31 July 2026 is a hard legal deadline. After that date, any cosmetic product placed on the EU market must comply with the expanded fragrance allergen labelling requirements under Commission Regulation (EU) 2023/1545. That means 82 individually regulated allergens — not the 26 most brands have been working with for the past two decades.
If your Cosmetic Product Safety Report (CPSR) was written under the old framework, it is already out of date under current EU law. If your labels only declare the original 26 allergens, they may be non-compliant for new product batches placed on the market from 1 August 2026 onwards. If your documentation hasn’t been updated, your compliance may already be at risk under current EU law.
This guide explains exactly what changed, what your CPSR must now reflect, and how to work through the compliance process before the deadline hits.
What Is the Cosmetic Allergens EU Update and Why Does It Matter?
For years, EU allergen rules required labelling of 26 fragrance allergens under Regulation (EC) No 1223/2009. That list was built on early 2000s science.
The Scientific Committee on Consumer Safety (SCCS) reviewed hundreds of fragrance ingredients over the following years. The findings were hard to ignore; far more substances were triggering allergic reactions than the original 26 captured.
Commission Regulation (EU) 2023/1545 formally amended Annex III of Regulation (EC) No 1223/2009. It came into force as a direct update to the EU allergen rules that brands had operated under for years.
As a result, a completely revised EU fragrance allergens list 2026, and a compliance challenge that touches labels, safety reports, and supplier documentation simultaneously.
The EU Fragrance Allergens List 2026: From 26 to 80+ Substances
EU Fragrance Allergens: Old vs New Framework
| Category | Old EU Allergen Rules (Regulation (EC) No 1223/2009) | New EU Allergen Rules (Commission Regulation (EU) 2023/1545) |
| Number of regulated allergens | 26 fragrance allergens | 80+ fragrance allergens |
| Scientific basis | Early 2000s SCCS data | Updated SCCS scientific reviews |
| Scope | Limited fragrance-only compounds | Fragrance + oxidation products + natural isolates |
| Labeling requirement | Only 26 listed substances above threshold | Expanded list with stricter substance-specific thresholds |
| CPSR impact | Basic allergen reference in safety report | Full allergen quantification required in CPSR (Part A & B) |
| Product coverage | Traditional fragrance ingredients | Fragrance, essential oils, plant extracts, derivatives |
| Regulatory update | Regulation (EC) No 1223/2009 | Commission Regulation (EU) 2023/1545 |
What the EU 80 Allergen Rules Actually Cover
The old list under Regulation (EC) No 1223/2009 had 26 substances. The new EU 80 allergen rules don’t just add a handful of extras. They more than triple the number of substances requiring mandatory allergen labeling.
Here’s what the updated EU fragrance allergens list 2026 includes, across key categories:
Already listed, now with revised thresholds under EU allergen rules:
- Benzyl alcohol
- Cinnamal
- Eugenol
- Geraniol
- Linalool
- Citronellol
- Benzyl salicylate
- Farnesol
Newly added under the EU 80 allergen rules:
- Hydroperoxides of limonene
- Hydroperoxides of linalool
- Methyl heptine carbonate
- Isoeugenol derivatives
- Tree moss and lichen extracts (multiple compounds)
- Several terpene oxidation products
- A range of natural isolates and synthetic fragrance molecules
The full updated list sits in the revised Annex III of Regulation (EC) No 1223/2009. Your safety assessor should have the complete table, and your fragrance suppliers should be cross-referencing it against their materials right now.
Why the EU Fragrance Allergens List 2026 Is Longer Than Expected
Some of the newly added substances aren’t obvious fragrance ingredients. They’re breakdown products, what forms when certain terpenes oxidise over time. Others are natural extract components that weren’t individually flagged before.
This matters because “unscented” products aren’t automatically outside scope. Plant extracts, essential oils, and certain carrier ingredients can naturally contain compounds on the EU fragrance allergens list 2026. If those compounds sit above the threshold, allergen labeling is required, regardless of whether fragrance was deliberately added.
