The 2026 New Fragrance Allergen Labelling Rules: What Every Formulator (and Soap Maker) Needs to Do
INTRODUCTION
Today, I'd like to talk about the new fragrance allergen rules that will come into effect shortly.
The short version? The EU has added to the list of fragrance allergens you have to name on a label, increasing it from 26 to around 82. That is an additional 56 allergens to consider. I know it sounds alarming, but bear with me, and I'll show you why it really isn't as bad as that number makes it look.
If you formulate with essential oils, this will probably affect you more than it does someone using a synthetic fragrance blend. It kind of feels backwards, don't you think?! But this change applies to all fragrances, natural or not.
Now, the good news. This change is mostly admin, not reformulating. You ask your suppliers for proper breakdowns, you run your numbers against the longer list, and you update your ingredient declarations before the deadline for your market. The formula stays as it is. It's the label that changes.
WHAT'S ACTUALLY CHANGED IN THE EU
This change is nothing new; we have known it was coming for a while now. The Scientific Committee on Consumer Safety (SCCS), the body that advises the EU on this, reviewed the evidence on fragrance contact allergy and recommended that more of the substances known to trigger it should be listed separately. The reason is the same for any kind of allergen, think peanuts, gluten and so on. If you've already become sensitised to something, you can only avoid it if you can see it on the label. The brands this hits hardest are the indie and natural ones, purely because they tend to use more botanical material.
The actual law, if you want to note it down, is Regulation (EU) 2023/1545, and it amends Annex III of the main EU Cosmetics Regulation, 1223/2009. It was published in July 2023 and came into force that August, with the deadlines phased so you're not left scrambling. Before this, 26 fragrance allergens had to appear on the ingredient list once they exceeded a set concentration. The amendment adds 56 more, some single substances and some groups, and that's how you get to the 82 entries you now check your formula against.
Some of those are single molecules, some are group names covering families of related substances, and a handful of essential oils and natural extracts are now named in their own right. Then, in late 2025, the Commission published a corrigendum, which just tidied a few things: it corrected three INCI names in the new entries (damascenone became Rose ketone-4), clarified the scope of one essential oil entry, and added a substance. The deadlines didn't change. So if you've already started a compliance list, check your INCI spellings against the corrected version before any of it goes to print.
THE TWO DEADLINES THAT MATTER, AND WHAT THEY MEAN
There are two dates here, and they do two different jobs.
The difference comes down to two phrases the regulations use: placing on the market and making available on the market. They're not the same thing.
Placing on the market is the first time a product is supplied into the EU, whether by you, the manufacturer, or an importer.
Making available is every sale after that, all the way down to the person who buys it off the shelf.
The date to plan around is 31 July 2026. From then on, anything you place on the EU or EEA market must carry the full updated allergen declaration. Up until that date, you can still place the old-style labels on the market, so that's your window to get the artwork sorted.
The second date, 31 July 2028, is your sell-through, and this is the one that's easy to misread. It is not a transition period that lets you carry on making non-compliant batches until then. It only covers stock you'd already placed on the market before 31 July 2026, the units already in the supply chain or on a shelf, and that stock can keep being sold until 2028. A new batch you make after July 2026 is freshly placed on the market, so it has to comply from the start.
In practice, treat 31 July 2026 as your real deadline. Anything you newly sell into the EU after that needs the updated label. The 2028 date is really just there so shops don't have to bin perfectly good old-label stock overnight. One more thing on who this catches: Northern Ireland still follows the EU Cosmetics Regulation under the Windsor Framework, so if you ship to NI, plan as though you're selling into the EU.
I'll be honest with you, I think this one's a little hard on the smaller maker. Because of the way placing on the market works, the moment you make a fresh batch after 31 July 2026, it needs the new label, even for a product you've sold happily for years. That's a new label and an amended CPSR each time, and since every brand is up against the same date, your Safety Assessor will be swamped with amendments all at once.
If this is the first you're hearing of it, you've effectively got about a month to get sorted, and that isn't long. So the sooner you pull your breakdowns together and get into your assessor's queue, the better off you'll be.
WHEN YOU ACTUALLY HAVE TO DECLARE AN ALLERGEN
The thresholds of allergen declaration haven't changed either. You list a listed allergen on your ingredient list when it's present at or above a set concentration in the finished product. This limit depends on whether the product remains on the skin or washes off.
So the maths is exactly what it always was.
A quick word for the soap makers, because this question always comes up: where soap is sold as a cosmetic, it follows the same rules as anything else. Soap is usually a rinse-off, so the 0.01% is your threshold. The only thing that's grown is the length of the list you run that calculation against.
| Product type | Declare the allergen above | In plain numbers |
|---|---|---|
| Leave-on (creams, balms, serums, lip products, perfume) | 0.001% of the finished product | 10 parts per million |
| Rinse-off (cleansers, shampoo, body wash, soap) | 0.01% of the finished product | 100 parts per million |
| Product type | Declare the allergen above | In plain numbers |
|---|---|---|
| Leave-on (creams, balms, serums, lip products, perfume) | 0.001% of the finished product | 10 parts per million |
| Rinse-off (cleansers, shampoo, body wash, soap) | 0.01% of the finished product | 100 parts per million |
Why natural formulators get caught out most
A good number of essential oils and natural extracts are now listed in Annex III in the Cosing database in their own right, and many of the newly listed allergens are already present in common oils.
Lavender, bergamot, lemon, neroli, peppermint, ylang ylang, geranium, sandalwood, clove and patchouli are all on the new list as named oils.
And things like carvone, menthol, the pinenes and the rose ketones are naturally present in oils you might never have thought of as "fragrance" at all.
What that means in practice is that an oil you've used happily for years can now push one or more named allergens over the threshold in your finished product.
