Fragrance allergen labelling is undergoing its biggest update in over two decades.
On 23 July 2026, CTFA hosted a webinar for members on this topic. Here’s a recap of the key points covered.

From 26 to 80+ allergens

Since 2003, EU cosmetics regulation has required 26 known fragrance allergens to be declared on the label. Following a Scientific Committee on Consumer Safety (SCCS) opinion and years of consultation, Commission Regulation (EU) 2026/909 has significantly extended that list — adding 56 additional substances, bringing the total to more than 80 allergens that must now be considered for
labelling.

Importantly, this is not a reformulation mandate. The fragrance itself doesn’t need to change, no ingredients need to be removed, and the overwhelming majority of consumers will experience no adverse effects from these substances.

This is purely a transparency measure: giving allergic individuals the information they need to make an informed choice.

The thresholds haven’t changed

• Leave-on products: ≥ 0.01% (100 ppm)
• Rinse-off products: ≥ 0.001% (10 ppm)

What has changed is the scope of substances that count toward those thresholds — including constituents of natural complex substances (NCS) like essential oils and botanical extracts, not just synthetic fragrance ingredients.

Key dates

European Union

• 31 July 2026 – deadline for placing new products on the market with extended-list labelling
• 31 July 2028 – end of the transitional period; non-compliant products must be off the market entirely

South Africa

CTFA has reviewed the impact for local industry, and aligned — but locally adjusted — deadlines:

• 31 March 2027 – new products placed on the SA market must carry compliant labelling
• 31 July 2028 – non-compliant products must no longer be available on the market

This matters for two distinct groups: South African companies exporting to the EU (who must meet the EU deadlines), and companies manufacturing, importing, or distributing in South Africa (who must meet the SA deadlines).

Getting the labelling right is more nuanced than it looks

One of the more technical aspects of the new Annex III is the distinction between standalone and grouped allergen entries:

• For standalone entries, you label using the individual INCI name once the substance exceeds the threshold.
• For grouped entries, the group name is mandatory once the combined concentration of all substances in that group exceeds the threshold — even if only one of them is present. Using an individual INCI name instead of the group name is a common compliance mistake.

Allergens can also enter a formulation through multiple routes — as part of the fragrance compound, as a constituent of an NCS, as an impurity/contaminant, or as an intentional cosmetic ingredient in its own right. Where a substance is added intentionally as a cosmetic ingredient, it must be declared regardless of whether the threshold is reached. For the other routes, contributions from all sources are summed to determine whether the labelling threshold has been crossed.

What companies should be doing now

1. Review all finished products containing fragrances, essential oils, or botanical extracts.
2. Identify which of the extended allergens are present, working with ingredient suppliers.
3. Calculate the total quantity of each allergen in the final formulation, combining all contributing sources.
4. Check which allergens cross the relevant threshold for leave-on vs rinse-off products.
5. Update ingredient listings accordingly — remembering allergens must sit before colourants or at the end of the list.
6. Ensure all new products from the applicable deadline carry compliant labelling.
7. Phase out non-compliant stock before the market-withdrawal deadline.

How CTFA is supporting members

To help take the guesswork out of Step 3 and 4, CTFA is developing an Allergens Calculator, which will be made available to member companies on our website. The tool is designed to:

• Allow quick and easy input of formulation data
• Automatically calculate total allergen quantity in the final formulation across all contributing sources
• Advise whether an allergen needs to be included in the ingredient listing, based on product type (leave-on vs rinse-off)

In the meantime, if you have questions about how the extended allergens list affects your labelling, CTFA’s Technical & Regulatory Affairs team is here to help.

Dershana Jackison, Technical & Regulatory Affairs Manager – CTFA