July 31, 2026 is the single most important date in EU cosmetic labeling right now. On that date, Regulation (EU) 2023/1545 takes full effect — and it adds 56 new fragrance allergens to the mandatory declaration list in Annex III of the EU Cosmetics Regulation. Any new product placed on the EU market after that deadline must declare all relevant allergens, or it cannot legally be sold.
This article is the implementation reference that most brands are missing. We've mapped all 56 new additions with INCI names and CAS numbers, explained the declaration thresholds, and identified which product categories are most affected. For a broader introduction to the regulation, see our guide to EU Allergen Labeling Changes 2026–2028, and for overall EU label requirements, see the Complete Guide to EU Cosmetic Label Requirements.
As of April 2026, brands have under four months to audit formulations, request allergen disclosures from fragrance suppliers, redesign labels, and clear relabeling lead times. Label print runs and supplier data requests can take 8–12 weeks. Act now.
Why These 56 Allergens Were Added
The expansion isn't arbitrary. It follows years of Scientific Committee on Consumer Safety (SCCS) opinions identifying fragrance substances with documented sensitization potential. The additions fall into three main categories:
- Widely used substances newly confirmed as sensitizers. Ingredients like menthol, geranyl acetate, and linalyl acetate have been in commercial cosmetics for decades. SCCS accumulated sufficient clinical and epidemiological data to conclude their declaration is warranted.
- Essential oils containing multiple known sensitizers. Lavender oil and tea tree oil are now individually listed because they contain several previously regulated allergens (linalool, linalyl acetate, terpinen-4-ol, etc.) at concentrations that make undeclared exposure a real risk.
- Naturally occurring substances previously overlooked. Compounds like β-caryophyllene, α-pinene, and myrcene appear naturally in plant-derived ingredients. As "natural" cosmetics grew in market share, their exposure levels rose — and so did sensitization reports.
This matters beyond compliance: understanding why an allergen was added tells you where to look in your formulations. If your product contains any essential oil or complex fragrance blend, you almost certainly need to audit for new-list allergens.
Declaration Thresholds: The Same Rules Apply
The existing threshold framework extends to all 56 new additions. No new threshold calculations are required — the same rule that governed the original 26 now governs all 82:
| Product Type | Declaration Threshold | In Parts Per Million | Examples |
|---|---|---|---|
| Leave-on products | > 0.001% | > 10 ppm | Moisturizers, serums, body lotion, perfume, foundation, lip balm, deodorant |
| Rinse-off products | > 0.01% | > 100 ppm | Shampoo, conditioner, shower gel, face wash, hand soap |
Below these concentrations, no declaration is required. But you need to know your concentrations — which means requesting full allergen composition data from every fragrance supplier, at the individual substance level. Many brands discover this data gap only when they try to comply.
The Complete List: All 56 New Fragrance Allergens
The following table lists the 56 new allergens added to Annex III of Regulation 1223/2009 by EU Regulation 2023/1545 (OJ L 192, 29.7.2023). For the authoritative, legally binding text, always reference the Official Journal of the European Union directly.
Use the EU Cosmetic Allergen Checker to instantly search the full Annex III list — all 82 allergens — by name, INCI, or CAS number. Includes both the original 26 and these 56 new additions.
