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 / 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
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 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 / Review of other studies
Multiple chemical sensitivity has no dedicated diagnostic code and is instead coded, when coded at all, under nonspecific ICD-10 codes for unspecified respiratory conditions from inhaled fumes/gas/chemical vapors (J68.9) or unspecified allergy/hypersensitivity/idiosyncrasy (T78.4); some countries and agencies (US EPA, US ADA, Germany, Austria) have given the condition some form of recognition, while Italy's health ministry has declined to recognize it as a rare disease due to diagnostic-nosology difficulty.
Moderate evidence.
Caveats
Regulatory-recognition landscape as of this review's 2015 search cutoff and largely focused on Italy; recognition status in individual US states, agencies or other countries may have changed since, and the review does not cite the specific EPA/ADA source documents establishing "recognition.".
Source: Rossi 2018, Journal of Occupational & Environmental Medicine Link to this fact
Laws and loopholes / Journalism
Neither the US Food and Drug Administration nor the Consumer Product Safety Commission requires individual fragrance ingredients to be listed on product labels or Material Safety Data Sheets.
Moderate evidence: Regulatory/legal statement, not a chemistry finding; drawn from the article's own citations to FDA and CPSC statutes.
Source: Kessler 2011 (EHP Forum), Environmental Health Perspectives Link to this fact
Laws and loopholes / Measured in people or real products
The EU's mandatory '26 allergens' cosmetic label did not reduce allergen use in German deodorants: the share containing at least one of the 26 EU-labeled fragrance allergens rose from 52% (2008) to 83% (2011), years after the labeling rule took effect.
Moderate evidence.
Caveats
Three non-representative convenience samples of the German market (n=66/200/108), not a tracked panel of the same products; the author states representativeness for the whole market is not established.
Source: Klaschka 2012, International Journal of Hygiene and Environmental Health Link to this fact
Laws and loopholes / Measured in people or real products
Deodorants marketed with words like 'sensitive', 'soft' or 'skin soothing' were not allergen-free: 95% still contained perfume and 15% contained a strong allergen above the labeling threshold.
Moderate evidence: N=102 of 308 products across the 2010-2011 samples; single-country, label-based.
Source: Klaschka 2012, International Journal of Hygiene and Environmental Health Link to this fact
Laws and loopholes / Measured in people or real products
Where two specific fragrance allergens (Lyral, oak moss extract) did become rarer in German deodorants, it tracked binding IFRA/SCCNFP maximum-concentration recommendations introduced around 2004-2009, not the general disclosure-only labeling rule.
Moderate evidence.
Caveats
A within-paper contrast drawn by the author from the same three-year dataset; only 2 of the 26 allergens had a specific concentration cap recommended, so this may not generalize to the other 24.
Source: Klaschka 2012, International Journal of Hygiene and Environmental Health Link to this fact
Laws and loopholes / Other evidence
The same biocidal preservative gets an EU environmental risk assessment when used in a laundry detergent but not when used, at the same concentration limits, in a shampoo or lotion, because personal-care-product preservative safety is delegated to REACH instead of the Biocidal Products Regulation — and REACH was not designed to environmentally assess substances with intended biological effects. A 2016 household-inventory study found 63.8% of all biocidal-substance uses observed (2,618 of 4,106) had no environmental risk assessment coverage under the Biocidal Products Regulation.
Moderate evidence.
Caveats
Single study's regulatory analysis of the German/EU legal structure circa 2015-2016; the 63.8% figure reflects this household sample's specific product mix, not a formal EU-wide audit.
Source: Wieck 2016, Environment International Link to this fact
Laws and loopholes / Review of other studies
Under the EU's REACH chemical regulation, data from the mouse sensory-irritation bioassay are generally not accepted to classify a chemical as causing respiratory tract irritation (that classification is limited to tests showing direct tissue damage); the bioassay's data can only be used case-by-case to help set a short-term safe-exposure value.
Moderate evidence.
Caveats
Describes the regulation's stated scope as the authors summarize it (citing ECHA 2012, 2017 guidance documents), not an independent legal analysis; the authors argue this restriction rests on a misreading of an earlier study by a different group.
Source: Nielsen & Wolkoff 2017, Regulatory Toxicology and Pharmacology Industry-funded Link to this fact
Laws and loopholes / Review of other studies
A scoping review of 63 fragrance-free/scent-free policies from Canadian and US institutions found that fewer than half (47.6%) actually define what counts as "fragranced," leaving most policies to rely on an undefined, subjective standard.
Moderate evidence.
Caveats
Gray-literature document review (no peer-reviewed policy literature qualified for inclusion); findings are overwhelmingly North American (59/63 documents) and describe policy text, not enforcement in practice.
