A single fragrance composition can contain dozens, sometimes even hundreds of individual ingredients. Until you have to work out which of them belongs on a cosmetic label, that is probably little more than an interesting fact.
For beauty brands in the EU, it became a much more practical concern on 31 July 2026. Under Commission Regulation (EU) 2023/1545, 56 additional fragrance allergens became subject to individual labelling requirements.
This change has sent companies back to their formulations, ingredient information and labels. But before delving into the thresholds, there is one important false impression to clear up: fragrance allergens are not only found in perfume.
Fragrance Allergens Are Not Always Synthetic
Fragrance ingredients are found in far more than just perfume. They can be found in deodorants, shampoos, shower gels and plenty of other products sitting in your average bathroom cabinet. And they don’t all start in a laboratory.
That last point can probably cause confusion. A product described as ”natural” is not automatically free from fragrance allergens.
Take citral as an example. It is a regulated fragrance allergen, but it can also occur naturally in plant-derived ingredients such as essential oils. So, a cosmetic made with naturally derived ingredients isn’t necessarily free from fragrance allergens, and ”natural” doesn’t give it a regulatory pass.
From a regulatory perspective, where the allergen came from is not the deciding factor. Whether it arrived through a synthetic fragrance mixture or an essential oil, the same principle applies once a fragrance allergen exceeds the applicable concentration threshold, it needs to be declared on the label.
Two Very Small Numbers Determine What Goes on the Label
0.001% and 0.01%. These two tiny thresholds are important numbers to remember.
Not every trace of a fragrance allergen has to be individually declared. The concentration in the finished cosmetic product determines whether the declaration requirement is triggered.
For leave-on cosmetics such as creams, perfumes and lotions, the threshold is 0.001%. For rinse-off products, including shampoos, shower gels and cleansers, it is 0.01%.
Above the relevant threshold, the allergen must be included in the ingredient list using the appropriate designation established under Annex III of the EU Cosmetics Regulation.
What Does the 2026 Deadline Mean?
31 July 2026 marked the end of the first transition period. From that point on, products that do not meet the expanded fragrance allergen requirements can no longer be placed on the EU market.
This does not mean that older products suddenly have to disappear from the shelves. Products that have been placed on the market before the deadline have until 31 July 2028 to make their way through the market, giving businesses two more years to manage their existing stock.
The Label Is the Last Step
For consumers, the most visible change may simply be a longer ingredient list. For cosmetic brands, the work starts much earlier.
Before an allergen makes its way onto the label, someone needs to know it is there, work out how much of it is present and determine whether it crosses the relevant threshold. Only then does the artwork come into the picture.
This is why tackling fragrance allergen compliance is difficult to treat as a simple labelling exercise. It connects the formulation, regulatory assessment, up until the last stage of the words being printed on the package.
For brands working through that process, Obelis can support the review of formulations, product documentation and labelling against the updated EU requirements. In the end, a few extra words on the label can involve a surprising amount of work.
Are you currently working through these changes now? What bumps have you hit along the way?
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 products. Retrieved on 09/09/2026.
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