By 31 July 2026, every cosmetic product placed on the EU market must declare an expanded list of fragrance allergens — and the rule has changed slightly since you last read about it. Here is what brands need to do, when, and how to keep multilingual labels consistent under deadline pressure.
Why this matters now
Commission Regulation (EU) 2023/1545 expanded Annex III of the EU Cosmetics Regulation to require individual labeling of substantially more fragrance allergens than the old list of 24. From 31 July 2026, every new cosmetic product placed on the EU market must comply. Existing stock has until 31 July 2028 to clear.
If you have been tracking this since 2023, the headline numbers are familiar. What may not be is that a Corrigendum to the regulation was published in late 2025 — quietly, with no change to the deadlines — that corrected one INCI name, expanded the scope of one essential oil entry, and added a new substance to the list. Brands that finalized their artwork against the original 2023 text now have a small set of changes to retro-fit before July.
This guide explains what changed, what is required, where the labeling work gets harder than it looks, and the practical action plan cosmetics teams should be running through right now. It is written for regulatory affairs, packaging, and artwork managers across the cosmetics value chain — brand owners, contract manufacturers, and private-label specialists alike.
What the regulation actually requires
The EU Cosmetics Regulation requires that fragrance compositions be listed on labels under the generic terms "parfum" or "aroma" — except where specific allergenic substances are present above defined thresholds. Those substances must be declared individually, by their INCI name, in the ingredients list.
The thresholds remain unchanged:
- 0.001% in leave-on products (creams, lotions, perfumes, makeup)
- 0.01% in rinse-off products (shampoos, shower gels, soaps)
Regulation (EU) 2023/1545 expands the list of substances that trigger this individual disclosure requirement. Before the amendment, 24 fragrance allergens required individual labeling. The amendment adds 56 substances identified by the Scientific Committee on Consumer Safety (SCCS) as having clearly caused allergies in humans but not previously requiring individual labeling. The expanded list also realigns existing entries with the latest Common Ingredients Glossary (the official INCI source) and groups similar substances into combined entries.
The result is roughly 80 substances on the labeling list — the exact number varies depending on how grouped entries are counted, which is itself one of the operational complexities discussed below.
The 2025 Corrigendum: what changed
A Corrigendum to Regulation (EU) 2023/1545 was published in November 2025. It is small in scope but operationally significant for any brand that finalized artwork against the 2023 text and assumed the work was done. Three changes matter:
- Rose ketone INCI name corrected. The original entry has been replaced with Rose ketone 4 (Damascenone) to ensure accurate identification. Labels carrying the old name need to be updated.
- Pelargonium Graveolens scope expanded. The entry now covers oil, flower oil, and leaf oil. Each must be declared individually when above threshold. Brands working with rose geranium essential oils need to re-verify their labels and supplier declarations.
- Pogostemon Cablin Leaf Oil added. Patchouli leaf oil is now an allergen on the list. Both the oil and the leaf oil variants must be declared.
The Corrigendum did not change the deadlines. The 31 July 2026 cutoff still applies, and the changes above must be reflected in artwork by that date.
Why this is harder than it looks on paper
"Add some allergens to the ingredients list" sounds straightforward. In practice, four things make this one of the most operationally awkward labeling changes the cosmetics industry has had to absorb in years.
Allergens hide in essential oils and natural fragrance compositions
Linalool, limonene, geraniol, citronellol, eugenol, and citral are not exotic ingredients sourced from a single supplier. They occur naturally — often in measurable concentrations — in lavender oil, citrus oils, rose oils, ylang-ylang, bergamot, eucalyptus, and dozens of other essential oils used across the cosmetics industry. A formulation that uses three or four essential oils in a complex fragrance composition can easily cross the threshold for several allergens simultaneously.
This means the labeling work is not "did we add this ingredient?" but "is this ingredient present, naturally or otherwise, above the threshold?" That requires fresh disclosures from every fragrance and essential oil supplier — analyzed against the expanded 80-substance list rather than the old 24.
The grouping rule changes how some allergens appear on the label
The amendment groups similar substances under a single common name where appropriate. For example, the substances Citral, Geranial, and Neral are all labeled as CITRAL. This simplifies the label in some cases but introduces a new complication: the rule requires the use of the specified common name when there are multiple INCI names for what is effectively the same allergen. Getting the grouping right requires a substance-by-substance check against the regulation, not a simple substitution against an old list.
The INCI Glossary is being updated at the same time
From 30 July 2026 — the day before the fragrance allergen deadline — the use of the updated EU Common Ingredients Glossary becomes mandatory. The new Glossary adds 348 ingredient entries, bringing the total to over 30,400. For cosmetics brands, this means that labels finalized this year against the current Glossary may need a second round of updates to align ingredient terminology with the version that becomes mandatory next year. The two regulatory changes — fragrance allergens and the Glossary update — should be handled in a single coordinated artwork pass, not separately.
Multilingual artwork multiplies the work
Cosmetics products are placed on the 24 EU official languages, plus market-specific regional or local variants where applicable. The fragrance allergen list itself is identical across markets — INCI names are standardized — but the surrounding ingredient lists, product descriptions, claims, and any allergen-related warnings must be consistent in every language version of every SKU. A typo introduced in the French version of a label that gets caught in the English version is exactly the kind of drift that manual review struggles to catch under deadline pressure.
