The EU has expanded the list of fragrance allergens that must be declared individually on cosmetic product labels.
Under Commission Regulation (EU) 2023/1545, the number of fragrance allergens requiring individual declaration has increased significantly. Previously, cosmetic labels only needed to declare the well-known fragrance allergens when present above the legal threshold. The new regulation adds many more fragrance allergens, including individual fragrance molecules and some natural extracts/essential oils.
This applies to both synthetic fragrances and natural aromatic materials such as essential oils, absolutes, extracts and aromatic blends.
Fragrance allergens must be listed individually in the ingredients list when they are present above these levels in the finished cosmetic product:
Leave-on products: above 0.001%
Rinse-off products: above 0.01%
This means that a fragrance allergen may be present inside a perfume blend or essential oil, but it only needs to be declared separately on the cosmetic label if it exceeds the relevant threshold in the final product.
From 31 July 2026, all new cosmetic products placed on the EU market must comply with the expanded fragrance allergen labelling requirements.
Products already placed on the EU market before this date may continue to be made available until 31 July 2028, giving brands time to sell through existing compliant stock under the transition period.
If your cosmetic product contains fragrance, perfume, essential oils, natural aromatic extracts or flavour/aroma materials, you must request an updated allergen declaration from your supplier.
The old allergen declaration may no longer be sufficient, because many suppliers previously only declared the older list of fragrance allergens. You should now request documentation that covers the expanded EU allergen list under Regulation (EU) 2023/1545.
You may need to update:
If a facial oil contains lavender essential oil, the label should not simply list:
Lavandula Angustifolia Oil
The responsible person must also check the updated allergen declaration for that essential oil. If any regulated fragrance allergens are present above 0.001% in the finished leave-on product, those allergens must also be listed individually in the ingredients list.
For example:
Lavandula Angustifolia Oil, Linalool, Limonene, Geraniol
The exact allergens listed will depend on the supplier’s allergen declaration and the final percentage of the essential oil used in the product.
“Natural” does not mean allergen-free. Essential oils and natural fragrance materials often contain naturally occurring fragrance allergens. These allergens may still need to be declared on the cosmetic label if they exceed the legal threshold in the finished product.
Before printing labels or launching a cosmetic product, always ask your fragrance or essential oil supplier for:
This ensures the cosmetic label is accurate and compliant with the latest EU requirements.
The core legal basis is Commission Regulation (EU) 2023/1545, with the main deadlines of 31 July 2026 for new products and 31 July 2028 for existing products already on the EU market. (EUR-Lex)