If a detergent contains fragrances not restricted by the Cosmetics Directive, does the label still have to state contains fragrance? Does it have to specify the particular fragrance?
Annex VII.A contains two separate obligations in relation to fragrance (perfumes): • An obligation to list perfumes as a generic ingredient if any have been added at all; • And an obligation to name specific allergenic fragrances annexed to the Cosmetics Directive (Directive 76/768, as amended: Annex III, Part 1) that have been added to the product at significant concentrations (0.01% or, if applicable, the risk-based threshold for the specific substance). In other words, if fragrances that are not restricted under the Cosmetics Directive (and only such fragrances) are added to a product, the label must state that the product contains fragrances but need not specify the particular fragrance or fragrances added.