From 31 July 2026, every cosmetic product placed on the EU market must declare 56 additional fragrance allergens on its label where those allergens are present above threshold concentrations. The current declared list covers 24 substances. After July 31, the full list reaches 80. For US beauty brands entering the EU, this is not optional, because label changes are legally required before a single unit can be placed on the market after the deadline.

Regulation (EU) 2023/1545 amends Annex III of the EU Cosmetics Regulation (EC) 1223/2009. The 56 new substances cover a broad range of fragrance raw materials including atranol, chloroatranol, and a range of terpenes and aromatic compounds that appear across perfume, lotion, hair care and rinse-off formulations. The declaration threshold for leave-on products is 0.001%, so even low-concentration fragrance ingredients in moisturizers, serums and body lotions may trigger a labeling obligation. For rinse-off products, the threshold is 0.01%. Brands relying on fragrance-blend INCI names alone may now be non-compliant, because individual allergen declaration is required where thresholds are exceeded.

Products already placed on the EU market before 31 July 2026 have a sell-through window until 31 July 2028, but that window covers stock already in distribution channels, not new shipments from that date. Any product manufactured and placed into the EU supply chain after July 31 must carry the updated label. For brands planning EU launches or restocking between now and that date, the 12-week countdown is effectively a production-cycle question, because if label artwork changes require a full print run, the lead time is now.

• 56 additional fragrance allergens must be declared from 31 July 2026, with a leave-on threshold of 0.001% and a rinse-off threshold of 0.01%
• The total declared allergen list expands from 24 to 80 substances, so brands using complex fragrance blends face the broadest label update
• Supplier documentation must confirm the concentration of each new allergen in finished formulations, and existing fragrance supplier data may not cover the expanded list
• The Responsible Person must update the Product Information File (PIF) to reflect the new label declarations
• The sell-through window to 31 July 2028 applies to stock already in EU distribution, while new shipments placed after the July 2026 deadline must carry the updated label

The fragrance allergen update is one of three active EU cosmetics compliance deadlines hitting in 2026. Brands entering the EU now need to confirm current formulation status against the expanded list and feed any updates through to artwork, PIF documentation and EU Responsible Person sign-off before July. Expandly's compliance onboarding runs label audit and documentation review as the first step, before marketplace or fulfillment setup.