EU 2023/1545, the expanded fragrance allergen disclosure rules.

The old Annex III list required 24 fragrance allergens to be named on cosmetic labels above the standard thresholds. Regulation (EU) 2023/1545, adopted on 26 July 2023, extends that list to roughly 80 substances, including additional natural extracts and isomers identified by the Scientific Committee on Consumer Safety (SCCS) as relevant skin sensitisers. Once present above 0.001% in a leave-on product or 0.01% in a rinse-off product, each allergen must appear in the ingredient list by its INCI name, in line with Article 19(1)(g) of Regulation (EC) 1223/2009.

Two dates govern the transition. From 31 July 2026, cosmetic products placed on the EU market must declare the full expanded list of fragrance allergens on the label. From 31 July 2028, products that do not meet the new labelling rules can no longer be made available, even if they were placed on the market before the first deadline. Brands typically need to repaper labels, refresh CPNP and SCPN notifications and re-issue the PIF and CPSR ahead of the 2026 cut-off.

Health Canada published a notice of intent in 2023 proposing fragrance allergen disclosure on cosmetic labels, broadly aligned with the EU's expanded list. The Canadian proposal uses similar concentration thresholds and INCI naming, with disclosure either on the label or via a digital link. Brands selling into both markets benefit from treating the EU list as the working master and mapping Canadian-specific differences as exceptions.

For one product line, this is a manual relabelling exercise. For a brand with hundreds of SKUs across multiple fragrances, contract manufacturers and markets, it is a data problem: every formulation must be re-screened against the new Annex III, every label artwork updated, every CPNP, SCPN and (where relevant) MoCRA submission re-issued, and every PIF and CPSR re-signed. Worldover holds the formulation once, screens it against the live Annex III list and Health Canada's published list, generates the updated ingredient declaration and pushes refreshed labels and notifications downstream.