Fragrance allergen evidence for skincare makers

Trace the evidence before calculating an allergen contribution

A supplier's allergen declaration belongs to a particular material and issue. Before using it, match the supplier code, grade and document version to the material in the formula. A declaration for a similar fragrance name is an unresolved identity question, not a substitute.

The European Commission's fragrance-allergen overview describes the expanded Annex III labelling requirements. It identifies 31 July 2026 and 31 July 2028 as different transition milestones, subject to the regulation's conditions. Record the actual product and supply history for specialist review; a packaging print date alone cannot establish which transition applies.

Collect the inputs as a connected set

Keep the formula revision, intended sales destination, intended use, material inclusion rates and the supplier evidence together. Record whether a supplier value is an exact amount, a range, an upper bound or a reporting limit. Keep the units and basis visible. A blank entry does not mean zero.

Ask the specialist which materials need to be included in the review, including possible contributions outside the main fragrance blend. Do not assume that removing parfum from the formula removes every relevant source. Keep identity and composition questions separate from the later label decision.

Synthetic formula F03: two contributions to the same candidate

The working example is a fictional cream. Material FR-01 is included at 0.5% by mass and its hypothetical declaration states 0.4% of candidate Allergen A by mass in that material. The contribution is 0.5 multiplied by 0.4 and divided by 100, giving 0.002% by mass in the finished mixture.

A second fictional material, BT-02, is included at 1.5% and contains 0.1% of the same candidate on the same basis. Its contribution is 0.0015%. Adding these two contributions gives 0.0035%. These are invented exact values chosen to demonstrate percentage arithmetic. They are not data for a real fragrance, botanical or product.

The calculation assumes the values share a compatible basis and that the candidate identity is the same in both records. If either assumption is unverified, keep the total provisional. A real declaration containing ranges or grouped substances needs its own interpretation; do not silently replace its values with the invented exact values used here.

Preserve the path back to the files

The blank worksheet provides fields for each source contribution, its evidence reference, the calculation basis and the unresolved question. Save the supplier documents separately and link their exact identities. The synthetic worksheet includes a total row with the two input references so another person can reproduce the arithmetic.

Keep a calculation check distinct from a specialist finding. Someone can confirm that 0.002 plus 0.0015 equals 0.0035 without establishing the applicable Annex III identity, naming rule, threshold, legal date or finished-product safety.

Hand the result to the label reviewer

Provide the formula revision, product type, candidate identities, total contributions, source documents and uncertainties. The label-review guide B05 continues that task. It should receive the calculation record, rather than only a copied list of ingredient names.

Keep Ireland/EU, Great Britain and Northern Ireland as separate review scopes. This example does not decide a GB or NI requirement. In the workspace, assign an owner to the missing supplier evidence and preserve the current product revision. If a material or supplier declaration changes, record which calculations and artwork decisions need another review. Release linked task guides only after their own review gates are satisfied.

Sources and legal dates