The trade-secret loophole, explained
Federal law in the United States gives cleaning product manufacturers the right to list every fragrance compound under a single word on the ingredient label. The mechanism differs by product category, but the outcome is identical.
For personal-care products, the Federal Food, Drug, and Cosmetic Act (FFDCA) exempts fragrance formulas from full ingredient disclosure under trade-secret protection. For household cleaning products, the Toxic Substances Control Act (TSCA) provides a parallel shield. A candle and a multi-surface spray can sit side by side on a shelf with the same label word concealing entirely different chemistry.
The International Fragrance Association (IFRA) and its research arm RIFM set voluntary safety standards for member companies. A March 2025 review in Toxicological Research documented that this self-regulatory structure leaves significant gaps: the standards are set by the same industry the standards govern, third-party verification is limited, and mixtures can include sensitizers that fall below individual thresholds but trigger reactions in combination.
What research finds inside "Fragrance"
A 2025 analysis reviewed in PMC found that fragrance formulas in common consumer products can contain more than 100 distinct compounds. The categories that appear most consistently in research:
Phthalates as fixatives and solvents. DEHP and DBP are endocrine disruptors that interfere with hormone signaling. They have been detected in cleaning products at measurable levels in multiple studies, despite not appearing anywhere on the label.
Formaldehyde and formaldehyde-releasing preservatives. Certain compounds used to stabilize fragrance blends, including bronopol and quaternium-15, decompose to release formaldehyde over time. Formaldehyde is a known carcinogen and a respiratory irritant.
Volatile organic compounds (VOCs). Terpenes, synthetic musks, and aromatic aldehydes evaporate at room temperature and contribute to indoor air pollution. A sensitizing VOC at low concentrations can trigger contact dermatitis or airway irritation in people who develop a response over repeated exposures.
Sensitizers. Compounds including isoeugenol, cinnamal, and certain musks are classified as contact allergens by the European Scientific Committee on Consumer Safety. They prime the immune system on first exposure and cause reactions on subsequent contact. None of these compounds has to appear on the label.
Why "Natural Fragrance" is the same problem
The word "natural" has no regulatory definition in the context of cleaning products. A manufacturer can source fragrance compounds from plant-derived isolates and still blend them into a complex, undisclosed mixture the consumer cannot evaluate from the label.
The University of Cincinnati Law Review noted in a March 2024 article on clean-beauty regulation that courts have generally found terms like "natural" and "clean" too ambiguous to constitute actionable deception. The practical result: "natural fragrance" functions as a marketing claim with no legal substance, backed by the same trade-secret exemption as "fragrance."
Essential oils at high concentrations are not automatically benign. Limonene is a sensitizer that causes allergic contact dermatitis in a meaningful share of the population. Linalool, geraniol, and several other compounds found in common essential oil blends are classified as contact allergens in Europe. What matters is not whether the source was a plant, but whether the specific aroma compounds are named on the label.
The California law that is starting to shift things
In 2024, California's Fragrance and Flavor Right to Know Act began requiring manufacturers of consumer products sold in the state to disclose fragrance ingredients on product labels or manufacturer websites, phased in over several years based on chemical priority.
The California Air Resources Board (ARB) administers the regulation as part of its Consumer Products Program. The law targets compounds on the state's Priority Chemical list, which includes phthalates, formaldehyde releasers, and carcinogens.
What the law covers: a meaningful subset of high-concern chemicals that were previously hidden inside "Fragrance," for products sold in California.
What it still does not cover: the full composition of a fragrance formula. Compounds that do not appear on the Priority Chemical list remain trade-secret protected. A brand can technically comply with the California law and still conceal dozens of additional fragrance components. The law is a floor, not a ceiling.
The early effect on reformulation: several brands have begun proactively disclosing fuller ingredient lists in anticipation of enforcement, particularly in the cleaning and laundry categories. This is the same dynamic that drove wider reformulations after California's Proposition 65.
How to read the label
Signals that a formula is transparent:
Named essential oils or aroma compounds listed individually. "Lemon oil," "lavender essential oil," "limonene (from citrus)," or even "linalool" are named ingredients that can be looked up and screened against sensitizer lists.
"Fragrance-free" means no fragrance compounds were added, synthetic or natural. It is not the same as "unscented," which can mean fragrance compounds were added to mask the base smell of the formula. Fragrance-free is the correct term to look for.
Third-party certifications. EWG Verified requires full ingredient disclosure to EWG and prohibits compounds on its Red and Orange lists, which include the phthalates and formaldehyde releasers most commonly found inside "Fragrance." MADE SAFE similarly requires full disclosure and screens against a human health hazard list. Products carrying these marks have been reviewed at the formula level, not just the label level.
Red flags that remain:
"Fragrance," "Parfum," or "Natural Fragrance" on the ingredient list, without any further specification. These terms mean the composition is not disclosed.
"With essential oils" in marketing copy, if the ingredient list still reads "fragrance" or "natural fragrance." Marketing copy and ingredient lists are different documents; the ingredient list governs.
Certifications that do not require fragrance disclosure: USDA Organic (applies to agricultural ingredients, not finished-product chemistry), B Corp (governance and supply-chain certification, not ingredient-level), and "cruelty-free" (animal testing practices only).
The guides that apply this screen
The guides below cover the cleaning categories where synthetic fragrance is most concentrated in conventional products. Every pick has passed the disclosure gate described above.
- Best Organic Non-Toxic Cleaning Sprays
- Best Non-Toxic Glass and Window Cleaners
- Best Non-Toxic All-Purpose Cleaners
- Best Non-Toxic Floor Cleaners
- Non-Toxic Hand Soap for Every Sink in the House
FAQ
Does "fragrance-free" mean a product has no smell at all?
No. "Fragrance-free" means no fragrance compounds were added to the formula. Some cleaning products have a faint base odor from their active ingredients. Citric acid has a mild sour scent; certain plant-derived surfactants have a faint botanical character. The absence of fragrance compounds is what matters, not the complete absence of any odor.
Is "natural fragrance" safer than regular fragrance?
No. The term "natural fragrance" carries the same trade-secret exemption as "fragrance." A manufacturer can source compounds from plant-derived isolates and still blend them into an undisclosed mixture. Essential oils themselves contain sensitizing compounds such as limonene and linalool. The label obligations are identical to those for synthetic fragrance.
Does the California fragrance law apply outside California?
Technically it is a California requirement, but in practice it affects the national market. Most volume brands sell nationally, and reformulating or disclosing separately for one state adds significant compliance cost. The precedent from Prop 65 and California's VOC rules for consumer products is that California requirements often pull the whole product line toward compliance. As of 2026, there is no federal equivalent.
Which certifications actually verify fragrance disclosure?
EWG Verified and MADE SAFE both require full ingredient disclosure to the certifying body and prohibit compounds on their respective hazard lists, which include phthalates and formaldehyde releasers. USDA Organic, B Corp, GOTS, and "cruelty-free" marks do not screen cleaning-product fragrance formulas at the ingredient level.
Can I trust a product that says "scented with essential oils"?
Only if the specific essential oils and aroma compounds are listed by name on the ingredient list. If the ingredient list still reads "fragrance," "natural fragrance," or "essential oil blend," the composition is undisclosed regardless of the marketing copy. A named ingredient is one that can be looked up; a category term is not.
Cover image: Ron Lach via Pexels (Pexels License). Source.
