On 31 July 2026, the European Union (EU) will begin the hard enforcement of Commission Regulation (EU) 2023/1545, the most significant change to fragrance allergen labelling in two decades.
The amendment expands Annex III of Regulation (EC) No 1223/2009 from the familiar list of 26 entries (commonly referenced as ‘the 26’) to approximately 82 substances and substance groups that must be individually disclosed on cosmetic product labels above threshold.
There is no general grace period.
From that date, any new cosmetic product placed on the EU market crossing into EU customs for distribution must comply.
Existing inventory placed on the market before 31 July 2026 has until 31 July 2028 to be withdrawn if it does not comply.
For brands and manufacturers that have not yet started the work, the timeline is unforgiving.
Here is what matters most in the weeks ahead.
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What has changed that beauty brands need to know?
The expanded Annex III adds 56 new entries on top of the legacy list.
These additions fall into three groups:
- New allergens, such as vanillin, menthol, linalyl acetate, beta-caryophyllene, methyl salicylate, anethole, carvone and the rose ketone family (now clarified as ‘Damascenone’ by the 2025 Corrigendum).
- New natural extracts and essential oils, including bergamot, lavender, rose, ylang-ylang, peppermint, eucalyptus, clove, geranium, patchouli and Peru balsam.
- Prehaptens and prohaptens – substances that activate into allergens through air oxidation (limonene, linalool, geraniol, alpha-terpinene) or skin enzyme activity (eugenol, isoeugenol, cinnamyl alcohol). Under the 2023 amendment, these are now treated as equivalent to their activated forms.
Thresholds remain unchanged: 0.001% in leave-on products and 0.01% in rinse-off products.
Above those levels, every declared allergen must appear by its exact INCI name in the ingredient list.
Consumer reading a beauty product label
What does this mean in practice for beauty businesses?
This is not a label change exercise. It is a regulatory
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