devices with no federal ingredient-disclosure requirement.
Moderate evidence: Trace ng/g levels; 1,4-dioxane is a surfactant by-product.
Source: Lin 2020, Environment International Link to this fact
Laws and loopholes / Review of other studies
History shows removing the exposure works: as industrial turpentine use fell from 94.5% of US supply as a solvent in 1935 to 4.5% in 1975, turpentine skin allergy declined with it.
Moderate evidence: Ecological historical correlation.
Source: Karlberg & Lepoittevin 2021, Contact Dermatitis Link to this fact
Laws and loopholes / Review of other studies
Official limits for the same gas odorant differed about 280-fold in 2009: Germany allowed 50 ppm at work, a Dutch health agency derived 0.18 ppm, and the US had no limit.
Moderate evidence: Regulatory values as reported by the paper (2009); may have been revised since.
Source: Baur & Bittner 2009, American Journal of Industrial Medicine Link to this fact
Laws and loopholes / Review of other studies
In the US, "fragrance-free" means that no ingredient is used solely to give a smell. A fragrance chemical that also does another job, such as benzyl alcohol used as a preservative, can legally be in a "fragrance-free" product.
Moderate evidence: US definition as quoted by dermatologists in 2007; not a legal analysis; FDA has no binding definition of "fragrance-free".
Laws and loopholes / Review of other studies
After German industry stopped using musk xylene in 1993, its level in breast milk fell about 70% in four years, but the related musk ketone, which was not phased out, did not fall.
Moderate evidence: Cites a BgVV 2000 press release; single-country natural experiment.
Source: Schmeiser 2001, International Journal of Hygiene and Environmental Health Link to this fact
Laws and loopholes / Self-reported survey
Nearly half (49%) of US families in a survey bought children's makeup from large online retailers, and US labeling law (the Fair Packaging and Labeling Act) requires ingredient lists on the package, not on the website.
Moderate evidence: Purchase share is survey self-report; legal point is the authors' reading of the FPLA as of 2022.
Source: Medley 2023 Link to this fact
Laws and loopholes / Review of other studies
Fewer than 20% of the roughly 3,000 high-production-volume (HPV) chemicals in the US have been tested for potential to cause developmental neurotoxicity.
Moderate evidence.
Caveats
Directly verified in Landrigan 2010 (Curr Opin Pediatr), which states this identically in its abstract and body text, citing Goldman 1998 (Environ Health Perspect) as the primary source — not yet read in this evidence base, and not raw EPA testing data. Concerns high-production-volume chemicals in general (solvents, metals, pesticides); Landrigan 2010 never names a fragrance or cosmetic ingredient.
Source: Sealey 2016 (citing Landrigan 2010), Environment International Link to this fact
Laws and loopholes / Review of other studies
The researchers report that citronellol content varies up to 1000-fold within the same product category, which they attribute to the absence of regulation of fragrance content in household products.
Moderate evidence: Stated in the discussion citing industry/market sources; no product measurements in this paper.
Source: Kim 2024, Journal of Hazardous Materials Link to this fact
Laws and loopholes / Measured in people or real products
Workers with fragrance-related asthma were twice as likely as other work-asthma cases to still be exposed at work (50% vs 26%) and more often had workers' compensation claims denied (30% vs 21%), though ER visit and hospitalization rates were the same.
Moderate evidence: Interviewed cases only (~58% of fragrance cases); unadjusted.
Laws and loopholes / Review of other studies
More than 40% of US occupational exposure limits are set to prevent eye, nose and throat irritation, and a systematic comparison of 18 agencies confirms that US, German and EU regulators set substantially different limits for the same chemicals — overall stringency ranges from Poland's geometric-mean level of 0.23 to US OSHA's 0.61 (a 2.67-fold spread), with the EU's own 'health-based' indicative limits sitting above Germany's stricter national MAK limits.
Moderate evidence.
Caveats
Workplace limits, not consumer or home limits. The >40%-for-irritation figure is still secondhand (Edling & Lundberg 2000, not independently in our evidence base). The 'agencies differ' clause is now backed by a large, systematic primary (Schenk et al. 2008: 18 agencies, 1,341 substances), but the claim stays below 'strong' because the irritation-basis figure remains unverified.
Source: Dalton & Jaén 2010, Current Opinion in Allergy and Clinical Immunology Industry-funded Link to this fact
Laws and loopholes / Review of other studies
A fragrance-and-flavor company reported that about half of the chemicals it handles are classified hazardous, and that few of the more than 3,000 flavoring substances in use have workplace exposure limits.
Moderate evidence: Industry self-description, no inventory published; flavor materials at one company.
