The regulation requires the brand-owning company, i.e. the Responsible Person, to carefully review its cosmetic products to ensure compliance with the updated labelling requirements.
Therefore, these companies must:
- Identify whether their products contain any of the 80 listed allergens:
Commission Regulation (EU) 2023/1545 of 26 July 2023 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards labelling of fragrance allergens in cosmetic products. - Adapt ingredient lists on cosmetic products to include the listed substances if their concentration exceeds:
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- 0.001% in leave-on products
- 0.01% in rinse-off products
- Update product packaging and labels in accordance with the new rules.
- Plan the transition for existing products before 31 July 2028 in order for the products to continue to be sold.
The regulation applies to products sold on the European market. For exports outside the EU, it is important to verify the applicable requirements for the specific market where the product will be sold. Cosmetic companies operating in multiple markets may therefore need to adapt labelling and ingredient lists if they wish to use a uniform product packaging across all markets.
Which dates are important to know?
The brand-owning company must comply with the new requirements according to the following timeline:
· From 31 July 2026, all products placed on the EU market must comply with the updated labelling requirements.
· Products already on the market before 31 July 2026 may continue to be sold until 31 July 2028.
· After 31 July 2028, all products must be fully compliant with the new rules.
Why has this legal requirement been introduced?
Many people may develop fragrance allergies and/or contact allergies through repeated or long-term exposure to certain substances, particularly fragrance ingredients. By providing clearer information about allergens in cosmetic products, consumers with known allergies can avoid products that may cause allergic reactions. At the same time, the regulation contributes to a more transparent market.
Sources
· Fragrance allergens labelling – European Commission
· Guidelines on the ‘fragrance allergens’ requirements