EU Fragrance Allergen Compliance Checklist
From 31 July 2026, 56 new allergens must be declared on-pack. The seven-step checklist for indie brands selling into the EU.
Regulation EU 2023/1545 expands the fragrance allergen declaration list from 26 to 82 substances on 31 July 2026. Stock placed on the EU market before the deadline can sell through to 2028; anything entering the supply chain after must comply. This checklist is the seven-step run we do with EU-selling clients in LaunchOS, with realistic timelines, supplier letter templates, and the cutover plan.
What's inside
Everything you need, nothing you don't.
The 56 new allergens explained
A plain-English breakdown of which substances are now in scope, the leave-on (0.001%) and rinse-off (0.01%) thresholds, and how to read an IFRA certificate against the new Annex III.
Seven-step compliance run
From listing fragranced SKUs through to printing new labels, including the supplier letter wording that gets a fragrance house to issue an updated IFRA certificate.
Realistic timeline
Phone call to fragrance house, IFRA certificate received, concentration calculation, label artwork, PIF and CPSR update, CPNP re-notification, print and apply - with realistic durations for each step.
Sell-through window playbook
How to co-ordinate the cutover date with your contract manufacturer so old-label stock placed before 31 July keeps selling through to 2028 and new-label stock takes over cleanly.
Retailer notification template
What to tell Cult Beauty, Space NK, Boots, Selfridges, and Sephora EU about your cutover date so they plan inventory windows around you instead of rejecting deliveries.
Failure-mode list
The eight things that go wrong - missing IFRA certificates, outdated CPSR, label artwork that does not fit the new ingredient list, and how to fix each one.
Who it's for
EU-selling indie beauty brands with fragranced SKUs
Brand owners working with third-party fragrance compounders
Operations leads coordinating between contract manufacturers and the EU Responsible Person
UK brands shipping into the EU under post-Brexit arrangements
Sample insights from this resource
12 weeks
to the deadline