The European Green Deal

The European Green Deal is the EU’s climate-neutrality programme, and the fragrance industry’s objection to it is narrow and specific: several proposals under it would restrict materials on hazard classification alone rather than on measured exposure. A 2023 open letter from perfumers warned that over 400 materials could be banned if those proposals were adopted as drafted. As of August 2026 the new hazard classes are EU law, but the revision of the Cosmetic Products Regulation that would apply a hazard-based ban mechanism to fragrance materials has still not been proposed.

The European Green Deal could ultimately remove 400+ materials from the perfumer’s palette. Is this an important precaution—or regulatory overreach that could reshape fragrance as we know it?

What Is the European Green Deal?

The European Green Deal is the EU’s broad sustainability initiative aimed at achieving a climate-neutral economy. While its goals are environmentally driven, the fragrance industry faces major implications—both opportunities and substantial risks.

On the positive side, the Deal encourages sustainability, traceability, eco-friendly sourcing, and transparency—areas where modern consumers are increasingly invested. But the challenges are significant: potential ingredient bans, increased production costs, reduced palette diversity, and difficulty navigating a more complex regulatory system.

Why Are Perfumers Concerned About the Green Deal?

Although well-intentioned, several proposals under the Deal could shift chemical regulation toward a hazard-based—not exposure-based—model. This represents a major departure from the scientific principles that currently govern fragrance safety.

Under hazard-based policy, materials may be restricted regardless of:

• how little is used in finished products
• whether exposure is effectively zero
• whether decades of safe use data exist
• whether the material comes from a natural plant source

This model risks eliminating hundreds of natural and nature-identical materials—not because they are unsafe in real-world applications, but because they contain constituents that trigger hazard classifications at high, unrealistic levels.

The result? A potential loss of:

• natural essential oils
• plant-derived isolates
• materials that define entire fragrance families (citrus, floral, aromatic, resinous)

For perfumers, this represents not just a regulatory challenge but a creative one. A reduced palette limits artistic expression and the ability to recreate culturally important fragrance profiles.

Hazard-Based vs. Exposure-Based Safety: What Is the Difference?

The two models ask different questions about the same molecule. One asks whether a substance could ever cause harm; the other asks whether it causes harm at the amount people actually meet.

The fragrance industry’s position is not that hazard classification is wrong, but that it answers the wrong question on its own. To check the exposure-based limit that applies to a specific material in a specific product, use the IFRA category lookup tool.

How Would Hazard-Based Rules Affect Creativity, Safety Science, and Cost?

For example, it is scientifically normal for a natural essential oil—like rose, lemon, thyme, or lavender—to contain dozens or hundreds of naturally occurring constituents. Some occur at levels that would classify them as “hazardous” in pure form, yet they pose no risk at realistic use concentrations.

If these materials are restricted based on hazard alone, perfumery loses:

• iconic naturals (rose oil contains 350+ molecules)
• naturally occurring trace components like p-cymene
• materials that have been safely used for generations

Additionally, compliance with new sustainability requirements may increase:

• raw material costs
• manufacturing expenses
• documentation and regulatory overhead

These costs ultimately impact brands—especially small and mid-size companies—and consumers.

Where Do the Green Deal Proposals Stand in 2026?

This post was first published in August 2023, while the proposals below were still under discussion. Here is where each one actually stands, checked against the EU’s own records in August 2026.

So the direction of travel the open letter warned about is real, but so far it has landed in classification rather than in a ban list. The step the letter was written against — widening the hazard-based prohibition in cosmetics from CMR substances to the newer hazard classes — would require the Cosmetic Products Regulation revision that has not been proposed.

Nothing above is a forecast. Where a measure has not been adopted, we say so rather than assume a date. For the wider regulatory picture, start at our fragrance oil knowledge center.

Where Can You Read More About the Green Deal?

To make your own assessment, here are key resources:

• Read the perfumers’ open letter
• A perfumer’s industry perspective
• IFRA’s overview of the European Green Deal

The primary sources behind the status table are Delegated Regulation (EU) 2023/707, Regulation (EU) 2024/2865, Regulation (EC) No 1223/2009 and the European Parliament’s legislative train entry on the Cosmetic Products Regulation.

Notable Excerpts Worth Highlighting

“We live in a chemical world and life itself is chemistry in action.”

“By volume, 50% of the palette of perfumers today is nature-identical.”

“Rose oil is around 350 molecules—not a single substance.”

“We have come to associate the word ‘chemical’ with danger, as though ‘natural’ is its opposite.”

“Harmfulness is exposure-based, not hazard-based. Even hazardous substances can be harmless at low doses—and innocuous substances can be harmful in the right conditions.”

“Banning p-cymene would unintentionally ban hundreds of naturals—lemon and thyme oils included.”

“Exposure to fragrance materials is far lower than exposure to the same constituents in food. Peeling one orange a day equals the limonene exposure of 140 perfume sprays.”

Frequently Asked Questions

Share Your Thoughts

This is an important moment for the fragrance industry. We’d love to hear your perspective—whether as a maker, brand, perfumer, or consumer.

To discuss a specific formulation or compliance constraint, see our fragrance design services or contact the team.