Additional Fragrance Allergen Labelling for European Cosmetics

EU Commission publishes final report recommending extension of on-pack labelling from 26 to 87 allergens

The European Commission has drafted a Working Document and Annex III entry to the EU Cosmetics Regulation to require on-pack labelling for 61 additional fragrance allergens. Currently, cosmetic products in the EU and UK must list 26 allergenic chemicals found in fragrances or essential oils on their labels if they are present at levels greater than 0.001% for leave-on products or 0.01% for rinse-off products. This change takes the total number of allergens to be considered and potentially labelled to 87. The draft regulations include a transition period of three years for products being placed on the market and five years for the withdrawal of non-compliant products.

It is likely the legislative proposal will be published in Q4 2021 with official legislation following to implement this change in 2022. Once this becomes an official legislative proposal, the exact details of the new requirements will become clear and will undoubtedly pose significant challenges for cosmetic product manufacturers and retailers in the EU, as those requirements have the potential to significantly increase the space needed for ingredient labelling on already often overcrowded packs.

Industry bodies have commented that the transition periods should be longer and that existing products do not pose any new risk and should not need to be withdrawn from the market. They will also continue to advocate for the possibility of digital labelling of the additional allergens as an alternative to on-pack labelling where there are space restrictions.

As of today, there are no plans for the UK government to implement this new requirement for products sold in Great Britain (England, Scotland, and Wales). However, as Northern Ireland still follows EU rules, this new labelling will be required for products sold there.

How Exponent Can Help

Exponent's chemical regulation consultants are ready to advise manufacturers of cosmetic products sold in the EU and UK. We can perform thorough label artwork reviews including allergen-specific requirements when this new labelling becomes law to keep products compliant and provide guidance on all other aspects of bringing cosmetic products to market. Exponent will continue to monitor this situation and advise clients of any developments as soon as they arise.