A peptide serum sold in the EU needs a fragrance-allergen review of the complete formula. The peptide's trade name will not tell the label team which allergens arrive through perfume, botanical extracts or other blended raw materials. For a new launch, collect current supplier declarations before approving the carton. A late discovery can change the ingredient list after packaging has already been printed.
The figures that affect a leave-on serum
The European Commission explains that Regulation (EU) 2023/1545 introduced individual labelling for 56 additional fragrance allergens. Listed allergens must be declared when their concentration exceeds 0.001% in a leave-on product or 0.01% in a rinse-off product. A conventional facial serum belongs in the leave-on assessment. These are labelling thresholds, not universal safe-use limits. [1]
The Commission identifies 31 July 2026 as the transition deadline for placing non-compliant products on the EU market. Qualifying products already placed on the market before that deadline may remain available until 31 July 2028, subject to the regulation. A new launch after that deadline needs labels that meet the current requirements. A purchase order or a production date alone does not establish when a product was placed on the market. [2]
Build the calculation from commercial grades
Ask for a declaration tied to each supplier product code and revision. An old statement covering only the former allergen set may leave gaps. Record whether the supplier provides an exact concentration, a maximum specification or a range. Where a range crosses a label threshold, the responsible person needs sufficient information to reach a defensible decision.
- List the percentage of every commercial raw material in the finished formula.
- Obtain relevant allergen data for the fragrance and other potentially contributing blends.
- Match substance identities and applicable grouped entries before adding contributions.
- Keep the calculation linked to the approved formula and artwork revision.
A declaration for the neat peptide does not cover the entire stock solution. Review its carrier and other declared components as part of the same exercise. For ingredient identity questions, the cosmetic peptide knowledge library provides a starting point.
A worked example: two sources of the same allergen
This is a hypothetical mass-balance example, not a formula or a supplier result. Suppose a perfume is used at 0.20% by weight and contains 0.60% of a particular listed allergen. Its contribution is:
If a botanical blend used at 1.00% contains another 0.04% of that same allergen, it contributes 0.0004%. The combined concentration is 0.0016%, equivalent to 16 ppm by mass. That exceeds the 0.001% leave-on labelling threshold. Reviewing the botanical and perfume separately would miss their combined contribution.
Keep percentages on the same basis
Use mass fractions consistently. A volume-based dosing instruction needs the appropriate density information before it can enter a weight-based calculation. Include all relevant sources, retain the supplier assumptions and ask the responsible person to resolve grouped-substance or nomenclature questions. Do not round an uncertain result down to avoid a label entry.
Keep the label review separate from formula compatibility
A correct ingredient list cannot establish that a fragrance is compatible with a copper peptide or a thickened serum base. A supplier or fragrance change can alter odour, colour, clarity or dispensing behaviour. Evaluate the revised finished formula and package against the approved development plan.
Likewise, a passing stability result does not answer the allergen-labelling question. Assign separate owners for composition data, safety assessment, formula testing and artwork approval. Their records should reference the same commercial version. The site's EU CPNP and UK SCPN guide covers the wider document handover.
Documents to request before printing
- A dated allergen declaration identifying each relevant commercial grade.
- The finished-formula calculation, including contributions from blends.
- The agreed ingredient names and final ingredient-list order.
- Confirmation that the product information file and safety assessment reflect the marketed composition.
- Approved bottle and carton artwork, with a change-control owner.
If a contract manufacturer keeps the quantitative formula confidential, arrange an appropriate confidential review with the responsible person. A generic assurance that a perfume is compliant leaves the brand unable to trace the concentration calculation.
Frequently asked questions
Does a peptide serum need an allergen label if it contains no perfume?
Review the complete composition. A listed fragrance allergen may arrive through another raw material. The absence of a perfume addition does not replace supplier declarations and the finished-product calculation.
Does 0.001% mean the maximum amount allowed in a serum?
It is the individual labelling threshold for relevant allergens in leave-on cosmetics. Substance-specific restrictions and the finished-product safety assessment remain separate requirements.
Can I use old packaging for a new EU launch after July 2026?
A new launch must meet the applicable current requirements. The transition for qualifying products already placed on the market before the July 2026 deadline is not a general permission to use old labels for new stock.
Will changing fragrance require a new review?
Yes. Obtain the new grade's composition information, recalculate relevant allergens and assess the effect on formula testing, safety documentation and artwork before release.
Sources and scope
Sources checked on 31 October 2026. This is editorial guidance for cosmetic formulation and procurement. Examples are hypothetical unless a source is identified; no original product testing or certification is claimed.
Regulatory points are market-specific. Confirm the applicable requirements and product assessment before launch. For a correction or a question about the sources, contact Pure Peptide Serum.