From 31 July 2026, 56 additional fragrance allergens must be listed on the labels of cosmetic products placed on the EU market.

What does this mean for manufacturers, importers and industry professionals?

• Assess allergen concentrations.
• Update product labels.
• Update CPNP notifications.
• Review Cosmetic Product Safety Reports (CPSRs).                                                                        

The clock is ticking for cosmetics businesses operating in the European Union. The deadline of 31 July 2026 marks a milestone for the industry: from that date, every product placed on the EU market must list—where applicable—56 additional fragrance allergens on its label.

This requirement was introduced by Commission Regulation (EU) 2023/1545 and is expected to affect the majority of cosmetics manufacturers worldwide targeting the European market.

From 1999 to Today

As early as 1999, the EU Scientific Committee had identified 26 fragrance substances requiring mandatory disclosure on labels to help consumers with allergies avoid allergenic ingredients.

In 2011, new clinical studies identified additional substances with allergenic properties. Based on this scientific assessment, Regulation (EU) 2023/1545 added 56 new allergens, bringing the total to 82 substances now listed in Annex III to the Cosmetics Regulation.

What Are Fragrance Allergens?

There is a common misconception that fragrance allergens are found only in synthetic fragrances. This is incorrect.

Fragrance allergens are not limited to synthetic chemical compounds. They occur naturally in many botanical ingredients—essential oils, plant extracts and other naturally derived ingredients—which are subject to exactly the same labelling requirements. Formulations rich in essential oils or plant extracts require particular attention.

How Are Allergens Declared?

An allergen does not automatically have to appear on every label—only when its concentration in the finished product exceeds specific thresholds:

▸ Leave-on products, such as serums and creams:
Mandatory declaration if the concentration exceeds 0.001%.

▸ Rinse-off products, such as shampoos and shower gels:
Mandatory declaration if the concentration exceeds 0.01%.

Important: The concentration is calculated in the finished product, not in the individual fragrance blend. Analytical testing of the finished product is particularly recommended for verification.

What Documents Do You Need for Compliance?

In addition to standard documentation—raw material specifications, Safety Data Sheets and Certificates of Analysis—fragrance ingredients require specific supporting documentation:

1. IFRA Certificate
2. Allergen Declaration / Allergen List
3. Analytical Testing of the Finished Product

Compliance Checklist: 5 Steps for July 2026

1. Update Product Information Files (PIFs).
2. Assess allergen concentrations.
3. Update product labels.
4. Update CPNP notifications.
5. Review Cosmetic Product Safety Reports (CPSRs)

31 July 2026 is not far away. For businesses with extensive product ranges or complex formulations, the compliance process requires considerable time and coordination with suppliers, laboratories and qualified safety assessors.

For specific questions about the compliance of your products, contact us at info@laqem.gr.