Fragrance Archives - Focal Point

CARB launches 2025 Technical Assessment for Personal Fragrance Products VOC Compliance

Srishti Chaudhari — Mon, 13 Apr 2026 19:29:50 +0000

California Air Resources Board is conducting its 2025 Personal Fragrance Products Technical Assessment to evaluate the feasibility of meeting the 50% VOC limit using current and emerging technologies. All required data submissions must be provided by March 31, 2026, using CARB’s designated reporting tools for responsible parties and formulators. The assessment follows regulatory definitions of ‘fragrance’ under the Consumer Products Regulation and will support a confidential, data-driven review of industry capabilities and compliance pathways.

For more information, reach out to us.

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CARB Launches 2025 Personal Fragrance Technical Assessment

Srishti Chaudhari — Fri, 13 Feb 2026 21:24:37 +0000

If you manufacture or sold personal fragrance products with 10 percent or less fragrance in 2025 products in the California market, it is time to prepare for the latest technical assessment from the California Air Resource Borad (CARB).

CARB is currently evaluating whether it is feasible for the industry to meet the upcoming 50% Volatile Organic Compound (VOC) standard using current or emerging technologies. As part of this evaluation, new reporting requirements are now in effect.

Deadline: All data for the 2025 Personal Fragrance Products Technical Assessment must be submitted to CARB by March 31, 2026.

What is Required:

Responsible Parties need to complete two main tasks:

Submit the Data: You must use the interactive Personal Fragrance Products Reporting Tool (PFP-RT). This is a macro-enabled Excel workbook (available for both Windows and Mac) where you will list products, ingredients, and responsible parties.

Submit a Written Report: In addition to the raw data, you are required to submit a written update regarding your R&D efforts. This report should detail the work being done to meet the future 50% VOC standard.

Streamlined Process for Formulators:

To make reporting easier, CARB has changed how they handle trade secrets and third-party formulators. You do not need to contact your formulators for their data. Instead, once you submit your report (PFP-RT) listing your Product Formulators, CARB staff will contact them directly. CARB will send them a separate tool (PFP-RTF) to collect the necessary formulation data, ensuring confidentiality is maintained without you having to act as the middlemen.

This assessment is a critical step toward the January 1, 2031, regulations. By that date, non-aerosol fragrance products (with 10% or less fragrance) and aerosol products will be required to meet the strict 50% VOC limit. This assessment is CARB’s way of checking the industry’s pulse to see if the goal is achievable.

Next Steps: Download the reporting tools and review the definition of ‘Fragrance’ to ensure you are reporting the correct ingredients. If you require assistance in understanding the regulations, please contact us.

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Changes to the Canadian Cosmetic Notification (CNF) form requirements as of October 9, 2024

Nathan John — Thu, 17 Oct 2024 14:33:41 +0000

There are number of changes that are in effect as of October 09, 2024 for the Cosmetic Notification (CNF) form requirements

Changes to the CNF came info force on October 09, 2024. The new CNF has been released by Health Canada.
Changes include having to identify whether the cosmetic is a leave-in or rinse-off product, use of different concentration ranges compared to those used previously, the need for label contact details to be listed, requiring a Canadian entity / Responsible Canadian Party / Canadian Agent to be listed, removal of the need to include distributor information.
At this time, Health Canada has informed stakeholders that the requirement to list a Canadian entity / Responsible Canadian Party / Canadian Agent will not be mandatory on the CNF until early 2025 (exact date to be confirmed) as this has a significant impact to a lot of companies. The Canadian entity / Responsible Canadian Party / Canadian Agent will be the primary contact that Health Canada will reach out to, should they require any action in relation to a notified product.
- There are ongoing discussions with Health Canada to clarify the responsibilities that this Canadian entity / Responsible Canadian Party / Canadian Agent is to have
- It is believed that the Canadian entity / Responsible Canadian Party / Canadian Agent will function as a contact between the brand owner and Health Canada, however, at this time, the regulations detail a lot more responsibility
- The Canadian entity / Responsible Canadian Party / Canadian Agent bears the same responsibility as a manufacturer
The above requirement for a Canadian entity / Responsible Canadian Party / Canadian Agent will not apply to any CNFs that have already been filed and will only impact new or amendment CNFs filed as of Oct. 09, 2024.

Additional Changes to the Cosmetic Regulations

Ingredient Disclosure Flexibility

For cosmetics sold in small packages, there will be more flexible options for ingredient disclosure. Alternatives such as attaching a tag, tape or card or providing information via a website are now permitted to ensure consumers are informed.

Strengthened Cosmetic Notification Requirements

There is now a requirement to notify Health Canada when a cosmetic is discontinued. The regulations have also been amended to allow Health Canada to halt the sale of a product if the notification requirements are not met or if requested information is not provided.

Removal of Distributor Information

Distributor information will no longer be required on the cosmetic notification. Given that Health Canada can follow up with the manufacturer, importer or Canadian entity / Responsible Canadian Party / Canadian Agent, as needed, regarding distribution of the product for compliance and enforcement purposes.

Identification of Product Type

Cosmetics must now specify whether they are rinse-off or leave-on products in their notifications.

Fragrance Allergen Disclosure

A new mandate will require the disclosure of fragrance allergens on cosmetic labels if they exceed a certain limit. The transition period for the implementation of the changes is three years (July 31, 2026) for new products placed on the market, and five years (July 31, 2028) for existing products to sell through.

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