Answer: Since 31 July 2026, a new cosmetic product first placed on the EU market must follow the expanded fragrance-allergen labelling rules in Commission Regulation (EU) 2023/1545. Products that were already placed on the EU market before that date may continue to be made available until 31 July 2028, subject to the transition conditions. For haircare, the practical check is the product’s EU market status, its rinse-off or leave-on use, the current ingredient list, and the product batch or packaging date—not a claim that “fragrance-free” or a longer INCI list proves safety.
Scope note: this is an editorial reading of EU primary sources checked on 2 October 2026. It is not a review of any named brand or product and is not medical or regulatory advice.
What changed, and why two dates matter
Regulation (EU) 2023/1545 expands the fragrance allergens that must be individually named in a cosmetic ingredient list when the relevant concentration threshold is exceeded. It amended Annex III to the EU Cosmetics Regulation. The EU transition uses two different market steps:
| Product status | Transition date | Practical reading |
|---|---|---|
| First placed on the EU market | 31 July 2026 | New products placed after the cut-off must meet the updated rules. |
| Already placed on the EU market before the cut-off | May be made available through 31 July 2028, if the transition conditions apply | Later retail availability does not by itself prove that a product was first placed on the market after the cut-off. |
“Placed on the market” and “made available” are separate steps. A seller’s shelf date, a product’s manufacture date, and the first EU supply date are not interchangeable. If a business relies on the transition, it needs records that establish the product’s status and the applicable rule; a consumer cannot determine that history from a front-of-pack claim alone.
How to read the ingredient threshold for hair products
The Regulation sets individual labelling thresholds of 0.001% for leave-on products and 0.01% for rinse-off products for the listed allergens, subject to the specific entry and product-category conditions in Annex III. A conditioner that is rinsed out and a leave-in styling cream therefore cannot automatically be assessed under the same threshold. Some entries also have product-specific restrictions or wording, so a generic “allergen list” is not a substitute for checking the relevant Annex III entry.
The threshold is a legal labelling trigger, not a measurement printed on the package. An ingredient list normally does not tell a shopper the exact concentration of each fragrance substance. The absence of a name from a photo of an ingredient panel also cannot establish that a formula is safe for a particular person: the image may be incomplete, the product may be for another market, or it may show another formula version.
A product-check sequence that avoids common mistakes
- Confirm the intended market. Identify whether the pack is intended for the EU/EEA market; identical product names may have different regional labels.
- Record the exact SKU and formula version. Capture the full front and back label, barcode, batch/lot code and any stated formula or packaging revision.
- Classify use from directions. Note whether the product is rinsed off or left on, and whether it is a spray/aerosol. Do not infer the category from marketing copy alone.
- Compare listed names against the current legal entry. Use Annex III of Regulation 1223/2009 as amended by 2023/1545. CosIng can help look up ingredient names, but the Commission says the database is informative; the Regulation and its Annexes establish the legal conditions.
- Separate label review from personal suitability. A listed allergen is not a finding that the product is unsafe for everyone. People with a known fragrance allergy should follow their clinician’s advice and check their specific allergen names; a general “sensitive scalp” claim cannot answer that question.
- For stock questions, ask for market-placement evidence. A distributor, importer or responsible person may need to document when the product was first made available on the EU market and which transitional condition applies.
What a label comparison can—and cannot—establish
| Evidence visible to a shopper | It can help establish | It cannot establish by itself |
|---|---|---|
| Full INCI list on the package | Which names the supplied label declares | Exact concentrations, complete batch history, or individual allergy risk |
| Rinse-off directions | How the product is intended to be used | Whether every legal entry uses only a generic rinse-off threshold |
| Lot code and pack images | Which physical version is being inspected | When it was first placed on the EU market |
| “Fragrance-free” or “natural” marketing | The wording a brand chose to use | Compliance with Annex III or suitability for a specific allergy |
Questions shoppers and sellers ask
Does a longer ingredient list mean a product is more dangerous?
No. The updated rule improves ingredient disclosure for identified fragrance allergens. The Commission explains that an individually listed allergen does not itself mean the product is unsafe.
Can a QR code or online product page replace the required pack information?
Do not assume so. Check the applicable EU cosmetics labelling requirements and the actual on-pack list for the product sold in the EU. A digital page may add context, but it should not be treated as proof that a pack is compliant.
Can I compare two hair products by counting allergen names?
That is not a reliable safety ranking. Products may differ in use category, formula, market and concentration; a name count does not show exposure or personal tolerance.
Sources and update note
- European Commission: Fragrance allergens labelling — transition dates, consumer interpretation and the role of the ingredient list.
- Commission Regulation (EU) 2023/1545, Official Journal / EUR-Lex — binding amendment, thresholds and Annex III conditions.
- European Commission CosIng database — ingredient lookup; informative database, not the legal authority.
Editorial method: We compared the Commission’s consumer-facing explanation with the amending Regulation. We did not inspect, test or certify any particular product. Recheck the official text before making a current compliance decision.
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