Ultimo aggiornamento 16 June 2026
Introduction
For manufacturers of detergents and scented products, the issue of allergens can no longer be put off. Detergent labels must be revised.
Regulation (EU) 2023/1545 was adopted as an amendment to Cosmetics Regulation 1223/2009 regarding the labeling of allergenic fragrances, but its practical impact extends far beyond the cosmetics sector alone: the substances in question are in fact widely used in detergents, fabric softeners, and other household products as well, with practical implications for data collection from suppliers, formula revisions, documentation updates, and reprint planning.
The issue is not just a regulatory one, but an organizational one as well.
Under EU Regulation 2023/1545, the list of allergenic fragrances that must be individually listed on the labels of cosmetic products has been updated, introducing new substances and confirming declaration thresholds of 0.001% in leave-on products and 0.01% in rinse-off products. This means that, for the same formula, a product may now require significantly more information than in the past, with a direct impact onlabel management, packaging readability, and consistency with the technical information received from suppliers.
Companies, however, often make the same mistake: they look at the deadline and think they still have time. In reality, the timeline set by the regulation requires them to act now. Cosmetic products placed on the market after July 31, 2026, must comply with the new requirements, while those already on the market before that date may only be made available until July 31, 2028. After July 31, 2028, even products still on the shelves may no longer be sold if they do not comply.
And this is where the issue becomes particularly relevant for those who work with cleaning products as well. Although EU Regulation 2023/1545 formally amends the cosmetics framework, in practice it requires companies to review how they manage perfumes, essential oils, complex fragrances, and related composition information. If the supplier updates the list of allergens present in a fragrance, the database used toupdate the detergent label changes, and this may also affect scented detergents, as the allergens required to be listed on detergent labels depend (in part) on the Cosmetics Regulation.
Waiting until the July 31, 2026, deadline would therefore be a mistake. Between requesting information from suppliers, verifying thresholds, assessing the impact on labels, potentially updating documentation, and managing old inventory, there is a significant amount of work to be done. And for those who import raw materials or finished products from non-EU suppliers, the timeline may be even longer. For this reason, the real question is not whether to comply by July 2026, but how to immediately begin a process of updating that will allow you to be prepared for both the first deadline of July 31, 2026, and the final end of the transition period on July 31, 2028.
Allergens on detergent labels: what really changes under Regulation (EU) 2023/1545
The key provision of Regulation (EU) 2023/1545 is the significant increase in the number of allergenic substances that must be listed individually on the label when they exceed certain thresholds. Until now, the regulatory framework required the listing of 26 allergenic substances already listed in Annex III of the Cosmetics Regulation; with the new regulatory measure, an additional 56 allergenic fragrances are added to this list, identified by the Scientific Committee on Consumer Safety as substances that have clearly caused allergies in humans. The result is a very significant expansion of the list of substances to be monitored and, consequently, of the information that companies must be able to manage.
This means that the change also affects the administrative burden associatedwith updating labels, technical specifications, and supporting documentation. A fragrance that, until recently, required only a few entries to be listed may now require a much longer list of substances to be declared individually, even if the formula of the finished product has not changed.
There is also another factor: Regulation 1545 updates the way certain substances must be listed on the label. When there are multiple common names for a substance, the regulation specifies the name to be used in the ingredients list, with the aim of simplifying labeling, making it more understandable for consumers, and facilitating the work of businesses and authorities. At the same time, certain similar substances are grouped under a single entry. This means that the company must not only determine whether to declare an allergen but also how to declare it correctly.
This is an important step because many fragrances, essential oils, and plant extracts have complex compositions, with multiple CAS numbers, isomers, or possible names. The regulation has updated several entries in Annex III specifically to align common names with the latest version of the ingredients glossary and to group similar substances under a single entry. In practice, reading the supplier’s technical documentation becomes even more challenging: the same substance may appear in the data sheet under one name but must be listed on the label with a different name or with a group name defined by the regulation.
For companies, all of this boils down to a very concrete conclusion: Regulation 1545 does not merely require a minor formal adjustment, but calls for a genuine review of the available information on the fragrances used. This is why the July 31, 2026 deadline should not be viewed as a distant one. By that date, products placed on the market must comply with the new requirements, and given the large number of new allergenic fragrances that must be listed individually, the legislator has provided for a transition period precisely because the adjustments may involve formulations, containers, and labels. Non-compliant products already on the market as of July 31, 2026, may remain available until July 31, 2028.
