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Targeted adjustments
The Omnibus VI proposes targeted adjustments to three pieces of legislation: the Regulation on the Classification, Labelling and Packaging of chemicals (CLP), the Regulation on Cosmetic Products and the Regulation on Fertilising products. The relevant changes for the fragrance industry relates to CLP, and the Cosmetic Products Regulation (CPR).
What it means for fragrance
Under the Classification, Labelling and Packaging of chemicals (CLP) Regulation, the adopted text provided legal certainty through the “stop-the-clock” mechanism putting on hold certain provisions introduced by the revision of CLP in 2024. In addition, the proposal aims to make labelling rules more practical for small vials and samples widely used in the fragrance industry and restore realistic timelines for the label updates of self-classified substances.
For the fragrance sector, this matters because companies, especially SMEs, work with a high number of customised mixtures, each requiring its own label. Fragrance samples and small vials are essential business tools used daily in creation, testing and customer decision‑making. When every formulation needs a unique label, even minor changes in labelling rules can result in thousands of updates across a company’s portfolio. This creates a heavy administrative and financial burden, particularly for smaller businesses with limited resources. The proposed adjustments help ensure that compliance remains achievable without diverting time and investment away from innovation, product development and workplace safety.
Under the Cosmetic Products Regulation, the proposal aims to clarify how ingredients that have been classified can continue to be used in cosmetics, bringing transparency to a derogation process that has not resulted in a single derogation since the legislation applied in 2012.
More specifically, the proposal introduces clear deadlines and transitional periods, establishes a proportionate approach for constituents of natural complex substances, and streamlines the derogation procedure.
It reaffirms the central role of the Scientific Committee on Consumer Safety (SCCS) in assessing safety and enabling the continued use of classified ingredients in cosmetics.
The proposal does not alter the safety assessment that is to be carried out when applying for a derogation for a CMR-classified substance. The independent Scientific Committee on Consumer Safety (SCCS) will continue to be the essential safeguard only allowing safely used ingredients in cosmetic products.
Fragrance: A rules-dependent sector
As an industry operating in a highly complex global supply chain, the fragrance sector depends on rules that keep safety at the heart of the system, while still being practical to implement.
Yet, under the current Cosmetic Product Regulation, no derogation has ever been granted in 13 years despite several dossier submissions, highlighting that the existing mechanism is not functioning as intended, and cannot play the role it was designed to support.
“The fragrance sector operates as a highly technical and integrated part of the European economy”
Safety as a core ingredient
The fragrance sector operates as a highly technical and integrated part of the European economy, characterised by a deep commitment to rigorous safety science. This work begins with the exhaustive assessment of every ingredient, whether derived from natural sources or through synthetic chemistry.
This ensures that all materials meet the most stringent standards for consumer protection. This scientific oversight provides the foundation for the safety profiles of the thousands of products used by consumers every day.
Reformulating a fragrance is a highly complex process. Fragrances are made from dozens or even hundreds of individual ingredients, so replacing even a single ingredient often requires rebalancing the entire formula to maintain the original olfactive character while simultaneously ensuring the stability, safety, and performance of the newly formulated product.
Inspiring creations need workable rules
For the fragrance sector, the concept of workability is fundamentally about ensuring that regulatory expectations can be met in practice. Any assessment of ‘suitable alternatives’ must be anchored in what is technically, economically, and olfactively achievable. A regulatory requirement that necessitates disproving an infinite number of hypothetical combinations or technologies represents an insurmountable hurdle for a creative industry built on precision and specificity.
Furthermore, the industry requires implementation timelines that reflect the time required for the complex process of reformulation and supply-chain adjustments. Realistic transition periods prevents the unnecessary destruction of safe products and ensures that small and medium-sized enterprises (SMEs) have the necessary window to adapt their production without facing significant market disruption.
A science-based approach must also consider how fragrances are actually used, As consumers primarily experienced them through the skin, regulatory decisions should focus on relevant exposure routes rather than relying solely on abstract hazard profiles.
Finally, it is essential that the regulatory framework recognizes the unique nature of natural ingredients. Ensuring that the derogation process remains accessible for substances which are constituents of natural ingredients is vital to preserving ingredients that are both culturally and economically significant to the European landscape, supporting a value chain that stretches from local farmers to global creators.
Balancing safety, clarity and innovation in European cosmetics regulation
Aurélie Perrichet, Regional Director Europe EMEA, and Johannes Weiss, Manager Public Affairs and Sustainability Europe, outline key the regulatory developments in EU chemicals policy
A long-standing challenge has been the potential banning of ingredients based on hazard classification, even where safe use in cosmetics can be demonstrated, leading to unnecessary reformulation and lost innovation.
In response, the European Commission proposed the Omnibus VI on Chemicals, recognising regulatory complexity as a barrier to investment.
For IFRA, the proposal brings meaningful improvements, including more workable labelling rules under CLP, realistic implementation timelines, and a more functional derogation system for cosmetics. In 2026, discussions will continue as EU institutions work towards a balanced, science-based outcome that protects consumers while supporting innovation and competitiveness.