The New EU Allergen List

What’s Changing and Why?

Until recently, EU law required cosmetic products to list 24 specific fragrance allergens on their packaging if they were present above very low levels. These rules were designed to help people who are sensitive to certain ingredients avoid products that might cause them problems. However, as our understanding of allergies has improved, it’s become clear that more substances can cause reactions than were previously listed.

To address this, the EU has adopted Regulation (EU) 2023/1545, which significantly expands the list of allergens that must be declared. Now, instead of just 24, there are over 80 substances that need to be mentioned on the label if their concentration exceeds certain thresholds. This move is all about transparency and giving consumers the information they need to make safer choices.

When Do the New Rules Apply?

There’s a generous transition period to help manufacturers and retailers adjust. Here’s how the timeline works:

From 31 July 2026, any new cosmetic products placed on the EU market must comply with the updated allergen labelling requirements. Products that were already on the market before this date can continue to be sold until 31 July 2028, but after that, all products must meet the new rules.

The regulation itself came into force on 16 August 2023, but these transition dates give everyone time to adapt.

What Does This Mean for Labels?

If you’re a consumer, you’ll notice longer ingredient lists on your favourite products. Brands will need to update their packaging to include any of the listed allergens if they’re present above 0.001% in leave-on products (like creams and lotions) or 0.01% in rinse-off products (like shampoos and body washes). For some substances, the regulation allows similar allergens to be grouped under one name, which helps keep ingredient lists from becoming unmanageably long. But that is the only concession. Inevitably INCI lists are going to get longer.

Most companies will be switching over as quickly as possible. But we are hearing that some natural companies are going to put off adding the new allergens until the last possible moment in 2028. The idea of being that nobody wants to be the first natural brand to add a load of allergens to their packs. As is often the case with these things, it is probably best to follow the crowd.

Why Is This Important?

Allergies to fragrances and other ingredients in cosmetics are not uncommon, and repeated exposure can sometimes lead to new sensitivities. By giving clearer information, the new rules help people with allergies avoid ingredients that could cause them discomfort or worse. For manufacturers, it means reviewing formulations, updating safety reports, and making sure every product on the shelf is fully compliant.

In Summary

If you’re a consumer, these changes mean more transparency and a better chance of avoiding ingredients that might cause you trouble. If you’re in the industry, now’s the time to check your formulations and labels to ensure you’re ready for the new rules. Either way, the end result should be safer, more informed choices for everyone.

Implementation dates to remember: 31 July 2026: New products must comply 31 July 2028: All products must comply, including those already on the market

The Expanded List of Allergens

References

https://eur-lex.europa.eu/eli/reg/2023/1545/oj/eng