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European Federation of Essential Oils

EFEO

The European Federation of Essential Oils represents the interests of producers and traders of plant-derived oils.

Lobbying Activity

Meeting with Christophe Clergeau (Member of the European Parliament, Rapporteur) and European Chemical Industry Council and

3 Dec 2025 · ENVI - ECHA

Essential oil federation demands independence for consumer safety committee

2 Dec 2025
Topic — Proposal to update the European Chemicals Agency's legal framework and governance structure.
Message — EFEO supports integrating the consumer safety committee if it retains its distinct identity and independence. They recommend that the committee’s mandate be broadened to include additional product categories. They also advocate for establishing an appeal system against agency opinions.123
Why — Independent oversight of safety assessments protects industry interests from potential conflicts within agency objectives.4
Impact — Agency leadership loses the ability to integrate committee procedures or appoint staff to lead evaluations.5
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Meeting with Pietro Fiocchi (Member of the European Parliament)

19 Nov 2025 · Omnibus VI

Essential oil federation demands reform of organic residue rules

17 Nov 2025
Topic — EU consultation on modifying organic trade rules and simplifying production standards.
Message — The federation requests a scientifically sound definition of 'presence' that aligns with existing pesticide limits. They propose using processing factors to account for the natural concentration of residues in essential oils. Additionally, they call for a reform of the reporting system to ensure data transparency.123
Why — A revised framework would reduce bureaucratic burdens and prevent costly storage fees during investigations.45
Impact — Farmers and value chain operators suffer when goods are blocked during lengthy investigations.67
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Response to Evaluation of the Cosmetic Products Regulation

20 Mar 2025

Introduction The European Federation of Essential Oils (EFEO) expresses its gratitude to the European Commission for the opportunity to contribute to the initial evaluation of the Cosmetic Products Regulation (EC) No. 1223/2009. General Comments EFEO reaffirms that the CPR has proven to be a relevant, efficient, and proportionate regulatory framework. It ensures consumer safety while facilitating the smooth functioning of the internal market. The regulation provides a high level of consumer protection through clear guidance and effective risk management measures. Animal Testing The ban on animal testing must be maintained. Additionally, the CPR should benefit from the forthcoming European Commission roadmap for the phasing out of animal testing to ensure alignment across chemicals legislation. Scientific Committee on Consumer Safety (SCCS) In accordance with Articles 15 and 31 of the CPR, EFEO requests that the structure, governance, and role of the SCCS (Scientific Committee on Consumer Safety) be preserved. Given the increasing complexity and volume of mandates, its capacity should be further strengthened while maintaining its excellence in independent expertise in human health risk assessment. Furthermore, the experience of SCCS members in the use of New Approach Methodologies (NAMs) is invaluable. Plant Extracts Plant extracts, classified as Natural Complex Substances (NCS), are primarily marketed as essential oils. Recent developments suggest the need to align the CPR with the derogation granted to plant extracts under Article 5 of the revised Classification, Labelling, and Packaging (CLP) Regulation. NCS should not be considered as mere mixtures of individual chemicals. Consequently, EFEO supports this interpretation for the application of Article 15.2 and requests a dedicated guidance document for NCS to prevent any future misinterpretations. Endocrine Disruptors Regarding substances with endocrine-disrupting properties (Article 15.4), EFEO recommends adherence to the provisions of Articles 15.1 to 15.3, maintaining alignment with Carcinogenic, Mutagenic, or Reprotoxic substances (CMRs), as is currently the case. Conclusion EFEO appreciates the European Commissions consideration of its feedback and remains available for further discussions and collaboration. About EFEO The European Federation of Essential Oils (EFEO) is dedicated to raising awareness among policymakers, regulators, and authorities regarding essential oils and their derivatives. EFEO advocates for a comprehensive understanding of their uses, cultural and economic significance, and the potential impact of legislative and regulatory measures on the sector. EFEO Transparency Register Entry : 180153441003-55
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Meeting with Sophie Alexandrova (Cabinet of Commissioner Ekaterina Zaharieva)

13 Mar 2025 · Essential oils

Meeting with Christophe Clergeau (Member of the European Parliament)

22 Nov 2024 · AGRI/ENVI

Meeting with Marina Mesure (Member of the European Parliament)

23 Oct 2024 · Demandes du secteur des huiles essentielles

Meeting with Valérie Hayer (Member of the European Parliament)

22 Oct 2024 · huiles essentielles

Meeting with David Cormand (Member of the European Parliament) and International Flavors & Fragrances

