Draft Proposal on the Mandatory Labeling of Specific Fragrance or Flavor Ingredients in Cosmetics in Taiwan

On January 21, 2025, the Taiwan Food and Drug Administration (TFDA) under the Ministry of Health and Welfare proposed two draft regulations: “Labeling Requirements for Outer Packaging, Containers, Labels, or Package Inserts of Cosmetics” and “Specific Fragrance or Flavor Ingredients Required to Be Labeled in Cosmetics.” These drafts have been released for a 60-day public consultation period to collect feedback from various stakeholders.

Taiwan,Cosmetic,Fragrance,Flavor,Ingredient,Labeling

According to the draft regulation, 24 specific fragrance or flavor ingredients must be explicitly listed on the product label if they are present in a cosmetic product at concentrations exceeding the specified limits. These ingredients cannot be generically labeled as "Fragrance," "Flavor," "Parfum," "Perfume," or "Aroma." Instead, their specific names must be disclosed.

Draft Amendment to the Labeling Requirements for Outer Packaging, Containers, Labels, or Package Inserts of Cosmetics

On January 21, 2025, TFDA announced a proposed amendment to Article 7 of the Labeling Requirements for Outer Packaging, Containers, Labels, or Package Inserts of Cosmetics, in accordance with Paragraph 4, Article 7 of the Cosmetic Hygiene and Safety Act. The draft regulation is expected to take effect one year after its official promulgation. Cosmetics that have been manufactured or imported before the effective date may continue to be sold with their original labeling until the end of their shelf life.

Comparison between the Draft and Current Provisions

Amended Provisions	Current Provisions	Explanation of Amendments
The labeling of fragrances and flavors may use the terms “香精” , “香料”, “Flavor,” “Fragrance,” “Parfum,” “Perfume,” or “Aroma.” However, if specific fragrance or flavor ingredients are subject to separate regulatory requirements, they must be labeled in accordance with the relevant regulations	The labeling of fragrances and flavors may use the terms “香精”, “香料” , “Flavor,” “Fragrance,” “Parfum,” “Perfume,” or “Aroma.”	If specific fragrance or flavor ingredients need to be labeled, they should be handled in accordance with the relevant cosmetic labeling regulations regarding those specific ingredients.

Draft List of Specific Fragrance or Flavor Ingredients Required for Labeling in Cosmetics

On January 21, 2025, TFDA announced a draft regulation based on Article 7, Paragraph 1 of the Cosmetic Hygiene and Safety Management Act. This draft specifies 24 fragrance or flavor ingredients that must be labeled on cosmetic products. The draft regulation is expected to take effect one year after its official announcement. Cosmetics that have been manufactured or imported before the effective date may continue to be sold with their original labeling until the end of their shelf life.

Draft Regulation and Explanation

Draft Regulation

Explanation

This regulation is formulated in accordance with Article 7, Paragraph 1, Item 10 of the Cosmetic Hygiene and Safety Management Act.

Basis for the Formulation of This Regulation.

If a cosmetic product contains any of the specific fragrance or flavor ingredients listed in the annex and exceeds the following concentration thresholds, the exact ingredient name must be labeled. Generic terms such as Flavor, Fragrance, Parfum, Perfume, Aroma, or their equivalents cannot be used as substitutes.

Rinse-off Products: The specific ingredient name must be labeled if the concentration exceeds 0.01%.

Leave-on Products: The specific ingredient name must be labeled if the concentration exceeds 0.001%.

Requirement for Labeling Specific Fragrance or Flavor Ingredients in Cosmetics.

Specific Fragrance or Flavor Ingredients

No.	INCI Name	CAS No.
1	Amyl Cinnamal	122-40-7
2	Benzyl Alcohol	100-51-6
3	Cinnamyl Alcohol	104-54-1
4	Citral	5392-40-5
	2,6-Octadienal,3,7-dimethyl-,(E)-	141-27-5
	2,6-Octadienal,3,7-dimethyl-,(Z)-	106-26-3
5	Eugenol	97-53-0
6	Hydroxycitronellal	107-75-5
7	Isoeugenol	97-54-1
		5932-68-3
		5912-86-7
8	Amylcinnamyl Alcohol	101-85-9
9	Benzyl Salicylate	118-58-1
10	Cinnamal	104-55-2
11	Coumarin	91-64-5
12	Geraniol	106-24-1
13	Anise Alcohol	105-13-5
14	Benzyl Cinnamate	103-41-3
15	Farnesol	4602-84-0
16	Linalool	78-70-6
17	Benzyl Benzoate	120-51-4
18	Citronellol	106-22-9
		1117-61-9
		7540-51-4
19	Hexyl Cinnamal	101-86-0
20	Limonene	5989-27-5
		138-86-3/7705-14-8
		5989-54-8
21	Methyl 2-Octynoate	111-12-6
22	Alpha-Isomethyl Ionone	127-51-5
23	Evernia Prunastri (Oakmoss) Extract	90028-68-5
24	Evernia Furfuracea (Treemoss) Extract	90028-67-4

If you need any assistance or have any questions, please get in touch with us via cosmetic@cirs-group.com.

Our Compliance Services in Taiwan

Taiwan Cosmetic Product Registration;
Taiwan Cosmetic Product Information File (PIF) Compilation;
Taiwan Cosmetic Labeling Review;
Safety Assessment Report Preparation; and
Taiwan Cosmetic Compliance Testing.

Further Information

https://www.fda.gov.tw/tc/includes/GetFile.ashx?id=f638729861144442115

https://www.fda.gov.tw/TC/newsContent.aspx?cid=5072&id=30920

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