From 26 to 82: The EU's Expanded Fragrance Allergen List, Explained

For more than two decades, every leave-on cosmetic sold in the European Union had to declare 26 specific fragrance compounds on its ingredient list, if present above a threshold concentration. From 31 July 2026, that list more than triples to 82 entries under Commission Regulation (EU) 2023/1545. It is the most consequential change to cosmetic fragrance labelling in the EU since the original rule was introduced.

This explainer walks through why the change is happening, what the new entries are, what it means for people with sensitive skin, and how to read a label after the deadline.

The original 26 — quick recap

Under the original 1999 SCCNFP opinion (later carried into the EU Cosmetics Directive and then into Regulation EC 1223/2009), the EU required 26 specific fragrance compounds to be declared by name on the ingredient list when present above:

• 10 ppm (0.001%) in leave-on cosmetics (creams, lotions, perfumes)
• 100 ppm (0.01%) in rinse-off cosmetics (shampoos, washes)

Below those thresholds, they could remain under the generic Parfum or Fragrance umbrella. Above them, the consumer was entitled to see the specific molecule listed — so anyone with a documented fragrance allergy could read a label and identify their trigger.

The original 26 are listed in detail in our dedicated 26 fragrance allergens article — including the most-common: linalool, limonene, citronellol, geraniol, coumarin, eugenol, citral.

Two of those 26 — HICC (Lyral) and Butylphenyl Methylpropional (Lilial) — were subsequently moved from disclosure to outright prohibition (banned 2021 and 2022 respectively) because the rate of allergic contact dermatitis they were causing was too high for disclosure alone to manage.

Why the list is expanding now

The original 26 dated from late-1990s patch-test data. Over the following two decades, three things happened in clinical dermatology:

1. Patch-test methodologies improved, becoming standardised across European Society of Contact Dermatitis (ESCD) centres.
2. More fragrance compounds came into widespread use, especially in the explosion of “natural” essential oil cosmetics.
3. Rates of fragrance contact allergy continued to rise — fragrance is now one of the top causes of contact dermatitis across Europe.

The SCCS 2012 opinion (SCCS/1459/11) reviewed the evidence and identified 82 fragrance substances with documented allergic potential at concentrations relevant to cosmetic use. The 26 original allergens are a subset; the SCCS recommended extending the disclosure regime to cover all 82.

It took more than a decade for the EU regulatory process to translate that scientific opinion into law. Commission Regulation (EU) 2023/1545 was published in July 2023, with a transition period for compliance that ends 31 July 2026 for placing new products on the market, and 31 July 2028 for products already on shelves.

The 56 new entries

The expanded list adds 56 more individually-named fragrance compounds. The new additions fall into several categories:

Common essential oil constituents

A large fraction of the new entries are molecules naturally present in essential oils that were not on the original list but show meaningful allergic reactivity:

• Camphor, present in many essential oils, especially camphor laurel
• Carvone (L- and D-), found in spearmint and caraway oils
• Cedrol and Cedryl Acetate, from cedarwood
• α-Damascone, trans-β-Damascone, δ-Damascone — rose-scented molecules
• Linalyl Acetate — present in lavender and bergamot oils
• Menthol and Menthone, from mint oils
• Myrcene, found in hops, lemongrass, basil
• Nerol and Neryl Acetate
• α-Pinene and β-Pinene, dominant in pine and many conifer oils
• Pulegone, a key constituent of pennyroyal
• Terpineol (multiple isomers)
• Vanillin and Ethyl Vanillin

This addresses a long-standing gap: a product could be labelled “natural” and “free from synthetic fragrance” while still being a vehicle for the same allergens the SCCS had identified — just delivered via essential oils rather than synthetic perfumery accord.

Modern synthetic perfumery materials

The other major category is newer synthetic fragrance ingredients that have entered widespread use since the original 26 were established:

• Acetylcedrene
• Amyl Salicylate
• trans-α-Bergamotene, Bergamot Oil, Bergamotene
• Cinnamic Aldehyde variants
• Cyclohexyl Salicylate
• trans-2-Hexenal
• Iso E Super (Octahydro-tetramethyl-acetonaphthone) — one of the dominant modern aromatic chemicals
• Lauraldehyde
• Methyl Salicylate
• β-Phellandrene
• Salicylic Aldehyde
• Trimethylbenzenepropanol (Majantol)

Combined, the new entries cover the vast majority of fragrance ingredients that account for documented contact allergy cases in recent ESCD data.

What this means for consumers

The headline change: a label that currently reads “Parfum” plus 4-6 declared allergens may, after 31 July 2026, read “Parfum” plus 10-15 declared allergens. The same fragrance hasn’t necessarily changed — many of those new allergens were already in the formulation, just under the Parfum umbrella. They’re now visible.

Practical effects:

For people without diagnosed fragrance allergy: Most cosmetics will look “busier” on the back of the bottle. A typical leave-on product with a complex perfume composition could show 10-15 individually-declared allergens where previously it showed 3-4. This is not a sign the product is more dangerous; the chemistry is unchanged.