22 Oct 2024 · REACH

Meeting with Cristina Maestre (Member of the European Parliament)

22 Oct 2024 · Introductory meeting with European Federation of Essential Oils

Meeting with Andrey Novakov (Member of the European Parliament)

22 Oct 2024 · CLP Regulation / REACH Regulation

Meeting with Emil Radev (Member of the European Parliament)

22 Oct 2024 · Future REACH revision

Meeting with Niclas Herbst (Member of the European Parliament)

22 Oct 2024 · CLP-VO und Reach

Meeting with András Tivadar Kulja (Member of the European Parliament)

22 Oct 2024 · Introductory meeting

Meeting with François-Xavier Bellamy (Member of the European Parliament)

21 Oct 2024 · Chimie

Meeting with Christophe Clergeau (Member of the European Parliament)

6 Sept 2023 · Essential oils

Meeting with Jutta Paulus (Member of the European Parliament) and Union of the European Lubricants Industry and Downstream Users of Chemicals Co-ordination Group

3 May 2023 · CLP regulation

Meeting with Maria Arena (Member of the European Parliament)

25 Apr 2023 · CLP

Meeting with Cristina Maestre (Member of the European Parliament)

25 Apr 2023 · Sector Aceites Esenciales (APA level)

Meeting with Tilly Metz (Member of the European Parliament)

25 Apr 2023 · Plant Extracts

Meeting with Benoît Biteau (Member of the European Parliament)

25 Apr 2023 · Huiles essentielles & Pacte Vert

Meeting with Maria Arena (Member of the European Parliament)

19 Apr 2023 · CLP

Meeting with João Albuquerque (Member of the European Parliament, Shadow rapporteur)

18 Apr 2023 · CLP - Classification, labelling and packaging

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

13 Apr 2023 · Essential oils, CLP, chemical policies

Essential oil federation seeks adapted chemical classification rules

30 Mar 2023
Topic — A revision of European rules for classifying and labeling hazardous chemical substances.
Message — The federation wants essential oils to be classified based on the whole substance. They request an approach that recognizes the natural complexity of these plant-based oils.12
Why — This avoids costly product modifications and protects small businesses from impossible technical demands.34
Impact — Health advocates lose protection if serious hazards are not identified at the constituent level.5
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Meeting with Anja Hazekamp (Member of the European Parliament, Shadow rapporteur) and European Coalition to End Animal Experiments

29 Mar 2023 · classification and packaging

Essential oil industry seeks clearer rules for endocrine disruptors

18 Oct 2022
Topic — A consultation on introducing new hazard classes for classification, labelling, and packaging of chemicals.
Message — EFEO requests clear definitions for endocrine disruptors incorporating irreversibility and the use of modern testing methods. They also advocate for higher concentration limits and delayed implementation until comprehensive guidance is released.123
Why — This would prevent essential oils from being unfairly classified and lower technical compliance burdens.45
Impact — Consumer safety groups may see weaker standards and significant delays in chemical hazard reporting.67
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Response to Update of the list of recognised third countries and control bodies for import of organic products

11 Aug 2022

EFEO (European Federation of Essential Oils) represents the interest of producers and traders/importers of Essential Oils used as flavouring extracts in the food industries in the EU. These products are covered by category D (processed agricultural products for use as food) and thus are affected by the draft proposal. EFEO clearly objects to the intended deletion of the 4 certification bodies from annex II of Regulation (EU) 2021/2325 which are responsible for the certification of the largest part (as far as we know: approximately 80 % and more) of the Indian organic production of essential oils exported to the EU. Once deleted, these certification bodies could not be replaced in a timely manner, and the remaining certifying companies authorized in India would not have the capacities to carry out the necessary controls as required by EU organic production legislation. Thus, the proposed measure would seriously affect the Indian exporters as well as European importers and their industrial customers in the EU. Certified organically produced essential oils would in future not be available in quantities serving the needs of the food industries. It should be considered that it does not appear justified that all companies involved in the supply chain suffer a disadvantage. Further on, the deletion of the most important certification bodies in India would lead to a restricted access of Indian organic producers to the Union market for organic products. In addition, it seems possible that the affected products would find their way into the EU market via other channels, with the result that competition could be distorted. Indian organic producers would increasingly be forced to turn to conventional farming, as the production of organic essential oils by Indian growers and distillers would not be a viable economic alternative any longer. This might also result in an increased use of pesticides in the agricultural areas. This development would neither be compatible with the basic idea of organic farming nor with aspects of environmental protection and would be in contradiction to the Green Deal policy pursued by the EU. The EU Commission is therefore requested to re-consider the current regulatory approach and instead propose a solution less intrusive and more acceptable in its impact, both for the EU-based food industries and for Indian producers of essential oils and their growers of the plant source material. Lutz Düshop, atty. Secretary General European Federation of Essential Oils Sonninstrasse 28, D-20097 Hamburg Tel.: +49 (0)40 23 60 16 14/13 Fax: +49 (0)40 23 60 16 10/11 secretariat@efeo.eu EU Transparency Register No 180 153 441 003-55
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

