Understanding and meeting the evolving European Requirements for Body Oils is a core compliance imperative that all relevant brands and manufacturers must address in 2026 and beyond. With the growing popularity of natural and therapeutic concepts, products containing body oils have gained wide acceptance in the European market. However, the European Union maintains one of the world’s most stringent and rapidly evolving regulatory frameworks for cosmetics. This article will systematically sort out the key regulatory developments affecting body oil products, providing clear and forward-looking compliance guidance for enterprises.
Quick Overview of Key European Requirements for Body Oils (2026–2028)
The table below summarizes the key EU regulatory updates affecting body oil products in the near term, helping you quickly grasp compliance timelines and core requirements.
| Key Regulatory Points | Core Requirements | Key Effective/Deadline Dates |
| CLP Regulation and Classification of Essential Oils | A proposed amendment that could have classified essential oils as a whole as “harmful to health” has been temporarily excluded following industry advocacy. However, relevant negotiations and reviews are still ongoing, and businesses must continue to monitor the final developments. | To be determined |
| Allergen Labeling (EU) 2023/1545 | The number of fragrance allergens that must be individually listed in the ingredient list has been significantly increased from 26 to 80. Whole oils of common essential oils (such as lavender, citrus, patchouli, ylang-ylang, etc.) have themselves been included in the list. | From 31 July 2026, newly launched products must comply with the new regulations. From 31 July 2028, all products on the market must be compliant. |
| CMR Substance Ban (Omnibus Procedure) | Through the EU “Omnibus” procedure, substances consistently identified as carcinogenic, mutagenic, or toxic for reproduction (CMR) are rapidly added to the list of substances banned in cosmetic products. | Subject to ongoing dynamic updates. For example, the compliance deadline for Omnibus VIII Regulation ((EU) 2024/2564) is 1 May 2026. |
| PFAS Restrictions (REACH Regulation) | Per- and polyfluoroalkyl substances (PFAS) are strictly regulated due to their persistence. The total concentration of specific PFAS (such as PFHxA) in cosmetic products must not exceed extremely low limits. | As of 10 October 2026, products exceeding the limits shall not be placed on the market or used. |
| Packaging and Packaging Waste Regulation (PPWR) | Packaging must be recyclable and reduced, with the extended producer responsibility scheme enforced. This directly impacts packaging design, material selection and costs for essential oil products. | Key implementation standards (such as unified labeling formats) are expected to be adopted by 12 August 2026. |
| Tea Tree Oil Concentration Limits | The European Union Scientific Committee on Consumer Safety (SCCS) has issued safe concentration limits for tea tree oil in specific product categories. | Shall be used as the latest safety evidence for product safety assessment. |
1.Regulatory Cornerstone: Core Regulatory Framework
In the European Union, body oil products shall primarily comply with Regulation (EC) No 1223/2009 on cosmetic products if their main purpose is to clean, perfume, or beautify the body. This regulation establishes the responsible person for product safety, mandatory product information files, and requirements for safety assessment reports.
At the same time, as substances, essential oils must also comply with horizontal chemical regulations:
- REACH (Registration, Evaluation, Authorization and Restriction of Chemicals): For essential oils imported into the EU, if the annual import volume exceeds 1 ton, registration must be completed by a legal entity established in the EU (e.g., an importer or a designated Only Representative).
- CLP (Classification, Labelling and Packaging of Substances and Mixtures): Essential oils must be classified according to their hazards, and a compliant Safety Data Sheet (SDS) must be provided.
2.Ingredient Safety and Dynamic Updates
CLP Classification Disputes and Industry Exemptions
At the end of 2022, a European Commission proposal to amend the CLP Regulation had planned to classify essential oils as a whole as “harmful to health”, triggering strong opposition from major producing countries such as Bulgaria and France. Following negotiations, the European Parliament adopted a compromise text, temporarily excluding essential oils from this new classification.
This does not mean a relaxation of supervision, however. The Council of the European Union has requested the Commission to submit a new analytical report in four years’ time, and the future direction of classification still requires close monitoring.