For people with diagnosed fragrance allergy: This is a significant upgrade. If your patch test confirmed sensitivity to, say, linalyl acetate (lavender oil), you previously had no way to identify it on a label — it was hidden under Parfum. After 31 July 2026, you can read it directly. The disclosure regime finally aligns with the 82 allergens that ESCD patch tests have been checking for years.

For people choosing fragrance-free: “Fragrance-free” or Sans Parfum products carry no impact from this regulation. They contain no perfume materials and therefore no declared allergens regardless.

For users of “natural” or essential-oil-based products: Many natural products will see the largest increase in declared allergens, because essential oils contain numerous compounds simultaneously. A lavender-scented cream that previously showed only Linalool and Geraniol may now also need to show Linalyl Acetate, β-Pinene, Camphor and others. Natural ≠ allergen-free, and the new labelling makes that explicit.

What this means for brands

For brands, this is one of the largest mass relabelling exercises in EU cosmetic history. Every product containing fragrance — which is the vast majority of skincare, haircare, body care, decorative cosmetics, and perfume — needs:

1. Fragrance composition analysis to identify which of the 82 substances are present above the threshold
2. Updated ingredient lists on all packaging
3. Updated Product Information Files (PIF) held by the Responsible Person in the EU
4. Updated digital product pages showing accurate INCI lists

Brands with fragrance compositions sourced from third-party perfume houses depend on those houses providing certified allergen breakdowns. Most major perfume houses (Givaudan, Symrise, Firmenich, IFF, Mane) have been preparing for this since 2023; the lift falls hardest on small indie brands that buy fragrance from less-transparent suppliers.

The compliance timeline

The Regulation has two key dates:

• 31 July 2026: products placed on the EU market for the first time must comply
• 31 July 2028: products already on the market on the earlier date may continue to be sold until this final deadline

This means that for roughly two years, EU shelves will contain a mix of products labelled under the old 26-allergen regime and the new 82-allergen regime. Reading two products side-by-side may show very different-looking INCI lists for similar fragrance profiles, depending on when each was placed on market.

By August 2028, the transition is complete — only the new 82-disclosure regime applies.

How to read a label under the new rules

Three practical things to know:

More allergens declared does not mean less safe. A product showing 12 declared allergens is showing them because the disclosure threshold caught them, not because they were added. The same formulation under the old rules might have shown only 4. The chemistry is identical.

The position of allergens on the INCI list matters less than under the original 26. All declared allergens appear toward the end of the list, after the Parfum marker. Their relative order roughly indicates concentration but is much less informative than ingredient ordering before the Parfum marker.

If you have a known allergy, get a patch-test-confirmed allergen list from your dermatologist. The new 82-disclosure regime makes self-identification easier, but a confirmed clinical patch test (typically the standard ESCD baseline series) is still the basis for any informed avoidance.

How LuxSense handles the new allergens

Every one of the 82 allergens is in the LuxSense ingredient database, with its own profile page including:

• Sensitisation rate from public ESCD data
• Whether the allergen is present in common cosmetic categories
• Synonyms and Latin binomials for natural-source equivalents
• The disclosure threshold

When you scan a product with LuxSense, the analysis flags every disclosed allergen against your skin profile if you’ve set one. Users with confirmed fragrance allergy who add their specific allergen to their profile get immediate flagging when a scanned product contains it — across all 82 substances, not just the original 26.

Our methodology treats individual allergen sensitisation as a separate consideration from generalised “safety scoring.” A product can score well overall and still contain a specific allergen that a particular user must avoid.

FAQ

Are the new 56 allergens dangerous?

For most people, no. The allergic contact dermatitis rate for any single fragrance allergen is in the low single digits of the general population. The disclosure regime exists for the minority with confirmed sensitivity; the new entries don’t suggest the substances are inherently more risky than the original 26.

Should I avoid all 82?

Only if you have confirmed fragrance allergy and your patch test was positive to all of them — which is essentially never the case. Most fragrance-allergic patients react to a small subset (typically 1-5 specific compounds). Indiscriminate avoidance of all 82 would eliminate most fragranced cosmetics for negligible additional safety benefit if you’re not sensitised.

Why now and not in 2014 when the SCCS opinion came out?

EU regulatory processes typically take 7-12 years from scientific opinion to mandatory law. The 2012 SCCS opinion went through the Cosmetics Working Group at the European Commission, the European Parliament, member state consultation, and final publication. The 2023 regulation was the formal codification.

Will this affect UK products?

The UK MHRA hasn’t yet announced an equivalent expansion. Products dual-marketed in the EU and UK will likely use the new EU labelling by default; UK-only products may temporarily continue with the 26-allergen regime until UK regulation aligns.

Will costs go up?

Negligibly. Relabelling is a one-time cost that brands absorb as part of normal artwork refresh cycles. No reformulation is required — just disclosure.

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The expanded 82-allergen disclosure regime lands the same week as the EU INCI Glossary update and within months of the microplastic phase-out. For a single overview of all three changes, read our 2026 EU cosmetic regulation roundup.