EU Fragrance Allergen Labelling Changes in 2026: What Cosmetics Brands Should Check
The EU's expanded fragrance allergen rules affect labels and supplier data. Learn the 2026 transition, 2028 sell-through date and review workflow.
This guide summarises EU or GB requirements as understood in October 2026. For product-specific decisions, the appointed Responsible Person and qualified specialists must review the actual dossier.
What changed
Commission Regulation (EU) 2023/1545 expanded the list of fragrance allergens subject to individual declaration requirements in cosmetic ingredient lists. This affects more than perfume: fragranced skincare, haircare and makeup can also be relevant. Brands should review their fragrance supplier documentation and finished-product formula data rather than assuming that an old fragrance declaration remains adequate indefinitely.
The important dates
The regulation provides transition periods. For products that do not meet the updated provisions, the placing-on-the-market date reached 31 July 2026, while the extended period for making previously placed products available runs to 31 July 2028, subject to the legal wording and applicability of the transitional provisions. These dates do not mean every historic product can be sold forever without review. The position depends on when goods were placed on the market and whether the new rules apply to their composition.
What to request from a fragrance supplier
Ask for current allergen declarations suitable for the expanded EU requirements, along with identification of the exact fragrance concentrate used in each product. Where the disclosure is tied to a concentration or formula revision, reconcile that data with the brand's finished-product formulation and label version. Manufacturers and fragrance houses may have different naming conventions; unclear ingredient identity or percentages should be resolved through authorised professional channels.
A portfolio-level audit makes sense
For brands with dozens of fragranced SKUs, prepare a register identifying the fragrance supplier, formula version, perfume inclusion level, current label artwork, market status and likely exposure route. Group products by common source materials where legitimately possible, but do not assume a shared fragrance code proves that every product has identical labelling requirements. Have a qualified reviewer determine which changes are needed.
Make the work part of the launch calendar
A label review is more useful when tied to printing deadlines, remaining stock, distribution and update commitments. Get revised artwork signed off before the next packaging order and track which products are already on shelves. A managed coordination service can handle supplier correspondence and the change register while the professional interpretation is handled by the appointed qualified advisers.
Official sources
Regulatory guidance evolves. Follow the links below to check for subsequent updates.
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