CBD cosmetics: 56 more fragrance allergens on the label
Since 31 July 2026, any cosmetic placed on the European market for the first time must name 56 more fragrance allergens in its ingredient list: from 0.001% in a leave-on product, from 0.01% in a rinse-off one. Some are hemp terpenes, such as β-caryophyllene, pinenes and terpinolene. A CBD balm scented with essential oils may therefore list new names while its formula stays the same.
Key takeaways
- Under Regulation (EU) 2023/1545, 56 more fragrance allergens must be named individually.
- A leave-on product must label them from 0.001%, a rinse-off product from 0.01%.
- Stock placed on the market before 31 July 2026 may stay on sale until 31 July 2028.
- Limonene and linalool were already declared, and β-caryophyllene, pinenes, terpinolene and terpineol now join them.
- CBD is absent from this allergen list, and a European scientific committee has judged it safe in cosmetics up to 0.19%.
What has changed since 31 July 2026
Regulation 1223/2009, the EU cosmetics regulation, already made ingredient lists compulsory. Fragrance substances can be grouped under "Parfum" or "Aroma", apart from certain allergens that must be named one by one above a threshold. Regulation (EU) 2023/1545 extended that list. In the European Commission's summary, it introduces individual labelling for 56 additional fragrance allergens, and AEMPS, the Spanish medicines agency, now counts 81 allergens that must be labelled by name.
Two dates frame the transition. From 31 July 2026, no non-compliant product may be placed on the market for the first time. Products already placed on the market before that date may be sold until 31 July 2028. During 2026 and 2027, two identical creams can thus carry different labels and both be legal.
The day you buy a product says nothing about when it was placed on the market. An old label in 2027 may be perfectly legal; in August 2028, it would be an offence.
Thresholds: 0.001% or 0.01%, depending on rinsing
A listed allergen must be named above 0.001% of the finished product in a leave-on product (cream, balm, massage oil) and above 0.01% in a rinse-off product (shower gel, shampoo). The threshold follows the use, whatever the texture. A "gel" may be a treatment left on the skin or a cleanser you rinse off, so read the directions.
For scale, 0.001% equals 10 mg per kilo of cream, or 0.5 mg in a 50 g jar. A name missing from the list does not prove the substance is absent: its content may be below the threshold, or the label may predate the transition.
Labelling thresholds say nothing about tolerance either. They trigger an obligation to inform, and a person who is already sensitised may still react below them. What the French framework allows a brand to say is covered in our article on CBD cosmetics and sensitive skin.
Hemp terpenes on the list
Here CBD cosmetics have a feature of their own. Terpenes are the aromatic molecules of the plant, and several also serve as perfumery raw materials. A balm scented with a terpene-rich hemp extract, or with pepper, citrus or pine essential oils, can contain them above the thresholds.
| Name on the label (INCI) | Typical smell | Status |
|---|---|---|
| Limonene | Citrus | Already declared before 2023 |
| Linalool | Floral, lavender | Already declared before 2023 |
| Beta-Caryophyllene | Peppery, woody | Added by Regulation 2023/1545 |
| Pinene | Pine resin | Added |
| Terpinolene | Herbal, citrus | Added |
| Terpineol | Lilac | Added |
| Myrcene | Earthy, musky | Not on the list |
"Beta-Caryophyllene" or "Pinene" on a new label means the information is more detailed, and no fragrance has necessarily been added. Our article on hemp terpenes describes their chemistry. A CBD isolate contains no terpenes, so a product made with an isolate and no fragrance has no reason to list these names.
Reading the label in 5 steps
- Write down the batch number or identification reference, which the regulation makes compulsory, together with the exact product name and variant.
- Check whether the product is left on or rinsed off, since that sets the applicable threshold. The word "balm" or "gel" alone will not tell you.
- Read the entire Ingredients list, looking for "Parfum" or "Aroma" and then for the individual names. Ingredients present at under 1% may follow the others in any order, so their position tells you nothing about concentration.
- Compare like with like. When the pack you received differs from the online page, ask the seller which list matches your batch and whether the formula changed or only the label.
- Ask a question that can be checked. "Does this list match the batch shown?" calls for a documented answer, which a line about being "natural" does not provide.
Keep reading past a botanical name, because a natural essential oil can itself contain allergens from the list. Our guide to CBD product labelling covers the other compulsory information on a pack. To judge a formula, see the guide on how to assess a cream, balm or gel.
And CBD: what does the label say?
CBD is absent from this list of fragrance allergens. In the ingredient list it appears under its INCI name, "Cannabidiol". According to MILDECA, the French interministerial mission against drugs, CosIng, the EU cosmetic ingredients database, added pure CBD in February 2021 following the Kanavape ruling of the EU Court of Justice.
There is now a safety benchmark. In 2026, the EU Scientific Committee on Consumer Safety (SCCS) adopted a final opinion judging CBD safe up to 0.19% in cosmetics applied to the skin or used in the mouth. It also judges THC impurities safe up to 0.00025%. This scientific opinion has not yet become a limit written into the regulation, and it does not cover inhaled products.
A CBD cosmetic may not claim any therapeutic effect. The six criteria that apply are set out in our article on permitted claims.
Frequently asked questions
No. "Parfum" designates the fragrance blend as a whole. Listed allergens must be named separately above the threshold: 0.001% for leave-on, 0.01% for rinse-off.
Not automatically. A product placed on the market before 31 July 2026 may be sold with its original label until 31 July 2028. The new list is compulsory only for products placed on the market for the first time after 31 July 2026.
Most likely its fragrance or hemp extract contains substances added to the list in 2023, such as β-caryophyllene or pinenes. The extra names reflect more detailed information and do not imply more fragrance. Ask the seller whether the formula changed.
No. A sensitised person can react to any substance, and a short list does not rule out an allergen below the labelling threshold. If you have a known allergy, search the list for the exact INCI name and ask the manufacturer.
It is absent from the list of fragrance allergens to declare. In its final opinion of 2026, the European scientific committee judges it safe up to 0.19% in a cosmetic, and points out the limits of its own data.
Written by the Phytogrammes team
Each journal article draws on cited primary sources: ANSM, EFSA, EUR-Lex and peer-reviewed publications. Product profiles are distinguished from documented laboratory results. Our approach.
Article published on . CBD is not a medicine.