Laws and loopholes / Review of other studies
Only about 1 in 3 (36.5%) of 63 reviewed fragrance-free policies set a default fragrance-free standard; most instead require an individual to request accommodation or file a complaint before anything changes.
Moderate evidence.
Caveats
Document analysis of published policy text, not a measure of what actually happens when a complaint is filed; sample is gray literature the authors could find online, not a census of all such policies.
Laws and loopholes / Review of other studies
Fewer than half (46.0%) of 63 reviewed fragrance-free policies included any supply-chain or procurement control over the cleaning, laundry, or air-freshening products the institution itself buys, even though named triggers in the companion focus-group study rank cleaning and laundry products alongside or above perfume.
Moderate evidence: Document analysis; does not establish that procurement control would reduce measured exposure, only that most policies do not attempt it.
Laws and loopholes / Review of other studies
Two-thirds (65.1%) of 63 reviewed fragrance-free policies describe some enforcement mechanism, but only about 1 in 5 (22.2%) specify an actual consequence for breaking the rule, and responsibility for compliance is left unclear in 42.9% of policies.
Moderate evidence: Document analysis of stated policy language; a policy can specify consequences on paper and still not apply them, which this review cannot measure.
Laws and loopholes / Review of other studies
Only 15.9% of 63 reviewed fragrance-free policies included formal staff training, and only 22.2% specified a review or evaluation cycle, despite 74.6% naming a responsible authority and 95.2% stating a rationale for the policy.
Moderate evidence.
Caveats
Gray-literature document review; the gap between naming an authority and specifying monitoring is a feature of the published text, not a direct measurement of institutional follow-through.
Laws and loopholes / Measured in people or real products
The natural extracts Evernia furfuracea (tree moss) and Evernia prunastri (oak moss) were labeled on only 14 and 3 of 5,588 cosmetic products respectively, far rarer than their frequency as sensitizers in European patch-test clinics, most likely because they are used in concentrations below the EU's 10 ppm (leave-on) / 100 ppm (rinse-off) labeling thresholds.
Moderate evidence: The paper infers the below-threshold explanation; it did not chemically analyze product concentrations to confirm it.
Source: Bennike 2017/2018 Link to this fact
Laws and loopholes / Review of other studies
Only 26 fragrance allergens currently must be individually listed on EU cosmetic labels; the report states the European Commission was expected to expand this list by another 62 allergens.
Moderate evidence: As of this report (2022) the expansion was 'expected'; the actual expanded EU list (Regulation 2023/1545) was adopted after this report was published.
Source: Tegengif 2022 Link to this fact
Laws and loopholes / Review of other studies
Lilial (butylphenyl methylpropional) was banned from EU cosmetics starting March 2022 on reproductive-toxicity grounds (CMR Category 1B classification from its REACH dossier) — a different and separate hazard axis from the endocrine-disruption and genotoxicity questions that remain contested or unconfirmed in the literature for the same compound.
Moderate evidence: Regulatory background restated from the paper's introduction (citing Regulation (EU) 2021/1902), not this paper's own new data.
Source: Jablonská 2023, Sci Rep 13:18536, Scientific Reports Link to this fact
Laws and loopholes / Review of other studies
EU cosmetics law caps aluminum-zirconium antiperspirant complexes at 20% hydroxychloride and 5.4% zirconium and bans them outright in aerosol sprays, but sets no equivalent binding limit on plain aluminum salts such as aluminum chlorohydrate.
Moderate evidence: Regulatory text as relayed by a single review; not independently verified against the current consolidated Annex III text.
Source: Martini 2020, Annales de Dermatologie et de Vénéréologie Link to this fact
Laws and loopholes / Review of other studies
After regulators banned BPA from baby bottles (EU 2011, Canada 2010, US FDA 2012-2013), manufacturers increasingly switched to substitute bisphenols such as BPS and BPF, which several human studies now also link to obesity and which are not proven to be safer than BPA.
Moderate evidence.
Caveats
Some studies of BPS/BPF exposure found no significant association with obesity, so the evidence is not unanimous, though none of the substitutes has been shown to be free of hormone-disrupting activity.
Source: Dalamaga 2024, International Journal of Molecular Sciences Link to this fact
Laws and loopholes / Review of other studies
Some salicylate compounds not approved by the FDA as sunscreen UV filters (e.g. butyloctyl salicylate, tridecyl salicylate) are added to mineral sunscreens under the ingredient category "stabilizer" rather than "UV filter" — a practice the review calls "doping" — letting manufacturers reduce the white cast of mineral formulations while avoiding the UV-filter regulatory category.
Moderate evidence: Single secondary citation for the labeling practice; not independently verified against product labels in this review.
