How hard it really is to release a perfume in Europe

From the outside, releasing a perfume looks like a creative act: a bottle, a name, a story. From the inside, it is mostly paperwork — long, technical, signed paperwork — produced months before anyone smells anything. We are inside that paperwork right now, and we wanted to show you what it actually looks like.

This is not a complaint. The European framework is one of the most demanding in the world, and we think that is, on balance, a good thing. But it does mean that "launching a fragrance" is a very different exercise from what social media tends to suggest.

What people think it takes vs. what it actually takes

The popular version of a perfume launch is: a founder finds a perfumer, picks a juice, designs a bottle, opens a website. The real version, in Europe, sits on top of a stack of regulation that has to be in place before the bottle ever ships. Every one of the steps below is mandatory. None of them are optional for a brand of any size — there is no "small brand" exemption.

We will walk through each one in plain language, with the real term in brackets the first time it appears, so the rest of the internet is easier to read afterwards.

The umbrella: Regulation (EC) No 1223/2009

The single text that governs cosmetic products across the entire European Union is Regulation (EC) No 1223/2009 — the EU Cosmetic Products Regulation. Perfume is a cosmetic product under EU law, so this regulation applies to us in full.

1223/2009 does several things at once. It sets out who is legally accountable for a product on the market, what safety work has to be done before it is sold, what has to appear on the label, what has to be notified to authorities, and what records must be kept and for how long. Everything else in this post is, in practice, a consequence of this one text.

The Responsible Person, the PIF, and the Safety Assessor

Under Article 4 of 1223/2009, every cosmetic product placed on the EU market must have a Responsible Person (RP) — a legal entity established inside the European Union that is on the hook for the product's compliance. If something goes wrong, the RP is who the authorities call. For a brand based in the EU, the RP is typically the company itself. For brands established outside the EU, the RP must be appointed in writing and physically based in a Member State.

The RP has to keep a Product Information File (PIF) — Article 11 — a complete dossier on the product: the formula, the manufacturing method, the stability and microbiological testing, the proof for any claims, and the safety report. The PIF must be kept readily accessible to the authorities, in the language of the Member State or in a language the authorities understand, and it has to be retained for ten years after the last batch of the product was placed on the market. Not ten years after launch — ten years after the final batch leaves the shelf. That is a long memory.

Inside the PIF sits the Cosmetic Product Safety Report (CPSR) — Article 10 — a formal safety assessment of the finished product. The CPSR has to be signed by a Safety Assessor with specific qualifications recognised under the regulation (typically pharmacy, toxicology, or medicine). The Safety Assessor reviews the formula, the stability data, the toxicological profile of every ingredient, the intended use and exposure, the packaging, and the manufacturing conditions, and then puts their name to a conclusion. This is not a checkbox. A Safety Assessor's signature is a professional liability they carry personally.

Our first prototypes are with our perfumer now, and the next stop is exactly this: France, for the toxicology work and the CPSR. The regulation is what determines the order of operations — you cannot legally sell the bottle until this file exists.

IFRA, and why a perfumer's hands are not entirely free

On top of 1223/2009 sits a parallel layer for fragrance specifically: the IFRA Standards, published by the International Fragrance Association. IFRA Standards are the global, science-based rules that limit, restrict, or prohibit certain fragrance ingredients depending on how the finished product is used and which body areas it contacts. They are voluntary for non-members but compulsory for IFRA members — which, in practice, includes most of the fragrance houses a serious brand would work with. EU authorities and downstream brands treat them as the de facto safety baseline for fragrance compounds.

IFRA updates the Standards in numbered Amendments. The 51st Amendment was the most recent compliance milestone: notified on 30 June 2023, with a deadline of 30 October 2025 for existing creations to be brought into line (new creations had an earlier deadline of 30 March 2024). The 51st added new restrictions on a range of ingredients based on updated safety science.

The 52nd Amendment is currently in public consultation — open 12 December 2025 through 12 June 2026 — so the next round of restrictions is being shaped right now. For a brand designing a perfume in this window, you do not get to ignore that. You design knowing that the rules will move, and that anything close to a current limit may be tighter by the time you ship a second batch.

