Fragrance-free, unscented and no added fragrance are three different claims

Unscented is a claim about what you can smell, not about what is in the bottle. The convention across the trade is that fragrance materials have not been used to give the product a scent, while chemicals that neutralise or mask the odour of the other ingredients are permitted, and the US Environmental Protection Agency writes exactly that distinction into the criteria document behind its own fragrance-free label 1.

The FDA describes the same practice from the buyer’s side, warning that a product carrying the word may contain fragrance ingredients because “the manufacturer may add just enough fragrance to mask the unpleasant smell of other ingredients, without giving the product a noticeable scent” 2. A raw surfactant base or an enzyme blend can smell of something nobody would choose, and masking it is ordinary formulation practice. The word does not carry the meaning most people take from it.

Fragrance-free is the stronger claim, and in the United States it has no legal definition behind it. The closest thing to a written standard is the EPA criterion attached to the Safer Choice label, which states that fragrance-free means “neither fragrance materials nor masking scents are used in the product”, and which certifies that by checking a product’s ingredients against the IFRA Transparency List of materials used to impart or mask a scent 1.

That definition binds one label on one voluntary programme rather than the phrase itself, and the same document adds something worth knowing: a certified fragrance-free product may still have an odour 1. Fragrance-free is not odour-free, and a reader who treats a smell as proof of a hidden perfume will reject products that are doing what the label says.

There is a second gap in the US, and for a home care site it is the larger one. The FDA’s rules cover cosmetics, and laundry detergents, fabric softeners, dryer sheets and room fresheners are not cosmetics: they fall to the Consumer Product Safety Commission 2. The agency that has written most about what unscented means is not the agency overseeing the bottle under the sink.

No added fragrance is the narrowest of the three, and it is precise if you read it literally: nothing has been added for the purpose of fragrancing. It says nothing about whether a fragrance material is present, because an ingredient can be in a formula for another job and be a fragrance allergen anyway.

Benzyl alcohol is the clean example. It appears at entry 68 of Annex III of the EU cosmetics regulation, the list of substances that have to be named individually on a label, and at entry 34 of Annex V of the same regulation, the list of preservatives allowed in cosmetics at up to 1.0% 3. A formulator adding it as a preservative has added no fragrance and has put a declarable fragrance allergen in the product. Both statements are true at once.

Europe does not define fragrance-free either, and it takes a different route: it makes the list do the work. Under Article 19(1)(g) of Regulation (EC) No 1223/2009, a perfume composition and its raw materials are shown by the single word parfum or aroma, so one entry on a label can stand for dozens of components without naming any of them 3.

The exception is the allergen list. Entries 67 to 92 of Annex III are the 26 fragrance allergens that must be named individually in addition to the parfum entry, once the substance exceeds 0.001% in a leave-on product or 0.01% in a rinse-off one 3. Twenty-four are single substances, from amyl cinnamal to alpha-isomethyl ionone, and two are botanical extracts: oak moss and treemoss, listed under their Latin names, Evernia prunastri and Evernia furfuracea.

That list of 26 is the one most reference material still describes, and it is no longer the current one. Regulation (EU) 2023/1545 extended it substantially, and the transition has run out at one end: products that do not meet the new labelling could be placed on the EU market until 31/07/2026 and may be made available until 31/07/2028 4. A bottle bought today can carry either version, and the label gives no clue which.

Detergents are governed separately again. Regulation (EC) No 648/2004 requires perfumes to be declared as a class whatever the concentration, with the individual allergens named above 0.01% by weight 5. That instrument is on its way out: Regulation (EU) 2026/405 was adopted on 11/02/2026, applies from 23/09/2029 and repeals the old one from the same date 6. Part D of its Annex V runs to 105 numbered fragrance allergens, labelled where intentionally added above 0.01% by weight, and ties future changes to the cosmetics list 6. On a laundry label, the named list gets four times longer at the end of this decade.

The most common misreading on this shelf is that a fragrance derived from plants is not a fragrance in the regulatory sense. It is. The EU allergen list is built substantially out of the constituents of essential oils: limonene from citrus peel, linalool from lavender, citral from lemongrass, geraniol from rose, eugenol from clove 3. Scent a product with lavender oil and, above the threshold, linalool goes on the label.

The regulations do not stop at constituents. Oak moss and treemoss extracts are listed as whole botanical materials 3, the new detergent list adds Pinus mugo leaf and twig oil among others 6, and the 2023 amendment carries provisions on verbena essential oils 4. No synthetic fragrance is a claim about where the molecules came from. Fragrance-free is a claim about whether they are there.

None of that argues plant-derived fragrance is worse than synthetic, and the evidence available does not settle it either way. The narrower point is firm: the word on the front does not track the allergen, and the list on the back does.

• Read the ingredient list rather than the front of the pack. Every claim above is a summary somebody else wrote of that list.
• Treat parfum, fragrance, perfume and aroma as one entry standing for many, and count what is named after it 3.
• Learn the allergen names you are most likely to meet: limonene, linalool, citronellol, geraniol, citral, coumarin, eugenol, benzyl alcohol and hexyl cinnamal 3.
• Read botanical oil names as fragrance. Lavandula angustifolia oil and Citrus limon peel oil are perfume ingredients written in Latin.
• Do not stop at unscented. Look for fragrance-free plus a list with no parfum entry and no named allergens.
• In the US, Safer Choice with the fragrance-free notation is the one claim checked against a list of fragrance materials by somebody other than the manufacturer 1.
• Do not use smell as the test. A certified fragrance-free product can still have an odour of its own 1.

The thresholds above are labelling triggers, not safety lines for a given person. The reasoning published with the 2023 amendment is explicit that sensitised people can react to concentrations below the permitted maximums, which is the stated reason the individual names are required at all 4. A product can comply completely and still be the wrong product for one reader.

The US position is thinner still. The FDA states that it lacks the legal authority to require allergen labelling for cosmetics that it has for food, and its advice to anybody worried about fragrance sensitivity is to choose fragrance-free products and read the ingredient list carefully 2. The Modernization of Cosmetics Regulation Act requires the agency to set fragrance allergen labelling by regulation 7, and when we looked on 21/08/2026 we could not find a published rule doing it. Until that changes, a US shopper reading a detergent label has neither a defined phrase nor a named list, and the EU list is the nearest reference either market offers.