EU fragrance allergen changes: a 2026 and 2028 action plan

Review EU fragrance-allergen changes against the stock record

This guide is scoped to the EU fragrance-allergen labelling change under Regulation (EU) 2023/1545. Northern Ireland applicability needs a separate check. It makes no assumption that a GB rule or transition is equivalent.

As at 16 October 2026, the first transition date has already passed. The European Commission guidance distinguishes the restriction on placing nonconforming products on the EU market from the remaining period for qualifying products already placed on the market. It identifies 31 July 2026 and 31 July 2028 respectively. The relevant conditions must be checked against Regulation (EU) 2023/1545 and the current Annex III.

Build two evidence questions

First ask whether the current product composition and artwork meet the applicable requirements. Record the exact specification, supplier information, product type and ingredient statement under review. A fragrance trade name is not enough to establish the relevant substances or their quantities.

Then ask whether a specific stock group can rely on a transition. Identify the evidence of placing on the market and the relevant dates and conditions. A manufacturing date, an internal stock receipt or an artwork print date should not be treated as proof of that legal event without checking what the record actually establishes.

Three fictional stock groups

Stock group A has an internal manufacturing record dated before the first transition date, but no evidence identifying a placing-on-market event. The example finding is Unresolved. The date on the batch sheet alone has not answered the question.

Stock group B has a distribution record that the reviewer has not yet examined. The action is to identify the transaction, market and product/stock link, then obtain the specialist's finding on the conditions. A document's presence does not establish that the transition applies.

Stock group C is a proposed new supply route with current artwork still awaiting review. Its owner needs a current composition and artwork review. It cannot borrow group B's conclusion merely because both groups use the same product name.

The working CSV shows these three groups with open findings. No example grants permission to place, supply or relabel stock.

Reconcile the records

Keep the supplier composition information, formulation revision, safety-assessment information and ingredient artwork connected. The Commission identifies consistency between composition, labelling, the PIF and safety assessment as part of the business review. A new artwork file should have its own version and review history.

Allocate the next action

Give each stock question an owner, an evidence request and a specialist decision field. Confirm the exact transition language and current provisions before relying on an outcome. The remaining July 2028 date is not a general extension for every batch or every future supply. Keep the source-retrieval date distinct from all legal and stock-event dates.

Sources and legal dates