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Fragrance allergens and IFRA certificates: the EU 81-entry list, IFRA 51st/52nd Amendments and Thai rules

11 min read · Updated 10 Nov 2026

Fragrance allergens and IFRA: why Thai exporters need both

Fragrance allergens are fragrance substances and natural oils that can cause skin sensitisation, and several markets now require them to be named on cosmetic labels above set thresholds. Alongside those laws sits IFRA (International Fragrance Association), the global fragrance industry body whose IFRA Standards limit or ban fragrance materials. IFRA is voluntary industry self-regulation, not a law, but it is binding on IFRA members, who produce about 80% of the world's fragrance by volume, and buyers routinely write it into supply contracts.

For Thai brand owners and OEM factories that export, fragrance in a cosmetic is governed by three layers at once. The first is the law of the destination market, such as the European Union's list of fragrance allergens that must be labelled. The second is private industry standards, meaning IFRA, enforced through contracts. The third is quality standards for essential oils, such as the ISO standards of technical committee ISO/TC 54. The same supplier documents feed all three, but each layer answers a different question.

Several things changed in 2026. The EU expanded its labelling list from 24 to 81 entries in the legal text, and new products placed on the EU market must already follow the new list. The IFRA 51st Amendment has applied in full to existing fragrance creations since 30 October 2025, and the 52nd Amendment is expected to be notified around mid-January 2027. Thailand and ASEAN, meanwhile, still do not require individual fragrance allergens on the label. Companies that sell at home and abroad therefore manage two label standards and a heavier document pack.

This guide covers what IFRA is, what an IFRA certificate should state, how the 51st and 52nd Amendments differ, which EU entries matter for Thai raw materials, and what the Thai FDA requires. Information is current as of 3 November 2026.

What an IFRA certificate is and who issues it

An IFRA certificate, formally an IFRA Certificate of Conformity, is a document the fragrance house that formulated a fragrance compound gives its customer. It confirms that the compound can be used up to stated maximum levels in each product category and still conform to the IFRA Standards, up to and including the amendment named on the certificate. When a buyer asks for an IFRA certified fragrance, this certificate is what they mean.

A common misunderstanding is that IFRA certifies products. IFRA does not issue certificates and does not appoint third-party certifiers. Anyone who understands the IFRA Code of Practice may issue one, even a non-member. Final responsibility sits with the maker of the finished product, so a certificate does not replace the product safety assessment and does not override any national law.

What the certificate should show

• The compound name or code, matching what you actually buy.
• The amendment number and its notification date. In 2026 this should be the 51st Amendment, notified 30 June 2023.
• Maximum use levels by product category, across all 12 categories.
• A conformity statement that the finished product complies when the compound is used within those levels.

The 12 IFRA product categories

Since the 49th Amendment, IFRA assesses skin sensitisation with the QRA2 method, which counts aggregate exposure from several products, and splits products into 12 categories, some with sub-categories. Examples from the 51st Amendment Guidance include Category 1 (lip products), Category 2 (underarm products), Category 4 (fine fragrance), Categories 5A to 5D (body lotion, face cream, hand cream and baby products), Category 9 (rinse-off body and hand products) and Category 12 (products not intended for skin contact). Published limits apply to the finished product, not to the compound.

The IFRA Guidance gives a worked example. Hay absolute contains 8% coumarin, and the Category 4 limit is 1.3%. If the compound is used at 20% in a fine fragrance, the compound may contain no more than 16.25% hay absolute. Your real dosage in the formula matters as much as the number on the certificate.

Single essential oils do not get a compound-style certificate

For a single natural raw material (a Natural Complex Substance) such as a citrus oil, the IFRA Guidance says the supplier should not issue an IFRA certificate in the compound format. Instead, the supplier should state the levels of IFRA-restricted constituents in the oil, together with a statement of conformity with that oil's own Standard. The formulator then does the calculation.

IFRA Standards come in three types: restrictions (maximum concentrations in the finished product), prohibitions (no use at all, including non-skin-contact uses) and specifications (purity, impurity or production criteria).

IFRA 51st vs 52nd Amendment: what an IFRA certified fragrance must cite

51st Amendment: in force

IFRA notified the 51st Amendment on 30 June 2023. Prohibitions applied to existing creations from 30 July 2024, and restrictions applied to existing creations from 30 October 2025. The amendment revised 7 Standards and added more than 40 new ones. These dates run from the shipment or invoice date of the compound leaving the fragrance house, whichever comes first, not from the date the finished product is made.

In our assessment, certificates that still cite the 49th or 50th Amendment are out of date for deliveries after 30 October 2025. Ask for a certificate citing the 51st Amendment and check whether the maximum level for your product category has changed.

52nd Amendment: coming

The 52nd Amendment consultation closed on 12 June 2026, and IFRA published its End of Consultation letter on 31 August 2026. That letter says formal Notification is expected around mid-January 2027. An older IFRA page from June 2026 had pointed to late November 2026; the newer letter supersedes it.

