EU Fragrance Allergen Labelling: The 2026 and 2028 Transition Dates

Short Answer

The EU fragrance-allergen amendment added 56 allergens to the individual-labeling framework. Products that do not comply with the new rules could no longer be placed on the EU market from 31 July 2026; products placed on the market before that date may remain available until 31 July 2028.

Key Takeaways

• 31 July 2026 controls new placing on the market.
• 31 July 2028 is the sell-through deadline for products placed earlier.
• The stated labeling thresholds remain 0.001% for leave-on products and 0.01% for rinse-off products.

Regulatory Status and Transition

Commission Regulation (EU) 2023/1545 amended Annex III to Regulation (EC) No 1223/2009 and established the transition dates for the expanded fragrance-allergen labeling rules. [EU-2023-1545]

The European Commission states that 56 additional fragrance allergens must be individually labeled when their concentration exceeds 0.001% in leave-on products or 0.01% in rinse-off products. [EU-FRAGRANCE-2026]

From 31 July 2026, non-compliant products may no longer be placed on the market. Products placed on the market before that date may remain available until 31 July 2028. [EU-FRAGRANCE-2026][EU-2023-1545]

Preparation Priorities

• Obtain current fragrance-allergen data from suppliers.
• Recalculate against the finished-product formula and product type.
• Update label artwork, PIF and safety documentation together.
• Separate post-2026 launches from eligible transition stock.

Practical Checklist

• Supplier declarations are versioned.
• Leave-on or rinse-off classification is recorded.
• Threshold calculations are retained.
• Label, PIF and safety records use the same formula version.
• Transition inventory has placing-on-market evidence.

How EasyComply Can Help

EasyComply can help teams keep formula, supplier, label and transition evidence tied to one controlled product version. Product-specific conclusions still require a complete source and formula review.