Today’s consumers are more discerning than ever when it comes to the ingredients in the products they buy and how these products are manufactured. Meeting specific standards demonstrates a brand’s commitment to safety and sustainable practices.

In the fragrance industry, regulatory compliance works a little differently than in other industries. This is because fragrances aren’t regulated by the Food and Drug Administration (FDA) or any other governmental agency in the United States. That doesn’t mean there are no standards, though—quite the opposite. Fragrance manufacturers must meet the standards set by groups like the International Fragrance Association (IFRA). Further, clients may need manufacturers to adhere to certain chemical, safety, environmental, and manufacturing standards, many of which are published by governmental and private regulatory agencies. As regulatory partners, we’re committed to staying abreast of all new regulatory developments as they’re published and to ensure we comply with any specific requirements related to fragrances 

Regulatory compliance support made simple

We develop fragrances with regulations from multiple agencies in mind because these regulations support consumer, worker, and environmental health and safety. Navigating the regulatory landscape can be overwhelming, so our team offers customized support to meet every client’s needs. We provide regulatory support in the following areas:

  • Safety Standards. This includes limiting the use of certain ingredients.
  • Labeling. This includes supporting requirements for the labeling of specific ingredients.
  • Good manufacturing practices. These involve ensuring that products are manufactured with the correct ingredients with processes that follow environmental standards
  • Chemical regulations. These standards regulate the use of certain chemicals and their impact on the environment.
  • Product Registration. We support clients through the process of registering their finished product.

We also liaise with various regulatory bodies such as the Consumer Product Safety Commission (CPSC), Environmental Protection Agency (EPA), and the Food and Drug Administration (FDA).

Our approach to compliance

Because your products may be available in markets outside the U.S., we ensure compliance with applicable international regulations. For instance, we can ensure that the fragrance for your product adheres to EU cosmetic regulations. For products that don’t need to adhere to EU regulations, simply understanding these regulations gives us insight into potential future requirements. 

We also assess all fragrances we create according to International Fragrance Association (IFRA) standards. These standards are based on scientific evidence reviewed by the Expert Panel for Fragrance Safety of the Research Institute for Fragrance Materials (RIFM), and they ensure the safe use of a fragrance in a consumer product. 

What’s happening in fragrance regulation right now?

The Modernization Of Cosmetics Regulation Act of 2022 (MoCRA) is currently being implemented in the US. This is one of the most significant pieces of legislation to affect the U.S. cosmetics industry since the Federal Food, Drug and Cosmetic Act was passed in 1938.

Under MoCRA, the FDA is now authorized to establish regulations for facilities that manufacture cosmetic products. This includes Good Manufacturing Practice (GMP) requirements, fragrance allergen labeling requirements, and standardized testing methods for detecting and identifying asbestos in talc-containing cosmetic products. It also requires the FDA to publish a report on the use of per- and polyfluoroalkyl substances (“PFAS”) in cosmetic products and the scientific evidence regarding the safety of such use in cosmetic products, including any risks associated with such use.

Cosmetic manufacturers and processors are also required to register their facilities with the FDA every two years. 

You can read more about MoCRA here.

Understanding new legislation can be a challenge but as your partner, we can support your brand all the way through their implementation so you don’t lose any time or productivity.

Regulatory compliance doesn’t have to be difficult

Here’s our take on regulatory compliance: it’s complicated and ever-changing. Fragrances may be unregulated in the U.S., but American consumers—like consumers all over the world—have expectations for the products they use. They expect their products to be effective, great-smelling, and above all, safe. At Custom Essence, we don’t simply view regulatory as a department, but as a core competency and unique difference-maker. All of our regulatory information is housed in a proprietary system that feeds into our development team’s creative platform, ensuring that fragrances we develop or select from our vast library are compliant to each specific project. Our external portal also provides our clients with 24/7 access to over 35 unique regulatory documents. 

The Custom Essence team is also available to answer questions and discuss regulatory issues when you need us. Whether that’s decoding natural ISO standards (9235 vs. 16128) or talking through a retailer’s Clean Standards, such as Target or Sephora, we’re here to guide and advise you toward the best decisions for your brand and products. 

Ready to learn more? Contact Custom Essence today to set up your initial consultation with our team.