EU fragrance-allergen labelling after July 2026

The July 2026 fragrance-allergen transition deadline has passed, but the work does not end with checking the date. A team reviewing a label needs supplier composition data, a finished-product calculation, and the correct artwork. Stock relying on the remaining transition needs a separate review of its supply history.

This guide follows those steps. For a quick summary of the two dates, see the short deadline briefing.

Distinguish the two market events

Regulation (EU) 2023/1545 allowed relevant products not meeting the new restrictions to be placed on the market until 31 July 2026 and made available until 31 July 2028, subject to the conditions in the applicable entries. Some provisions expressly require compliance with restrictions applicable on 15 August 2023.¹

The Cosmetics Regulation defines placing on the market as first making available. Making available covers supply for distribution, consumption, or use in a commercial activity.² The Blue Guide explains that placement concerns individual products, including units made in a series.³

Identify the stock and transactions behind any reliance on the transition. Establish the placement history of those units, including units of a product type launched years earlier. Resolve gaps in that history before relying on the transition for supply.

Gather data for the actual formula

Use the exact formula version and supplier documents covering its materials. Check the material identity, declaration revision, concentration basis, ranges, and reporting limits. An empty cell is missing information until its meaning is established; it must not silently become zero.

Include relevant contributions from all formula inputs. A raw material filed as a botanical or active still needs consideration where its composition contributes a listed substance.

Calculate the concentration in the finished product

The individual-labelling thresholds are more than 0.001% for leave-on products and more than 0.01% for rinse-off products. Apply the actual Annex III entry, including grouping, declaration names, and any additional restrictions.¹

Here is a hypothetical calculation using mass percentages. The formula contains 0.50% fragrance, and the supplier reports 1.00% of a listed substance in that fragrance:

0.50 × 1.00 ÷ 100 = 0.0050% in the finished product.

That contribution exceeds the leave-on threshold for an entry using those limits. Add any contribution from other ingredients before comparing the total. Preserve the calculation before rounding. This arithmetic example is not an assessment of a real formula’s safety or overall compliance.

Carry the result into the artwork

Link the calculation to the proposed ingredient-list version, then check the text in the packaging file actually supplied for production. Use the current Annex III and applicable corrections; EUR-Lex lists corrigenda associated with the amendment.⁴

Identify who checked the calculation and declaration names, which artwork was approved, and when it became available. Make older artwork recognisable wherever packaging is ordered or selected. A revised supplier declaration should trigger a comparison with the data used for approval.

Review transition stock separately

For stock considered eligible, retain its identifier, label version, quantity, location, and supporting placement evidence. Reconcile quantities with distribution partners before the remaining deadline and assign unresolved questions.

If software helps screen formulas, change a supplier declaration in a test case and follow it through the calculation and label review. Assign responsibility for maintaining inputs, investigating flags, and recording the final assessment.

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