The EU fragrance allergen list went from 24 to 80
You asked the lab to remove fragrance, and limonene still shows up on the ingredient list. The EU added 56 substances to the 24 it already required, and the deadline for newly launched products passed on 31 July 2026. The trigger is 0.001% in leave-on products.
What a sensitive-skin product has to drop is not the word "fragrance" but a list of named substances. Regulation (EU) 2023/1545 added 56 allergens to the 24 already requiring individual declaration, taking the list to roughly 80, and newly launched products had to comply by 31 July 2026. The trigger concentrations are 0.001% leave-on and 0.01% rinse-off, the same figures Korea uses.
Why limonene appears on a "fragrance-free" ingredient list
Almost every sensitive-skin brief says "no fragrance." Then the finished ingredient list comes back with limonene or linalool at the tail end, and the brand assumes the lab ignored the request. The paperwork is usually correct.
Both the EU and Korea refuse to let certain scent constituents hide inside the single word "fragrance." Above a set concentration, each one has to be named on its own. So the thing a sensitive-skin product removes is not a category — it is a list of specific substances. Treating the two as the same thing is where label copy goes wrong.
The first EU deadline has already passed
Regulation (EU) 2023/1545, published in July 2023, expanded the list substantially. Fifty-six substances joined the 24 that were already in entries 67–92 of Annex III, which sources total as 80 or 81 depending on how the natural extracts are counted.
The dates matter more than the count. Products newly placed on the EU market had to comply from 31 July 2026; stock already being made available has until 31 July 2028. If samples are moving toward Europe right now, the first of those dates is behind you.
| Korea | EU | |
|---|---|---|
| Substances | 25 scent allergens | 24 → roughly 80 |
| Leave-on trigger | above 0.001% | 0.001% (10ppm) |
| Rinse-off trigger | above 0.01% | 0.01% (100ppm) |
| In force | 1 January 2020 | new 31 Jul 2026 / existing 31 Jul 2028 |
The trigger concentrations are identical. A formula already screened for the Korean domestic market does not need new arithmetic — it needs the same arithmetic run against a longer list.
Essential oils are allergen bundles, not an exemption
This is where briefs break down. Swapping synthetic fragrance for plant-derived oil reads as a sensitive-skin decision, and on the label it often does the opposite.
Orange oil runs 91.4–97.0% limonene. With a leave-on trigger of 0.001%, dosing orange oil at 0.0011% already pushes limonene past 10ppm. For scale, 0.001% is one milligram in a 100g jar.
Lavender and citrus oils carry linalool, limonene, geraniol and citronellol together, so a single oil can add three or four lines to the declarable list. "Naturally derived" and "not declarable" are separate claims, and only one of them is about chemistry.
Preservatives get swapped, not deleted
Preservative-free is rarely a real option. The line the EU drew around methylisothiazolinone shows how much room a formulator actually has.
| Substance | Leave-on | Rinse-off |
|---|---|---|
| Methylisothiazolinone (MI) | prohibited | 15ppm (0.0015%) |
| MCI/MI mixture | prohibited | prior conditions retained |
Wet wipes fall under leave-on, so any cleansing-tissue formula heading to Europe starts in that first column. The prohibition also covers MI arriving as a raw-material preservative, which is the version that slips through unnoticed.
Benzyl alcohol causes its own confusion. It functions as a preservative and sits on the allergen declaration list, so it carries the same concentration triggers as a scent constituent. That is exactly where an "alcohol-free" claim collides with preservative design. Cetyl and stearyl alcohol are fatty alcohols with different behaviour, and bundling them into the same request tangles the formula.
Three documents to request at quotation stage
Collecting paperwork before changing the formula cuts the number of revision rounds. Three items do most of the work.
- The fragrance supplier's allergen declaration, separate from an IFRA certificate
- Lot-level composition analysis for every essential oil — limonene and linalool content shifts with origin and harvest
- A declarable-substance list calculated twice: once against Korea's 25, once against the EU list
Manufacturers rarely produce the third unprompted. Asking at quotation stage trims both label-proofing costs and launch delay. For what is moving on the Korean shelf right now, see today's ingredient signals, and to turn a direction into a quotation, use the product planner.
In short
- A sensitive-skin product removes named substances, not the category "fragrance."
- The EU added 56 to its 24; the deadline for new launches passed on 31 July 2026.
- Triggers are 0.001% leave-on and 0.01% rinse-off — the same as Korea.
- Orange oil can exceed 90% limonene, so 0.0011% of it is already declarable.
- Methylisothiazolinone is prohibited in EU leave-on products, wet wipes included.
*Sources: Regulation (EU) 2023/1545 — EcoMundo, Biorius / methylisothiazolinone rules — Biorius / Korea's 25 scent allergens — CNC News, Woman Consumer / orange oil composition — Orange oil, Wikipedia / benzyl alcohol labelling — CosmileEurope. Checked 8 October 2026.*
Questions people ask
Fifty-six were added to the existing 24, which different sources total as 80 or 81. The number added is the same everywhere. Products placed on the market had to comply from 31 July 2026; stock already on shelves has until 31 July 2028.
0.001% in leave-on products and 0.01% in rinse-off products, or 10ppm and 100ppm. Korea's 25-substance rule uses the same two numbers, so one calculation covers both markets. Essential oils cross these lines at dosages most briefs treat as rounding errors.
If the oil is there for scent, its allergens surface on the ingredient list. Orange oil is 91.4–97.0% limonene, so 0.0011% of it in a leave-on formula already puts limonene above 10ppm. Natural does not mean exempt.
Methylisothiazolinone is prohibited in EU leave-on products, and wet wipes count as leave-on. Rinse-off products are capped at 15ppm. What replaces it is decided by your manufacturer's challenge test, not by the brief.
Three documents: the fragrance house's allergen declaration, lot-level analysis for any essential oil, and a declarable-substance list calculated against both the Korean and EU lists. Without them you cannot lock label copy, and launch dates slip.