Allergen Labelling (EU 2023/1545)
We review your fragrance documentation and tell you exactly which allergens have to appear on your label under Regulation (EU) 2023/1545 — the amendment that substantially expanded the declarable list and left a great many existing labels non-compliant.
€ 75.00
Why this became urgent
Regulation (EU) 2023/1545 amended Annex III of the Cosmetic Regulation and substantially expanded the list of fragrance allergens that must be individually named on the label. Products compliant under the previous, much shorter list are frequently not compliant under the new one, and the substances involved arrive inside the fragrance accord rather than appearing on the formulation you were given.
In practice this means a brand cannot answer the question from its own paperwork. The information sits in the fragrance house documentation, and reading it correctly is the job.
What we do
- Review the allergen declaration, IFRA certificate or fragrance breakdown from your supplier.
- Calculate the concentration of each declarable allergen in your finished product, not in the fragrance oil — which is the step most often got wrong.
- Apply the correct threshold for your product type: leave-on and rinse-off are different figures.
- Return the exact list of allergens that must be declared, with the INCI name in the form required on the label.
- Tell you where in the ingredient list they belong, according to their concentration.
What we need from you
- The allergen declaration or IFRA certificate from your fragrance house.
- The dosage of the fragrance in your finished formula.
- Whether the product is leave-on or rinse-off.
You do not need the fragrance formula itself. Accords are trade secrets and no reputable supplier will release one — the allergen declaration is what exists precisely for this purpose.
Why not just copy the supplier’s list
- The supplier lists allergens in the oil, not in your product. At 1% fragrance dosage those percentages are a hundred times too high, and using them directly declares allergens you do not need to declare.
- Thresholds differ by product type. The same fragrance in a face cream and in a shower gel produces different declarations.
- Position in the list matters. Allergens belong in descending concentration order like any other ingredient, not appended at the end.
- Over-declaring has a cost too. Naming allergens you are not required to name puts avoidable allergen warnings on your pack.
Allergen Labelling (EU 2023/1545)
Q & A
Allergens are one part of the ingredient list
The full INCI list needs correct nomenclature, descending order and restricted substances flagged. We prepare it label-ready.
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