48 JOURNAL OF COSMETIC SCIENCE
at the level of countries and commodity crops. A more detailed commercially available
analysis including natural raw materials of relevance to the fragrance industry is available
from the Union for Ethical Biotrade (UEBT) [53].
The industry consensus is that in most cases where abuses are identified, the best way forward
is to work with the concerned supply chain to improve conditions, rather than to walk away,
and this is also the philosophy of CSDDD. Concerning cosmetic ingredients, the Responsible
Mica Initiative is a good example [54] where external assessment has confirmed progress.
There are a limited number of consortia working to improve identified issues on specific
fragrance ingredient supply chains, such as the Sustainable Vanilla Initiative hosted by the
Sustainable Trade Initiative (IDH) and the Harvesting the Future Project coordinated by the
Fair Labor Association. Some natural materials can be purchased with ethical certification
like UEBT-certified, Fair-for-Life certified, FairWild certified and, Flocert (Fairtrade).
The acronyms Human Rights Due Diligence and HREDD (Human Rights and
Environmental Due Diligence) are increasingly common, and AIM-progress has recently
provided open-sourced guidance for companies to perform HREDD assessments [55].
In terms of specific legislation, in the USA the California Transparency in Supply Chains
Act of 2010 (S.B. 657, § 2) requires companies to disclose the steps they are taking to
eradicate slavery, human trafficking, or forced labour from their supply chains, both within
the company or their supply chain. Today this takes the form of a signed declaration
confirming compliance.
For Europe, as mentioned above, CSDDD or CS3D, (EU) 2024/1760 was approved in 2024
and concerns companies with more than 1,000 employees and a worldwide turnover of
more than €450 million. It can be seen as an extension of the 2023 German Supply Chain
Supply Obligations Act (LkSG) both in geographic scope and extent, especially concerning
indirect suppliers [56]. CSDDD covers human and environmental due diligence, alongside
aspects of climate change, deforestation, and biodiversity discussed above. Many of the
prohibitions and obligations included in the Environmental Instruments (Annex, Part II)
are not relevant to the fragrance industry. The same cannot be said for the Rights and
Prohibitions included in International Human Rights Instruments (Annex, Part I).
Concerned companies have to implement a risk-based system to monitor, prevent, or
remedy human rights and environmental damage linked to direct and indirect suppliers,
following a six-step approach to corporate responsibility, based on the due diligence process
described in the OECD Due Diligence Guidance for Responsible Business Conduct [57].
CSDDD covers a broad range of human rights, drawing on a number of existing Covenants
and Conventions included are: right to life, prohibition of torture, right to liberty and
security, freedom of thought and religious practice, fair and living wage, adequate housing,
food, clothes, water and sanitation, children’s rights, prohibition of child labour, prohibition
of forced or compulsory labour, freedom of association, equal employment, environmental
degradation (discussed above), and land rights.
If a violation of human rights or environmental obligations is identified, companies have
to take appropriate measures to prevent, mitigate, and bring to an end or minimise the
adverse impacts arising from their activities. Companies can be held liable for damage
caused and potentially provide compensation for the affected parties.
Annual reporting is required and for most concerned companies this will be via their
CSRD report.

49 Sustainable Fragrances
Alongside CSDDD there is a related regulation, (EU) 2024/3015, prohibiting products
made with forced labour on the Union market, referred to as the Forced Labour Regulation.
Whilst CSDDD explicitly lists forced labour, it primarily focuses on corporate conduct and
due diligence procedures rather than measures to prevent the placement and availability of
products made with forced labour on the EU market or their export from the EU market.
The Forced Labour Regulation has a much broader reach than CSDDD in terms of
company size and includes the entire supply chain, not just the economic operator’s own
activities. It covers many products made using forced labour and all industry sectors. If the
authorities conclude that forced labour has been used, they can decide to ban and withdraw
the concerned products from the EU market and online marketplaces.
CONCLUSION
The sense of smell plays an important role in life from the very pragmatic ability to
detect danger, the enjoyment of food and our environment, to more subtle effects of social
interactions. The use of fragrance or fragranced products can equally extend from a very
functional role, like malodour control, to reassurance of a job well done, to bringing
emotional benefits such as a sense of well-being, often associated with memories.
With typical fragrances containing 50 or more ingredients of different origins there is no
magic bullet in designing more sustainable fragrances. The industry will need to work
diligently on multiple vectors to improve across diverse factors from carbon and water
footprint to environmental and safety concerns. Biotechnology is often cited as a future
solution but reality is not so simple whilst carbon footprint can be low, it is less clear for
water footprint, the typical starting materials like sugar cane have issues of food competition
and biodiversity impact, time and conversion yields are unfavourable compared to standard
“organic” chemistry, and the human and environmental hazard of the final product is
agnostic of how it was made.
Figure 8. OECD Due Diligence Process (2020) – courtesy UNFSS [57].