| # | Common Name | INCI Name | CAS Number | Typical Product Categories |
|---|---|---|---|---|
| 1 | Acetyl cedrene | Acetylcedrene | 32388-55-9 | Woody fragrances, aftershaves, masculine body care |
| 2 | Allyl heptanoate | Allyl Heptanoate | 142-19-8 | Fruity fragrances, body sprays |
| 3 | Allyl isovalerate | Allyl Isovalerate | 2835-39-4 | Fruity/tropical fragrances |
| 4 | Anisyl acetate | Anisyl Acetate | 104-21-2 | Powdery/cherry fragrances, prestige cosmetics |
| 5 | Anisyl formate | Anisyl Formate | 122-91-8 | Oriental fragrances, floral compositions |
| 6 | Benzaldehyde | Benzaldehyde | 100-52-7 | Almond/cherry fragrances, face creams, hair care |
| 7 | Benzyl acetate | Benzyl Acetate | 140-11-4 | Jasmine fragrances, floral body care (very widely used) |
| 8 | Borneol | Borneol | 507-70-0 | Herbal/camphor fragrances, masculine scents |
| 9 | Camphor | Camphor | 464-49-3 | Cooling products, lip balms, muscle rubs, anti-itch creams |
| 10 | Carvone (D/L) | Carvone | 99-49-0 | Mint-scented products, oral care, shampoos |
| 11 | β-Caryophyllene | Caryophyllene | 87-44-5 | Natural/organic cosmetics, CBD-formulated products, botanical extracts |
| 12 | Cedrol | Cedrol | 77-53-2 | Woody/cedarwood fragrances, aftershaves, hair care |
| 13 | Cinnamyl acetate | Cinnamyl Acetate | 103-54-8 | Spicy-floral fragrances, oriental compositions |
| 14 | cis-3-Hexenol | Hexenol | 928-96-1 | Fresh/green fragrances, body sprays, hair products |
| 15 | Citronellal | Citronellal | 106-23-0 | Citrus/lemon fragrances, anti-insect products, natural cosmetics |
| 16 | Citronellol | Citronellol | 106-22-9 | Rose/geranium fragrances, body lotions, soaps (very widely used) |
| 17 | p-Cresol | Cresol | 106-44-5 | Leather/smoky fragrances, masculine perfumery |
| 18 | Cyclamen aldehyde | Cyclamen Aldehyde | 103-95-7 | Floral fragrances, fine perfumery, prestige cosmetics |
| 19 | Dihydrocoumarin | Dihydrocoumarin | 119-84-6 | Sweet/hay/vanilla-type fragrances, gourmand compositions |
| 20 | Dimethylbenzyl carbinyl acetate | Dimethylbenzyl Carbinyl Acetate | 151-05-3 | Floral fragrances, white musk compositions |
| 21 | Estragole | Estragole | 140-67-0 | Anise/basil/tarragon-type fragrances, herbal cosmetics |
| 22 | Fenchyl alcohol | Fenchyl Alcohol | 1632-73-1 | Herbal/conifer fragrances, aftershaves |
| 23 | Geranyl acetate | Geranyl Acetate | 105-87-3 | Rose/geranium fragrances, floral body care, shampoos |
| 24 | Guaiacol | Guaiacol | 90-05-1 | Smoky/woody fragrances, leather accords |
| 25 | Heliotropin (piperonal) | Heliotropin | 120-57-0 | Powdery/cherry fragrances, floral cosmetics |
| 26 | trans-2-Hexenal | Hexenal | 6728-26-3 | Fresh-green fragrances, body sprays |
| 27 | 2-Hexylidene cyclopentanone | Hexylidene Cyclopentanone | 17373-89-6 | Jasmine-type fragrances, fine perfumery |
| 28 | α-Ionone | Alpha-Ionone | 127-41-3 | Violet/orris fragrances, prestige face creams |
| 29 | β-Ionone | Beta-Ionone | 14901-07-6 | Violet/woody fragrances, floral compositions |
| 30 | Isocyclocitral | Isocyclocitral | 1335-66-6 | Citrus/woody fragrances |
| 31 | Isopulegol | Isopulegol | 89-79-2 | Mint/cooling products, shampoos, body wash |
| 32 | Lavender oil (Lavandula angustifolia) | Lavandula Angustifolia Flower Oil | 8000-28-0 | Body lotions, shampoos, sleep/relaxation products, any lavender-marketed product |
| 33 | Linalyl acetate | Linalyl Acetate | 115-95-7 | Lavender/bergamot products, floral body care (very widely used) |
