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Review Article
Essential oils – a review of the regulatory framework in the European Union
expand article infoStanislava Ivanova, Kalin Ivanov, Yana Gvozdeva, Radiana Staynova, Daniela Grekova-Kafalova, Maria Hristozova, Nina Koleva
‡ Medical University of Plovdiv, Plovdiv, Bulgaria
Open Access

Abstract

The current trend in consumers’ preferences for healthy lifestyles resulted in an increased demand for natural products. Many companies replaced synthetic compounds, used as preservatives, flavourings, or active ingredients, with natural ones. Nowadays, essential oils (EOs) and compounds isolated from EOs are regarded as promising and safe alternatives for many synthetic substances used as food additives, food preservatives, repellents, antimicrobial agents, etc. A great dynamic regarding the studies on EOs and in the global market of EOs was also reported. Moreover, the European market of EOs represents a significant share of the global EOs market. According to some recent reports, the European EOs market generated a revenue of more than 11 billion USD per year recently and is expected to reach well over 20 billion USD per year in 2030. The article provides an overview concerning EOs regulation in the European Union (EU). In the EU, the different product categories containing EOs are controlled under specific regulations to enhance product quality and safety. The manuscript highlights the key points of the EU legislation on EOs intended for food purposes, cosmetics, and health care.

Keywords

aromatic plants, essential oils, food supplements, natural products, regulation

Introduction

The current trends in consumers’ preferences for healthy lifestyles resulted in an increased demand for natural products. Many companies have been compelled to substitute synthetic compounds, traditionally used as preservatives, flavourings, or active ingredients, with natural ones. Currently, essential oils (EOs) and compounds isolated from EOs are regarded as promising and safe alternatives for many synthetic compounds used as food additives, food preservatives, repellents, antimicrobial agents, etc. (Sharmeen et al. 2021).

The European EOs market represents a significant share of the global EOs market. It has reportedly generated over 11 billion USD in annual revenue in recent years, with projections indicating it may exceed 20 billion USD annually by 2030 (Grand View Research). According to Horizon Databook, the largest revenue share (9.53% in 2023) belongs to the orange essential oil (EO). The European market of EOs is associated with several important key points, including EO industry growth and strong consumption of EOs in the food and cosmetic industries.

The pharmaceutical sector also has a significant share in the consumption of EOs, although there are not many medicines containing EOs registered in the EU. However, there is a great variety of food supplements (FS) containing EOs. Although FS are regulated as “food”, these products represent an important part of the European pharmaceutical market and are often included in the management of many medical conditions. It is a common practice for the FS to be recommended not only to enrich the diet. Many pharmacists and physicians often recommend FS in combination with some medicines for the treatment of the first symptoms of colds, to enhance bone health, and others (Dickinson et al. 2009; Wang et al. 2020; Crawford et al. 2022).

The pharmaceutical industry is often faced with some challenges regarding EOs because of their sensitivity to factors such as light, oxygen, temperature, high volatility, and strong hydrophobicity (Ju et al. 2019). These limitations can be overcome by encapsulating EOs in different drug delivery systems (DDS), which enable controlled release, enhance bioavailability and efficacy, and optimise their pharmacokinetic profile (Cimino et al. 2021). Encapsulation serves as an advanced method to preserve the functionality of EOs while also enabling their controlled release during human metabolism (Shetta et al. 2019). The encapsulation of EOs in DDS offers numerous advantages, including enhanced bioavailability due to DDS adherence to mucous membranes, protection from hydrolysis and oxidation for greater chemical stability, reduced toxicity and volatility, and improved targeting of therapeutic doses, ultimately increasing patient compliance. Various DDS strategies have been explored for EO encapsulation, such as liposomes, solid lipid nanoparticles, self-nano-emulsifying drug delivery systems, and inclusion complexes with cyclodextrins to enhance the stability of their active components (Severino et al. 2015). Particulate delivery systems offer several benefits, including enhancing the organoleptic properties of EOs while also extending their shelf life. Additionally, these systems improve stability, compatibility, and in vivo absorption. Other notable advantages include increased oil solubility and dissolution rates, optimised pharmacokinetics and release profiles, altered biodistribution, and the potential for targeted therapy. A promising recent approach involves the combined encapsulation of EOs with conventional synthetic drugs to enhance efficacy, improve biocompatibility, and mitigate resistance mechanisms (Cimino et al. 2021). As highlighted, the selection of formulation composition and preparation methods is crucial in developing optimal pharmaceutical products (Cimino et al. 2021). The same strategies could be involved in the development of DDSs containing EOs. EO formulations exist in various forms, including liquids (emulsions, micelles, and solutions), semi-solids (gels, liposomes), solids (microcapsules, microcomposites), and aerosols. Semi-solid formulations, such as creams and ointments, have been used for systemic treatment via transdermal absorption. Given their fat-soluble nature, EOs penetrate the skin’s membranes, enter the microcirculation, and are subsequently transported through systemic circulation to various organs (Baptista-Silva et al. 2020). Ointments are formulated by incorporating EOs into a stable base, with considerations for shelf life and application. For instance, ointments based on animal fat have a limited shelf life, necessitating alternative bases that maintain therapeutic efficacy while improving formulation technology (Shaimerdenova 2019). The transformation of liquid EOs into crystalline form allows for the development of powders, granules, and tablets. Through drying techniques such as micro- or nano-spray drying and precipitation, EOs can be processed into solid dosage forms, including soft pills, tablets, and chewing gums. Recently, EO-containing films have been developed, showcasing antimicrobial and antioxidant properties. Oregano EO-based films, for example, have demonstrated significant bioactive potential, while studies on chitosan-based films infused with lemon, thyme, and cinnamon EOs have shown enhanced antimicrobial properties and improved structural integrity, making them a promising option for advanced formulations (Baptista-Silva et al. 2020).

