EU Hair Dye Labeling Requirements 2026: Safety Assessment Guide for Hair Color Manufacturers
For hair dye manufacturers and suppliers, getting the formulation right is only half the battle. Labeling, claims, and safety assessment requirements are equally complex and critical under EU Regulation (EC) No 1223/2009.
Because hair dye products carry a real potential for allergic reactions, they are subject to specific labeling obligations. The 2026 regulatory updates have added new labeling requirements, and the SCCS continues to refine its safety assessment expectations. This article is a practical guide to EU hair dye labeling, claims, and safety assessment for hair color manufacturers, suppliers, and factories.
Key takeaways
- Article 19 sets nine mandatory label elements for every hair dye sold in the EU.
- Hair dyes carry mandatory allergy warnings, including the 48-hour allergy alert (patch) test advice.
- Regulation (EU) 2026/909 adds an allergy warning for HC Yellow No. 16; fragrance allergen declarations expand from 31 July 2026.
- The CPSR (Part A + Part B), prepared by a qualified safety assessor, is the core of the Product Information File.
- Every claim—“ammonia-free”, “PPD-free”, “100% gray coverage”—must be substantiated under the Common Criteria.
Core Labeling Requirements
Article 19 of Regulation (EC) No 1223/2009 specifies the mandatory labeling requirements for all cosmetics, including hair dye products. To sell hair dye products in the EU, the following information must appear on the packaging:
- Product name and function — e.g., “permanent hair color”, “semi-permanent hair dye”.
- Responsible Person (RP) — the name and address of the RP established within the EU.
- Country of origin — required on imported products.
- Nominal content — quantity in the container (weight or volume).
- Date of minimum durability — expiry date, or the period-after-opening (PAO) symbol where applicable.
- Batch number — for traceability.
- Precautions for use — including the mandatory allergy warnings for hair dyes.
- INGredient list — all ingredients in INCI names, in descending order of concentration.
- Fragrance allergens — identified individually on the label where required.
INCI Requirements for Hair Dyes
Ingredients must be listed using the standard INCI names from the cosmetics ingredient database. For hair dyes specifically:
- All colorants must be listed, with their CI (Colour Index) numbers where applicable.
- Oxidative hair dye precursors and couplers must be clearly identified.
- The list must be easily readable, in a legible font size.
Hair Dye-Specific Warning Labels
Hair dyes carry specific warning obligations under Article 19 and the relevant Annexes of the Regulation.
Oxidative Hair Dye Warnings
- Oxidative hair dyes containing PPD-type substances must carry the warning “Contains phenylenediamines”.
- Products containing hydrogen peroxide must carry the warning “Contains hydrogen peroxide”.
General Hair Dye Warnings
The EU requires the following warnings on hair dye packaging:
“Hair colorants can cause severe allergic reactions.”
“Conduct an allergy alert test 48 hours before each time you color (see enclosed leaflet), even if you have already used coloring products before.”
“Do not use to dye eyelashes or eyebrows.”
The 48-hour allergy alert (patch) test advice is a critical element of hair dye safety communication. The EU labeling requirements specify that this warning must appear on the packaging, and manufacturers should include detailed patch test instructions in the package leaflet.
New 2026 Labeling Requirements
HC Yellow No. 16 (Regulation (EU) 2026/909). Under Regulation (EU) 2026/909, hair dye products containing HC Yellow No. 16 must carry an allergy warning on the label.
Fragrance allergen declarations (Regulation (EU) 2023/1545). From 31 July 2026, cosmetics placed on the EU market must individually declare a substantially expanded list of fragrance allergens when present above the applicable concentration thresholds (0.001% in leave-on products, 0.01% in rinse-off products). In practice this means that, where a listed sensitizing substance is present in a hair dye formulation above the threshold, it must be named individually on the label—no longer covered by a generic “may cause allergic reaction” statement. For hair dye manufacturers and suppliers, this is a significant increase in the level of detail required on product labels.
The SCCS Safety Assessment Process
The Scientific Committee on Consumer Safety (SCCS) provides scientific advice to the European Commission on cosmetic ingredient safety. For hair dye ingredients, SCCS opinions are particularly important, because some hair dye ingredients can cause skin allergic reactions in people who use the products.
The Cosmetic Product Safety Report (CPSR)
The Cosmetic Product Safety Report (CPSR) is a core component of the Product Information File (PIF) that hair dye manufacturers and suppliers must hold to sell in the EU. It is prepared by a qualified safety assessor and consists of two parts:
Part A — Product safety information:
- Quantitative and qualitative formulation
- Physical and chemical characteristics and stability
- Microbiological quality
- Impurities, traces, and information on packaging material
- Normal and reasonably foreseeable use
- Exposure to the product and to its substances
- Toxicological profile of each substance
- Adverse effects and serious adverse effects
Part B — Safety assessment:
- Assessment conclusion (the product is safe or not safe)
- Labeling warnings and instructions for use
- Reasoning for the assessment conclusion
How the SCCS Evaluates Hair Dye Ingredients
The SCCS evaluates hair dye ingredients through a comprehensive review of toxicological data, including the potential to:
- Cause genetic damage (as seen with Basic Brown 16 and Basic Blue 99);
- Cause allergic reactions;
- Cause cancer;
- Affect reproduction;
- Cause harm after absorption.
