
Locate the transition
EU Regulation 2023/1545 expands individual fragrance allergen labelling. It allows placing products under previous provisions until 31 July 2026 and making them available until 31 July 2028, subject to its conditions. On 3 October 2026, older and newer labels can therefore coexist.
Compare the exact reference
Photograph list, batch and purchased reference. Ask whether online ingredients match that batch. A longer list does not by itself prove a formula change; separate labelling updates from product changes.
Prepare the question
For a known allergy, keep the professional’s exact name and check the precise product. Scent notes do not replace ingredients. Mark missing information and ask a specific question instead of assuming a commercial term guarantees tolerance.
Document a list difference
Keep dated photographs with each product’s reference and batch. Compare full lists rather than one isolated ingredient. State the market when contacting the manufacturer. A website consultation date does not establish manufacture or market placement of a bottle.
Deadlines on 6 October 2026
On 6 October 2026 the first deadline has passed; qualifying existing stock may remain available until 31 July 2028 under the regulation’s conditions. Two ingredient lists alone cannot date market placement. Ask the product responsible party to confirm a specific reference.
Your checklist
- Identify market
- Keep list and batch
- Separate formula and label
Frequently asked questions
Does a new list mean a different perfume?
Not necessarily. Information can change without a corresponding formula change; ask the manufacturer.
Can an unofficial batch calculator prove a date?
Do not treat its result as evidence. Ask the manufacturer for batch correspondence and available information.
Sources & references
- Regulation (EU) 2023/1545 · fragrance allergen labelling ↗European Commission / EUR-Lex · Sources consulted on 2026-10-06
- Understanding the label ↗Cosmetics Europe · Sources consulted on 2026-10-06
- Fragrance allergens labelling ↗European Commission · Sources consulted on 2026-10-06
