The EU's Expanded Fragrance Allergen List under Regulation (EU) 2023/1545: 56 New Substances and the 2026 Deadline

The EU has substantially expanded the list of fragrance allergens that must be individually declared on cosmetic labels from 24 substances to around 80 under Regulation (EU) 2023/1545. With a key compliance deadline of 31 July 2026, this is one of the most significant fragrance allergen labelling changes in years. This guide explains what changed, the deadlines, and what brands must do.

This change amends the annexes of the EU Cosmetics Regulation. Confirm current detail, including any corrections, for your specific products.

The background: fragrance allergen labelling

Certain fragrance substances can cause contact dermatitis skin reactions in sensitised individuals. To help these consumers avoid what affects them, the EU requires that specific fragrance allergens be named individually in the ingredient list when present above a defined threshold, rather than being hidden within the generic term 'parfum'. This individual labelling requirement is the mechanism at the heart of this change, and a core plank of consumer protection in this category.

Historically, 24 fragrance allergens had to be declared this way. But scientific assessment by the Scientific Committee on Consumer Safety identified many more substances that can cause allergic reactions and were not being individually labelled and Commission Regulation (EU) 2023/1545 addresses that gap by greatly expanding the list.

What changed: 56 new substances

Regulation (EU) 2023/1545 adds 56 additional new allergens to the list of substances requiring individual labelling, taking the total to around 80 (the exact count varies depending on how grouped entries are counted). These are substances the Scientific Committee on Consumer Safety identified as clearly capable of causing allergies in humans but which previously did not require individual declaration.

The amendment also updates existing entries aligning ingredient names with the latest glossary, refining CAS and EC numbers, and grouping related substances to make labelling clearer and more consistent. So the change is both an expansion of the list and a tidying of the existing entries.

The thresholds haven't changed

Importantly, the thresholds for when an allergen must be declared remain the same: 0.001% in leave-on products and 0.01% in rinse-off products. An allergen present above these levels must be named in the ingredient list. What has changed is the number of substances subject to this rule, not the levels that trigger it.

This means brands apply the familiar leave-on and rinse-off thresholds, but now to a much longer list of substances. The practical effect is that many products will have additional named allergens appearing on their product label, because more of the substances in their fragrances now require declaration.

The deadlines

There are two key dates. From 31 July 2026, cosmetic products placed on the EU market must comply with the new labelling meaning new products must carry the expanded allergen declarations. Products already on the market before that date have until 31 July 2028 to be sold through or brought into compliance during this transition period. So there is a placing-on-market deadline in mid-2026 and a sell-through period running to mid-2028.

The 31 July 2026 deadline is now imminent, making this an active compliance priority for brands selling in the EU. New products and new labelling from that date must reflect the expanded list. Given the work involved in identifying allergens and revising labels across a range, brands should be well advanced.

Why this is a big task

Expanding the expanded list sounds simple, but complying is a substantial exercise. Brands must determine, for every fragranced product, which of the ~80 allergens are present above the threshold which requires detailed allergen breakdown data from fragrance suppliers. Then the ingredient lists must be revised, and label artwork updated, across the whole range.

For a brand with many fragranced products, each using fragrances that may contain several of the newly-listed allergens, this is a significant data-gathering and relabelling project. It is precisely the kind of change that benefits from starting early and working systematically through the portfolio.

The UK position

This expansion is an EU measure. At the time of writing, Great Britain has not adopted the expanded list, so the GB requirement may differ though the industry widely expects the UK to move in a similar direction. Northern Ireland, following EU rules, is covered by the expansion. Brands selling across the EU and UK should track both positions.

This is a clear example of post-Brexit divergence in practice: a major EU labelling change that does not automatically apply in Great Britain. Brands should confirm the current GB position separately and be ready for the UK to follow with its own measure. Our UK vs EU guide covers this kind of divergence.

What brands need to do

The steps are: obtain updated allergen data for every fragrance and essential oil from suppliers; identify which of the expanded allergens exceed the threshold in each product; revise ingredient lists and label artwork to declare them; and update the Product Information File accordingly. For products sold in the EU, this must be reflected in new products from 31 July 2026, and your Responsible Person should sign off on the updated file.

Because this hinges on accurate allergen data and careful label revision across potentially many products, it is a task worth resourcing properly. Our allergen review service exists to work through exactly this calculating the declarable allergens for each product and getting the labelling right, and confirming your cosmetic product safety report remains accurate against the updated ingredient list.

A practical plan for a fragranced range

For a brand with many fragranced cosmetic products, complying with the expanded allergen list is best tackled as a structured project rather than product by product in isolation. The first step is to gather updated allergen breakdowns for every fragrance and essential oil used across the range, from suppliers this is the single biggest task and the one to start first, since it depends on third parties.

With that data in hand, the declarable allergens can be calculated for each product by applying the leave-on or rinse-off threshold, and the ingredient lists revised accordingly. Doing this systematically across the range rather than ad hoc avoids missing products and makes the relabelling manageable. Label artwork can then be updated in batches, and the PIFs updated to match maintaining consumer confidence in the brand's transparency.

Because the 31 July 2026 EU deadline for new products is now close, this is a task to be well into rather than beginning. Brands that have not yet gathered their allergen data should treat that as the immediate priority, since everything else depends on it. A systematic approach, started early, turns a daunting range-wide new requirement into an orderly project.

The expanded allergen list at a glance

Frequently asked questions

References: Commission Regulation (EU) 2023/1545 (EUR-Lex); Regulation (EC) No 1223/2009 Annex III; SCCS opinion on fragrance allergens. Verified July 2026; confirm current detail, including any corrigenda, before acting. General information only, not legal advice.