Guide
When a material you rely on is restricted
A material you rely on gets a lower limit, a purity requirement, or a ban. You did nothing; the assessment moved. If you sell for long enough this is not a question of whether.
Checked against the sources named at the foot of this page on 13 August 2026.
It will happen to you
A material you rely on gets a lower limit, a purity specification, or a prohibition. You did nothing; the assessment moved. If you sell for long enough it is not a question of whether but of how many times, and the houses it has already happened to are every house that has been going more than a few years.
Oakmoss was restricted and then given a specification on the atranol and chloroatranol it contains, which rebuilt the base of most classical chypres. HICC, which the trade knew as Lyral, was declarable and is now banned outright. Butylphenyl methylpropional, which the trade knew as Lilial, went the same way. Those two are the reason the famous list of 26 fragrance allergens is now 24: they left it upward, into prohibition, rather than because anyone decided they were harmless.
Finding out before a customer does
The unglamorous half of this is knowing that something changed at all. There is no letter. The realistic sources are the amendment notifications from the industry body, the Official Journal when a regulation moves an annex, and your own suppliers, who usually know first because their certificates have to change.
What makes the difference is not vigilance but records. If you can answer "which of my formulas contain this material, and which batches went out with it" in a minute rather than an afternoon, the news is an inconvenience. If you cannot, it is a week of reading old spreadsheets, and the answer at the end of it is a guess.
Three different problems wearing the same coat
What actually changed decides what you do
A lower limit
Arithmetic first
You may already be under it. Check before you touch anything, and remember the limit is per category and per finished product.
A specification
Ask your supplier
A purity or peroxide requirement is about the bottle, not the dose. A compliant grade may exist and your formula may not need to change at all.
A prohibition
It has to come out
The only one that forces reformulation. Check whether a trace arriving inside a natural is separately allowed, because some prohibitions say so.
Two of the three often need no change to the formula at all. Reformulating before you have worked out which one you are looking at is the most common way to spend a month unnecessarily.
How long you have
An industry amendment gives two deadlines and they apply to different fragrances rather than to different obligations. A new creation, briefed after the amendment settles, gets the earlier one. An existing creation, already on the market or already in development, gets the later one, and that is your grace period for something you already sell.
A change in law works differently again: a regulation typically gives one date after which non-compliant product may no longer be placed on the market, and a later one after which it may no longer be sold to the end customer at all. The second is a sell-through allowance for stock already in the chain, not an extension for new production. Work out which of those four dates applies to you before you plan the work, because the difference between them is usually a year or more.
Substitution is not a swap
The instinct is to find the nearest-smelling bottle and change one line. It rarely works, because a material is not doing one job. It contributes a smell, it contributes tenacity, it contributes to how the materials around it read, and it may be holding the whole top together.
So start from what the material was doing rather than from what it smelled like. Which facet of it were you actually using? Was it carrying the drydown or the first ten minutes? Is what you need one material or an accord of two or three that between them do the same job? Very often the honest answer is that no single material replaces it and the section has to be rebuilt.
Two practical cautions. Check the substitute against the same rules before you fall in love with it, because a material that is unrestricted today can be under assessment already, and replacing a restricted material with one heading the same way is a job done twice. And check what it does to your allergen declaration: a substitute that is fine on every limit can still push an entry over a labeling threshold and change what has to be printed.
Proving it is still the same product
This is the part that decides whether customers notice. Judge the new version against the old one directly, not against your memory of it, which is generous and wrong. Two blotters side by side, dated, over hours and then over days, with the old formula made fresh rather than smelled from an aged bottle that has itself moved.
Then decide honestly whether it is the same fragrance or a new one. Both are legitimate. What is not legitimate is quietly shipping a materially different product under the same name to people who bought the first one; a reformulation note costs you very little and a discovered silent change costs you the customer.
What the reformulation drags behind it
The formula is the small part. A changed composition is a changed product, and most of the file follows it.
- A new version of the formula, kept beside the old one rather than overwriting it, because batches made under the old one still have to be explicable.
- A fresh compliance check at the category it sells in, not an assumption that a smaller quantity of something must be safer.
- A new allergen declaration, and a new label if it moved. Printed labels for the old version are now stock you may not be able to use.
- The safety assessment revisited, which is a cost and a wait, and the reason to batch several changes together rather than reformulating twice in a year.
- An updated portal notification where the change affects what a poison center would say.
- A safety data sheet revision, if you supply this to other businesses, sent to everyone you supplied in the past year.
And the old batches do not disappear. Stock already made is still out there, still yours, and still has to be explicable years later against the rules as they stood when it was made.
How Orris Bench handles this
Finding what is affected is a question rather than an afternoon: the library knows which formulas contain a material, including the ones where it arrives inside a natural rather than as a line of its own, which is where a search through spreadsheets misses it. When a material is out or discontinued it will suggest substitutes from what you have.
Every version is kept rather than overwritten, and two can be compared side by side, so the old formula stays available to make fresh for the comparison and the batches made under it still resolve. Amendments are held beside each other rather than replacing one another, so a batch made under an earlier one is judged against the rules that actually applied to it.
And the documents that have to follow the change come out of the same record: the assessment at the right category, the allergen declaration at the strength actually made, the label, and the product file.
Sources
The two-deadline structure for industry amendments is IFRA's own notification practice, described in the guide to the IFRA Standards on this site. The placing-on-the-market and making-available dates are how a Commission regulation amending the annexes of Regulation (EC) No 1223/2009 is normally written; Regulation (EU) 2023/1545 is the current worked example. The prohibitions of HICC and of Butylphenyl methylpropional are amendments to Annex II of that Regulation. This page is written for people who make fragrances and it is not legal advice; whether a reformulated product is safe to sell is a question for a qualified safety assessor.
Common questions
A material in my formula has been restricted. What do I do first?
Work out which of three things happened, because two of them often need no change at all. A lower limit is arithmetic: you may already be under it, and the limit is per category and per finished product rather than per concentrate. A specification is about the bottle rather than the dose, so a compliant grade may exist and your formula may be fine. Only a prohibition forces reformulation, and even then check whether a trace arriving inside a natural is separately allowed.
How long do I have to reformulate?
It depends whether the change came from the industry Standards or from law. An industry amendment gives an earlier deadline for newly briefed fragrances and a later one for anything already on the market or in development, which is your grace period. A regulation gives a date after which non-compliant product may no longer be placed on the market, and a later date after which it may no longer be sold to the end customer; the second is a sell-through allowance for stock already in the chain, not an extension for new production.
How do I find a substitute?
Start from what the material was doing rather than what it smelled like. Which facet were you using, was it carrying the drydown or the opening, and is what you need one material or an accord of two or three. Often no single material replaces it and the section has to be rebuilt. Check the substitute against the same rules before committing to it, and check what it does to your allergen declaration: something that clears every limit can still push an entry over a labeling threshold.
Do I have to tell customers I reformulated?
Decide honestly whether it is the same fragrance or a new one, and both answers are legitimate. What is not legitimate is quietly shipping a materially different product under the same name to the people who bought the first one. A reformulation note costs very little; a silent change that customers discover costs you them.