Source: Angelini 2016, PLoS ONE Industry-funded Link to this fact
Laws and loopholes / Review of other studies
US product labels only have to say "fragrance", not which chemicals, and household products need not list ingredients at all; MoCRA (2022) requires companies to name on cosmetic labels the fragrance allergens FDA designates by regulation (proposed rule was due June 2024), which the authors expect to be many, but not all.
Moderate evidence: Check current MoCRA rule status before quoting; household products are outside MoCRA; statute §609(b) is a mandate; check final rule status.
Laws and loopholes / Measured in people or real products
The UK national air-pollution inventory counts zero emissions of limonene or the silicone D5 from shampoos, shower gels and skin products, although these were the two largest emissions measured from them.
Moderate evidence: The authors judge the missing mass small at national scale (~0.4 kt/yr vs 807 kt total UK VOC).
Laws and loopholes / Review of other studies
Most national microbead bans cover only rinse-off products such as scrubs and cleansers; microplastics are still commonly used in leave-on products, especially color cosmetics like lipstick and eye makeup.
Moderate evidence: Narrative review; 8 of 14 listed jurisdictions explicitly rinse-off/exfoliant only; EU 2023/2055 is broader.
Laws and loopholes / Review of other studies
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: Secondhand from a 2018 JAMA Intern Med commentary; EU count includes substances never used; US rules changed after MoCRA 2022.
Source: Khalid & Abdollahi 2021, Iranian Journal of Pharmaceutical Research Link to this fact
Laws and loopholes / Lab study (cells or chemistry)
A finished perfume is usually not toxicity-tested as a whole; its safety is assessed on paper from its secret ingredient list. When researchers tested 42 whole perfumes directly, they found hazards that ingredient-by-ingredient assessment is not designed to catch.
Moderate evidence: EU framework described by the authors; the hazards are in vitro and unidentified.
Source: Morlock & Heil 2025, Journal of Chromatography A Link to this fact
Laws and loopholes / Review of other studies
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: Asserted without evidence; interview evidence is Scruggs & Ortolano 2011.
Source: BCPP 2018 Link to this fact
Laws and loopholes / Review of other studies
A 2015 CMAJ editorial (Flegel & Martin, CMAJ 187:1187, DOI 10.1503/cmaj.151097) states hospital environments free from artificial scents 'should become a uniform policy, promoting the safety of patients, staff and visitors alike'; the US CDC's own workplace policy separately says fragrance 'is not appropriate for a professional work environment' (CDC wording still unverified against a primary CDC source).
Moderate evidence.
Caveats
CMAJ quote now verified against the primary editorial, now in our evidence base (src-2015-artificial-scents-no-place-hospitals): exact wording is 'should become a uniform policy' (ASEQ-EHAQ's paraphrase drops the article 'a', not a substantive misquote). The editorial is opinion/commentary, not a study — its own cited prevalence numbers (30% scent sensitivity, 27% of asthmatics worsened) are the same Caress & Steinemann survey figures used elsewhere in our evidence base. CDC portion remains unverified; the CMAJ editorial itself never mentions the CDC.
Source: ASEQ-EHAQ 2020 (quoting CMAJ 2015 and CDC) Link to this fact
Laws and loopholes / Review of other studies
People with chemical sensitivities asked the US Justice Department to consider fragrance as an access barrier during its 2008 ADA rulemaking.
Moderate evidence: Shows the issue was raised in the record; the attachment makes no legal argument and our evidence base has no record of DOJ's response.
Source: DONTSPRAYCALIFORNIA 2008 (DOJ ADA docket) Link to this fact
Laws and loopholes / Advocacy group testing
In a 2010 Canadian survey, volunteers found no ingredient list on 28% of toothpastes and mouthwashes and 14% of antiperspirants and deodorants; in Canada, personal-care products sold as 'drugs' need list only their active ingredients.
Moderate evidence: Some missing lists were discarded outer packaging; 2010 Canadian law.
Laws and loopholes / Government agency
In the US, fragrance sensitivity or multiple chemical sensitivity can count as a disability under the Americans with Disabilities Act, but not automatically: it is decided case by case, usually on whether breathing is substantially limited.
Moderate evidence: Authors' reading of statute in a 2009 business-conference paper; no case survey; the 2008 ADA Amendments postdate their cases.
Laws and loopholes / Government agency
In Hunt v. St. Peter School (1997), a scent-free classroom was treated as a reasonable accommodation, but a school-wide fragrance ban was ruled an undue hardship.
Moderate evidence: One district-court case as described by the authors; the opinion itself is not in our evidence base.
Laws and loopholes / Review of other studies
As of 2011, US law let makers write 'fragrance' instead of listing its ingredients as a trade secret, and the FDA pre-approved only color additives in cosmetics; the industry's own review panel had declared just 9 ingredients unsafe since 1976.
