From 31 July 2026, a cosmetic product newly placed on the EU market has to name more than 80 fragrance allergens in its ingredient list rather than 26. Northern Ireland is in scope. Great Britain, for now, is not. Which means the same tube of moisturiser can carry two different ingredient lists depending on where you sell it. Your regulatory team has spent time and energy getting the artwork right. But is this consistent with what your retailer pages are showing?
In short: Regulation (EU) 2023/1545 expands the EU fragrance allergen declaration list from 26 substances to more than 80. It applies to products newly placed on the market from 31 July 2026, with existing stock saleable until 31 July 2028. It covers the EU, the EEA and Northern Ireland. Great Britain has not adopted it, though UK brands selling into the EU are caught by it and are permitted to use the longer EU label in GB if they prefer to run one version. Every one of those choices has to be reflected on the retailer pages that shoppers actually read. This is the commercial companion to our pillar guide on digital shelf analytics for beauty and personal care brands, which covers variant complexity, visual content and AI-driven discovery in full.
Table of Contents
- Why does the same product now carry two ingredient lists?
- Does this affect you if you sell in Great Britain?
- Why do retailer pages drift out of step with the pack?
- What happens during the two-year sell-through window?
- How do you find the listings that are wrong?
- What this means for your digital shelf strategy
Why does the same product now carry two ingredient lists?
Regulation (EU) 2023/1545 amended the EU Cosmetics Regulation to expand the list of fragrance allergens that must be named individually in the ingredient list rather than sitting anonymously inside "parfum". The old list covered 26 substances but the regulation adds 56 more, taking the total past 80 substances and grouped entries. If you want the full list, it is set out entry by entry in the annex to the regulation itself, and Cosmetics Europe has published detailed guidance on how the grouping names are meant to be applied in practice. A corrigendum published in late 2025 tidied up one INCI name and one essential oil entry without moving any deadlines.
What about thresholds? Declaration is required above 0.001% in leave-on products and 0.01% in rinse-off products. At that level the change reaches a long way past fine fragrance and into moisturisers, deodorants, shampoos, baby care and plenty of products marketed as gentle or unscented.
The key dates to be aware of.. From 31 July 2026, anything newly placed on the EU market has to comply. Anything already made available on the EU market can be sold through until 31 July 2028.
Geography matters just as much. The regulation applies across the EU and the EEA, and in Northern Ireland under the Windsor Framework. Great Britain sits outside it.
Compliance was designed around the pack. Shoppers read the ingredient list on a retailer page.
Does this affect you if you sell in Great Britain?
Yes, though not in the way you might expect. The UK Cosmetics Regulation still requires the original 26 allergens and no decision has been taken on whether Great Britain will follow the EU. So it is easy to assume Brexit divergence means the change can be ignored on this side of the Channel.
Two things to consider here. The first is that the obligation follows the market, not the company, so if you place product on the EU market, including through online sales aimed at EU consumers, you comply, wherever you are based. Most European beauty brands of any scale are therefore in scope for at least part of their portfolio.
The second is that the CTPA has secured Assured Advice through its Primary Authority Partnership with Trading Standards confirming that a label carrying the fuller EU declaration will still be accepted as compliant in Great Britain. Over-labelling, in other words, is fine, meaning you have a choice: one label across every market and accept a longer list in GB, or run market-specific versions and keep the GB pack shorter.
Neither answer is wrong. Both create work on the digital shelf. Run one label and your GB retailer pages need updating to match a pack that has changed even though the law did not require it. Run two and you need to know, for every listing, which version belongs there.
Why do retailer pages drift out of step with the pack?
Ingredient lists reach retailer pages by several routes: syndication feeds, retailer content teams, distributor uploads and, more often than anyone likes to admit, someone typing them in. Each route runs on its own update cycle, and none of them has a trigger that fires when a regulation changes.
You will recognise the pattern if you have ever audited a large portfolio. The pack leaving the warehouse is right. The document on the brand site is right. The marketplace listing still carries copy loaded three years ago, because nothing in that chain ever told it to change.
There is a second failure that is easier to miss though. Retailer ingredient fields have character limits, so a longer allergen declaration can push a list past that limit, so the complete text sits happily in the feed while the page shows a version that stops mid-sentence. The listing looks populated. The information a sensitive shopper came for is missing..
For most product content, drift is a quality problem you get round to. For an ingredient list it is a trust problem, and ingredient transparency is one of the main reasons a beauty shopper opens a product page at all.
What happens during the two-year sell-through window?
