Why Is My Product's Maximum Fragrance Level Lower Than the IFRA Limit?

One of the questions we're asked most often is:

"The IFRA Certificate says this fragrance can be used at 20% (or even 100%) in perfume, so why have you only allowed 5%, 10% or 18% in my Cosmetic Product Safety Report?"

The short answer is that an IFRA Certificate is not the same as a Cosmetic Product Safety Assessment.

IFRA Standards are an important part of cosmetic safety, but they are only one part of the overall picture. An IFRA Certificate tells you the maximum level at which a fragrance can be used based on the fragrance ingredients that are restricted under the IFRA Standards. It does not assess every aspect of cosmetic safety.

A Cosmetic Product Safety Report (CPSR), on the other hand, looks at the finished cosmetic product as a whole. This includes the intended use of the product, how much is applied to the skin, how often it is used, the exposure to individual ingredients, regulatory restrictions under the UK and EU Cosmetics Regulations, technical impurities, contaminants, allergens and any other available toxicological information.

For this reason, it is entirely possible for a fragrance supplier's IFRA Certificate to show a higher permitted concentration than the level recommended in a cosmetic safety assessment.

There are several reasons this can happen.

Firstly, some fragrance suppliers produce separate Cosmetic Safety Evaluations in addition to their IFRA Certificates. These evaluations take into account regulatory requirements that sit outside the IFRA Standards, including substances listed in Annex II and Annex III of the Cosmetics Regulation, technical impurities and the intended cosmetic application. A supplier may therefore conclude that although the IFRA Standard would allow a higher concentration, they are only willing to support a lower concentration for a specific cosmetic product.

Secondly, a supplier's cosmetic evaluation may have been produced specifically for a customer's formulation. For example, if a customer requests an evaluation for a perfume containing 18% fragrance, the supplier may only assess and approve that concentration. This does not necessarily mean that 19% or 20% would be unsafe, simply that those concentrations have not been evaluated and therefore cannot be supported by the supplier.

Finally, cosmetic safety assessors will often apply professional judgement and risk management. Even where a higher concentration may technically be possible, an assessor may recommend a lower level to ensure an adequate margin of safety, reduce the likelihood of skin sensitisation or irritation, or remain within the limits of the available supporting documentation.

This is why it is important to remember that the IFRA Certificate is not the final word. It is an essential document, but it forms only one part of the evidence used when assessing the safety of a cosmetic product.

At Revega, we review the available documentation as a whole. This includes the IFRA Certificate, Safety Data Sheet (SDS), allergen declaration, cosmetic safety evaluations (where available) and the requirements of the UK and EU Cosmetics Regulations. Where several documents provide different limits, we will always work to the most appropriate and well-supported value. This ensures that your CPSR is based on the strongest available evidence and provides the highest level of consumer safety.

If your CPSR specifies a lower maximum fragrance level than the IFRA Certificate alone, it isn't because we're being overly cautious or making up our own rules. It's because we're considering all of the available safety information—not just one document. Our aim is always to provide assessments that are both scientifically justified and fully compliant with current cosmetic regulations.

It is equally important to note that this principle works both ways. If an IFRA Certificate specifies a lower maximum usage level than a customer wants or supplier guidance, the IFRA limit must always be respected. IFRA Standards are industry safety standards developed to manage the safe use of fragrance ingredients and should never be exceeded. We always work to the lowest applicable limit, whether that comes from the IFRA Certificate, the supplier's cosmetic safety evaluation, the Cosmetics Regulation, or the outcome of the cosmetic safety assessment.

It is also worth remembering that, regardless of the IFRA limit, cosmetic safety assessors will often apply practical risk-management limits based on the type of product being assessed. Whilst every formulation is assessed individually, it is common for fine fragrances and perfumes to be assessed at around 15–25% fragrance, rinse-off cosmetic products such as shower gels and shampoos to be limited to around 2–3%, and leave-on products such as creams, lotions and body oils to around 1–2%. Deodorants are frequently limited to 1% fragrance, while products fragranced with essential oils often have even lower permitted levels due to the cumulative effects of naturally occurring fragrance allergens, skin sensitisation potential and overall consumer safety.

These are not arbitrary limits or additional regulations, but professional risk-management decisions based on the intended use of the product, toxicological data, cumulative exposure, the Margin of Safety (MoS), and the experience of the safety assessor. Where an assessor specifies a maximum fragrance level for your CPSR, that limit should always be respected, even if the IFRA Certificate itself would permit a higher concentration.

This ensures your product remains compliant with all applicable safety requirements, your customers are safe and protects you from potential customer issues and complaints.

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