IFRA vs EU 1223/2009: What a Fragrance Buyer Must Hold
Short answer
IFRA is a private industry body whose Standards set maximum use levels and restrictions for fragrance materials by product category, while Regulation (EC) No 1223/2009 is the binding EU law that governs how cosmetic products are placed on the market and sold in the EU and EEA. The two are not rivals: 1223/2009 is legally mandatory, IFRA compliance is not a legal requirement but is what buyers, retailers and cosmetic safety assessors will ask you to demonstrate. A fragrance buyer working in the EU should hold both, plus the supplier's certificate of analysis and safety data sheet for every batch.
What is IFRA, and what do the Standards do?
The International Fragrance Association publishes a set of Standards in parts. Together they define how fragrance materials are used: the Code of Practice for members, safety data requirements, and the restrictions themselves, with maximum levels set per product category and, in some cases, outright prohibitions in particular categories. Categories run from leave-on lip products through fine fragrance (Category 4), soap (Category 6), rinse-off products such as shampoos and body wash (Category 9), to products used on the skin other than face and hands, which includes baby products (Category 12).
The Standards are amended periodically. The most recent major amendment was published in 2023, and amendments can add restrictions or lower maximum levels for a material. This is why an IFRA certificate that references an old amendment is not automatically current, and why buyers ask for the certificate that matches the amendment in force when the compound is sold.
The practical effect is simple: a material can be entirely legal to buy and still be unusable at your intended concentration. Oakmoss absolute, for instance, carries well-known IFRA restrictions that limit its use in fine fragrance. The catalogue flags materials where these limits bite, and the compliance summary explains how to check a material before it goes into a brief.
What does Regulation (EC) No 1223/2009 require?
The Cosmetic Products Regulation applies to products intended to be placed on the market as cosmetics in the EU. Its core obligations are:
- ✓A Responsible Person established in the EU, who is the legal point of contact for the authorities and for consumers.
- ✓A Cosmetic Product Safety Report (CPSR), prepared by a safety assessor holding a recognised qualification, covering the safety of the formula, the manufacturing method, the purity and the substantiation of the claims.
- ✓A Product Information File (PIF) containing the CPSR, the product description, the manufacturing method, proof of claimed effects, and the animal testing data, retained for ten years after the last batch was placed on the market.
- ✓Notification in the EU cosmetic product notification portal before the product is placed on the market.
- ✓Labelling under Article 19, including nominal content, batch number, date of minimum durability or period-after-opening, precautions, function and the INCI ingredient list, plus declaration of fragrance allergens above set thresholds.
- ✓Good manufacturing practice and a documented procedure for serious undesirable effects, which the Responsible Person reports to the competent authority.
Note the scope. Soap is within the scope of the regulation. Candles, reed diffusers, room sprays and general cleaning products are not cosmetics and sit under chemical classification and labelling rules instead, principally Regulation (EC) No 1272/2008, with detergents additionally covered by Regulation (EU) No 648/2004. If you are launching a home line rather than a cosmetic line, that distinction changes the whole compliance path.
How do the two relate in practice?
They sit at different levels. IFRA is self-regulation agreed by the fragrance industry, with no legal force of its own, but it is the reference most cosmetic safety assessors work from when evaluating a fragrance compound inside a CPSR. Regulation 1223/2009 is law, and it does not set maximum levels for individual fragrance materials; the levels in a product come from the safety assessment, which in practice starts from IFRA conformity.
For a buyer this means a workable sequence: buy materials that are IFRA-conformant for your intended category, compound or purchase a fragrance that carries an IFRA certificate, and have the cosmetic product assessed by a qualified safety assessor who confirms the formula against both the IFRA position and the CPSR requirements. The quality and documentation approach we describe covers the supplier side of that chain, and the white label service is built around the same documentation chain for brands.
