EU fragrance allergen labeling: 31 July 2026 placing-on-the-market cut (Reg. 2023/1545)
Original source
Regulation / actCommission Regulation (EU) 2023/1545 of 26 July 2023 amending Regulation (EC) No 1223/2009 as regards labelling of fragrance allergens in cosmetic products
Regulatory Details
Official source. Regulation (EU) 2023/1545
Key points
- Amends Annex III of Regulation (EC) No 1223/2009 for fragrance allergen disclosure.
- Adds a large set of substances (commonly described as 56 new entries / ~80-allergen regime — confirm the annex table, not a social post).
- Thresholds remain 0.001% leave-on and 0.01% rinse-off unless the annex says otherwise.
- Placing on the market: 31 July 2026. Making available: 31 July 2028.
- Great Britain is not automatically aligned — do not copy EU artwork to GB without a UK check.
Dates. OJ 26 July 2023. Placement cut 31 July 2026. Off-shelf 31 July 2028.
Verify in the official text. Exact Annex III entries, grouping names, and any corrigenda after 2023.
Open questions. Confirm any transitional stock rules and whether your exact INCI / product type is named. This desk brief is a prioritisation aid, not a legal determination.
What changed: Expanded individual allergen labeling becomes mandatory for new EU placements on 31 July 2026.
Who is affected: EU Responsible Persons, fragrance houses, and any SME placing leave-on or rinse-off products after the cut date.
Suggested next steps: 1. Split inventory into “placed before / after 31 July 2026”. 2. Collect allergen breakdowns for post-cut placements. 3. Book artwork slots; 2028 is only for already-placed stock.
Business Impact
Regulation (EU) 2023/1545 expands individual labeling of fragrance allergens in Annex III. The first hard date for new placements is 31 July 2026; sell-through of already-placed stock runs to 31 July 2028.
Any SME still shipping into the EU with 2024 artwork should treat this as a packaging project this month, not a 2028 problem.
Risk is high for fragrance-heavy and leave-on SKUs because 0.001% (leave-on) / 0.01% (rinse-off) thresholds catch a lot of “just parfum” formulas.
This week: freeze a list of SKUs that will be placed after 31 July 2026 and send their perfume houses a written allergen breakdown against the expanded list.
Official text
Official English extract from Regulation (EU) 2023/1545. The full OJ text and Annex III table prevail.
Commission Regulation (EU) 2023/1545 of 26 July 2023 amends Regulation (EC) No 1223/2009 as regards labelling of fragrance allergens in cosmetic products.
Article 2 (transitional provision) provides that cosmetic products containing the substances concerned which do not comply with the restrictions may be placed on the Union market until 31 July 2026 and made available on the Union market until 31 July 2028.
Individual labelling of the fragrance allergens listed in Annex III applies where the substance is present above the concentration laid down in that annex (commonly 0.001% in leave-on products and 0.01% in rinse-off products, unless the annex entry provides otherwise).