What the timeline really looks like
Brands often plan against a single deadline — 31 July 2026 — and miss the staging that surrounds it. The actual operational picture has more dates that matter:
30 July 2026
The updated EU Common Ingredients Glossary becomes mandatory. Any artwork updated for fragrance allergen compliance after this date should also reflect the new Glossary terminology.
31 July 2026
New cosmetic products placed on the EU market must comply with the expanded fragrance allergen labeling. From this date forward, no non-compliant new product may enter the market.
31 July 2028
Existing stock that was placed on the market before 31 July 2026 must clear by this date. Products on shelf that do not comply must be withdrawn.
Aligned international changes
Canada is phasing in similar requirements based on largely the same SCCS-identified substances. Brands selling into both EU and Canadian markets are coordinating a single artwork update wave rather than running them separately.
The action plan: five priorities for cosmetics teams
The teams handling this well are not the ones with the largest regulatory departments. They are the ones who started in 2024 and are now finalizing rather than starting. If you are still in the planning phase, the next ten weeks are critical. Five priorities, sequenced.
1. Request fresh allergen disclosures from every fragrance and essential oil supplier
The single highest-leverage step. Suppliers' existing disclosures were prepared against the old 24-allergen list. You need declarations against the expanded list — including the Corrigendum changes — for every fragrance composition and every essential oil in your portfolio. Without these, the rest of the work is guesswork.
Build a tracker of which suppliers have provided updated declarations and which have not. The bottleneck is rarely your team; it is suppliers consolidating their own data.
2. Re-screen leave-on products against the lower threshold
The 0.001% threshold for leave-on products catches trace amounts that the old 24-allergen list rarely required disclosure for. A leave-on product that previously needed three allergens listed may now require eight or nine. Run the screening with the updated supplier disclosures from step 1, not from your historical INCI lists.
3. Align ingredient terminology with the updated INCI Glossary
Pull the latest Common Ingredients Glossary and audit your product portfolio for terminology that needs to be updated by 30 July 2026. Where possible, do this in the same artwork pass as the fragrance allergen update. Two updates, one production cycle, is much cheaper than two separate cycles.
4. Apply the grouping rule consistently
Walk through the expanded Annex III entry by entry and confirm which substances are labeled individually, which are grouped, and what name to use for grouped entries. This is the step where unconscious carry-over from the old list creates errors — long-standing label conventions that no longer match the new rule.
5. Verify artwork at the file level, not the screen level
The final stage is always the same: comparing what is about to print against what was approved, and catching drift before it ships. Manual proofreading, line by line, in a foreign-language version, against an expanded ingredients list, is exactly the workflow where errors slip through. Automated text comparison — including across languages — becomes operationally necessary at this scale, not nice-to-have.
The risk profile, plainly stated
A misdeclared allergen on a cosmetic label is not a minor compliance issue. The thresholds in the regulation exist because a small percentage of consumers are sensitized, and for those consumers, contact with an undisclosed allergen can cause an allergic reaction. From a regulatory standpoint, a misdeclaration is grounds for product withdrawal in the affected market.
From a brand standpoint, the costs cascade further. A withdrawal triggers retailer notifications, point-of-sale removal, customer-service load, and reputational risk in a category where consumer trust is the primary purchase driver. The economics of getting the label right the first time, even at the cost of an extra automated verification step, are vastly better than catching the mistake post-print.
How Content Compare helps
InformaIT's Content Compare is the automated proofreading platform used by cosmetics brands and contract manufacturers to keep ingredient lists, allergen declarations, and label content accurate across every variant and every market. It is built for the verification step in the action plan above:
- Text Compare catches every word-level change between artwork versions — including a single character difference in an INCI name, an italic missing on a grouped allergen, or an inconsistency between two language variants of the same SKU.
- Multilingual support applies the same diff logic across English, French, German, Italian, Spanish, Arabic, and Asian scripts — without losing precision in any of them.
- OCR support means you can verify ingredient panels even when artwork arrives as a flattened image, not editable text.
- Park & Resume lets reviewers pause long, complex reviews and return later without losing context — essential when you are reviewing dozens of SKUs in a coordinated update wave.
The platform is browser-based, supports SSO via SAML v2, and is ISO 27001 certified.
What to do next
Two practical next steps if you are responsible for cosmetics labeling and the July deadline is on your plate:
- Run the supplier disclosure audit this week. Every fragrance and essential oil declaration that is more than two years old needs to be refreshed against the expanded list, including the Corrigendum changes. This is the rate-limiting step for everything else.
- Stress-test your verification step on one SKU family. Take a complete language family of one product — every market variant — and run it through automated text comparison. The output will tell you, concretely, whether your current process can scale to the volume of changes you have ahead of you in the next 60 days.
If you would like to see what an automated artwork verification step looks like on a real cosmetics label, our team can run a sample through Content Compare in a 45-minute demo. Bring a current ingredients-line file. Get in touch.
References and further reading
- Commission Regulation (EU) 2023/1545 — Official Journal of the European Union
- Regulation (EC) No 1223/2009 — Cosmetic Products Regulation
- SCCS Opinion SCCS/1459/11 — Scientific Committee on Consumer Safety
- European Commission — Cosmetics regulatory portal
This guide reflects the regulatory state as of June 4th 2026, including the November 2025 Corrigendum to Regulation (EU) 2023/1545. We review and update this guide annually, with the next scheduled update in June 2027.