The past decade has witnessed a substantial increase in research focused on the potential applications of EOs, with expectations for their use to broaden across various sectors. Furthermore, projections indicate that the essential oil market may experience a twofold growth within the next five years. This anticipated expansion necessitates thorough examination of the regulatory frameworks governing EOs across diverse industries. The aim of this article is to provide an overview of EOs regulation in the EU. The article highlights data about the procedures for approval in the EU of some of the most popular EOs included in herbal medicinal products (HMP).

Essential oils for cosmetic purposes

The growing demand for chemical-free cosmetics in the EU is regarded as a driving force behind the popularity of EOs in cosmetic formulations. As consumers become more conscious about the ingredients in their skincare/haircare products, there has been a noticeable shift toward more natural, organic, and sustainable alternatives (Sharmeen et al. 2021). Essential oils can be incorporated into cosmetic products for their fragrance, as natural preservatives, or because of their diverse biological activity (antioxidant, antimicrobial, etc.) (Fig. 1). However, using EOs undiluted or in excessive concentrations can lead to skin irritations. In topical applications, they are typically diluted to concentrations ranging from 0.5% to 5%, though some oils may be used at levels up to 10% (Abelan et al. 2022).

Figure 1. 

Applications of EOs in cosmetic products (created with BioRender.com, accessed on 3 February 2025).

All products containing EOs intended to be used for cosmetic purposes in the EU must follow Regulation (EC) № 1223/2009 (Regulation (EC) No 1223/2009 2009). This regulation is the main regulatory framework governing finished cosmetic products placed on the market in the European Union. According to this regulation, a cosmetic product is defined as “any substance or mixture intended to be applied to the external surfaces of the human body, including epidermis, hair, nails, lips, etc., for the sole or main purpose of cleaning, perfuming, changing their appearance, or correcting body odours” (Taobe Consulting 2024). The regulation replaced Directive 76/768/EC, adopted in 1976 (Cosmetic Products 2013), and has some significant strengths compared to the old directive, including better safety requirements for cosmetic products; the introduction of the notion of ‘responsible person’; centralised notification of all cosmetic products placed on the EU market; and reports of serious undesirable effects, colourants, preservatives, and UV filters, which must be explicitly authorised. A technical dossier should prove the safety of the cosmetic product according to Article 10 of the Cosmetics Regulation. This dossier includes comprehensive data on the quality and safety of the essential oils (or the blend, if the product contains multiple oils). Based on the intended use, the responsible person is required to compile the Safety Report as outlined in Annex I of the Cosmetics Regulation, followed by a safety assessment (Taobe Consulting 2024). The safety evaluation of natural cosmetic ingredients follows a risk assessment framework that incorporates hazard identification, hazard characterisation, exposure assessment, and risk characterisation. This process involves detecting chemical, microbial, or physical components that may pose health risks and assessing the probability of both local (such as skin sensitisation, irritation, etc.) and systemic toxicological effects (Manful et al. 2024). According to some reports, EOs used in cosmetics could contain varying levels of heavy metals (Manful et al. 2024). Luka and Akun have reported that contamination from extraction equipment can be a potential source of heavy metal presence in EOs (Luka and Akun 2019). The European Pharmacopoeia (Ph. Eur.) states that the risk associated with EOs depends on factors such as the type of contaminant, the source of the plant material, and the extraction method (EDQM 2021). It was reported that cold-pressed EOs might be associated with a higher risk of contamination with heavy metals compared to distilled ones. Research by Brkljača et al. indicates that olive oil obtained through mechanical pressing had higher lead concentrations than oil extracted via centrifugation (Brkljača et al. 2013). The Ph. Eur. has established heavy metal limits for EOs, setting maximum levels at 5 ppm for lead, 1 ppm for cadmium, and 0.1 ppm for mercury.