But remember, that doesn't make the oil a problem, and it certainly doesn't make your formula unsafe. It just means the allergen has to be listed on your ingredient list, rather than tucked away under "parfum". Think of it as a checklist to work through, and remember your oil choices feed straight into what ends up on that label.
Before you panic at the number 82
Two things make 82 sound less scary.
You don't declare all 82, you check 82. You only ever name the allergens that are actually present above the threshold in your particular product.
Some of the entries are group names, so one name covers an entire family. This is intentional; the regulation groups related isomers under a single label name.
Rose Ketones covers a set of damascones and damascenone.
Pinene covers alpha and beta.
Citral covers its two isomers, geranial and neral.
Terpineol, Santalol, Menthol, Carvone, Camphor, and Limonene each cover their respective forms under a single name.
The essential oils work the same way, so you write the botanical INCI name ( for example: Lavandula Angustifolia Oil) once rather than listing out every fragrant constituent. What grouping does not let you do, though, is lump different oils together. If both bergamot and lemon are over the threshold, that's still two separate names on your label.
WHERE THE UK STANDS RIGHT NOW
As things stand in June 2026, Great Britain is still running on the original list of around 26 allergens. The expanded list hasn't been written into the UK Cosmetics Regulation yet, so strictly speaking, a GB-only product has no legal duty to name the 56 additions today. That's the legal position at the time of writing this post.
That said, change is clearly on the way. On 31 October 2025, the Office for Product Safety and Standards (OPSS) notified the World Trade Organisation of an amendment to the Annexes of the UK Cosmetics Regulation, and the draft was open for comment until 30 December 2025. Around the same time, the CTPA and IFRA UK issued joint guidance on placing on the market and making available, which is exactly the sort of groundwork you'd expect to see before a labelling change actually lands.
So here's what I'd do. If you sell into the EU or Northern Ireland, you're already on the EU clock, so work to 31 July 2026. If you're GB-only, there's no duty yet, but a UK version is coming, and getting ready now is sensible, since it's much cheaper to update your artwork once than to reprint it twice.
Keep an eye on OPSS for the confirmed GB timeline, and don't assume the UK dates will match the EU's. When the UK amendment is finalised, it'll bring its own deadlines, and they may or may not line up.
YOUR TO-DO LIST
Getting the paperwork together from suppliers does take a little time, so I suggest you start sooner rather than later.
Here's the order I'd work in.
1. Map your markets first. Write down where each product actually sells: GB, EU or EEA, Northern Ireland, anywhere else. That's what tells you which deadline applies to which product.
2. Get full breakdowns from your suppliers. Ask your fragrance and essential oil suppliers for an allergen declaration against the updated Annex III list of 82 entries, not the old 26. A good supplier will have these ready to send.
3. Run your numbers. Work out how much of each listed allergen ends up in your finished product, and compare it against the threshold, 0.001% for leave-on and 0.01% for rinse-off. Note down which ones go over, and keep that working on file. Use this free calculator I created just for this. I promise it will make your life easier.
4. Update your ingredient lists and PIFs. Add the newly required allergen names to your INCI declaration everywhere it appears: packaging, labels, your website, and any marketplace listings. Keep the wording identical across all of them.
5. Update your safety paperwork. Talk to your Safety Assessor about updating the relevant CPSR, carry the changes through to your Product Information File, and update your product notification (CPNP for the EU) where needed.
6. Plan your artwork around 31 July 2026 for your EU and NI lines, so the new label goes into your next print run instead of a rushed, expensive reprint.
7. Use the sell-through window sensibly. Old-label stock already on the market in the EU can be sold until 31 July 2028. So don't throw away compliant stock, but don't carry on printing old labels either.
8. For GB, get ready now and confirm later. Have your breakdowns and draft labels ready, then keep watching OPSS for the confirmed UK dates before committing to an actual GB reprint.
FAQ
Do I have to reformulate? Almost certainly not. These allergens are still permitted in cosmetics, so nothing has to be removed from your formula. You're just declaring the ones that go over the threshold.
My product is all-natural, only essential oils. Does this still apply to me? Yes, it does. Natural doesn't mean exempt. Many of the new allergens occur naturally in essential oils, so all-natural products are often the ones that get caught most often.
What if an allergen falls just under the threshold? Then you don't have to name it. Do keep your calculations on file, though, because if you tweak the formula or a supplier changes their profile, you can cross that line without realising.
I only sell in the UK. Can I ignore this? Not quite. There's no GB duty yet, but a UK change is expected, and the EU rules already affect you the moment you ship to the EU or Northern Ireland. Getting ready now will save you money later on.
Does this affect soap? It does, where soap is sold as a cosmetic, it follows the same rules as everything else. Soap is usually a rinse-off, so the 0.01% threshold applies to you.
So the whole thing really comes down to this. Get your supplier breakdowns together, check them against the longer list, and update your labels in good time. Do that, and the deadlines pretty much look after themselves.
And if you'd like to talk any of this through, or see how it plays out on a real label rather than in the abstract, that's exactly the sort of thing we work through together inside the Lab Notes Society. Come and ask.
References
- Regulation (EU) 2023/1545 amending Annex III of Regulation (EC) No 1223/2009, full text on EUR-Lex.
- Scientific Committee on Consumer Safety (SCCS), opinion on fragrance allergens in cosmetic products (the scientific basis for the expanded list).
- European Commission, fragrance allergens labelling guidance.
- Corrigendum to Regulation (EU) 2023/1545 (2025), correcting INCI names in the new Annex III entries.
- CTPA and IFRA UK, joint communication on placing on the market and making available for allergen labelling.
- Office for Product Safety and Standards (OPSS), notification to the World Trade Organisation of amendments to the UK Cosmetics Regulation, 31 October 2025.
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