How Indian Fragrance & Perfume Oil Manufacturers Can Prepare SDS for EU Exports in 2026

Indian fragrance and perfume oil manufacturers are increasingly targeting the lucrative EU market, where demand for high-quality scents remains strong. However, exporting to the EU comes with strict chemical safety rules, especially around Safety Data Sheets (SDS), also still referred to as MSDS in some older contexts.

Many manufacturers search for queries like:

• "SDS for fragrance oils EU export"
• "MSDS perfume oil for Europe"
• "Safety data sheet for perfume export to EU"
• "REACH SDS requirements fragrance India"
• "CLP SDS perfume mixture"

These searches highlight a real pain point: EU importers (your buyers) must comply with REACH and CLP regulations, and they expect non-EU suppliers like you to provide accurate, up-to-date SDS for the fragrance oils/mixtures you ship. Without proper SDS, shipments face delays, rejections, or additional costs at customs.

This guide explains exactly what EU SDS obligations look like for fragrance and perfume oils exported from India in 2026, why the final product SDS matters, and practical steps to get it right—without unnecessary complexity.

1. Who Needs to Provide the SDS? (The Short Answer)

Under EU law:

• REACH & CLP obligations fall primarily on the EU importer (your buyer), not the non-EU manufacturer/exporter.
• However, you (the Indian supplier) must supply a compliant SDS to your EU customer at the first delivery if the fragrance oil or perfume mixture is classified as hazardous (which most are due to sensitization, flammability, or environmental hazards).
• The SDS helps the importer fulfil their duties: classify/label the mixture, submit Poison Centre Notification (PCN) with UFI if required, and communicate hazards downstream.

In short: No proper SDS from you → your buyer cannot easily place the product on the EU market → they stop ordering or demand fixes.

2. When Is an SDS Mandatory for Fragrance & Perfume Oils?

You must provide an SDS with CLP hazard classification criteria, including:

• Skin Sensitisation Cat. 1 (very common for fragrance allergens)
• Eye Irritation / Serious Eye Damage
• Flammable Liquid (many perfumes contain ethanol or high-flashpoint carriers)
• Aquatic Chronic / Acute toxicity
• Aspiration hazard

2026 reality check: Almost all concentrated perfume oils and fragrance compounds trigger at least one of these, especially with the expanded list of ~80 mandatory fragrance allergens under Regulation (EU) 2023/1545 (full labelling transition by July 2026).

Even if the final diluted perfume is below classification thresholds, the concentrated oil you export usually still needs an SDS.

3. Key Differences: Fragrance Oil SDS vs Final Perfume SDS

A frequent mistake: sending only the fragrance oil SDS and assuming that's enough.

EU importers need SDS information for the specific mixture they create (e.g., 10–20% fragrance in alcohol/carrier). Your SDS should provide enough detail so they can derive their own classification.

What to include in your SDS (REACH Annex II format, aligned with GHS):

• Section 1: Identification – full product name, recommended use ("fragrance compound for fine perfumery / cosmetics"), supplier details (your Indian address + emergency contact)
• Section 2: Hazards – GHS pictograms (exclamation mark for sensitization, flame for flammability), signal word ("Warning" or "Danger"), hazard statements (H317: May cause allergic skin reaction; H226: Flammable liquid…)
• Section 3: Composition – list hazardous ingredients ≥0.1% (for sensitizers) or ≥1% (others), with concentration ranges if trade secret; include CAS/EC numbers
• Section 9: Physical properties – flash point, boiling point, appearance (clear liquid, pale yellow, etc.)
• Section 11: Toxicological – skin sensitization data, reference to IFRA standards if applicable
• Section 14: Transport – usually UN 1266 "Perfumery products" or "Not regulated" depending on flash point
• Section 16: Revision date and changes (critical in 2026 with allergen list expansion)

Tip for Indian exporters: Provide the SDS in English (mandatory) + optionally in the buyer's language. Many EU importers appreciate allergen breakdown tables as an annex.

4. PCN / UFI – How Does It Relate to Your SDS?

From 2025–2026, hazardous mixtures (including many perfumes) require:

• PCN submission to ECHA Poison Centres via the EU portal before placing on the market
• UFI (16-digit Unique Formula Identifier) printed on the label

Your role: Your SDS (especially Section 3 composition ranges) gives the EU importer the data needed to generate their UFI and submit PCN. If composition is too vague, they cannot comply → they may reject your supply.

Many Indian suppliers now include a UFI-ready allergen & composition annex to make life easier for buyers.

5. Step-by-Step: How to Create an EU-Compliant SDS for Your Fragrance Oils (2026)

1. Gather data
   • Full formulation (CAS/EC numbers, % ranges)
   • Supplier SDS for raw materials
   • Phys-chem tests (flash point, density) – use NABL-accredited labs in India
   • Toxicological info (RIFM data, IFRA compliance certificate)
2. Classify the mixture
   • Use CLP criteria (skin sens 1 if any allergen ≥0.01–0.1% depending on potency)
3. Draft the SDS
   • Follow REACH Annex II (16 sections)
   • Use EU-harmonised phrases from ECHA library
   • Include 2026 allergen updates (new 56+ substances)
4. Verify & update
   • Have a qualified person (chemist / regulatory expert) review
   • Revise whenever formulation or regs change (e.g., post-July 2026 allergen labelling)
5. Deliver to buyer
   • Send at first shipment + whenever updated
   • Format: PDF with digital signature if possible

6. Quick Checklist for EU Export Readiness (Fragrance / Perfume Oils)

• SDS in English, Annex II compliant, EU buyer may ask for secondary languages
• Accurate Section 3 (ingredients & ranges)
• GHS/CLP classification & labelling elements
• Flash point & transport info
• Allergen declaration table (for buyer’s final labelling)
• IFRA Certificate attached (many EU buyers require it)
• PCN/UFI support data ready for importer

Wrapping Up

EU buyers increasingly expect Indian fragrance suppliers to provide detailed, accurate SDS right from the start, it's no longer optional if you want repeat orders. Getting this right builds long-term trust and reduces rejection risks at EU entry points.

If you're an Indian fragrance or perfume oil manufacturer preparing SDS for EU exports and want practical help aligning your documentation, our team at Japag Regulatory Solutions specializes in authoring EU Compliant Safety Data Sheet (SDS/MSDS) supporting manufacturers just like you, accurately and efficiently.

Need help navigating SDS creation for EU markets?Visit our website or schedule a quick consultation to see how we can support you.