Since August 1, 2026, a scented cosmetic product placed on the EU market has to be labeled against a much longer list of fragrance allergens. The names that end up on that label come from a document the brand never writes.

The rule reads like a labeling job. For most brands it is a document-chasing job first, because the information the label needs sits with the fragrance supplier, and the label built from it has to be rechecked every time the fragrance, the supplier or the dose changes.

What the regulation changed, and when

Under the EU Cosmetics Regulation, a fragrance appears in the ingredient list as "parfum" or "aroma". Some fragrance substances must also be named individually, in addition to "parfum", once their concentration in the product passes a threshold. Those substances are listed in Annex III of the regulation.

Naming them lets people who are already sensitized avoid the substance they react to. The regulation puts the share of the EU population allergic to fragrance allergens at an estimated 1 to 9%.

Commission Regulation (EU) 2023/1545, adopted on July 26, 2023, extends the list. Its recitals record 24 fragrance allergens individually labeled at the time, and 56 more that the EU's Scientific Committee on Consumer Safety found have clearly caused allergies in humans. The regulation introduces individual labeling for those additional allergens, at the thresholds the existing ones already carry: 0.001% in a leave-on product, which stays on the skin or hair, and 0.01% in a rinse-off product, which is washed off.

Summaries often give the new total as 82, the 26 allergens listed when the Cosmetics Regulation was adopted in 2009 plus the 56. Two of those 26, HICC and butylphenyl methylpropional, have since been banned outright, which leaves the 24 the regulation counts. The annex also groups some substances under one label name, so geranial and neral, for example, are both declared as "Citral". The total matters less than it seems. A label names only the listed allergens its product contains above the threshold.

The Cosmetics Regulation defines placing on the market as a product's first making available in the EU. The Commission's general guidance on EU product rules, the Blue Guide, treats placing on the market as something that happens to each individual product, not to a product type. Read that way, the 2026 date is not only about launches. The next batch of a line that has sold for years needs the new labeling too, while units placed on the market before August 2026 can be sold through until the end of July 2028.

Why the hard part is the supplier's declaration

To print the right names, a brand has to know, product by product, which listed allergens its fragrance contains and at what level. That is rarely in the brand's own records. The fragrance formula is normally the fragrance house's to know, and what reaches the brand is a declaration: a document from the supplier stating which allergens the fragrance contains, and how much of each.

The brand cannot readily check those numbers itself. It depends on the declaration being complete, current, and about the fragrance it actually buys. Three details make that harder under the new list.

• Coverage. A declaration written against the old list says nothing about the 56 new allergens. Holding one is not the same as knowing what the fragrance contains.
• Names. The annex sets the name to print, and groups some substances together. A declaration that lists geranial and neral separately still has to become one "Citral" on the label.
• Units. The threshold applies to the finished product. If the declaration gives each allergen's level in the fragrance itself, the brand still has to scale it by how much fragrance each product contains.

That last step is where one fragrance can produce two different labels. Say a fragrance contains 0.5% linalool and makes up 1% of a body lotion. The lotion contains 0.005% linalool, above the 0.001% leave-on threshold, so linalool goes on the label. Put the same fragrance at the same dose in a shower gel and the level is still 0.005%, now below the 0.01% rinse-off threshold, so it stays off.

What goes stale at reformulation

A declaration describes one fragrance at one point in time. The label built from it stays right only while everything underneath holds still. Each of these changes reopens the label question:

• The fragrance house reformulates the fragrance, even slightly.
• The brand switches fragrance suppliers, even for a close match of the same scent.
• The fragrance dose in the product moves, up or down.
• The same fragrance goes into a different product type, such as a leave-on version of a rinse-off line.

None of these shows on the label itself. A label printed from last year's declaration looks exactly like a correct one, so the error survives until someone checks the documents behind it.

The 2028 date adds a check of its own. Older stock placed on the market before August 2026 with the old labeling can be made available only until July 31, 2028, so slow-moving lines and long distribution chains are worth checking now.

What a team can do about it

Most of the work is document control, applied to documents that arrive from outside.

• For each scented product sold in the EU, record the fragrance, its supplier, its dose in the product, and whether the product is leave-on or rinse-off.
• For each fragrance, hold a current allergen declaration that covers the expanded list, with its issue date or version recorded.
• Link each printed label version to the declaration it was built from.
• Ask fragrance suppliers to notify you when a fragrance changes, and treat every new declaration as a trigger to recheck each product that uses it.
• Recheck the allergen names whenever the dose, the product type or the supplier changes, before the next batch ships.
• Plan the sell-through of older stock against July 31, 2028.

One test shows where a team stands. For each scented product it sells in Europe, it should be able to name the supplier declaration the printed label was built from, and the date that declaration was issued. If the answer takes a search through old email, the label rests on memory rather than on a record.

Whether the check runs in a spreadsheet or in software, the job is the same. Read what the supplier sent, compare it with the brand's own formula and label, and keep the source of every value. It is the kind of reconciliation Smart-Suited Tech's document agent, Elara, performs on other supplier paperwork.

The risk for a small brand was never misreading the regulation. It's a label printed from last year's declaration.