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Expandly Blog

EU Fragrance Allergen Labeling: 82 Substances Required on EU Labels by 31 July 2026

From 31 July 2026, every cosmetic product newly placed on the EU market must carry on-label declarations for all 82 mandatory fragrance allergens, including 56 newly required under EU Regulation 2023/1545.

In This Article

01The new EU allergen list explained
02Leave-on and rinse-off thresholds
03The July 31, 2026 enforcement date
04Sell-through rights for existing stock
05Who carries the compliance liability

Key Takeaways

►82 allergens required on EU labels from 31 July 2026
►56 substances are newly added to the list
►Existing EU stock has sell-through until 31 July 2028
►Responsible Person carries label compliance liability

From 31 July 2026, every cosmetic product newly placed on the EU market must declare all 82 mandatory fragrance allergens on-label under EU Regulation 2023/1545. That includes 56 substances added to the list in 2023. Products already in EU distribution before the deadline have a sell-through window until 31 July 2028. For US beauty brands with EU-bound inventory currently in production or transit, the label update cannot wait.

82 Total fragrance allergens requiring on-label disclosure from 31 July 2026. 56 are newly added under EU Regulation 2023/1545. Source: European Commission, EU Regulation 2023/1545.

The original EU Cosmetics Regulation (EC 1223/2009) required disclosure of 26 fragrance allergens above threshold concentrations. EU Regulation 2023/1545 extended that list by 56 substances, bringing the total to 82. The disclosure thresholds are precise: 0.001% for leave-on products and 0.01% for rinse-off products. Any allergen present above those concentrations must appear by name on the product label.

New compliance guidance published in July 2026 addresses the approaching deadline. The July 31 date is a hard compliance line: the EU offers no retail grace period for products placed on the market after that date. A cosmetic product placed on the EU market from 1 August 2026 without the correct on-label declaration is non-compliant from the moment it reaches a retailer or marketplace.

The enforcement liability rests with the Responsible Person — the EU-established entity legally responsible for each cosmetic product's compliance. For US brands selling into the EU without a local operation, a designated Responsible Person must be in place. That entity carries the compliance exposure if a product fails a label check at retail or at importation.

  • EU Regulation 2023/1545 mandates declaration of 82 fragrance allergens on cosmetic labels from 31 July 2026
  • 56 substances are newly added to the original list of 26 under EC 1223/2009
  • Disclosure thresholds: 0.001% for leave-on products, 0.01% for rinse-off products
  • Products in EU distribution before 31 July 2026 may sell through until 31 July 2028
  • Non-compliant products placed after 31 July 2026 face enforcement risk at retail and at importation

Expandly's compliance onboarding includes a label review for EU-bound cosmetics. The Responsible Person designation, CPNP notification, and label audit run as part of the standard market entry process, so brands arrive in the EU with their labeling in order.

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

Find out more
  • EPR compliance managed from day one — packaging, WEEE, batteries and beyond
  • Product label review and Responsible Person service for EU and UK market entry

The bigger picture

EU Cosmetics Labeling Reform starting with allergen disclosure

The EU's 2023 allergen expansion is the most significant update to EU cosmetics labeling requirements since EC 1223/2009 was introduced. For US beauty brands entering the EU, the July 31, 2026 deadline for the 82-allergen disclosure is a concrete compliance gate at the product level. Expandly's compliance onboarding includes a label review against current EU requirements, with the Responsible Person designation in place to carry legal accountability from day one. Getting labels right before products enter the EU is what determines whether those products stay on shelves.

  • EU Regulation 2023/1545 extends mandatory allergen declarations from 26 to 82 substances from 31 July 2026
  • Expandly's onboarding includes CPNP notification, label audit, and Responsible Person designation for all EU cosmetics
  • Non-compliant labels on products placed after 31 July 2026 risk withdrawal from EU retail channels

EU Beauty & Personal Care Market

The EU beauty and personal care market is valued at $146.93 billion in 2026, growing at 4.18% annually. For US beauty brands, this is an established market with active retail and marketplace channels, and a firm compliance baseline before any product reaches shelves.

$146.93B

Mordor Intelligence, EU Beauty Market Report 2026

EU Cosmetics Regulation

EC Regulation 1223/2009 covers every cosmetic placed on the EU market, regardless of where it was manufactured. A safety report and Responsible Person designation are required before any product goes on sale. The 82-allergen declaration requirement sits inside this framework.

EC 1223/2009

EU Cosmetics Regulation — governing all products on the EU market

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.

2,000+

brands expanded with Expandly

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

Expandly helps US ecommerce brands expand into Europe — compliance, marketplaces and fulfilment, all handled.

Self-Serve

  • £1,150/month
  • Platform-led with email support
  • Best for: $1M–$5M brands

Guided

  • £3,000/month
  • Dedicated Account Manager
  • Best for: $5M–$20M brands

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  • £5,000/month
  • Dedicated VIP Consultant
  • Best for: $20M–$50M+ brands
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