Fragrance counts toward it
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The awkward arithmetic
A fragrance works by evaporating and reaching a nose. Many fragrance materials are therefore volatile organic compounds, and they count toward the content the regulation limits.
So the budget is shared
Whatever the limit is, the carrier and the fragrance spend from the same allowance. A heavier fragrance load leaves less room for alcohol, and a higher alcohol content leaves less room for fragrance.
Which pushes toward water plus solubiliser
If the fragrance has to be a meaningful percentage for the product to work at all, the carrier is where the saving has to come from.
Ask the fragrance house for the VOC content
They will know it, it is a routine question in this category, and it is far better than calculating from a safety data sheet. Ask before you commit to a scent rather than after.
Natural does not mean low
Essential oils are volatile organic compounds. A product formulated from naturals for marketing reasons can have a higher VOC content than one built on a synthetic blend.
And the regulation has a fragrance provision
59.203 contemplates fragrance being incorporated up to a combined level of 2 weight-percent in certain circumstances. Whether that provision reaches your product is a question to put to the text rather than to assume from the existence of the clause.
Design the product around the number
Decide the limit first, allocate the fragrance load you need for the product to work, and build the carrier from what is left. Doing it the other way round produces a product that smells right and cannot be sold.
Get the number in writing before you fall in love with a scent
Choosing a fragrance and then discovering its VOC contribution rules out the carrier you wanted is the common sequence, and reversing it costs nothing but a question asked earlier.