The U.S. is still catching up on fragrance safety. Here’s what MoCRA could — and might not — change.
Pick up almost any perfume, body lotion, or hair product, and somewhere on the label you’ll find the word “fragrance.” That single word can legally stand in for any combination of thousands of individual compounds, none of which a brand is required to name. But as of April 12, Canada became the first North American country to require brands to start breaking that down — and the FDA is expected to follow with a proposed rule under the Modernization of Cosmetics Regulation Act as early as May 2026. Both are notable milestones, and both are arriving considerably late to a standard the European Union set all the way back in 2003.
The fragrance labeling loophole exists because federal cosmetics regulation in the U.S. has been, until very recently, spectacularly stagnant. MoCRA, signed by President Biden in December 2022, is the first significant update to federal cosmetics law since the Federal Food, Drug, and Cosmetic Act of 1938 — an 84-year gap for an industry that generates hundreds of billions annually in the U.S. alone. Among its provisions, MoCRA requires the FDA to publish a list of specific fragrance allergens that must be disclosed individually on product labels, rather than obscured under the catch-all term.
The FDA’s current target is May 2026 — still only a proposed rule, with a final rule unlikely before 2027. The Trump administration’s executive order requiring agencies to eliminate ten regulations for every new one added has slowed new rulemaking across the board, even for requirements Congress has already mandated. FDA restructuring and staffing reductions have compounded the delay. “Although more is needed to ensure the safety of chemicals used in cosmetics, this update is a welcome step in the right direction,” Scott Faber, senior vice president for government affairs at the Environmental Working Group, said of MoCRA’s passage. “Consumers, not just the FDA, will have more information when purchasing cosmetics, since fragrance allergens will now be on product labels.” For now, that information remains on hold.
Where the rest of the world stands on fragrance disclosure
The EU made fragrance allergen labeling mandatory in 2003, when Directive 2003/15/EC required individual disclosure of 26 specific substances — a list built from scientific assessments the European Commission’s advisory body had been conducting since 1999. The thresholds are precise: allergens must be named when present above 0.001 percent in leave-on products or 0.01 percent in rinse-off products. That was the baseline. Under Regulation (EU) 2023/1545, the EU’s allergen list is now expanding from 26 substances to more than 80, with full implementation required by July 31, 2026. The EU is in the process of upgrading a system the U.S. hasn’t yet started.
Canada’s April 12 action aligns it nearly exactly with current EU standards: 24 required allergens now, expanding to 81 by August 1, at the same concentration thresholds. That Canada chose to sync with Europe rather than wait on U.S. leadership is, at this point, a telling choice.
What the rule will — and won’t — actually fix
When the FDA’s fragrance allergen rule is eventually finalized, it is expected to track closely with EU standards, requiring individual allergen labeling above comparable thresholds. For Americans who experience fragrance sensitivity or allergic reactions to specific compounds — currently with no way to trace the source from a label — that would mark a genuine shift.
What it will not do is require full ingredient transparency. Even a product that satisfies every MoCRA requirement can still list “fragrance” or “parfum” for non-allergen components, meaning most of a formula remains legally hidden. A brand could comply fully with the rule and still leave the majority of its fragrance chemistry unnamed. Voluntary programs — like Credo Beauty’s Radical Fragrance Transparency initiative, which has 71 brand partners disclosing their complete ingredient lists — fill part of that gap by choice. Nothing in federal law will require them to.
The U.S. market will remain the regulatory outlier until at minimum 2027, when a final rule might realistically take effect — leaving American shoppers without information that European consumers have had for over two decades and that Canadians now have as of this week.
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