Disclaimer: The information in this article presents our understanding and views and is not legal advice. If you need more details on any legislation or legal advice about what action to take when labelling your products, please contact an adviser or solicitor.
What is IFRA?
The International Fragrance Association (IFRA) is the global representative body of the fragrance industry. It seeks to represent the collective interests of the industry and promote the safe use of fragrances. The Association was founded in 1973. IFRA has its head office in Geneva, Switzerland and its operations centre in Brussels, Belgium. Its members are 8 multinational companies (known as 'Regular Members') and 21 national associations, covering 23 countries. There are 8 'Supporting Members' from countries where IFRA does not have a national association.
What are the IFRA standards?
To ensure that you and your family can have trust in fragranced products, and to respect our shared environment, the fragrance industry has developed a system to manage the safe use of fragrance: the IFRA Standards. The rules are developed in partnership with members and other stakeholders in a transparent process overseen by independent experts.
Is IFRA different to CLP?
IFRA Standards and the CLP Regulation are separate. IFRA produce IFRA Standards which ban, restrict, or set criteria for the use of certain fragrance ingredients, with the aim of ensuring the safe use of fragrance for consumers. Adhering to IFRA standards is mandatory for IFRA members only. The CLP Regulation ensures that fragranced products (excluding cosmetics) are classified, labelled, and packaged in a consistent way so that the hazards of the products are clearly conveyed to consumers. If your product is hazardous according to CLP, it is your legal responsibility to classify, label and package it appropriately.
What are the IFRA amendments?
IFRA periodically issues 'Amendments' to the IFRA Standards. Taking the latest scientific evidence to assess the wide range of fragrance ingredients – sometimes called the ‘perfumer’s palette’ – IFRA sets the maximum dose of all natural and synthetic fragrance ingredients in finished consumer goods. These amendments can result in the removal or restrictions in the use of commonly used fragrance ingredients. Updates have historically been anything from 12 months to almost 5 years apart. Three recent Amendments are:
• IFRA 48th Amendment - June 2015
• IFRA 49th Amendment - Jan 2020
• IFRA 50th Amendment - Jun 2021 (Single Material Update*)
Amendments to IFRA standards are designed to be used by the professional perfumers and chemists who make fragrances. The changes notified in these standards typically become legally binding.
Candle Shack and other fragrance suppliers use specialist software to generate CLP SDS and other documents (i.e. label templates, IFRA Allergen Declarations, IFRA Certificates). These software applications basically apply the IFRA standards to the materials that make up the mixtures and generate the necessary documentation, taking into account the limits specified in the IFRA Amendment in use. For example, the 49th Amendment is effective from the 10th May 2022.
IFRA 50TH amendment
The IFRA 50th Amendment was a minor update, dealing with the prohibition of a single fragrance ingredient (Mintlactone). The last major update remains the 49th Amendment.
IFRA 49TH amendment
The 49th Amendment was the first major amendment since June 2015. The below are highlighted changes, impacting the home fragrance market.
Diffusers
Under IFRA 49, the big news for home fragrance brands was that reed diffusers moved from Category 11 to Category 10A and come with much stricter usage guidelines than they previously did. Unfortunately, this change means that many fragrances we had previously approved for diffuser use at 15% or even 20%, can no longer be used at that level from 10 May 2022.
Candles, wax melts and room mists
Whilst diffusers have seen the biggest impact, the change from 11 to 12 categories also saw room mists move from Category 9C to Category 10B and Candles/Melts move from Category 11 to Category 12.
How will these changes affect me and my business?
The main impact on Candle Shack customers is that following the category change, some diffuser recipes will no longer be suitable for sale, requiring makers to significantly reduce the amount of fragrance oil used to make a product, potentially to unworkable levels.
Some fragrance oils cannot be used at any level- this means that the fragrance cannot be used for reed diffusers at all under IFRA 49.
How will I know if a particular fragrance oil has been affected?
The fragrance oil pages now state maximum usage under IFRA 49, but as always, we recommend you view the IFRA certificates and decide if the allowable amount is right for your product.
Affected Fragrances
The fragrances in the table below are affected by IFRA 49 and may not be suitable for reed diffusers, as the maximum allowable usage is under 14%.
For example, you might find that a fragrance previously used at 15% will have a maximum allowable usage of 10% from 10 May 2022. However, we recommend testing the new allowable fragrance oil % to see if it will work for your product, rather than assuming it will not.
How will Candle Shack respond to IFRA 49?
We are working with our perfumers to determine which of the affected fragrances can be modified. This is not straightforward, as we do not want to change the olfactory character of the oils or affect the usage in candles and melts. This means we will do one of three things:
1. Create a Diffuser Mod. For bestselling fragrance oils we may develop a diffuser only oil, which is optimised for use in reed diffusers. This would be separate from the candle oil and may be slightly different in character.
2. Create a Universal Mod. If we can modify the fragrance and make it usable in diffusers at 14%+, without impacting the character or candle compatibility, then we will do so.
3. Do Nothing. Where it is not possible to create a universal mod, and there is insufficient demand to justify a diffuser only mod, sadly we will need to advise against the use of some oils in diffusers.
We have updated the fragrance pages for all affected oils and will outline any plans to intorduce modifications on these pages to keep information in one place.
Why have some SDS' not been updated to IFRA 49 yet?
IFRA 49 comes into force on the 10th May 2022. Until then, you can still sell reed diffusers according to IFRA 48 limits. We have been updating unaffected fragrances to IFRA 49, as this means we can continue to supply the relevant paperwork without removing your diffuser SDS.
As the deadline is 10th May 2022, we have added a line to the product pages of affected fragrances, so that you are aware of the IFRA limits after this date, so please ensure you have sold all diffuser stock that is affected prior to 10th May 2022.
We will update the CLP documentation for IFRA 49 affected oils in the coming weeks. When we do so, we will put a note on product pages showing the IFRA 48 diffuser limit, as we know many of you have a very short sales cycle via B2C channels and may be able to make and sell diffusers within a short period of time (days). We will leave the IFRA 48 documentation in the regulatory folder until the deadline, clearly marked as IFRA48.
Lilial / BMHCW Reclassification
Please be advised that some of our oils still contain Lilial and that you may need to limit the amount of fragrance in your diffuser to comply with IFRA, even if the CLP SDS is available. There is another blog post that goes into this in detail.
TO SUMMARISE
The fragrance oil pages now state maximum usage under IFRA 49, but as always, we recommend you view the IFRA certificates and decide if the allowable amount is right for your product.
Candle Shack will update the status of the affected fragrance list in this article as soon as the information becomes available.
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