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Dual-standard compliance: why checking IFRA and NZ CPG isn't the same check twice

IFRA and NZ CPG both restrict fragrance ingredients — but the rules don't align. The same ingredient can pass one standard and fail the other. Here's how to think about it.

Most brands selling cosmetics into New Zealand treat fragrance compliance as two sequential checkboxes: check IFRA, then check NZ CPG. The assumption is that they’re parallel requirements covering similar ground — two authorities looking at the same things from slightly different angles.

That assumption produces errors.

What IFRA actually regulates

IFRA (International Fragrance Association) restricts specific fragrance materials based on safety concerns: sensitisation potential, phototoxicity, systemic toxicity, and other endpoints. The restrictions are concentration-based and product-category-specific.

Amendment 51 — the current reference as of June 2024 — covers 214 fragrance materials across 12 product categories. The categories group products by how they’re used and how much skin contact they involve: leave-on face products, rinse-off body products, fine fragrance, oral-care products, and so on. A fragrance material restricted to 0.3% in a Category 5 body lotion may have a different limit in a Category 9 rinse-off product. Sometimes higher. Sometimes lower. The product category governs the threshold.

Determining which IFRA category a product falls into is itself a judgment call. IFRA categories don’t map cleanly onto product marketing descriptions. “Body lotion” is clear enough — but a “facial mist” or a “leave-on hair treatment” requires a considered reading of IFRA’s category definitions before you know which concentration limits apply.

What NZ CPG actually regulates

NZ CPG (Cosmetic Products Group Standard) covers a broader scope than IFRA. It includes:

  • Schedule 4 — 2,166 prohibited substances (outright bans)
  • Schedules 5–8 — 23,334+ restriction rules, including concentration limits that vary by product type
  • Schedules governing approved colorants, preservatives, and UV filters

Some IFRA-restricted fragrance materials also appear in NZ CPG schedules. But CPG also covers a large number of non-fragrance ingredients that are entirely outside IFRA’s scope: preservatives, colorants, heavy metals, UV absorbers. IFRA compliance tells you nothing about those.

Where the same substance appears in both standards, the permitted concentrations don’t necessarily align. CPG’s permitted level for a substance might be higher than IFRA’s limit, lower, or structured differently (for example, as a limit on the finished product versus a limit on the fragrance component). The two frameworks were developed independently. They were not designed to interoperate.

The interaction problem

Here’s where sequential checking breaks down.

Consider a fragrance compound used at 2% in a leave-on body lotion. You run the IFRA check first. The compound passes — its constituent materials are all within IFRA Category 5 limits at that use level. You note it as compliant and move to the CPG check.

The CPG check looks at the finished formulation’s ingredient list, not just the fragrance compound. One constituent of the fragrance — a substance that wasn’t flagged by IFRA because its IFRA limit is higher — turns out to have a CPG Schedule 5 restriction that’s more stringent. At 2% fragrance, the constituent’s contribution to the final product concentration exceeds the CPG limit.

Or the inverse: a substance passes CPG’s permitted concentration for a given product type, but IFRA’s more restrictive limit for the specific product category — which you’ve now determined is Category 4 (near-eye products) rather than Category 5 — is lower. The CPG check gave you a pass, but the correct IFRA category gives you a fail.

These aren’t edge cases. They’re the normal complexity of fragrance compliance across two independent regulatory frameworks with overlapping but non-identical scope.

What this means for manual processes

Teams running sequential manual checks introduce errors at the boundaries between the two standards. The most common failure modes:

  • Wrong IFRA category applied. The check runs against the wrong set of thresholds because the product was assigned to the wrong category, or the category definition was read loosely.
  • CPG Schedule 5 limit missed. The IFRA check returned a pass, so the CPG check receives less scrutiny. A restriction in Schedules 5–8 that applies specifically to the product type gets overlooked.
  • Concentration interactions not tracked. A fragrance compound is checked as a unit rather than its constituent substances being evaluated individually against CPG schedules, missing restrictions that apply at the ingredient level.

The only reliable approach is simultaneous dual-standard evaluation: both frameworks checked together, against the same formulation concentrations, for the specific product category and type.

What this means for tooling

This is exactly the complexity that software should handle. Not the judgment about what constitutes an acceptable risk — that’s still a question for qualified regulatory professionals. But the systematic cross-referencing: which substances are in this formulation, at what concentrations, against which CPG schedules, against which IFRA category thresholds, with no gap between the two checks.

Handling that systematically, without the category-assignment errors and boundary gaps that manual sequential checking introduces, is what we’ve built into ComplianceFlow’s screening engine.