New allergen labelling in perfumes and cosmetics: what changes from 2026

Why is allergen labelling changing in perfumes and cosmetics?

The labelling of fragrance allergens in cosmetic products has changed with the application of Regulation (EU) 2023/1545, which amends Regulation (EC) 1223/2009 on cosmetic products.

The main objective of this update is to provide clearer information to people who already know they are sensitive or allergic to certain substances present in fragrances. In perfumery and cosmetics, many aromatic raw materials may contain components that can cause contact allergic reactions in some people.

This means that, when certain allergens exceed the limits set by the regulation, they must be identified in the product ingredient list. This allows consumers to check the label and avoid ingredients to which they already know they are sensitive.

Until now, individual labelling applied to a smaller number of fragrance allergens. With the new regulation, the list is significantly expanded and requires labels, boxes, leaflets and other packaging materials to be reviewed.

Which products are affected by this update?

The amendment affects cosmetic products that contain fragrances. This may include perfumes, eaux de toilette, eaux de cologne, perfumed creams, gels, lotions, hair products, deodorants and other cosmetics with an aromatic composition.

It is important to distinguish cosmetic products from other aromatic products that are not applied to the body, such as certain air fresheners, reed diffusers or home fragrance products. Regulation (EU) 2023/1545 refers to the labelling of fragrance allergens in cosmetic products.

For body perfumes, the practical implication is clear: if a fragrance contains allergens subject to declaration and they exceed the established thresholds, the label must reflect the updated information. It is not enough to indicate only “parfum” or “aroma” when the regulation requires individual substances to be declared.

What exactly changes in the ingredient list?

In the ingredient list of a cosmetic product, fragrance compositions are usually declared with terms such as “parfum” or “aroma”. However, when certain fragrance allergens are present above the established limits, they must be added individually to that same ingredient list.

The main change is that the number of substances that may need to be declared is expanded. The previous regulation covered a more limited number of mandatory fragrance allergens. The new regulation adds new allergens and updates some existing entries.

In practice, this can make the INCI list of a perfume or cosmetic product longer than before. This does not necessarily mean that the formula has changed; it may simply mean that more information must now be declared on the label.

Some ingredient names are also harmonised and certain similar substances are grouped under common names to facilitate clearer and more consistent identification. This is especially relevant for manufacturers, distributors and brands operating in different European markets, as labels must be aligned with the names required by the regulation.

What thresholds determine whether an allergen must be declared?

The Regulation establishes two general thresholds for declaring these allergens in the ingredient list:

• For leave-on products, the allergen must be declared when its concentration exceeds 0.001%.
• For rinse-off products, the allergen must be declared when its concentration exceeds 0.01%.

This distinction exists because not all products have the same type of contact with the skin. A rinse-off product, such as a gel or shampoo, remains on the skin or hair for less time. A leave-on product, such as a perfume, cream or lotion, remains in contact with the user for longer.

In perfumery, this requires each product to be reviewed against its updated technical documentation. An old allergen list should not be copied, nor should a previous design be reused without checking that the information corresponds to the current version of the fragrance or cosmetic product.

What happens from 31 July 2026?

31 July 2026 is a key date. From that date, the period for placing cosmetic products on the market that do not comply with the new fragrance allergen declaration requirements ends.

This means that, from 1 August 2026, cosmetic products placed on the market must already comply with the new labelling requirements. In practical terms, any cosmetic product placed on the market from this date must use the updated allergen information.

For a shop, distributor or private label brand, this means reviewing labels, boxes or leaflets before approving new designs or preparing new orders. The allergen information must correspond to the current version of the product, not to old versions used before the regulatory change.

The most common mistake will be to think that the deadline runs until 2028 in all cases. It does not. The period until 2028 does not allow new products to continue being placed on the market with previous labelling. It is intended for products that had already been legally placed on the market before the relevant transition period ended.

What happens to products that were already on the market before that date?

The regulation provides for a transitional period until 31 July 2028 for certain products that had already been legally placed on the market before 31 July 2026.

This means that products with previous labelling may remain on the market until 31 July 2028, provided that they meet the conditions set out in the regulation and had been legally placed on the market before the end of the relevant transition period.

The key is to distinguish between two situations:

• Products already placed on the market before 31 July 2026 may benefit from the transitional period and remain in commercialisation until 31 July 2028, if the applicable conditions are met.
• Products placed on the market from 1 August 2026 must already comply with the new allergen declaration requirements.

This distinction directly affects stock management, replenishment and commercial documentation. The year 2028 should not be interpreted as a general extension to continue manufacturing, labelling or placing new products on the market with outdated information.

What should brands, distributors and shops review?

Companies that sell, distribute or work with perfumed cosmetic products should review their labelling materials. This includes adhesive labels, boxes, leaflets, product sheets, documentation accompanying the product and any material showing the ingredient list or allergen information.

The practical recommendation is to always work with the latest technical information provided for each product. If an updated allergen declaration exists, an earlier version should not be used.

Before validating new materials, it is advisable to check that the final design matches the current documentation. This is particularly important in private label projects, personalisation, packaging changes, supplier changes or material replenishment.

It is also advisable to maintain document traceability: version of the allergen list used, review date, batch or product reference and final approved file. This organisation reduces errors and helps respond to any internal review or later enquiry.

What mistakes should be avoided?

One of the most important mistakes is reusing old labels without checking the allergen list. Even if the design, bottle or commercial name has not changed, mandatory information may have changed due to the regulatory update.

Another common mistake is thinking that if the perfume keeps the same formula, the label does not need to be reviewed. The obligation may change even if the formula has not changed, because more substances may now be subject to individual declaration.

Mixing information from different versions of the same product should also be avoided. If a technical update has been received, that version should be the reference for new validations and new materials.

Finally, mandatory information should not be simplified or removed for space reasons. If the ingredient list expands, the material design must be adapted. Legibility and consumer information are part of labelling compliance.

How can you prepare in an organised way?

The simplest way to adapt is to work with a clear internal process.

First, identify which cosmetic products you have in stock.

Then, check whether updated allergen information is available for each reference.

Next, compare that information with the labels, boxes, leaflets and product sheets used so far.

If there are differences, the designs should be updated before the product is launched again.

It is also advisable to separate old materials from updated materials to avoid confusion in the warehouse, production or order preparation.

In private label projects, this review should be carried out before approving the final design. It is better to correct the design before producing materials than to have to remake labels, boxes or packaging already prepared.

What should the professional customer be clear about?

The change in allergen labelling should not be seen only as a legal obligation, but also as a transparency measure. The aim is to give consumers more information about ingredients that may be relevant for sensitised people.

For shops, distributors and brands, the key point is to always work with current documentation and not reuse old lists. From 31 July 2026, cosmetic products placed on the market must comply with the new allergen declaration requirements. Products that had already been legally placed on the market before that date may benefit from the transitional period until 31 July 2028, provided that the conditions are met.

In case of doubt, the most prudent approach is to review each product individually, confirm the updated version of the allergen information and adapt labelling materials before preparing new orders, replenishments or placing products on the market.

This content is for information purposes and does not replace a specific technical or regulatory review of each product.