The EU Chemical Strategy for Sustainability: Straight Answers on What's Changing, and What We're Doing About It
You may have heard about something called the Chemical Strategy for Sustainability (CSS) and wondered what it means for you. This article explains what is changing, which of our fragrances are affected, and exactly what we are doing about it.
What Is CSS?
CSS is part of the EU Green Deal, a broad push to make chemicals safer for people and the planet. As part of this, certain fragrance ingredients are being reviewed and, in some cases, reclassified as hazardous substances under EU chemical law.
When an ingredient receives a CMR 1B classification, it is automatically banned from cosmetic products and limited in non-cosmetic products such as candles, diffusers, and room sprays. This affects everyone in the supply chain, whether you are making, importing, or selling products in Europe or in countries that follow EU regulations. If you remember Lilial being removed from fragrances a couple of years ago, that is exactly what happened. The same process is now underway for nine more ingredients.
These changes affect the whole fragrance industry, and we want to be open with you about where things stand.
The Nine Affected Ingredients
The nine ingredients below are currently going through the EU review process. All dates are estimated only and are not confirmed. Once any official publication takes place, we will email again with a confirmed update. Diphenyl Oxide is a self-classification and a separate email will be going out with further information on this.
Group 1 — Official publication imminent (estimated in-force date: approx. Sept 2027, may move to late 2027–early 2028):
Heliotropine and Tea Tree Oil.
Group 2 — WHO notification anticipated Dec 2026, official publication anticipated March 2027 (estimated in-force date: approx. Sept 2028):
Acetophenone, Bourgeonal, P-tert-Butyltoluene, Cuminaldehyde, Cyclamen Aldehyde, Cyclemax, and Para-Cymene.
Self-classification (not a harmonised ECHA/European Commission classification):
Diphenyl Oxide. Further information is coming separately.
None of our fragrances contain Tea Tree or Acetophenone.
Affected Fragrances
Where these ingredients appear in our fragrances, we have been working to reformulate them.
Earlier estimated timeline — Heliotropine (approx. Sept 2027)
Official publication is imminent. An 18-month transition period applies. The in-force date may move to late 2027 or early 2028. All dates are estimated only and not confirmed.
Black Raspberry & Peppercorn, Buttery Croissant, Effete, Himalayan Cedar & Jasmine, Luscious Vanilla, Paradise Beach, Parisienne Spring, Rising Sun, Solaris Blanc, Sweet Pea, Vanilla Embers, Verdant Blossom.
Later estimated timeline — Bourgeonal, P-tert-Butyltoluene, Cuminaldehyde, Cyclamen Aldehyde, Cyclemax, Para-Cymene (approx. Sept 2028)
WHO notification is estimated for December 2026. Official publication is estimated for March 2027. An 18-month transition period applies. All dates are estimated only and not confirmed.
Amber Noir, Aphrodite, AquaLume, Black Fig & Vetiver Candle Oil, Black Orchid, Black Pomegranate, Blackcurrant & Tuberose, Cinnamon Frankincense & Cedarwood, Clean Cotton, Cranberry & Spiced Ginger, Creamy Musk & Sandalwood, Damson Plum Rose & Patchouli, Eau Verbena, English Rose, Enliven, Fairy Dust, Frankincense & Myrrh, Jasmine & Patchouli, Marine, Meadow Lily & Cotton Musk, Pain Au Chocolat, Passionfruit & Mango, Pear & Freesia, Peony & Blush Suede, Peppermint & Eucalyptus, Pink Champagne & Pomelo, Pink Pepper & Rose, Solaris Noir, Tuscan Herbs.
What Candle Shack Is Doing About It
We have been working on this since last year, and by the time you read this, a significant amount of work has already been completed behind the scenes. Some fragrances have been straightforward to update, some have only needed slight tweaks, and others have had to be completely reformulated.
Unfortunately, we will have a couple of casualties. Lavender & Dead Sea Minerals will be discontinued. Enliven may also need to go, as it is proving difficult to replicate. We will keep you updated on this.
There is a silver lining. We have taken advantage of the reformulations to broaden compatibility. Some much-loved fragrances that could not previously be used in reed diffusers will now be suitable, notably Himalayan Cedar & Jasmine and Meadow Lily & Cotton Musk.
UFI Numbers
All new reformulations will have new UFI Numbers. These will appear in Section 1.1 of the 100% SDS and on your CLP Labels on your fragrance bottles. You will need to notify your products when using the new Mods.
Rollout From June
We will begin transferring over to the new formulations from June. You will be kept updated as each fragrance becomes available. Current versions will remain on sale until stock is sold out, and new Mods will sell alongside them to help with the transition and testing period.
All reformulated fragrances will be given new product codes, so there will be no confusion between old and new. When you see a new product code, you will know it is the updated, fully compliant version.
Once new formulations are launched, candle recipes will be available for each one so you can get straight to testing with confidence. Many use the same wick as the current version. Testing has been carried out in RCX, EU464, and Apricot & Coconut waxes.
If You Make Cosmetics
If you use our fragrances in cosmetic products, please check your formulations against the affected ingredient list. If you need anything from us, please do not hesitate to get in touch.
Our Own Soaps & Lotions Range
Some of our own-brand soaps and lotions will also be affected. A separate email will be going out to all customers who buy Soaps & Lotions with full details, including dates when products will need to cease being sold. The above ingredients are a complete ban in cosmetics, and the compliance bar for leave-on and rinse-off products is higher.
The new fragrance modifications for our soaps and lotions range are currently with our manufacturer for stability testing and cosmetic assessment. This will take a few weeks and we will update you as soon as products are cleared for production.
Affected Soaps & Lotions:
Black Pomegranate, Black Orchid, Blackcurrant & Tuberose, Black Fig & Vetiver, Black Raspberry & Peppercorn, Damson Plum Rose & Patchouli, Effete, Himalayan Cedar & Jasmine, Frankincense & Myrrh, Paradise Beach, Pink Pepper & Rose, Lemongrass & Ginger, Lime Basil Mandarin.
Stay in the Loop
Please make sure you are signed up for our newsletters. That is how we will keep you informed on all regulatory matters and let you know as soon as updated fragrance versions are released. Under GDPR rules we can only email you if you have opted in, so if you have not already, please sign up.
This document is intended as a general guide and is accurate to the best of our knowledge at the time of publication.
Candle Shack Product & Regulatory Team
