Introduction: Navigating a complex global landscape for fragrance safety
Safeguarding the safe use of fragrance ingredients requires an understanding not only of their intrinsic properties but also of how and where consumers are exposed to them. As regulatory frameworks expand and authorities refine their approaches to chemical management, the fragrance sector operates in an environment characterized by heightened scientific scrutiny, diverging regional requirements, and increasing expectations for transparency especially in a world where information spreads rapidly but is often unverified. This evolving context reinforces the need for a coherent, globally applicable system that supports consistent safety practices across markets. The IFRA Standards fulfil this role by providing a risk-based product stewardship framework developed through transparent scientific assessment, independent expert review and structured stakeholder consultation. Regularly updated to reflect new data and advances in scientific understanding, the IFRA Standards remain a cornerstone of global fragrance safety. The forthcoming 52nd Amendment continues this iterative process, introducing new and revised measures, including a significant update to the IFRA Furocoumarin Policy.
How the IFRA Standards work: a living, science-based system
The IFRA Standards are developed through a structured, science-driven process designed to ensure the safe use of fragrance ingredients across product categories and regions. This process begins with the Research Institute for Fragrance Materials (RIFM), which conducts safety evaluations of individual fragrance ingredients using established methodologies (1), (2), (3). These assessments consider multiple toxicological endpoints and are informed by industry data, peer-reviewed literature, and data from relevant regulatory sources.
All RIFM safety assessments are reviewed and endorsed, following thorough scrutiny, by the Expert Panel for Fragrance Safety (https://fragrancesafetypanel.org), a group of independent international scientists with expertise in toxicology, dermatology, pathology and allied disciplines. The Panel evaluates the scientific robustness of each assessment and determines whether the available evidence supports conclusions on safe use.
Where assessments indicate that existing exposure conditions cannot be supported, IFRA develops appropriate risk management measures in the form of IFRA Standards. These measures may include prohibitions, restrictions, and/or specifications, depending on the safety profile of the ingredient. Importantly, each amendment to the Standards is subject to a public consultation, allowing all stakeholders, including manufacturers, downstream users, regulators, NGOs, or scientific experts from academia to review and comment on the proposed measures. This process promotes transparency and ensures that the Standards reflect both sound science and practical implementation considerations.
The 52nd Amendment: Scope, timing and priorities
The 52nd Amendment represents the next scheduled update to the IFRA Standards. As with previous amendments, it brings together new Standards and revisions to existing Standards into a single package, providing clarity and predictability for stakeholders.
In its current form, the Amendment is expected to introduce 51 new Restriction Standards and to revise 18 existing ones, reflecting updated RIFM safety assessments and Expert Panel conclusions. These changes incorporate improved understanding of exposure patterns, toxicological endpoints, and aggregate use scenarios.
A central element of the 52nd Amendment is the comprehensive revision of the IFRA Furocoumarin Policy. This revision consolidates the policy into a single Standard and removes eight older Standards that are no longer relevant. The updated approach is underpinned by advances in analytical methods, key marker selection, and an updated scientific rationale supporting thresholds for consumer safety.
The public consultation for the 52nd Amendment began on 12 December 2025 and will run for six months. Following consideration of stakeholder feedback and finalization of documentation, formal notification of the Amendment is expected in late 2026. This structured timeline ensures transparency, scientific rigor, and global applicability.
Case study: revising the IFRA Furocoumarin Policy
The revision of the IFRA Furocoumarin Policy is one of the most significant components of the 52nd Amendment and illustrates how scientific progress and regulatory dialogue can reshape long-standing risk management approaches. Furocoumarins are naturally occurring constituents of many citrus oils and other botanicals. While not intentionally added as fragrance ingredients, their phototoxic potential is well established, necessitating careful control of their presence in finished consumer products (4).
Because furocoumarins are not used as discrete fragrance ingredients, they fall outside the usual scope of RIFM safety assessments. Consequently, the revised policy was developed through targeted scientific workstreams, data integration, and extensive engagement with IFRA members and external stakeholders, with the Expert Panel maintaining independent oversight of the scientific robustness of the work.
An important first step was the development of a robust analytical method capable of identifying and quantifying 15 furocoumarins in raw materials used in consumer products, enabling consistent characterization of individual furocoumarins (5). Building on this, IFRA evaluated both the phototoxic potency of known furocoumarins and those occurring at the highest concentrations. Based on an extensive review of the published literature, eight key markers were selected to form the basis of quantification and risk management. A final step, supported by a comprehensive and carefully conducted literature review, involved establishing three threshold limits for skin-contact products, reflecting differences in exposure conditions (4):
- 1 ppm and 5 ppm for leave-on products, depending on intended use and exposure;
- 50 ppm for rinse-off products, where exposure is substantially lower.
