Safety · 3
The "2027 ban list" isn't settled yet, and checking it takes three moves
· 26 min read
An 88-reply thread was worrying about a 2027 ban list of ten materials. Those ten touch 35.0% of our 954-formula corpus, but the list conflates two different things: an EU cosmetics ban already in force, and IFRA proposals still in consultation. IFRA's own page dates that consultation 12 December 2025 to 12 June 2026. A second thread found Iso E Super is restricted after all, and that searching the trade name on IFRA's site returns nothing.
Ten months ago someone posted one line to r/DIYfragrance: how is everyone feeling about the 2027 ban list. Underneath came heliotropin, cyclamen aldehyde, acetophenone, cuminaldehyde and Lilial, with an edit adding bourgeonal, Cyclemax, para-cymene, tea tree oil and 4-tert-butyl toluene. Eighty-eight replies.
A shorter thread, 18 replies: the poster had just learned that Iso E Super is IFRA-restricted. Every video he had seen said it wasn't, and typing "Iso E Super" into IFRA's site returned nothing. The CAS number found it.
A third thread was blunter: the rules keep changing, so they cannot be telling you anything real about safety.
All three are the same problem. This information circulates in the community and almost nobody goes back to the source document. I went back.
The short version
- Those ten materials touch 35.0% of the formulas in our 954-formula corpus. That part is worth being nervous about. Open up that 35.0% and a third of the formulas cannot be made today.
- The list conflates two different mechanisms. Lilial is an EU cosmetics ban already in force since 1 March 2022. The rest are IFRA proposals still moving through a process.
- IFRA's own page gives the dates: the 52nd Amendment consultation opened 12 December 2025 and closed 12 June 2026. "2027" is a date derived from a timetable, not a published one.
- The Iso E Super story is the more useful one. It is restricted, and there is a findable reason the trade name returns nothing.
About a 10 minute read.
What the list actually touches
Measure before panicking.
| Material on the list | Formulas | Share of 954 |
|---|---|---|
| Lilial | 154 | 16.1% |
| Heliotropin | 144 | 15.1% |
| Cyclamen aldehyde | 64 | 6.7% |
| Acetophenone (incl. para-methyl) | 21 | 2.2% |
| Cuminaldehyde | 11 | 1.2% |
| Bourgeonal | 11 | 1.2% |
| Para-cymene | 9 | 0.9% |
| Cyclemax | 4 | 0.4% |
| Tea tree oil | 0 | 0.0% |
| 4-tert-butyl toluene | 0 | 0.0% |
334 formulas contain at least one of them: 35.0%. Those that do average 1.25 hits, median 1, maximum 3.
The impact concentrates at the top. Lilial and heliotropin together account for 28.2%, and the remaining eight add under seven percentage points between them. Tea tree oil and 4-tert-butyl toluene never appear in this corpus at all.
The list mixes two mechanisms
Lilial does not belong on the same list as the others, because a different machine governs it.
Lilial (butylphenyl methylpropional) is law. Regulation (EU) 2021/1902 placed it in Annex II of the Cosmetics Regulation as entry 1666 on a CMR category 1B classification, applicable from 1 March 2022. Breaching that with a cosmetic on the EU market is illegal. It has been in force for over four years. It is not a 2027 matter.
The others move through IFRA Standards. IFRA is an industry self-regulatory body. Its Standards bind its members and the signatory supply chain, and they are not themselves law. The rhythm is: publish a draft for consultation, collect comment, issue formal notification, then run a compliance window.
IFRA's own page is explicit: the public consultation on the 52nd Amendment opened on 12 December 2025 and remained open until 12 June 2026. The page carries a publication date of 29 January 2026.
Where "2027" comes from is reconstructable. IFRA's rule is that prohibition Standards enter into force two months after notification for new creations and thirteen months for existing ones. Put notification at the end of 2026 and the deadline for existing creations lands at the end of 2027. That is a derived date, not a published one. Industry reporting puts formal notification around late November 2026; I could not confirm that on an IFRA page, so treat it as indicative.
One more detail worth holding onto: several materials have derogation dossiers under evaluation, tea tree oil and heliotropin among them. A name on the list is not a verdict.
"Restricted" means nothing without a category
Back to Iso E Super. The poster said it is "restricted to 20%". True, and that is the loosest of sixteen numbers on the page.
I pulled the Standard. Here are its maximum acceptable concentrations in the finished product across all twelve categories:
| Category | Limit | Category | Limit |
|---|---|---|---|
| 1 | 0.41% | 7A | 0.67% |
| 2 | 1.1% | 7B | 0.67% |
| 3 | 0.41% | 8 | 0.19% |
| 4 (fine fragrance) | 20% | 9 | 2.4% |
| 5A | 5.1% | 10A | 2.4% |
| 5B | 0.56% | 10B | 6.6% |
| 5C | 0.76% | 11A | 0.19% |
| 5D | 0.19% | 11B | 0.19% |
| 6 (oral care) | 0.0093% | 12 | No restriction |
Category 4 is fine fragrance, capped at 20%. Category 6 is things that go in your mouth, capped at 0.0093%. A factor of 2,150 between them. Category 12 carries no restriction at all.
Which makes "this material is restricted to X%" a broken sentence. It drops the one field that decides the answer. Knowing which product category you are building comes first; the number means something only after that.
The Standard also records two fields people skip. The driving risk is dermal sensitisation and systemic toxicity, and the implementation dates were 10 February 2021 for new creations and 10 February 2022 for existing ones.
