EU fragrance allergen labelling in 2026: the new rules for perfume

Under Regulation (EU) 2023/1545, a perfume sold in the EU must name each listed fragrance allergen on its label when that allergen is above 0.001% of the finished product (0.01% for rinse-off products). The list grew from a couple of dozen substances to more than 80 entries, many of them essential oils and extracts. New products placed on the EU market have had to follow the new list since 31 July 2026. Products already on the market before then can still be sold until 31 July 2028.

At perfume strength, 0.001% is tiny. In practice, almost every listed allergen in your concentrate will need to be on the label.

What changed

Fragrance ingredients usually appear on an ingredient list as one word, Parfum. Since 2005, a short list of individual substances known to cause allergies (such as linalool, limonene, citral and eugenol) has had to be named separately when above the thresholds.

Regulation 2023/1545 expands that list in Annex III of the EU Cosmetics Regulation (1223/2009). The main changes are:

• Many more entries. More than 80, including natural extracts in their own right, such as several citrus peel oils, rose, lavender and ylang-ylang.
• Grouped entries. Some closely related substances are grouped under a single name. When a group is present above the threshold, the label uses the group name, and the threshold applies to the combined total.
• Updated names. Some existing entries now have new names, so older labels may use names that are out of date.

The deadlines

If you are launching in the EU now, label to the new list from the start.

How to work out what goes on the label

Allergens are counted in the finished perfume, from every source.

Example. Your concentrate is 20% of an eau de parfum, and it contains 2% linalool in total (some added on its own, some from lavender and bergamot). In the finished perfume that's 2% × 20% = 0.4%, far above 0.001%. Linalool goes on the label.

Even 0.01% linalool in the concentrate gives 0.002% in the finished perfume, which is still above the threshold. That's why nearly everything listed ends up named.

For each listed allergen:

1. Add up everything you added directly.
2. Add what each natural material, compound and base carries in. Use your supplier's certificate of analysis or safety data sheet for the real figures, or typical compositions when that's all you have.
3. Multiply by your perfume's concentration to get the percentage in the finished product.
4. If it's above 0.001% (leave-on), name it in the ingredient list after Parfum, using the name exactly as it appears in Annex III.

Keep the calculation with your product records. Your safety assessor and your EU Responsible Person will ask for it.

Other EU checks to keep in mind

• Banned substances (Annex II). Some materials can't be used in cosmetics at all. Check your formula before you check your label.
• Use limits (Annex III). Some substances have maximum concentrations as well as labelling duties.
• The rest of the label. Name and address of the Responsible Person, nominal quantity, batch number, the full ingredient list, and the language of each country you sell in.

This guide covers the EU. Great Britain has its own cosmetics rules; check GOV.UK before relying on it for UK sales.

Doing it in Nezzo

Nezzo checks every formula against the EU Annex II list of banned substances on every plan, free. The EU allergen check is a Pro feature: it covers all the Annex III entries under Regulation 2023/1545, traces allergens inside natural materials, and works out which ones need to be named at your concentration. You can then print the label with the allergen names in place.

It's a support tool, not a certification. Your safety assessor and Responsible Person have the final word.