Source: Hodge 2025, Marine Pollution Bulletin Link to this fact
Laws and loopholes / Review of other studies
Octocrylene, which sunscreen manufacturers adopted as an alternative after bans on oxybenzone in reef-protective jurisdictions (Hawaii, Key West Florida, Bonaire, Aruba, Palau, US Virgin Islands), is itself contaminated with benzophenone during manufacture and cannot be fully purified of it; it also undergoes a slow retro-aldol condensation reaction in the finished product that continuously regenerates more benzophenone as the sunscreen ages.
Moderate evidence: The underlying primary (Downs et al. 2021a) is not yet a evidence base source; treat the aging/regeneration mechanism as reported by this review pending that primary.
Source: Hodge 2025, Marine Pollution Bulletin Link to this fact
Laws and loopholes / Review of other studies
Global DEHP regulation is patchy and mostly national: Japan restricted DEHP in food packaging and childcare products in 2003, the EU in 2006, and Canada, the USA, and Australia later banned DEHP above set concentrations in children's products, but many countries still lack comprehensive DEHP regulation, and the exposure data analyzed in this study (2008) predate most of these rules.
Moderate evidence: Regulatory history as summarized in the paper's Discussion, not independently verified against primary legal texts.
Laws and loopholes / Government agency
A year before DOJ's case-by-case ruling, HUD's own internal guidance (Technical Guidance Memorandum 91-3, June 1991) told its regional Fair Housing investigators without qualification that "HUD presently recognizes MCSD as a 'handicap' under the Fair Housing Act" and that people with it "are also considered 'individuals with handicaps' under Section 504" — a more categorical stance than DOJ later endorsed.
Moderate evidence.
Caveats
This is an internal HUD policy memo, not a court ruling or DOJ's own position; DOJ's 1992 letter (the same file) declines to adopt this categorical framing, and nothing in our evidence base shows whether HUD later revised the memo.
Source: HUD TGM 91-3 (1991) Link to this fact
Laws and loopholes / Government agency
In a 1993 letter of findings, the US Department of Justice determined that a public entity is not required to prohibit employees from wearing perfume or other scented products, because that would not be a "reasonable" modification to personnel policy under ADA title II.
Moderate evidence.
Caveats
A technical-assistance letter states DOJ's own enforcement position; it is not a regulation or court ruling and does not bind courts. Addresses title II public access only, not title I employment accommodation.
Source: DOJ Civil Rights Division 1993 (TAL 383) Link to this fact
Laws and loopholes / Government agency
The same 1993 DOJ letter states that failing to adopt any access policy for individuals with environmental illness does not itself violate title II of the ADA, and that nothing in the ADA or its legislative history shows Congress meant to require public entities to regulate employees' use of scented products.
Moderate evidence: DOJ's own stated position at the time; not a court ruling, and DOJ explicitly declined to decide whether environmental illness meets the ADA's disability definition.
Source: DOJ Civil Rights Division 1993 (TAL 383) Link to this fact
Laws and loopholes / Government agency
In 1995 the US Department of Justice told a member of the public that under the ADA, it would 'usually' not be legally required for a medical facility to make its staff stop wearing fragrance to accommodate a patient with multiple chemical sensitivity, because fragrance use is treated as an employee's personal choice rather than a business policy.
Moderate evidence.
Caveats
Informal technical assistance to one inquirer, not a regulation or case law; DOJ's own letter states it 'does not constitute a legal interpretation of the statute' and 'is not binding on the Department.' 30 years old; predates the 2008 ADA Amendments Act's broadened definition of disability (a separate legal question this letter does not address).
Source: DOJ TAL605, 1995 Link to this fact
Laws and loopholes / Government agency
DOJ's letter answered a general, facility-wide framing of the question ('require their employees to refrain from wearing fragrances'), not the complainant's actual, narrower request for one department to go fragrance-free for one scheduled day.
Moderate evidence: DOJ's reply never analyzes the narrower request or any undue-hardship balancing; the mismatch is visible only by reading the attached correspondence alongside the reply.
Source: DOJ TAL605, 1995 Link to this fact
Laws and loopholes / Government agency
HUD's own Occupancy Handbook (4350.3 REV-1, Exhibit 2-6, June 2007) states that for a HUD-assisted housing resident with chemical sensitivity disorder, it is not an undue financial and administrative burden for the owner to give advance notice before cleaning common areas and to use nonchemical alternative cleaning methods where practical.
Moderate evidence.
Caveats
Binding operational guidance for HUD-assisted multifamily housing, not a court ruling; applies only to owner-controlled common-area cleaning, not to other tenants' or staff's personal fragrance/scent use, and 'where practical' is left case-by-case.
