The EU updated allergens list: are your cosmetic labels ready?

According to the regulations, products may be placed on the market up until 31st July 2026 using the current labeling rules of 26 allergens - and if placed on the market before 31st July 2026, they can be made available until 31st July, 2028. However, any new products placed on the market after 31st July 2026 must carry the much more detailed allergens list at the end of the ingredient list, as well as match Cosmetic Product Information files and of course, the Cosmetic Product Notification Portal. 

As this deadline is looming, we started checking supplier information and various cosmetic brand labels, and we were shocked to see just how many brands and even suppliers still carry old allergen information. Find out more, watch:

• EU cosmetic regulations overview
• How to get your ingredient list right

It prompted us to write this blog and ask: are your cosmetic labels ready for the new allergens label requirements?

For suppliers: are your MSDS, technical data sheet and allergens information ready?

The new cosmetic labelling of fragrance allergens in cosmetic products has also meant changes to how hypoallergenic claims can be made and supported, as well as a shifting view of how consumers might perceive the safety of natural products when significantly longer ingredient lists, providing full allergen disclosure as required by the new regulations, are updated as required. 
 

What are the cosmetic and fragrance allergen rules?

In the EU, leave on products containing more than 0.001% or rinse off products containing more than 0.01% of substances listed in Annex III of the Cosmetics Directive as known allergens must be listed on the label. These substances, commonly referred to as ‘allergens’, are found in many essential oils and fragrances.

If you are formulating a personal care product that will be sold in Europe, you must make sure to check and list any allergens that are present in excess of these amounts in the finished product. To do this you will need to:

• check the SDS of the individual essential oils and/or fragrances to see if the allergen is stated.
• if no allergens are stated, go back to the supplier and ask them for specific allergen information as present in the material. It is a regulatory requirement that they must provide this information to you.
• add the different allergens present (where present from more than one material).
• check the amount present from all sources against the formulation to determine if the 0.001% (leave on) or 0.01% (rinse off) limit has been exceeded.
• if they are, then the allergens must be stated on the label.

Natural does not mean safe - or that you don’t need to comply! You can still create great natural fragrances and perfumes, but you must provide the correct allergen information. Get inspired with our natural formulas:

• How to create natural perfumes
• Alcohol free natural perfume
• Natural perfume stick 
   

What are the materials now recognised as cosmetic and fragrance allergens?

We have summarised the full list of allergens, by INCI name, that are required to be declared if present above the threshold limits. In this table: 

• materials are listed in alphabetical order to make it easier to locate/compare with supplier MSDS or technical data sheets;
• not all chemical names/INN names have been listed - a search by CAS number may be required to correctly identify a substance if its chemical name/INN name has been used;
• all items listed must be listed in the ingredient list using the name in the far right hand column when the presence exceeds 0.001% in leave on products or 0.01% in rinse off products;
• all materials must still comply with IFRA and EU input limits if relevant.

How can your brand be ready? As a supplier, how can you get your paperwork up to date? 

If your brand is selling cosmetic products with a fragrance, flavour, essential oil or even plant extract in the EU, then you must comply with these new regulations. If you are a supplier selling to EU manufacturers and brands, your paperwork must comply. 

We provide two key units of learning that will ensure you have the skills and knowledge to learn how to conduct cosmetic ingredient searches and in particular, how to check for cosmetic fragrance allergens, including the use of essential oils. These units can be found in both our:

• Diploma of Personal Care Formulation (11268NAT): 100% online training to become a fully qualified Cosmetic Chemist and
• Certificate in Cosmetic Regulatory Essentials: become skilled in not just fragrance and ingredient compliance, but full regulatory compliance including microbial and stability (shelf life) testing, product safety evaluations, registration on the EU CPNP, multi-country compliance and even MoCRA (US) compliance.