IFRA and the International Society of Perfumer-Creators share perspectives on ingredient substitution at the European Commission’s CPWG meeting

Joining the discussion on behalf of ISPC, Thierry Wasser, President of the ISPC provided a unique perspective from the creator’s side. His contribution focused on the technical and artistic realities of ingredient substitution, and how reformulation processes unfold in practice within today’s complex regulatory framework.

Speaking as the head of a global community of perfumer-creators, Thierry Wasser explained what it truly means to reformulate an existing fragrance. He described the creative, sensory and technical functions of the many hundreds of materials in a perfumer’s palette, and how each contributes to the balance and performance of a fragrance. He highlighted that removing or changing one material impacts the entire architecture of a scent, and that reformulation is a careful, time-intensive process that requires harmonising safety, compliance and olfactory integrity.

He also described how this work is supported by decades of safety science conducted through IFRA, the Research Institute from Fragrance Materials (RIFM) and the International Dialogue on the Evaluation of Allergens (IDEA) project, which collectively support a strong global safety framework for fragrance ingredients.

He explained that the fragrance sector has consistently adapted to new requirements under REACH, CLP and cosmetics legislation. He stressed that perfumers work responsibly within these frameworks, while also safeguarding cultural heritage, craftsmanship and the quality of consumer experience.

The conversation underscored the value of continued collaboration between the fragrance sector and regulators to ensure that safety assessments and regulatory tools reflect consumer, use in cosmetics, and the technical realities of complex fragrance formulations. IFRA and the ISPC reiterated the need for clarity, proportion and scientific consistency, along with timelines that allow responsible innovation and reformulation.

During the exchanges, Thierry Wasser also highlighted broader challenges faced by the fragrance sector. He noted the limits of hazard-only approaches and explained why exposure-based assessment is essential for understanding real-world use. He underlined the difficulty of applying regulatory tools originally developed to protect workers dealing directly with high-volume industrial chemicals, but which are now being used to regulate complex fragrance mixtures used in very small quantities – and pointed to sectoral inconsistencies where the same molecule may be treated differently depending on the category of use. He also stressed the impact of regulatory decisions on agricultural supply chains – from rose and citrus to lavender – and the limited operability of Article 15 in real-life fragrance applications. These points were presented as part of the shared need for proportionate and workable solutions.

In her complementary intervention speaking on behalf of IFRA and Cosmetics Europe, Veronique Scailteur presented evidence from recent safety evaluations and creation efforts to maintain the olfactive notes of fragrance, highlighting how the fragrance and cosmetics sectors already apply strong safety controls long before and long after ingredient classifications. Drawing on the example of Lilial, she explained how extensive data generated over decades – through RIFM, SCCS reviews and Cosmetic Product Safety Reports – demonstrated safe use in cosmetic conditions, even when later hazard-based classifications triggered regulatory bans. She showed how companies undertake years of research to identify and validate alternatives, often reshaping the olfactive notes of thousands of finished products, and emphasised that industry does not seek derogations where workable substitutes exist. Her message underlined that safety and responsibility are embedded across the sector, and that the Omnibus is an opportunity to build a system that recognises exposure, real-use conditions and feasibility when evaluating the availability of alternatives.

Jointly attending the CPWG meeting reflected the fruitful cooperation between IFRA and the ISPC, and the shared commitment to supporting workable and science-based regulatory solutions for fragrance ingredients that respect both consumer safety and the long-standing cultural and creative heritage of perfumery.