When the SCCS concludes that an ingredient is not safe, it indicates that the ingredient should be subject to regulatory action (such as restriction or prohibition) when used in cosmetics, as it did with Basic Brown 16 and Basic Blue 99 in non-oxidative hair dye formulations.
Claims Substantiation for Hair Dyes
Any claim made about a cosmetic product must be substantiated. For hair dye products, common claims include: “long-lasting color”, “100% gray coverage”, “ammonia-free”, “gentle on scalp”, and “natural-looking results”.
The Common Criteria Framework
The European Commission’s Common Criteria for claims substantiation require that claims must:
- Not conflict with the Regulation;
- Be accurate and not create false impressions or artificially created data;
- Be substantiated by adequate and verifiable evidence;
- Be easily understood by the average consumer.
For hair dye manufacturers and suppliers, this means that any claim published on packaging, marketing materials, websites, or elsewhere must be supported by appropriate testing data.
“Ammonia-Free” and “PPD-Free” Claims
Claims such as “ammonia-free” or “PPD-free” are common on hair dye products. Under EU rules:
- If ammonia is not used in the production of the product, it may be labeled “ammonia-free”.
- If the product does not contain ammonia but contains another alkaline agent (such as ethanolamine or monoethanolamine), this must be disclosed clearly to avoid misleading consumers.
- “PPD-free” claims must be accurate — if any PPD-type substance is found in the product, the claim is invalid.
Practical Labeling Checklist for Hair Dye Suppliers
For hair dye manufacturers, suppliers, and factories exporting to the EU, the key labeling requirements are summarized in the checklist below:
| Requirement | Status |
|---|---|
| Product name and function | ✓ Required |
| Responsible Person name and address | ✓ Required |
| Country of origin | ✓ Required |
| Nominal content | ✓ Required |
| Expiration date / PAO symbol | ✓ Required |
| Batch number | ✓ Required |
| INCI ingredient list (descending order) | ✓ Required |
| Individual fragrance allergen declarations | ✓ Required from 31 July 2026 |
| “Hair colorants can cause severe allergic reactions” | ✓ Required |
| “Conduct allergy alert test 48 hours before use” | ✓ Required |
| “Do not use to dye eyelashes or eyebrows” | ✓ Required |
| “Contains phenylenediamines” (if applicable) | ✓ Conditional |
| “Contains hydrogen peroxide” (if applicable) | ✓ Conditional |
| HC Yellow No. 16 allergy warning (if applicable) | ✓ Conditional |
Frequently Asked Questions
What information is mandatory on hair dye labels in the EU?
Under Article 19 of Regulation (EC) No 1223/2009, hair dye labels must show: product name and function, the name and address of the EU Responsible Person, country of origin, nominal content, expiry date or PAO symbol, batch number, precautions for use, the INCI ingredient list in descending order of concentration, and individually named fragrance allergens.
What allergy warnings must hair dye packaging carry?
EU hair dye labels must state that hair colorants can cause severe allergic reactions, advise an allergy alert test 48 hours before each use, and warn not to use the product to dye eyelashes or eyebrows. Oxidative dyes containing PPD-type substances must additionally state “Contains phenylenediamines”, and products containing hydrogen peroxide must state “Contains hydrogen peroxide”.
What are the new labeling obligations for hair dyes in 2026?
Under Regulation (EU) 2026/909, products containing HC Yellow No. 16 must carry an allergy warning. In addition, from 31 July 2026, Regulation (EU) 2023/1545 requires individual declaration of fragrance allergens on the label when present above the applicable concentration thresholds.
Summary
EU hair dye labeling, claims, and safety assessment requirements are among the most detailed in the world. For hair dye manufacturers, suppliers, and factories, compliance requires attention to:
- The full range of mandatory label elements under Article 19;
- Hair dye-specific warnings, including the 48-hour allergy alert test advice;
- Individual fragrance allergen declarations under Regulation (EU) 2023/1545;
- The SCCS safety assessment process, particularly for new or controversial ingredients;
- Claims substantiation under the Common Criteria framework.
Staying current with these requirements—particularly the 2026 updates—is essential for any hair color manufacturer or supplier seeking to maintain EU market access.
Sources
European Commission, Regulation (EC) No 1223/2009, Article 19
Obelis, “Patch Testing Cosmetics: 2026 EU Compliance Rules Explained,” July 31, 2026
Cosmetics Europe, “Recommendation No. 24a – Labelling Information and Warnings for Retail Hair Colouring Products”
LabelCheck, “Cosmetic labelling: requirements of Regulation 1223/2009,” March 21, 2026
CIRS Group, “欧盟SCCS发布关于染发剂Basic Brown 16和Basic Blue 99的最终意见,” February 25, 2026
