Verification of Compliance

The verification of compliance process is based on the analysis of a range of finished product samples to detect the presence of fragrance ingredients regulated by IFRA. It is a two-fold process:

• Detection of prohibited ingredients (ingredients that cannot be used in fragrance compounds) in consumer products, using validated analytical methods
• Detection of restricted ingredients (ingredients that have maximum level-of-use restrictions) in consumer products that do not comply with the restrictions established by IFRA.

The program first concentrates on prohibited ingredients (Phase 1) and at a latter stage will be extended to restricted ingredients (Phase 2).

The collection and evaluation of consumer products and the reporting of non-complying products follows a predefined procedure and a set of agreed-upon protocols.

Outline of the Verification Process

1. Selection of Consumer Products

The selection of the consumer products to be analysed follows a specific protocol. Products are selected at random in various countries and/or regions around the world that are members of IFRA:

• 15 in one segment of the fine fragrance category (e.g. Eau de Toilette, Perfume)
• 15 in one segment of the cosmetics and toiletries category (e.g. shampoo, deodorant)
• 20 in one segment of the household and detergents category (e.g. air freshener, fabric conditioner, washing powder).

Each year, IFRA selects the segment in each category on a rotating basis.
Ten countries where IFRA is linked to Fragrance Associations (through direct membership or through a regional association of IFRA) are selected every year by a random computer program operated by a supporting external laboratory which also operates as a third party administrator (TPA).
In each country, the top leading 15 products for each segment are identified based on their ranking of the preceding year.
After elimination of the products common to several country rankings and likely to contain identical fragrances, 15, 15 and 20 products according to the breakdown already described are selected at random by a computer program also operated by the third party administrator.
These products are sampled from each related market and channeled to the external laboratory in charge of the analysis of the products. 

2. Analysis of Consumer Products

The product analysis is defined in specific procedures and is coordinated by the third party administrator in order to eliminate any conflict of interest.
The third party administrator is well accredited and scientifically recognised and follows internal procedures to ensure confidentiality and impartiality in each step of the program.

3. Reporting of Results

The TPA shall handle the results of the analyses according to strict confidentiality procedures and shall only report to the IFRA Director General those results which suggest non-compliance and would require further verification action.

4. Actions to be taken when non-compliant products are identified

When the analysis reveals that a consumer product contains fragrance ingredients that are either prohibited by IFRA (phase 1) or used at a higher level than the IFRA restriction (once phase 2 is launched), the IFRA Director General or the IFRA staff person designated by him shall take actions in order to identify the fragrance supplier that provided the fragrance compound used in the finished product in question to the consumer products manufacturer.

Contacts with consumer product manufacturers

The liaison (if determined) of the consumer product manufacturer whose product is concerned shall be notified by IFRA that its product appears to contain a fragrance that is non-compliant. In the absence of a designated liaison, the Director General shall make his best efforts to identify the appropriate person within the company to be provided with the information.

Contacts with fragrance manufacturer/suppliers

1. The manufacturer/supplier is an IFRA Member:

• The potential non-compliant fragrance supplier shall be contacted through the designated liaison (if available) regarding the findings.
  If in case of confirmed non-compliance the supplier agrees to correct the situation, and there are no repeated violations, no further action shall be contemplated. Corrective actions shall be verified through the collection and analysis of additional sample products.
• If the supplier does not take corrective action, the name of that supplier shall be listed on the IFRA website as not complying with the IFRA Code of Practice (List of Non-Complying Companies) and the national association to which that supplier belongs shall be asked to take appropriate steps regarding membership.
  

2. The manufacturer/supplier is NOT an IFRA Member:

In case of verified non-compliance of the fragrance compounds, the offending supplier that is not an IFRA member shall be contacted by the Director General to discuss the results of the analyses and to be encouraged to join the appropriate national or regional Fragrance Association. Such discussions shall be kept strictly confidential.