- No limit for non-skin-contact products or in the absence of UV exposure
Where possible, these thresholds align with existing regulatory benchmarks, including the 1 ppm limit for sun-protection and bronzing products set under the EU Cosmetic Products Regulation and adopted in the ASEAN Cosmetic Directive.
An important feature of the revision process was constructive dialogue with regulatory authorities, particularly in Switzerland. Swiss authorities approached IFRA to discuss the existing policy, indicating that the earlier version was no longer aligned with current scientific understanding. IFRA shared its updated analytical data, marker selection, and scientific rationale, enabling an informed exchange over several months. As a result of this engagement, Switzerland has reflected IFRA’s eight selected markers in its national regulation.
The revised Furocoumarin Policy thus illustrates how IFRA’s risk-based framework can adapt to evolving science while supporting greater regulatory convergence.
Regulatory context: risk-based product stewardship and global alignment
The Amendment to the IFRA Standards takes place against a broader shift in chemical management policy, particularly in regions where regulatory decisions are increasingly hazard-based. While hazard identification is a fundamental component of risk assessment, approaches that rely solely on intrinsic properties, without considering actual consumer exposure, may lead to outcomes that are overly conservative and do not reflect real-world risk.
Recent regulatory decisions highlight this challenge. The regulatory treatment of 2-(4-tert-butylbenzyl)propionaldehyde, for example, resulted in its prohibition in European cosmetic products following hazard reclassification (6), not because safe use could not be demonstrated, but because the change in hazard category triggered regulatory criteria unrelated to exposure that could not be fulfilled. This illustrates the tension between hazard-based frameworks and risk-based approaches that integrate both hazard and exposure.
In this context, the IFRA Standards provide a coherent, science-based, and risk-focused product stewardship framework that can be applied consistently across regions. As regulatory expectations and scientific knowledge evolve, global alignment in fragrance safety becomes increasingly important. Fragmented requirementsEM_DASHthrough differing national restrictions, divergent interpretations, or inconsistent implementationEM_DASHcreate practical challenges and business uncertainty.
By offering a globally applicable, risk-based reference point developed through transparent scientific assessment and independent expert review, the IFRA Standards help reduce complexity, protect consumers, and support innovation in an increasingly hazard-driven regulatory environment.
Conclusion and outlook
The 52nd Amendment represents a forward-looking update to the IFRA Standards, integrating new scientific insights and reflecting constructive engagement with stakeholders and regulators. The revision of the furocoumarin policy, in particular, demonstrates how IFRA’s risk-based product stewardship framework can evolve in response to scientific and regulatory developments.
As regulatory landscapes continue to change, maintaining a transparent, evidence-driven system remains essential. Ongoing collaboration across industry, science, and regulatory authorities will continue to be central to IFRA’s mission and to secure the safe, responsible, and confident use of fragrance ingredients globally.
References and notes
- Api et al., Criteria for the Research Institute for Fragrance Materials, Inc. (RIFM) safety evaluation process for fragrance ingredients. Food and Chemical Toxicology (2015). 82, S1–S19. DOI: 10.1016/j.fct.2014.11.014
- Api et al., The RIFM approach to evaluating Natural Complex Substances (NCS). Food and Chemical Toxicology (2022). 159, 112715. DOI: 10.1016/j.fct.2021.112715
- Lapczynski et al., Aquatic risk of fragrance materials: advancing prioritization in aquatic systems. Environmental Toxicology and Chemistry (2025). 44, 3636-3645. DOI: 10.1093/etojnl/vgaf214
- Irizar et al., Phototoxicity and skin damage: A review of adverse effects of some furocoumarins found in natural extracts. Food and Chemical Toxicology (2025). 200, 115332. DOI: 10.1016/j.fct.2025.115332
- IFRA, Quantification of Furocoumarins HPLC/DAD Procedure. 2025 ifra-analytical-method-quantitative-determination-of-furocoumarins-by-hplc-dad_revised-20250320.pdf
- Regulation – 2021/1902 – EN – EUR-Lex https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2021.387.01.0120.01.ENG&toc=OJ%3AL%3A2021%3A387%3ATOC.
