In the EU, Annex III of the Cosmetics Regulation lists the substances. Regulation (EU) 2023/1545 added 56 more, roughly trebling the list. They have to be named when they exceed 0.001% in leave-on products or 0.01% in rinse-off products, using their INCI names. The first deadline has now passed: since July 31, 2026, products newly placed on the EU market have to carry the expanded declaration, and products already on the market can stay available until July 31, 2028. In the US, MoCRA directs FDA to set a fragrance allergen disclosure rule, which had not been finalized when this entry was written.
Why it matters for labeling
Each allergen has to be named in the ingredient list, in the right position, and updated whenever a fragrance changes. The same product in different markets can carry different lists. Every new batch placed on the EU market since July 31, 2026 is in scope, and the 2028 date only covers stock that was already on the market. The Responsible Person is accountable for getting this right.
Common mistakes
- Relying on a supplier's old allergen declaration
- "Parfum" listed with no allergens named
- A fragrance change without a label review
- INCI spelling that differs between language versions
- Assuming the 2028 date applies to new batches