As July 2026 approaches: the countdown to the application of Regulation (EU) 2023/1545 on allergens is underway

The recent correction to Regulation (EU) 2023/1545 published on 13 November 2025 introduces technical adjustments to three ingredients in the new list of 81 allergens. Although these are targeted changes, they directly affect the labelling and documentation that companies must have ready before 31 July 2026.

The correction published on 13 November 2025 amends three entries in Annex III of the Cosmetics Regulation:

• The denomination “Damascone” changes to “Damascenone”, the correct term for one of the key components of rose ketones.
• The INCI names of Pelargonium graveolens essential oil (geranium) are expanded to reflect its different variants and extraction methods.
• A new INCI name is introduced for Pogostemon cablin essential oil (patchouli), widely used in perfumery.

Although these adjustments may seem minor, any discrepancy between the INCI used and the INCI required by the regulation can lead to non conformities, traceability issues or even product withdrawal.

The sector is also preparing for two key dates under Regulation (EU) 2023/1545, which amends Regulation (EC) Nº1223/2009 regarding the labelling of fragrance allergens in cosmetic products:

• 31 July 2026: new products placed on the market must already comply with the new labelling requirements.
• 31 July 2028: all products —including those already marketed— must be fully adapted.

This update of the list, which increases the number of allergens from 26 to 81, responds to evidence gathered by the Scientific Committee on Consumer Safety (SCCS) regarding the rise in skin sensitisation associated with substances present in fragrances, essential oils and botanical extracts.

For cosmetic companies, the impact is clear:

• Verification of ingredients with suppliers.
• Updating labelling and technical documentation.
• Reviewing the product dossier, safety data sheets and allergen declarations.
• Planning redesigns and managing current inventories.

At Siam we support companies in interpreting and implementing the obligations arising from the EU Cosmetics Regulation. We help anticipate risks, ensure compliance and successfully navigate key regulatory milestones such as the expansion of the European list of allergens.