Regulatory notes: Communicating With Customers About Fragrance Regulatory Changes

Contact Author John Cox, Law offices of John H. Cox, PPLC
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Regulations that require registration or record keeping are usually straightforward. The obstacles occur when regulations require labeling or disclosure to authorities of certain ingredients.

Two recent changes in the law have made this a challenge for the cosmetic industry. Neither the Seventh Amendment to the European Cosmetic Directive nor the California Safe Cosmetics Act requires reformulations of fragrances, but some customers have responded as though they do.

Seventh Amendment to the European Cosmetic Directive

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The Seventh Amendment to the European Cosmetic Directive, published in March 2003, requires manufacturers of cosmetics to indicate the presence of certain allergenic substances in the list of ingredients if the substances are present above certain levels.

This regulatory change has created many challenges. Primarily focused on banning animal testing, the amendment led to the necessity of identifying certain ingredients on the label. Does this apply to any ingredient from any source? The answer is yes, to the consternation of essential oil suppliers.