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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.

12 min read· 124+ downloads

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.

1

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.

2

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.

3

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.

4

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.

5

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.

6

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The eight things that go wrong - missing IFRA certificates, outdated CPSR, label artwork that does not fit the new ingredient list, and how to fix each one.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

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