In short
- Fragrance allergens in Annex III to Regulation (EC) No 1223/2009 must be named in the list of ingredients if their concentration exceeds 0.001% in leave-on and 0.01% in rinse-off products.
- Until now this applied to 24 allergens. Commission Regulation (EU) 2023/1545 adds another 56, identified by the Scientific Committee on Consumer Safety (SCCS) in its 2012 opinion.
- The regulation entered into force on 16 August 2023. Products that do not meet the new rules could be placed on the market until 31 July 2026 and made available (sold) until 31 July 2028.
- Being listed on the label is not a ban. It is there for people who already have a confirmed contact allergy to a specific substance.
Why allergens are listed
A perfume composition may be shown on the pack by a single word – parfum or aroma. For someone with a contact allergy to a particular fragrance substance, though, it matters whether a product contains it. That is why Directive 2003/15/EC introduced the requirement to name 26 fragrance substances; 24 of them are individual chemicals and two are natural mixtures – oakmoss and treemoss extracts.
Several of these substances are common components of natural essential oils: linalool in lavender, limonene in citrus, geraniol and citronellol in rose. So they appear on the label even when a product contains “only” a natural oil.
The 0.001% and 0.01% thresholds
| Product type | Examples | List above | Equivalent to |
|---|---|---|---|
| Leave-on | perfume, cream, body lotion, deodorant | 0.001% | 10 mg per kg of product |
| Rinse-off | shampoo, shower gel, soap | 0.01% | 100 mg per kg of product |
According to the European Commission’s plain-language summary, there were not enough dose–response data available when these thresholds were introduced; they were set as a pragmatic administrative decision. Some allergens also have a maximum permitted concentration in Annex III.
Deadlines
| Date | What applies |
|---|---|
| 27 July 2023 | Regulation (EU) 2023/1545 published in the Official Journal of the EU. |
| 16 August 2023 | Entry into force. |
| 31 July 2026 | The last day on which products not meeting the new requirements could be placed on the EU market. |
| 31 July 2028 | The last day on which such products (already placed on the market) may still be made available – sold off from stock, for example. |
As of today (October 2026), then: new products placed on the market must carry the extended list of allergens, but you may still come across older packaging in shops until 31 July 2028.
What is banned
Two substances from the original list of 26 may no longer be used in EU cosmetics:
- Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde (HICC) – Regulation (EU) 2017/1410 moved it, together with atranol and chloroatranol from oakmoss, to the prohibited substances; products containing them may not be placed on the market from 23 August 2019, nor made available from 23 August 2021.
- Butylphenyl Methylpropional – Regulation (EU) 2021/1902 listed it among the prohibited substances as a category 1B CMR substance, with effect from 1 March 2022.
The original list (Directive 2003/15/EC)
| INCI | Plain English | Status |
|---|---|---|
| Alpha-Isomethyl Ionone | alpha-isomethyl ionone | list above threshold |
| Amyl Cinnamal | amyl cinnamal | list above threshold |
| Amylcinnamyl Alcohol | amylcinnamyl alcohol | list above threshold |
| Anise Alcohol | anise alcohol | list above threshold |
| Benzyl Alcohol | benzyl alcohol | list above threshold |
| Benzyl Benzoate | benzyl benzoate | list above threshold |
| Benzyl Cinnamate | benzyl cinnamate | list above threshold |
| Benzyl Salicylate | benzyl salicylate | list above threshold |
| Butylphenyl Methylpropional | butylphenyl methylpropional | banned |
| Cinnamal | cinnamal (cinnamaldehyde) | list above threshold |
| Cinnamyl Alcohol | cinnamyl alcohol | list above threshold |
| Citral | citral (geranial + neral) | list above threshold |
| Citronellol | citronellol | list above threshold |
| Coumarin | coumarin | list above threshold |
| Eugenol | eugenol | list above threshold |
| Evernia Furfuracea Extract | treemoss extract | list above threshold |
| Evernia Prunastri Extract | oakmoss extract | list above threshold |
| Farnesol | farnesol | list above threshold |
| Geraniol | geraniol | list above threshold |
| Hexyl Cinnamal | hexyl cinnamal | list above threshold |
| Hydroxycitronellal | hydroxycitronellal | list above threshold |
| Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde | HICC | banned |
| Isoeugenol | isoeugenol | list above threshold |
| Limonene | limonene | list above threshold |
| Linalool | linalool | list above threshold |
| Methyl 2-Octynoate | methyl 2-octynoate | list above threshold |
Added by Regulation 2023/1545
The regulation added new entries 327 to 371 to Annex III and at the same time replaced the wording of several existing entries so that the labelling requirement applies to them as well. The table shows the new entries (by their names from the glossary of common ingredient names) and two replaced entries for which we have checked the requirement in the text of the regulation.
Several of the new entries are whole natural essential oils – bergamot, lavender, rose, sandalwood and patchouli among them. If a product contains such an oil above the threshold, it is named even when it is part of the perfume.