12 Apr 2022

EFEO thanks the Commission for the opportunity to provide comments on the document Ref. Ares(2022)1871487 - 14/03/2022: "Chemicals – making best use of EU agencies to streamline scientific assessments". Essential Oils are natural complex substances (NCSs) originating from botanically defined plant source material. They are obtained by physical processes like distillation or cold pressing. Plant growing and oil production takes place in Europe (e.g., Lavender, Citrus) and all over the world bearing a high socio-economic impact throughout our industry. These raw materials are mainly used in very low levels in the finished products and the real exposure to consumers and the environment should be considered. The industries (Fragrance, Flavour, Cosmetic, Detergents et al.) where Essential Oils are used, have a long history in "safe use" – risk assessment and risk management measures are applied successfully. This also demonstrates the effectiveness of case-by-case approaches which consider application, exposure etc. EFEO fully supports the "aims [of the initiative] to consolidate in EU agencies the technical and scientific work on chemicals performed at EU level under, or in support of, EU legislation." Moreover, we share "[t]he objective [...] to ensure high-quality deliverables, to use resources more efficiently, avoid duplication of efforts, exploit synergies, make best use of expertise in EU agencies, and ensure more coherent safety assessments for chemicals across legislation." An effective coordination between the EU bodies, if necessary new, comprehensive & accessible data bases and an efficient setup are key to manage the existing and the many expected volumes of substance data ! EFEO also likes to clarify: "one substance, one HAZARD assessment" ! However, for EFEO there is no question that – particularly when dual use/multi-application raw materials like Essential Oils are concerned – only an independent, science-based and application- and exposure-oriented risk evaluation can do justice to all, consumers, authorities, manufacturers, and the product itself including its ingredients. Consumer safety is THE priority our industry and regulators have in common, and we have some recommendations to make sure the initiative prioritises consumer safety oversimplification and efficiency, and further fosters robust safety assessments considering the latest science. Moving the responsibilities of the independent committees would put at risk a model for carrying out scientific assessments that is highly successful. A culture focused on expertise,exposures, and mitigation of the likelihood of harm would be threatened, without any obvious compensating benefits for consumer safety. Advances in the adoption of the most up-to-date scientific evidence would also be placed at risk, weakening the protection of consumer safety. It is our strong belief that strong scientific expertise in safety assessment and independence are paramount for a high-quality outcome of the review of priority ingredients formulated into consumer products (e.g., in the case of priority classes of ingredients, new human or environmental health risks, new exposures such as aggregate exposure across product types or industries). Please refer to the attached file !
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

