Labeling a fragrance in compliance with U.S., Canadian, and E.U. regulations is not particularly difficult but finding the information you need can be challenging.
Labeling a fragrance in the U.S. is simple and U.S. regulations tend to be slow to change. Thus you are not confronted with frequent updates.
E.U. regulations are a pain to round up but are, essentially, practical and compliance is not difficult.
The problem with the E.U. is the lack of simple guidance coupled with frequent updates, most of which will not affect your labeling. However, updates to the E.U.'s list of ingredients which must be listed on your label does change regularly.
Canadian regulation of perfume labeling is somewhat exceptional in that the information is easy to find and the documentation easy to understand. Canada seems to be aware that while the regulations are for every manufacturer, some manufacturers may be home businesses and the documentation of regulations seems to give consideration of this possibility.
Read the "Summary" first. It may tell you everything you need. I think perhaps the political nature of U.S. regulations (like the E.U.) makes it difficult for agencies to create a simple and complete manual that would be useful to small businesses and hobbiests. From a practical point of view, if you do your best to follow the Summary, unless you are making large sales and rub someone the wrong way, it is not likely you will run into troubles with the regulatory agencies.
- Summary of Regulatory Requirements for Labeling of Cosmetics Marketed in the United States
Read this first. For the U.S. you may not need to go any farther.
- Cosmetic Labeling Guide
- Labeling Regulations Applicable to Cosmetics (Code of Federal Regulations, Title 21)
- Fair Packaging and Labeling Act TITLE 15 - COMMERCE AND TRADE CHAPTER 39 - FAIR PACKAGING AND LABELING PROGRAM
- Title 21 Code of Federal Regulations, Cosmetic Products
- Color Additive Regulations Title 21, Code of Federal Regulations - Color Additives
- Good Manufacturing Practice (GMP) Guidelines/Inspection Checklist
- Voluntary Cosmetic Registration Program (VCRP)
- Ingredients Prohibited & Restricted by FDA Regulations
June 22, 1996; Updated May 30, 2000. With the important exception of color additives that are not coal-tar hair dyes, cosmetic ingredients are not subject to FDA premarket approval authority. However, regulations prohibit the use of some substances and restrict the use of others because of safety concerns or environmental factors. Violating the restrictions on the use of these substances may cause FDA to pursue regulatory action.
With a few clicks of your mouse on the references below you can be very well informed on the requirements for marketing a fragrance in Canada. There are some additional steps you must take beyond U.S. regulations but in most cases they will not be burdensome. Perfume is classified as a cosmetic.
- Guidelines for Cosmetics Manufacturers, Importers and Distributors — This booklet is short and to the point. Essential reading if you want to market a fragrance in Canada and very useful reading if you want to market a fragrance elsewhere.
- Cosmetic Regulations (C.R.C., c. 869)
- General Requirements for Cosmetics — General Requirements for the Sale of Cosmetics in Canada
- Cosmetic Notification - Form — This form must be submitted to Health Canada within the first ten days a cosmetic is available for sale in Canada.
- Guide for Completing Cosmetic Notification Forms — Instructions for completing Cosmetic Notification Forms.
- List of Prohibited and Restricted Cosmetic Ingredients ("Hotlist") — An explanation of the Hotlist and how to read it.
- Cosmetic Ingredient Hotlist - March 2011 — This is the actual "Hotlist". Be aware of restrictions on certain salicylates and bans on certain musks. And remember, this list is periodically updated.
- Consumer Packaging and Labelling
- New Ingredient Labelling Requirements - Frequently Asked Questions
Start by reading Cosmetic Ingredient Labelling in the European Union. Then be sure to check the Annex III list of listable ingredients, which is updated regularly.
- Cosmetic Ingredient Labelling in the European Union
- COLIPA GUIDELINES ON COSMETIC PRODUCT LABELLING, 2011
- Cosmetic products (until 2013)
CosIng is the European Commission database with information on cosmetic substances and ingredients contained in the:
- "Cosmetics Regulation" (EC) No 1223/2009 of the European Parliament and of the Council;
- "Cosmetics Directive" 76/768/EEC (Cosmetics Directive), as amended;
- Inventory of Cosmetic Ingredients, (which later will be replaced by the Glossary of Common Ingredient Names), cf. article 33 of the Regulation; and
- Scientific Opinions on Cosmetic Substances of the Scientific Committees. However, references to the scientific opinions are limited to those published on the Internet.
- Annex II
LIST OF SUBSTANCES PROHIBITED IN COSMETIC PRODUCTS
- Annex III
LIST OF SUBSTANCES WHICH COSMETIC PRODUCTS MUST NOT CONTAIN EXCEPT SUBJECT TO THE RESTRICTIONS LAID DOWN
- Annex III (Part 1)
List of substances which cosmetic products must not contain except subject to the restrictions and conditions laid down