Why the trade name finds nothing
This is the most useful thing in that thread, and the reason is checkable.
The Standard is not titled Iso E Super. It is titled 1-(1,2,3,4,5,6,7,8 Octahydro-2,3,8,8-tetramethyl-2-naphthalenyl) ethanone (OTNE), and it covers four CAS numbers — 54464-57-2, 54464-59-4, 68155-66-8, 68155-67-9 — with the document stating that its scope is not limited to those.
"Iso-E Super" appears in the synonym list, tagged as a commercial name, sitting alongside Ambergris Ketone, Amberonne, Boisvelone, Isocyclemone E and Orbitone. And in the document it carries a hyphen. Searching "Iso E Super" failing while the CAS works is exactly consistent with that.
Material names mislead covered this problem, and the frequency article walked into the same mine when hedione and methyl dihydrojasmonate counted as two materials. Looking up regulation is where that mistake gets expensive.
Do the bans do anything
The "rules keep changing so they mean nothing" thread asked a question that can actually be measured.
One material offers a natural test. Lyral (HICC, hydroxyisohexyl 3-cyclohexene carboxaldehyde) was banned from cosmetics in the EU in 2021.
Hernández Fernández and colleagues, writing in Actas Dermo-Sifiliográficas in 2025, analysed every consecutive patient in the Spanish Contact Dermatitis Registry (REIDAC) patch tested with both HICC and fragrance mix II between 1 June 2018 and 31 December 2023.
Of 12,029 patients, 96 (0.8%) were positive to HICC and 396 (3.3%) to fragrance mix II. The authors conclude that HICC sensitisation prevalence in Spain is low and has decreased in recent years, and that 72 of the 96 HICC positives (75%) would be caught by fragrance mix II alone. They recommend dropping HICC from the baseline series.
The study window straddles the ban, so the decline lines up with it in time. The design cannot establish causation on its own, and the authors do not claim it does. The safe reading is more modest: these restrictions are not arbitrary paperwork, and what got restricted subsequently shows up less in clinical data.
The numbers behind them are not improvised either. IFRA Standards rest on RIFM safety assessments, and RIFM's 2026 criteria update states that the process covers more than 3,000 fragrance materials through a stepwise, endpoint-specific approach including thresholds of toxicological concern and quantitative risk assessment for dermal sensitisation. Agreeing with it is a separate question from whether it has a method.
Three moves
To check whether a material is still usable, do these three things.
One: search by CAS, never by name. A trade name may be hyphenated in the document, filed as a synonym, or covered by a Standard spanning four CAS numbers. A name that returns nothing is not evidence that no Standard exists.
Two: read the category before the number. Limits across the twelve categories span three orders of magnitude. Establish which category your finished product falls into, then read that cell. Check the implementation dates while you are there — new creations and existing creations are usually twelve months apart.
Three: know which body governs. IFRA Standards and local law are two separate systems, and a material may be caught by only one of them. Selling in the EU means Annex II of the Cosmetics Regulation; other markets mean their own rules. Forum lists routinely blur the two, and this one did.
We have a correction to make too
Heliotropin is on that proposal list, and we wrote about it without mentioning that it is under evaluation.
Nothing in that article is wrong, but a field is missing. Once the 52nd Amendment notification lands and heliotropin is either prohibited, restricted or granted a derogation, that article needs a paragraph. Saying so here in the meantime keeps a reader from assuming our material guides are a snapshot of regulatory status. They are not. They describe smell and physical properties, and the regulatory cell always has to be checked against the current version yourself.
What this doesn't establish
I confirmed the consultation window, not the final list. IFRA's page gives dates. I did not obtain the consultation draft itself, which sits in a permissioned shared space, and I found no published final 52nd Amendment Standards on an official page. So I cannot confirm whether those ten names are complete or accurate.
The effective dates are reconstructed. The two-month and thirteen-month rule is IFRA's general practice, combined with a secondary report of when notification is expected. The real dates arrive with the notification.
The 35.0% describes public demo formulas, not what is on shelves. That corpus is 74% patent or sourced examples with an unknown time span. It shows how common these materials are in formula writing, and cannot be pushed onto today's finished products.
The HICC figures are Spanish. Sensitisation prevalence varies widely by region, so 0.8% does not transfer to another market unchanged.
References
C. P. Hernández Fernández et al., Should Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde (Lyral®) Still be Part of the Baseline Series?, Actas Dermo-Sifiliográficas, 116(10), T1084–T1092 (2025). PMID 41076186. doi:10.1016/j.ad.2025.10.016
A. M. Api et al., Updates to the RIFM Criteria Document for fragrance ingredient evaluation, Food and Chemical Toxicology, 217, 116329 (2026). PMID 42567301. doi:10.1016/j.fct.2026.116329
IFRA Standard, 1-(1,2,3,4,5,6,7,8 Octahydro-2,3,8,8-tetramethyl-2-naphthalenyl) ethanone (OTNE), 49th Amendment (2020), standard number 068. Checked 2026-08-27.
IFRA, IFRA Standards – 52nd Amendment Consultation, news page published 2026-01-29. Checked 2026-08-27.
Regulation (EU) 2021/1902, amending Annex II to Regulation (EC) No 1223/2009; butylphenyl methylpropional listed as entry 1666, applicable from 1 March 2022.
Related: Material names mislead, Look up how many formulas it appears in, How to read fragrance safety studies.