Cosmetics that are scented are a unique part of the beauty industry. They are designed to evoke emotions, enhance personal style, and leave a lasting impression. But in the EU, compliance is just as important as creativity in getting to the market.
One thing that perfumes, body mists, and hair perfumes all have in common is that they are all applied directly and left on, and they are often used a lot. This means that people who use these products are more likely to come into contact with fragrance ingredients, allergens, and solvents than with many other cosmetics. Because of this, these products are at the intersection of the EU Cosmetics Regulation (EC) No 1223/2009 and the IFRA Standards. These two sets of rules outline the requirements for manufacturers to produce, label, and document their products.
In this guide, we’ll explain why these products need special care, what it means to follow IFRA rules, how CPSR rules apply, and what the new EU allergen rules for 2023 mean for your brand.
Why These Products Need Special Attention
High Fragrance Load and Frequent Use
Many perfumes, body mists, and hair perfumes have a lot of fragrance oils in them. Fine fragrances, in particular, may have some of the most powerful scents in cosmetics. When you use these products often throughout the day, your skin and, in the case of hair products, your respiratory system are exposed to them again and again.
Larger Skin and Hair Exposure Areas
Body mists can cover a lot of ground in just one application. Hair perfumes are made for hair, but they can easily get on your neck, face, and even your clothes or bedding. Because of this wider exposure, it is important to make accurate safety assessments.
Risk Factors for Allergens and Sensitisation
Allergens in fragrances are one of the most common things that make people’s skin react to cosmetics. The more often a product is used and the bigger the area it covers, the more likely it is to cause sensitization, especially if the allergens are not properly labeled and handled.
EU Cosmetic Regulation: The Legal Framework
Regulation (EC) No 1223/2009 essentials
This rule is what keeps cosmetics safe in the EU. It applies to all cosmetics sold, from perfumes to skin care products, and it says that each one must be safe for people to use in normal or reasonably foreseeable ways. It also makes rules about how products are made, how they are labeled, what claims they can make, and how technical documents should look.
Role of the Responsible Person
A Responsible Person (RP) who lives in the EU/EEA must be in charge of each cosmetic. This person or company is completely responsible for following the law. They are responsible for making sure the formula meets safety standards, checking that the claims and labels are correct, and keeping the Product Information File (PIF) ready for inspection. They must also update the PIF if the formula, packaging, or regulations change.
CPNP Notification and PIF Requirements
Before a product can be sold, the RP must tell the Cosmetic Products Notification Portal (CPNP) about it. This is a central EU database that authorities and poison centers can access. The PIF must be full and up to date. It must have:
- The CPSR, or Cosmetic Product Safety Report
- A complete description of the product
- Information about how the product was made and whether it follows good manufacturing practices (GMP). Proof for any claims made about the product. Information about any animal testing that was done
This system makes sure that all cosmetics sold in the EU can be traced, are checked by regulators, and are safe for consumers.
What is IFRA Compliance?
IFRA’s Role in Fragrance Safety
The International Fragrance Association (IFRA) makes rules for how to safely use fragrance ingredients all over the world. IFRA Standards are not required by law in the EU, but they are widely known and used by safety assessors to help make sure that rules are followed.
Categories relevant to perfumes, body mists & hair perfumes (Cat 4 & 7B)
There are different types of fragrance categories based on how they are used:
Category 4: Fine scents that are put on the skin, like perfume, eau de toilette, and eau de parfum.
Category 7B: Hair products that you leave on, like hair perfumes and styling sprays.
Choosing the right category is very important for figuring out safe levels of use.
The 51st Amendment: Key Updates for Brands
The 51st Amendment changed the IFRA Standards by changing the limits on concentrations, making the definitions of categories clearer, and improving the Quantitative Risk Assessment (QRA) process. Brands need to make sure that their fragrance suppliers give them IFRA Certificates of Conformity for the right category and dose.
Regulation (EU) 2023/1545: New Allergen Rules
Regulation (EC) No 1223/2009 governs the safety of cosmetics in the EU. It covers all cosmetics sold on the market, such as perfumes, body mists, and hair perfumes. The main rule of the regulation is that all products must be safe for people to use under normal or reasonably expected conditions. It also makes it clear what the product’s ingredients, labels, claims, and paperwork should look like.
Every cosmetic must have a Responsible Person (RP) in the EU/EEA to make sure it meets these standards. The RP is legally responsible for making sure that the formula meets safety standards, that the labeling and claims are correct, and that the Product Information File (PIF) is complete and available for authorities to look at. The RP must also keep the PIF up to date if the formula, packaging, or rules change. This means that the product must always be in compliance.
The Cosmetic Products Notification Portal (CPNP) must register a product before it can be sold. Regulatory authorities and poison centers can access this EU database. This makes it easy to find safety information quickly if needed. The PIF must include the Cosmetic Product Safety Report (CPSR), a full description of the product, details about how it was made according to Good Manufacturing Practice (GMP), proof of any marketing claims, and information about any animal testing that was done. This framework makes sure that cosmetics in the EU are not unique and attractive but also safe, open, and responsible.
