The short answer: **the EU’s 31 July 2026 and 31 July 2028 dates are not a blanket extension for every cosmetic or every fragrance allergen.** Commission Regulation (EU) 2023/1545 attaches transition conditions to specified Annex III entries. For entries carrying the relevant footnotes, products that do not meet the amended restrictions may be placed on the Union market only until 31 July 2026, and qualifying products may continue to be made available until 31 July 2028. Some footnotes also require compliance with the restrictions that applied on 15 August 2023.
As of this review on 20 October 2026, the first date has passed; the second is still in the future. They describe different legal steps in a supply chain. They do not mean a salon can ignore ingredient restrictions, assume a product is safe for every client, or sell any old stock regardless of its exact formulation and status.
## Read the footnote attached to the substance
Regulation 2023/1545 amends Annex III of the EU Cosmetics Regulation (EC) No 1223/2009. The amended annex lists substances and, where applicable, concentration limits and ingredient-name requirements. The regulation’s footnotes specify transitional treatment for certain entries. A practical review should therefore follow this order:
1. Identify the exact cosmetic product and market. Is it being placed on the EU market or sold in another jurisdiction?
2. Read the ingredient declaration for the INCI name. A marketing shade or fragrance name does not identify the full formula.
3. Search the exact substance in the amended Annex III, rather than relying on a social-media list of “new allergens.”
4. Read the entry’s conditions and footnote. Record any concentration threshold, product type and transition wording.
5. Separate “placing on the market” from “making available.” The two dates do different work.
6. Ask the responsible supplier or safety assessor to confirm product-specific status if the entry or formula is unclear.
## How to interpret the dates
| Date in the regulation | What the footnotes say for the entries carrying them | What not to infer |
|—|—|—|
| 31 July 2026 | Certain non-compliant products may be placed on the Union market only up to this date; some footnotes add a condition tied to restrictions applicable on 15 August 2023 | That every product must have vanished from every salon on this date |
| 31 July 2028 | Certain qualifying products already within the transition may be made available on the Union market up to this date | That all stock, every substance or every product category automatically qualifies |
“Placed on the market” and “made available” should be read in the legal context of the regulation and the product’s supply-chain history. A salon’s retail stock, a distributor’s inventory and a product first supplied after the transition date may have different facts. Do not decide a product’s compliance from the calendar alone.
## What salons and stylists can record
For a client consultation or stock review, record the product name, shade or fragrance line, batch/lot where available, supplier, market, full ingredient list and the date the stock was acquired. If a client reports a reaction, follow the salon’s own incident and referral procedure; ingredient-list review is not diagnosis. Do not promise that a product is hypoallergenic or suitable for a particular person based only on the presence or absence of one name on a label.
## Scope limitation
This article discusses EU Regulation 2023/1545 and EU market transition language. It does not describe U.S., Philippine, UK or other national labelling rules, and it is not a product-specific safety assessment. Verify the current consolidated Cosmetics Regulation and product documentation before commercial decisions.
**Primary source:** [Commission Regulation (EU) 2023/1545 on EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1545), including the amended Annex III entries and footnotes (*1), (*2) and (*4).
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