Citral in essential oils is now a limit, not just a label. Here is how to work out whether your formula fits.

Which date applies to your product

There are two kinds of date, and they answer different questions.

• 1 January 2027 — placing. From this date a cosmetic product that does not meet the new restrictions shall not be placed on the Union market. This is the date that matters for anything you manufacture, import or release onto the market from then on.
• Sell-through — making available. Stock that was already placed on the market in compliance may stay available for a while longer: until 1 July 2028 for citral itself (3,7-dimethyl-2,6-octadienal, CAS 5392-40-5), and until 1 August 2028 for the two isomer lines of the same entry, geranial (CAS 141-27-5) and neral (CAS 106-26-3).

Which of the two sell-through dates is yours depends on how each raw material declares its citral. A fragrance compound that lists citral falls under the July date. A lemongrass or litsea oil whose certificate lists geranial and neral falls under the August date.

Many botanical products contain both kinds of declaration. My working rule is to apply the earliest date in the file to the whole product, and to rely on the August date only when the file shows that the isomer lines are the sole source of citral in the formula. The month you gain by the other reading is not worth a product that is on the shelf when it should not be.

The limits do not depend on any of this. Citral, geranial and neral sit in one entry (Annex III, entry 70), with one maximum per product type. The text does not say in so many words whether the maximum applies to each substance or to the three together. My reading, which I write into the file, is that it covers them together: add the citral, the geranial and the neral from every source, and compare the sum with the limit.

The limits that matter most to a natural brand

Percentages are of the ready-for-use product. The complete table of nine product types is in the 2026/909 guide; these are the ones natural brands meet first.

Find your product type in the Annex first. The limit that applies to you is the one for your type, not the highest on the list.

Why an IFRA certificate does not settle it

A certificate from a fragrance supplier is a good start, but it covers the fragrance compound and nothing else in the formula. It is set against IFRA's own categories and against the IFRA standard that was in force when it was issued. The EU limit is the law. It uses the Annex's own product types, and it applies to the finished product from all sources: the compound, the essential oils, the plant extracts, anything else that carries citral.

So ask the fragrance supplier for the citral, geranial and neral content of the compound, as numbers. Then do the addition yourself, for the finished product.

Lot-to-lot variation in lemongrass and litsea oil

Lemongrass and litsea oil are both mostly citral. In my working experience the range is in the order of 60 to 85 %, depending on origin and harvest. That range is not a standard, and I do not cite one for it: your supplier's certificate for the lot is the figure that counts.

What follows from it is that a formula can pass with one lot and fail with the next. A worked example for a leave-on skin product, limit 0.15 %, where the oil is the sole source of citral:

The formula has not changed, but the amount of oil it can take has moved by about 12 %. A file that sits close to the limit has no room for that.

The practical answer has three parts:

1. Set a maximum citral content in the raw-material specification for the oil.
2. Calculate at the top of the supplier's stated range, not in the middle of it.
3. Check each lot's certificate against that specification before the lot goes into production. A single certificate from a single lot is how a formula ends up over the limit.

If the oil is not the sole source, subtract what the other ingredients contribute before you divide.

What retailers and distributors should ask brands for

A distributor has a duty of due care under Art. 6 of Regulation (EC) No 1223/2009 and must not make available a product it has reason to believe does not comply. A written answer from the brand protects the distributor as much as the brand. Four things are worth asking for:

1. A dated statement on whether any of the twelve substances named in Regulation (EU) 2026/909 is in the formula, and for which dates.
2. The date each batch was first placed on the Union market, because that date decides whether the stock is covered by the 1 January 2027 date and by the sell-through dates.
3. Confirmation that the safety report, the product information file and the CPNP notification have been updated where the formula changed (Art. 10(1), Art. 11(1), Art. 13(1)).
4. The contact details of the Responsible Person.

Use the corrected text

Two corrigenda exist. The one of 5 May 2026 renumbers the new Annex III entries (381 to 386 instead of 379 to 384). The one of 8 May 2026 corrects an Annex II reference. If you downloaded the Regulation before those dates, or you are working from a summary written then, check the entry numbers against the corrected text.

What I would expect next

This section is my view, not a statement of the law. Non-compliant products can still be placed on the market until the end of 2026, so I would expect enforcement on citral to start in 2027. I would expect the early checks to fall most often on products sold online from outside the EU. Measuring citral in a finished product is routine for a laboratory; what takes care is choosing the right one of the nine limits.

If you work with essential oils, I would also keep an eye on tea tree oil, which has a final SCCS opinion but, as of the consolidation of 18 May 2026, no entry in Annexes II–VI, and on heliotropin, whose opinion was still being finalised in early September.

What to do

1. Ask each botanical supplier for a lot-level composition: citral, geranial, neral.
2. Calculate the finished product for every product type you sell, adding the three substances from all sources.
3. Write the specification limit into the raw-material specification and calculate at the top of the range.
4. Decide the date with the earliest-date rule above, and write down why.
5. Update the file if the formula changes: the safety report, the product information file and the notification.

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