| 34 | Tea tree oil (Melaleuca alternifolia) | Melaleuca Alternifolia Leaf Oil | 68647-73-4 | Acne treatments, scalp products, natural/organic cosmetics, cleansers |
| 35 | Menthol | Menthol | 89-78-1 | Lip balms, cooling body gels, oral care, after-sun, shampoos |
| 36 | Methyl eugenol | Methyl Eugenol | 93-15-2 | Rose/clove/carnation fragrances (largely restricted) |
| 37 | Myrcene | Myrcene | 123-35-3 | Fresh/herbal fragrances, citrus-type products |
| 38 | Nerolidol (trans) | Nerolidol | 40716-66-3 | Floral/woody fragrances, jasmine notes |
| 39 | Nerolidol (cis) | Nerolidol | 3790-78-1 | Floral/woody fragrances |
| 40 | Neryl acetate | Neryl Acetate | 141-12-8 | Bergamot/floral fragrances, prestige cosmetics |
| 41 | Nonanal | Nonanal | 124-19-6 | Rose/waxy fragrances, fine perfumery |
| 42 | Oct-1-en-3-ol | Octenol | 3391-86-4 | Fresh/green fragrances |
| 43 | Phenylacetaldehyde | Phenylacetaldehyde | 122-78-1 | Honey/rose fragrances, fine perfumery |
| 44 | 2-Phenylethanol | Phenethyl Alcohol | 60-12-8 | Rose fragrances, floral body care (extremely widely used) |
| 45 | α-Pinene | Alpha-Pinene | 80-56-8 | Pine/forest fragrances, natural cosmetics, botanical products |
| 46 | β-Pinene | Beta-Pinene | 127-91-3 | Pine/forest fragrances, natural cosmetics |
| 47 | Pulegone | Pulegone | 89-82-7 | Pennyroyal/mint fragrances (largely restricted) |
| 48 | Safrole | Safrole | 94-59-7 | Camphor/spice fragrances (largely prohibited — must declare any trace) |
| 49 | Terpinen-4-ol | Terpinen-4-Ol | 562-74-3 | Tea tree products, natural/organic cosmetics, scalp treatments |
| 50 | α-Terpinene | Alpha-Terpinene | 99-86-5 | Natural/botanical cosmetics, citrus-type fragrances |
| 51 | γ-Terpinene | Gamma-Terpinene | 99-85-4 | Citrus fragrances, natural cosmetics |
| 52 | α-Terpineol | Terpineol | 98-55-5 | Floral/lilac fragrances, hair care, shampoos |
| 53 | Thymol | Thymol | 89-83-8 | Antiseptic products, oral care, deodorants, natural cosmetics |
| 54 | Ylang ylang oil (Cananga odorata) | Cananga Odorata Flower Oil | 83863-30-3 | Fine fragrance, hair care, luxury body care |
| 55 | 4-tert-Butylcyclohexanol | tert-Butylcyclohexanol | 98-52-2 | Woody/clean fragrances, muguet compositions |
| 56 | p-tert-Butylphenol | tert-Butylphenol | 98-54-4 | Certain fine fragrance compositions (also a known sensitizer) |
Source: EU Regulation 2023/1545 (OJ L 192, 29.7.2023), amending Annex III of Regulation (EC) No 1223/2009. Always verify against the Official Journal for the legally binding text. The above 56 entries are in addition to the original 26 allergens already required under the Cosmetics Regulation.
Key Allergen Deep-Dives: Most Common in Formulations
Six substances deserve particular attention — either because they're new additions that will catch brands off-guard, or because they're already in the original 26 but appear so frequently that proper compliance is still widespread. Understanding the context behind each allergen helps identify where it's hiding in your formulations.
The addition of menthol surprises many formulators. It's used in lip balms, after-sun gels, cooling body creams, shampoos, and oral care products precisely because consumers expect that "cooling tingle." But SCCS found sufficient contact sensitization data to mandate declaration. Any product marketed with a cooling or mint effect almost certainly contains menthol above the leave-on threshold. Check your fragrance composition breakdowns urgently.
