EU fragrance allergen labelling 2026: what small cosmetic makers need to know
Since 31 July 2026, cosmetics newly placed on the EU market must declare far more fragrance allergens than before. The list has grown from 26 substances to around 81, and it now includes common essential oil components such as menthol, camphor and linalyl acetate, along with many essential oils themselves. If you make creams, balms, soaps or serums with essential oils or fragrance, this affects your labels.
This guide explains what changed, who it applies to, and how to work out which allergens belong on your ingredient list.
What changed
EU Regulation 2023/1545 amended the EU Cosmetics Regulation to expand the list of fragrance allergens that must be named on the label. Before, makers had to declare 24 substances (the original 26, minus two that are now banned). The expanded list adds:
- Single substances such as menthol, camphor, vanillin, linalyl acetate, terpineol, carvone, anethole, benzaldehyde, geranyl acetate and pinene.
- Natural extracts and essential oils, including lavender, peppermint, spearmint, eucalyptus, geranium, patchouli, sandalwood, ylang ylang, jasmine, rose, clove, cinnamon, bay leaf, lemongrass, bergamot, lemon peel and bitter orange.
- Restricted substances that now need labelling, such as turpentine, terpinolene, alpha-terpinene, methyl salicylate and Peru balsam.
The labelling thresholds have not changed:
- Leave-on products (creams, lotions, serums, balms): declare an allergen if it is present above 0.001% of the finished product.
- Rinse-off products (cleansers, shampoos, soaps, shower gels): declare an allergen if it is present above 0.01%.
The key dates
- 31 July 2026: products placed on the EU market from this date must carry the expanded allergen declarations.
- 31 July 2028: products placed on the EU market before 31 July 2026 can stay on sale until this date. After that, they must comply too.
Does this apply to UK makers?
It depends on where you sell.
- Selling into the EU, including online orders shipped to EU customers: yes, your labels must follow the expanded list.
- Northern Ireland: under the Windsor Framework, the EU cosmetics rules apply there, so the expanded list applies too.
- Great Britain only: at the time of writing (October 2026), Great Britain has not adopted the expanded list. GB labels still follow the original allergen list. The Office for Product Safety and Standards (OPSS) could adopt the new list in future, so check its current guidance before you print labels.
Many small brands are choosing to label to the EU list now. It means one label works for every market, and you won't have to reprint if Great Britain follows the EU.
Why essential oils need extra care
Essential oils are mixtures of many natural chemicals, and several of those chemicals are allergens in their own right. Lavender oil, for example, is rich in linalool and linalyl acetate. Lemon and orange oils are mostly limonene. Peppermint oil contains menthol and limonene.
So when you use an essential oil, you need to check two things:
- The oil itself. Many essential oils are now on the list by name. If you use the oil directly, it already appears in your ingredient list under its INCI name (for example, Lavandula Angustifolia Oil).
- The allergens inside the oil. Each allergen component, such as linalool, limonene or menthol, must be named separately if its amount in the finished product is above the threshold.
The same applies to fragrance oils (listed as Parfum). Your fragrance supplier's allergen declaration tells you which allergens the fragrance contains and how much.
How to work out which allergens to declare
You need your supplier's allergen declaration (sometimes part of the IFRA certificate or the technical data pack) for each essential oil or fragrance. It lists the allergens in that oil and their percentages.
Then, for each allergen:
% in your product = % of the oil in your formula × % of the allergen in the oil ÷ 100
Worked example: a face cream contains 0.5% lavender essential oil. The supplier's declaration says the oil contains 30% linalool and 0.1% coumarin.
- Linalool: 0.5 × 30 ÷ 100 = 0.15%. That is well above 0.001%, so linalool must be declared.
- Coumarin: 0.5 × 0.1 ÷ 100 = 0.0005%. That is below 0.001%, so coumarin does not need to be declared.
If the same allergen comes from more than one oil (limonene from both orange and lemon oil, say), add the amounts together before comparing with the threshold.
Declared allergens go in your ingredient list by their INCI name. Like any ingredient present below 1%, they can appear in any order after the ingredients above 1%.
Practical tips
- Ask for up-to-date declarations. Some supplier documents still cover only the original 26 allergens. Ask your suppliers for declarations that cover the expanded list.
- Use batch-specific data. Natural oils vary from harvest to harvest. When you change supplier or batch, check the new declaration.
- Remember the low leave-on threshold. At 0.001%, even a small amount of essential oil in a leave-on product will usually trigger several declarations.
- Update your safety report. Your Cosmetic Product Safety Report and Product Information File should reflect your current formula and labels.
Let our calculator do the maths
Our free Formula Calculator includes an allergen check built on the EU's expanded list. Choose leave-on or rinse-off, enter the allergen percentages from your supplier's declaration for each essential oil or fragrance, and the calculator:
- works out the amount of each allergen in your finished product
- adds up allergens that come from more than one oil
- tells you which ones must be declared
- adds them to your INCI ingredient list in the right place
- includes everything in a downloadable PDF formula sheet
This article is general guidance, not legal advice. Labelling requirements depend on where you sell, and every cosmetic product must have a safety assessment by a qualified safety assessor before it is placed on the market.