Fragrance allergens: what changes on EU cosmetic labels in 2026
Updated · By Justine Teruel
The short answer
Regulation (EU) 2023/1545 expands the list of fragrance allergens that must be labelled from 24 to more than 80 substances. Since 31 July 2026, any new cosmetic placed on the EU market must list them in the ingredient list above 0.001% (leave-on) or 0.01% (rinse-off). Products already on the market before that date can still be sold until 31 July 2028.
What the regulation says
Regulation 2023/1545 amends Annex III of the EU Cosmetics Regulation 1223/2009. It adds dozens of fragrance substances that must be named individually, including components of essential oils and natural extracts.
The thresholds stay the same: 0.001% in leave-on products (creams, serums, perfumes) and 0.01% in rinse-off products (shower gels, shampoos). Above that, the allergen must appear in the INCI list.
The two dates that matter
31 July 2026: a non-compliant product can no longer be placed on the EU market for the first time.
31 July 2028: a non-compliant product already on the market can no longer be made available (including stock held by retailers).
Why brands underestimate it
Many brands do not know the detailed composition of their fragrance or essential oils. Without an up-to-date allergen statement from your fragrance supplier covering the new Annex III list, you cannot know what must go on the label.
What this means in practice for a brand
- Ask your perfumer or essential-oil supplier for an allergen statement covering the new 2023/1545 list.
- Recalculate each allergen’s level in the finished product, not in the neat fragrance.
- Update the INCI list on your artwork before the next print run, and plan to sell through old stock before July 2028.
- Tell your Responsible Person and safety assessor: the PIF / CPSR must stay consistent with the label.
Get your label checked before print
I check the INCI list, declared allergens, mandatory mentions and claims on your real artwork, then send you ready-to-apply fixes.
See the Label & Claims Review — €390Frequently asked questions
My product is already on sale — do I need to reprint now?
No. A product placed on the market before 31 July 2026 can stay available until 31 July 2028. Any new product or new placing on the market after 31 July 2026 must comply.
Do essential oils count?
Yes. Allergens naturally present in an essential oil count just like those in a synthetic fragrance. This is often where the new mentions appear.
How do I know which allergens to list?
You need your supplier’s allergen statement, then calculate the concentration in the finished product and compare it with the 0.001% or 0.01% thresholds.
Is “parfum” in the INCI list enough?
No. “Parfum” stays, but every allergen above the threshold must be named separately.
Primary regulatory sources
Related guides
Regulatory consulting and documentation preparation — not a certification and not a regulated role. Bridge & Flow does not act as Responsible Person (Reg. 1223/2009), does not sign safety assessments, does not file notifications and is not a notified body.