Compound library · Regulation
Allergens that must be declared on the label
23 of the 106 compounds in the library are on the list of fragrance allergens that must be named individually on cosmetic labels in the European Union. This page explains what that list is, where it applies, and why it matters even if you sell only in Vietnam.
A note when checking against the original text: those 23 entries correspond to only 20 label names, because some compounds are declared together. Citral, neral and geranial are all declared as CITRAL; α-pinene and β-pinene are both declared as PINENE.
Which regulation
Regulation (EU) 2023/1545, adopted on 26 July 2023 and published in the EU Official Journal the following day, amends Annex III of Regulation (EC) 1223/2009 on cosmetic products. It extends the list of fragrance allergens that must be declared individually from 24 to about 80 substances and groups of substances.
The declaration thresholds are unchanged: 0.001% in leave-on products and 0.01% in rinse-off products. Below those levels, fragrance ingredients need only be listed collectively as fragrance.
New products placed on the EU market must comply from 31 July 2026 — that date has passed. Products already on the market have until 31 July 2028. A corrigendum narrow in scope was published in November 2025.
This is an EU regulation, not a Vietnamese one
Cosmetics in Vietnam are regulated under Circular 06/2011/TT-BYT and the ASEAN Cosmetic Directive. The ASEAN system has historically followed the older EU list, but we do not claim that ASEAN has adopted the 2023 extension, or from when.
So why record it here. First, if you export to the EU it is mandatory. Second, even when selling domestically, knowing which compounds are on the list helps in choosing raw materials and writing labels — because the list reflects the allergy data that exist, which do not depend on borders.
This is not legal advice. Before printing a label, check against the current texts and with the body responsible for notifying your product.
Ten compounds on the original list
The group of 24 substances that predates 2023. This is the most familiar list, and most suppliers already declare it.
| Compound | Label name | Chemical family |
|---|---|---|
| Cinnamaldehyde | CINNAMAL | Aldehydes |
| Citral | CITRAL | Aldehydes |
| Citronellol | CITRONELLOL | Alcohols |
| Coumarin | COUMARIN | Lactones |
| Eugenol | EUGENOL | Phenols |
| Geranial | CITRAL | Aldehydes |
| Geraniol | GERANIOL | Alcohols |
| Limonene | LIMONENE | Monoterpenes |
| Linalool | LINALOOL | Alcohols |
| Neral | CITRAL | Aldehydes |
Thirteen compounds added in 2023
This group is new, and many compounds in it are very common — camphor, menthol, vanillin, pinene. If you rely on an old supplier declaration, these compounds may not appear on it yet.
| Compound | Label name | Chemical family |
|---|---|---|
| Camphor | CAMPHOR | Ketones |
| Linalyl acetate | LINALYL ACETATE | Esters |
| Menthol | MENTHOL | Alcohols |
| Methyl salicylate | METHYL SALICYLATE | Esters |
| Terpinolene | TERPINOLENE | Monoterpenes |
| Vanillin | VANILLIN | Aldehydes |
| trans-Anethole | ANETHOLE | Other compounds |
| α-Pinene | PINENE | Monoterpenes |
| α-Santalol | SANTALOL | Alcohols |
| α-Terpinene | ALPHA-TERPINENE | Monoterpenes |
| α-Terpineol | TERPINEOL | Alcohols |
| β-Caryophyllene | BETA-CARYOPHYLLENE | Sesquiterpenes |
| β-Pinene | PINENE | Monoterpenes |
A point that is easy to miss
The 2023 extension does not only add pure compounds. It also brings essential oils themselves, as raw materials, onto the list: lemongrass, lavender, eucalyptus, jasmine, ylang-ylang, sandalwood, patchouli, and many citrus peel oils.
That means a product using only pure essential oils, with no synthetic fragrance added, may still have to declare — and must declare both the name of the oil and the allergenic compounds in it.
This is where a GC/MS analysis becomes necessary rather than optional: without it, you do not know how much linalool or limonene your lot contains, so you do not know whether it crosses the declaration threshold.