I've just "stepped into the IFRA minefield", as Chris Bartlett so aptly puts it, as I'm in the fortunate position of being invited to sell my scents in a real live shop. (Something I wasn't sure I was quite ready for, but it would be daft to turn down the chance.)
I thought I'd share what I'm going through. I shan't bore you with the endless internet research I did before getting a recommendation. I'd just say, do see if you can work on recommendations because it saves a whole load of faff. (Like companies who want to make your scents for you, not do what you need.)
From the lovely Karen Gilbert I got Penny Williams, owner of www.orchadia.org. She's a perfumer and expert on regulations, on the IFRA technical panel, and she's the one who can get me my IFRA certificate, if I need them - one for each fragrance. Not law in the EU, but many shops ask for them (partly because they assume IFRA is the law.)
Penny kindly talked though all the different issues I have, and will be the person I go to when I'm ready to apply for IFRA certificates. I don't have to join IFRA to get these, so I can still make bespoke fragrances for people who want certain things that IFRA's regulations prohibit. And I was releived to hear that I can still make my own stuff in my own loft, and retain full indie status.
Penny then recommended Anthony Dweck, analytical chemist, who can produce my Cosmetics Safety Assessments. These I do need for the EU. If some of my scents are not safe, he can advise on reformulation. I'd have to give him my complete formulae, and also a copy of the Materials Safety Data Sheet for every single material I use.
So my scent which contains oudh that I bought fromt he Dubai oudh soukh, well that doesn't have a hope of passing. There is no way I'd ever get a materials safety data sheet from the shop owner or his supplier, so I'll have to reformulate that one before it goes anywhere near a test.
So far I've emailed all my suppliers.
Mistral - makes of the perfumers' alcohol I use, along with many of us here - got right back to me and pointed out that the MSDS is on their website... Should have looked first.
Bristol Botanicals - they got back to me within the hour with full MSDSs for everything I've ever bought from them, plus extra data on green peppercorn essential oil because they didn't feel that the data sheet was good enough. 5 stars to Bristol Botanicals and their medicinal grade oils.
Hermitage - Adam's not that well at the moment, but he's chasing up his suppliers for me to get hold of the MSDSs. He says that his French supplier is not good at admin. Hermitage are marvellous. Great range of really good quality oils and Adam is passionate about going out and sourcing his own stuff. I really want to keep getting my naturals from him, so fingers crossed for the suppliers having the data on hand. (They really ought to have it available for him.)
However, I've found out that a material that's very well known like lavender or mint doesn't always need a separate data sheet to go with the appication for a Cosmetics Safety Assessment. But if I insist on using rasberry leaf or goji berry or or yuzu - which I do - I've got to have the materials data as they are not well known and would mean that a perfume which contained them would fail the safety test.
I'll update this when I hear from the other people I buy from, including the people who sell synthetics. If I can't get the data sheets, I'll probably shift over to Bristol Botanicals for the synthetics - more expensive but super impressive on this point.
Update: Tom from Baldwin's has emailed and is going to get the data sheets for everything I've bought from him from his suppliers. I'll post when they arrive.
If you've had experience of getting hold of data sheets, I'd be very happy to hear about it.