This dossier answers a very concrete question: what information must actually appear on the bottle and packaging of a cosmetic perfume sold in France and the European Union?
The label is not just an INCI list. The European cosmetics regulation governs several mandatory mentions, while the rules relating to allergenic fragrance substances have been strengthened by Regulation (EU) 2023/1545.
1. The bottle: what information must be checked?
For a cosmetic perfume, Article 19 of Regulation (EC) No 1223/2009 governs the main information intended for the consumer. Depending on the product and its presentation, one must in particular check:
- the name and address of the responsible person in the European Union;
- the nominal content (for example, 50 ml);
- the date of minimum durability where the durability is less than 30 months, or the period after opening symbol where the corresponding conditions are met;
- the precautions and warnings required for the safe use of the product;
- the batch number or a reference allowing the product to be identified;
- the function of the product where it is not obvious;
- the list of ingredients according to the applicable regulatory nomenclature.
For a product manufactured outside the European Union, the country of origin must also be indicated. In France, the regulatory information intended for the consumer must be presented in French according to the applicable rules.
2. "Parfum" in the INCI: why are the materials not all detailed?
A fragrance composition can generally appear in the list under the terms "Parfum" or "Aroma". This does not mean that all odoriferous substances can remain grouped under this single mention: certain fragrance substances subject to the obligation of individual labeling must appear separately when they exceed regulatory thresholds.
The INCI list must be distinguished from a complete manufacturing formula. The label informs the consumer according to the rules provided by the regulation; it does not necessarily constitute the full disclosure of the commercial formula.
3. Fragrance allergens: what changes in 2026
Regulation (EU) 2023/1545 has amended Annex III of the cosmetics regulation and strengthened the individual labeling of certain fragrance substances. The European Commission indicates that the new system adds 56 fragrance allergens to the obligation of individual labeling and updates certain existing entries.
When a concerned substance exceeds the applicable threshold in the finished product, it must be identified individually in the list of ingredients: 0.001% for leave-on products and 0.01% for rinse-off products.
From July 31, 2026, cosmetic products that do not comply with these new requirements can no longer be placed on the Union market. Products placed on the market before this date may, under the conditions provided for by the regulation, continue to be made available until July 31, 2028.
4. Seeing an allergen on the label does not mean the perfume is "dangerous"
The presence of a fragrance substance in the INCI list is not, in itself, a conclusion on the overall safety of the product. The labeling obligation is intended, in particular, to allow people already sensitized to certain substances to identify their presence.
The European Commission specifies that a fragrance allergen declared on the label does not mean that the product is dangerous for all consumers. The safety assessment of the finished product remains a distinct mechanism.
5. "Allergen-free": a formulation to be handled with caution
A claim such as "allergen-free" can be misleading if it gives a general assurance that scientific or regulatory data do not allow one to establish. The DGCCRF specifically draws attention to this type of claim and to the need to be able to justify cosmetic claims.
It is therefore necessary to distinguish "certain regulated fragrance allergens are not present or do not exceed the labeling threshold" from a much broader assertion that a product is "allergen-free".
6. "Natural", "alcohol-free", "hypoallergenic": the label cannot promise everything
Claims on the bottle, box, product sheet, or advertising must comply with the rules applicable to cosmetic claims and be substantiable.
The DGCCRF reminds us in particular that terms like "hypoallergenic" require an appropriate documentary basis and that certain "free from..." claims can be misleading when they give the product a superiority that cannot be demonstrated.
7. Bottle, box, and leaflet: where can the information appear?
Not all information necessarily needs to fit on a small bottle. The regulation provides for different methods depending on the nature of the information and the practical constraints of presentation. Certain mentions may, in particular, appear on the packaging or, when a practical impossibility is demonstrated, be referred to information accompanying the product with the appropriate symbol.
For a perfume sold online, one must also distinguish the physical label from the information presented before purchase. The DGCCRF reminds us that information broadcast online must allow the consumer to access the required essential characteristics.
8. Example of reading an oriental perfume
Let's imagine a bottle indicating a fragrance composition and an INCI list including, in particular, alcohol, parfum, and several individual fragrance substances. One should not interpret this list as an olfactory pyramid: it follows a regulatory logic of ingredient identification.
Likewise, the presence of a commercial name like "oud", "musk", "rose", or "amber" on the front does not prove in itself that a corresponding natural material constitutes an ingredient identifiable in that same form in the formula. The marketing side and the regulatory list do not have the same role.
9. Label control checklist
- Identify the responsible person and their address in the Union.
- Check the nominal content.
- Check durability and the appropriate symbol as the case may be.
- Check the batch or traceability reference.
- Check the precautions for use and warnings.
- Check the product function if it is not obvious.
- Reread the entire INCI list.
- Check fragrance allergens according to Annex III and applicable thresholds.
- For an imported product, check the country of origin.
- Check the consistency between formula, safety assessment, product dossier, label, and online information.
10. IFRA and INCI: two documents, two functions
An IFRA certificate or document relating to a fragrance composition does not replace the regulatory label of the finished product. Likewise, the INCI list does not replace the safety assessment or the product information file.
To understand the separation of roles, consult IFRA vs European regulation: understanding who does what and Putting a perfume on the European market: safety, product dossier, and responsibilities.
Key takeaways
For a cosmetic perfume sold in France, the label must allow for the identification of the product, its responsibilities, its quantity, its traceability, its precautions, and its ingredients according to the European framework. As of July 31, 2026, the new requirements for individual labeling of fragrance allergens must be taken into account for newly marketed products.
The best reflex is to read the INCI list as regulatory information, not as a transcription of the olfactory pyramid or the complete recipe.
Reference sources
- EUR-Lex — Regulation (EC) No 1223/2009 on cosmetic products
- EUR-Lex — Regulation (EU) 2023/1545
- European Commission — Fragrance allergens labelling
- DGCCRF — Cosmetic product labeling
- DGCCRF — "Free from" claims in cosmetic products
In the same library
Perfume regulation in France and the European Union · IFRA vs European regulation · Putting a perfume on the European market · Perfume safety
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