The August 1 2026 List 2 Allergen Deadline Explained

There are two allergen deadlines on the calendar this year, and it's easy to conflate them if you're not looking closely. List 1 lands April 12, 2026. List 2 lands August 1, 2026. This one is about List 2, and if your April work was solid, this second deadline should be a much smaller lift, but it's not nothing.

What List 2 Actually Is

List 1 is the original, foundational fragrance allergen set, the substances that have been the reference point for fragrance allergen disclosure for years, things like limonene, linalool, citronellol, geraniol, eugenol, and coumarin. List 2 expands on that with an additional set of allergens aligned with international lists used elsewhere, broadening the group of substances that trigger mandatory disclosure on the CNF and the label.

The practical effect is that some fragrance materials that didn't require declaration under List 1 alone will require it once List 2 becomes mandatory, if they're present above the disclosure thresholds.

The Thresholds Don't Change, Only the List Does

This is worth being precise about, because the two deadlines are sometimes confused as involving different thresholds. They don't. The disclosure triggers are the same across both lists:

• Leave-on products: disclose above 0.001 percent, which is 10 ppm
• Rinse-off products: disclose above 0.01 percent, which is 100 ppm

What changes on August 1, 2026 is which substances you're checking against those thresholds, not the thresholds themselves. So the calculation work you did for List 1, tracing every fragrance component back through your supplier documentation to real finished-product concentrations, is the same work, just applied against a longer list of names.

Why This Deadline Sneaks Up on People

If you already did the heavy lifting for the April 12 deadline, meaning you pulled full fragrance disclosure breakdowns from your suppliers and mapped every component to INCI names and concentrations, then checking against List 2 is mostly a re-run of a process you've already built. The people who get caught off guard are the ones who treated April 12 as a one-time project instead of building a repeatable process, closed the file, and now have to reopen supplier documentation they'd already set aside.

The other trap is assuming your April 12 relabeling covered everything permanently. If List 2 catches an allergen in your formula that List 1 didn't, you may need a second relabeling pass in the middle of the year, on top of whatever you already did for the first deadline.

What to Do Before August 1

• Re-pull fragrance supplier disclosures. Ask specifically whether the breakdown covers List 2 substances, not just List 1. Some suppliers issued List 1-focused documentation earlier in the year and haven't updated it yet.
• Re-run your concentration math for every leave-on and rinse-off product, since a different set of allergens means different substances might now cross the threshold even at the same use levels.
• Check your CNF amendment status. If a new allergen needs declaring for a product already notified, that's an amendment, filed when a formula's declared composition changes, distinct from a fresh notification.
• Update label artwork on a realistic timeline. Printed packaging has lead times. If you know a product needs a new allergen on the label, get that into your reprint queue well before August, not the week of.

A Simple Before and After

	Before August 1, 2026	After August 1, 2026
Mandatory allergen set	List 1 only	List 1 and List 2
Disclosure thresholds	10 ppm leave-on, 100 ppm rinse-off	Unchanged
Label impact	Reflects List 1 findings	May require additional allergens added
CNF impact	List 1 declarations	List 2 declarations added where triggered

The Honest Advice

Treat this less like a single deadline and more like the second half of one ongoing project that started back in April. Don't wait until July to open your supplier files again. And because both lists depend entirely on real finished-product concentrations, not raw material percentages, this is exactly the kind of arithmetic that's easy to get wrong by hand across a full product line.

Cosmetic Comply carries ingredient percentages through from supplier blend to finished product automatically and flags allergens against current thresholds, so when a list changes, you rerun the screen instead of rebuilding the spreadsheet.