Fragrance allergen calculator

How the calculation works

Your supplier's allergen declaration gives each allergen as a percentage of the fragrance oil. What the law looks at is its concentration in the finished product:

% in the product = fragrance load (%) × % in the oil ÷ 100

A body lotion with 1% fragrance oil, where the oil is 12% linalool, contains 1 × 12 ÷ 100 = 0.12% linalool. That is far above 0.001%, so “Linalool” goes on the label.

Cosmetics: the 0.001% and 0.01% rule

Annex III to the EU Cosmetics Regulation names an allergen “when its concentration exceeds” 0.001% in a leave-on product or 0.01% in a rinse-off product. A rinse-off product is one meant to be removed after it is applied to the skin, hair or mucous membranes; a leave-on product stays in prolonged contact. “Exceeds” means strictly above: exactly 0.001% in a lotion does not have to be named.

Some entries cover several substances, and then the rule applies to their total. Geranial and neral are added up and labelled as “Citral”; alpha- and beta-pinene as “Pinene”; the damascones as “Rose Ketones”. The calculator recognises the names and synonyms of all 81 entries and groups them for you. Ingredients are listed in descending order of weight, but those under 1% may follow in any order after the rest, so the calculator gives the allergens highest first, after the perfume.

Great Britain still uses the original list, so a GB-only label can leave out the 2023 additions; the result says which those are. Northern Ireland follows the EU list.

Candles, wax melts and diffusers: EUH208 under CLP

Home fragrance is not a cosmetic, so it is labelled under the CLP Regulation (EC) No 1272/2008 in the EU and Northern Ireland, and its retained version, GB CLP, in Great Britain. The rule for allergens is Annex II, section 2.8: a mixture that is not classified as sensitising but contains a skin sensitiser at or above the limit in Table 3.4.6 must carry EUH208: “Contains (name of sensitising substance). May produce an allergic reaction.” The limit is 0.1% for a Skin Sens. 1 or 1B substance and 0.01% for 1A, and for a substance with a specific concentration limit (SCL) it is a tenth of that limit. Here the test is “equal to or greater than”.

At higher levels the whole product is classified as a skin sensitiser: from 1% of a Skin Sens. 1 or 1B substance, 0.1% of a 1A substance, or the SCL itself (Table 3.4.5). Then the label needs the exclamation-mark pictogram, the signal word “Warning”, H317 “May cause an allergic skin reaction.” and the sensitisers named with the product name. Each substance is compared on its own; sensitisers are not added together. Cosmetics in their finished state are outside CLP, which is why a soap never carries EUH208.

Worked examples

1. Body lotion, 1% fragrance (the default above). Linalool 12% of the oil gives 0.12%, limonene 8% gives 0.08%, geraniol 2% gives 0.02% and citral 0.6% gives 0.006%: all exceed 0.001%. Eugenol at 0.08% of the oil gives 0.0008% and coumarin at 0.05% gives 0.0005%: not named. Wording: Parfum, Linalool, Limonene, Geraniol, Citral.

2. The same oil in a shower gel, 1% fragrance. The products are the same numbers, but the threshold is 0.01%. Linalool, limonene and geraniol are named; citral at 0.006% is not. Wording: Parfum, Linalool, Limonene, Geraniol.

3. A container candle, 8% fragrance. Suppose the SDS lists linalool at 10% (Skin Sens. 1B), citral at 1.5% (Skin Sens. 1), coumarin at 1% (Skin Sens. 1B) and isoeugenol at 0.2% (Skin Sens. 1A). In the candle that is 0.8%, 0.12%, 0.08% and 0.016%. Linalool and citral reach 0.1% and isoeugenol reaches its 0.01% limit; coumarin does not. None reaches its classification limit, so the label needs: Contains Linalool, Citral, Isoeugenol. May produce an allergic reaction. At 12% fragrance the linalool would reach 1.2%, and the candle would be classified H317 instead. The categories here are invented for the example: always take them from your own SDS.

Where the numbers come from

For cosmetics, ask your fragrance supplier for the allergen declaration of each oil: it gives the Annex III allergens it contains as percentages of the oil. For home fragrance, use the safety data sheet. The British Candlemakers Federation and Cornwall Council Trading Standards advise getting an SDS that matches the proportion you use, such as 10%, because the SDS for the neat oil shows hazards your finished candle may not have. The calculator is a check on that paperwork, not a substitute for it.

Common mistakes

• Comparing the oil, not the product. 0.5% coumarin in the oil sounds high, but at a 1% load it is 0.005% in a rinse-off product, below 0.01%.
• Forgetting the group totals. Geranial 0.4% and neral 0.3% of the oil are 0.7% “Citral” together.
• Mixing up the tests. Cosmetics use “exceeds”; CLP uses “equal to or greater than”.
• Using cosmetic rules for a candle, or putting EUH208 on a soap. Each product type has its own regulation.
• Rounding too early. The calculator keeps full precision and shows enough decimals to compare with 0.001%.