EU Cosmetic Regulation for SMEs
The EU framework for placing cosmetics on the Union market centres on Regulation (EC) No 1223/2009 — Responsible Person, CPNP, safety file, labeling, and annex-driven ingredient rules.
Labeling
US MoCRA for SME cosmetic brands
MoCRA expanded FDA’s cosmetics authority: facility and product listing, safety substantiation, serious adverse event reporting, and a still-moving rulemaking calendar.
Japan cosmetics under the PMD Act
Japan splits cosmetics and quasi-drugs under the PMD Act. Cosmetics follow the Standards for Cosmetics; many “functional” claims push a product into quasi-drug approval.
ASEAN Cosmetic Directive for SME brands
The ASEAN Cosmetic Directive (ACD) is a common product standard. You still notify in each Member State. Annex updates often track the EU with a lag.
2026 Q3 desk: GB 7916, No. 70, allergen cut, Illinois
The August desk: China rewrote the standard stack and the filing portal; the EU allergen placing date landed; Illinois joined the US state grid.
“EU banned all fragrance allergens overnight” — debunked
2023/1545 is a labeling expansion with 2026/2028 dates. It is not a same-day ban on perfume.
EU fragrance allergen labeling: 31 July 2026 placing-on-the-market cut (Reg. 2023/1545)
From 31 July 2026, new EU placements must disclose the expanded Annex III fragrance allergens. Existing stock can sell through to 31 July 2028.
EU allergen cutover: how to split inventory so 2026 and 2028 do not get mixed
31 July 2026 is a placing-on-the-market date. 31 July 2028 is making-available. Warehouse logic has to know the difference.
EU Commission fragrance-allergen topic page: use it with 2023/1545, not instead of it
The Commission’s allergen topic page is context. The binding table is Annex III as amended by 2023/1545.
US professional-use cosmetics: MoCRA labeling expectations still apply
“Salon only” is not a MoCRA off-ramp. Adverse-event contact and other required statements still need a home on the pack or the mandated alternative.