Fragrance ingredients are widely used in cosmetic products, including perfumes, creams, shampoos and deodorants. Some fragrance ingredients can cause allergic contact dermatitis in sensitised individuals.
Perfume and aromatic compositions and their raw materials can generally be listed as ‘parfum’ or ‘aroma’ in the list of ingredients. However, certain fragrance allergens must be identified individually on the label when they are present above specified concentration thresholds.
What are the current labelling requirements?
Commission Regulation (EU) 2023/1545 amended Annex III to the Cosmetics Regulation to strengthen the individual labelling of fragrance allergens.
It introduces individual labelling requirements for 56 additional fragrance allergens. It also updates existing entries, including by grouping certain substances and updating substance identification information.
The presence of a fragrance allergen covered by Annex III must be indicated in the list of ingredients when its concentration exceeds 0.001% in leave-on products or 0.01% in rinse-off products. These requirements allow consumers who are sensitised to particular fragrance allergens to identify and avoid products containing those substances.
What does this mean for businesses?
Manufacturers, responsible persons and other economic operators should ensure that cosmetic products placed on the EU market comply with the fragrance allergen labelling requirements applicable under Annex III of the Cosmetics Regulation.
In particular, businesses should
- review the fragrance ingredients used in their cosmetic products
- determine whether any of the fragrance allergens covered by Annex III are present above the applicable labelling thresholds
- ensure that the relevant allergens are correctly included in the list of ingredients
- update product packaging and other labelling information where necessary
- ensure that the information provided in the product information file and safety assessment is consistent with the composition and labelling of the product
Since 31 July 2026, cosmetic products that do not comply with the new fragrance allergen labelling requirements may no longer be placed on the EU market.
Cosmetic products placed on the market before 31 July 2026 may continue to be made available on the EU market until 31 July 2028. The conditions are set out in Regulation (EU) 2023/1545.
Businesses should therefore take particular care when supplying products placed on the market before 31 July 2026 during the transition period ending on 31 July 2028.
What does this mean for consumers?
Consumers may see more individual fragrance ingredients listed on cosmetic product packaging.
An ingredient appearing in the list does not mean that the product is unsafe. Individual fragrance allergen labelling provides information to consumers, particularly those already sensitised to specific fragrance allergens. It helps them identify products containing substances to which they may react.
Consumers can check the list of ingredients on the packaging to identify individually labelled fragrance allergens.
Where can I find the list of fragrance allergens?
The legally binding list of restricted fragrance allergens and the conditions that apply to them are set out in Annex III to Regulation (EC) No 1223/2009.
The European Commission's CosIng database provides information on cosmetic ingredients and their regulatory status, including references to the Cosmetics Regulation and its annexes. CosIng is an informative database and does not itself determine whether an ingredient may be used in a cosmetic product.