For manufacturers, formulators, and brand owners, these developments are important to monitor closely. While the regulatory process is still ongoing for most of the substances involved, the potential consequences could be substantial, affecting product formulation, compliance requirements, and long-term product portfolios.
What Is the Chemicals Strategy for Sustainability?
The Chemicals Strategy for Sustainability (CSS) is part of the EU Green Deal and aims to improve the safety of chemicals used throughout Europe. One of its objectives is to identify substances that may present risks to human health or the environment and to ensure that these risks are appropriately managed.
Within this framework, certain fragrance ingredients are being reviewed for possible classification as CMR substances (Carcinogenic, Mutagenic, or Reprotoxic). If an ingredient receives a CMR Category 1B classification, the consequences for the cosmetics sector are significant.
Under EU cosmetic legislation, ingredients classified as CMR 1B are generally prohibited in cosmetic products unless a specific exemption is granted. In addition, their use in products such as candles, reed diffusers, room sprays, and other fragranced consumer goods may become restricted.
This is the same regulatory mechanism that led to the phase-out of Lilial, a widely used floral fragrance ingredient that disappeared from the European market after being classified as reprotoxic.
Why Are These Reviews Important?
At this stage, most of the substances discussed below have not yet completed the regulatory process. However, the fragrance industry is already preparing for possible outcomes because reformulation projects, stability testing, regulatory assessments, and supply chain adjustments require considerable time.
The current reviews affect ingredients that contribute floral, powdery, woody, herbal, spicy, and fresh aromatic notes found across a wide range of cosmetic and home fragrance products.
For manufacturers, the key challenge is not only regulatory compliance but also maintaining fragrance performance and olfactory character if reformulation becomes necessary.
The Ingredients Currently Under Review
Acetophenone
Acetophenone is a fragrance ingredient with sweet, floral, and slightly almond-like characteristics. It is also used as an intermediate in the manufacture of other fragrance materials.
Earlier this year, the Scientific Committee on Consumer Safety (SCCS) published a preliminary opinion assessing the substance and its potential implications for cosmetic use.
Bourgeonal
Bourgeonal is highly valued for its fresh floral character, often associated with lily-of-the-valley accords. It has long been an important building block in perfumery because it provides brightness and natural floral lift to fragrance compositions.
As one of the more recognizable fragrance ingredients on the review list, Bourgeonal has attracted considerable attention from fragrance houses and formulators.
p-tert-Butyltoluene
This aromatic hydrocarbon is used primarily as a fragrance raw material and intermediate. While it is less familiar to consumers than some other ingredients on the list, it remains relevant within certain fragrance manufacturing processes.
Cuminaldehyde
Naturally associated with the characteristic scent of cumin, Cuminaldehyde delivers warm, spicy, aromatic notes. It is used in fragrance compositions requiring herbal, oriental, or spicy dimensions.
Its presence on the review list highlights that both naturally occurring and synthetic fragrance materials can be subject to regulatory reassessment.
Cyclamen Aldehyde
Cyclamen Aldehyde is one of the industry’s classic floral materials. Despite its name, it is not derived from cyclamen flowers but is a synthetic ingredient known for its fresh, watery, floral profile.
It is commonly used in personal care products, fine fragrances, and household fragrances to create clean and airy floral accords.
Cyclemax
Cyclemax, also known as p-cumenyl propionaldehyde, provides floral and green fragrance notes and is often used to support complex fragrance structures.
Although less well known outside professional perfumery circles, it contributes to the character and performance of many fragrance formulations.
Heliotropine
Heliotropine, sometimes known as piperonal, is a classic perfumery ingredient valued for its sweet, powdery, almond-like scent profile. It is widely used in floral, gourmand, and oriental fragrances.
Among the substances currently under review, Heliotropine is considered one of the closest to potential regulatory publication, meaning the industry is monitoring developments particularly closely.
Para-Cymene
Para-Cymene is an aromatic compound found naturally in several essential oils and plant-derived materials. It contributes fresh, aromatic, and slightly citrus-like characteristics and also serves as a building block in fragrance chemistry.
Tea Tree Oil
Tea Tree Oil is perhaps the most recognizable ingredient on the list from a consumer perspective. Derived from the leaves of Melaleuca alternifolia, it is widely used in cosmetic and personal care products due to its characteristic fresh, medicinal aroma and its popularity in products marketed for skin and scalp care.
The ingredient has recently attracted increased regulatory attention following the publication of an SCCS opinion assessing its safety in cosmetic products.
A Special Case: Diphenyl Oxide
Diphenyl Oxide is often discussed alongside the nine ingredients under review, but its situation differs from the others.
Unlike the substances currently undergoing harmonized classification procedures through European regulatory authorities, Diphenyl Oxide has become the subject of a supplier self-classification. This means its regulatory pathway is different and should not be directly compared with the harmonized classification process affecting the other ingredients.
For this reason, many industry stakeholders are treating Diphenyl Oxide as a separate regulatory topic. However, the industry is monitoring developments closely, as future regulatory actions or broader adoption of the self-classification could influence its long-term availability and use in cosmetic and fragranced products.
What Happens Next?
For most of the ingredients currently under review, industry guidance suggests that regulatory notifications may occur during late 2026, followed by publication in the Official Journal of the European Union around 2027 if the proposals proceed as expected.
Should classifications be formally adopted, transition periods of approximately 18 months are anticipated before restrictions fully take effect. While these timelines remain estimates and may change during the legislative process, they provide manufacturers with an indication of the planning horizon involved.
What Manufacturers Should Be Doing Now
Although no immediate action may be required for every affected product, now is the time for manufacturers to review fragrance portfolios, identify products containing any of the ingredients under scrutiny, and begin discussions with fragrance suppliers.
Early preparation can help businesses avoid last-minute reformulation projects and ensure a smoother transition if regulatory changes are ultimately confirmed.
As with many developments emerging from the Chemicals Strategy for Sustainability, the direction of travel is clear: greater scrutiny of chemical substances, stronger safety requirements, and increasing pressure on the industry to anticipate regulatory change before it becomes mandatory.
For companies operating in cosmetics, personal care, and home fragrance markets, staying informed will be essential over the coming years.