Once notified, the 52nd Amendment will apply to new creations after 11 months and to existing creations after 30 months. According to the letter it contains 48 new Standards and 15 revised ones. If Notification does happen in mid-January 2027, new creations would need to comply around December 2027 and existing creations around mid-2029. We calculated those two dates from the 11- and 30-month rules; they are not official dates.

The change that hits citrus oils

Phototoxic furocoumarins in citrus oils will be measured differently. The 51st Amendment uses bergapten as the marker, with a combined limit of 15 ppm in products exposed to the sun. The 52nd Amendment moves to 8 marker substances with limits of 1 ppm for products intended for deliberate sun exposure, 5 ppm for other leave-on products and 50 ppm for rinse-off products. Brands using cold-pressed citrus peel oils in creams or lotions should ask suppliers for furocoumarin data now.

The EU fragrance allergen list: from 26 fragrance allergens to 81 entries

The EU fragrance allergen list is set by Commission Regulation (EU) 2023/1545, which amends Annex III of Regulation (EC) No 1223/2009. It was adopted on 26 July 2023 and entered into force on 16 August 2023.

• Labelling threshold: above 0.001% in leave-on products or above 0.01% in rinse-off products, the same thresholds as before.
• Transition: products that do not follow the new list could be placed on the EU market until 31 July 2026 and may be made available until 31 July 2028.
• No reformulation required: the rule changes labelling only.

26, 24, 80, 81 or 82?

Published counts differ because they count differently. The old list had 26 fragrance allergens, which fell to 24 after the EU banned Lilial (BMHCA) and HICC (Lyral). Reading the legal text on EUR-Lex on 3 November 2026, we count 81 entries: 24 existing entries (at Annex III references 45 and 67 to 92) plus 57 new or amended entries. Some entries group several INCI names, such as lemongrass oil, which covers three plant species. That is why secondary sources quote 80 or 82 fragrance allergens, and some count more than 100 INCI names. Check the latest Annex III before printing labels; a corrigendum was reported in November 2025 that we have not yet compared.

Entries relevant to raw materials used in Thailand

In the list we read, entry 354 covers only the three lemongrass species above; we did not find citronella oil (Cymbopogon nardus or C. winterianus), although citronella constituents such as Geraniol and Citronellol are already listed. Plai, kaffir lime, turmeric and Thai basil oils are not listed as oils, but their constituents may still trigger labelling, depending on the analysis of the actual batch.

The Thai FDA has itself published a list of allergens referencing Regulation (EU) 2023/1545, updated 21 February 2026, which classifies each substance by its status under Thai law: prohibited, restricted, or on neither list. It is a list of names only and sets no labelling threshold.

Allergens in perfume and cosmetics: how to calculate whether to label

A threshold of 0.001% equals 10 mg per kg of product, and 0.01% equals 100 mg per kg. These are low enough that a small amount of fragrance compound or essential oil can exceed them. Guidance from EU authorities and consultants sets out these key rules for allergens in perfume and cosmetic products:

1. Add up all sources. The same substance from several raw materials, for example citral from lemongrass oil and from a compound, must be summed before comparing with the threshold.
2. Two-level naming. If an oil is listed and also contains listed constituents, both names may be required.
3. Worst-case assessment for natural materials whose composition varies between batches.
4. Group names for cross-reacting substances, labelled when the group total exceeds the threshold.
5. Pre- and pro-haptens such as Limonene, Linalool, Linalyl Acetate, Alpha-Terpinene and Geraniol (which become sensitisers when oxidised), plus Eugenol and Isoeugenol, are counted as allergens.
6. On-pack only. Digital-only labelling is not enough. Substances below 1% may be listed at the end in any order.

Worked example

The Austrian agency AGES gives this example: a leave-on cream contains 1.3% Lavandula hybrida oil, and the oil contains 45% Linalool. The product therefore contains 1.3 × 0.45 = 0.585% Linalool, far above 0.001%. The label must show both the lavender oil name and Linalool.

The same logic applies to Thai oils. If a cream contains lemongrass oil, Lemongrass Oil must be listed once it exceeds the threshold, and Citral, Limonene, Geraniol or other constituents must be calculated from the supplier's GC-MS results for that batch, then added to any amount coming from the fragrance compound.

A batch-level GC-MS report showing the percentage of each allergen and each IFRA-restricted constituent therefore serves several purposes at once: EU labelling, checking against the IFRA certificate, and the product safety file that the EU Responsible Person must hold.

Thai FDA and ASEAN rules on fragrance allergens

As of November 2026, Thailand and ASEAN do not require individual fragrance allergens to be named on the label. Listing fragrance collectively as Fragrance or Parfum is still compliant in Thailand.

• The Cosmetic Committee notification on cosmetic labelling B.E. 2562 (2019) requires all ingredients in descending order, with those below 1% in any order, but says nothing about fragrance allergens. For the full Thai label rules, see Thai cosmetic labelling requirements.
• The Thai FDA notification system manual lets applicants enter fragrance as Perfume, Parfum or Fragrance.
• The ASEAN Cosmetic Directive Annex III (release of 5 June 2023) has no 0.001% or 0.01% labelling condition, and the labelling appendix (Appendix 2) allows perfume, fragrance, aroma or flavor as a collective name. We found no evidence that ASEAN has adopted the 2023/1545 list.

