Your fragrance supplier confirmed compliance. That doesn't cover July 31.

Keywords: fragrance allergens EU 2026  ·  Regulation EU 2023/1545 cosmetics  ·  fragrance allergen labelling July 2026  ·  EU cosmetics compliance July 2026  ·  80 fragrance allergens cosmetics

Your fragrance supplier sent you an updated IFRA certificate. Your formulator confirmed the fragrance is compliant. You have documentation on file.

None of that is enough for July 31.

Regulation (EU) 2023/1545 does not require your fragrance to comply with IFRA standards. It requires your finished product label to individually declare every fragrance allergen present above a defined threshold. That obligation sits with you — not with your supplier, not with your formulator, and not with the IFRA certificate.

July 31 is seven weeks away. This article explains exactly what the regulation requires, why supplier compliance is a different question from product compliance, and what you need to do before the deadline.

What the regulation actually requires

Regulation (EU) 2023/1545, published in July 2023, amends Annex III of the EU Cosmetics Regulation. It expands the list of fragrance allergens that must be individually declared on the ingredient label from 26 to more than 80 substances. The deadline for new products placed on the EU market is 31 July 2026. Products already on the market before that date may remain available until 31 July 2028.

The declaration thresholds have not changed:

– Leave-on products: individual declaration required when concentration exceeds 0.001% in the finished product.

– Rinse-off products: individual declaration required when concentration exceeds 0.01% in the finished product.

When the threshold is met, the allergen must appear in the INCI ingredient list — individually named, not grouped under 'parfum' or 'aroma'. This applies regardless of whether the allergen is synthetic or naturally derived.

Why supplier compliance is not product compliance

This is the distinction most brands are not making clearly enough — and it is where the compliance gap actually sits.

IFRA certificates confirm that a fragrance compound meets the safety standards set by the International Fragrance Association. They are ingredient-level documentation. They tell you the fragrance is safe at defined use levels. They do not tell you whether individual allergens in that fragrance, at the concentration used in your specific formulation, exceed the EU labelling thresholds.

The calculation the regulation requires is at the finished product level: the concentration of each allergen in the fragrance compound, multiplied by the percentage of that compound in your finished formula. If the result exceeds 0.001% in a leave-on or 0.01% in a rinse-off, that allergen must appear on your label. Individually.

The natural formulation trap

The brands most likely to be caught by this requirement are not the ones using complex synthetic fragrance blends. They are the brands using essential oils, botanical extracts, and natural fragrance components — and presenting their products as fragrance-free, unscented, or clean.

Citral is present naturally in lemon, lemongrass, bergamot, and mint essential oils. Limonene is in virtually every citrus ingredient. Linalool is in lavender. Geraniol is in rose and geranium. Eugenol is in clove and cinnamon. None of these arrive through a named fragrance ingredient. All of them are on the expanded allergen list. All of them must be declared individually if they exceed the threshold in the finished product.

A brand whose face cream contains rose oil, bergamot oil, and lavender extract — and whose label currently reads 'fragrance-free' — may have three undeclared allergens above the threshold and a claim that is no longer sustainable.

The grouped allergen complication

Some allergens on the list are grouped. Citral, for example, includes Geranial and Neral as components. The declaration obligation applies to the combined concentration of all components of the group — not to each one individually. A product where neither Geranial nor Neral individually exceeds the threshold, but their combined concentration does, still requires a Citral declaration.

This is the kind of detail that does not appear in IFRA certificates. It requires a calculation at the formulation level, using the allergen composition data from the supplier.

The five steps before July 31

1. Request updated allergen declarations from every fragrance and botanical supplier

The starting point is supplier documentation — but the right documentation. Ask every supplier of fragrance compounds, essential oils, botanical extracts, and hydrolates for an allergen declaration specifically referenced to Regulation (EU) 2023/1545. IFRA certificates are a starting point, not a substitute. The declaration must include the concentration of each of the 80+ regulated allergens in the supplied material.

2. Calculate finished product concentrations

With supplier data, calculate the concentration of each allergen in the finished product: allergen concentration in ingredient × percentage of that ingredient in the formula. Compare each result against the relevant threshold (0.001% leave-on, 0.01% rinse-off). Any allergen above the threshold must be declared.

Do not forget grouped allergens. Citral (= Geranial + Neral), and similar groups, require the sum of all components to be assessed against the threshold.

3. Update the INCI ingredient list and label

Any allergen exceeding the threshold must appear in the INCI ingredient list, individually named, in descending order of concentration. It cannot be grouped under 'parfum' or 'aroma'. If its INCI name has changed under the updated EU Glossary (Regulation (EU) 2025/1175, mandatory from 30 July 2026), the new name is the one that must appear.

Note that the INCI Glossary deadline (30 July) falls one day before the allergen deadline (31 July). Both apply simultaneously to any new product placed on the market from 31 July.

4. Review claims

If your product carries a claim such as 'hypoallergenic', 'fragrance-free', 'for sensitive skin', or 'unscented', the allergen review may reveal that the claim is no longer sustainable. A product that must declare Citral, Limonene, and Linalool on its label cannot credibly claim to be fragrance-free. Claim review is part of the compliance process — not a separate step to address later.

5. Update the PIF and CPNP notification

Any change to the label requires updating the Product Information File. If the safety assessment does not cover the allergens now being declared, the CPSR may need revision. Any label change must also be reflected in the CPNP notification — the Responsible Person is legally obligated to keep the notification current.

The 2026 and 2028 deadlines — which one applies to you

The regulation establishes two dates that are frequently confused:

– 31 July 2026 — mandatory compliance for all new products placed on the EU market from that date. A new product that does not meet the expanded allergen labelling requirements cannot be placed on the EU market after July 31.

– 31 July 2028 — end of sell-through period. Products already on the EU market before July 31, 2026 may continue to be sold until this date, provided they complied with the rules in force when they were placed on the market.

For a brand producing continuously — which is the majority of indie brands — the relevant date is 31 July 2026. Any new batch produced and placed on the market after that date must carry the updated label. The 2028 date applies only to existing stock already in circulation.

The coordination opportunity

July 31 does not arrive in isolation. The INCI Glossary update (Regulation (EU) 2025/1175) is mandatory from 30 July — one day earlier. Both obligations involve the same process: supplier documentation, INCI list review, label update, PIF revision, CPNP notification update.

A brand managing both separately runs the same process twice. A brand managing them together runs it once. Given that both have the same seven-week window, the choice is largely about planning — not resources.

At Cláritas Regulatory, we help independent brands complete their July allergen review — from supplier documentation to INCI list update, PIF revision, and CPNP notification. If you're not sure where your portfolio stands before July 31, get in touch.