Expanded EU Allergen List in Cosmetics: First Compliance Deadline is Approaching

2026.04.27

In light of the amendment Regulation (EU) 2023/1545, adopted on July 26, 2024 and being effective on August 16, 2023, expanding allergen labeling requirement from 26 to 80+ substances) on cosmetic products in EU market, the industry was given in 3-year period of time to do necessary adjustment on the product formulations and containers to ensure the product complying the new requirements. Now the first key transition deadline is fast approaching.

As outlined in the regulation, new cosmetic product placing on the EU market must comply with the expanded allergen labeling requirement by July 31, 2026. This marks the first phase implementation and will directly impact product formulation, artwork, and compliance.

What this means for you

New product (and its label) placing on the market after the deadline must comply with the expanded allergen listing requirement
Cosmetic Product Safety Report (CPSR) and Product Information File (PIF) shall reflect the updated requirement
Non-compliant products may face market access restrictions.

What you should do

Review product portfolis
Identify any affected items that may containe expanded list of allergens above labeling threshold
Review and update labeling content (ingredientd declaration), when necessary.
Ensure alignement of information across formulations, allergen documentation, safety assessment, labeling content, regulatory documents.
Coordinate with the safety assessors, responsible persons and supply chain parties for compliance.

How the allergens should be labelled

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