Fragrance Free vs Unscented: How the Cosmetic Product Safety Report Treats Each and What to Switch First

Fragrance free and unscented sit next to each other on shelves and mean different things, which is a problem for the many people choosing products to calm reactive skin. The distinction matters because fragrance is the commonest cause of cosmetic contact allergy, and because the law requires named fragrance allergens on the label above thresholds under Regulation (EC) No 1223/2009, expanded from 26 to more than 80 substances by Regulation (EU) 2023/1545 for products placed on the EU market from July 2026. In Great Britain the same regulation is enforced through the Cosmetic Products Enforcement Regulations 2013, and both claims are judged against the criteria in Regulation (EU) No 655/2013.

This article explains the difference precisely, shows how a Cosmetic Product Safety Report handles each claim, covers masking fragrance and why it defeats the purpose for sensitive users, addresses the essential oil question that brands find hardest, gives a switching order for anyone reducing fragrance exposure, explains what the label tells you in seconds, works through an example of a range whose claims were corrected, and sets out how a brand should word both claims so they survive an assessment. It is written for brands and for the people who write to them asking why an unscented cream made their face sting.

What is the actual difference?

Fragrance free means no fragrance material has been added to the product for the purpose of giving it a scent. Unscented means the finished product has no perceptible odour, which can be achieved in two ways: by using raw materials that happen to have little smell, or by adding a masking fragrance that neutralises the base odour of the formula. The second route is common, because many cosmetic raw materials, particularly some surfactants, plant oils and actives, have smells that customers dislike. So an unscented product may contain fragrance and a fragrance free product may have a faint natural smell from its own ingredients. For a consumer avoiding fragrance the two claims point in opposite directions, which is exactly why the distinction is worth getting right on a pack.

How does the CPSR treat each claim?

Why masking fragrance defeats the purpose

Because the person avoiding fragrance is avoiding the allergens, not the smell. A masking fragrance is a fragrance composition like any other, contributing the same constituents, and the label will name any of them present above 0.001 percent in a leave on product or 0.01 percent in a rinse off. Someone with sensitive skin and sensitised to linalool reacts to it whether it was added for scent or to cover the smell of a surfactant. This is why an unscented product can cause exactly the allergic reactions the customer was trying to avoid, and why the complaint email says the product had no smell so it cannot have been the fragrance. For brands, the answer is either to formulate around the base odour, which is a real formulation challenge and sometimes means accepting a product that smells faintly of its ingredients, or to be precise on the pack and not let unscented imply fragrance-free product. Our article on hypoallergenic claims and the CPSR covers the neighbouring claim.

The essential oil question

Essential oils used to scent a cosmetic are fragrance. That sentence causes more argument than any other in this area, because brands that have deliberately avoided synthetic fragrance feel the claim should be available to them. Regulatory reality is unsentimental: essential oils contain many of the same sensitising constituents as fragrance chemicals, several are on the expanded EU allergen list in their own right from July 2026, and a product scented with lavender declares linalool and limonene exactly as a product scented with a synthetic composition would. A product with essential oils is therefore not fragrance free, and an assessor will refuse the claim. What the brand can say, accurately and usefully, is scented only with essential oils, or no synthetic fragrance, both of which describe a real formulation choice without misleading the person who needs to avoid allergens altogether.

What to switch first

The order follows exposure: how long the product stays on, how much skin it covers, how sensitive that skin is and how often it is used. Switching a face moisturiser makes more difference than switching a body wash, which is why someone who has changed only their shower gel and seen no improvement has usually started in the wrong place. If masking agents are present in a product, they should also be considered when identifying potential sources of fragrance exposure.

Does removing fragrance change the rest of the formula?

It can, in ways worth planning for. Fragrance compositions sometimes contribute incidental antimicrobial activity, so a formula that passed its challenge test with a fragrance can behave differently without one, and the test must be repeated on the actual fragrance free version rather than assumed. Base odour becomes visible once the covering scent goes, which occasionally sends a brand back to the raw material choice: a different grade of a plant oil, a deodorised butter, or a surfactant with a cleaner smell. Colour can shift too, since some fragrance materials mask slight discolouration. And customers notice: a loyal buyer who liked the scent will write in, which is why the clearest brands explain the change rather than making it quietly. None of this is difficult, but it is a reformulation rather than a deletion, and it needs its own assessment. Our article on how a CPSR sets the period after opening covers the stability and preservation side.

What the label tells you in seconds

• Parfum or Fragrance. A fragrance composition has been added..
•  Aroma. A flavouring, usually in lip and oral products, and still a fragrance material.
• Names after Parfum such as Linalool, Limonene, Geraniol, Citronellol, Coumarin. Declared allergens present above threshold.
• Latin binomials ending in Oil, such as Lavandula Angustifolia Oil. Essential oils, which are fragrance in a leave on product.
• Extracts with a strong natural scent. Worth checking, since some are used partly for odour.
• No Parfum, no allergens, no essential oils. A genuinely fragrance free formula.
  

