Room Fragrance, Detergent, Cosmetic: Which Regulations Apply to Your Product?

Three factors determine the classification, and none of them is the formula itself:

• Site of application: Is the product applied to the human body, or to the air, laundry, or a surface?
• Primary purpose: Is it intended to clean, to impart fragrance, or to destroy micro-organisms?
• Claim: What you write on the label, in advertising, or in a marketplace listing title. This is where the most penalties are issued.

The third point is critical. If you use terms such as antibacterial, disinfectant, antimicrobial, or similar on your product, it will no longer be assessed as a cosmetic product. In other words, you do not change the product; you change a sentence — and the product instantly moves into an entirely different licensing regime.

In Turkey these four frameworks are administered by different bodies. On the cosmetics side there is TİTCK; under Cosmetics Act No. 5324, cosmetic products must be notified to the Product Tracking System (ÜTS) before they are placed on the market. Room fragrances, car fragrances, and scented candles are a different matter entirely: market surveillance and inspection of air-aromatising products (room fragrances, laundry fragrances, car fragrances, incense, scented candles, etc.) falls under the authority of the Ministry of Trade's Directorate General of Consumer Protection and Market Surveillance.

On the detergent side the definition is clear: a detergent is a product in any physical form that contains soaps and/or other surfactants and is intended for washing and cleaning processes other than the cleaning of the human body. The phrase "other than the cleaning of the human body" is the fine line that separates liquid soap from dishwashing detergent.

Once a hygiene claim enters the picture, everything changes: antibacterial hand and skin sanitisers fall under Biocidal Product Type 1 and must obtain a biocidal authorisation. Products without a biocidal product authorisation may not be manufactured or placed on the market.

If your product fits none of the above, you do not fall into a gap; the umbrella provision applies. Where no specific technical regulation exists for the product group they are responsible for, the competent authorities apply the general product safety provisions, and the General Product Safety Regulation entered into force on 12 March 2021.

1. Step 1 — Is the product applied to the body?

   Everything that comes into contact with skin, hair, nails, lips, or oral mucosa and whose purpose is to clean, impart fragrance, or alter appearance falls on the cosmetics side. Cologne, perfume, liquid soap, and body spray all belong here. If the answer is "no", proceed to Step 3.

2. Step 2 — Does the product carry a micro-organism claim?

   If you say "antibacterial", "disinfectant", or "kills 99% of germs", you exit the cosmetics regime. A cosmetic product notification must not be made for products of this kind. The route leads to a biocidal authorisation — a far more demanding file than a notification.

3. Step 3 — Is the product released into the air or used to fragrance a space?

   Room sprays, reed diffusers, car fragrances, scented candles, incense, and laundry perfumes. These fall under the heading of air-aromatising products and the supervisory authority is the Ministry of Trade. The relevant communiqué covers manufacturers of preparations and substances used to impart a pleasant scent to a space or to alter its smell; manufacturers of air-aromatising products must notify the Ministry.

4. Step 4 — Does the product clean?

   If it contains surfactants and is intended for washing or cleaning, you are in the detergent framework. Detergent products are assessed under the "Regulation on Detergents" published in the Official Gazette No. 30314 dated 27 January 2018. Declaring fragrance allergens on the label is the most frequently overlooked part of this framework; the legislation governs the additional information on the label and/or packaging of detergents, including any fragrance allergens they contain.

5. Step 5 — Does it not fit any of the above?

   Borderline products such as scented stones, wardrobe fresheners, and decorative aroma objects fall under the general product safety and chemical legislation umbrella. This is not a "free zone"; on the contrary, it is where the most penalties are written.

6. Step 6 — Check your chemical labelling (CLP) obligations.

   For alcohol- and solvent-based fragrances you may need hazard pictograms, hazard and precautionary statements, child-resistant closures in some cases, and tactile warnings for the visually impaired. This is the most common shortcoming found during inspections.

7. Step 7 — Identify the responsible person and the product file.

   Whoever places the product on the market bears the obligation. For cosmetics, the notification is made by the responsible person who places the product on the Turkish market (the manufacturer or the importer). If you have used a contract manufacturer, the phrase "the factory handles it" will not protect you; the company named on the label is responsible.

