IFRA, cosmetic regulations and INCI: who regulates what in perfumery?

In the world of fragrance, the terms IFRA, cosmetics regulation, INCI, allergens, and certificate of conformity are often mixed together. However, they correspond to different mechanisms. Distinguishing between them makes it easier to understand what a manufacturer, supplier, or seller actually needs to verify.

IFRA and European regulation: two different levels

The IFRA Standards constitute a voluntary risk management system established by the fragrance industry. They may prohibit, restrict, or set certain criteria for fragrance materials. They are mandatory for IFRA member companies under its Code of Practice.

However, IFRA itself points out that its Standards do not replace national or regional regulations. Regulatory compliance of the product remains the responsibility of the company placing it on the market. See IFRA’s official explanations.

The European Cosmetics Regulation

When a fragrance falls under the European framework for cosmetic products, it must comply with the applicable cosmetics legislation, notably Regulation (EC) No 1223/2009 and its amendments. This framework is legally different from a voluntary professional standard.

It notably imposes requirements concerning product safety, its file, its responsible person, and its labeling. The details depend on the product and the market concerned.

What about INCI?

INCI refers to the nomenclature used to declare cosmetic ingredients on labeling. An INCI list is therefore neither a complete formula intended for the public nor an olfactory pyramid.

In a fragrance, the term “Parfum” may refer to the fragrance composition in the ingredients list. However, certain fragrance substances must be declared individually when they are subject to the applicable labeling rules.

Allergens: regulation, not “IFRA certification”

It is essential not to confuse the regulatory declaration of certain fragrance allergens with an IFRA certificate of conformity. IFRA explicitly states that these labeling obligations arise from the European Cosmetics Regulation, not from the IFRA Standards.

The new European rules arising from Regulation (EU) 2023/1545 have applied since 31 July 2026, with a transitional period for certain products already placed on the market. See the European Commission’s page on fragrance allergens.

What does an IFRA certificate really mean?

One point that is often misunderstood: IFRA does not itself certify products, raw materials, or finished fragrances. The certificate of conformity with the Standards is a document prepared by the manufacturer of the fragrance composition, based on its relationship with its customer.

It therefore does not constitute an “IFRA certification of the fragrance” issued directly by the organization. See IFRA’s official position on certificates of conformity.

Who does what?

Why can a fragrance comply with IFRA without complying with European law?

Because the two systems do not serve the same purpose. IFRA manages certain risks related to fragrance ingredients within its professional system. European law, on the other hand, imposes all legal requirements applicable to the cosmetic product concerned.

IFRA itself gives the example of situations in which a national or European regulatory measure may differ from its own Standards. Complying with the IFRA Standards therefore never exempts you from checking the law applicable in the target market.

And what about a natural substance?

The reasoning becomes even more interesting with a complex natural substance. An essential oil or another Natural Complex Substance may contain several constituents relevant to the assessment and use restrictions. The origin, plant part, extraction process, and analytical profile may therefore matter.

That is why the concepts we have studied in this library - traceability, analysis, standardization, and safety - come together in the actual management of a material.

A simple rule to avoid confusion

IFRA = risk management within the framework of the industry's Standards.
Cosmetics Regulation = legal requirements applicable to the product.
INCI = nomenclature used to declare ingredients.
IFRA Certificate = a document confirming compliance with the Standards, not product certification by IFRA.

Key points

A serious perfume is not limited to a pyramid of notes or a statement that it is “IFRA-compliant.” To understand its compliance, each piece of information must be placed within its system: safety, regulations, formulation, labeling, and responsibility for placing the product on the market.

This article is for informational purposes and does not replace a professional regulatory assessment for placing a product on the market.