Limonene and linalool on EU labels: the 0.001% rule
In the EU, limonene (Annex III No 88) and linalool (No 84) must be individually named in the ingredient list above 0.001% in leave-on and 0.01% in rinse-off products; limonene also needs a peroxide value below 20 mmol/L. The US allows them under “fragrance”.
Short answer: in the EU, limonene and linalool must each appear by name in the ingredient list when they exceed 0.001% in leave-on or 0.01% in rinse-off products (Regulation 1223/2009, Annex III No 88 and No 84, per Article 19(1)(g); consolidated 18.05.2026). Limonene additionally requires a peroxide value below 20 mmol/L. In the US, both can sit inside the word “fragrance”.
The numbers
| Substance | EU entry | Leave-on threshold | Rinse-off threshold | Extra condition | US |
|---|---|---|---|---|---|
| Linalool | Annex III No 84 | 0.001% | 0.01% | — | Under “fragrance” |
| Limonene | Annex III No 88 | 0.001% | 0.01% | Peroxide value < 20 mmol/L | Under “fragrance” |
US vs EU
The thresholds are per substance, not per fragrance blend. A face cream with 0.4% parfum that contains 0.15% linalool must name linalool — 0.15% is far over the 0.001% leave-on threshold, and "the parfum was only 0.4%" is not a defence. Position in the list follows the ingredient-order rules after the fragrance entry.
In the US, fragrance components may be declared collectively as “fragrance” under 21 CFR 701.3, and no federal allergen-threshold rule exists (MoCRA directed FDA to set fragrance-allergen labeling; no such rule was in effect at our last check).
Common mistakes
- Applying the rinse-off threshold to a leave-on product — the leave-on threshold is ten times lower.
- Naming limonene but buying a cheap oxidized grade. The peroxide value condition is part of the entry.
- Listing the allergens but keeping them out of the ingredient order. They slot into the descending order like any other ingredient.
- Assuming citrus-free means limonene-free. Limonene is added synthetically to many formulas as a scent component.
Do this now
Ask your fragrance house for the IFRA/allergen breakdown of every parfum you use, and check the leave-on products for any allergen above 0.001%. That single document settles the whole EU list.
FAQ
At what level must limonene or linalool be named on an EU label?
Above 0.001% in leave-on and 0.01% in rinse-off products (Annex III No 84 and No 88).
Does the threshold apply to the fragrance blend or each substance?
To each substance. A 0.4% parfum containing 0.15% linalool still triggers the linalool listing.
Does limonene have any extra condition?
Yes. Its entry requires a peroxide value below 20 mmol/L.
Sources
- Regulation (EC) No 1223/2009, Annex III No 84 and No 88; Article 19(1)(g) — consolidated text 18.05.2026
- 21 CFR 701.3, ingredient designation (fragrance pooling) — eCFR, issue 2026-11-06
- FDA, MoCRA overview — fda.gov
Last verified: 2026-11-10.
Not legal advice, and not a guarantee of compliance or of acceptance by any authority.
Want this checked against your own formula? Run the free label check. It names every allergen that crosses the EU threshold and slots it into the ingredient order. It returns an issue list, not a print-ready label.
Related: EU fragrance allergen labeling · Benzyl alcohol: 1% cap and allergen rule