For a single-glance view of the decision tree:

Know the institutional split from the outset: applications for biocidal products that come into direct contact with the human body — Product Type 1 (hand sanitisers, antibacterial liquid soaps, etc.) and Product Type 19 — are submitted to TİTCK's Cosmetic Products Department; applications for other biocidal products, such as environmental, air, and surface disinfectants, are submitted to the Directorate General of Public Health. Going to the wrong authority means throwing weeks away.

The cosmetics side operates on a notification regime, not a prior-authorisation regime. There is no "prior approval" system for cosmetic products — there is a "notification" system; products must be registered and notified in ÜTS. However, "notification" does not mean "easy". Under the notification and inspection provisions of the Cosmetics Act, any changes to the product or the manufacturer after ÜTS registration must also be notified. This means every formula revision, packaging change, or change of contract manufacturer must be entered into the file.

This notification also carries a fee, and you may still find sources online claiming it is free — that information is no longer current. It was decided that cosmetic notifications would be charged from 28 May 2024 onwards; the published figures were 298.18 TL per product barcode, 178.31 TL at the discounted rate for manufactured products, and 5,048.01 TL for cosmetics company registration. These figures reflect the tariff in force at the time of publication; TİTCK fees are updated annually in line with the revaluation rate, so verify your budget against the current official tariff. If you are launching ten products from a single fragrance family, the per-barcode fee is a significant line item.

The biocidal side is an entirely different league. Here there is no notification — there is authorisation, and authorisation is demonstrated through efficacy tests. Before the application dossier is prepared, the biocidal product formula must be developed at an efficacy level that covers the product's claims, and the analyses must be carried out in a laboratory accredited under TS EN ISO/IEC 17025 for the relevant parameter. Fee line items — product label registration, authorisation fee, registration fee — are each defined separately and updated annually; the TİTCK fee schedule lists biocidal product label registration, authorisation fee, and registration fee as separate items. In other words, the decision "I'll write antibacterial on my liquid soap — it'll sell better" will come back to you as a laboratory invoice and months of waiting.

Air-aromatising products appear at first glance to be the most straightforward category; in reality, the most product recall decisions originate here. The reason is not authorisation — it is the label. The grounds cited in Ministry of Trade unsafe product notifications for room fragrances repeat with striking frequency: a decorative ambient fragrance product was found to be non-compliant with the provisions of the CLP Regulation for lacking a "tactile warning" and was declared a risky product on the grounds of risk of injury, burning, and allergic reaction. In another example the grounds are even more fundamental: absence of ingredient information on the label, missing mandatory minimum information on the inner packaging label, and absence of a tactile hazard indicator.

Enforcement is not theoretical either. Products found to be non-compliant following inspections are subject to sanctions including administrative fines as well as bans on market supply and product recalls. In the cosmetics sphere, manufacturing, packaging, or importing cosmetic products without notifying the Ministry of Health is prohibited, and administrative fines and other sanctions are provided for in the Act for cosmetic products placed on the market without notification. Although penalty amounts are stated in the legislation, they are updated each year through the revaluation rate; always check the current figure from an official source.

If you are importing, there is an additional layer. Products for which ÜTS notification has been completed may be subject to risk-based inspection at the customs stage via TAREKS. On the tax side, perfume and cosmetic items carry a specific burden; perfume (HS 3303) and similar cosmetic tariff headings are assessed under Special Consumption Tax (ÖTV) List IV. The calculation of "I bought it cheaply from abroad" may therefore look very different at customs.

Do not overlook chemical legislation either. The legal bases cited in unsafe product notifications for room fragrances include Product Safety and Technical Regulations Act No. 7223, the KKDİK Regulation, and the CLP Regulation together. KKDİK obligations in the purchase and sale of fragrance oils and solvents are a separate topic; ask your supplier for written confirmation of tonnage thresholds and registration schedules, and always verify any deadline information — such as the deadline stated for pre-registration — against the current official announcement.

These ranges are starting points, not formulas. Every base behaves differently; test in your own formula and make decisions based on stability results.