How Commission Regulation (EU) 2023/1545 Changes Allergen Labeling Thresholds
The Numbers That Trigger Mandatory Allergen Labeling
Under the updated EU allergen rules, the concentration thresholds that trigger mandatory allergen labeling vary by product type. And some newly added substances carry stricter limits than the original 26.
| Product Type | Threshold for Original 26 | Threshold Under EU 80 Allergen Rules |
| Leave-on products | 0.001% | 0.001% (some substances lower) |
| Rinse-off products | 0.01% | 0.01% (some substances lower) |
| Newly listed substances | N/A | Varies, check Annex III individually |
Commission Regulation (EU) 2023/1545 doesn’t apply a single blanket threshold. Each substance in the revised Annex III of Regulation (EC) No 1223/2009 needs checking individually. Some carry standard thresholds. Others are stricter.
This is exactly why allergen labeling updates can’t be done quickly. You need concentration data for every substance, per product, per formula.
Compliance Deadlines Under EU Law: What Commission Regulation (EU) 2023/1545 Sets
Commission Regulation (EU) 2023/1545 sets two hard deadlines under EU law:
31 July 2026: New products placed on the EU market must comply with the updated allergen labeling requirements. Any product launched after this date must reflect the full EU fragrance allergens list 2026.
31 July 2028: All products on the EU market must comply. Existing stock, legacy formulations, products already in circulation- everything falls under the EU 80 allergen rules by this date.
Two years sounds like a lot. It isn’t, especially if you have a large portfolio, complex supply chains, or products that need reformulation rather than just label updates.
Start the allergen audit now. The brands scrambling in mid-2028 will be the ones who treated 2026 as someone else’s problem
Which Products Are Most Affected by the EU 80 Allergen Rules?
Not every product carries the same risk level. But under the cosmetic allergens EU update, almost anything containing fragrance ingredients needs reviewing against the EU fragrance allergens list 2026.
| Product Category | Risk Level | Why |
| Leave-on moisturisers & serums | High | Prolonged skin contact, no rinse-off |
| Body lotions & oils | High | Large application area, leave-on |
| Facial creams & treatments | High | Sensitive facial skin, daily use |
| Baby & children’s products | High | Stricter scrutiny under EU law |
| Intimate hygiene products | High | Sensitive area, higher absorption risk |
| Parfums & eau de toilette | High | High fragrance concentration |
| Shampoos & conditioners | Medium | Rinse-off but direct scalp contact |
| Body washes & shower gels | Medium | Rinse-off, brief skin contact |
| Facial cleansers | Medium | Rinse-off, frequent daily use |
| “Fragrance-free” skincare | Check | Natural extracts may still trigger allergen labeling |
| “Unscented” formulas | Check | Masking agents may appear on EU fragrance allergens list 2026 |
One thing brands consistently miss: “fragrance-free” doesn’t mean allergen-free under EU allergen rules. Plant extracts, essential oils used for skin benefits, and certain emollients can naturally contain substances from the updated EU fragrance allergens list 2026. If they’re above threshold, allergen labeling is required. Full stop.
Fragrance Allergens CPSR: What Regulation (EC) No 1223/2009 Now Requires
This is the part most guides skip over. Allergen labeling gets the attention. But the fragrance allergens CPSR impact is just as significant, and honestly more complex.
What the Fragrance Allergens CPSR Update Requires in Part A
Part A of your CPSR covers safety information. Under the cosmetic allergens EU update, it now needs to include:
- Quantitative composition of all fragrance allergens present in the finished product
- Calculated concentrations of each allergen against the new thresholds under EU 80 allergen rules
- Safety data for each newly listed substance present above threshold
- Updated exposure assessment where allergen concentrations have changed, or new substances have been identified
If your current CPSR was built under the old 26-allergen framework, it won’t cover the newly listed substances. That’s a compliance gap, not a minor oversight.
What the Fragrance Allergens CPSR Update Requires in Part B
Part B is where the safety assessor concludes. Under the updated EU allergen rules, Part B must:
- Reference the revised Annex III of Regulation (EC) No 1223/2009 explicitly
- Address any allergens newly triggered by Commission Regulation (EU) 2023/1545
- Include risk characterisation for sensitisation based on current SCCS opinions
- Confirm the product is safe when used as intended, with the full EU fragrance allergens list 2026 considered
A CPSR that doesn’t reflect the cosmetic allergens EU update isn’t legally sufficient.