CPSR Requirements for Fragrance Products
Part A: Safety information you must gather
Part A of the CPSR has all the information about the product’s formulation, including the raw materials used, any impurities, how it is packaged, how it is used, and the toxicological profiles of each ingredient. The IFRA Certificate and allergen calculations for the finished product must also be included.
Part B: Safety assessment process
In Part B, a qualified safety assessor reviews the data from Part A to determine if the product is safe for its intended use. This involves considering the dose, frequency of use, and groups of people who are more likely to be harmed.
Linking IFRA Compliance to CPSR Conclusions
The CPSR looks at the whole cosmetic product, while IFRA compliance only checks that the fragrance compound is safe to use in its category. The CPSR is still valid, but IFRA data backs it up.
Label & Claims Compliance Checklist
INCI, Allergens, Batch Codes, and PAO
A compliant label is more than just a list of ingredients; it’s an important part of keeping products safe and clear. The full INCI list must be on the label for perfumes, body mists, and hair perfumes. Each ingredient must be listed using the correct, standardized name. If a leave-on product has allergens above 0.001%, they must be listed one by one, along with “Parfum” or “Aroma” to show the scent mixture.
The label must also have the batch or lot number on it so that it can be traced back to its source. This makes it easy to do quick recalls or quality checks if needed. There should also be a PAO (Period After Opening) symbol, which tells you how long the product is safe to use after opening.
Avoiding Misleading “Allergen-Free” or “Hypoallergenic” Claims
Under EU law, you need to think carefully about marketing claims. If your product has any of the allergens listed in Annex III above the legal limit, even in small amounts, claims like “hypoallergenic” or “allergen-free” can be misleading. The EU’s cosmetics claims regulation says that all claims must be true, backed up, and not likely to trick people. This means that claims about allergens must be based on the actual ingredients of the product and be backed up by proof.
Matching Packaging and E-commerce Listings
It’s not enough to just make sure the physical packaging is compliant; the digital channels have to be compliant as well. The list of ingredients on the packaging must match the list of ingredients on websites, online stores, and marketplaces exactly. Using old INCI names online, for example, can put you at risk of not following the rules.
To avoid problems, many brands change their packaging and online listings at the same time. This makes sure that all channels show changes, like the new allergen labeling required by Regulation (EU) 2023/1545. This consistency not only makes sure that the rules are followed, but it also builds trust with customers by making sure the information they see is correct and up to date.
Common Pitfalls for Each Product Type
Perfumes: High Load and Small-Pack Dose Control
Perfumes are often the most fragrant cosmetics, even though they come in small bottles. Reapplying often during the day can greatly increase exposure. The safety assessment may have thought that the daily exposure would be lower than it is if the actuator delivers a large spray dose. This means that it is very important to accurately measure the dose per spray and model how the product will be used in real life.
Body Mists: Large Surface Area & Frequent Application
People usually use body mists over large areas of skin and several times a day. This makes it more likely that allergens and solvents will come into contact with each other. To make sure that both IFRA limits and allergen labeling requirements are met, safety assessors need exact information about how often and how much the product is used.
Hair Perfumes: Transfer, Build-Up, and Dual-Use Issues
Hair perfumes stay on the hair for hours, can build up with repeated use, and can also get on skin, clothes, or bedding. Use the more strict IFRA category if a product can be used on both hair and skin. When modeling exposure, you need to think about both direct application and secondary exposure from transfer.
Step-by-Step Compliance Workflow
Define Intended Use & IFRA Category
First, figure out how the product will be used: on skin, hair, or both. Then, choose the right IFRA category. If the product can be used in more than one way, use the more limited category from the start to avoid having to change it later.
Collect Supplier Documents & Allergen Data
Get IFRA Certificates of Conformity from the suppliers of the fragrances you want in the right amount and category. Get full ingredient lists, purity standards, and allergen compositions so that you can figure out how many allergens are in the finished product.
Complete CPSR, Finalize Labels, and Notify via CPNP
Get help from a qualified safety assessor to fill out the Cosmetic Product Safety Report (CPSR) and make sure that both Part A and Part B are complete. Make sure your labels are in line with Annex III allergen thresholds and that your packaging matches your e-commerce listings. Before the product can be sold in the EU, the Responsible Person must send the product notification through the Cosmetic Products Notification Portal (CPNP).
Frequently Asked Questions
Q1. Is it required in the EU to follow IFRA?
No, but many safety assessors think it’s best practice and expect it.
Q2. What are the limits for allergens in perfumes?
For leave-on products, it’s 0.001%, and for rinse-off products, it’s 0.01%.
Q3. If I have an IFRA certificate, do I still need a CPSR?
Yes. The fragrance compound is covered by IFRA, and the whole cosmetic product is covered by the CPSR.
Q4. What IFRA categories do these products fall under?
Most perfumes are in Category 4, most hair perfumes are in Category 7B, and most body mists are in Category 4 unless they are meant to be something else.
Conclusion
Perfumes, body mists, and hair perfumes are beautiful and smell great, but they also have a lot of rules that must be followed. Brands can make sure their products are both interesting and fully compliant in the EU market by making sure that their IFRA category limits match a full CPSR, following the 2023 allergen labeling rules, and keeping their labels correct across all sales channels.
Learn more about our Cosmetic Product Safety Report (CPSR) service or explore more insights on compliance in our blogs.