Grams or millilitres? This is why bottles overflow

Always build formulas by weight — but when converting to volume, account for density. The specific gravities of fragrance oils and solvents vary considerably: citrus-dominant volatile oils are around 0.84 g/ml, while heavy resins and some synthetics can exceed 1.10 g/ml. A 100 g formula will either overflow a 100 ml bottle or leave headspace. Use the conversion volume = mass ÷ density and fill one control bottle per batch.

Water does not prevent cloudiness — it triggers it

This is the most widely misunderstood topic in the industry. When you add water to an alcoholic fragrance, the hydrophobic (water-insoluble) aroma chemicals and natural oils in the fragrance oil lose their solubility in the alcohol; they separate as micro-droplets and produce the cloudiness known as louching (the ouzo effect). The purpose of water is not to prevent cloudiness; it is to soften the initial harshness of the alcohol and to balance costs. For this reason, start with a small amount of water, leave it for 24 hours, then check for clarity. If you encounter problems, using a ready-made perfumer's alcohol (solubilizer-containing, balanced alcohol) is the most practical solution.

Do not confuse maceration with chilling

Maceration is a chemical maturation process: alcohol–fragrance interaction and slow esterification reactions. As temperature drops, these reactions slow down. For this reason maceration is carried out at room temperature (approximately 15–20 °C) and in the dark — not in a refrigerator. There is no "accelerated maceration" technique; you only extend the process.

Chilling is a separate, subsequent step: the product is held at approximately 0–4 °C for around 24 hours so that insoluble waxy structures precipitate. These are then removed by cold filtration. Skip this step and you will receive complaints about sediment at the bottom of the bottle and cloudiness throughout the shelf life. The correct sequence is: maceration at room temperature → chilling → cold filtration → filling.

What you think are fixatives are actually carriers

MPG (monopropylene glycol) and IPM (isopropyl myristate) are not true fixatives; they are carrier solvents and emollients — volatility modifiers. Because they slow the evaporation of alcohol slightly they exhibit a mild fixative effect, but do not call them "fixatives" on your label. True fixatives are macrocyclic musks, glucose ethers such as Glucam P-20, and heavy balsams/resins. If you use MPG at a high level (2% and above) it will leave a tacky feeling on the skin; that is usually the invisible source of customer complaints.

Longevity cannot be bought with concentration alone

Longevity and sillage depend not only on the fragrance oil percentage; the primary determinant is the volatility of the raw materials. A 25% citrus-dominant concentrate can evaporate quickly, while a 10% product built around amber, oud, and musk may last considerably longer. Designations such as EDT/EDP are a convention of ratios, not a performance guarantee. Therefore, do not make absolute hour promises in your product descriptions; "varies according to formula composition" is both honest and legally safe. The real leverage in scent design is not diluting a ready-made fragrance oil with alcohol — it is building an accord and balancing the weights of the raw materials.

IFRA: it's about molecule and category, not total percentage

IFRA limits are set not for your total fragrance oil percentage but for individual substances and allergens within the fragrance oil, and for the product category (leave-on or rinse-off). The generalisation "every fragrance oil is safe up to 20%" is wrong and will leave you defenceless during an inspection. There is only one correct approach: request the IFRA certificate / compliance declaration for the fragrance oil from your supplier and read the row corresponding to your product category.

Two final points to keep in mind when writing label text. First: even if you see the words "food grade" on fragrance oil packaging, cosmetic and perfume fragrance oils are not food; they are not edible or drinkable. Food flavourings and cosmetic fragrance oils belong to separate supply chains and separate regulatory frameworks. Second: if you venture into the aromatherapy space, stay well away from health and therapeutic claims. Phrases such as "heals", "treats", or "cures illness" are both incorrect and risky; use cautious language such as "traditional use" and "sense of relaxation" and state that this does not constitute medical advice. Similarly, when making open fragrances or ambient scents, avoid any implication that the product is a copy of a specific brand or product; keep within a technical frame of reference.

Choosing the correct framework does not constrain your creativity — it protects it. You choose the fragrance oil, you build the ratio, you balance the accord. The regulations only tell you which shelf the bottle goes on. Everything else is your signature.