Fragrance Sellers EU Compliance Requirements

Fragrance sellers EU compliance touches 107 sellers that Eldris tracked listing perfume and fragrance across Amazon's four largest EU marketplaces. Each is a cosmetic product under Regulation (EC) 1223/2009. That means allergen labelling under Annex III, a CPSR under Article 10 and CPNP notification under Article 13 all apply before a legal sale.

Fragrance is the smallest of the major sub-types in the data, but it carries the strictest labelling rules. The allergen declaration is what sets perfume apart from other cosmetics.

This report sets out the three duties a fragrance seller must meet. It starts with the allergen rule, because that is where perfume differs most from skincare and haircare.

Why fragrance sellers EU compliance is stricter

Perfumes carry high concentrations of aromatic compounds. Several of those compounds are known skin sensitisers, which is why the EU singles them out.

The regulator's response is mandatory allergen declaration. The aim is to let a sensitive consumer read the label and avoid a reaction. The 107 fragrance sellers in the data all face this duty.

The duty applies whether the fragrance oil is bought in or made in-house. The seller cannot pass the responsibility to a supplier. The label on the bottle is the seller's legal statement.

The cornerstone EU cosmetics seller compliance index places fragrance at 107, behind skincare, personal care, haircare and makeup. Small volume, but no lighter a burden. If anything, the labelling work is heavier per product.

Allergen labelling under Annex III

Annex III of Regulation (EC) 1223/2009 lists the fragrance allergens that must be named on the label. Sellers declare them when present above set thresholds.

The thresholds are 0.001 percent in leave-on products and 0.01 percent in rinse-off products. A perfume is a leave-on product, so the lower threshold applies and more allergens reach declaration.

That lower threshold is the practical reason perfume labels run long. A single fragrance accord can contain several declarable allergens at once. Each one has to be named.

Each listed allergen must appear by its INCI name in the ingredient list. The standardised names come from the CosIng database, which records the exact form to use.

The allergen list has expanded over time. The EU added many new declarable substances in a recent update, so an older formula may now need a longer declaration than before.

This is why the screen must be current. A perfume notified two years ago may carry a label that no longer meets the updated allergen rules.

The CPSR and notification still apply

Allergen labelling does not replace the core obligations. It sits on top of them.

The safety report

A perfume needs a Cosmetic Product Safety Report under Article 10. The high concentration of fragrance compounds makes the toxicological assessment central to the report.

The assessor weighs the dermal exposure from a leave-on product. Perfume sits on the skin and is reapplied, so the exposure model differs from a wash-off item. Inhalation exposure may also feature in the safety assessment.

The two-part Annex I structure is the same as for other cosmetics. The skincare CPSR report explains Part A and Part B, and the same template applies to a perfume.

The CPNP notification

Every perfume must be notified through the Cosmetic Products Notification Portal (CPNP) under Article 13. The notification must exist before the first unit ships.

It records the product, its frame formulation and the Responsible Person. One notification covers all EU markets at once. The Responsible Person files it once, not country by country.

Brands based outside the EU must appoint that Responsible Person first. The appointment under Article 4 is the gate that the notification and the safety report both depend on.

How fragrance sellers stay compliant

The sequence mirrors the rest of cosmetics, with the allergen screen added. Identify the declarable allergens, complete the CPSR, then notify and label. Each step depends on the one before it.

The allergen screen comes first because it feeds both the label and the safety report. A change to the fragrance oil can change the declared allergens, which then changes the label.

Get the screen from the fragrance supplier as a documented breakdown. That breakdown should state each allergen and its concentration, so the threshold test is simple to apply.

Keep that document in the Product Information File. If an authority queries the label, the breakdown is the evidence that the declaration is correct and complete.

Haircare sellers face a similar labelling overlap for scented products, covered in the haircare compliance report. Eldris runs the full chain through our CPNP and CPSR service, including the allergen declaration.

Done in the right order, fragrance compliance is predictable. The allergen screen drives the label, the CPSR confirms safety, and the notification clears the product for all 27 EU markets at once.

Data source: Eldris proprietary tracking of 16,931 active Amazon third-party sellers across 22 marketplaces, observed October 2025–February 2026. Figures are aggregated and anonymised; no individual seller is identifiable. Cosmetics sellers identified via product-category keyword classification.

Frequently Asked Questions

How many EU sellers list perfume and fragrance?

Eldris tracked 107 sellers listing perfume and fragrance across Amazon's four largest EU marketplaces. Each is subject to the EU Cosmetics Regulation in full.

What allergen labelling applies to fragrance in the EU?

Annex III lists fragrance allergens that must be declared on the label. The thresholds are 0.001 percent in leave-on products and 0.01 percent in rinse-off products.

Do perfumes need a CPSR?

Yes. A perfume is a cosmetic product, so it needs a Cosmetic Product Safety Report under Article 10 before notification. The high concentration of fragrance compounds makes the assessment important.

Do fragrance sellers need CPNP notification?

Yes. Every perfume must be notified through the Cosmetic Products Notification Portal under Article 13 before the first unit is placed on the EU market.

Why is allergen labelling stricter for fragrance?

Perfumes carry high concentrations of aromatic compounds, several of which are known skin sensitisers. Declaring them on the label lets sensitive consumers avoid an allergic reaction.