Cosmetics · Fragrance allergens
Fragrance allergens: are your cosmetic labels compliant?
Expanded fragrance allergen labelling requirements already affect new supplies of cosmetics. Companies should check label compliance separately from the conditions for continuing to sell products already placed on the market.
Status checked on 9 November 2026.
For cosmetics containing fragrances, reviewing the ingredients list involves more than checking the word “Parfum”. Regulation (EU) 2023/1545 expanded the requirements for individually listing fragrance allergens. Manufacturers and importers therefore need to establish whether they have enough information for each formula to prepare an accurate label.
Two deadlines, two different obligations
Regulation (EU) 2023/1545 provides two transitional periods: products meeting the previous requirements but not yet complying with the new ones could be placed on the market until 31 July 2026 and may be made available on the market until 31 July 2028. The Chemicals Office of the Republic of Slovenia also explains these conditions.
In November 2026, planning to update labels only in 2028 is therefore insufficient. Companies must distinguish products being placed on the EU market for the first time now from stock for which they can demonstrate that the transitional conditions are met. Manufacturing a batch or printing old packaging does not, on its own, establish the date of placing on the market.
What should you request from your fragrance supplier?
We recommend obtaining an up-to-date fragrance allergen declaration for the specific raw material. The document should allow you to calculate allergen concentrations in the finished product. If you use different fragrance versions or several suppliers, assess each version separately and record the document date.
A practical question for the supplier is whether the documentation covers the expanded Annex III requirements and any corrigenda to the Regulation. A declaration that was suitable for the previous list may provide insufficient information for a current review.
Review the complete formula
Allergens can enter a product through several raw materials. We therefore recommend including essential oils and other natural ingredients in the review, as well as purchased fragrance compositions. The calculation should reflect the total concentration of each substance under review in the finished product.
For the relevant Annex III entries, individual labelling is triggered above 0.001% in leave-on products and above 0.01% in rinse-off products. Apply the conditions and ingredient names specified in each entry; some entries group several substances together. Before designing the label, also check the published corrigendum.
How can you organise a portfolio review?
We recommend keeping a spreadsheet recording the product, formula version, fragrances used, date of supplier information, calculation result and label version. For older stock, add evidence of the date of placing on the market. This helps identify which supplies require immediate action and which may remain in distribution.
Involve the cosmetic product’s responsible person and safety assessor in the review. A label wording change and a formula change are different interventions; for each, consider the implications for documentation and notified information.
Support with reviewing labels
BiSafe helps review cosmetic product composition, labelling and documentation. Send the formula, draft label and current allergen declarations to info@bisafe.si. You can also explore our cosmetic product services.
