Malaysia Fragrance Allergen Labelling: When Must the 26 Fragrance Ingredients Be Listed Separately

In Malaysia, fragrance itself may be listed collectively in the ingredient list as "Parfum" or "Fragrance," but among it are 26 known fragrance allergens that, once their concentration in the finished product exceeds a threshold, must be listed separately in the ingredient list by their individual INCI names and may not be hidden within Parfum. This requirement comes from Annex III of the ASEAN Cosmetic Directive (ACD), which NPRA adopts together in its Cosmetic Labelling Requirements (Annex I Part 7). The thresholds are: leave-on products > 0.001% (10 ppm); rinse-off products > 0.01% (100 ppm). For the overall labelling rules, first see the NPRA cosmetic notification overview.

Why they must be listed separately

Fragrance is one of the most common sources of contact allergens in cosmetics. Many natural or synthetic fragrance ingredients can cause contact dermatitis in sensitive groups, with symptoms ranging from redness and itching to rashes. The problem is that if you only write "Parfum," consumers who are already allergic to a specific fragrance have no way to know whether the product contains the ingredient that triggers their allergy. Regulators therefore pick out the 26 higher-risk ingredients with sufficient evidence of sensitisation and require that, when they exceed the threshold, they be "broken out and written clearly," so allergic consumers can identify and avoid them. This is an information-transparency obligation, not a branding of the ingredients as contraband.

Who regulates, and on what basis

• Under the ACD labelling requirements, NPRA requires ingredients to be listed by INCI name in descending order of concentration; Annex III adds the condition "to be labelled in the ingredient list" for these 26 fragrance allergens.
• This is a labelling obligation, not a prohibition: ingredients exceeding the threshold may still be used, but must be visible to consumers in the ingredient list so allergic consumers can identify them.
• The concentration is judged on the "finished product," not the proportion in the raw fragrance material itself; so the same fragrance used at different dosing levels may produce different labelling results.

The 26 fragrance allergens that must be labelled

Expressed by INCI name: Amyl cinnamal, Amylcinnamyl alcohol, Benzyl alcohol, Benzyl benzoate, Benzyl cinnamate, Benzyl salicylate, Cinnamal, Cinnamyl alcohol, Citral, Citronellol, Coumarin, Eugenol, Farnesol, Geraniol, Hexyl cinnamal, Hydroxycitronellal, Hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC/Lyral), Isoeugenol, Limonene, Linalool, Methyl 2-octynoate, alpha-Isomethyl ionone, Anise alcohol, Butylphenyl methylpropional (Lilial), Evernia prunastri (oakmoss) extract, Evernia furfuracea (treemoss) extract.

How to do it in practice

• Obtain the IFRA certificate and allergen declaration from your fragrance supplier to get the proportion of each allergen in the fragrance, then multiply by the fragrance's dosing level in the formula to convert to the final concentration.
• List each item exceeding the threshold in the ingredient list; a common way of writing it is Parfum (Linalool, Limonene, Citronellol, ...).
• Review risk ingredients early: HICC (Lyral), Butylphenyl methylpropional (Lilial), oakmoss/treemoss extract have been tightened or banned in the EU, so it is advisable to replace them early at the formulation stage to avoid a redo when ASEAN harmonisation later tightens. If the product also markets itself as "clean/fragrance-free," be sure to review it together with organic/natural cosmetic claims.

Relationship to future trends

These 26 are the list currently adopted by the ASEAN Cosmetic Directive, but allergen labelling is a field that "will expand." In 2023 the EU substantially expanded the fragrance allergens requiring individual labelling to more than 80, with a transition period of several years. Because the ASEAN Cosmetic Directive has long harmonised by following the EU framework, it is reasonable to expect that NPRA will also gradually expand the list. Brands that build a "fragrance allergen database" at the formulation stage and require suppliers to provide complete declarations will find it much easier to respond to list expansion later, without having to re-test and reprint labels every time. Brands selling across markets should in particular prepare materials to the stricter end (usually the EU) and then map to Malaysia's current requirements.

Common mistakes

• Writing only Parfum and calling it done—if the 26 items exceeding the threshold are not listed separately, it is non-compliant labelling.
• Applying the leave-on threshold to rinse-off products (or vice versa)—the two differ by a factor of 10, making it easy to under- or over-label.
• Ignoring natural essential oils—citrus, lavender, tea tree and other essential oils naturally contain Limonene, Linalool, Citral and often exceed the threshold unnoticed; the amount of essential oil also affects preservation, see the cosmetic preservatives allowed list.

Frequently asked questions (FAQ)

Q: Are these 26 fragrance allergens banned in Malaysia? No. They may be used; it is only that when they exceed the threshold they must be listed separately in the ingredient list by INCI name—a disclosure obligation, not a prohibition.

Q: What are the thresholds for leave-on and rinse-off? Leave-on (such as lotions, perfumes, colour cosmetics) > 0.001% (10 ppm); rinse-off (such as shampoos, shower gels) > 0.01% (100 ppm).

Q: Do natural essential oils count too? Yes. Essential oils naturally contain multiple listed ingredients and must be converted per the supplier's declaration; if they exceed the threshold they must equally be labelled.

Q: My product uses only a tiny amount of fragrance—do I still need to test? Go by calculation. Even at a low fragrance dosing level, if a certain allergen is present in a high proportion in the fragrance, the final product may still exceed the threshold, so it is advisable to convert from the formula rather than rely on a hunch.

Q: Are there rules on the labelling position? They must be listed within the ingredient list (INCI list), usually after Parfum; the overall labelling must still meet NPRA's requirements for language, clear and indelible type.

Self-check checklist

• [ ] Obtained the fragrance supplier's allergen declaration and IFRA document
• [ ] Converted the final concentration using the correct leave-on/rinse-off threshold
• [ ] The 26 allergens exceeding the threshold are listed separately by INCI in the ingredient list
• [ ] Reviewed allergens brought in by natural essential oils
• [ ] Assessed replacement of high-risk ingredients such as HICC, Lilial, oakmoss

Conclusion: The point of fragrance allergen labelling is not "can you use it" but "have you let the consumer see it." Converting with the correct thresholds, listing each of the 26, and avoiding high-risk fragrances early are the keys to passing NPRA labelling checks.

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This article is compiled from official sources for reference only; actual compliance is subject to the latest official texts and reviews of the competent authorities.