The proposal is currently undergoing public consultation before any final requirements are adopted. Although still in draft form, it provides an early indication of the direction Indian authorities are taking regarding ingredient safety, environmental protection and sustainable sourcing.
For cosmetic manufacturers and fragrance suppliers, the proposal is an opportunity to review formulations and evaluate the potential regulatory impact on products intended for the Indian market.
Why Is India Introducing This Measure?
The draft has been developed within the framework of the Bureau of Indian Standards, India’s national standardization body.
According to the proposal, the objective is to establish a harmonized list of fragrance raw materials that should no longer be used because of concerns related to one or more of the following:
- Human health and toxicological risks.
- Environmental impact.
- Sustainability of sourcing.
- Improved consistency in regulatory compliance across the fragrance sector.
Although the document is addressed to the fragrance industry, its practical implications extend to numerous downstream industries that incorporate fragrances into finished products, particularly cosmetics and personal care formulations.
Scope of the Draft Standard
The proposed standard defines a list of prohibited fragrance raw materials that would not be permitted in fragrance compositions.
Its scope includes products manufactured or marketed for sectors such as:
- Fine fragrances and perfumes.
- Cosmetics and personal care products.
- Household cleaning and air-care products.
- Incense and similar fragranced products.
Therefore, this proposal affects not only fragrance manufacturers but also cosmetic brands, contract manufacturers and formulators using fragrance compounds supplied by third parties.
The Proposed List of Prohibited Ingredients
Annex A of the draft contains 64 fragrance raw materials identified by their chemical names and CAS numbers. The substances include synthetic aroma chemicals, solvents, nitro musks, essential oils and naturally derived ingredients that have been associated with safety or environmental concerns.
Among the substances included are Musk Ambrette, Benzene, Toluene, Nitrobenzene, Safrole, Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde (HICC), Peru Balsam, Costus Root Oil, Chenopodium Oil, Styrene, Ethyl Acrylate, Furfuryl Alcohol, Hydroquinone Monomethyl Ether, Hydroquinone Monoethyl Ether and Colophony.
Several naturally derived ingredients also appear on the proposed list, reflecting that regulatory decisions are based on scientific risk assessment rather than on whether an ingredient is synthetic or natural.
The draft specifies each prohibited substance together with its corresponding CAS number to facilitate unambiguous identification throughout the supply chain.
What Does This Mean for Cosmetic Manufacturers?
Although the proposal has not yet entered into force, companies supplying cosmetics or fragranced products to India should begin evaluating its potential impact.
Manufacturers may wish to:
Review fragrance compositions supplied by fragrance houses, identify whether any listed substances are present in existing formulations, discuss possible reformulation strategies with suppliers where necessary, and monitor the progress of the draft through the consultation process.
For companies operating internationally, this proposal also highlights the importance of continuously monitoring regulatory developments in different markets, as ingredient restrictions increasingly vary between jurisdictions.
