Fragrance Regulatory: 50 Shades of Grey

Fragrance safety regulations can be confusing, even for us.  While many folks think of IFRA limits as clearly black and white, they are really a constantly changing world of grey. 

We use IFRA standards for all our formulations.  IFRA is the global governing body for fragrance safety and regulatory.  Compliance to their recommendations is voluntary but they are generally the most widely used standards in the professional industry.  IFRA sets maximum recommended dosage levels by product category based on the ingredients (and allergens) in the formula and the intended use of final product.  These recommendations are constantly changing as new research and information is available, and every so often they go through a major update called an Amendment (we are currently at Amendment 51).  

Most simply, IFRA limits are all about fragrance exposure, primarily through our skin.  The skin is the largest organ in our body and whatever we put on our skin goes in our body.  For this reason, IFRA tries to approximate the level of contact with actual fragrance in given product forms based on how they are used.  But this is not an exact science and the results are often changing.  For example, after years of being considered a 'no contact' product like candles, reed diffusers are now more heavily regulated because they now take into consideration that reeds are often 'flipped' by hand and thus there is skin contact.  In addition, there is constantly new data around ingredients and chemical components than can further restrict usage.  The result is that IFRA restrictions are constantly changing and don't always make sense (to us).  

A note about phototoxicity: some of our IFRA docs have statements referring to risk of phototoxicity.  These come from naturally occurring chemical components of raw materials (like citrus) and the warning applies only to products that combine skin contact AND exposure to sun, like sunscreen products.