Perfumes, fragrances and aerosols

• Regulation (EC) No 1223/2009 — Cosmetics
• Directive 75/324/EEC — aerosol dispensers
• Regulation (EC) No 1272/2008 — CLP
• Regulation (EC) No 1907/2006 — REACH

Who has to appoint one

Manufacturers and sellers outside the Union placing perfumes and cosmetic aerosols on the EU market. Aerosol dispensers carry a second regime on top of the cosmetics rules, with its own marking and pressure testing requirements.

Thresholds and exemptions

None. Sample vials and travel sizes are placed on the market like any other unit.

What must appear on the label

Full cosmetic labelling including the responsible person, nominal content, durability, precautions, batch number, function and INCI list with the twenty-six declarable fragrance allergens above threshold. Aerosols additionally carry the reverse epsilon marking, the nominal capacity, the flammability warnings and the specific aerosol precautions.

Marketplace fields

Aerosols face transport and fulfilment restrictions as dangerous goods, which limits the channels available. Marketplaces check the responsible person and the flammability warnings in listing images.

Documentation you must hold

Product Information File with the Cosmetic Product Safety Report signed by a qualified assessor, CPNP notification, and for aerosols the technical documentation demonstrating compliance with the aerosol Directive including the pressure test records. Poison centre notification with UFI where the mixture is classified.

Standards and testing

Stability, compatibility and preservative efficacy for the formulation, allergen quantification for the declarable fragrance substances, and for aerosols hydraulic pressure testing and flammability classification of the contents.

Language requirements

Precautions, warnings and function in the language of each member state of sale.

When it applies

CPNP notification and the completed Product Information File before the first unit is placed on the market.

How long records are kept

Product Information File for ten years after the last batch was placed on the market.

What happens if you do not comply

Withdrawal and recall, Safety Gate alerts for aerosol pressure failures, and in several member states criminal liability for the responsible person where an unnotified cosmetic reaches consumers.

Who enforces it

Cosmetics competent authorities, market surveillance authorities, and transport authorities for the dangerous goods aspects.

Where the boundary lies

An aerosol is two regulated products at once: the cosmetic inside and the dispenser around it. Sellers routinely complete the cosmetic notification and overlook the aerosol Directive marking, which is checked because pressure failures injure people.

Questions we are asked

Do we need to list fragrance allergens?

Yes, the declarable allergens must be named individually above 0.001% in leave-on and 0.01% in rinse-off products, and the list has been substantially expanded.

Can we ship perfume by air?

Alcohol-based perfumes and aerosols are dangerous goods with packing and quantity restrictions, which is a transport matter separate from product compliance.