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82 Substances, 31 Days: The EU Fragrance Allergen Deadline US Beauty Brands Can’t Ignore

Regulation 2023/1545 expands the EU mandatory declaration list to 82 allergens. Labels on affected SKUs must change before 31 July — and new production must comply now.

Key Takeaways

►82 allergens now require EU label declaration

►New production must comply after 31 July

►Existing stock: 12-month sell-through window

►No Responsible Person means no lawful EU sales

Regulation 2023/1545 has expanded the EU mandatory fragrance allergen declaration list to 82 substances, adding 56 new compounds to the existing 26. The 31 July 2026 deadline is approaching, and for US beauty brands selling fragrance products into Europe, the compliance question is not whether to act — it's whether there's still time to do it in the right order.

82 restricted fragrance allergens now requiring mandatory EU label declaration under Regulation 2023/1545 (Source: EU Official Journal / Obelis)

The rule operates in two stages. Products already on the EU market before 31 July benefit from a 12-month sell-through period, meaning existing stock can continue to circulate under current labelling into mid-2027. New production ordered after 31 July must comply immediately, with updated labels that declare all 82 allergens by name if present at or above the threshold concentration.

That sell-through provision is not a reason to delay the SKU audit. It is time to complete the review before new stock arrives that cannot legally enter the EU without updated labels. Brands that wait until August to start the label review will be ordering production runs that cannot move through the EU supply chain until relabelling is complete.

There is a harder issue for US brands without EU representation. Placing any cosmetic product on the EU market requires a designated Responsible Person: the legal entity responsible for compliance under EU Cosmetics Regulation 1223/2009. No Responsible Person means no lawful EU sales, regardless of allergen label status. For brands currently reaching EU customers through international shipping without formal market entry, the RP designation is not optional.

Regulation 2023/1545 adds 56 new substances — total EU mandatory allergen declaration list now stands at 82
31 July 2026: new production must comply; existing stock in circulation has a 12-month sell-through period
All 82 allergens must appear on the label by name if present at or above the threshold concentration
US beauty brands without an EU Responsible Person cannot legally sell cosmetic products in the EU at all

The label change is the visible requirement. The Responsible Person designation is the prerequisite that makes selling legally possible in the first place.

Expandly helps US ecommerce brands expand into Europe — compliance, marketplaces and fulfilment, all handled. We’ve supported 2,000+ brands make the move.

VAT registration handled across UK, Germany, Netherlands and all EU markets
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The bigger picture

EU beauty compliance is converging on a tight summer window

July 31 is the fragrance allergen label deadline. July 30 is when the updated EU Cosmetics INCI Glossary becomes mandatory for new production. August 2 is the EU AI Act Article 50 transparency deadline. Three distinct obligations land within four days of each other. For US beauty brands in the process of EU market entry, this summer window is the compliance pressure point. Brands that have already set up a Responsible Person and completed their label audit are navigating this in sequence. Brands that haven't are facing all three at once.

Conduct a full SKU-level allergen audit against the 82-substance list now — identify which products require label changes before the next production run
If you don't have an EU Responsible Person in place, set this up first — it is the legal prerequisite for everything else in EU cosmetics compliance
Cross-reference the July 30 INCI Glossary update in the same audit run — new entries affect labelling on the same production cycle

Restricted Allergens on the EU Mandatory List

56 new substances added under Regulation 2023/1545, bringing the total from 26 to 82 — all must be declared on labels if present above threshold

Source: Regulation 2023/1545 / Obelis

New Production Compliance Deadline

After this date, new production runs for EU SKUs must carry updated allergen declarations — existing stock in circulation has a 12-month sell-through period

31 Jul 2026

Source: Regulation 2023/1545

EU Responsible Person, Included

Cosmetics, supplements and electronics sold in the EU require a designated Responsible Person. Expandly provides this designation as part of your compliance setup, with no separate service or third party required.

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brands expanded with Expandly

If this sounds like your world,
let's talk.

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82 Substances, 31 Days: The EU Fragrance Allergen Deadline US Beauty Brands Can’t Ignore

In This Article

Key Takeaways

The bigger picture

EU beauty compliance is converging on a tight summer window

If this sounds like your world, let's talk.

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If this sounds like your world,
let's talk.