Pesticides represent other contaminants that might be present in natural cosmetics (Tascone et al. 2014; Manful et al. 2024). Many studies have reported pesticide residues in different EOs (Lavender, Peppermint, Citrus, etc.). The most commonly found residues include chlorpyrifos, 3,5,6-trichloro-2-pyridinol, carbofuran, carbamate, 3-hydroxycarbofuran, propiconazole, tebuconazole, and others (Bella et al. 2006; Fillâtre et al. 2011; Tascone et al. 2014). As a result, certain cosmetic ingredients must require analyses for pesticides. According to the European Pharmacopoeia’s “Monographs on Essential Oils,” pesticide levels in distilled essential oils rarely exceed permissible limits (Tudi et al. 2022).

The inclusion of EOs in cosmetics is associated not only with some beneficial effects but also with a potential risk for skin sensitisation (Manful et al. 2024). According to Buonomo and Warshaw, approximately eighty EOs, including some of the most popular EOs (tea tree oil, thyme oil, neem oil, and eucalyptus oil), are associated with contact allergies. As a result, skin sensitisation is a key dermal toxicological endpoint in the safety assessment of natural cosmetic ingredients (Buonomo and Warshaw 2021; Manful et al. 2024).

Many cosmetic products contain mixtures of multiple compounds of natural origin, including EOs, fragrances, and other compounds. In general, for the EOs, the chemical composition could vary considerably depending on the geographical origin of the plant material, conditions of harvest, storage, and some further technical processing (Grul’ová et al. 2016; Baranová et al. 2025). In these cases, the cosmetic ingredient should contain data about the qualitative identification and semi-quantitative concentrations of the substances in the mixture (0.1% to <1%, 1% to <5%, 5% to <10%, 10% to <20%, 20%, and more). For mixtures of variable composition, an indication of the range and the maximum levels of the compounds that may be present in the mixture must be included. Specific labelling to reduce the incidence of contact-allergic reactions has been foreseen by the inclusion of potentially sensitising fragrance substances in Annex III to Regulation (EC) No 1223/2009, most of which are naturally found in EOs (EUR-Lex 2023). More specifically, the presence of these compounds must be indicated in the list of the composition of the product on the label when their concentrations in the final product exceed 0.001% in leave-on products or 0.01% in rinse-off products (2003/15/EC). For example, the monoterpene citral is an important fragrance ingredient, which could be found in the EOs isolated from Cymbopogon schoenanthus (L.) Spreng., Litsea cubeba (Lour.) Pers., Melissa officinalis L., and Verbena officinalis L. and other plant species (Capetti et al. 2021). The presence of citral must be indicated in the list of ingredients referred to in Article 19(1), point (g), when the concentration of the compound exceeds 0.001% in leave-on products and 0.01% in rinse-off products. The same requirements are published for citronellol, limonene, α-terpinene, and other compounds. For limonene, the peroxide value is required to be less than 20 mmoles/L, and for α-terpinene, the same value is required to be less than 20 mmoles/L. Although these compounds are regarded as allergens, they are associated with diverse biological activity, and the research on them seems remarkable (Table 1). It is believed that these skin sensitisers react with epidermal proteins through mechanisms that involve radical intermediates (Sahli et al. 2022). In general, these compounds are susceptible to autoxidation, and this is one of the key points in their skin sensitising potential. For example, it is considered that the pure citronellol is safe and non-allergenic. However, when exposed to air, it autoxidises and can cause an allergy. The air-exposed citronellol has a significant skin sensitising potential that is mainly attributed to the hydroperoxides detected at high concentrations in the oxidation mixtures. It is considered that such hydroperoxides can result in the rise of specific antigens. Moreover, the hydroperoxides are believed to react with skin proteins through mechanisms involving radical intermediates (Sahli et al. 2022). The full mechanism of skin sensitising effects is still not clarified.

