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从政策到实践
欧盟委员会于 2020 年 10 月 14 日通过了《可持续性化学品战略》（CSS），该战略扩展了《欧盟分类、标签和包装法规》，为内分泌干扰物和具有持久性、生物累积性、毒性、流动性或极持久性的物质规定了单独的危害等级。它还探讨了通用混合物评估因子和必要用途概念，该概念可限制某些香料成分，除非其更广泛的社会价值得到证明。
对香水的意义
现代香水依赖于大约三千种天然和合成分子的调色板。当新的危害等级通过第 2023⁄707 号委托法规（2023 年 3 月 31 日发布）进入欧盟法律时，一些熟悉的成分，如硝基麝香和某些木质香料，需要新的数据或重新配方。
必要用途的概念是指一种物质对于健康、安全或社会运转是否不可或缺。IFRA 提供的证据表明，香水有助于卫生、情感健康和文化表达，因此，只要成分能带来明显的益处，就可以继续使用。
拟议的混合物评估因子将要求香味产品供应商证明，多种物质的综合暴露量保持在安全范围内。香料行业已经通过香料研究所（Research Institute for Fragrance Materials）生成了大量的暴露数据，并应用了国际香料协会标准（IFRA Standards），为监管者提供了一个以科学为基础的参考点。
通过立场文件、技术研讨会以及与欧盟委员会和欧洲化学品管理局的定期对话，IFRA 寻求制定相称的规则，在保护人类和环境的同时，让欧洲的香味创新传统得以延续。
The fragrance industry: Continuing the safety mission
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 12 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”
What the fragrance industry does
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. Because are made from dozens or even hundreds of individual ingredients, 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.
Fragrance sector workability requirement
For the fragrance sector, the concept of workability is fundamentally about ensuring that regulatory expectations can be met in practice[AP1] . 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.