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02/03/2026

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General ingredient defence updates

Recent developments under EU chemicals legislation affect a number of fragrance ingredients.

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The Harmonised Classification and Labelling (CLH) proposal to classify 7-hydroxycitronellal (HCA, CAS No. 107-75-5) as a Reproductive Toxicant Category 2 (Repr. 2) has been withdrawn. As a result, the proposal will not move forward at this stage.

In parallel, CARACAL – the Competent Authorities for REACH and CLP – has begun discussions on the draft 25th Adaptation to Technical Progress (ATP) to the EU Classification, Labelling and Packaging (CLP) Regulation. The draft ATP is based on RAC opinions adopted in 2025, as well as one opinion adopted in 2026 concerning a cosmetic ingredient. The current proposal includes both the bourgeonal and cyclamal groups with a proposed Reproductive Toxicity Category 1B (Repr. 1B) classification.

An ad hoc virtual CARACAL meeting has been scheduled for 18 March 2026 to continue discussions on the draft 25th ATP.

Published 02/03/2026 • Updated on 02/03/2026

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