‘Insights’ Series
Welcome to Our New ‘Insights’ Series! Our deeper dives into current hot topics
We are pleased to introduce a new addition to our regular industry updates: the ‘Insights’ series. These articles will be published throughout the year, interspersed with our standard news and interest pieces.
Our goal with this series is to go beyond the "what and why" of regulatory compliance. By drawing on our recent project work, we will explore the practical challenges and the potential solutions we encounter when navigating complex industry topics.
To kick things off, we’re diving straight into a topic that’s currently keeping many of us busy: Fragrance Allergens.
Fragrance Allergens: Observations from the Field
You probably know the basics: the EU list of declarable allergens has expanded significantly. But in practice, we’ve noticed a few recurring "obstacles" that brands are tripping over. Here’s what’s been on our radar:
1. Out-of-date IFRA Declarations
The International Fragrance Association (IFRA) maintains Standards that set limits, restrictions, or bans on specific ingredients and issues declarations of allergens present in the material.
The Observation: While suppliers usually issue allergen statements to assist brands with labelling, we frequently find that some manufacturers are holding outdated IFRA certificates and declarations. If a document does not comply with the latest version of the IFRA Code, it may not reflect recent safety reviews. This is not merely a paperwork issue; if restrictions on a substance have changed and your documentation is old, it could become a matter of product safety. In respect of our topic today, frequently, what we’re seeing are allergen declarations that only contain the original 26 (non-extended) list with no mention of the extended list.
The Solution: We recommend a robust process for ensuring all fragrance documentation is regularly updated and confirmed as valid against the current versions of the IFRA Code and Cosmetics Regulation requirements.
2. The "Botanical Blind Spot"
A common misconception is that allergen labelling requirements only apply to the "fragrance" component of a formulation. In reality, the requirement applies regardless of the source.
The Observation: We have seen instances where manufacturers prepare ingredient lists based only on the fragrance oil, overlooking the fact that botanical extracts and essential oils are often rich in allergens, too.
The Solution: If your product contains natural extracts, ensure your manufacturer has factored the constituents of these botanicals into their final allergen calculations.
3. Inconsistent Supplier Declarations
For many brand owners who outsource their manufacturing, a great deal of emphasis is placed on the contractors with whom they are working and the suppliers that they choose.
The Observation: We have encountered situations where raw material suppliers claim an IFRA declaration is unnecessary, perhaps because the material is not classified as a "fragrance." However, we have noted that the exact same botanical from a different supplier often comes with a full declaration showing significant allergen levels.
The Solution: Discrepancies between suppliers can lead to accidental non-compliance. It is vital to scrutinise "no declaration needed" claims, especially for complex plant-derived ingredients.
4. The "No Intentional Addition" Trap
In almost all of the projects we have worked on, we have not received a full set of documentation without some digging with the manufacturer and suppliers.
The Observation: This is an issue we see frequently. When questioned about allergens in botanical-heavy products, some manufacturers respond that there is "no intentional addition".
"Not intentionally added" is not the same as "not present." If an allergen is naturally occurring within a botanical, it must be accounted for. Relying on "intentional addition" statements may mean a brand is inadvertently non-compliant with the law.
The Solution: Be prepared to ask your partners: "Have the constituents of the botanicals been checked for allergens?"
Understanding the 2026 Deadline
There is some confusion regarding the 31 July 2026 deadline for the expanded allergen list. Specifically, the definition of "placing on the market" is often misunderstood.
It is important to clarify that this deadline does not only apply to brand-new product launches. It applies to NEW STOCK. Any product released into the supply chain by the EU Responsible Person after 31 July 2026 must be compliant with the new labelling requirements. If you are preparing stock now that will be released after that date, it is time to ensure your labels are ready.
Consequences for Brands
The cumulative effect of these oversights is often an incomplete ingredient list. This not only risks enforcement action from authorities but also undermines the core purpose of the regulation: ensuring consumers have the information they need to avoid specific allergens.
How We Can Help ?
Navigating the transition to the new allergen requirements is a significant undertaking, particularly when managing existing inventory alongside new production. At Bloom, we specialise in helping brands bridge the gap between complex raw material data and compliant finished products.
Whether you are struggling to extract accurate constituent data from your supply chain or need a strategic plan to ensure your stock rotation aligns with the 31 July 2026 deadline, our team is here to support you. We offer:
Supply Chain Audits: Verifying that your IFRA certificates and allergen declarations are current and technically sound.
Formula Reviews: Working with your suppliers to identify "hidden" allergens in botanicals to ensure your INCI lists are robust and accurate.
Transition Strategy: Helping you manage the release of new and old stock to maintain compliance without disrupting your supply chain.
Amanda Isom