Fragrances in baby cosmetics — why “fragrance-free” isn’t the same as “unscented”
Why should children’s cosmetics be free of fragrance? The difference between fragrance-free and unscented, Annex III allergens and EU Regulation 1223/2009.
The baby and infant cosmetics aisle smells of lavender, chamomile and “gentle powder”. Manufacturers know that scent builds parents’ trust — it’s associated with cleanliness, naturalness and mildness. The problem is that, from the perspective of paediatric dermatology, every fragrance substance in a child’s cosmetic is an unnecessary risk. We explain why — and how to read labels so you really do protect your child’s skin.
Why is a child’s skin more sensitive to fragrance?
A newborn’s and infant’s skin differs from an adult’s in several key ways that directly affect the safety of cosmetics:
- Epidermal thickness — in a newborn it is 20–30% thinner than in an adult. The horny layer (stratum corneum) is thinner and contains fewer layers of corneocytes (10–15 vs 15–25 in an adult).
- Skin barrier — immature. The production of ceramides, cholesterol and free fatty acids (which form the “mortar” between corneocytes) only reaches maturity between the ages of 2 and 4.
- Surface-area-to-body-mass ratio — in an infant it is 2.5–3 times higher than in an adult. This means proportionally greater absorption of substances applied to the skin.
- Skin pH — in a newborn it is around 6.5–7.0 (4.5–5.5 in an adult). A higher pH means weaker defence against pathogens and a more permeable barrier.
- Immune system — immature and still “learning”. Early exposure to contact allergens can lead to lifelong sensitisation (allergy).
A study published in Pediatric Dermatology (Stamatas et al., 2010) confirmed that transepidermal absorption in infants is significantly higher than in adults — especially in the nappy area, where occlusion (closure under the nappy) further increases penetration.
Annex III fragrance allergens in children’s products
EU Regulation 1223/2009 does not ban the use of fragrance substances in cosmetics for children under 3 — but it imposes additional requirements on them. Article 19(1)(f) requires products intended for children under 3 to carry special warnings on the label.
In practice this means a manufacturer may add Parfum to a cream for an infant, provided it declares the Annex III allergens above the thresholds (0.001% leave-on, 0.01% rinse-off). And many manufacturers do.
An analysis carried out by the French magazine 60 Millions de Consommateurs (2020) found that, of 52 baby cosmetics tested that were available on the French market:
- 67% contained at least one fragrance substance declared on the INCI list.
- 42% contained 3 or more allergens from Annex III.
- The most common were: Linalool (38% of products), Limonene (35%), Citronellol (22%), Benzyl Alcohol (18%).
In its 2021 guidelines, the European Academy of Dermatology and Venereology (EADV) clearly recommends avoiding fragranced products in infants and young children, pointing to the rising frequency of contact allergy in the paediatric group.
“Fragrance-free” vs “unscented” — the crucial difference
This is one of the most common labelling traps that parents fall into:
Fragrance-free (free of fragrance substances)
This means the product contains no substances added to give it a scent. Neither “Parfum” nor “Fragrance” should appear on the INCI list. It’s the safest choice for a child’s skin.
Note: a “fragrance-free” product may have a natural smell coming from its raw materials (e.g. shea butter smells nutty, coconut oil smells of coconut). That is not a fragrance substance added on purpose.
Unscented
This is a far less restrictive term. “Unscented” only means the product has no perceptible smell — but it may contain fragrance substances used to mask the unpleasant smell of raw materials (a so-called masking fragrance). “Parfum” may still appear on the INCI list.
In practice, an “unscented” cream for an infant can contain the same fragrance allergens as a perfumed cream — just at a lower concentration, below the threshold of olfactory perception. For a child’s skin, that is still exposure to potential allergens.
How does this look in practice?
| Claim | Does it contain “Parfum” in the INCI? | Fragrance allergens? | Safety |
|---|---|---|---|
| Fragrance-free | NO | NO (deliberately added) | Highest |
| Unscented | POSSIBLY | POSSIBLE | Uncertain |
| Hypoallergenic | POSSIBLY | POSSIBLE | Not legally defined |
| Gentle scent | YES | YES | Low |
EU regulations — what does the law say?
Regulation (EC) No 1223/2009, in Article 19, sets out the requirements for the labelling of cosmetics intended for children under 3 years of age:
- Mandatory warnings — products must include special information about conditions of use.
- Safety assessment — the safety report (CPSR) must take into account the specifics of children’s skin.
- Allergen declaration — the same thresholds as for adults (0.001% leave-on), which many experts consider too high for the paediatric population.
In a 2023 opinion, the SCCS (Scientific Committee on Consumer Safety) suggested that the declaration thresholds for fragrance allergens should be lower for paediatric products — but the proposal has not yet been implemented in legislation.
Practical tips for parents
- Look for “fragrance-free”, not “unscented” — check the INCI list to make sure there really is no “Parfum”.
- Minimise the number of cosmetics — an infant doesn’t need a lotion, baby oil, cream, powder AND shampoo. The fewer products, the less exposure.
- Avoid “natural scents” from essential oils — lavender, chamomile and orange in a baby cream are still allergens (Linalool, Bisabolol, Limonene).
- Read the full INCI list — use the PurScore search engine to check the safety profile of every ingredient.
- Check for “Aqua” and “Parfum” — in a good baby cosmetic, “Parfum” should not appear at all.
You’ll find more on interpreting INCI lists in our guide to cosmetic labels.
Looking for safe cosmetics for your child? Enter the product name in the PurScore search engine — we’ll analyse the formula for fragrance substances, allergens and ingredients unsuitable for children’s skin.
FAQ
Not always. “Unscented” only means there is no perceptible smell, but the product may contain fragrance substances that mask the unpleasant smell of raw materials. Look for a “fragrance-free” claim and check that there is no “Parfum” entry on the INCI list.
Lavender oil contains 25–38% linalool and 25–45% linalyl acetate — both are allergens from the EU’s list of 26 substances that must be declared. An infant’s skin is 20–30% thinner than an adult’s and absorbs these substances more easily, which increases the risk of sensitisation.
Dermatologists and the EADV recommend avoiding fragrance substances in children’s cosmetics until at least the age of 3 — until the skin barrier matures. In children with atopic dermatitis or a predisposition to allergies, caution is advised for even longer.
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