If you sell anything scented, a perfume, a body wash, a candle-adjacent lotion, your ingredient list probably ends with one word: "fragrance." That's been legal in the US for decades. It's going to change. Nobody knows exactly when yet, though, and that's what most brands get wrong when they plan for it.
Here's where it actually stands, and what I'd do in email before anything becomes required.
What the law already says
The Modernization of Cosmetics Regulation Act (MoCRA) passed at the end of 2022. One section of it, now 21 U.S.C. 364e, says the brand responsible for a cosmetic has to list each fragrance allergen on the label. The catch is that FDA has to decide by regulation which substances count as allergens, and it can set thresholds below which you don't have to disclose them. Until that rule is final, "fragrance" is still allowed.
FDA was supposed to propose that rule within 18 months of the law, so by June 2024. It didn't. The 2026 target was May, and FDA's own Office of Cosmetics said in May it would miss that too (HBW Insight). The current federal Unified Agenda entry (RIN 0910-AI90) lists it at the proposed rule stage.
So to be clear about what's true today: there is no proposed rule yet. When one shows up, there'll be a comment period, then a final rule, then a compliance date. You have time. You just don't have a date.
Europe already went first
If you want a preview of what the US list might look like, the EU is the obvious place to look, and MoCRA tells FDA to consider international requirements. Under Regulation (EU) 2023/1545, the number of fragrance allergens that have to be named individually goes from roughly two dozen to about 80. New products placed on the EU market after July 31, 2026 have to comply. Products already out there can keep selling until July 31, 2028.
If you ship to Europe, you're probably already doing this work for those labels. A lot of US brands aren't, and that's who this post is for.
Why this is an email problem before it's a label problem
Packaging takes months to change. Email and product pages take an afternoon. And the people who care most about fragrance allergens are already on your list. They're the customers who reply to your welcome email asking "is this OK for sensitive skin?" or who went quiet after one order because something made them itch.
Those customers don't care whether FDA has finished its paperwork. They want to know what's in the bottle. So I'd treat the rule as a deadline you can beat on purpose, in the channels you control. (More on how we approach email marketing for beauty and grooming brands.)
What I'd do now
1. Get the allergen breakdown from your fragrance supplier. Most fragrance houses can give you the list of declarable allergens in each blend, because EU customers already ask for it. You can't write anything until you have this, and it's the step that takes longest.
2. Put it on the product page first, then link to it from email. One short "Fragrance allergens" line under the ingredient list. Your post-purchase and product-education emails link to that instead of repeating it, so you only update it in one place.
3. Add it to the emails sensitive-skin customers actually read. The welcome series question about skin type, the first post-purchase email, and any "how to use" email. Something like: "Our fragrance contains linalool and limonene. If you react to those, try the fragrance-free version." Plain and specific.
4. Sell the fragrance-free version properly. If you have one, a fragrance-sensitive branch in your flows gives those customers a reason to buy. If you don't have one, that's worth a product conversation.
5. Watch your inbox replies. This one's separate from labeling but it matters more. MoCRA already requires brands to report serious adverse events to FDA within 15 business days, and FDA's definition includes things like serious and persistent rashes and significant hair loss (FDA). Customers report reactions by replying to marketing email all the time. Whoever reads those replies needs to know where to send them.
6. Don't write anything that sounds like a medical claim. "Hypoallergenic" and "safe for eczema" carry baggage that "fragrance allergens listed" doesn't. Telling people what's in the product is enough.
What I wouldn't do
I wouldn't send a campaign announcing "new FDA rules." There isn't one yet, and if the proposal changes or slips again you'll look like you jumped the gun. I also wouldn't reprint packaging on a guess. The final US list and thresholds could differ from the EU's.
Disclosing in email and on product pages is low cost and you can change it whenever you need to. If the rule lands the way most people expect, you'll already be ahead. If it slips again, you'll still have answered the question your most careful customers keep asking.