Moderate evidence: US situation in 2011; MoCRA (2022) later added limited changes; CIR count from its 2011 website.
Source: Gilton 2011 Link to this fact
Laws and loopholes / Animal study
The EU cosmetics committee's own estimate of how much 4-MBC enters the body of someone using it (0.23 mg/kg body weight) was only three times below the no-effect dose, and thirty times below the lowest harmful dose, in this rat developmental study.
Moderate evidence.
Caveats
The human figure is a 1998 SCCNFP estimate, not a measurement; rat dosing was oral and lifelong while human exposure is dermal and intermittent; developmental risk assessment normally applies a 100-fold factor, which this margin does not meet.
Laws and loopholes / Measured in people or real products
Glycol solvents brought into consumer products as 'low-reactivity' replacements, and largely exempt from VOC limits, still make a large share of consumer-product ozone because so much is used.
Moderate evidence: Model result (oxygenates ~37% of VCP ozone in NYC); exemption statement is the authors' summary of US rules.
Source: Coggon 2021 Link to this fact
Laws and loopholes / Review of other studies
US law has never defined "fragrance-free"; the only definition is of fragrance itself ("used solely to impart an odor", 21 CFR 700.3(d)), so an ingredient that smells but is also claimed as a preservative or moisturizer can go into a "fragrance-free" product. FDA's own website said in 1999 that "fragrance-free" products, like "unscented" ones, may contain fragrance chemicals.
Moderate evidence.
Caveats
Legal point from a 1999 commentary quoting the FDA's own website of that era, not a legal analysis or product survey. The US statute (MoCRA 2022) still has not defined 'fragrance-free' 23 years later.
Source: Scheinman 1999, Journal of the American Academy of Dermatology Link to this fact
Laws and loopholes / Review of other studies
A 2015 CMAJ editorial by two physicians argued that hospitals should adopt uniform scent-free policies, because patients — unlike employees — cannot request accommodation and can be involuntarily exposed to fragrance from staff, other patients or visitors.
Moderate evidence.
Caveats
An opinion editorial (peer-reviewed CMAJ commentary), not a study; its cited prevalence (~30% scent-sensitive, 27% of asthmatics worsened) and atopy/BHR findings are secondary citations of Caress & Steinemann 2009 and Elberling 2005, already in our evidence base.
Source: Flegel & Martin 2015, CMAJ (Canadian Medical Association Journal) Link to this fact
Laws and loopholes / Review of other studies
As of 2015, no Canadian hospital accreditation standard required a scent-free policy, and it was not policy in all Canadian hospitals.
Moderate evidence: The editorial's own 2015 assessment; the policy landscape may have shifted since — see Roy 2026 for a later, focus-group-based assessment of implementation gaps.
Source: Flegel & Martin 2015, CMAJ (Canadian Medical Association Journal) Link to this fact
Laws and loopholes / Review of other studies
A leading pediatric environmental-health review states that fewer than 20% of the roughly 3,000 high-production-volume industrial chemicals in the US have been tested for potential to cause developmental neurotoxicity.
Moderate evidence: Landrigan 2010 traces this to Goldman 1998 (Environ Health Perspect), not read directly in this evidence base; concerns industrial chemicals in general, not fragrance specifically.
Source: Landrigan 2010, Current Opinion in Pediatrics Link to this fact
Laws and loopholes / Review of other studies
A 2006 Lancet review found that of roughly 3,000 US high-production-volume industrial chemicals, basic toxicity data were publicly unavailable for nearly half, and 80% had no information on developmental or pediatric toxicity at all.
Moderate evidence.
Caveats
Cites the US EPA's own 1998 Chemical Hazard Data Availability Study directly, one citation hop closer to a primary than the Goldman 1998 chain behind our other testing-gap claim. Concerns general developmental/pediatric toxicity testing, a broader category than the narrower 'developmental neurotoxicity' endpoint in the related claim — not a strict numeric confirmation of it. About industrial chemicals in general (solvents, metals, pesticides); no fragrance ingredient named.
Source: Grandjean & Landrigan 2006, Lancet Link to this fact
Laws and loopholes / Government agency
The overall strictness of occupational exposure limits varies nearly threefold between the strictest and most lenient of 18 regulators studied, and the European Union's own limits, despite being described as purely health-based, are on average less strict than Germany's national limits.
Moderate evidence.
Caveats
One systematic study, not replicated by another research group; a database-wide average that does not predict the direction for any single chemical (e.g. Germany's ethyl acetate limit is reportedly higher than the EU's for that one substance).
