What Actually Counts as a Declarable Fragrance Allergen

A maker adds lavender essential oil to a lotion, hears "linalool" mentioned somewhere, and now isn't sure if the whole oil needs declaring, just the linalool, or nothing at all until some deadline arrives. That confusion is common, and it comes from mixing up two related but different things: fragrance ingredients in general, and the specific, named allergens that trigger a disclosure requirement.

Fragrance ingredient versus declarable allergen

Every scented product contains fragrance ingredients, whether that's a synthetic fragrance compound or a blend of essential oils. Most of what's in a fragrance formula never needs individual naming on a label; it can sit under a general "fragrance" or "parfum" listing. But a specific, defined subset of fragrance-related substances is treated differently: these are the declarable allergens, named individually because they're associated with a meaningfully higher rate of skin sensitization or allergic reaction than fragrance ingredients generally.

In Canada, this is organized into two sets. List 1 is the original fragrance allergen set, becoming mandatory on the CNF and the label on April 12, 2026. List 2 is an expanded set aligned with international lists, becoming mandatory August 1, 2026. Common named allergens include Limonene, Linalool, Citronellol, Geraniol, Eugenol, and Coumarin, and there are more beyond this handful once you're working from the full lists.

The concentration threshold is what actually triggers disclosure

Here's the part that resolves most of the "do I need to declare this" confusion: it's not simply presence, it's concentration. The disclosure trigger is above 0.001% (10 ppm) in leave-on products and above 0.01% (100 ppm) in rinse-off products. Below those thresholds, individual declaration isn't required even if the substance is technically present as a trace constituent.

This matters a lot in practice, because:

• A rinse-off product tolerates a higher trace concentration before disclosure kicks in than a leave-on product does, reflecting lower expected skin contact time.
• Many essential oils contain these named allergens naturally, sometimes at levels well above the threshold, sometimes not, depending on the oil and how much of it you're using.
• The question isn't "does my fragrance contain linalool as an ingredient," it's "at the concentration I'm using it, does the linalool content in the finished product cross 10 ppm leave-on or 100 ppm rinse-off."

Working through a real example

Say you're formulating a leave-on body lotion at 1% total essential oil blend, and that blend is 2% linalool by composition. The linalool's actual concentration in the finished product is 1% times 2%, which works out to 0.02%, or 200 ppm. That's above the 10 ppm leave-on threshold, so linalool needs individual declaration. Drop your essential oil blend down to a 0.1% usage rate in the same lotion and the math changes to 20 ppm, still above threshold. You'd need a genuinely trace usage rate to fall under 10 ppm for a leave-on product, which is exactly why leave-on fragrance formulas so often end up needing several named allergens on the label rather than none.

A quick reference

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

Allergen list	Mandatory date
List 1	April 12, 2026
List 2	August 1, 2026

The naturally-occurring trap

The single biggest source of surprise for makers is realizing these named allergens aren't just synthetic fragrance chemical additions, they occur naturally inside essential oils and botanical extracts that makers reach for specifically because they're "natural." Lavender, citrus oils, geranium, clove, and many others carry one or more of these named allergens as part of their natural chemical makeup. Using an essential oil doesn't exempt you from the allergen math; if anything, it's exactly the category most likely to trigger it.

What this means for your workflow

Get in the habit of running the actual math for every essential oil or fragrance blend in every formula, not just glancing at the ingredient name. You need the allergen composition of whatever fragrance material you're using (your supplier should be able to provide this, similar to how they'd provide CoA data) and your usage rate, multiplied together, checked against the right threshold for leave-on or rinse-off. This is precisely the kind of calculation Cosmetic Comply's ingredient mapping step is designed to carry through automatically, taking your formula and usage levels and flagging which named allergens actually cross the declaration threshold for the product type you're filing, so you're not manually recalculating percentages every time a lavender-scented product goes out the door.