EU vs UK Allergen Rules: Are They the Same?
Short answer: they are heading the same way, but they are not the same yet.
| Factor | EU Position | UK Position |
| Governing regulation | Commission Regulation (EU) 2023/1545 amending Regulation (EC) No 1223/2009 | UK Cosmetic Regulation (retained EU law at Brexit) |
| Number of allergens required | 80+ under EU 80 allergen rules | Currently 26 (original list) |
| Deadline for new products | 31 July 2026 | No confirmed date yet |
| Deadline for all products | 31 July 2028 | No confirmed date yet |
| SCCS opinions referenced? | Yes, mandatory basis | Yes, referenced voluntarily |
| Alignment expected? | N/A, already in force | Yes, OPSS signalling future alignment |
| CPSR requirements | Fragrance allergens CPSR must reflect full updated list | Current CPSRs still reference 26-allergen framework |
Here’s the practical reality. If you sell in both markets, building to the EU standard now is the only sensible move. Writing your fragrance allergens CPSR to cover 80+ substances costs the same effort as writing it for 26. And when the UK does align with EU allergen rules, which most regulatory experts expect, you won’t need to redo everything.
Don’t run two parallel compliance tracks. Build one strong CPSR that satisfies EU law and covers the UK by default.
How to Audit Cosmetic Products for Compliance
This is the part most brands find overwhelming. The EU fragrance allergens list 2026 is longer, the thresholds are more complex, and supplier conversations take time. But there’s a clear process to follow.
Step 1: Map Every Fragrance Ingredient Across Your Portfolio
Start with a complete list of every product you sell. For each one, identify all intentional fragrance ingredients, any raw materials that could naturally contain fragrance allergens, and the supplier and grade of each ingredient. You need this map before anything else can happen.
Step 2: Request Updated Safety Data from Suppliers
This is where things slow down, so start early. Contact your fragrance and raw material suppliers and ask specifically for full allergen declarations aligned with Commission Regulation (EU) 2023/1545, concentration data for each substance on the EU fragrance allergens list 2026, and updated Safety Data Sheets referencing the revised EU allergen rules.
Step 3: Calculate Allergen Levels in the Finished Product
Take the allergen concentration in the raw material. Multiply by the percentage of that ingredient in your formula. Check the result against the threshold for your product type under EU allergen rules, leave-on or rinse-off.
If the number is above threshold, that allergen goes on the label. And into your fragrance allergens CPSR.
Step 4: Update Your Fragrance Allergens CPSR
Work with your qualified safety assessor to update both Part A and Part B. Give them your allergen calculation data, supplier declarations, relevant SCCS opinions for newly listed substances, and an updated exposure assessment where concentrations have changed.
This step cannot be rushed. A properly updated fragrance allergens CPSR is your legal standing under EU law.
Step 5: Update Allergen Labeling and Artwork
Newly triggered allergens go on the ingredient label by their INCI name. Please check the ordering rules under Regulation (EC) No 1223/2009. Brief your designer, request updated proofs, and make sure you account for print lead times, especially when managing a large product range.
Step 6: Check CPNP Notifications
If your product is already notified on the Cosmetic Products Notification Portal, formula or label changes may trigger an update. Please check with your regulatory affairs contact whether your specific changes require a new CPNP submission under EU law.
Reformulation: When the EU 80 Allergen Rules Point Beyond Labelling
Sometimes the right answer isn’t adding allergens to a label. It’s reducing or removing them from the formula entirely.
This is worth considering seriously for products claiming suitability for sensitive skin, anything marketed as “hypoallergenic” under EU law, children’s products where regulatory scrutiny continues to grow, and products where four or more newly listed substances now trigger allergen labeling.
If a consumer sees six new allergen names on a label that previously showed two, that affects brand perception, especially for products marketed as gentle or low-irritant. The cosmetic allergens EU update creates a commercial question alongside the compliance one. Both deserve an answer.
Can You Still Use “Hypoallergenic” Claims?
There’s no single legal definition of “hypoallergenic” in EU law. But claims like “suitable for sensitive skin,” “hypoallergenic,” or “free from fragrance allergens” carry real risk under the updated EU allergen rules.