In other words, here’s what really changes with EU Regulation 2023/1545: the number of allergens that must be monitored increases, the amount of information that can appear on labels grows, the use of correct terminology becomes more important, and there is less leeway to address the issue at the last minute. For those working with scented products—and in particular with detergents and formulations that use complex fragrances—the update must begin now, not just before July 2026.
Detergent labels: why updating allergen information is a real issue
For detergent manufacturers, the issue of allergens on labels is a pressing one—not because Regulation (EU) 2023/1545 applies directly to the detergent sector, but because the detergent framework has long incorporated the list of allergenic fragrances established in the cosmetics sector.
Regulation (EC) No. 648/2004 on detergents stipulates, in Annex VII A, that allergenic fragrances must be listed on the label if present in concentrations exceeding 0.01% by weight. It is precisely this substantial reference to the list of allergens developed for cosmetics and to the scientific opinions of the relevant European committee that makes Regulation 2023/1545 relevant to detergents as well: when the reference used to identify which allergens must be declared changes, the information that may appear on detergent labels also changes.
(AUTHOR’S NOTE: For the sake of completeness, EU Regulation 2026/465 has been published; it will repeal Regulation 648/2004 and introduce a list of allergens.)
Regulation 2023/1545 significantly updates the cosmetic regulations governing allergenic fragrances, expanding the list of substances considered relevant and updating certain names. Since the allergen labeling system for detergents has always been based on that technical-scientific framework, the practical implication for detergent manufacturers is the need to verify whether the fragrances used in their products now require them to declare more substances than before.
This is where the practical implications come into play. If a supplier updates the allergen composition of a fragrance in accordance with the new framework, the company that formulates scented detergents must review the label of the finished product in light of Annex VII A of Regulation 648/2004. In many cases, the detergent formula does not change, but the list of allergens that exceed the 0.01% threshold—and must therefore be listed on the label—does change. This entails reviewing the information received from the supplier, carefully checking concentrations, and possibly updating the label layout, especially for products with complex fragrances, essential oils, or intricate fragrance blends.
The impact is even more evident because Regulation 2023/1545 does not merely add new substances: it also updates certain names, groups similar substances under a single heading, and clarifies which name must be used on the label of cosmetics.
For detergent manufacturers, this translates into a very real need to update ingredient information, technical assessments, and labels.
Labels on imported cleaning products: why the risk is even higher
The issue of allergens becomes even more sensitive when it comes to imported products or raw materials purchased from suppliers outside the EU.
Regulation 2023/1545 does not apply directly to detergents, but the labeling of allergens in consumer detergents remains subject to the provisions of the Detergents Regulation and the 0.01% by weight threshold for allergenic fragrances that must be declared. In particular, technical and legislative sources that refer to Annex VII of the Detergents Regulation state that fragrance allergens must be listed on the label above this threshold and refer to the allergen list developed within the cosmetics framework. For this reason, when the scope of allergenic fragrances in the cosmetics sector is updated, the operational impact also extends to detergents: the manufacturer or importer must determine whether the fragrances present in their products now require more extensive labeling than in the past.
With imported products, however, the situation becomes even more complicated. A non-EU supplier may not be fully familiar with European regulations, may not have updated the fragrance documentation yet, or may provide incomplete data—with trade names or descriptions that are insufficient to determine which allergens actually exceed the applicable thresholds. This slows down verification, extends label review times, and makes it more difficult to plan for packaging replacement and stock depletion. In practice, what may already be a challenging update project for a European manufacturer easily becomes a problem of coordination between the supply chain, documentation, and time-to-market for an importer.
For this reason, when it comes to imported cosmetics and detergents, the work should begin well in advance of the deadlines.
Conclusions
If you manufacture or import detergents and want to understand in advance how the updates regarding allergens, labels, and technical documentation might affect you, now is the time to take action. A timely review of the fragrances used, data received from suppliers, and update timelines can help avoid delays, urgent reprints, and commercial issues as we approach July 2026.
With our consulting services, we can assist you in reviewing documentation, verifying which allergens must be declared, reviewing SDSs and labels, and planning regulatory updates for cosmetics and detergents—so you can be fully prepared for upcoming deadlines without having to scramble at the last minute.
Leave the technical work to us. You focus on your business.
