For years Lilial was one of perfumery's favourite lily-of-the-valley notes, and it turned up in plenty of candle fragrance oils. In March 2022 it vanished from EU cosmetics. Since then candle makers have heard two opposite claims: that Lilial is "banned", and that the ban "doesn't apply to candles". Both are half right. Here's what actually changed, what it means for a candle, and what the story teaches about any fragrance ingredient that becomes a CMR (carcinogenic, mutagenic or toxic for reproduction).

What Lilial is

Lilial is a trade name. On an ingredient list it's butylphenyl methylpropional; on a safety data sheet it may be 2-(4-tert-butylbenzyl)propionaldehyde, BMHCA or Lysmeral, with CAS 80-54-6 and EC 201-289-8. It gives a soft, watery floral note used in muguet, "clean cotton" and fresh laundry accords.

Three rules, one date

  • 8 July 2021: ECHA added it, with its stereoisomers, to the Candidate List of substances of very high concern, as toxic for reproduction (REACH Article 57(c)).
  • 1 March 2022: its harmonised classification Repr. 1B, H360Fd "May damage fertility. Suspected of damaging the unborn child." started to apply. It came from Delegated Regulation (EU) 2020/1182, the 15th adaptation to technical progress (ATP) of CLP, index 605-041-00-3, following a Risk Assessment Committee opinion of January 2019. When we checked ECHA's C&L Inventory on 29 September 2026, this was its only harmonised hazard class, with no specific concentration limit.
  • Same day: Regulation (EU) 2021/1902, known as "Omnibus IV", added it to Annex II of the Cosmetics Regulation, the list of prohibited substances. EU cosmetics law bans CMR 1A and 1B substances by default, so the ban followed the classification.
  • Same day: Regulation (EU) 2021/2204 added it to Appendix 6 of REACH Annex XVII. This is the one that matters for candles.

So is Lilial banned in candles?

Not by name. A candle isn't a cosmetic, so the cosmetics ban doesn't reach it. IFRA doesn't stop it either: its standard (49th Amendment) prohibits BMHCA in lipsticks and oral care, but allows up to 16% in Category 12, the IFRA category that covers candles. An IFRA certificate will say your oil is fine.

But two general rules do apply to candles, and together they work like a ban above a certain level.

Rule 1: from 0.3%, the candle is Repr. 1B

Under CLP, a mixture containing a Repr. 1B substance at 0.3% or more is itself classified Repr. 1B. Lilial has no specific limit, so this generic 0.3% applies. A candle over the line needs the health hazard pictogram (GHS08), the signal word "Danger" rather than "Warning", and H360Fd. There's no gentle middle step like the EUH208 allergen line for sensitisers.

Rule 2: Repr. 1B mixtures can't go to consumers

REACH Annex XVII entries 28 to 30 cover the CMR 1A and 1B substances listed in its Appendices 1 to 6. Lilial is in Appendix 6. These substances, and mixtures containing them at or above the relevant concentration limit, shall not be placed on the market for supply to the general public, and the packaging must say "Restricted to professional users". The exemptions are medicines, cosmetics, certain fuels, artists' paints, a few listed uses and medical devices. Candles aren't among them.

So a candle with 0.3% Lilial or more can't legally be sold to consumers, and adding the GHS08 pictogram doesn't fix that. The same goes for a fragrance oil or diffuser refill you sell to the public.

A worked example

Take a hypothetical older floral oil whose SDS lists 4% butylphenyl methylpropional:

  • At a 10% load, the candle holds 0.4% Lilial. That's over 0.3%, so the candle is Repr. 1B: GHS08, "Danger", H360Fd, and restricted to professional users. You can't sell it in your shop or at a market.
  • At a 7% load, it holds 0.28%. That's under 0.3%, so there's no reproductive toxicity classification. But it's still over 0.1%, so a business customer, such as a shop that stocks your candles, can ask you for a safety data sheet even if the candle isn't classified as hazardous (REACH Article 31(3)).

The quick rule: the maximum Lilial content of your oil is 0.3% divided by your load. At 10% the oil must hold less than 3%; at 6%, less than 5%. Everything else on the label, such as H317 from sensitisers, is still worked out separately.

Lyral: banned in cosmetics for a different reason

Lyral (HICC, hydroxyisohexyl 3-cyclohexene carboxaldehyde) is another muguet material that left EU cosmetics under Regulation (EU) 2017/1410: no new products from 23 August 2019, none on shelves from 23 August 2021. The reason was allergy, not CMR. Its harmonised classification is Skin Sens. 1A, so in a candle it's handled like any strong sensitiser: H317 and the exclamation mark from 0.1%. IFRA restricts it rather than prohibiting it, and allows up to 91% in Category 12. A cosmetics ban tells you something about a substance, but your candle's label comes from its CLP classification.

Other CMRs in fragrance

Harmonised CMR 1A or 1B classifications are rare among fragrance materials. The one worth knowing is safrole, found in sassafras and some other essential oils. It is harmonised Carc. 1B (H350) and Muta. 2, so its generic limit is 0.1% and it's covered by the same consumer restriction. IFRA is stricter still: safrole may not be added as such, and natural extracts may bring at most 0.01% in total into the finished product. Category 2 "suspected" CMRs, such as musk ketone (harmonised Carc. 2), classify a candle from 1% (3% for Repr. 2) and aren't restricted by entries 28 to 30.

What to check on your fragrance SDS

  • The revision date. An SDS written before 1 March 2022 predates the harmonised classification and may not show H360Fd even if the oil contains Lilial. Suppliers must update an SDS without delay when new hazard information or a restriction applies, so ask for the current version.
  • Section 3. Look for CAS 80-54-6 or any of its names, and multiply its percentage by your load.
  • Section 2. "Repr. 1B" or H360Fd in the oil's own classification means it contains at least 0.3%.
  • Old stock. An oil bought before 2022 may still be on your shelf with its original SDS.

Molekule reads each component from your SDS, checks it against ECHA's live harmonised classifications, so a new ATP entry reaches your calculation without you tracking regulations, and runs the 0.3% reproductive toxicity check at your load. Check your fragrance oils for CMR ingredients in Molekule.