Lavender oil is simultaneously one of the most popular cosmetic ingredients and one of the most widespread sources of fragrance sensitization. It contains linalool (original 26 allergen) and linalyl acetate (one of the 56 new additions) — both declarable on their own. Now lavender oil itself must also be declared by name when present above threshold. Brands using whole lavender oil in body lotions, sleep sprays, or hair care products face a double-declaration requirement: the oil and its individual sensitizing components if present in sufficient quantity.
Natural and organic cosmetic brands are particularly exposed here. Tea tree oil is a staple of acne treatments, scalp serums, and "natural" cleansers — often at concentrations well above the declaration threshold. Three of its major components (terpinen-4-ol, α-terpinene, γ-terpinene) are also independently listed among the 56 new additions, meaning products with tea tree oil face multiple declaration requirements. This is the addition that will cause the most compliance failures among indie and natural beauty brands.
Linalyl acetate is the ester form of linalool (the original-26 alcohol) and is the dominant component of true lavender oil, clary sage oil, and bergamot. It's one of the highest-volume fragrance ingredients globally. Products with lavender or bergamot positioning almost certainly contain linalyl acetate above the declaration threshold — often in direct combination with linalool, which was already required to be declared.
Citral has been declarable since 2003. It's included here because it's one of the most frequently missed declarations — not because it's new, but because it appears in countless products via lemongrass oil, lemon myrtle oil, and citrus essential oils. Brands that have been using "parfum" as an umbrella declaration may have never itemized citral. As you audit for the 56 new allergens, audit for original-26 compliance simultaneously. Many brands discover gaps in both lists at the same time.
Geraniol has been in the original 26 since 2003 and is one of the most common fragrance allergens documented in clinical patch testing. Its companion compounds — geranyl acetate (new addition #23) and nerolidol (new additions #38 and #39) — are now also required to be declared. Brands using rose oil or geranium oil are likely exposing consumers to geraniol, geranyl acetate, and potentially nerolidol — three separate declaration requirements from a single source ingredient.
Compliance Timeline: New Products vs. Existing Stock
| Milestone | Date | What It Means | Status |
|---|---|---|---|
| Regulation published | July 2023 | EU 2023/1545 entered into force. 3-year transition window began. | Done |
| New products deadline | July 31, 2026 | All products placed on the EU market after this date must declare all 82 allergens above threshold. | 106 days |
| Existing stock deadline | July 31, 2028 | Products manufactured before July 31, 2026 may continue to circulate until this date. Then all stock must comply. | 2+ years |
The 2028 deadline applies only to products already in the supply chain before July 31, 2026. Anything manufactured after that date must comply with the full 82-allergen list from day one — regardless of how long it sits in a warehouse.
How to Audit Your Labels for Compliance: Step-by-Step
Most brands will need 3–6 months to complete a proper allergen audit across their portfolio. Here's the process:
- List every product and its full formula Pull your complete formulation database — every INCI ingredient at actual usage concentrations, including fragrance compositions, essential oils, and natural extracts.
- Request allergen breakdowns from all fragrance suppliers Ask each fragrance supplier for a written declaration covering all 82 allergens under EU 2023/1545 (the original 26 plus the 56 new additions) with exact concentrations in the fragrance blend as supplied. If they can't provide this, escalate. This data is a compliance requirement, not a courtesy.
- Calculate allergen concentrations in the finished product Apply your fragrance usage level to the supplier's allergen data to determine each allergen's concentration in the finished product. A 1% fragrance usage level × 2% linalyl acetate content in the fragrance = 0.02% linalyl acetate in the product — above the 0.001% leave-on threshold.
- Cross-reference against the full 82-allergen list Compare calculated concentrations against both the original 26 and the 56 new additions. Flag any allergen present above the applicable threshold (0.001% leave-on / 0.01% rinse-off) that is not currently declared on your label.
- Identify reformulation needs Some allergens on the list (methyl eugenol, safrole, pulegone, atranol, chloroatranol, HICC) are prohibited or severely restricted, not merely declarable. Products containing these above the legal limit must be reformulated, not just relabeled.
