What allergen labeling is required in the EU for fragrance in hair care products?

Quick Answer (for busy buyers)

Here’s the buyer-first summary. If your brand name is on the label, you usually act as the responsible person and must ensure the listing is submitted and kept current.

• Under EU Regulation (EC) No 1223/2009, fragrance allergens in cosmetics require labeling when above threshold levels.
• For hair care products like shampoos or conditioners (typically rinse-off), the limit is 0.01% for each of the 26 allergens, such as limonene or linalool.
• This must be clearly stated in the ingredient list, often using INCI names, to avoid non-compliance risks for brands selling in the EU market.
• In our OEM/ODM workflow, we integrate allergen management from the start.
• During formulation feasibility, we review ingredient suppliers for allergen concentrations and adjust recipes if needed.
• For sampling, we conduct GC-MS analysis to verify allergen levels, which adds about 2-3 weeks to the timeline and impacts MOQ decisions, as smaller batches may require more frequent testing.
• Packaging design must allocate space for full ingredient declarations, and we ensure labels meet EU formatting standards to prevent rework.
• Lead times factor in compliance checks, with production gates including allergen documentation like the Product Information File (PIF).
• We assist with testing and documentation but cannot guarantee regulatory approval, as final responsibility lies with the brand.
• Cost considerations include testing fees, which vary by SKU complexity, and MOQs (e.g., 10,000 units) help amortize these expenses.
• Always provide your target market details upfront to streamline the process.