The full methodology — what gets computed, what gets flagged, and what stays yours.
The workload the regulation created
Regulation (EU) 2023/1545 expands the individually labellable fragrance allergens from 26 to more than
80 (45 new Annex III entries, plus amendments to existing ones) — including whole botanicals such as
patchouli, ylang-ylang and peppermint oil. Products
placed on the market after 31 July 2026 must comply; everything made available must
comply by 31 July 2028. New import batches count as new placements. For every fragranced SKU that
means: chase updated supplier declarations, recompute every allergen against the 0.001 % (leave-on) /
0.01 % (rinse-off) thresholds, rewrite the INCI list, amend the CPSR, re-notify. Per SKU, roughly an
hour of certificate-chasing arithmetic — portfolio-wide.
Step 1 — Send the documents
The formula with percentages (CSV or spreadsheet) and the supplier documents you already hold: allergen
declarations, IFRA conformity certificates, SDS. Annexa reads the common supplier formats; unreadable or
unusual documents are handled by our team, never silently skipped.
Step 2 — Annexa computes and cross-checks
Threshold mathematics. Every disclosed substance × inclusion rate, aggregated across
all fragrance components, against the product-type threshold. Deterministic arithmetic — no AI touches
your formulas.
Ruleset from the official texts. All 45 new entries of Reg. 2023/1545 (incl. the 2025
corrigendum), the amended and legacy Annex III entries, and outright bans that still surface on old
labels (e.g. BMHCA/Lilial, HICC).
Plausibility cross-check. Declarations are compared against reference constituent
ranges. A may-chang certificate declaring no citral — an oil that is typically 60–75% citral — gets
flagged, not trusted.
Document-coverage report. Any declaration that predates 2023/1545 cannot clear the
new allergens (linalyl acetate alone sits at 25–45% of every lavender oil). You get a per-supplier
re-request list. The scale of the problem is measurable: we analysed 232 public supplier compliance
documents, and 80 of the 83 allergen declarations among them still disclose only the old
26-allergen list.
Step 3 — You review, sign, and bill
The deliverable is a white-label audit workbook: required INCI additions, the complete calculation
trail with every figure cited to the verbatim line of its source document, plausibility warnings, and the
supplier re-request list. You review it, sign it, and bill your client for it.
See a complete example →
Why a maths layer — and not another AI compliance app
Your letterhead, your client. Brand-facing AI platforms pitch your clients directly.
Annexa is consultant-first: white-label output, no brand-side accounts, no disintermediation.
Screening aid, not certification. Every number is a draft for professional review
with mandatory sign-off. That is what makes the output billable by you — and defensible by you.
Confidentiality, structurally. EU-only processing, deterministic pipeline,
self-hosted deployment for firms. The full data story →
It doesn't end with the allergen wave
Stored portfolios re-run automatically on every Annex III change: Reg. (EU) 2026/909 restricts twelve
further ingredients from January 2027, the CMR omnibus cycle continues annually, and UK divergence keeps
dual-market SKUs on two rulebooks. One seat keeps your whole client book current.