- Update label artwork and product information files Add all newly required allergen declarations to the ingredient list. Update your Product Information File (PIF) and safety assessment to reflect the revised allergen mapping. Notify your Responsible Person of all changes.
- Reprint and restock before the deadline Factor in label printing lead times (typically 4–8 weeks for custom labels), stock clearance timelines, and distribution delays. Work backward from July 31, 2026 — not forward from today.
Many brands list "parfum" or "fragrance" and assume they've declared everything. This doesn't work — "parfum" is a catch-all for the fragrance blend itself, but individual allergens above threshold must be declared by their specific INCI names, separately from "parfum." Listing "parfum" doesn't exempt you from allergen declarations. Both must appear.
For the complete EU compliance picture — including responsible person requirements, batch codes, and INCI formatting rules — see our Complete Guide to EU Cosmetic Label Requirements. For who is legally liable for your label's compliance, see our EU Responsible Person guide. To run through a full verification workflow before production, use our 5-step EU cosmetic label compliance checklist.
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Run Free Allergen Audit →Frequently Asked Questions
EU Regulation 2023/1545 added 56 new fragrance allergens to the mandatory declaration list in Annex III of Regulation 1223/2009. Key additions include menthol, linalyl acetate, citronellol, lavender oil (Lavandula angustifolia), tea tree oil (Melaleuca alternifolia), β-caryophyllene, α-pinene, geranyl acetate, and 2-phenylethanol, among others. The full list with CAS numbers is published in the Official Journal of the EU (OJ L 192, 29.7.2023). Combined with the original 26 allergens, the total now stands at 82 declarable fragrance substances.
All 82 EU fragrance allergens must be declared when present above 0.001% (10 ppm) in leave-on products (moisturizers, perfumes, body lotions, lip balms) and above 0.01% (100 ppm) in rinse-off products (shampoos, shower gels, face washes). These thresholds apply equally to the original 26 and the 56 new additions under 2023/1545.
New products placed on the EU market must comply by July 31, 2026. Products already in circulation before that date have until July 31, 2028 to sell through or be relabeled. Any product manufactured after July 31, 2026 must comply immediately — the 2028 date is for existing stock only, not a general grace period.
Yes. Menthol (CAS 89-78-1, INCI: Menthol) is one of the 56 new fragrance allergens under EU Regulation 2023/1545. It must be declared by name on EU cosmetic labels when present above 0.001% in leave-on products or 0.01% in rinse-off products. This affects lip balms, cooling gels, after-sun products, shampoos, and oral care cosmetics from July 31, 2026.
Yes. Lavandula angustifolia flower oil (lavender oil, CAS 8000-28-0) was added as one of the 56 new fragrance allergens. Products using lavender oil face a double-declaration requirement: the oil itself must be declared, and individual allergen components like linalool (original 26) and linalyl acetate (new 56) must also be declared separately if present above threshold.
Yes. Melaleuca alternifolia leaf oil (tea tree oil, CAS 68647-73-4) was added as one of the 56 new allergens. Three of its major components — terpinen-4-ol, α-terpinene, and γ-terpinene — are also independently listed, creating multiple declaration requirements from a single source ingredient. Natural and organic brands using tea tree oil in acne or scalp products are among the most affected.
Non-compliant cosmetics can be withdrawn from the EU market by national authorities. Fines range from €5,000 to over €100,000 depending on jurisdiction. Recall costs are borne by the brand. The EU Responsible Person bears primary legal liability. Germany, France, and the Netherlands are the most active enforcement jurisdictions.
Yes. All 56 new allergens must be declared in rinse-off products (shampoos, shower gels, face washes) when present above the 0.01% (100 ppm) threshold. The declaration rules apply to all cosmetics sold in the EU, regardless of product category.
Several substances on the extended list face prohibition or concentration limits, not just declaration requirements. Methyl eugenol, safrole, pulegone, and certain high-sensitization compounds are restricted or banned above specific concentrations under Annex II or Annex III of the Cosmetics Regulation. If these are present above legal limits, relabeling is not sufficient — the product must be reformulated.