Source: HUD Occupancy Handbook 4350.3 REV-1, Exhibit 2-6 (2007) Link to this fact
Laws and loopholes / Government agency
The same HUD guidance states it would be an undue administrative burden for a HUD-assisted housing owner to survey every tenant in a building for what chemicals they use to clean their own units and when, and compile that into a weekly report for a chemically sensitive resident.
Moderate evidence.
Caveats
HUD's stated reason is administrative capacity ('could not be handled by the existing staff'), not cost; this refusal is specific to a full building-wide, ongoing, per-tenant monitoring and reporting scheme, not to lesser accommodations.
Source: HUD Occupancy Handbook 4350.3 REV-1, Exhibit 2-6 (2007) Link to this fact
Laws and loopholes / Government agency
The EU sets a specific migration limit of 0.6 mg/kg for benzophenone as a plastics additive (Directive 2002/72/EC) and caps its deliberate use as a flavoring at 0.5 mg/kg in beverages and 2 mg/kg in foods generally (Council of Europe, 2000), while US reported flavoring-use levels range from 0.57 to 3.27 ppm across beverage, baked-good, and frozen-dairy categories.
Moderate evidence.
Caveats
Regulatory limits describe permitted/reported levels, not measured exposure; actual food-content surveys cited elsewhere in the monograph found some samples above these reference levels (e.g., 7.3 mg/kg in one high-fat chocolate).
Source: IARC 2013 Link to this fact
Laws and loopholes / Government agency
The ACCC's 2019 consultation paper compared Australia's cosmetics labeling rules against the EU, New Zealand, US, and ISO standards in detail and identified nanomaterial disclosure and additional label fields (expiry date, batch number, responsible person, product function) as the substantive gaps worth reforming — fragrance-allergen disclosure was not raised anywhere in the paper as an issue, gap, or reform option.
Moderate evidence.
Caveats
Absence of a topic in a policy document is evidence the ACCC did not identify it as an issue at that time; it is not proof the ACCC considered and affirmatively rejected an allergen list.
Source: ACCC 2019 Link to this fact
Laws and loopholes / Review of other studies
The Endocrine Society calls for EDC regulation generally to be hazard-based and precautionary rather than risk/threshold-based, the same hazard-based approach the EU currently applies only to pesticides and biocides and not to cosmetics, toys, or food-contact materials.
Moderate evidence.
Caveats
The statement itself does not discuss the EU's cosmetics carve-out or recommend extending hazard-based regulation to cosmetics specifically; the link to the EU's two-track policy is this evidence base's inference, not the Society's stated position.
Source: Endocrine Society 2025 Link to this fact
Laws and loopholes / Other evidence
MoCRA's mandated talc-in-cosmetics asbestos testing-methods rule was proposed by FDA in December 2024 and then withdrawn in November 2025.
Moderate evidence: Based on FDA's own overview page's link labels and dates, not on the Federal Register documents' full text, which were not separately captured in this batch.
Source: FDA MoCRA overview page, accessed 2026-09-28 Link to this fact
Laws and loopholes / Government agency
The New Zealand cosmetics standard amendment taking effect 1 January 2026 (decision APP204297, dated 25 January 2024) covers the group standard's scope, Schedules 4 to 8, and a PFAS phase-out, according to the superseded document's own regulatory-history table — labeling requirements are not named as part of what changed.
Moderate evidence.
Caveats
This is a secondhand summary from the pre-amendment document's own regulatory-history table, not the amendment's full text; the actual current EPA document was not fetched or read in this ingest.
Source: Cosmetic Products Group Standard 2020 (NZ, HSR002552, consolidated to 2025) Link to this fact
Laws and loopholes / Self-reported survey
MCS is legally recognized as a disability in Canada, but in a national survey most people with MCS who asked for a workplace or housing accommodation before the pandemic (85% of 119) were refused at least once (the paper's own figure: 'at least 78%').
Moderate evidence.
Caveats
Self-reported, cross-sectional, community-based convenience sample of 119 recruited substantially through an MCS advocacy charity's own channels (ASEQ-EHAQ, which also funded the study and paid some authors); over-represents Quebec; likely under-represents the most severely affected.
Source: Diallo 2026 Link to this fact
Laws and loopholes / Self-reported survey
Fear of retaliation, stigma, and losing support increasingly kept Canadians with MCS from even requesting an accommodation: the share who did not request one nearly tripled, from 15% before the COVID-19 pandemic to 42% after, and every listed fear-based reason for not requesting increased over the same period.
Moderate evidence.
Caveats
Self-reported, n=119 (18 and 50 respondents gave reasons in the two periods respectively), multi-select so percentages exceed 100%; cannot separate deterrence from reduced need (e.g., remote work) as the cause.
Source: Diallo 2026 Link to this fact
Information, not medical advice. See also: myths we won’t tell you.