Tag: EU 2023/1545

🇰🇷 한국어판

Hello, this is Dr. J. Today: Korea’s 25 fragrance allergens, and the rule that decides when one of them stops hiding inside the word fragrance and gets a name of its own on the box.

Start with the thing most guides skip. A long tail of unfamiliar names after fragrance does not mean the product is heavily perfumed. It means something in the perfume crossed a labelling threshold. The names are not a leak. They are the rule working.

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Primary sources first

📄 Cosmetics Act Article 10 (Korea Cosmetic Association)

📄 Annex 2, fragrance allergens (Korean Law Information Center)

📄 Labelling Q&A (Korea Cosmetic Association)

📄 Regulation (EU) 2023/1545 (EUR-Lex)

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Five lines, if you are in a hurry

✔ A perfuming agent may be written as the single word fragrance

✔ But if it contains one of the listed 25, that substance must be named

✔ Thresholds: above 0.01% in rinse-off, above 0.001% in leave-on products

✔ Judged per substance, never on the sum of them

✔ The EU uses the same two figures — and its list is getting much longer

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Why a name leaves the word fragrance — a rule in three tiers

Korean guides usually explain the third tier alone, which makes the rule look arbitrary. It is not. It is a principle, an exception, and a proviso inside the exception.

Tier	What it says	Source
Principle	The package lists every ingredient used in manufacturing	Cosmetics Act Art. 10(1), item 3
Exception	A perfuming agent may be written as the single word fragrance	Enforcement Rule Annex 4 (labelling standards and methods)
Proviso	If the perfuming agent contains a fragrance allergen listed by the ministry, the single word is not enough and the substance must be named	Same Annex 4 · MFDS notice Annex 2

A fragrance is not one ingredient but dozens blended together, which is why the middle tier exists at all. The proviso has applied to products manufactured or imported since 1 January 2020.

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Two thresholds, ten times apart

✔ Rinse-off products — above 0.01%

✔ Leave-on products — above 0.001%

The leave-on figure is ten times lower because the product stays on the skin. That is why perfumes, mists and body lotions carry longer allergen tails than a body wash does.

One point is easy to get wrong: the figures are not a combined total. The Korea Cosmetic Association’s Q&A puts it plainly — the figure refers to the content of each individual substance, and each is judged on its own. Five allergens at low levels are five separate decisions, not one sum.

The denominator is the net content of the product. In a 250 g body lotion, 0.05 g of limonene is about 0.02% — over the line, so limonene is named.

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The 25, as the notice names them

#	#
1  Amyl cinnamal	2  Benzyl alcohol
3  Cinnamyl alcohol	4  Citral
5  Eugenol	6  Hydroxycitronellal
7  Isoeugenol	8  Amylcinnamyl alcohol
9  Benzyl salicylate	10  Cinnamal
11  Coumarin	12  Geraniol
13  Anise alcohol	14  Benzyl cinnamate
15  Farnesol	16  Butylphenyl methylpropional
17  Linalool	18  Benzyl benzoate
19  Citronellol	20  Hexyl cinnamal
21  Limonene	22  Methyl 2-octynoate
23  Alpha-isomethyl ionone	24  Evernia prunastri (oak moss) extract
25  Evernia furfuracea (tree moss) extract

Entries 24 and 25 are not single molecules but botanical extracts. The notice sets no order or format for where the names go; the association recommends following the ordinary ingredient-list method, and the ministry has said that pulling allergens out into a separate block of their own is not appropriate, because it suggests those substances alone are a problem.

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When nothing is named

Situation	Why	What follows
Below the threshold	Under 0.01% / 0.001% there is no duty to name	The substance can be present and still invisible on the box
Small packages	Net content of 10–50 mL (g) leaves no room	The listing may be omitted, but the information must be findable on the company’s website
Online listings	—	The ingredient list shown on a sales page must carry the allergens too
Raw material reporting	—	Allergens that appear on the label are included in the annual raw material report

So an absent name does not mean an absent substance — and a present name does not mean a bad one. It means a threshold was crossed and the rule asked for daylight.

There is Korean market data on how this plays out. The Seoul Institute of Health and Environment tested 106 fragranced cosmetics on sale in the city — 85 leave-on (perfume, body mist, body cream, hand cream) and 21 rinse-off (body wash) — screening for 23 of the allergens by GC-MS. One body mist failed the coumarin labelling requirement and was referred for administrative action; the other 105 complied. Measured levels ran from not detected up to about 1.5%.

