From policy to practice

The CSS, adopted by the European Commission on 14 October 2020, extends the EU Classification, Labelling and Packaging Regulation with separate hazard classes for endocrine disruptors and for substances that are persistent, bio-accumulative, toxic, mobile or very persistent. It also explores a generic mixture-assessment factor and an essential-use concept that could restrict certain fragrance ingredients unless their broader societal value is demonstrated.

Implications for fragrance

Modern perfumery depends on a palette of roughly three thousand natural and synthetic molecules. When the new hazard classes entered EU law via Delegated Regulation ²⁰²³⁄₇₀₇ (published 31 March 2023), familiar ingredients such as some nitro-musks and certain woody notes required fresh data or reformulation.

The essential-use idea asks whether a substance is indispensable for health, safety or the functioning of society. IFRA provides evidence that fragrance supports hygiene, emotional well-being and cultural expression so that ingredients remain available where they deliver clear benefits.

A proposed mixture-assessment factor would oblige suppliers of scented products to show that combined exposure to multiple substances remains within safe limits. The sector already generates extensive exposure data through the Research Institute for Fragrance Materials and applies the IFRA Standards, giving regulators a science-based reference point.

Through position papers, technical workshops and regular dialogue with the European Commission and the European Chemicals Agency, IFRA seeks proportionate rules that protect people and the environment while allowing Europe’s tradition of scent innovation to continue.

Green Deal recommendations and advocacy tools

To support constructive policymaking, IFRA has published clear policy recommendations on the Green Deal and the Chemicals Strategy for Sustainability. These documents propose a path forward that combines safety, environmental performance and innovation.

We also commissioned a business impact study from Ricardo Energy & Environment to assess how the proposed changes could affect the fragrance value chain. The findings show the importance of building flexibility into policy design and of avoiding unintended restrictions on ingredients that contribute to hygiene, well-being and economic value.

Ricardo Impact Assessment on the CSS IFRA policy paper on the EU Green Deal SHIFT2024 recommendations (external)

Sources for further reading

European Commission, Chemicals Strategy for Sustainability – Towards a Toxic-Free Environment COM(2020) 667, 14 October 2020.
Commission Delegated Regulation (EU) ²⁰²³⁄₇₀₇ amending Regulation (EC) ¹²⁷²⁄₂₀₀₈, adopted 19 December 2022; OJ publication 31 March 2023.
European Commission, “Essential-use concept – Questions and Answers”, 22 April 2024.
The International Fragrance Association, IFRA Standards, 51^st Amendment