Table 1.

Data about the biological activity of some volatile compounds isolated from EOs.

Compound Biological activity and applications Safety concerns Ref.
Citral Good antifungal and antibacterial activity, including anti-methicillin-resistant Staphylococcus aureus activity. Citral (1%) was reported to completely inhibit UVB-induced skin carcinogenesis in mice. The compound is associated with a potential to reduce the microbial load of pathogenic microorganisms and to extend the shelf life of different products. Strong sensitising effects. (Saddiq and Khayyat 2010; Idrees et al. 2019; Kremer et al. 2019; Long et al. 2019; Gutiérrez-Pacheco et al. 2023)
Citronellol Anti-inflammatory and analgesic activities were reported. Citronellol is present in the composition of many natural repellents based on citronella EOs. Strong sensitising effects. (Santos et al. 2019; Sahli et al. 2022)
Limonene Anti-obesity activity and antibacterial activity were reported. R-(+)-limonene is associated with the ability to stimulate insulin secretion in pancreatic β-cells. Limonene is used as a flavour additive in food, beverages and fragrances because of its pleasant lemon-like aroma. Dermal exposure to limonene at high levels results in skin irritation. The irritant property depends on the degree of oxidation. Some of the allergenic oxidation products include limonene hydroperoxides and R-carvone. (Ravichandran et al. 2018)
α-Terpinen The compound was reported to extend animal longevity. It is used in aromatherapy and cosmetics. Strong sensitising effects. Autoxidises on air exposure and forms allergenic compounds, including allylic epoxides and p-cymene. The compound is associated with photooxidation. (Ronzani et al. 2013; Baldissera et al. 2016)

The Scientific Committee on Consumer Safety has adopted an opinion on fragrance allergens in cosmetic products which expands the list of fragrance allergens considered relevant for consumers and makes it possible to derive a general threshold for substances with a higher number of recorded cases (SCCS/1459/11) (European Commission, Directorate General for Health and Consumers 2012).

The regulation of EOs in cosmetic products is complex and flexible. However, some novel requirements could be introduced for providing better safety. For example, constant monitoring of heavy metals and pesticide levels for every batch should be introduced. Moreover, the chemical composition of every batch should be obligatorily analysed according to the GLP standards. These quality requirements would benefit the customers and their safety. However, this will result in much more expensive production because the quality evaluation involves the work of highly specialised personnel and equipment such as GC-MS and GC-FID, and the quality analyses are often expensive.

Essential oils for food purposes

In the European Union (EU), regulations governing ЕОs utilised for food applications are stringent, aimed at guaranteeing optimal consumer safety and product quality. For EOs to be considered 100% pure and 100% natural, they need to meet specific standards and to be free from adulteration with synthetic chemicals or other oils. The quality tests include evaluation of the density, optical rotation, and refractive index; gas chromatography analyses; and others. This ensures that the EOs have the expected chemical composition and are not contaminated with impurities or substituted with cheaper oils that mimic the desired aroma. Labelling requirements for diluted oils or blends are also important for transparency. Consumers need to know exactly what they are purchasing, especially if an oil has been diluted or if it is a blend of different oils. This helps prevent misunderstandings about the oil’s strength, quality, or intended use. To enter the European food market, EOs intended for food purposes must comply with several regulations that guarantee food safety, including the General Food Law and Regulation (EC) 1333/2008. The General Food Law is essential in maintaining the safety and quality of food products. The key points of the law cover a broad range of areas—traceability, hygiene, and contaminant control. The core purpose of the General Food Law is to ensure that food products are safe for consumption and that they meet regulatory standards. It sets up the European Food Safety Authority (EFSA)—an independent agency responsible for scientific advice and support. EFSA work is regarded as crucial in maintaining the integrity of the food supply and addressing emerging issues, such as new food additives, contaminants, or novel food products like seaweed hydrocolloids.