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Korea and the EU: the same two numbers, lists drifting apart

This is the part worth knowing if you buy Korean products abroad, or sell them there.

	Korea	European Union
Legal basis	Cosmetics Act Art. 10 · Enforcement Rule Annex 4 · MFDS notice Annex 2	Regulation (EC) No 1223/2009 Art. 19(1)(g) · Annex III
The single word	fragrance	「Perfume and aromatic compositions and their raw materials shall be referred to by the terms ‘parfum’ or ‘aroma’」
What comes out of it	the 25 substances in Annex 2	「the presence of substances, the mention of which is required under the column ‘Other’ in Annex III」
Thresholds	above 0.01% rinse-off · above 0.001% leave-on	the same — 「0,01 % in rinse-off products」 · 「0,001 % in leave-on products」
Most recent change	Annex 2 still stands as amended on 16 December 2019	Regulation (EU) 2023/1545 added 45 entries to Annex III, replaced 17 and deleted 10, after the SCCS identified 56 further fragrance allergens
Transition	—	non-compliant products may be placed on the market until 31 July 2026 and sold until 31 July 2028

Read that last row together with the one above it. From August 2026, the same formula will need a longer allergen list in Brussels than it needs in Seoul. A short tail on a Korean box is not a cleaner perfume, and a long tail on a European one is not a heavier one. The two lists are simply different lengths, and only one of them has just grown.

The EU also folded in prehaptens and prohaptens — substances that become allergens after air oxidation or metabolism on the skin — and grouped similar substances under shared names to make the labels readable. Korea’s notice has not taken that step.

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What to check on the box

✔ Look at the tail end of the ingredient list, around the word fragrance

✔ A leave-on product showing more names than a rinse-off one is the rule working, not a warning

✔ If a scent has stung before, write down that one name and compare boxes

✔ On a small bottle with no names, check the brand’s own website listing

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In one line

A name after the word fragrance is not something that slipped out — it is something the rule pulled out. The thresholds are 0.01% and 0.001%, and each substance is judged on its own.

What I left out, and why

✔ CAS numbers for the 25 — the Korean Law Information Center was unreachable the day this was written, so Annex 2 itself could not be opened. The names are taken from two trade publications that match character for character; the numbers are omitted rather than guessed

✔ Verbatim text of Enforcement Rule Annex 4 — same reason: the substance of the provision is given, but not in quotation marks

✔ The EU’s own list of substances — Annex III tables do not come through in the consolidated text. Only the entry counts stated by the amending regulation are given

✔ The current Korean status of butylphenyl methylpropional (Lilial) — the EU moved it to the prohibited annex in 2022. Korea’s prohibited-ingredient annex could not be opened, so whether it may still be used here is not stated either way

✔ Prevalence figures for individual allergens — no primary studies were opened for this article, so none are quoted

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📌 Earlier guides

📌 How to Read a Korean Cosmetic Ingredient List (Ingredient Guide 14) — where the order stops at 1%

📌 Ceramides: cholesterol and fatty acid ratio (Ingredient Guide 4)

📌 Panthenol: What the Dexpanthenol Studies Show (Ingredient Guide 7)

📌 Skin Concern Ingredient Map

📄 Sources

· Cosmetics Act (Korea), Article 10 · Enforcement Rule, Annex 4 (labelling standards and methods)

· MFDS notice, Precautions for Use of Cosmetics and Labelling of Fragrance Allergens, Annex 2

· Korea Cosmetic Association, ingredient dictionary Q&A on allergen labelling

· MFDS guidance on labelling fragrance allergens (via trade press reporting)

· Seoul Institute of Health and Environment, survey of 106 fragranced cosmetics

· Regulation (EC) No 1223/2009, Article 19(1)(g) · Regulation (EU) 2023/1545

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This article summarises statutes and ministry notices and is not a substitute for diagnosis or treatment. The Korean Law Information Center was unreachable the day it was written, so the 25 names were cross-checked against an association Q&A and two trade publications, and CAS numbers and verbatim provisions were left out. EU material is taken from the current public text on EUR-Lex.

— Dr. J Ingredient Notes