What about flavour, and products for the lips and mouth?

Lip balms, lipsticks, toothpastes and mouthwashes raise the same question in a different vocabulary. Aroma on an ingredient list is a flavouring composition and is treated as a fragrance material for allergen purposes, so a lip balm flavoured with a vanilla aroma declares any allergens above threshold exactly as a scented cream would. A fragrance free claim on a lip product therefore requires no Aroma as well as no Parfum, which many brands overlook because they think of flavour as a separate category. There is a further consideration specific to lips: the product is ingested in small quantities, so the exposure assessment in the Cosmetic Product Safety Report treats oral exposure as well as skin contact, and the IFRA category for lip products is the strictest of all. A brand developing an unflavoured lip balm for sensitive users has a genuinely useful product and should say fragrance and flavour free, which is precise and immediately understood.

A worked example: a range corrected

A sensitive skin brand submits four products labelled unscented and fragrance free interchangeably. The cleanser and the body lotion contain no fragrance material at all, so both claims are accurate and the brand is advised to standardise on fragrance free because it is the more informative term. The face cream contains a masking fragrance at 0.15 percent, which the assessor identifies in Part A and which produces declarations for two allergens; unscented is supported, fragrance free is refused, and the brand chooses to reformulate without the masking agent rather than lose the claim, accepting a faint base odour. The hand balm is scented with a lavender and geranium blend; both claims are refused and the pack is rewritten as scented only with essential oils, with the allergen declaration updated against the expanded list. The brand ends with three genuinely fragrance free products and one honestly described scented one, and its customer service enquiries about reactions fall over the following year.

Can a fragranced product still suit sensitive skin?

Sometimes, and it is worth saying plainly because the opposite message pushes brands towards claims they cannot support. Not everyone with sensitive skin is sensitised to a fragrance allergen; many people react to irritation from surfactants, acids, alcohol or a damaged barrier rather than to allergy, and for them a lightly fragranced, well formulated product may be perfectly comfortable. What a brand cannot do is assume that, or claim suitability without evidence. The honest route for a fragranced product aimed at this audience is an in use tolerance study on a panel with self declared sensitive skin under dermatological supervision, a clear allergen declaration on the label, and wording that describes what was tested rather than promising universal suitability. What it cannot claim is hypoallergenic, since a product declaring fragrance allergens contradicts that claim on its own pack. The distinction between irritation and allergy is one of the more useful things a brand can explain to its customers, because it helps them work out which products to avoid rather than avoiding whole categories.

How brands should word these claims

• Use fragrance free only where nothing has been added for scent, including
• masking fragrance and essential oils. 
• Use unscented for products with a masking fragrance, and do not let the pack imply fragrance free. 
• Say scented only with essential oils where that is the formulation choice. 
  Never write no synthetic fragrance on a product containing a masking fragrance that happens to be natural. 
• Keep the allergen declaration current against the expanded list. 
  Explain the difference on your website, because most customers do not know it. 
• Have the assessor confirm which claim the formula supports before print. 
  

Myths we hear

• Unscented means no fragrance. It means no perceptible smell, which is often achieved with a masking fragrance.
• Essential oils do not count as fragrance. They are fragrance and they declare allergens.
• If I cannot smell it, it cannot react. Sensitisation is to the constituent, not to the perception of scent.
• Fragrance free products have no smell. They often smell faintly of their own ingredients, which is normal and honest.
• Switching shower gel is a good first step. Start with leave on face products; exposure is far higher.
  

What to do this week

•    Audit your range for which claim each product can actually carry. 
•    Identify any masking fragrance in your formulas. 
•    Standardise the wording across packs and website. 
•    Update allergen declarations against the expanded list. 
•    If you are a customer rather than a brand, switch your face moisturiser first. 
Two words, one letter apart in most people's minds, and a real difference for anyone with reactive skin. Getting them right costs a brand nothing and saves its customers a great deal of trial and error.

Related reading on the Spectra blog

•    Clinically proven and dermatologist tested: the evidence a CPSR files
•    Can a Cosmetic Product Safety Report back up hair care claims?
•    When can a Cosmetic Product Safety Report support a hypoallergenic claim?
•    All Spectra articles

Spectra services mentioned in this article

•    The Complete Compliance Pack: CPSR, PIF, SDS and SCPN or CPNP (£295)
•    CPSR services by product type
•    PIF services
•    CPSR for Perfumes and Fragrances (from £84)
•    UK and EU Responsible Person
•    Contact Spectra

Official sources and legislation

•    Regulation (EU) 2023/1545 on fragrance allergen labelling
•    Regulation (EU) No 655/2013 on cosmetic claims
•    Regulation (EC) No 1223/2009 on cosmetic products, Annex III
•    Scientific Committee on Consumer Safety (SCCS)
•    OPSS guidance on cosmetic products regulations

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.