Allergens on the label: why the INCI list has grown and what to say at the counter

From 31 July 2026, every cosmetic product placed on the European market for the first time must declare a much longer list of fragrance allergens on its label than before: more than 80 substances instead of 26. Products already placed on the market before that date may remain on sale until 31 July 2028.

The result is that, at this moment, two generations of labels for the exact same product coexist on the same shelf.

This is the question customers will ask at the counter over the coming months, and it has a precise answer: the INCI list has become longer, but the formula has not changed. Those substances were already present, included under the term parfum. What has changed is the obligation to name them individually.

[INDICE:h2]

What Regulation (EU) 2023/1545 provides

The regulation, adopted by the Commission on 26 July 2023, amends Annex III to Regulation (EC) No 1223/2009 on cosmetic products. It incorporates an opinion from the Scientific Committee on Consumer Safety, which had identified 56 additional fragrance allergens capable of causing allergies in humans and which, until then, were not subject to the requirement for individual declaration.

With that addition, the list of odorous substances that must be declared separately in the INCI list when they exceed the thresholds set out in the annex has grown to more than eighty entries. Until then, there were 26.

The thresholds are lower than you might think

This is the detail that makes everything else in the discussion useful: the requirement for individual declaration is triggered at 0.001% in leave-on products and at 0.01% in rinse-off products.

In other words, seeing a name on the label means that a minimum quantity has been exceeded, not that the substance is present in abundance. It is exactly the opposite of the instinctive interpretation, and it is why a longer INCI list does not describe a more heavily loaded formula.

The two dates, which are not the same thing

The technical distinction matters because it explains why both labels coexist on the shelf.

1. 31 July 2026 — placing on the market. This is the first time a product is made available on the Union market. From this date, every product entering the market for the first time must comply with the new provisions. No leeway is provided.
2. 31 July 2028 — making available on the market. This means every subsequent supply for distribution, consumption or use. Products placed on the market before July 2026 may continue to circulate until this date; after that, even stock remaining on shelves must be withdrawn.

Three years to adapt formulas, labels and packaging materials, and five years to sell through products that were already in circulation: this is the transitional period chosen by the legislator precisely because of the large number of products involved.

Why this will come up at the counter

Because the label is the only part of the product that customers actually read, and a suddenly longer ingredient list is interpreted in only one way: they have added something to it.

The correct interpretation is the opposite. Fragrance compositions have always been declared as a group under the term parfum, which may contain dozens of different raw materials. Extracting some of them and naming them individually does not add anything to the formula: it makes visible what was already there but grouped together.

The phrase that works at the counter is short: "the cream hasn't changed; what's changed is how much it is allowed to keep hidden". Seeing more names on the label means having more information, not a less safe product.

For people with a confirmed allergy, it makes a big difference

This is why the regulation exists, and it is worth saying this first when the customer has already experienced allergic contact dermatitis.

People who know the substance they are sensitized to — typically through a dermatological patch test — may previously have encountered it hidden under the generic term parfum, with no way to identify it. Now, if it exceeds the threshold, they will find it written on the label. For that person, this is not a bureaucratic detail: it is the difference between being able to choose and not being able to.

For everyone else, the point remains the same as always: fragrance is the leading cause of contact sensitization in cosmetics, and on skin that is frequently irritated, it is the first variable to remove.

For reactive skin with a vascular component, the reasoning is the same, but the margin is even narrower: the more compromised the skin barrier, the more important it is to reduce the number of stimuli rather than add new ones.

Three things not to say

These are the most likely oversimplifications, and each creates a different problem.

• "They are safer now." The product's safety had already been assessed: what changes is the transparency of the information, not the formula's safety profile.
• "If it says it's an allergen, it is harmful." A fragrance allergen is a problem for people who are sensitized to that substance, not for the general population. The percentage of people who develop allergic contact dermatitis remains limited and stable.
• "Choose the one with the shorter list." A short list may simply belong to the old labeling system, or to a product placed on the market before July 2026. At this stage, the length of the INCI list is not an indicator of anything.

How to use it as an opportunity to advise

A customer who stops to look at the label is a customer who has already opened the conversation: this is when the pharmacy can do what no online channel can do — read the label together with them and explain which part applies to them.

There are three useful questions: whether they have ever had documented skin reactions, whether they have ever had a patch test, and which products they are currently using overall — because sensitization depends on cumulative exposure, not on a single tube.

Be mindful of the boundary: an allergy is diagnosed with a dermatological test, not by reading an INCI list. In the presence of repeated reactions, the correct advice is to see a dermatologist for a patch test, which identifies the responsible substance. The cosmetic product should be chosen afterwards, based on that result.

The regulatory landscape in the coming months

This deadline does not come alone: it coincides with two other developments that directly affect the pharmacy counter. EU Regulation 2026/78 on CMR substances and the new limits on retinol expected by May 2027 follow the same logic: gradual adaptation, with transitional periods during which products complying with different rules coexist on the shelf.

For pharmacy staff, the practical consequence is just one, and it applies to all three: during a transitional period, the date of placing on the market matters more than the appearance of the packaging. A perfectly legitimate product may have a different label from its identical counterpart that arrived three months later.

In summary

No recalls, no mandatory reformulation for safety reasons, and no alarm to raise. Just a broader information requirement, a period during which labels will not be uniform, and a concrete opportunity to explain something customers genuinely need to know.

LeLang formulas are distributed through partner pharmacies precisely because this kind of conversation needs a pharmacy counter and someone who knows how to lead it.

Sources for this article

01 Commission Regulation (EU) 2023/1545 of 26 July 2023 amending Regulation (EC) No 1223/2009 as regards the labeling of fragrance allergens in cosmetic products
02 Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products, Annex III
03 Scientific Committee on Consumer Safety, opinion on fragrance allergens in cosmetic products, SCCS/1459/11, 26–27 June 2012

On the website: EU Regulation 2026/78 on CMR substances · why buy cosmetics at a pharmacy · what sensitive skin is