“Fragrance-free” has a test, and it is not the ingredient list

“Fragrance-free” looks like a fact about an ingredient list. It is closer to three separate questions that happen to share a phrase, and they do not have the same answer for the same product.

• What the pack is allowed to say. A claims test, and it turns on what an ingredient is doing in the formula.
• What a list can be checked for. A name test. It is what we run, it is what any reader can run, and it is the only one an ingredient list can actually support.
• Whether it is safe for you. A different question again, answered by a named allergen rather than by a phrase.

masks pass our fragrance-free name test

79masks pass our fragrance-free name testof 215

carry nothing we recognise as scent material at all

69carry nothing we recognise as scent material at allno perfume word, no oil, no declared allergen

name at least one fragrance allergen individually

78name at least one fragrance allergen individuallythe entries an allergic reader can actually use

The gap between the first two of those numbers is 79 minus 69, and it is where the rest of this piece lives.

Cosmetic claims in the EU are governed by Article 20 of the Cosmetics Regulation and by Regulation (EU) No 655/2013, which sets six common criteria a claim has to satisfy: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. Those are standards rather than thresholds, which is why the interesting material is in the guidance written to apply them. A working group of the Member States, the consumer organisation BEUC and the industry bodies produced a technical document for that purpose, and in July 2017 added an annex dealing specifically with “free from” claims.

One sentence in it does most of the work:

Read that against a label and the problem is immediate. The test is about function, and function is not printed. An ingredient list gives you names in descending order of concentration; it does not tell you why a formulator put something in. A plant oil that is in there for its smell and a plant oil that is in there as an antimicrobial print identically. The pack’s claim is assessed against a fact about the formula that the pack does not disclose.

The same annex has a second rule that matters even more for masks, because it covers the case where a single ingredient wears two legal hats: “free from” claims addressing functional groups of ingredients should not be allowed if the product contains ingredients with multiple functions and among these is the function the product is claimed to be free from.

Benzyl Alcohol is the textbook instance, and it is on 17 masks here. It is a permitted preservative under Annex V of the Cosmetics Regulation at up to 1%. It is also one of the original twenty-six fragrance substances, and Annex III entry 45 requires it to be named above 0.001% in a leave-on product and 0.01% in a rinse-off one — expressly for purposes other than inhibiting the development of micro-organisms in the product. Same INCI name, two annexes, and the annex that applies depends on the formulator’s intent.

Which produces a genuinely awkward result on this site. 3 masks here are excluded from our fragrance-free count on the strength of benzyl alcohol and nothing else: no perfume word anywhere on the list, no essential oil, no other declarable allergen.

In a charcoal or clay mask carrying no other scent material, benzyl alcohol is overwhelmingly likely to be there as the preservative. Our flag cannot see that, because the printed list does not say it. So we hold the conservative position and count it — and say plainly here that for these masks the flag is probably stricter than the claims test would be. The same trap catches “preservative-free”, which the guidance also rejects when something in the formula is doing preservative work; that is the subject of the preservatives piece.

The guidance also closes off two phrases that would be far more useful than “fragrance-free” if they were available.

“Free from allergenic substances”

Not allowed, and the reasoning is worth quoting because it applies to every gentle-sounding claim in the category: a complete absence of the risk of an allergic reaction cannot be guaranteed, and the product should not give the impression that it does. There is no formula that is safe for everybody, and a claim implying otherwise fails the honesty criterion.

“Hypoallergenic”

Permitted, but only where the product has been designed to minimise its allergenic potential, with evidence confirming a very low allergenic potential through scientifically robust and statistically reliable data, kept updated as new data arrives. Where a product does claim it, the guidance says the presence of known allergens or allergen precursors should be totally avoided — including substances identified as sensitisers by the SCCS, substances classified as skin sensitisers under the CLP rules, and substances generally recognised as sensitisers in the scientific literature. And it repeats the limit: the claim does not guarantee a complete absence of risk of an allergic reaction.

“Allergen precursors” is the phrase to notice. A substance that is not itself much of an allergen until air gets to it is precisely a precursor, and that describes the two most common fragrance entries in this catalogue — Linalool and Limonene. What happens to them on the shelf is the subject of the companion piece.

This site publishes a fragrance-free filter on 215 masks, so it owes you the methodology and the failure modes rather than the badge alone. A mask counts as fragrance-free here when no entry on its printed list reads Parfum, Fragrance or Aroma, and no entry carries an EU allergen-labelling duty. That is a name test over a published document, which makes it reproducible: you can run it yourself on a box in a shop. It is wrong in two opposite ways, and both are countable.

Fragrance contact allergy runs at an estimated 1-3% in the general European population and around 16% among eczema patients, so for most readers this is a preference and for some it is a medical constraint. The instructions differ.

1. Use the phrase to narrow, then read the list. The claim is assessed on function you cannot see; the list is a legal document you can. Where they disagree, the list is the thing in your hand.
2. Scan for the oils, not only for the word.A botanical name ending in “oil” near the end of a list is scent material, whatever the front of the box says.
3. If you have a diagnosed allergy, work from the named entry. 78 masks here name at least one allergen individually, and that name is worth more than any claim.
4. Do not read “hypoallergenic” as “safe for me”. The guidance that permits the word states in terms that it guarantees no such thing.
5. Distrust a badge that has no test behind it. Including ours: the two failure modes above are published for the same reason the ≈1% line is drawn as an approximation.