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IFRA 49th Amendment Implementation & Lilial (BMHCA) Restrictions
Who Is IFRA?
IFRA is a self-regulatory body that has represented the interest of the fragrance industry since 1973. It is a globally recognized association that promotes the safety and benefits of fragrances while setting rules that are compulsory for all of its members.
Criteria for safe use of fragrance ingredients is prescribed within IFRA standards, which can either prohibit, restrict or set purity requirements for specific ingredients based on the findings of the Research Institute for Fragrance Materials (RIFM). As new information is made available, IFRA standards are updated or new ones are issued as part of the IFRA amendment process.
Background Information
IFRA 49th Amendment Implementation.
The deadlines for entry in force with regards to the Implementation of the 49th Amendment to the IFRA Guidelines are as follows:
• 10th May, 2021: Entry into force for new formulations
• 10th May, 2022: Compliance of existing formulations created before 10th May 2021
Harmonised Classification and Labelling (CLH) proposal for reproductive toxicity of BMHCA/Lilial (CAS n° 80-54-6, EINECS n° 201-289-8) as CMR1b
As you may be aware the above regulation prohibiting the presence of BMHCA/Lilial in new and existing cosmetic products in the EU was recently published with the transition period for compliance as follow;
• The use of BMHCA in new and existing cosmetic products will be banned in the EU from 1st March, 2022, 18 months after the EIF described above. This date refers to a ban ‘on-shelf’ of BMHCA-containing cosmetic products in the EU. At Supplies for Candles, we have made the appropriate arrangements for product reworks to meet this deadline.
• The above-mentioned regulatory events and activities are limited to those products manufactured and sold within the EU. The use of BMHCA in cosmetic products sold outside the EU and in home care products in general remains largely unaffected with the exceptions outlined below.
• Home care products marketed in the EU and sold to the general public such as detergents and air fresheners that contain 0.3 % or more BMHCA would be classified as CMR 1b and therefore banned from sale. Professional homecare products containing 0.3% or more of BMHCA will have to be classified and labelled as CMR1b with labels that contain all of the appropriate language for professional use.
• The schiff base, Lysmeral-methyl anthranilate or Verdantiol, CAS no. 91-51-0 is also impacted by this legislation.
Here at Supplies for Candles, we took decisive action in Spring of 2021, we took decisive action in Spring of 2021, to reformulate and remove Lilial (BMHCA) where present in all our existing fragrances.
Due to this change we have had to make some amendments to the fragrance Allergen, SDS, IFRA certification and hazard labelling. We are currently working on updating our website technical files to reflect these changes. As you can appreciate due to the huge range of fragrances that we supply this may take some time. We their fore ask that if you require any urgent documents to please contact customerservice@suppliesforcandles.co.uk and we will send you the updated documents as quickly as possible. Please check the required documents on the website state IFRA 49th Amendment before contacting us.
We will also let you know if any fragrance formulations will be amended and when this will be effective from.
What this means for you
You can refer to your IFRA to see what percentage of an item you can use depending on the purpose of your final product. Under the 48th amendment there were 11 categories, under the new 49th amendment there are now 12 categories, which means that there have been changes on what categories your final product will fall into, you will need to take this into account moving forward.
Product | Old 48th Category | New 49th Category |
Reed Diffuser | Category 11 | Category 10A |
Room Spray | Category 9C | Category 10B |
Candles | Category 11 | Category 12 |
Wax Melts | Category 11 | Category 12 |
Can I use my old printed CLP Labels?
As we have replaced hazardous material with non-hazardous material your old CLP labels will NOT be understanding the hazards and endangering your customers. In the majority of cases, the only difference on the label will be the removal of Lilial from the 'Supplemental Information' line.
Remember percentages are usually rounded up on CLPs, for example, our CLPs range for 10%-25% and you may only be using 6% or 15% of fragrance oil in your products. The CLP regulation was introduced to protect end users, ensuring they are aware of the hazards associated with the products they have purchased and used. Therefore if you are using a BMHCA free version of your product but still using your old CLP label, you have supplied your customer with an even safer product and there is nothing hazardous in your product that hasn't been declared.
For any questions regarding changes under the IFRA 49th Amendment Implementation or the Lilial (BMHCA) restrictions, please contact our customer service team at customerservice@suppliesforcandles.co.uk