EU fragrance allergens: the 2023/1545 sourcing guide
The EU fragrance allergen list went from 26 substances to 82 under Regulation (EU) 2023/1545. Thresholds, dates and what it requires per batch.
Key figures
- Substances requiring individual disclosure
82 in Annex III, up from 26 held since 1999. Of the 82, 28 are natural extracts and 54 are individual chemicals
As of
- Disclosure thresholds
0.001% in leave-on products, 0.01% in rinse-off products
As of
- Date of application
31 July 2026 for anything newly placed on the EU market
As of
- Grace period for existing stock
Products already on the market before 31 July 2026 may keep selling through 31 July 2028
As of
This page carries the rule. For the argument about what it does to natural, traceable sourcing, and who it favours, see the EU cosmetic allergen list, and what it costs naturals.
What Regulation (EU) 2023/1545 changed
The regulation amends Annex III of Regulation (EC) No 1223/2009, the EU Cosmetic Products Regulation. It takes the list of fragrance substances that must be named individually on a product from 26, where it had stood since 1999, to 82. It closes a transition period opened by a 2012 opinion of the Scientific Committee on Consumer Safety.
The obligation is disclosure, not prohibition. None of the 82 substances is banned. What changes is that above a threshold, each one must appear by name in the ingredient list instead of disappearing into the word “parfum”.
The composition of the list is what makes it a sourcing problem rather than a labelling one: 28 of the 82 entries are natural extracts outright, and a large share of the remaining 54 individual chemicals are precisely the molecules that occur together, naturally, inside real essential oils and absolutes.
The 0.001% and 0.01% disclosure thresholds
| Product type | Threshold |
|---|---|
| Leave-on (fine fragrance, creams, lotions) | 0.001% |
| Rinse-off (shampoo, shower gel, soap) | 0.01% |
Both are far below the level at which any material contributes meaningfully to a formula’s odour. Nothing in perfumery scales with mass, and this is the clearest illustration: a constituent present at one part in a hundred thousand carries a legal obligation.
31 July 2026 and 31 July 2028: two different obligations
31 July 2026. Anything newly placed on the EU market must comply. This is the date most coverage reported, and the one that has passed.
31 July 2028. Products already on the market before the first date keep a grace period and may continue to be sold until then. So non-compliant stock is legal on a shelf today and will not be in two years.
Confusing the two is the common error. The first governs what a brand may launch, the second what a distributor may still move.
What compliance requires: PIF, CPSR, CPNP, IFRA certificates
Updating the label is the last step, not the work. Getting there means:
- Collecting a constituent-level allergen breakdown, per batch, from every supplier of a fragrance mixture, extract or essential oil.
- Reassessing concentrations in the finished product against both thresholds.
- Updating the Product Information File with that supplier documentation.
- Revising the Cosmetic Product Safety Report.
- Updating the Cosmetic Products Notification Portal entry.
- In most cases, collecting fresh IFRA certificates.
Why essential oils are the hard case
A synthetic aroma chemical is one substance. It is on the list or it is not, and the answer never changes between batches.
A natural extract is a mixture of dozens to hundreds of constituents, and several of the listed allergens occur in it naturally: linalool, geraniol, eugenol, citronellol, farnesol. Their proportions move with the variety, the season, the origin and the still. The same material, bought twice, can cross a threshold once and not the other time.
NATRUE, the certification body for natural and organic cosmetics, put it directly: “This is particularly true for the natural and organic sector, where formulations often rely on natural essential oils and botanical extracts.”
The practical consequence is a barrier that scales with supplier size rather than with practice, the same mechanism examined in sustainable fragrance: CITES, traceability, and who pays.
What to ask a supplier for, against the Annex III list
One question decides it: can you provide a constituent-level allergen breakdown, per batch, against the 82-substance Annex III list?
Origin paperwork does not substitute for it. Neither does a CITES permit, an organic certificate or a fair-trade label: they answer different questions. A supplier who cannot produce that document is not disqualified as a source of material, but the analytical cost moves to the buyer, who has to run it and carry it.
Primary sources
Maintenance record
Updates
- : Page created, consolidating the rule as it stood at the 31 July 2026 deadline.
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