Food supplements containing EOs—regulation

The main directive about food supplements (FS) regulation in the EU is Directive 2002/46/EC (The European Parliament and the Council 2004). Although the main function of the directive is to protect human health and to ensure safe products, many studies find the European legislation about FS quite soft and liberal. According to EFSA, FS are concentrated sources of nutrients marketed in “dose” form. A wide range of nutrients and other ingredients might be included in FS (vitamins, minerals, plant extracts, amino acids, etc.) (EFSA-Food supplements 2025). EFSA’s function in FS regulation is essential for consumer safety. EFSA experts provide a comprehensive assessment of substances that are permitted for use in FS in the EU. The assessment includes not only evaluation of the safety of a nutrient source but also the intake levels, the bioavailability, the effectiveness, and other key facts. If a company wishes to introduce a nutrient source to the EU market that is not included in the permitted list, an application must be submitted to the European Commission. The next step includes EFSA’s evaluation and scientific opinion (Directive 2002/46/EC) (Directive - 2002/46 n.d.) to support the European Commission’s evaluation of the request (The European Parliament and the Council 2004). If a substance intended to be used in the composition of an FS does not have a history of safe use in the EU before 1997, EFSA is requested to provide a scientific opinion on its safety accordingly (European Union Parliament 2015). Not all plant-derived EOs are suitable for inclusion in FS. To be incorporated into FSs, EOs must fulfil specific regulatory criteria. According to the Novel Food Regulation, an EO must possess documented evidence of significant consumption in food, sourced from a particular plant, prior to May 15, 1997 (European Union Parliament 2015). In the absence of such documentation, the EO is classified as a novel food and is not permitted for use in FS. Furthermore, the labelling of FS must include nutritional and health claims selected exclusively from those that have been authorised. This requirement presents challenges, particularly for plant extracts and their derivatives, as numerous claims are still under evaluation at the European level (Taobe Consulting 2024).

Currently, there is a great variety of FS containing EOs. Although the main purpose of FS is not treatment of medical conditions but enrichment of the diet and promotion of general well-being, many FS containing EOs claim to manage different medical conditions, including symptoms of cold and cough. Many manufacturers prefer to register their products as FS, not as HMP, because the procedure for registration is much easier and allows fast introduction of new products on the market. The areas of use of EOs included in FS are based on the ‘traditional use’ of the EOs. For example, the eucalyptus EOs HMP have been used safely for at least 30 years (including at least 15 years within the EU), and their use does not require medical supervision. The therapeutic area of eucalyptus EOs based on “traditional use” includes management of inflammation and pain and management of symptoms of cough and cold (EMA 2016b). For example, an FS called “Cough & Cold Syrup”, containing different plant extracts and eucalyptus EOs (2.6 mg in 5 mL), is available in the EU and Canada and has been launched as a fast-acting, soothing blend of herbs for the relief of sore throat and sinus congestion (Natural Factors 2025).

Other products containing pure eucalyptus EOs are available in the EU and intended for food purposes. They recommend the intake of 1–2 drops daily per lump of sugar or dissolved in water. This EO is also recommended for culinary purposes: 1 drop to smoothies, shakes, etc. (Organea 2025). It is considered that eucalyptus EO has beneficial effects on the upper respiratory tract. Many studies reported that this EO is a good natural food preservative, and its addition to food/beverages prevents food spoilage and extends the shelf life (Kumar Tyagi et al. 2014; Boukhatem et al. 2020).

Currently, many scientists find the regulation of FS in most parts of the world as too soft and even inefficient. In the last 20 years, many FS have been reported to be contaminated with many pharmacologically active substances (Costa et al. 2019; Zapata-Linares and Gervasini 2024). In almost all countries in the world, including the members of the EU, manufacturers of FS are not required to provide data on the quality analyses of their products. This resulted in the production of many poor-quality FS contaminated with pharmacologically active substances (sibutramine, diuretics, anabolic steroids, etc.) (Woo et al. 2013; Kozhuharov et al. 2025).

The levels of pesticides and heavy metals are also not obligatorily monitored (Ivanova et al. 2022). The European regulatory framework regarding FS needs some urgent improvements to ensure consumers’ safety. Some important changes must be made, including the introduction of constant monitoring of the raw materials, constant and obligatory analytical monitoring of the composition of every batch, obligatory monitoring of the FS for pesticides and lead, etc.

