Currently, Regulation 1223/2009 requires to include 26 allergens, derived from synthetic fragrances, as well as natural essential oils and extracts, on the list of cosmetics ingredients (INCI). In practice, it means that if a given allergen exceeds 0.01% in a rinse-off cosmetic (e.g. soap, shower gel, shampoo) or 0.001% in a leave-on cosmetic (e.g. cream, lotion, tonic) then it must be listed on a cosmetic label in the INCI composition.
The current list of 26 allergens includes:
Alpha-isomethyl Ionone
Amyl Cinnamal
Amyl Cinnamyl Alcohol
Anise Alcohol
Benzyl Alcohol
Benzyl Benzoate
Benzyl Cinnamate
Benzyl Salicylate
Butylphenyl Methylpropional
Cinnamal
Cinnamyl Alcohol
Citral
Citronellol
Coumarin
Eugenol
Evernia Prunastri Extract
Evernia Furfuracea Extract
Farnesol
Geraniol
Hexyl Cinnamal
Hydroxycitronellal
Hydroxyisohexyl 3-cyclohexene Carboxaldehyde (HICC)*
Isoeugenol
Limonene
Linalool
Methyl 2-octynoate
*From 23 August 2019 cosmetic products containing HICC shall not be placed on the Union market. From 23 August 2021 cosmetic products containing HICC shall not be made available on the Union market.
The practice described above is primarily aimed at protecting consumers and informing them about the presence of individual allergens in cosmetics. This is especially important for people who are allergic to particular fragrances. The INCI list of ingredients is also important in clinical practice in the treatment of patients who are allergic to at least one of the fragrance allergens listed.
The Scientific Committee on Consumer Safety (SCCS) in its opinion on fragrance allergens in cosmetic products (SCCS / 1459/11) stated that consumers should also be informed about additional fragrance ingredients that go beyond the aforementioned list of 26 allergens. Review of clinical and experimental data shows that there are many more fragrances than currently declared 26 allergens that are sensitizing to humans. The SCCS opinion is available at: https://ec.europa.eu/health/scientific_committees/consumer_safety/docs/sccs_o_073.pdf
Therefore, works are currently in progress to implement new changes to Regulation 1223/2009, namely to expand the list from 26 to 82 fragrance allergens. “New allergens” may include: Menthol, Terpineol, Linalyl Acetate, Camphor, Vanillin, Geraniol derivatives: Geranial and Geranyl Acetate, as well as well-known essential oils, such as: ylang-ylang oil (Cananga Odorata Flower Oil), cinnamon oil (Cinnamomum Zeylanicum Bark Oil), or lavender oil (Lavandula Officinalis Flower Oil). The European Commission has proposed amendments to the Annex III, which you can see at: https://ec.europa.eu/docsroom/documents/34512
These changes can be introduced as early as 2020 or 2021. Then, cosmetics manufacturers will be obliged to modify cosmetics labels by adding more allergens to INCI compositions. Everything indicates that the lists of cosmetics ingredients will significantly increase soon or – if you prefer – they will be enriched with new allergens.
