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Regulations & EHS&S



Fragrance regulations

By Charlotte Purcell, Global Technical Director of CPL Aromas - 2nd September 2019

Charlotte Purcell, Global Technical Director of CPL Aromas, gives her personal perspective on dealing with regulations, meeting current trends and coping with Brexit.
 
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Regulations governing the fragrance industry are complex and it is an ever-changing environment. We must consider not only international, industry and product regulations but also ensure that our fragrances comply with our customers’ requirements. The uncertainties of Brexit bring an added set of challenges for our sector, as for so many others.
 
Fragrance houses try to assist their clients in keeping up to date with these regulatory changes. CPL Aromas does so by holding Regulatory Seminars, enabling our clients to discuss the challenges they face and updating them about any regulatory changes.
 
The new IFRA 49 Standards are due to be published later this year (2019) and this represents the most fundamental change to the IFRA standards since 2006. This industry body – the International Fragrance Association (IFRA) - is a global organization that plays a major role in self-governance for the sector.  IFRA has a Code of Practice which ensures consistency and compliance for the use of fragrance materials, regulating the safety of fragrance materials and compounds and ensuring human and environmental safety.
 
IFRA 49 will include an update to the list of categories and number of standards. It will also include a change to how the levels are calculated, moving to a quantitative exposure-based risk assessment with cumulative and systemic effects taken into account as well as the current sensitising effects of certain materials used by perfumers.
 
The introduction of IFRA 49 means that new documentation will be sent to all clients advising them of the new IFRA limits and timelines for implementation. This could mean a change to the allowed level of fragrance in their products. We also expect the number of IFRA categories to rise to 12 from 11 and the number of sub classes to drop to 16 from the current 22. The implementation timeline once the standards are published is expected to be 13 months for new creations and 2 years for existing fragrances.
 
Alongside IFRA 49, one of the other issues the sector faces now is the challenge of reclassifications of key fragrance ingredients. Following the process of REACh and the introduction of additional testing requirements, this has led to several reclassifications of some of our commodity items which in turn can lead to the re-classification of our customers’ products. This is particularly of note for air fragrance products such as candles or reed diffusers where CLP labelling is a requirement.
 
The natural fragrance market is dynamic and growing and CPL Aromas’ Natural Platform responds to this trend. Consumers are becoming increasingly aware of what they are buying, leading to a growth in ethical brands. Fulfilling a sustainable lifestyle however can be challenging when marketing is often driven and confused by vague claims and a glossary of terms that doesn’t have industry recognition or firm definition.
 
Driven by the next generation, the beauty community is looking for products that work holistically with people’s health concerns, ensure kindness to the planet and offer supply chain transparency. The CPL Aromas’ Natural Platform is a drive to create 100% natural fragrances that will define the naturals market in an educational and transparent way.
 
The fragrance industry always tries to stay several steps ahead of regulatory needs or public demand. A good example of this is the development of technological solutions to support sustainability needs as demonstrated by CPL’s EcoBoost Fragrances. These use just 10% of the normal fragrance dosage with no compromise in strength or quality, leading to a reduction in packaging as well as reduced transport, energy and disposal costs.
 
The requirement to label your non-cosmetic products according to CLP and the increased reclassification of materials as noted earlier means EcoBoost comes into its own. Its lower dosages are often below the regulatory threshold required for these labels, and so do not require on-pack labelling.
 
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Brexit negotiations brings complexities to the work we do and, from a regulatory perspective, the main concern is REACh. In the event of a ‘no deal’ Brexit, the UK will be immediately responsible for regulating chemicals through its own legislation. We are working with our suppliers to confirm that any raw materials produced or imported into the UK in relevant quantities with existing EU REACh registrations are ‘grandfathered’ into the UK regime; and we aim to ensure that raw materials produced in the UK continue to be EU REACh compliant.
 
However, we have met the challenges head on by pre-empting possible difficulties. In preparation for what could be a major change, CPL Aromas bought an existing Spanish fragrance house which is now operating as CPL Aromas Spain. This gives CPL an EU manufacturing base well ahead of the point when the UK leaves the EU.
 
Author:
Charlotte Purcell, Global Technical Director of CPL Aromas, Innovation House, 97 London Rd, Bishop's Stortford, CM23 3GW, UK
www.cplaromas.com