EU Fragrance Allergen and Formaldehyde Labelling: What Brands Must Check Now

Two EU labelling deadlines passed on the same day this summer, 31 July 2026. New products must now declare more than 80 fragrance allergens, and every formaldehyde-releasing product on EU shelves must carry the "Releases formaldehyde" warning above 0.001%. Great Britain is running to its own timetable. For brands selling in both markets, one master label file can no longer be assumed to cover both.

What changed on 31 July 2026 Expanded fragrance allergens (Regulation (EU) 2023/1545). New products placed on the EU market must name each listed allergen above 0.001% in leave-on products or 0.01% in rinse-off products. Products placed on the market before 31 July 2026 can still be sold until 31 July 2028.

Releases formaldehyde" warning (Regulation (EU) 2022/1181).

Any product releasing more than 0.001% (10 ppm) formaldehyde must carry the warning. There is no sell-through period left: non-compliant stock should have been withdrawn by 31 July 2026.

The formaldehyde rule has been mandatory for newly placed products since July 2024. July 2026 was the end of its sell-through period, which means every unit on EU shelves must now comply. Only the allergen rule still has a two-year window for older stock.

Fragrance allergens: where enforcement attention lands

The expanded list added 56 substances, including many essential oils and their components. Expect regulators and retailers to focus on:

• Natural and essential-oil-heavy products, where several allergens can cross the threshold at once • Group names, such as "Lemongrass Oil" or "Rose Flower Oil/Extract", which must be used instead of supplier INCI names • Raw material quality, as some entries now set oxidation limits for terpenes such as limonene and pinene • The 2025 corrigendum, which widened the geranium and patchouli entries and corrected a rose ketone name The two-year window is for stock already placed on the market, not for batches still in production. Any batch entering the EU market after 31 July 2026 needs the new labelling, even if it was made earlier.

Formaldehyde: the warning that now applies to every unit

The threshold for the warning dropped from 0.05% to 0.001%, a fiftyfold cut, and the wording changed from "contains formaldehyde" to "releases formaldehyde". It covers total free formaldehyde released by any combination of preservatives listed in Annex V, such as DMDM hydantoin, imidazolidinyl urea and sodium hydroxymethylglycinate.

At 10 ppm, many products using formaldehyde releasers will need the warning even at normal use levels. Many brands are choosing to reformulate instead.

Great Britain: same direction, different clock

GB has adopted the 0.001% formaldehyde threshold through SI 2026/23, but on its own transition timetable. It has not adopted the EU's expanded allergen list, so GB still uses the earlier list. Separately, SI 2026/109 restricts hexyl salicylate and adds further CMR bans with GB-specific deadlines that don't match the EU's equivalent Regulation (EU) 2026/78. Northern Ireland follows the EU.

How the two markets compare:

• Fragrance allergens : The EU and Northern Ireland require the 80+ list for new products since 31 July 2026. Great Britain still uses the earlier list.

• Formaldehyde warning : The EU and Northern Ireland apply the 0.001% threshold to all stock since 31 July 2026. Great Britain has adopted the same threshold through SI 2026/23, with its own transition dates.

• New CMR bans and hexyl salicylate : The EU acted through Regulation (EU) 2026/78, applying from May 2026. Great Britain acted through SI 2026/23 and SI 2026/109, with placing deadlines in July and August 2026 and off-shelf deadlines in early 2027.

• Notification : The EU and Northern Ireland use CPNP. Great Britain uses SCPN.

Why one master label may no longer work

A label built for the EU will usually be legal in GB too: listing extra allergens is allowed. The risk runs the other way. A GB-compliant label may now be non-compliant in the EU or Northern Ireland, and deadlines for the same substance can fall months apart. Brands using a single master file should check it against both rulebooks, rather than assuming one covers the other.

Your audit checklist

1. Map every SKU to its markets: GB, Northern Ireland, EU.
2. Request updated allergen statements from fragrance and essential oil suppliers, covering the full 2023/1545 list and the 2025 corrigendum.
3. Recalculate allergen levels in each finished product against the 0.001% and 0.01% thresholds.
4. Identify formaldehyde releasers in every formula and get released formaldehyde measured or calculated.
5. Check EU stock on hand by placing date. Pre-31 July 2026 stock can sell through to July 2028 for allergens only. Stock without a required formaldehyde warning must come off shelves now.
6. Decide your label strategy: an EU-standard label for all markets, or separate GB and EU artwork.
7. Update CPSRs, PIFs and notifications in CPNP and SCPN where labelling or formulas change.
8. Brief distributors and retailers on what must be withdrawn, and keep records.

FAQs

Can I still sell old-label stock in the EU? For the allergen change, yes, if it was placed on the market before 31 July 2026 and is sold by 31 July 2028. For the formaldehyde warning, no. Does GB require the 80+ allergens? Not currently. GB still uses the earlier list. Check for updates before each print run.

Is "releases formaldehyde" required in GB? GB has adopted the 0.001% threshold. Confirm the wording and transition dates in SI 2026/23 for your products.

How Labelring helps

Labelring holds one record per product and shows what each market needs, flagging allergens above threshold, formaldehyde releasers and label differences between GB and the EU, so your PIF and artwork stay right for every market.

Sources:

EU Regulation 2022/1181 text (via LawPlayer/EUR-Lex) · CosmeticOBS: 2022/1181 full implementation on 31 July 2026 · Certified Cosmetics: EU allergen rules in effect, GB position · Freyr: OPSS annex amendments (SI 2026/23) · Cosmeservice: SI 2026/109