Soon, new labeling laws on fragrance allergens will come into effect across the EU and Northern Ireland. As of July 31, 2026, all new cosmetic products entering the market must comply with expanded labeling requirements, listing approximately 80 substances and substance groups considered fragrance allergens. All cosmetic products made with fragrance allergens must now specify each allergenic substance on their labels. Previously, only 26 were required to be individually labeled.
The upcoming enforcement comes three years after the publication of Commission Regulation (EU) 2023/1545, which amends Annex III of the Cosmetic Products Regulation to include these additional fragrance allergens. For leave-on products, allergens must be listed when concentrations exceed 0.001%, and for rinse-offs, concentrations above 0.01%. Fragrance substances that can be transformed into known contact allergens via air oxidation or bioactivation must also be treated as equivalent and are subject to the same restrictions; examples include prehaptens and prohaptens.
Products placed on the EU market before the deadline have until July 31, 2028, to sell existing inventory under the old labeling laws. After this date, products may be withdrawn if noncompliant.
The new law, which is designed to better inform consumers on fragrance allergenic substances present in cosmetics and to protect individuals who are sensitive to allergic reactions, has proven a significant challenge for the industry due to its breadth of impact.
“The expanded allergen labeling requirements represent one of the most operationally demanding compliance exercises the beauty and personal care sector has faced in recent memory,” said Charles de Lusignan, Global Communications Director at Swiss-headquartered industry association the International Fragrance Association (IFRA).
Modern fragrance formulas can contain several hundred ingredients, and companies have had to map, verify, and document allergen presence across entire product portfolios, sometimes running through thousands of SKUs—which is “not a trivial task, even for well-resourced businesses,” Lusignan told BeautyMatter.
Critically, the new requirements have proven complex given the nuanced nature of raw materials and the diversity of product portfolios, he said. “Fragrances can comprise many ingredients, including some used at very low or occasional levels, requiring detailed verification across multiple formulations. As a result, this has been an exercise affecting the sector as a whole.”
Dr. Emma Meredith, Director-General at UK trade body the Cosmetic, Toiletry and Perfumery Association (CTPA), said compliance has certainly been “a very complex and time-consuming task” that has impacted businesses of all shapes and sizes, especially SMEs with smaller teams and budgets.
While the impact on industry is broad and “all companies will have had to look at their product portfolios,” she said, companies working with high levels of botanical extracts, essential oils, and fragrance, in particular, are most affected.
“Not only will manufacturers have had to look at their formulations, but they will also have had to engage with their suppliers for details of the allergen content in any fragrance mixtures, extracts, or essential oils they have supplied,” Meredith said. And many natural extracts, essential oils, and fragrance mixtures contain substances that now require individual labeling.
Dr. Florian Stintzing, President of the global trade association The International Natural and Organic Cosmetics Association (NATRUE), agreed. “NATRUE recognizes that the upcoming requirements on fragrance allergen labeling represent a significant and complex adjustment for the cosmetics industry. This is particularly true for the natural and organic sector, where formulations often rely on natural essential oils and botanical extracts that may naturally contain allergenic constituents.”
Meredith said that while the regulation has created a significant compliance exercise for industry, “it is important to remember that this is not about ingredient safety.” Fragrance allergen ingredients and substances need to be labeled, not removed, she said.
“The new law increases consumer awareness for those individuals who have been diagnosed as allergic to these substances,” she explained. “The vast majority of people will not have the genetic makeup to become allergic to the substances, but for those unfortunate enough to be allergic to any of these allergens, the ingredient list will alert them to cosmetic products to avoid.”
Lusignan agreed: “This is fundamentally a transparency exercise, and it does not in itself require reformulation.”
The expanded list principally covers substances identified as potential skin sensitizers by the EU's scientific advisory bodies, many of which have a long history of safe use in perfumery, he said. The general safety of fragrance ingredients in the EU is assessed based on risk and takes into account exposure levels, and these substances are “typically used at very low concentrations,” he said.
IFRA, therefore, has been heavily involved in working with the European Commission to ensure the regulatory framework in the EU reflects the “technical realities of fragrance formulation,” Lusignan said. The trade body has also worked alongside partners, including the Research Institute for Fragrance Materials (RIFM) and the International Dialogue on the Evaluation of Allergens (IDEA) Project, to advance the science underpinning allergen risk assessment.
The new EU labeling requirements are welcomed by the industry, Lusignan said. “IFRA supports measures designed to protect consumers, including those who live with fragrance sensitivities. Greater transparency on allergen presence on pack is, in principle, a positive step.”
Asked if the labeling changes might impact innovation and competition in fragrance development, Meredith said this is unlikely. While blends can take many years to develop, guided by the unique skills of fragrance experts or “noses,” she said, additional labeling requirements should not impact intellectual property.
Lusignan agreed: “The new allergen labeling requirements add targeted, consumer-facing transparency on specific substances of potential concern, which is distinct from full formula disclosure.”
While regulatory authorities in Europe will continue to have full access to formula compositions, what remains protected “legitimately, in the same way a food recipe or beverage formula is protected,” he said, is intellectual property. “The creative and commercial integrity of fragrance development remains intact.”
The beauty, personal care, and fragrance industry has known about these new labeling requirements since 2012, when the EU Scientific Committee on Consumer Safety (SCCS) issued its opinion on the matter, and widely supports the goal of improved consumer information. Plenty of time and effort have also been put into compliance measures ahead of the July 2026 deadline.
IFRA President Alexander Mohr has been consistent that compliance is not optional, and late preparation creates both reputational and legal risks. For companies still uncertain about the specifics, Lusignan said it is absolutely key to consult with fragrance suppliers and, where relevant, industry associations for guidance on documentation and labeling obligations.
The European trade association Cosmetics Europe issued a guidance document in 2023 to help the industry navigate the fragrance allergen labeling law.
For the time being, the EU regulatory update on fragrance allergens is not yet being introduced in Great Britain under the UK Cosmetics Regulation. However, any other global company placing products on the EU market, including UK companies, must also comply with the labeling standards. “While no decision has been taken in the UK yet as to whether it will implement similar requirements, CTPA has also engaged with Trading Standards through its Primary Authority Partnership to provide Assured Advice that if companies update their label to comply with the EU requirements, and also wish to place the same cosmetic product on the GB market, the 'over labeling' will still be accepted as compliant in GB,” she said. The association has also been keeping UK dermatologists updated so they can inform patients accordingly, she said.
Stintzing said NATRUE supports “the overarching goal of improved consumer information and safety.” However, the association calls for harmonized, science-based, and proportionate implementation across the EU and UK to avoid unintended impacts on innovation, traditional natural formulations, and market diversity. “Clear and consistent guidance is essential to ensure transparency for consumers without leading to unnecessary confusion or 'over-warning' of products,” he said.
Lusignan added, “The allergen labeling deadline is a significant milestone, but it should also be seen in a wider context. The fragrance sector has been adapting continuously to an evolving regulatory landscape—reformulating, documenting, investing in safety science—and it will continue to do so. What matters now is that future regulatory development is built on proportionate, science-based assessment that accounts for real-world exposure, protects consumers effectively, and allows the creativity and innovation that define this industry to continue to thrive.”