The 2026 Fragrance-Allergen Deadline: Ingredient Checks for Formulators
The 2026 fragrance-allergen transition changes the information a formulator needs from ingredient suppliers. It is not a reason to treat every listed ingredient as newly banned. Purchasing should support a finished-formu
The 2026 fragrance-allergen transition changes the information a formulator needs from ingredient suppliers. It is not a reason to treat every listed ingredient as newly banned. Purchasing should support a finished-formula and label review by collecting the right grade-specific information and recording whether the product is new to the market or already in the transition stock.
The current change and its scope
Regulation (EU) 2023/1545 expanded allergen labelling. The new-market transition date was 31 July 2026; qualifying previously placed products have a separate transition to 31 July 2028. Benzyl alcohol was already a listed allergen. Its preservative role does not erase the ingredient-information check. Source: European Union — 2023-07-27.
Separate ingredient identity from finished-product labelling
Confirm the ingredient’s exact identity and INCI information, and ask which composition/allergen statements are available for the offered grade. The same ingredient can appear through more than one input. Give the formulation owner enough information to evaluate the complete formula rather than reviewing only a fragrance blend or only the preservative. No label conclusion follows from a catalogue product name alone.
Keep transition evidence with the actual product
Record the responsible person’s determination of the applicable transition, the formula version and the packaging version. A date on a raw-material invoice is not, by itself, the finished product’s market-placement record. If a supplier changes grade or composition, send the new information back to the formula and label review before using the existing declaration unchanged.
| Buyer check | Question to resolve | Evidence to request |
|---|---|---|
| Ingredient | Identity/INCI and offered grade | Grade-specific supplier documents |
| Formula | All relevant ingredient contributions | Full formula and assessment-owner review |
| Product use | Leave-on or rinse-off and destination market | Defined product/application record |
| Transition | Market-placement and label version | Responsible-person determination and retained evidence |
Connect the assessment to the actual enquiry
The Benzyl Alcohol product page is a route to a grade-specific raw-material request. Its preservative description is not evidence that a finished cosmetic meets the expanded labelling rules. Ask for documents before qualifying the ingredient, and test the real formula where required.
Prepare a specific RFQ
For an RFQ, specify ingredient identity/INCI, intended function, leave-on or rinse-off product, destination market, formulation constraints, quantity, packaging and sample needs. Request TDS/SDS/COA and available composition/allergen information. State who will review finished-formula and label implications; do not ask the supplier to certify an undisclosed finished formula.
Buyer questions
Was benzyl alcohol newly banned by this change?
No. It was already a listed allergen; do not confuse expanded labelling with a new ban on the ingredient.
Do all products share the same transition date?
No. New market placement and qualifying existing products have different 2026 and 2028 transition dates.
Does preservative use remove allergen-information checks?
No. Ingredient function does not replace the applicable finished-product assessment.
What should the supplier document request contain?
Name the actual ingredient and grade, product use and market, and request identity/composition information alongside TDS/SDS/COA.