EFEO response to the Inception Impact Assessments on the revision of CLP regulation The European Federation of Essential Oils (EFEO) supports the objectives of the Chemicals Strategy for Sustainability (CSS) and welcomes the opportunity to comment on the Inception Impact Assessments (IIA) on the revision of the CLP regulation. EFEO represents about 200 companies in the production, import, trade and use of Essential Oils and other smelling or tasting plant extracts – collectively referred to as Natural Complex Substances (NCS). An Essential Oil is defined as a volatile part of a natural product, which can be obtained by distillation, steam distillation or expression in the case of citrus fruits. It contains mostly volatile hydrocarbons. Essential Oils are derived from various sections of plants. The oil is "essential" in the sense that it carries a distinctive scent, or essence of the plant. These plants are cultivated or, in some cases, collected from the wild – and often they are food. NCSs are used in cosmetics, detergents, foodstuff (including flavourings), pharmaceutical products, animal feed etc. and are typical “dual use” substances as the same product can be used in different applications. As bio-based and renewable raw materials NCSs fulfil both customer/consumer expectations and already today generic requirements of the Green Deal and CSS. Agricultural cultivation and the subsequent production processes have been continuously optimised in recent years but are ultimately subject to natural principles. By nature and definition NCSs are complex. In some cases, they are further processed after manufacture, but there are strict limits to the selective depletion of certain constituents. Moreover, such manipulations almost always lead to significant changes in the smelling and tasting profile. Therefore, it is impossible to react to “constituent alerts” which clearly distinguishes NCSs from mixtures. Treating NCSs as mixtures would be fundamentally wrong – and does not make classification or registrations less complex: NCSs are substances ! Data and subsequent classification of a NCS should be given preference over theoretical classification based on constituents. The classification based on constituents should only happen when there is no data on the NCS itself. In this context we assume that this is addressed by the following measure highlighted in the Policy options: "clarify the obligation to classify mixtures and some complex substances". EFEO is critical for the introduction of Endocrine Disruption – more known as mode of action than a specific hazard endpoint – as a new hazard class. Moreover, for complex substances like Essential Oils it is important to allow a clear differentiation between endocrine activity and endocrine disruption. It is therefore essential to avoid any confusion when considering the proposed "suspected" category and to build the possible new hazard classes on solid scientific criteria. Production, import and trade of NCSs is essentially the domain of micro, small and medium sized companies (SME) and starts at farm level. Many important Essential Oils are produced in Europe – for example in Bulgaria, France, Italy, or Spain whole regions are characterised by their cultivation – where they make an important contribution to the livelihoods of the people living in these regions. Moreover, most Essential Oils are low volume products. All additional and stricter information requirements would disproportionately affect small companies, many of whom cannot afford these additional costs. Finally, EFEO would like to stress the value of a socio-economic impact assessment and the need for dialogue with (all) stakeholders from the beginning, given the scale of the proposed changes and the level of ambition set out in the strategy. EFEO is ready to provide a comprehensive and effective input.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

EFEO response to the Inception Impact Assessment on the revision of the REACH regulation The European Federation of Essential Oils (EFEO) supports the objectives of the Chemicals Strategy for Sustainability (CSS) and welcomes the opportunity to comment on the Inception Impact Assessments (IIA) on the revision of the REACH regulation. EFEO represents about 200 companies in the production, import, trade and use of Essential Oils and other smelling or tasting plant extracts – collectively referred to as Natural Complex Substances (NCS). An Essential Oil is defined as a volatile part of a natural product, which can be obtained by distillation, steam distillation or expression in the case of citrus fruits. It contains mostly volatile hydrocarbons. Essential Oils are derived from various sections of plants. The oil is "essential" in the sense that it carries a distinctive scent, or essence of the plant. These plants are cultivated or, in some cases, collected from the wild – and often they are food. NCSs are used in cosmetics, detergents, foodstuff (including flavourings), pharmaceutical products, animal feed etc. and are typical “dual use” substances as the same product can be used in different applications. As bio-based and renewable raw materials NCSs fulfil both customer/consumer expectations and already today generic requirements of the Green Deal and CSS. Agricultural cultivation and the subsequent production processes have been continuously optimised in recent years but are ultimately subject to natural principles. By nature and definition NCSs are complex. In some cases, they are further processed after manufacture, but there are strict limits to the selective depletion of certain constituents. Moreover, such manipulations almost always lead to significant changes in the smelling and tasting profile. Therefore, it is impossible to react to “constituent alerts” which clearly distinguishes NCSs from mixtures. Treating NCSs as mixtures would be fundamentally wrong – and does not make classification or registrations less complex: NCSs are substances ! Data and subsequent classification of a NCS should be given preference over theoretical classification based on constituents. The classification based on constituents should only happen when there is no data on the NCS itself. In this context we would like to ask for clarification of the application of a Mixture Assessment Factor (MAF) to intentional mixtures. EFEO cannot support the extension of the Generic Approach while drifting towards hazard assessment and classification triggered regulatory instruments. A hazard-based approach is not suitable to NCSs. These raw materials are mainly used in very low levels in the finished products and the real exposure to consumers and the environment should be considered. We therefore support a likely more extensive but well-established and, above all, application based (and therefore consumer driven) risk assessment. In this context the "One substance – one assessment" concept could only work well for the hazard assessment. The approach to "essential use" in the CSS is too vague, it needs to be revised and discussed in detail. It should be based on scientific assessment and only implemented where an unacceptable risk is identified or where adequate control cannot be guaranteed. The reform of the REACH authorisation and restriction process should introduce a transparent procedure to ensure that the best and most efficient risk management option can be chosen. It is also important that adequate consultation is provided for. Production, import and trade of NCSs is essentially the domain of micro, small and medium sized companies (SME) and starts at farm level. Many important Essential Oils are produced in Europe – for example in Bulgaria, France, Italy, or Spain whole regions are characterised by their cultivation – where they make an important contribution to the livelihoods of the people living in these...
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