This is the first step in the implementation of Regulation (EU) 2023/1545: from 31 July 2026, all cosmetic products newly placed on the market in the European Union must include, in the list of ingredients on the labelling, the allergens featured on the list, which contains more than 80 such substances.
Published on 27 July 2023, Regulation (EU) 2023/1545 requires the labelling of the allergens it lists whenever their concentration exceeds 0.001 per cent in leave-on products and 0.01 per cent in rinse-off products.
It therefore comes into force, and, from 31 July 2026, new products that do not comply with these new requirements may no longer be placed on the market.
The concept of “placing on the market”
On this occasion, the trade association Cosmed is highlighting this point, which is often misunderstood.
Placing on the market, it explains, does not correspond to the date of manufacture or the year a product is launched, but rather to the act by which the Responsible Person makes a unit of the product available on the European market, that is to say, the moment at which they supply the product to their distributors or directly to the consumer.
In practical terms:
• where manufacturing is subcontracted within the European Union, the product is not placed on the market until it is fully finished and made available by the Responsible Person;
• in the case of imports, the Responsible Person is, in principle, the importer, who may only place the product …
