Understanding fragrance allergens

When it comes to packaged food, swerving sensitivities is pretty straightforward. It should always state in the ingredients if common allergens (say, nuts, fish and eggs) are included. But with fragrances, these kinds of warnings aren’t so cut and dry.

You see, there’s something called the EU Cosmetic Regulation Annex III (or the EU Allergens List) that identifies 26 substances sometimes included the fragrance component of leave-on products that can potentially cause immediate skin irritations (such as a rash) and allergies up to 24 hours later (like redness and swelling.) In order for the product to be eligible to be sold throughout Europe, these substances must be individually declared on the label when present in concentrations of at least 10 parts per million. The problem? Essential oils and plant extracts are made up of dozens to hundreds of different natural chemicals in various combinations. If you remove any one of those chemicals, your chance of having a reaction to that one chemical increases. But in its whole form - the way that nature puts it together - this likelihood is much smaller. 

“For example, I've never met anyone who has had a reaction to rose oil in the 19 years I've been in business,”  One Seed founder Liz Cook explains. “But they've banned ingredients like orange oil, lemon oil and tonka bean and considering banning others including rose oil. Because people can potentially have a reaction to a component of tonka bean, which is coumarin for example, or a component of citrus, like citronellol.” 

“Whether they are added to the formula as a single chemical or as a naturally-occurring component of a whole essential oil, they're considered to have the same allergenic properties.”

Because of this, most consumers wouldn’t even realise if it’s one of these 26 substances in particular that they are reacting to. Take linalool: a pleasant-smelling terpene that naturally occurs in more than 200 well-known plants and spices (e.g. jasmine and lavender) that can, in rare cases, result in dermatitis, itchiness, redness and hives.

“People never say, ‘Oh, I have a linalool allergy,’ Liz adds. “We might know that we're allergic to lemon, for example. But consumers don’t know what chemical components are in lemon.”

This is concerning considering this framework has been put in place to protect consumers by ensuring the safety of cosmetic products and providing them with adequate info whenever they make a purchase.

What’s more, it doesn’t speak to long-term reactions, meaning it really only scratches the surface of the damage certain substances can have on our health. 

“The biggest issue with the EU Cosmetics Regulation list is that nobody's looking at the long-term health effects of any of these ingredients, let alone those that aren’t on the allergens list,” Liz continues. 

Recently, the European Commission proposed to update this list to 82 allergens based on a review by the Scientific Community of Consumer Safety (SCCS) that suggested between 1 and 3 percent of the population are sensitised to substances still widely-used in fragrances. (As a side-note, around 33 percent of us experience uncomfortable side-effects from synthetic fragrance, such as nausea, headache and migraine.)

In order to determine which additional substances would be restricted, the European Commission considered information based on clinical studies of humans and “data from experimental animal studies that, based on historical experience with similar type of chemicals, suggest the potential of a fragrance substance to cause skin allergies.”

The new list is expected to include: Menthol, Terpineol, Linalyl Acetate, Camphor, Vanillin, Geraniol derivatives (Geranial and Geranyl Acetate,) as well as ylang-ylang oil (Cananga Odorata Flower Oil), cinnamon oil (Cinnamomum Zeylanicum Bark Oil) and lavender oil (Lavandula Officinalis Flower Oil).

But with this change comes more confusion, particularly because brands are moving away from using natural ingredients and towards synthetics to avoid having to declare that their formulas contain allergens - and to be able to continue selling them in the European market with increasingly tighter regulations.

“It does make me question what the motivation is behind doing the allergen declaration, because it's not really there for the average person on the street. It doesn’t serve the purpose it’s supposed to,” Liz says. “Consumers need to be aware that both natural and synthetic fragrance could cause allergies and patch testing is always important whenever you buy a new product.”

Below, we’ve shared a copy of the EU Cosmetic Regulation (Annex III) so those with allergies can better identify which substances may potentially cause a reaction. Note: with commercial fragrances, these will often appear under “ingredients” and not “potential allergens” on the label. 

EU Cosmetic Regulation (Annex III)