Here’s the core issue:
- Claims must be substantiated under Regulation (EC) No 1223/2009
- Substantiation must reference your product’s actual allergen profile
- A product that now triggers allergen labeling under Commission Regulation (EU) 2023/1545 may no longer support previous “allergen-free” claims.
Review your marketing claims alongside your allergen audit. They’re directly connected, and regulators are paying attention to both.
Why EU Allergen Compliance Matters
Non-compliance with EU allergen rules isn’t a paperwork problem. It’s a legal issue with real consequences.
National competent authorities across EU member states can:
- Require market withdrawal of non-compliant products
- Order mandatory product recalls
- Issue fines under national enforcement of EU law
- Refer cases for further regulatory action
Market surveillance is increasing. The cosmetic allergens EU update is on every regulator’s radar, which means inspectors know exactly what to look for. An outdated fragrance allergens CPSR, missing allergen labeling, or a claim that doesn’t hold up against the EU fragrance allergens list 2026 are all visible compliance failures.
The 31 July 2026 deadline for new products is EU law.
Key cosmetic allergens EU updates
| Action Required | Deadline | Who’s Responsible |
| Understand EU 80 allergen rules and revised Annex III | Now | Brand owners + safety assessors |
| Request allergen data from suppliers | Now | Regulatory / procurement teams |
| Calculate allergen concentrations per product | Before mid-2026 | Formulators + safety assessors |
| Update fragrance allergens CPSR | Before product placement | Qualified safety assessor |
| Update allergen labeling and artwork | Before 31 July 2026 | Brand owners |
| All products comply with EU allergen rules | 31 July 2028 | All brands in EU market |
Final Thoughts
Commission Regulation (EU) 2023/1545 isn’t a minor amendment. It’s a reset of how allergen labeling and fragrance allergens CPSR documentation work under EU law.
The EU fragrance allergens list 2026 is longer, the thresholds are stricter for some substances, and the documentation burden is real. But brands that treat this as a structured project, rather than a last-minute label fix, will get through it cleanly.
Start with an allergen map and gather supplier data early. Then update your fragrance allergens CPSR and make sure your labeling follows the full EU 80 allergen rules before July 2026.
FAQs:
Q1. What is the EU fragrance allergens list 2026 and what changed?
The EU fragrance allergens list 2026 is the updated Annex III under Regulation (EC) No 1223/2009, expanded by Commission Regulation (EU) 2023/1545. It grew from 26 to over 80 substances requiring mandatory allergen labeling in cosmetic products sold under EU law.
Q2. When do the EU 80 allergen rules apply to my products?
Under Commission Regulation (EU) 2023/1545, the EU 80 allergen rules apply to new products from 31 July 2026. All existing products on the EU market must comply with the full cosmetic allergens EU update by 31 July 2028 under EU law.
Q3. How does the cosmetic allergens EU update affect my CPSR?
The cosmetic allergens EU update requires your fragrance allergens CPSR to document concentrations, thresholds, and safety assessments for all 80+ listed substances, not just the original 26 under Regulation (EC) No 1223/2009. Part A and Part B both need updating.
Q4. Do EU allergen rules apply to “fragrance-free” products?
Yes, EU allergen rules apply to any product containing substances on the EU fragrance allergens list 2026, even if fragrance wasn’t deliberately added. Natural extracts and plant-derived ingredients can contain listed allergens, triggering mandatory allergen labeling under EU law.
Q5. What are the allergen labeling thresholds under the new EU allergen rules?
Under updated EU allergen rules, allergen labeling is triggered at 0.001% in leave-on products and 0.01% in rinse-off products. Commission Regulation (EU) 2023/1545 sets stricter thresholds for certain newly listed substances; each entry in the revised Annex III of Regulation (EC) No 1223/2009 must be checked individually.
Q6. Can I still use “hypoallergenic” claims under the EU 80 allergen rules?
Claims like “hypoallergenic” must be substantiated under Regulation (EC) No 1223/2009. If your product now triggers allergen labeling under the EU 80 allergen rules, any fragrance allergens CPSR or marketing claim suggesting it’s allergen-safe needs reviewing; EU law requires all cosmetic claims to be accurate and evidence-based.
