EU cosmetics rules 2026–2027: fragrance allergens, INCI glossary, CMR bans and which reports to update

For a brand outside the EU this means two things. A CPSR written before 2025 may describe a label and a formula that can no longer be placed on the market. And the cheapest moment to fix it is before the next production run, not after a distributor or an inspector asks.

Timeline: EU cosmetics deadlines 2025–2029

Always check the current text on EUR-Lex. The Omnibus IX dates above come from the draft and can change before adoption.

Fragrance allergens: from 26 to more than 80

Regulation (EU) 2023/1545 amended Annex III to Regulation (EC) 1223/2009. The SCCS confirmed the original 26 allergens and identified 56 more with evidence of contact allergy in humans. Each of them must appear in the ingredient list when its concentration in the finished product exceeds:

• 0.001 % in leave-on products (creams, serums, make-up, perfume);
• 0.01 % in rinse-off products (shampoo, shower gel, cleanser).

In practice, you need a new declaration from the fragrance house, because old declarations list only the 26 allergens. Each scent then gets its own calculation: two scents of one lotion have different allergen lists, so the labels differ too.

Essential oils count. Lavender, citrus and tea tree oils contain listed allergens, so a "fragrance-free" product with essential oils may still need allergen labelling. Some entries in the annex cover a group of related substances under one name, which is why different sources count the new list as 80, 81 or 82 entries.

Products placed on the EU market from 31 July 2026 must comply already. Units placed on the market before that date can still be made available with the old label until 31 July 2028. Under the Commission's Blue Guide, "placing on the market" refers to each individual unit, not to the product name, so a batch produced and supplied after 31 July 2026 should carry the new label even if the product was first sold years ago. Most brands switch at the next print run.

The new glossary of ingredient names

Decision (EU) 2025/1175 replaced the glossary from Decision (EU) 2022/677. It contains about 30,400 entries, adds 348 new names and corrects or removes others. From 30 July 2026 labels must use these names. Labels designed for Korea, China or the US often contain names the EU glossary spells differently, or translated names that do not exist in it.

A CPSR lists the composition using INCI names, so an old CPSR and the new label can end up using different names for the same ingredient. That alone is not a safety problem, but a label that does not match the file is one of the first things an inspector notices.

CMR bans: Omnibus VII, VIII and IX

Substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) under the CLP Regulation are banned in cosmetics, with narrow exceptions. Each time CLP adds classifications (an "adaptation to technical progress", ATP), the Commission adds those substances to Annex II through an "Omnibus" act:

• Omnibus VII, Regulation (EU) 2025/877, applies from 1 September 2025. It includes trimethylbenzoyl diphenylphosphine oxide (TPO), used as a photoinitiator in gel nail polish.
• Omnibus VIII, Regulation (EU) 2026/78, applies from 1 May 2026 and covers substances classified under the 22nd ATP.
• Omnibus IX is a draft based on the 23rd ATP, notified to the WTO in July 2026, with bans expected from 1 February 2027.

These bans usually have no sell-off period. If an ingredient in your formula appears in one of these acts, the product needs reformulation, not a new label.

Vitamin A and arbutin

Regulation (EU) 2024/996 set maximum concentrations for retinol and retinyl esters and for alpha-arbutin and arbutin, and introduced a mandatory warning for vitamin A products: "Contains Vitamin A. Consider your daily intake before use." The limits are 0.05 % retinol equivalent in body lotion and 0.3 % in other leave-on and rinse-off products. Products placed on the market from 1 November 2025 must comply. Non-compliant stock can be made available only until 1 May 2027.

Microplastics

Regulation (EU) 2023/2055 under REACH restricts intentionally added synthetic polymer microparticles. Microbeads used for exfoliation were banned in October 2023. Rinse-off products follow from 17 October 2027 and leave-on products from 17 October 2029. Make-up, lip and nail products have until 2035 but need a "contains microplastics" statement from 2031. Glitter and some film-forming or coated pigments are the most common surprises.

Which existing CPSRs need an update?

A CPSR is not a one-off document. Article 11 requires the PIF to be kept up to date, and the safety assessment must reflect the current law and science.

How we handle updates

When you send us existing reports and labels, the Notium software checks each formula against the current annexes, the Omnibus lists, the 2023/1545 allergens (0.001 % leave-on and 0.01 % rinse-off) and the 2025 glossary. You get a list of the products affected and what each one needs: a new label, an updated CPSR or reformulation. The document audit is free. Updates are priced like new reports, and lower when only the allergen and label sections change.

Agencies can also get access to the composition section of the software to check formulas themselves before ordering a report.