Fragrance Allergens in Your Cosmetics: The Checklist to Run Before the 31 July 2026 Deadline

Keywords: fragrance allergen deadline July 2026 · Regulation (EU) 2023/1545 checklist · EU cosmetics allergen labelling 2026 · fragrance allergen threshold 0.001% · indie beauty brand compliance

Most indie beauty brands know that fragrance allergen labelling is changing. Fewer know the exact thresholds that trigger a declaration, which of their own products are affected, or what happens to stock already sitting in a warehouse. This article is the practical version.

Awareness of this deadline has been spreading well beyond the regulatory press, and consumer media coverage means customers and retailers may raise the question before your own compliance review is finished. Here is what is actually changing, who it affects, and what to check in your own formulations before the 31 July 2026 deadline applies.

What's actually changing

The relevant rule is Commission Regulation (EU) 2023/1545, which amends Annex III of the Cosmetic Products Regulation (EC) No 1223/2009. It adds 56 new fragrance allergens to the list of substances that must be individually declared on the ingredient list when present above a set threshold — on top of the allergens already required since 2003.

The thresholds themselves are not new: an allergen must be individually named on the label when its concentration exceeds 0.001% in leave-on products (creams, serums, perfumes) or 0.01% in rinse-off products (shampoos, shower gels, soaps). What is new is the list of substances that trigger this obligation — more than doubled in size.

From 31 July 2026, this expanded declaration requirement applies to any cosmetic product placed on the EU market for the first time. Products already on the market before that date benefit from a transitional period: they can continue to be sold under the old labelling until 31 July 2028. That transitional window is doing a lot of quiet work in brands' planning right now, and it is worth understanding properly before you decide what to do with existing stock.

Why the list is expanding

The expansion is not arbitrary. It follows an opinion from the Scientific Committee on Consumer Safety (SCCS), which reviewed clinical and epidemiological data on contact allergy linked to fragrance ingredients and concluded that a significantly longer list of substances met the criteria for mandatory individual declaration. The rationale is consumer protection — specifically for the share of the EU population that experiences some form of fragrance-related contact dermatitis — allowing people with known sensitivities to check an ingredient list and avoid a specific trigger, rather than avoiding fragranced products altogether.

For brands, the practical consequence is that the allergen review is not a one-off checklist exercise. It sits on the same scientific track as the SCCS opinions that periodically restrict or reclassify other cosmetic ingredients — which means this list can be expected to move again in future updates.

Which products are affected

There is no category exemption. If a product contains a fragrance — whether purchased as a finished fragrance compound, an essential oil, or a botanical extract — it needs to be checked against the updated list. In practice, this affects:

•       Perfumes, eaux de toilette and other fine fragrance products

•       Facial and body creams, serums and lotions with added fragrance

•       Shampoos, conditioners and shower gels

•       Soaps and hand washes

•       Deodorants and antiperspirants

•       Haircare products marketed as “lightly scented” or “unscented with natural fragrance”

That last category catches brands off guard most often. A product marketed as fragrance-free but formulated with a masking fragrance, or with essential oils used for a functional rather than aesthetic purpose, is still a fragranced product for the purposes of this regulation.

What you need to do before 31 July

The practical steps break down into three stages.

First, get the full allergen breakdown from your fragrance supplier — not a compliance statement. An email confirming the fragrance “complies with EU regulation” is not a declaration. You need the exact list of allergens present above threshold in your specific fragrance compound, at your specific dosage rate, referenced explicitly to Regulation (EU) 2023/1545.

Second, recalculate concentration at the product level, not the fragrance level. An allergen that sits below threshold within a fragrance oil in isolation can still cross the labelling threshold once diluted at your actual usage rate in the finished formula. This is the single most common gap we find at this stage of a review — and the one most likely to be missed by a supplier declaration written for the fragrance compound alone, not your finished product.

Third, update your documentation and your artwork in parallel. Your Product Information File needs to reflect the same allergen declaration as your label — a mismatch between the two is one of the first things an inspecting authority will flag. And because adding allergens changes the INCI list, it also changes your label layout. If revised artwork has not gone to your printer or converter yet, send it as early as possible — production and stock lead times do not stretch for regulatory deadlines.

Deciding what to do with existing stock

The transitional provision to 31 July 2028 is generous, but it only protects stock that was genuinely placed on the market — meaning already released for sale — before 31 July 2026, not stock sitting in your own warehouse awaiting a future launch. If you are holding inventory that has not yet reached a retailer or been made available to end consumers, waiting until closer to the deadline to place it on the market does not extend your protection; the safer reading is to treat 31 July as the date by which stock actually needs to be in market, not simply produced.

For stock that clearly qualifies for the transitional period, the decision becomes commercial rather than purely regulatory: is it worth relabelling now to standardise your whole range on the new declaration, or does it make more sense to sell through the existing stock under the old label and switch cleanly on the next production run? There is no single right answer — it depends on shelf life, rotation speed, and how much of your range needs relabelling anyway for the INCI glossary change landing the day before.

The assumption that gets brands in trouble

We keep seeing the same gap in practice. A brand receives an updated IFRA certificate, or a reassurance from their fragrance house that the formula “complies with EU regulation,” and treats the question as closed. Neither of those documents is a per-product allergen declaration. Regulation (EU) 2023/1545 requires you to know which allergens are present above threshold in your finished product — not in the fragrance compound considered on its own. That distinction is exactly where a fully compliant fragrance supplier and a non-compliant finished label can coexist without anyone noticing, until an inspection or a retailer audit brings it to light.

For brands working with a contract manufacturer or private-label partner, the same logic applies one step further back: do not assume the allergen declaration on your label has already been updated on your behalf. Ask directly, in writing, and get the documentation rather than a verbal confirmation.

Other deadlines landing around the same date

The fragrance allergen deadline does not arrive on its own. Three separate compliance obligations land within two weeks of each other:

• 30 July 2026 — the updated INCI Glossary of Common Ingredient Names becomes mandatory. Ingredient names on your label need to match the new nomenclature.

  
  

• 31 July 2026 — the fragrance allergen declaration requirement covered in this article takes effect for new products.

  
  

• 12 August 2026 — Regulation (EU) 2025/40 (PPWR) applies, requiring a signed Declaration of Conformity for every packaging format placed on the EU market.

  
  

If your product is fragranced, all three deadlines can affect the same piece of packaging artwork at the same time. Sequencing these checks — rather than treating them as three separate projects — is the difference between one label revision and three.

As the deadline approaches, the fastest path is usually a short, focused check against your own formulations rather than a rewrite of your whole compliance file. At Cláritas Regulatory, we help indie brands run exactly this kind of review. If you'd like a second pair of eyes on your allergen declarations before 31 July 2026, get in touch — we can usually turn around a review within days, not weeks.