Volatile substances used as food flavourings – regulation

The inclusion of essential oils in foods as food additives is not currently allowed in the EU. However, many volatile compounds, naturally isolated from EOs, are included in foods as food flavourings (Medeleanu et al. 2024). The main function of the flavourings is to impart/modify odour and/or taste (Table 2). According to the EU legislation, there are several types of flavourings: flavouring substances, thermal process flavourings, flavour precursors, flavouring preparations, smoke flavourings, and other flavourings (European Commission n.d.). In the EU, the Food Flavourings Database is available online, and it is also known as the list of flavourings (Annex I of Regulation 1334/2008) in 2012 with Regulation EU 872/2012 (European Union n.d.). It contains all flavouring substances that are allowed to be used in food in the EU. The key point of the EU regulation of flavourings is to ensure the highest level of protection of human health.

Table 2.

Volatile substances used as food flavourings.

Substance Required purity Flavour/Odour Ref.
α-Farnesene At least 38% α-farnesene, 29% β-farnesene, 20% bisabolene as secondary components, and up to 10% other isomers. The odour is described as a woody, green, herbal, and floral background. (alpha-Farnesene 2012)
α-Terpinene Not less than 89% α-terpinene and secondary components 6-7% 1.4- and 1.8-cineole. It has a lemony and citrussy odour. Its taste is also described as predominantly lemony at concentrations under 40 ppm. However, the taste is described as rather bitter at higher levels. (alpha-Terpinene n.d.)
γ-Terpinene 95% Herbaceous, citrussy aroma and flavour, reminiscent of lemon. Often it is described as resembling that of α-terpinene, but warmer. (gamma-Terpinene 2012)
Carvone 95% R-(−)-carvone has a minty aroma and flavour. S-(+)-carvone is associated with a spicy aroma. (Carvone 2012; European Commission n.d.)
Geranyl acetate At least 90%, with secondary components 4–6% geraniol and 1–2% nerol. Its odour and flavour profiles are described as sweet, fruity-floral, rose, and fresh. (Geranyl acetate 2012)
Limonene 95% Flavour and odour of citrus, lemon-like. (Limonene 2012)
Linalool 95% Its odour is often described as floral and spicy wood. It has a light, citrussy taste, sweet with a spicy tropical accent. (Linalool 2012)
Menthol 95% Typical minty aroma and flavour with a well-known cooling characteristic. (Menthol 2012)
Myrcene 95% The aroma is earthy, fruity and clove-like. Slightly sweet flavour profile. (Myrcene 2012)
Sabinene hydrate 95% The flavour is a combination of citrus, wood, pine and mint. (Sabinene hydrate 2012)

Regulation of essential oils used as active pharmaceutical ingredients

The European Pharmacopoeia (Ph. Eur.) serves as the primary reference for the quality control of medicines and their ingredients within the EU. Important data about EOs are included in General Chapter 5.30, titled “Monographs on Essential Oils”, and in many individual monographs that define legally binding quality standards (Essential Oils: Revised Monograph and New General Chapter in the Ph. Eur. 2021). These monographs provide comprehensive analytical methods for the identification and quality assessment of essential oils (EMA 2014b; EDQM 2021).

In the EU, EOs intended for medical use are regarded as herbal medicinal products (HMP). The Committee on HMP in the EU is responsible for scientific opinions on herbal substances and preparations on behalf of the European Medicines Agency (EMA). Companies willing to introduce HMP to the EU market must follow the specific national procedures overseen by national competent authorities (NCAs) (EMA 2025).

The list of NCAs includes but is not limited to the Austrian Agency for Health and Food Safety, the Federal Agency for Medicines and Health Products (Belgium), the Bulgarian Drug Agency, the Agency for Medicinal Products and Medical Devices of Croatia, the Ministry of Health – Pharmaceutical Services (Cyprus), the State Institute for Drug Control (Czechia), the Danish Medicines Agency, the National Agency for the Safety of Medicine and Health Products (France), the National Organisation for Medicines (Greece), the Icelandic Medicines Agency, the Health Products Regulatory Authority (Ireland), and others (EMA 2025).

In general, three regulatory pathways have been developed for the introduction of HMP in the EU market:

  • Traditional use registration (Article 16a(1) of Directive 2001/83/EC)—in this case, no clinical tests or safety and efficacy trials are required because there are sufficient safety and efficacy data. The assessment is based mostly on bibliographic data. However, these products must be used for more than 30 years and at least 15 years in the EU.
  • Well-established use marketing authorisation (Article 10a of Directive 2001/83/EC)—the assessment is based mostly on bibliographic data. Scientific data about the active substances of the medicinal products have been used in well-established medicines within the EU for at least ten years.
  • Stand-alone or mixed application (Article 8(3) of Directive 2001/83/EC)—the safety and efficacy data are based on the company’s own research or a combination of their own studies and well-established scientific data (European Union n.d.).