Which documents should a fragrance buyer hold?
| Document | Issued by | What it evidences | When you need it |
|---|---|---|---|
| Certificate of analysis (COA) | Supplier or laboratory | Identity, batch number and results for that batch | Every batch |
| Safety data sheet (SDS) | Supplier | Hazard, handling and transport information | Every material, every shipment |
| IFRA Certificate of Compliance | Fragrance house or compound supplier | Conformity of the compound with the current Standards | Any product that is scented, on request from buyers |
| Supplier letter of compliance | Raw material supplier | That an individual material is IFRA-conformant, with limits | When you compound your own fragrance |
| Allergen declaration | Supplier | Natural allergen content above thresholds | Cosmetic labelling and reformulation checks |
| CPSR and PIF | Safety assessor | Safety assessment and product information file | Every cosmetic placed on the EU market |
| CPNP notification confirmation | Responsible Person | That the product was notified before sale | Every cosmetic placed on the EU market |
| Certificate of origin | Supplier or chamber of commerce | Origin for customs and preferential tariffs | Import documentation |
Keep them per batch and link them to the drum or bottle. A certificate that cannot be tied to a batch number is a general statement about the supplier, not evidence about the goods in front of you. If you are scaling beyond the bench, the bulk wholesale and trade distributor terms are built around supplying exactly this paperwork with every delivery.
Key takeaways
- ✓IFRA is voluntary industry self-regulation; Regulation (EC) No 1223/2009 is EU law and is mandatory for cosmetics.
- ✓Check the IFRA category that matches your product, and check the amendment the certificate references.
- ✓Cosmetics sold in the EU need a Responsible Person, a CPSR, a PIF kept for ten years, CPNP notification and Article 19 labelling.
- ✓Candles, diffusers and cleaning products are not cosmetics; classification and labelling rules apply instead.
- ✓Hold documents per batch, with batch numbers that match the goods, and let a qualified safety assessor sign off the formula.
Is IFRA compliance legally required?
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No. IFRA is a private industry body and its Standards are voluntary, so an IFRA-restricted material is not illegal to buy or sell on its own. It becomes effectively mandatory in practice because retailers, contract manufacturers, insurers and cosmetic safety assessors routinely require an IFRA Certificate of Compliance, and because exceeding a recommended maximum level can invalidate the safety data you rely on. Treat it as a commercial condition of sale as much as a technical one.
What is an IFRA Certificate of Compliance?
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It is a document issued by a fragrance house or compound manufacturer confirming that a specific fragrance compound complies with the current IFRA Standards and amendment for the categories it is intended for. It names the compound and the materials used, the categories covered and the amendment it refers to. If you compound fragrance yourself from raw materials, you make the conformity assessment yourself using your suppliers' letters of compliance and the published Standards, and you hold those records, not a third-party certificate.
Do candles and reed diffusers need a cosmetic safety assessment?
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Usually not, because they are not cosmetic products under Regulation (EC) No 1223/2009. They fall under chemical classification and labelling rules, principally Regulation (EC) No 1272/2008, and detergents may also fall under Regulation (EU) No 648/2004. What you should still hold is the SDS for each material, the COA, allergen information where relevant, and the IFRA position for any material the supplier flags as restricted, since some customers apply fragrance standards to home products by contract.
What must appear on the label of a cosmetic sold in the EU?
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Article 19 of Regulation (EC) No 1223/2009 requires the nominal content, the date of minimum durability or a period-after-opening symbol, particular precautions for use, the batch number or identifier, the function unless the product is self-evident, and the ingredient list in INCI names. Fragrance allergens above 0.001% in leave-on products and 0.01% in rinse-off products must also be declared. Language requirements are set by each Member State.
Do I need FDA approval to sell cosmetics in the United States?
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No. The United States does not pre-approve cosmetic products before they go on the market, which is a legal fact often confused with the European position. EU law is the regime that requires notification, a product information file and a safety assessment before sale. If you sell in both markets, build to the European standard first, because it is the more demanding of the two, and confirm local US requirements with a regulatory adviser for the specific product.