If your fragrance suppliers have started sending longer allergen lists, this is why: Regulation (EU) 2023/1545 has expanded the fragrance allergens that must be named on cosmetics from the long-standing 26 to around 80.

What changed

The EU Cosmetics Regulation has always required certain fragrance allergens to be listed by name in a product's ingredients, rather than hidden inside the single word "parfum". For years that meant a fixed set of 26 substances. Regulation (EU) 2023/1545 amends Annex III of the Cosmetics Regulation and grows that set to roughly 80 — pulling in many everyday fragrance materials, some as common as vanillin, that never had to be named before.

The thresholds

A substance on the list has to be declared once it's present above 0.001% (10 ppm) in a leave-on product, or 0.01% (100 ppm) in a rinse-off one — the same trigger levels as before, now applied to a much longer list. Below those levels it can still sit inside "parfum".

The deadlines

Two dates matter, and the first has already passed:

  • 31 July 2026 — from this date, any cosmetic product placed on the market must carry the expanded declarations. New and reformulated products already have to comply.
  • 31 July 2028 — products that were already on shelves get a longer runway: non-compliant stock can stay available until this date, after which it must be withdrawn.

What it means for candles and diffusers

A candle, reed diffuser or wax melt isn't a cosmetic, so this Annex III list doesn't set its label. For home fragrance that job belongs to CLP and the EUH208 "Contains…" line. But the change still reaches your workshop from the other direction: fragrance houses build their allergen declarations around this same list, so the allergen certificates and safety data sheets you receive are getting longer.

For a candle, that longer list isn't your label. Only the allergens classified as skin sensitisers above their threshold get named, and it's the CLP classification — not the raw cosmetics list — that fixes your EUH208 line. The one case where the list is your rule is if you also make something worn on the body, like a balm or a body-and-room spray sold as a cosmetic; that product follows Annex III directly.

What to do now

Ask your suppliers for allergen declarations updated to 2023/1545, and re-check any product where a newly-listed allergen might now cross its threshold. Molekule reads the fragrance's allergen data and generates your candle's EUH208 line from it, so when the list grows the change simply flows through — no re-checking every load by hand. Generate your allergen line in Molekule.