What this means in the studio: when our perfumer composes, they are not only chasing the right smell, they are working inside concentration limits per ingredient, per product category (skin contact, leave-on, fine fragrance), based on the current IFRA Standard. A note we love at 4% may only be permitted at 1.2% in fine fragrance on skin. Sometimes a candidate ingredient is simply not usable. That is the constraint the regulation creates for the craft — and, honestly, the constraint is part of what makes the work good.

Labelling, CPNP, and the shipping problem nobody talks about

Article 19 of 1223/2009 governs what must appear on the label. Every cosmetic sold in the EU must carry, indelibly and legibly: the name and address of the Responsible Person, the country of origin for imported products, nominal content, a date of minimum durability or a PAO ("Period After Opening") symbol — the small open-jar icon followed by a number of months — a batch code for traceability, the function of the product, any necessary warnings, and the full ingredient list using INCI (International Nomenclature of Cosmetic Ingredients) names in descending order of weight. Consumer-facing text — warnings, function, precautions — has to appear in the official language(s) of every Member State the product is sold in. Symbols like PAO and the metric content do not need to be translated, but the consumer-facing words do. (This intersects with another decision we have already written about — see why our site is English only — because product labelling and website language are governed by different rules.)

Before the product reaches a single customer, the Responsible Person must notify it via the Cosmetic Products Notification Portal (CPNP) — Article 13. CPNP is a single, central EU portal: notify once, and the information is available to competent authorities and to poison control centres in every Member State. No separate national filings inside the EU. The notification covers the product identity, the RP, the category, the formula in a form structured for poison-centre response, and the label artwork.

Then, separately, there is shipping. A finished perfume is a flammable liquid — typically UN 1266, Class 3 under the UN Recommendations on the Transport of Dangerous Goods and ADR (the European Agreement concerning the International Carriage of Dangerous Goods by Road). That classification is the reason perfume cannot simply be dropped in a standard parcel. There are however Limited Quantity (LQ) provisions — for UN 1266 in Packing Group III, the LQ threshold is 5 litres per inner packaging — that allow simpler packaging and a black-and-white diamond marking instead of the full hazard-class regime. LQ does not mean "no rules"; it means a calibrated, lower-friction set of rules for small consumer-sized units. Air freight is stricter than road, and certain carriers refuse fragrance entirely. Every one of these constraints lands on the e-commerce side of the operation, not the creative side.

Brexit: the UK is now a second filing

Until 2020, a single CPNP notification reached the UK as well. That is no longer the case. The UK now runs its own notification system, the Submit Cosmetic Product Notifications (SCPN) service, operated by the Office for Product Safety and Standards (OPSS) on gov.uk. The substantive rules largely mirror 1223/2009 (retained as part of UK law, enforced via the UK Cosmetic Products Enforcement Regulations 2013), but the administration is now separate: a separate notification, a separate UK-established Responsible Person, and separate labelling expectations for the GB market.

In other words: to sell in both blocs, you maintain two RPs, two notifications, and two compliance trails for what is, at the chemistry level, the same liquid in the same bottle. None of this is visible to the customer, and that is the point — it is supposed to be invisible.

Where we are right now

We are in the middle of this process, not at the end of it. The first prototypes are being finalised; the next batch is being prepared to send to France for the toxicology dossier and the CPSR; the Responsible Person, the PIF, the CPNP notification, and the labelling artwork are in parallel workstreams behind the scenes. Our perfumer is composing inside the current IFRA Standard while keeping one eye on what the 52nd Amendment consultation may move. We have a UK plan, but it is sequenced after the EU release, not alongside it.

We are writing this for two reasons. First, transparency — we would rather you know what is actually happening than perform a launch. Second, because the long quiet stretch between "we exist" and "you can buy a bottle" is not us being slow. It is what releasing a perfume in Europe responsibly looks like. The work is the work. We will keep showing it. (If you have not already, why our website is invitation-only explains the other half of why our pace looks the way it does.)

When the bottle is finally on the shelf, all of this paperwork will sit, signed and stored, in a file you will never see. That is, in a strange way, what we are most proud of.