Labelling: A Moving Target
Regulatory developments every brand should be preparing for
For cosmetic brands, finalising product labels can feel like reaching the finish line. After weeks of artwork revisions, compliance checks, and claim substantiation reviews, the packaging is finally signed off and production begins.
Except the finish line rarely exists.
In reality, labels remain a moving target. Expanding into new markets introduces additional regulatory requirements, while evolving legislation in existing territories can force brands back to the drawing board. And for many regulatory teams, 2026 is shaping up to be another year of obligatory label updates.
Against this backdrop, several EU and GB regulatory developments are now converging to create a new wave of labelling updates. From fragrance allergens and Vitamin A obligations to environmental labelling and emerging global warning requirements, brands operating across multiple markets will need to carefully assess how these changes impact existing products as well as future launches. The following developments are among the most significant labelling considerations currently on the regulatory horizon.
Fragrance Allergens
For a few years now, we’ve been aware of amendments to the EU Cosmetic Products Regulation revising several existing entries for fragrance allergens in Annex III and introducing 56 additional allergens to label.
These new substances will follow the same labelling thresholds that currently apply to the existing list of 26 allergens, but the list of substances that require declaration on product labels is now significantly expanded, and the compliance deadlines are now very close. If you haven’t already updated your labels, you need to be acting now.
Compliance timelines
Placing on the market: 31 July 2026
Making available on the market (off-shelf): 31 July 2028
What does placing on the market mean?
Placing on the market is often poorly understood in the context of the Cosmetics Regulation. In practice, what does it mean to be compliant from 31 July 2026? It means that any new stock that is released into the supply chain or imported to the EU after this date must declare the allergens according to the full extended list.
This deadline DOES NOT only apply to NPD products/new launches.
Vitamin A (Retinol, Retinyl Acetate, Retinyl Palmitate)
In recent years, retinol, retinyl acetate, and retinyl palmitate (Vitamin A derivatives) have been added to Annex III of the EU Cosmetic Products Regulation, introducing concentration limits and mandatory warning labelling.
Products containing these ingredients must now include the warning:
“Contains Vitamin A. Consider your daily intake before use.”
The first deadline for this requirement has already passed, but if you missed it, now is the time to act!
Compliance timelines
Placing on the market: 1 November 2025
Making available on the market: 1 May 2027
Formaldehyde and Formaldehyde-Releasing Preservatives
Formaldehyde is included in Annex II (Entry 1577) of the EU Cosmetic Products Regulation, however, formaldehyde-releasing preservatives remain permitted under Annex V, subject to concentration limits and additional labelling requirements.
In the past, the preamble to Annex V already required a warning statement for products releasing formaldehyde but the threshold that triggers this labelling is now lowered and specifically references the level released: Where a product releases a total of more than 0.001% free formaldehyde, the label must include the warning:
“Releases formaldehyde.”
Again, the first (placing on the market) deadline has already passed in the EU but the deadlines for Great Britain (GB) are now approaching and existing stock on the EU market may need to be shortly withdrawn from shelves. If you haven’t updated your labels but use formaldehyde-releasing preservatives - check if you need to amend your label.
Compliance timelines EU
Placing on the market: 31 July 2024
Making available on the market: 31 July 2026
Compliance timelines Great Britain
Expected placing on the market deadline: 15 July 2026
Making available on the market: 14 July 2027
EU Packaging Waste and Sorting Labels (PPWR)
The EU Packaging and Packaging Waste Regulation (PPWR) introduces harmonised waste sorting labels intended to create a standardised visual system across the EU. At this time (March 2026), the exact system is not confirmed, but it is anticipated that these labels will combine:
pictograms;
colour coding; and
limited explanatory text.
The objective is to improve consumer understanding of recycling instructions and ensure consistent sorting practices across Member States.
With the other changes needed on labels during 2026, now would be an ideal time to begin to add the new EU sorting labels to your packs. Unfortunately, we don’t yet have clarity on what this will look like or any guidance on the practical implementation so further label amendments may be required to implement this requirement!
Key milestones
August 2026: The implementing act on the harmonised waste sorting labels is expected to be published.
2026–2028: Additional technical guidance likely to clarify practical implementation.
Microplastics
The EU REACH restriction on microplastics introduces both formulation restrictions and labelling obligations for certain cosmetic products.
Label requirement 1:
Where an ingredient is deemed a ‘microplastic’ but it loses its microplastic status, e.g. in the formula or during use, instructions for use and disposal are required to avoid microplastic release to the environment.
This labelling requirement applies from 17 October 2025 and should be on your labelling now!
Label requirement 2:
Conversely, manufacturers of lip, nail and make-up products that have longer to phase out microplastics from products, may be obligated to include the label statement:
“This product contains microplastics.”
This labelling requirement will apply between 17 October 2031 and 16 October 2035.
However, labelling is only part of the jigsaw and for many products the issue is more likely to be reformulation and some approaching deadlines apply.
Key restriction timelines
17 October 2027: Rinse-off cosmetic products
17 October 2029: Leave-on cosmetic products
17 October 2029: Fragrance encapsulation
17 October 2035: Lip products, nail products and make-up
Taken individually, each of these developments may appear manageable. But when considered together, they illustrate a broader reality for cosmetic brands: product labels are no longer static compliance checkpoints, but dynamic regulatory touchpoints that must evolve alongside legislation.
For regulatory teams and brand owners alike, staying ahead of these changes requires more than periodic label checks. It demands a structured approach to monitoring regulatory developments, assessing portfolio impact, and planning updates well before compliance deadlines arrive.
Because in today’s regulatory landscape, the question is rarely whether labels will need to change, but when.
Get in touch if you would like to discuss any of the above topics or understand how you can build a proactive label compliance strategy.
Darshni Pattani & Amanda Isom