Tracker
What changed, and what changes next
The rules a fragrance has to meet move, and they move on dates set years in advance. This is the register of those dates: what each instrument requires, when it bites, and where it is published so you can read it yourself.
Reconciled against the sources named in each row on 13 September 2026.
This page is a register of dated changes, kept for people who make fragrances, and it is not legal advice. Each row names the instrument and where it is published so it can be checked at the source. Before relying on a date or a figure, read it in the instrument itself: a tracker tells you what to go and look at, and it is not a substitute for having looked.
What changes next
Soonest first, because this is a worklist.
European Union: Four new CLP hazard classes
Regulation (EU) 2023/707 CLP gained four hazard classes that did not exist before 2023: endocrine disruption for human health and for the environment, and persistent, bioaccumulative and mobile properties. A finished fragrance is a mixture, so the two dates that bind a fragrance are the mixture dates.
- in force : a substance must be classified and labeled against the new classes
- in force : a mixture must be
- still ahead : a substance already on the market before 1 May 2025 must comply
- still ahead : a mixture already on the market before 1 May 2026 must comply
Where it is published: The regulation's transitional provisions, as consolidated on EUR-Lex.
Explained in full: Safety data sheets and CLP labels
European Union: Fragrance allergen labeling
Regulation (EU) 2023/1545 The list of fragrance allergens that must be named on a cosmetic label grew from 24 entries to 81. The thresholds are unchanged: 0.001 percent of the finished product for a leave-on product, 0.01 percent for a rinse-off one, and there is no second, lower threshold for particular substances. A product labeled to this list declares up to 57 allergens that were not declarable before.
- in force : a product may only be placed on the Union market if it labels the expanded list
- still ahead : stock already in the shops must also comply
Where it is published: The regulation's own two dates, in the Official Journal text, and the consolidated Annex III on EUR-Lex. The 81 entries are the shipped list, counted from it rather than from any summary of it.
Explained in full: EU fragrance allergen labeling
What has already changed
Most recent first, because the thing that moved last is the thing most easily missed.
Great Britain: Hexyl salicylate restricted, not declarable
SI 2026/109 Hexyl salicylate (CAS 6259-76-3) becomes Annex III entry 325 in Great Britain as a concentration restriction with no declaration duty attached. In the Union the same substance is a declarable allergen, so one material is handled two different ways by the two regimes at once.
- in force : the GB restriction takes effect
Where it is published: The statutory instrument, on legislation.gov.uk, against the Union's Annex III entry.
Explained in full: Selling a fragrance in Great Britain
Great Britain: The GB REACH registration deadline moved
SI 2026/849 The GB REACH registration deadline was moved by statutory instrument, made in June 2026, to allow for a regulator system migration. A deadline that moves is worth recording with its instrument, because the date somebody wrote down last year is no longer the date.
- in force : the moved registration deadline
Where it is published: The statutory instrument, on legislation.gov.uk.
Explained in full: Selling a fragrance in Great Britain
Great Britain: The allergen list stays at 24
The GB Cosmetics Regulation, as amended Great Britain did not adopt the expanded list, so from the day the Union list took effect the two regimes are formally different. Great Britain keeps the original entries, which number 24 once the two it has since prohibited are taken out, at a single 0.001 percent leave-on and 0.01 percent rinse-off pair. A label written to the Union list names up to 57 allergens Great Britain does not require.
- in force : the two regimes are formally different from this date
Where it is published: The assimilated Cosmetics Regulation as amended by GB statutory instruments, against Regulation (EU) 2023/1545. The two counts are the shipped allergen list, which records which market each entry binds in.
Explained in full: Selling a fragrance in Great Britain
The IFRA Standards: The next amendment, in consultation
52nd Amendment The consultation on the next amendment has closed and formal notification is expected rather than published, so there is no set of Standards to assess against yet and no compliance date to work back from. An amendment is the one change on this page that can make a formula already sold need reformulating, so it is worth watching for.
- in force : the consultation closed
Where it is published: IFRA's published consultation record. Notification is expected around the end of 2026; that is an expectation and not a date anybody can rely on, which is why no date for it is printed here.
Explained in full: The IFRA Standards, explained
The IFRA Standards: The set of Standards in force
51st Amendment The 51st Amendment is the set in force, and every part of it is now live. Its prohibitions applied to new creations first and to existing creations a year later, and its restrictions and specifications followed the same pattern, so a formula written before it has been inside its scope since the last of those dates.