Source: Schenk et al. 2008, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
Laws and loopholes / Measured in people or real products
Even though EU law requires 26 specific fragrance allergens to be named individually above 0.01% concentration, 60% of the 1,447 scented detergents in this German household study listed only the generic term 'perfume', 'fragrance', or 'aroma' rather than naming any specific allergen, and only 46% named any of the 26 at all.
Moderate evidence.
Caveats
Generic wording can be legal (allergen absent, below threshold, or arriving undeclared via a natural extract, which the rule exempts); this paper did not test which explanation applies in which product.
Source: Wieck 2018, Regulatory Toxicology and Pharmacology Link to this fact
Laws and loopholes / Government agency
The UK continues to apply essentially the same EU cosmetic-claims rule after Brexit, unchanged in substance, as retained domestic law, with the UK's own legislation register confirming no outstanding legal effects have altered it.
Moderate evidence: Confirmed as of this single 2026-09-27 capture of legislation.gov.uk; the register could change at any later date and was not tracked over time here.
Source: Commission Regulation (EU) No 655/2013 Link to this fact
Laws and loopholes / Government agency
The European Commission's own guidance on cosmetic 'free from' claims (agreed with industry in 2017) says a 'free from perfume' claim should not be used if the product contains any ingredient that exerts a perfuming function, regardless of that ingredient's other functions — wording that would exclude a masking fragrance, not permit one.
Moderate evidence.
Caveats
Non-binding guidance, not the regulation itself, and it never uses the words 'fragrance-free', 'unscented' or 'masking agent'; this is our reading of its 'free from perfume' wording, not a direct statement about masking.
Source: EC Technical Document on Cosmetic Claims 2017 Industry-funded Link to this fact
Laws and loopholes / Government agency
EU guidance says a 'hypoallergenic' cosmetic claim requires the company to actively rule out known and suspected skin sensitizers through six named routes (including its own consumer-complaint records) and states plainly that the claim 'does not guarantee a complete absence of risk of an allergic reaction'.
Moderate evidence.
Caveats
Non-binding guidance (agreed by the Working Group on Cosmetic Products, not itself EU law); no EU product-testing study in our evidence base checks whether products actually meet this bar in practice.
Source: EC Technical Document on Cosmetic Claims 2017 Industry-funded Link to this fact
Laws and loopholes / Government agency
Under the EPA's Safer Choice program, 'fragrance-free' and 'unscented' are not the same claim: 'unscented' still allows a masking chemical added to cover other ingredients' smell, while 'fragrance-free' specifically bars masking scents as well as added scent.
Moderate evidence.
Caveats
This is the program's own written definition (evidence/agency), not a product-testing result; it applies only to products certified under this specific EPA program, not to any product that merely uses the words on its own label.
Source: US EPA Safer Choice Link to this fact
Laws and loopholes / Government agency
As of this page's 2026-09-27 capture, FDA's own consumer guidance states it "does not have the same legal authority to require allergen labeling for cosmetics as for food," and does not mention MoCRA or any pending/final fragrance-allergen rule, more than three years after MoCRA required FDA to write one.
Moderate evidence.
Caveats
This evidence base did not independently check the Federal Register/FDA rulemaking docket for a §609(b) rule; the page shows no "last updated" date, so it may simply be stale rather than reflecting the current rule status.
Source: FDA 2026 (Fragrances in Cosmetics) Link to this fact
Laws and loopholes / Journalism
As of 2010, the US FTC's Green Guides on environmental marketing claims had not been updated since 1998.
Weak evidence: Outdated: the Green Guides were revised in 2012 (and an update was proposed in 2022); do not use as a current fact.
Source: Dahl 2010, Environmental Health Perspectives Link to this fact
Laws and loopholes / Measured in people or real products
Musk ambrette, banned in the EU for years, was still detected in the blood of 2 of 100 young Austrians tested, and testing the specific lotion and perfume one of them used did not find musk ambrette in the product itself, so the source of the banned chemical could not be pinned down.
Weak evidence.
Caveats
N=2; the tested products were negative for musk ambrette, so contamination, an unlisted supply-chain source, or a different untested product cannot be distinguished; no source identified.
Source: Hutter 2009, Science of the Total Environment Link to this fact
Laws and loopholes / Government agency
Allergy UK's product-endorsement page does not disclose who pays for testing or endorsement; it sits under a business-facing URL and ends in a manufacturer submission form, consistent with (but not confirmation of) a manufacturer-initiated, fee-based process.
Weak evidence: Fee/payer structure is inferred from page layout, not stated by the source; do not cite this page for a fee claim.
Source: Allergy UK 2026 Link to this fact
Information, not medical advice. See also: myths we won’t tell you.