List 2 Fragrance Allergens Arriving August 1 2026

Two deadlines, four months apart, and it's easy to only plan for the first one. List 1 fragrance allergens become mandatory on the CNF and label on April 12, 2026. That's the date most makers have circled. But List 2 follows on August 1, 2026, expanding the mandatory disclosure set further, and a formula that cleared List 1 review isn't automatically fine under List 2.

Why there are two lists instead of one

List 1 represents the original, longer-established set of fragrance allergens that regulators have required disclosure for. List 2 is an expanded set aligned with international allergen lists, broadening the scope of what needs to be named on the label rather than folded anonymously into "fragrance" or "parfum." The staggered rollout gives makers a two-step runway, first adjust to List 1 disclosure, then extend that same discipline to a wider ingredient set a few months later, rather than absorbing both changes on the same day.

What doesn't change between the two lists

The underlying disclosure logic is the same for both lists. An allergen needs to be named by its INCI name on both the CNF and the label once its concentration crosses the relevant threshold:

• Above 0.001% (10 ppm) in leave-on products
• Above 0.01% (100 ppm) in rinse-off products

What changes is simply which substances count as allergens requiring that treatment. List 1 covers the familiar names many makers already recognize, Limonene, Linalool, Citronellol, Geraniol, Eugenol, Coumarin among them. List 2 broadens that roster.

Why a formula "clean" under List 1 can still need work for List 2

Here's the scenario that catches people off guard. You review your fragrance blend in the spring, check it against List 1's allergens, find nothing crosses the threshold, and consider the product settled. Then August arrives, List 2 becomes mandatory, and it turns out your fragrance oil contains a different allergen molecule, one that wasn't on List 1 at all, sitting well above the rinse-off or leave-on threshold. Nothing about your formula changed. The disclosure requirement just widened underneath it.

This is exactly why relying on a one-time check against April's list isn't enough if you're formulating or reformulating anything between now and August. The safer approach is to check new and existing formulas against both lists together, even though only List 1 is mandatory in the immediate term, so you're not doing this exercise twice within the same year.

Getting your documentation in order early

The practical bottleneck for most makers isn't the calculation itself, it's getting the underlying data. Essential oil and fragrance oil suppliers vary widely in how readily they provide a full allergen breakdown. Some proprietary fragrance blends list their allergen content plainly in supplier documentation. Others require a direct request.

A few steps worth taking now, ahead of August:

• Request updated allergen documentation from every fragrance and essential oil supplier you use, specifically asking whether it covers the expanded List 2 substances, not just List 1
• Flag any supplier that can't or won't provide this, since that's a sourcing risk independent of the regulatory deadline
• Rerun your concentration math for every formula using the full combined list, not just List 1, so a single review covers both deadlines

INCI names matter here specifically

Because the label requirement is to name the allergen by its INCI name once it crosses threshold, "fragrance" or "parfum" alone won't satisfy the disclosure for a substance that's crossed into named-allergen territory. This is one more reason trade name fragrance blends need to be mapped down to their actual component INCI names rather than left as a single line item, since the components are what get evaluated and, where applicable, named individually on the label and the CNF.

If you're working through a fragrance-heavy product line, right now is a good moment to get ahead of both deadlines at once rather than treating April and August as two separate fire drills. Cosmetic Comply expands supplier blends into their INCI-named components and carries the percentages through, then checks the summed allergen totals against both the List 1 and List 2 thresholds, so a formula reviewed once this spring doesn't need a second scramble in August.