- in force : notified
- in force : prohibitions apply to new creations
- in force : restrictions and specifications apply to new creations
- in force : prohibitions apply to existing creations
- in force : restrictions and specifications apply to existing creations
Where it is published: IFRA's own notification of the amendment, and its published Standards library.
Explained in full: The IFRA Standards, explained
European Union: The Unique Formula Identifier
CLP Annex VIII A mixture classified for a health or physical hazard carries a Unique Formula Identifier on its label and in section 1 of its safety data sheet, tied to the poison center notification for that formula. A reformulation that changes the notified composition needs a new identifier.
- in force : required for mixtures for professional use
- in force : required for mixtures for consumer and professional use
Where it is published: The Annex VIII compliance dates, as consolidated on EUR-Lex.
Explained in full: Safety data sheets and CLP labels
United States: Facility registration and product listing
MoCRA The Modernization of Cosmetics Regulation Act is the first substantial expansion of federal cosmetics authority since 1938. It requires a facility that makes or processes cosmetics to register, every product to be listed with its ingredients, and serious adverse events to be reported. A small business exemption covers the registration and listing duties but not the adverse event duty.
- in force : enacted
- in force : registration deadline for a facility already operating, and listing deadline for a product already on the market
Where it is published: The Act, as enacted in the Consolidated Appropriations Act, and the agency's published guidance.
Explained in full: Selling a fragrance in the United States
European Union: The safety data sheet format
Regulation (EU) 2020/878 The sixteen-section safety data sheet format was updated, and the updated format is the one an EU sheet must now follow. A sheet written to the older format is no longer acceptable for supply in the Union, whatever it says.
- in force : required for a new safety data sheet
- in force : required for every safety data sheet supplied
Where it is published: The regulation's own transitional dates, as consolidated on EUR-Lex.
Explained in full: Safety data sheets and CLP labels
Great Britain: Lilial prohibited in Great Britain
SI 2022/659 Butylphenyl methylpropional, or Lilial (CAS 80-54-6), is prohibited in Great Britain. It was entered in Annex II and removed from Annex III by Great Britain's own instrument on its own advice, about seven months after the Union acted, so the Union's prohibition is not the law that binds here even though the outcome is the same.
- in force : the GB prohibition takes effect
Where it is published: The Toys and Cosmetic Products (Restriction of Chemical Substances) Regulations 2022, on legislation.gov.uk. The Union's own instrument, Regulation (EU) 2022/1176, is not assimilated GB law.
Explained in full: Selling a fragrance in Great Britain
Great Britain: The older safety data sheet format
GB REACH Annex II Great Britain did not adopt the Union's updated safety data sheet format, so a GB sheet follows the retained annex as it stood at the split. The exposure scenario changes do not apply, and the wording of the persistence and bioaccumulation section differs.
- in force : the formats part company at the end of the transition period
Where it is published: The retained Annex II as it stood on exit, against Regulation (EU) 2020/878.
Explained in full: Safety data sheets and CLP labels
Great Britain: Two candidate lists, two lengths
GB REACH candidate list The Great Britain candidate list of substances of very high concern parted from the Union list and the two have grown apart since. The Union list is several times the length of the Great Britain one, so a substance can be on one and not the other and the answer depends on which market is being asked about.
- in force : the two lists part company
Where it is published: Both regulators' published candidate lists. The counts move, which is why this row does not print one.
Explained in full: Selling a fragrance in Great Britain
Standing differences between markets
Not changes, and not dated. These are places where two regimes simply answer the same question differently, and a product sold in both has to satisfy each on its own terms.
Great Britain: No Unique Formula Identifier
GB CLP Great Britain has no equivalent of the Union's Unique Formula Identifier. A sheet written for the Union can generally be used in Great Britain with the identifier removed from section 1, and the supplier should check it against current regulator guidance before relying on that.
Where it is published: GB CLP as assimilated and amended, and the regulator's published SDS guidance.
Explained in full: Selling a fragrance in Great Britain
How this register is kept
Every row names its instrument and where that instrument is published, so any date here can be read at the source rather than taken on trust. The date at the top of this page is the day the rows were last reconciled against those sources, written down by the person who did it rather than generated, because a page that recalculates how current it is stays current forever without anybody checking anything.
A date can move. One on this page already has: a registration deadline was pushed by a statutory instrument made weeks before it fell due, which is exactly why a deadline is worth recording with the instrument that set it rather than in a note to yourself.