Prepared for: Suppliers and Buyers of Cosmetic Products for the EU Market
URGENT REMINDER: The 31 July 2026 Deadline Is Approaching
From 31 July 2026, any new cosmetic product placed on the Union market must carry a label declaring the full expanded list of 81 fragrance allergens - a significant increase from the previous 26. If a new product is launched on or after that date, the old 26-allergen report format will no longer be accepted. This is not a distant regulatory change; it takes effect in just two weeks. For existing cosmetic products already made available on the Union market, a transitional period applies until 31 July 2028.
Background:
The expansion is driven by Commission Regulation (EU) 2023/1545, which amends the Cosmetics Regulation (EC) No 1223/2009. Following updated advice from the Scientific Committee on Consumer Safety (SCCS), the European Commission has added approximately 56 new fragrance allergens to Annex III, bringing the total number of individually declarable substances from 24 to 81. The declaration thresholds remain unchanged: The presence of the substance shall be indicated in the list of ingredients when it exceeds 0.001% (10 ppm) in leave-on products and 0.01% (100 ppm) in rinse-off products. The objective is to improve consumer protection by providing clearer information for individuals sensitised to specific fragrance allergens.
Timeline:
Today is 17 July 2026. The first major deadline is only two weeks away.
Product category | Deadline | Remark |
New cosmetic products placed on the Union market | 31 July 2026 | Must be fully compliant before placing on the market – no exceptions |
Existing cosmetic products already made available on the Union market | 31 July 2028 | May continue to be sold until this date; after which all products must comply |
Key point to understand: The transitional period applies only to products that were already on the market before 31 July 2026. It does not cover new batches manufactured or imported after that date - each new batch placed on the EU market constitutes a fresh placement and must carry the compliant label.
Immediate Action - Summary for new and existing products:
With the deadline fast approaching, we strongly recommend the following actions:
Action required | For new products (launching on / after 31 July 2026) | For existing products (already on market before 31 July 2026) |
Obtain updated 81 allergen report from fragrance house |
Immediate Do not accept old 26-allergen report anymore
| Start now Request reports early to avoid delays |
Update labels and artwork |
Urgent Review your new product portfolio and check the product labels and artwork are updated to include the new allergen information
Label changes can take weeks (artwork change triggers notification update) Prioritise this now
| Review and plan Schedule changes well before 2028 |
Update notification, CPSR and PIF |
Must complete and reflect the expanded allergen evaluation and notification before placing on market
| Complete well before the 2028 cut-off time |
For further information, the full text of Commission Regulation (EU) 2023/1545 is available on EUR-Lex. Should you require support with your regulatory documentation or allergen review, please do not hesitate to contact us.
Reference: EUR-Lex — 32023R1545