The Perfumery Logic of "Aromatic" Makeup Removers: How to Balance Fragrance and Gentleness?

I. Fragrance is a Brand Asset, but Also a Formulation Minefield

The moment a bottle of makeup remover is opened, the fragrance creates the consumer's first sensory impression. Fresh citrus notes, gentle florals, cool herbal scents—these olfactory signals play an undeniable emotional role in purchase decisions and repurchase experiences.

However, fragrance is also one of the ingredient dimensions that triggers the most consumer complaints in skincare.

Among the general adult population, up to 4.5% may be allergic to fragrance ingredients; among patients undergoing patch testing for contact dermatitis, the proportion of fragrance allergies can be as high as 20% to 25%. To date, over 150 fragrance ingredients have been confirmed to cause contact allergies. The most common sensitizers include the hydroperoxides of Linalool and Limonene, HICC (Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde), Tree moss and Oakmoss extracts, Isoeugenol, Cinnamyl alcohol, and Cinnamal.

A 2024 European systematic review published in the journal Contact Dermatitis, analyzing data from 1981 to 2022, showed that the overall sensitization rate for Fragrance Mix I (FM I) was 6.81% (95% CI: 6.37–7.28%), and for Fragrance Mix II (FM II) was 3.64% (95% CI: 3.3–4.01%).

This means: among your consumers, roughly 1 in 20 to 30 people may have a sensitivity tendency to a common fragrance ingredient. The game between the sensory value of fragrance and this potential irritation risk is the core proposition of "perfumery for aromatic makeup removers."

II. The Regulatory Turning Point: 2026 is a Critical Node for EU Fragrance Compliance

For brand owners aspiring to enter the European market, 2026 is an unignorable regulatory timeline for fragrance compliance.

EU Commission Regulation (EU) 2023/1545 has made major amendments to Annex III of the EU Cosmetics Regulation (EC) No 1223/2009, expanding the number of fragrance allergens that must be individually listed on the label from 26 to over 80. The applicable thresholds are: concentrations exceeding 0.001% in leave-on products or 0.01% in rinse-off products must be individually disclosed in the ingredient list. New products must comply by July 31, 2026, and the final transition deadline for existing products is July 31, 2028.

This expansion adds a massive number of fragrance ingredients, including Limonene, Linalool, Citronellol, Eugenol, and Geraniol, marking a significant step forward by the EU in ingredient transparency, aimed at protecting fragrance-sensitive populations and helping all consumers make more informed choices.

The practical formulation significance of this change is: fragrance bases that could previously be vaguely labeled as "Parfum" now need to be precisely analyzed to confirm whether every single component exceeds the new declaration thresholds. Many fragrance bases previously considered compliant now require re-evaluation.

III. The Hidden Hazard in Perfumery: The Sensitization Mechanism of Oxidized Terpenes

Before discussing the common consumer perception that "natural fragrances are gentler and synthetic fragrances are more irritating," a crucial scientific fact must be clarified—because it overturns this intuitive judgment.

Linalool and Limonene are typical "Prehaptens"—these ingredients themselves have very low or no sensitizing potential. However, after oxidation in the air, their oxidation products, "Hydroperoxides," exhibit significantly enhanced sensitizing power.

A retrospective study covering 5,773 patients from 2013 to 2020 showed that the contact allergy rate to oxidized linalool was 7.0%, and to oxidized limonene was 5.1%; approximately 95% of allergy cases were identified on days 3 to 4 of patch testing, and patients with positive reactions tended to be younger and predominantly female.

The formulation implications of this finding are profound:

• Essential oils rich in linalool (e.g., Lavender, Bergamot, Geranium)—linalool accounts for about 35% in lavender oil—if oxidized during product storage, their safety will drop significantly.

• Essential oils rich in limonene (e.g., Lemon, Sweet Orange, Grapefruit)—limonene is the main component of citrus oils—similarly face the risk of oxidizing into highly sensitizing hydroperoxides.

• "Natural fragrance" does not equal "low risk"—the speed of oxidation, storage conditions, and usage concentration determine the level of sensitization risk far more than the "natural/synthetic" origin distinction.

Since the oxidation process can be avoided or at least delayed by adding antioxidants, antioxidant protectants are being increasingly widely applied in the fragrance industry—but at the same time, it is necessary to closely monitor whether the antioxidants themselves (such as the commonly used BHT) trigger additional allergy risks.

IV. Perfumery Architecture Analysis: The Three-Layer Structure of Makeup Remover Scents

For brand owners, understanding the structural layers of a fragrance helps in proposing more precise demands when communicating with factories or fragrance suppliers.