In the EU, medicines that do not fall under the centralised procedure are authorised by NCAs. This means that each EU Member State has its own authority responsible for the evaluation and approval of medicines intended for the national market. However, the centralised procedure is reserved for certain medicines, including those with a significant public health interest or innovative treatments, which are both authorised by the EMA.

In general, EOs are widely used in the cosmetic and food sectors, while the use within the pharmaceutical sector represents a small part of the global EOs market. The production of EOs is often performed by small companies with limited experience in the manufacturing of active pharmaceutical ingredients (APIs) for pharmaceutical use. All companies that produce APIs in the EU must follow the “Good manufacturing practice for active pharmaceutical ingredients” (EMA 2000). The starting material used in the production of EOs is fresh plant material. The producers of plants for medicinal purposes must follow the “Good agricultural and collection practice for starting materials of herbal origin”.

The European Medicines Agency has published specific guidelines on HMP that provide valuable guidance to pharmaceutical companies in preparing marketing authorisation applications for medicines used in human and veterinary medicine (Table 3).

Table 3.

Scientific guidelines for herbal medicinal products.

Name Key points of the document Ref.
Declaration of herbal substances and herbal preparations in HMP/traditional HMP It explains the principles for uniform declaration of herbal substances/preparations and provides guidance on package leaflets, labelling, etc. (EMA 2023)
Good agricultural and collection practices for starting materials of herbal origin Quality assurance, personnel and education, buildings and facilities, equipment, documentation, seeds and propagation material, cultivation, collection, harvest, primary processing, packaging, storage and distribution. (EMA 2024)
Quality of combination herbal medicinal products/traditional herbal medicinal products Quality of combination HMP. (EMA 2008)
Quality of herbal medicinal products/traditional herbal medicinal products Qualitative and quantitative particulars of the active substance/s of HMP, declaration of the active substance, manufacturing process, control of herbal substances, and others. (EMA 2008)
Specifications: test procedures and acceptance criteria for herbal substances, herbal preparations and herbal medicinal products/traditional herbal medicinal products Tests, procedures, and acceptance criteria used to ensure the quality of the herbal substances/preparations and HMP. (EMA 2022)

The European Medicines Agency regularly publishes documents about the scientific conclusions reached by the Committee on Herbal Medicinal Products (HMPC) on the medicinal uses of different EOs (EMA 2016d) (Table 4). The European Union herbal monographs on some aromatic plants are also published on the EMA website (Valerianae aetheroleum 2016). These monographs include data about the qualitative and quantitative compositions, pharmaceutical forms, therapeutic indications and methods of administration, contraindications and precautions, interactions with other medicinal products/other forms of interaction, effects on fertility and pregnancy, effects on ability to drive and use machines, and other information.

Table 4.

Data about some EOs included in the HMP in the EU.

