EU law makes brands name certain fragrance allergens on the label, and the list grew from 26 to more than 80 in 2023.
Which fragrance allergens must be listed on EU cosmetic labels?
EU law lists fragrance allergens in Annex III of the Cosmetics Regulation (EC) No 1223/2009. A product must name each one above 0.001% in leave-on products or 0.01% in rinse-off products. Regulation (EU) 2023/1545 added 56 more. New products must comply from 31 July 2026. Older stock can be sold until 31 July 2028.
Definition
In the EU a perfume or lotion is a cosmetic product. The rules for it are in Regulation (EC) No 1223/2009, the Cosmetics Regulation. Annex III of that law lists substances you may use only under conditions [1][2].
Some Annex III entries are fragrance allergens. A brand must name these on the ingredient list when they pass a set level [1][2]. Below that level they can stay inside the word “parfum.”
This is a law, not an industry code. It applies to every cosmetic sold in the EU. That makes it different from the IFRA Standards, which bind IFRA members only. For the wider picture see Allergens in cosmetics and How fragrance is regulated in cosmetics.
The original 26
The first list had 26 fragrance substances. They came from an EU scientific opinion adopted on 8 December 1999 [3]. They entered the law through Directive 2003/15/EC, the 7th amendment to the old Cosmetics Directive [3][4].
The 26 include 24 single chemicals and two natural extracts [3]. Names you may know include linalool, limonene and citral. Coumarin, eugenol and geraniol are on it too. The two extracts are oakmoss and treemoss [3].
Two of the 26 are now banned outright [4][7]. HICC could not go into new products from 23 August 2019. Shops had to stop selling it from 23 August 2021 [5][6]. The same law banned two more allergens called atranol and chloroatranol [5][6]. Lilial (butylphenyl methylpropional) was banned from 1 March 2022 [7][8]. That is why some sources count 25 labeled allergens before 2023 [9][10]. Restricted and banned materials covers these bans in detail.
The labeling thresholds
The trigger levels are 0.001% for leave-on products and 0.01% for rinse-off products [1][4]. A leave-on product stays on your skin or hair. Perfume, body lotion and hair oil are leave-on. Shower gel and shampoo are rinse-off.
The EU’s scientific committee called these levels a practical choice [3]. There was not enough data to set a dose for each allergen [3]. The same two levels apply to the new entries in 2023 [1][9].
A name on the label does not mean the product is unsafe [1]. It is there so a person who reacts to one allergen can find and avoid it. How to read a fragrance ingredient label shows where these names sit on a box.
The 2023 expansion: Regulation (EU) 2023/1545
The Commission adopted Regulation (EU) 2023/1545 on 26 July 2023 [11][10]. It was published in the Official Journal on 27 July 2023 [10]. Its Article 2 says it enters into force on the twentieth day after publication. That was 16 August 2023 [11].
It added labeling for 56 more fragrance allergens [1][9]. The labeled list now has more than 80 substances [9][12]. It also groups some substances into one entry and updates how others are named [1][11]. One example is citral, which now also covers geranial and neral [11].
The new entries include single chemicals such as vanillin, menthol and camphor [10]. Linalyl acetate and pinene are on the list too [10][11]. They also include essential oils and extracts. Lemongrass oil, lavender oil, peppermint oil and eucalyptus oil are on the list [10]. Bergamot oil and lemon oil are new entries too [11].
The transition dates
The law sets two deadlines [1][12]:
| DATE | WHAT IT MEANS |
|---|---|
| 31 July 2026 | A product that does not name the new allergens can no longer be placed on the EU market. |
| 31 July 2028 | A product placed on the market before 31 July 2026 can be sold until this date. After it every product on sale must comply. |
“Placing on the market” means the first time a product is supplied in the EU [12]. “Making available” covers every later sale down the chain [12]. A relaunch or a new formula can count as a new placing [12].
As of 5 November 2026 the first deadline has passed. So a new launch must already follow the longer list. Older bottles may still show the shorter list until mid-2028. A new name on a box can be a label change alone. See What “reformulated” means.
I describe these rules for general reading. This is not legal or compliance advice.
Sources
All accessed 5 November 2026.