On 27 July 2023, Commission Regulation (EU) 2023/1545 was published, amending Annex III to Regulation (EC) No. 1223/2009 on Cosmetic Products by introducing new requirements for the labelling of fragrance allergens in cosmetic products.
In addition to the existing list of allergens, 56 new fragrance allergens have been identified. Where the concentration of these substances exceeds 0.001% in leave-on products or 0.01% in rinse-off products, they must be individually declared in the ingredient list.
EUROPEAN UNION (EU) AND TURKISH MARKET
31 July 2026
From this date onwards, only cosmetic products that comply with the new requirements may be placed on the EU and Turkish markets.
Please note that the transitional provision applies only to existing stocks that were placed on the market before 31 July 2026. The fact that a product was previously placed on the market or that its CPNP/ÜTS notification bears an earlier date does not permit the continued manufacture of the same product using the former allergen declaration after this date.
Accordingly, all new production batches placed on the market after 31 July 2026, even if they are continuations of existing products, must comply with the updated fragrance allergen labelling requirements.
31 July 2028
From this date onwards, only cosmetic products complying with the new requirements may remain available on the EU and Turkish markets.
Products that were placed on the market before the transition period but do not comply with the updated requirements must have been withdrawn from the market.
RECOMMENDED ACTIONS
- Obtain updated and expanded fragrance allergen declarations from your fragrance suppliers.
- Review product labels and plan the necessary revisions to ensure compliance with the new requirements.
- Update the Product Information Files (PIFs), Cosmetic Product Safety Reports (CPSRs), and product notifications accordingly.
RESPONSIBILITY
From 31 July 2026, the brand owner is responsible for ensuring that all newly manufactured batches placed on the market comply with the updated fragrance allergen labelling requirements.