Fragrance substances Thailand bans or limits

Even without a labelling rule, Thai ingredient lists must be checked. HICC, Atranol, Chloroatranol, Lilial and Musk ambrette are prohibited. Methyleugenol is prohibited except at naturally occurring levels in fragrance extracts within product-type limits. Musk xylene, Musk ketone and 6-Methylcoumarin have limits in the restricted-substances notification. The Thai restricted list does not include Linalool, Limonene, Citral, Geraniol or Eugenol.

Changing the allergen list on a notified Thai label

A Thai FDA explanatory note on re-notifying a cosmetic with a changed formula under the same product name (amended 29 October 2025) allows a new notification under the existing name with a letter of justification, for reasons such as raw material shortages or changes in foreign cosmetic law. The same note, however, lists changing how Allergens are shown on the label without changing the formula among the examples that do not qualify for this route. Where a reason does not qualify, the note says the old notification must be cancelled first and the product re-notified under the same name through the normal procedure. Plan for this before aligning a Thai label with an EU label. For the notification process itself, see how to notify cosmetics in Thailand.

Aroma oils are not always cosmetics

The Thai cosmetic notification criteria (revised 2021) state that essential oils claimed to be therapeutic, relaxing or sleep-promoting are not cosmetics, and air fresheners fall outside the cosmetic definition too. The same oil can fall under different laws depending on its claims.

United States and Canada: where fragrance allergen labelling stands

United States. Today 21 CFR 701.3 still allows fragrance or flavor to be listed collectively. MoCRA requires the FDA to issue a fragrance allergen labelling rule, but as of 3 November 2026 no proposed rule had appeared in the Federal Register, and the FDA gives no date. The US regulatory agenda had targeted November 2026 after earlier delays. Industry expects the US to build on the EU list, but no FDA document confirms that.

Canada has a system similar to the EU's. According to the sources we reviewed, new products must comply from 1 August 2026 and existing products from 1 August 2028.

In practice, a brand that already labels and documents to the EU list is best prepared for markets that follow the EU, and can answer buyers in several countries from one data set. For Thai FDA export certificates, see cosmetic export certificates from Thailand.

Documents to request from fragrance and essential oil suppliers

No law sets out this document list directly. It summarises IFRA and EU requirements and industry practice, and works as a checklist when you qualify or review a supplier.

1. IFRA certificate citing the 51st Amendment for compounds, with maximum levels for your product category. For single oils, ask for the levels of IFRA-restricted constituents with a statement of conformity.
2. Allergen statement against the new EU list, not the old 24 or 26 list, giving the percentage of every listed entry and naming the oil itself where it is listed, such as lemongrass, cananga or clove.
3. GC-MS or GC-FID results for the actual batch, or maximum values from the specification, covering main constituents, allergens and IFRA-restricted substances.
4. CoA and specification: botanical name, plant part, production method (steam distillation or cold pressing) and physical values to the relevant ISO standard where one exists.
5. SDS with all 16 sections. For imported compounds, check section 3 for Piperonal: Thailand lists it as a Category 4 narcotic, with exemptions at up to 10% in fragrance materials or up to 1% in finished products.
6. Prohibited-substance statement: no Atranol, Chloroatranol, HICC or Lilial, plus the Methyleugenol level.
7. Furocoumarin data for cold-pressed citrus and kaffir lime peel oils used in leave-on products.

Thai oil suppliers who can provide this full set have an edge in export markets. Brands that lack these documents should request them before the next production run, because EU label calculations are impossible without constituent figures.

Check fragrance allergens in your formula with our tools

Once you have the substance names from your formula or supplier documents, search them one by one in the Thai FDA ingredient search. Results show the status under Thai rules and carry a 🌸 tag when the substance is on the EU fragrance allergen list, with notes for essential oils, so you can see at once which substances need no name on a Thai label but must be calculated for the EU.

To check a full Thai label draft, use the free Thai FDA label checker. If you want our RA team to read your formula, IFRA certificate and allergen statement and report what each market's label must show, contact our consultants.

Rules change quickly, especially with the IFRA 52nd Amendment and the pending US rule. Check the date and amendment number on every document before relying on it.

Sources

1. Cosmetic Committee notification on cosmetic labelling B.E. 2562 (2019) · Open source · Search our archive
2. Thai FDA explanatory note on re-notifying a cosmetic with a changed formula under the same product name (amended 29 October 2025) · Open source · Search our archive
3. Thai FDA list of allergens referencing Commission Regulation (EU) 2023/1545 (updated 21 February 2026) · Open source · Search our archive
4. Ministry of Public Health notification on restricted cosmetic ingredients B.E. 2561 (2018) · Open source · Search our archive
5. Ministry of Public Health notification on prohibited cosmetic ingredients B.E. 2566 (2023) · Open source · Search our archive
6. Cosmetic notification criteria (revised 2021) · Open source · Search our archive

This article is for general information. It is not a Thai FDA ruling or legal advice, and rules change — check the latest notification or ask an expert before filing or producing.

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