Conducted on behalf of The International Fragrance Association (IFRA), the study assessed the impacts against baseline projections for industry growth. The findings suggest that more than a quarter of the industry’s portfolio in turnover terms would be affected in some way by the proposed changes. According to the report, for which data was collected from dozens of companies of all sizes from across Europe, this impact would be felt by consumers, with a reduction in the choice of products that people consider important to their mental and physical wellbeing.
The research focused on how specific proposals within the CSS, launched in October 2020, may affect fragrance companies and the wider industry in Europe. Such proposals include an extension of the Generic Approach to Risk Management (GRA) that does not take account of the specificities of fragrances; the addition of hazard classes to classification, labelling and packaging (CLP); and the introduction of a ‘mixture assessment factor’ to assess combinations of chemicals.
Reacting to the study’s findings, Martina Bianchini, IFRA President, said: “The study highlights the challenges posed by the current plans to the long-term socio-economic sustainability of our sector, especially for small businesses, which make up half of all companies in the European fragrance industry.
She added: “At a time of uncertainty, we should be wary of the unintended consequences of policies and how they may negatively impact innovation, employment, and growth. We want to make sure these important sustainability policies have a positive impact in these areas, as well as enhancing consumer choice, encouraging investment, and reinforcing fragrance’s place as a key part of Europe’s cultural heritage, as well as its future.”
Hans Holger Gliewe, IFRA Chairman, added: “We believe that by working together to address some of our concerns about the proposed rules, and by giving more time to develop and modify portfolios, we can achieve an outcome that gives Europeans the high level of consumer and environmental protection they deserve, and the choice and innovative products they desire."
Background on the report
As well as addressing the potential impact on the fragrance industry, the study is said to highlight a ‘ripple’ effect on the wider fragrance value chain – from raw materials suppliers, to manufacturers, consumer goods companies and retailers – due to the need to substitute and reformulate products.
The report presents the findings of the research which includes an analysis of the impact of the addition of hazards to the CLP Regulation (EC) No. 1272/2008; the extension of the Generic Risk Approach to Risk Management (GRA); and a qualitative assessment of the essential use concept.
The work has followed the EU Commission’s Better Regulation Guidelines where possible, although this is an analysis of business impacts only and so costs and benefits to human health and the environment have not been considered.
IFRA is due to present the findings of the study to European decision-makers as work progresses on implementation of the CSS.