Between now and July 2028, compliant and pre-existing stock will both be legitimately on sale. A retailer may hold both at once. A marketplace seller almost certainly will.
This means you cannot simply push one corrected ingredient list to every listing and consider it closed, because for some of those listings the older version is still the accurate one. What you need instead is a view of which listing, on which retailer, in which market, carries which version, and whether it matches what that retailer is currently shipping. The answer changes as stock turns over, and it turns over at a different rate in every market.
Most content problems have one right answer.
For the next two years, this one has two.
How do you find the listings that are wrong?
It starts with defining what right looks like for each product in each market, which is a content target rather than a completeness score. This is the distinction that catches teams out: a listing can score well on content quality and still carry the wrong allergen declaration for the market it sits in. Nothing is missing. It is just wrong.
Content Optimizer brings brand targets, category benchmarks and retailer field requirements together, so you are comparing what a listing says against what it should say for that product, at that retailer, in that market. Gap detection flags the listings that fall short and confirms once a correction has gone live, which matters when the same fix has to land across dozens of retailers and you need to know which ones actually took it.
The useful output is a short list, not an audit. Rather than reviewing every page, you see the listings that are wrong, ranked by where being wrong costs you most.
What this means for your digital shelf strategy
Your regulatory team has handled the pack. The commercial risk has moved into the gap between what is in the box and what a retailer publishes about it, in whichever of your markets has not caught up. That gap is invisible until someone looks for it.
Doing this across markets and retailers depends on accurate, current data. The eStore platform delivers 99.7% data accuracy across more than 3,000 retailer websites in over 70 markets, so you can see which listings carry which version, where a field has quietly truncated, and where a correction never landed.
For the full picture on variant complexity, visual content standards and AI-driven discovery in this category, read the complete guide to digital shelf analytics for beauty and personal care brands.
Key Takeaways
- Regulation (EU) 2023/1545 expands the EU fragrance allergen declaration list from 26 substances to more than 80, applying to products newly placed on the market from 31 July 2026.
- Thresholds of 0.001% for leave-on and 0.01% for rinse-off products take the change well beyond fine fragrance and into everyday personal care.
- The regulation covers the EU, the EEA and Northern Ireland. Great Britain has not adopted it, but brands selling into the EU are caught regardless of where they are based, and the longer EU label is accepted in GB if you prefer to run one version.
- Existing stock remains saleable until 31 July 2028, so both versions will be legitimately live at once and a single mass update to every listing will not work.
- Retailer character limits can truncate a longer declaration, leaving a listing that looks complete and is not. The eStore platform provides 99.7% data accuracy across more than 3,000 retailer websites.
Frequently Asked Questions
What changed on 31 July 2026 for cosmetic ingredient lists in the EU?
Regulation (EU) 2023/1545 expanded the list of fragrance allergens that must be declared individually in the ingredient list from 26 substances to more than 80. Products newly placed on the EU market from that date must comply. Products already made available may continue to be sold until 31 July 2028.
Does the change apply in the United Kingdom?
It applies in Northern Ireland under the Windsor Framework. It does not currently apply in Great Britain, where the UK Cosmetics Regulation still requires the original 26 allergens and no decision has been taken on whether to align. UK brands that place product on the EU market, including through online sales to EU consumers, do have to comply for those products.
Can a brand use the same label in Great Britain and the EU?
Yes. The CTPA has secured Assured Advice through its Primary Authority Partnership with Trading Standards confirming that a label carrying the fuller EU declaration is accepted as compliant in Great Britain. That makes running a single label a practical option, though it does mean GB retailer listings need updating to match a pack that has changed.
Why would a retailer listing show the wrong ingredient list?
Ingredient content reaches retailer pages through syndication feeds, retailer content teams, distributor uploads and manual entry, each on its own update cycle, and a regulatory change rarely triggers all of them. Retailer field character limits can also truncate a longer declaration so the page shows only part of it.
Turn Content Accuracy Into Commercial Advantage
If you lead ecommerce or category for a beauty or personal care brand and want to know which of your listings carry the right ingredient declaration in each market, we would welcome the chance to walk through how it works. Speak to our team for a detailed look at content monitoring across your retailers and markets.
References and Further Reading
- EUR-Lex, Commission Regulation (EU) 2023/1545 - the amending regulation, with the full list of new Annex III entries and the transition dates
- Cosmetics Europe - industry guidance on applying the expanded allergen requirements and grouping names
- CTPA - UK industry position, including the joint CTPA and IFRA UK note on placing on the market
- COSlaw - EU cosmetics regulatory analysis and deadline tracking