A complete fragrance architecture is usually composed of three layers of notes—Top Note, Heart Note, and Base Note. In rinse-off products like makeup removers, the perceptual weight distribution of these three layers differs from leave-on products:

Note Layer	Perceptual Characteristics in Makeup Removers	Common Fragrance Ingredients	Allergen Risk Level
Top Note	Smelled immediately upon opening, evaporates fast, determines the "first impression"	Citrus terpenes (Lemon, Orange, Bergamot), Mint	⚠️ Medium-High (High Limonene/Linalool content)
Heart Note	Perceived during use, constitutes the scent theme	Rose, Jasmine, Lily of the Valley, Cucumber	⚠️ Medium (Eugenol, Geraniol, etc.)
Base Note	Evaporates slowly, the scent impression left on the skin	Musk, Cedar, Patchouli, Vanilla	Synthetic musks have partial restrictions

For "rinse-off products" like makeup removers, because the product stays on the skin for a short time (usually tens of seconds to a few minutes), the actual skin contact amount of the base notes is lower than in leave-on products—this is the technical basis for makeup removers having a relatively relaxed space in fragrance dosage. However, this does not mean they can be added arbitrarily, because:

• Once the dosage of citrus terpenes in the top notes is too high, it will still trigger mandatory label declarations in the EU market.

• Consumers inevitably contact the periorbital area during use, and the eye mucosa is more sensitive to certain fragrance ingredients.

• China's NMPA has usage restrictions on certain fragrance ingredients; products entering the Chinese market must be verified separately.

V. The Red List of High-Risk Fragrance Ingredients: These Require Special Prudence

The following fragrance ingredients belong to the "high-risk" or "requires precise dosage control" categories in makeup remover formulations. Brand owners should proactively ask whether they are used and at what dosages when communicating formulation needs:

① Prehaptens for Linalool Hydroperoxides: Linalool

• Natural essential oils containing linalool: Lavender (35%), Bergamot (30%–40%), Geranium (7%), Neroli (34%), etc.

• Risk: The base form is low-sensitizing, but its oxidation product, hydroperoxides, is a newly added mandatory declared allergen in the EU. The formula must be paired with antioxidants (e.g., α-tocopherol) to delay oxidation, and raw material suppliers must be ensured to provide antioxidant-treated specifications.

② Prehaptens for Limonene Hydroperoxides: Limonene

• Typical raw materials containing limonene: Lemon essential oil (~65%), Sweet Orange essential oil (~95%), Grapefruit essential oil (~92%), etc.

• Limonene and limonene-containing natural products can only be used as fragrance raw materials when the level of organic hydroperoxides is below 20 mmol/L (or 10 mEq/L).

③ Ingredients Banned or Restricted by the EU: Oakmoss / Treemoss Extracts

• Contains the main allergens Atranol and Chloroatranol. The EU has banned their use in cosmetics. Any formula themed around a "mossy" scent must use alternative synthetic moss molecules, not natural oakmoss/treemoss extracts.

④ Cinnamal and Cinnamyl Alcohol

• Repeatedly confirmed as common sensitizers for contact dermatitis, they are core members of the EU's original 26 mandatory declared allergens. Their use in makeup removers requires strict dosage control, weighing the potential risks for sensitive skin consumers.

⑤ Eugenol

• The main component in clove essential oil, explicitly recorded in the EU 2023/1545 new declaration list. It must be confirmed whether its content exceeds the declaration threshold (Leave-on: 0.001%; Rinse-off: 0.01%).

VI. The Marketing Trap of "Natural Fragrance": Truths Brand Owners Need to Know

With the rise of Clean Beauty, "Natural Fragrance" has become the scent claim direction for more and more brands. However, brand owners must clearly understand the following points:

① "Natural Fragrance" Has No Unified Legal Definition in the US

"Natural fragrance" is a marketing term with no strict legal definition in US cosmetic regulations. It usually refers to a fragrance mixture composed mainly of essential oils or natural isolates—it describes the raw material source, not a guarantee of low irritation, nor does it equate to complete ingredient disclosure.

② Natural Essential Oils Do Not Equal Low Allergen Content

Taking lavender essential oil as an example: at a 1% usage rate of lavender oil, the content of Linalool in the finished product is about 0.35%—this concentration is 350 times the EU declaration threshold of 0.001%. Even natural essential oils at relatively low usage rates can trigger mandatory label declaration obligations.

③ The Correct Cognition Is: Origin Does Not Determine Risk; Dosage and Oxidation State Are Key

The active fragrance molecules in natural essential oils face the exact same EU regulatory requirements as synthetic fragrance molecules; at the same sensitizing ingredient content, natural sources do not enjoy any regulatory exemptions.

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Conclusion: Fragrance is an Art, but Also a Formulation Science Requiring Precise Calculation

An aromatic makeup remover that consumers fall in love with never has its perfumery work done by simply "adding a bottle of fragrance." It requires systematic judgment and trade-offs across four dimensions simultaneously: sensory attractiveness, skin safety, allergen compliance, and shelf stability.

Under the deadline node of the 2026 EU fragrance declaration new regulations, every formulation decision brand owners make starting now will directly affect the product's ability to compliantly launch in international markets. Choosing an OEM/ODM factory with fragrance compliance review capabilities is the most direct path to avoiding this risk.