When to Write Parfum and When to List Fragrance Allergens

Fragrance labeling has always had this odd two-tier structure: one word, Parfum, standing in for what might be forty or fifty individual aroma chemicals, plus a short list of named allergens that have to come out from behind that curtain and be declared on their own. If you've been squinting at a fragrance house's spec sheet trying to figure out what goes on your ingredient list, here's how the pieces fit together.

Parfum is a legitimate INCI term, not a loophole

Parfum (or Fragrance in some markets) is itself a recognized INCI entry. It exists specifically because fragrance compositions are proprietary blends, often dozens of components, and requiring full disclosure of every one would hand a fragrance house's formula to competitors. So the convention is: the finished fragrance compound gets one INCI listing, Parfum, positioned in your ingredient list at its actual concentration in the finished product, the same way any other ingredient would be.

That's the easy part. The complication is that certain individual molecules commonly found inside fragrance compounds are known skin sensitizers, and regulators around the world have decided those specific molecules need to be called out by name even though they're technically part of the Parfum blend.

The allergens that have to come out from behind the curtain

In Canada, this is happening in two stages. List 1, the original fragrance allergen set, becomes mandatory on the Cosmetic Notification Form and on the label as of April 12, 2026. List 2, an expanded set aligned with international allergen lists, becomes mandatory August 1, 2026. Once a listed allergen is present above the disclosure threshold, it has to be named on its own line in your ingredient list, in addition to (not instead of) the Parfum entry.

The thresholds are what actually trigger the requirement:

Product type	Disclosure threshold
Leave-on (lotion, serum, perfume)	Above 0.001% (10 ppm)
Rinse-off (shampoo, soap, cleanser)	Above 0.01% (100 ppm)

Below those levels, the allergen can stay folded into Parfum with no separate listing required. Above them, it needs its own line.

How this plays out on a real label

Say you're making a rose-scented body lotion. Your fragrance supplier's spec sheet shows the blend contains Linalool, Geraniol, and Citronellol, each above the leave-on threshold. Your ingredient list would read something like:

Aqua, Glycerin, Cetearyl Alcohol, Parfum, Linalool, Geraniol, Citronellol

Note that Parfum still appears. You're not replacing it with the allergen names, you're supplementing it. The allergens are almost always present in fragrance blends because they occur naturally in the essential oils and aroma chemicals that make up the scent. Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin are the names you'll see most often, and if you use citrus oils, floral notes, or clove-adjacent scents, expect at least a few of them to show up in your supplier's declaration.

Where the concentration data has to come from

You cannot guess at whether an allergen clears the threshold. Your fragrance supplier should provide an allergen declaration or IFRA certificate that breaks out the percentage of each regulated allergen within the fragrance compound itself. From there:

1. Take the allergen's percentage within the fragrance blend.
2. Multiply by the percentage of fragrance in your finished formula.
3. Compare the result to the leave-on or rinse-off threshold.

A fragrance oil that's 2% Linalool, used at 1% in your finished lotion, puts Linalool at 0.02% of the finished product. That's above the 0.001% leave-on threshold, so it needs its own listing. The same fragrance used at 0.05% in a rinse-off soap bar would land Linalool at 0.001%, under the 0.01% rinse-off threshold, so no separate listing is required there.

Why this matters for your CNF, not just your label

The same allergen disclosure applies to what you file, not only what customers see on the bottle. Once List 1 becomes mandatory in April 2026 and List 2 in August 2026, your Cosmetic Notification Form needs to carry the same named allergens at the same concentrations as your label. Filing one and labeling the other inconsistently is the kind of gap that surfaces in an audit.

This is exactly the sort of calculation that's easy to get subtly wrong by hand, especially once you're juggling ten SKUs each with a different fragrance supplier and a different allergen profile. Cosmetic Comply carries the math through for you, expanding a fragrance blend into its named components, running the concentration against the leave-on or rinse-off threshold, and flagging what needs to appear on both the filing and the label before a human reviewer signs off. If your fragrance library is large, it's worth checking each blend now rather than scrambling in March.