Since 31 July 2026, cosmetic products that do not meet the EU's expanded fragrance-allergen labelling requirements may no longer be newly placed on the EU market. For a private label skincare buyer, the practical response is not simply to ask a supplier whether a fragrance is “EU compliant.” You need one controlled chain connecting fragrance documentation, the finished formula, applicable thresholds, the INCI list, packaging artwork, the Product Information File and the safety assessment.
This matters to creams, serums, shampoos, body care and deodorants—not only perfume. If you are sourcing from a Guangzhou skincare OEM/ODM partner, the five checks below should happen before final artwork and production approval.
Commission Regulation (EU) 2023/1545 amended Annex III of the EU Cosmetics Regulation. According to the European Commission, it introduced individual labelling requirements for 56 additional fragrance allergens and updated a number of existing entries.
Where an allergen covered by Annex III exceeds the relevant concentration in the finished cosmetic product, it must be identified individually in the ingredient list. The threshold is 0.001% for leave-on products and 0.01% for rinse-off products.
The dates require careful reading. Since 31 July 2026, products that do not comply with the new requirements may no longer be placed on the EU market. Products placed on the market before that date may, subject to the transition conditions, continue to be made available until 31 July 2028.
“Placed on the market” is a legal concept. It should not be assumed to mean the manufacturing date, export date, warehouse arrival or online listing date. Brands should ask their EU responsible person or qualified regulatory adviser to assess the evidence for each batch and commercial arrangement.
Fragrance compounds appear in many cosmetic categories. A face cream, body lotion, shampoo or deodorant can contain perfume, essential oils or other aromatic materials. “Natural fragrance” does not automatically avoid allergen review, because natural aromatic materials can contain constituents that are subject to individual labelling.
The product format also changes the calculation. A body lotion is generally a leave-on product, while a body wash is rinse-off. The applicable threshold is therefore not the same. If one fragrance is used in both products, the buyer still needs a separate finished-product assessment.
A fragrance change can also affect more than the smell. It may require updates to the ingredient list, artwork, safety assessment and PIF. This is why scent approval and artwork approval should not be managed as disconnected tasks.
Request the available composition disclosure, allergen statement and document date from the relevant fragrance supplier. Record the fragrance code and version used in the approved sample. A generic statement for a fragrance family is not enough if production uses a different code or updated composition.
The legal threshold applies to the finished cosmetic product. The buyer therefore needs the fragrance or aromatic-material inclusion level and the concentration of relevant constituents after formulation. Reviewing only the raw-material document does not complete the assessment.
Confirm whether the product is leave-on or rinse-off and whether any special use condition changes the assessment. A product name alone can be misleading. The actual directions and foreseeable use should match the category applied in the review.
The final ingredient list, primary label, carton and e-commerce information should be controlled against the same formula version. Record file names, approval dates and markets. If the fragrance, formula or raw-material supplier changes, reopen the check instead of assuming the old artwork remains valid.
The label should remain consistent with the safety assessment and PIF held for the product. The brand and EU responsible person should confirm who updates each record, who approves market artwork and who keeps the supporting documents.
The result should be a traceable file, not a one-line supplier assurance. A useful buyer table contains the SKU, formula version, fragrance code, product type, relevant threshold, INCI version, artwork version, PIF status, reviewer and approval date.
For a new product, build the allergen-document checklist before or during sampling. This allows the formula, scent and packaging artwork to develop together and reduces late-stage relabelling.
For an existing product, separate stock that was genuinely placed on the EU market before 31 July 2026 from batches intended to be newly placed after that date. Do not treat the 31 July 2028 date as permission to keep producing any old formula under the former label.
For an artwork-only refresh, first confirm that the formula and fragrance documents are unchanged. If the scent, fragrance supplier, ingredient source or formula has changed, the project may require a new calculation and document update rather than a visual-only edit.
Multilingual packaging also needs version control. Required ingredient names should not be rewritten by a translator, and marketing copy should not introduce claims that are unsupported by the approved product file.
Guangzhou Lianbiquan Biological Technology Co., Ltd., represented online by Lanthome Skincare, is based in Guangzhou. Its website presents face, hair, body and eye-care sourcing together with OEM/ODM services for overseas buyers.
For an EU-focused project, Lanthome Skincare can help organise candidate products, formula and scent versions, packaging and ingredient-list files, sampling decisions and the questions that need confirmation from raw-material suppliers or regulatory specialists. This can help a buyer decide whether to begin with a stock-product test, light customisation or a full OEM/ODM development route.
The supplier is one participant in the compliance chain, not a substitute for the EU responsible person, safety assessor or qualified local adviser. Exact product availability, price, inventory, MOQ, lead time, test documents, compliance files, logistics and overseas fulfilment capability must be confirmed for the specific product, target country and current project conditions.
Do not approve a fragranced skincare SKU until you can connect five items: the fragrance document, finished-formula calculation, product classification, approved ingredient artwork and regulatory file. If one item belongs to a different version, pause and reconcile the records.
If you are evaluating a Guangzhou skincare supplier for an EU launch, send Lanthome Skincare your target country, sales platform or channel, budget, expected quantity and product direction. We can help you compare a stock-product test, light customisation and an OEM/ODM route, while identifying which fragrance and label questions still require project-specific confirmation.
