On 31 July 2026, a new European Union regulatory requirement affecting the majority of cosmetic products will become applicable. By this date, beauty brands placing products on the EU market must ensure that their labels include – where applicable – the disclosure of 56 additional fragrance allergens in the ingredient list.
Through this amendment to the EU Cosmetics Regulation, the total list has expanded from 26 to 82 allergens.
Failure to comply may result in products being held at customs or refused entry to the EU market.
What are fragrance allergens, and which ingredients may contain them?
Fragrance allergens are chemical substances present in fragrance ingredients that can trigger contact allergies in humans, particularly after repeated exposure through cosmetic use. These allergic reactions may manifest in various forms, including eczema and skin irritation.
Fragrance allergens can be found in both synthetic and natural ingredients. This means that not only synthetic perfumes, but also natural extracts and essential oils may contain such allergens.
How do I know if my products are affected?
All cosmetic products containing fragrance ingredients – e.g., perfumes, essential oils, or even natural extracts – may be affected.
What actions should brands take to ensure compliance?
Beauty brands should take the following steps:
· Contact your fragrance suppliers to obtain updated documentation
· Update the ingredient list on product labels if any of the regulated fragrance allergens exceed the thresholds established in Annex III
· Update the Cosmetic Product Safety Report (CPSR) if older than 3 years
· Update the CPNP notification
What constitutes “placing on the market”?
A product is considered to be placed on the market when it is made available for the first time on the EU market. Under EU harmonisation legislation, each individual product unit can only be placed on the market once.
This means that even if a product is already available in the EU, a new batch entering customs is still considered a new placement on the market. Therefore, all batches entering the EU for the first time after the deadline must comply with the new labelling requirements.
Non-compliant products may be held at customs, returned, or destroyed.
Can Obelis test my product for the presence of all regulated fragrance allergens?
Obelis can assist you with allergen testing, including the detection and quantification of all 82 fragrance allergens regulated at EU level in your finished product.
This analysis helps identify which allergens are present and whether they exceed the applicable thresholds, making it easier to determine which substances must be declared in the ingredient list on the product label.
What should you do with non-compliant stock?
If you hold stock of non-compliant products that you intend to place on the EU market after the deadline, you should carefully assess your options.
For case-by-case assessment and tailored solutions, you may contact us for support.
References
European Commission. (2023). Commission Regulation (EU) 2023/1545 of 26 July 2023 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards labelling of fragrance allergens in cosmetic product. Retrieved on 27/07/2023.
European Commission. (2022). Opinion on Fragrance allergens in cosmetic products. Retrieved on 08/04/2026.
SCCS. (2011). Opinion on Fragrance allergens in cosmetic products. Retrieved on 08/04/2026.
Chiara Lai
Regulatory Intelligence & Innovation Department
10/04/2026
Leave a Reply