The concept of «placing on the market» remains a key factor in planning supply flows. It refers to the act by which the responsible person (RP) releases a unit to the European market, to distributors, or directly to the consumer. Products placed on the market before July 31, 2026, may be sold until July 31, 2028.
More than 80 substances requiring labeling
The new framework broadens the scope of application: more than 80 substances will be required to be listed above the thresholds of 0.01 % for rinse-off products and 0.001 % for leave-on products. This change applies to manufacturers, subcontractors, importers, and distributors. The key tasks identified include verifying formulations, updating labels, and revising product information files (PIFs) as necessary. After July 31, 2026, no non-compliant products may be placed on the European market.
Precise Definition of «Placing on the Market»
Specific examples are provided: in the case of subcontracted manufacturing within the EU, the product is not placed on the market until it is completed and made available by the PR. For imports, the PR—generally the importer—may not supply the product until it has cleared customs. As of July 31, 2026, the PR will no longer be able to supply new non-compliant units. Stock already placed on the market before that date may continue to be sold until July 31, 2028.
Cosmed tools available since 2023
Cosmed offers a practical guide that has been available since 2023. The Practical Guide to Allergens—which is free and immediately available on cosmed.fr—compiles useful information, specifies reporting thresholds, and helps regulatory, R&D, and marketing teams understand the regulations. CosmedTV broadcasts short educational videos to help viewers understand the requirements and prepare for implementation. For in-depth monitoring, Cosmed’s regulatory service provides expert monitoring that analyzes cosmetic, chemical, and environmental regulations in more than 120 countries.
Two key milestones mark the timeline: July 31, 2026, for the cessation of the sale of non-compliant units, and July 31, 2028, for the end of the phase-out of existing inventory. All announced resources are available at www.cosmed.fr.
