EU Fragrance Allergen Labeling: What Cosmetic Brands Must Know Before August 2026

If your cosmetic brand sells or plans to launch fragranced products in the European Union, it’s important to determine whether your existing products or new launches are affected by the EU’s updated fragrance allergen labeling requirements. Starting on that date, the EU will expand its mandatory fragrance allergen labeling requirements from 26 allergens to 82 allergens under Commission Regulation (EU) 2023/1545. If your ingredient label, Product Information File (PIF), Cosmetic Product Safety Report (CPSR), or CPNP notification has not been updated accordingly, your product could face compliance issues when entering the EU market. In this article, you’ll learn: What has changed Why some sources mention 80, 81, 82, or even 83 allergens What cosmetic brands should do before the compliance deadline

1. The EU Fragrance Allergen List Expands from 26 to 82

For more than two decades, the EU required cosmetic products to declare 26 fragrance allergens on the ingredient label when they exceeded specific concentration thresholds. These allergens—including Limonene, Linalool, Citral, and Coumarin—are listed in Annex III of Regulation (EC) No 1223/2009. Importantly, the labeling thresholds have not changed. Products must still declare fragrance allergens when they exceed:

• Leave-on products: more than 0.001%
• Rinse-off products: more than 0.01%

What has changed is the number of allergens that must be monitored and, where applicable, declared. Based on the Scientific Committee on Consumer Safety (SCCS) opinion published in 2012, the European Commission adopted Commission Regulation (EU) 2023/1545 on 26 July 2023, adding 56 new fragrance allergens to Annex III. These newly added allergens include:

• 29 individual chemical substances
• 27 natural extracts and essential oils

Examples include:

• Cananga Odorata (Ylang-Ylang) Oil
• Cinnamomum Cassia Leaf Oil
• Various citrus peel oils

Combined with the existing 26 allergens, the official Annex III list now contains 82 fragrance allergens.

2. Key Compliance Dates

The regulation will be implemented in two stages. August 1, 2026 All cosmetic products newly placed on the EU market must comply with the expanded fragrance allergen labeling requirements. August 1, 2028 Products that were already available on the EU market must also comply.

After this date, products that do not meet the updated labeling requirements can no longer be made available on the EU market. If your products are already distributed within the EU, remember that “placed on the market” and “made available on the market” have different legal meanings under EU legislation. This distinction determines which compliance deadline applies to your products.

3. What Cosmetic Brands Need to Update

The biggest impact is on regulatory documentation. Many fragrance and essential oil suppliers still issue allergen declarations based on the previous 26-allergen list. Those documents are no longer sufficient. Before August 2026, cosmetic brands should:

• Request updated allergen declarations covering all 82 fragrance allergens
• Review documentation for all fragrances and essential oils
• Recalculate allergen concentrations in finished formulations
• Update ingredient labels where allergen concentrations exceed the regulatory thresholds
• Review and update the Cosmetic Product Safety Report (CPSR) if allergen information has changed
• Update CPNP notifications to match the revised ingredient labeling
• Ensure the Product Information File (PIF) reflects the updated documentation

4. Why Do Some Sources Say 80, 81, 82, or Even 83 Allergens?

This is probably the most confusing aspect of the new regulation. The different numbers do not represent different legal requirements. They simply come from different ways of counting the allergens. 82 Allergens This is the official number. Annex III currently contains:

• 26 original fragrance allergens
• 56 newly added allergens

Total: 82 allergens

81 (or 80) Allergens Some organizations exclude allergens that are already prohibited in cosmetics. Two substances from the original 26-allergen list have since been banned for cosmetic use:

• Butylphenyl Methylpropional (Lilial)
• Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde (HICC/Lyral)

Since these substances can no longer legally be used in cosmetic products, some companies remove one or both from their counting. As a result, some documents refer to 81 or 80 allergens.

83 Allergens Some fragrance suppliers voluntarily include additional screening substances that are not part of the legal Annex III labeling list. One example is 6-Methyl Coumarin. Although it has its own regulatory history and is sometimes included in supplier screening panels, it is not one of the official fragrance allergens listed in Annex III. In fact, we’ve received supplier documentation containing 83 screened substances, where the official 82 allergens were supplemented with 6-Methyl Coumarin as an additional internal safety check. This is a supplier-specific practice rather than a legal requirement.

5. Could This Affect Yuka Scores?

Potentially, yes. Apps such as Yuka consider fragrance allergens as potential sensitizers when evaluating ingredient lists. Under the previous rules, many fragrance components did not appear on product labels because they were not subject to mandatory declaration. With the expanded allergen list, more fragrance components may now appear on ingredient labels even though the formulation itself has not changed. As a result, some products may receive a lower Yuka score simply because more fragrance allergens are disclosed. This doesn’t necessarily mean the product has become less safe. Instead, the regulation is increasing ingredient transparency by requiring more detailed disclosure of fragrance components that were already present in the formulation.

6. Compliance Checklist Before August 1, 2026

Before the new requirements become mandatory, cosmetic brands should complete the following checklist.

1. Request updated allergen declarations covering all 82 fragrance allergens from every fragrance and essential oil supplier.
2. Verify grouped ingredients using the latest EU Common Ingredients Glossary, which becomes mandatory on July 30, 2026.
3. Recalculate allergen concentrations in finished products using the existing thresholds:

• Leave-on: 0.001%
• Rinse-off: **0.01%**Update ingredient labels if declaration thresholds are exceeded.

4. Review and update your CPSR, particularly if it has not been revised in several years or if allergen data has changed.
5. Update your CPNP notification so that it matches the revised ingredient labeling.
6. Review products already distributed within the EU to determine whether the 2026 or 2028 compliance deadline applies.

Frequently Asked Questions

1. Do the concentration thresholds change?
No. The declaration thresholds remain unchanged:

• Leave-on products: more than 0.001%
• Rinse-off products: more than 0.01%

Only the list of fragrance allergens has expanded.

2. Do cosmetic brands need to reformulate their products?
For many brands, compliance simply requires updated supplier documentation, revised ingredient labeling, and updates to regulatory documents such as the PIF, CPSR, and CPNP notification. However, some brands are choosing to reformulate their products for commercial reasons rather than regulatory necessity. For example, some of our own clients have decided to reformulate their fragrances to be free from all 82 EU fragrance allergens. While this is not a legal requirement, it can help minimize future labeling obligations, improve ingredient transparency, and support marketing claims for consumers who are sensitive to fragrance allergens. Ultimately, whether reformulation is necessary depends on each brand’s regulatory strategy, target market, and product positioning.

Final Thoughts

The expansion from 26 to 82 fragrance allergens represents one of the most significant labeling changes introduced under the EU Cosmetics Regulation in recent years. For cosmetic brands planning to sell products in the European Union, compliance goes beyond updating the ingredient label. It also requires reviewing supplier allergen declarations, the Product Information File (PIF), the Cosmetic Product Safety Report (CPSR), CPNP notifications, and product artwork to ensure everything remains consistent. Starting these updates well before August 1, 2026 will help minimize regulatory risks, avoid delays during market entry, and ensure a smoother transition to the new labeling requirements.