Does Adding a Different Fragrance Change My Formulation?
By: Kirsten Alcock, Principal Product Safety Consultant, email
YES. When you are adding a new fragrance to a formulation, there can be potential changes to the product classification as well as other regulatory issues you may not be aware of. Depending on the amount of fragrance you are exchanging, this can have an impact not only on your classification but also on the disclosure of chemicals on your Safety Data Sheet and labels.
In my experience, many fragrances contain upwards of 20-30 ingredients. The ingredients within these fragrances need to be looked at for some of the following issues:
- INVENTORY: You DO need to know if all of those 20-30 chemicals are on the Domestic Substances List (DSL)/ Non-Domestic Substances List (NDSL) for Canada or oxic Substances Control Act (TSCA) status in the United States.
- Carcinogenic, mutagenic, and reprotoxic chemicals (CMR’s): Are any of those chemicals in your fragrance a carcinogen, mutagen, or reproductive toxin? Are they in the product at greater than 0.1%?
- STATE REGULATIONS: Does the US supplier SDS indicate if any ingredients are on California Prop 65?
- STATE REGULATIONS: Is this product intended for California and subject to the California Cleaning Product Right to Know Act of 2017 (Senate Bill: SB258)
- SDS DISCLOSURE: If those chemicals in your fragrance require disclosure on your SDS, you can no longer make the claim ‘fragrance’ and place TRADE SECRET for CAS number on your SDS to be in compliance in Canada.
It is important to understand that changing a fragrance or adding a fragrance CHANGES your product formulation.
If you are having difficulty determining the requirements for your product compliance, let us know. We have the background and experience to know what to look for. We work with many clients who change out one fragrance for another and can help advise if any changes are required based on changing your formulation.
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