Rapid Ban on CMR Substances (Omnibus Procedure)
The EU has established an efficient “Omnibus” mechanism. Once a substance is harmoniously classified as a CMR substance (carcinogenic, mutagenic or toxic for reproduction) under the CLP Regulation, it will typically be added to the list of banned substances in cosmetic products via an amendment within a few months.
For example, Omnibus VIII Regulation sets 1 May 2026 as the compliance deadline. Companies must establish a continuous monitoring mechanism to ensure that their formulations do not contain the newly banned CMR substances.
Assessment and Restrictions of Specific Ingredients
In addition to systematic bans, the European Union Scientific Committee on Consumer Safety (SCCS) continuously conducts safety assessments on specific ingredients. For instance, the SCCS has issued opinions specifying the safe concentration limits of tea tree oil in different product categories such as shampoos, shower gels, and creams. Brands must adopt these latest scientific opinions in their product safety assessment reports.
3.Allergen Labeling: The Most Widely Impactful New Mandatory Regulation
Regulation (EU) 2023/1545 represents the most direct and far-reaching regulatory amendment affecting body oil products. It significantly expands the list of fragrance allergens that must be declared in the ingredient list of cosmetic products.
- Scope expansion: The number of allergens requiring individual declaration has increased from 26 to 80.
- Coverage of essential oils themselves: For the first time, the new list includes numerous whole essential oils, such as lavender oil, patchouli oil, ylang-ylang oil, and citrus essential oils. This means that whenever the concentration of such essential oils in a product exceeds the relevant threshold (> 0.001% for leave-on products, > 0.01% for rinse-off products), their specific names (e.g., “lavender oil”) must be clearly indicated in the ingredient list.
- Compliance timelines:
- From 31 July 2026, all newly placed products on the market must comply with the new labelling requirements.
- A transition period applies until 31 July 2028 for products already on the market.
4.Packaging and Sustainability: A Non-Negligible Compliance Dimension
The Packaging and Packaging Waste Regulation (PPWR) sets new environmental standards for the packaging of body essential oil products.
- Core requirements: include packaging minimisation, improved recyclability, targets for recycled plastic content, and the full implementation of the extended producer responsibility scheme.
- Key milestone: The European Commission is expected to adopt uniform packaging labelling requirements by 12 August 2026 to support separate collection. Brands should plan ahead and adopt compliant eco-friendly packaging.
5.Supply Chain and Documentation Requirements
EU buyers typically require suppliers to provide complete technical documentation to demonstrate product compliance and traceability, mainly including:
- Safety Data Sheet: SDS in compliance with CLP and REACH requirements.
- Certificate of Analysis: Certifying that each batch of essential oils meets specifications.
- Allergen Declaration: Providing accurate allergen ingredient information in accordance with (EU) 2023/1545.
- Traceability Information: Including botanical source, harvest date, extraction method, etc.
Summary
Overall, the requirements for body essential oils in Europe will become stricter and more complex in 2026, showing three major trends:
tightening horizontal chemical regulations, refined vertical cosmetic labeling, and implementation of sustainability requirements.
Companies must adopt a proactive compliance strategy:
- Review formulations and labeling immediately: Focus on verifying whether products are affected by the latest CMR bans, and update all product ingredient labels in strict accordance with the expanded allergen list (80 substances), ensuring completion by 31 July 2026.
- Establish a dynamic monitoring system: Subscribe to official updates or use professional service providers to continuously track CLP classifications, Omnibus amendments (such as the next deadline of 1 May 2026), and SCCS scientific opinions.
- Restructure supply chain documentation: Obtain updated allergen declarations and complete technical dossiers from suppliers in line with new regulations to ensure compliance starting from the source.
- Reassess packaging strategies: Integrate PPWR requirements into new product development and existing packaging upgrade plans, in order to meet the upcoming extended producer responsibility and unified labeling requirements.
If you are looking for a body essential oil manufacturer, please contact us. DESIFINE will empower your products.