EO and botanical names of the plant species Production process Medical applications Adverse reactions Safety concerns Ref.
Anise EO* Pimpinella anisum L. Steam distillation of the dry fruits. Symptoms of mild indigestion complaints, and as an expectorant for coughs associated with colds. Nausea, vomiting, skin rash. Aniseed EO HMP must not be used on children and adolescents under 18 years. (EMA 2016a)
Eucalyptus EO could be isolated from: Eucalyptus globulus Labill., Eucalyptus polybractea R.T. Baker, Eucalyptus smithii R.T. Baker This EO is obtained from fresh leaves/terminal branches by a current of steam. Pain and inflammation, cough and cold. No adverse reactions were reported. The peroral intake is recommended only for adults and adolescents from 12 years of age. For skin application it could be used from the age of 4. (EMA 2016b)
Caraway oil* Carum carvi L. This EO is obtained by a current of steam through the dried fruit. Gastrointestinal disorders. No adverse reactions were reported. Not recommended to be used in patients with liver or biliary disorders. (Carvi aetheroleum 2015)
Cinnamon Bark Oil Cinnamomum verum J. S. Presl, Cinnamomum zeylanicum Nees Steam distillation (cortex). Gastrointestinal disorders, including bloating and flatulence. Local irritation of the oral mucosa has been reported. Must not be used on children and adolescents under 18 years. (EMA 2009)
Clove oil Syzygium aromaticum (L.) Merr. et L.M. Perry Steam distillation (dried flower buds). Treatment of inflammations in the mouth or the throat. Mucosal irritations, allergic reactions Not to be used for longer than 1 week. (EMA 2010)
Matricaria Oil* Matricaria recutita L. Steam distillation. Skin disorders and minor wounds. Allergic reactions Should be used only by adults and from the age of 12. (EMA 2016c)
Valerian EO* Valeriana officinalis L. Steam distillation of underground parts. Sleep disorders and stress management. Nausea and abdominal cramps. Skin problems, infections, and circulatory problems are regarded as contraindications for bathing with valerian EO. (EMA 2016d)
Peppermint EO* Mentha x piperita L. Steam distillation from fresh aerial parts of the flowering plant. Pain and inflammation, cough and cold, and gastrointestinal disorders. Allergic reactions, headache, slow heart rate, tremor, contact sensitivity on the mucosa, nausea, and vomiting. When inhaled, side effects include apnoea and broncho- and laryngoconstriction in allergic patients. (EMA 2020a)
Lavender EO* Lavandula angustifolia Mill. Steam distillation from flowering tops of the plant. Sleep disorders, mental stress and mood disorders. Rare cases of allergic reactions. Individuals with open wounds, skin problems, and severe infections should not have full baths with this EO. (EMA 2014a)
Tea tree oil* Melaleuca alternifolia Cheel Steam distillation from fresh leaves and terminal branches. Mouth and throat disorders; skin disorders and minor wounds. Itching, burning sensation, skin irritation. Burn-like skin reactions have been reported rarely. (EMA 2017)
Thyme oil* Thymus vulgaris L. Steam distillation from the fresh flowering above-ground parts. Cough and cold Allergic reactions and skin irritation. Must not be used by patients with open wounds, extensive skin injuries or acute skin diseases. Should not be applied to the face. (EMA 2020b)

Currently, the number of medicines that contain EOs in the EU is relatively low. However, the research on EOs is significant, and it is expected that many novel medicines based on EOs will be introduced soon.

Essential oils included in medical devices

Medical devices (MD) encompass a great variety of products/equipment. In general, all these products are intended for medical purposes. According to the EU regulation, MDs must undergo a conformity assessment to demonstrate they meet all legal safety and utility requirements regulated at the EU Member State level. However, the EMA is also involved in the regulatory process. There are several distinct groups of MDs, and EMA’s responsibility vary among them. Manufacturers can place a CE symbol on their product once it has passed a conformity assessment (CA). The CE symbol derives from the French “Conformité Européenne” (conformity assessment). Generally, the conformity assessment involves evaluation of the manufacturer’s quality system, review of technical data provided by the manufacturer regarding safety, and review of technical data on the performance of the device. In the EU, the regulation about MD is called Regulation (EU) 2017/745, and the companies must comply with it when introducing new MD on the market. It repeals the following directives: Directive 93/42/EEC and Directive 90/385/EEC (EMA 2019). The number of medical devices containing EOs is limited in the EU. Most of these products are used as sprays for nasal congestion and include many different ingredients, including EOs.

Conclusion

The European market of EOs is associated with several important features, including EO industry growth and high levels of utilisation of EOs in the food industry, cosmetic industry, and pharmaceutical sector. The regulations concerning EOs are quite diverse, depending on the purpose of their applications. In the present review, some regulatory challenges associated with EOs were discussed. It is considered that there is a need for additional requirements for manufacturers of FS to ensure the highest levels of safety and quality. Although the regulation on EOs in cosmetic products is complex and detailed, some novel requirements could be introduced for providing better safety for cosmetics in the EU. For example, constant monitoring of heavy metals for every batch should be introduced. Moreover, the chemical composition of every batch should be subject to obligatory analyses according to the Good Laboratory Practice standard. These quality requirements would benefit customer safety. However, this will result in much more expensive production. Many volatile compounds, isolated from EOs and used in the cosmetics industry, are regarded as skin sensitisers because they are susceptible to autoxidation and can provoke allergies. It is essential that their concentrations are monitored for every batch released on the market. The skin-sensitising potential of these compounds is mainly attributed to the hydroperoxides detected at high concentrations in the oxidation mixtures. It is considered that such hydroperoxides can lead to the production of specific antigens. Moreover, it is considered that the hydroperoxides react with skin proteins through mechanisms involving radical intermediates. There is a need for novel strategies for monitoring the skin-sensitising potential of these compounds and constant improvements in the legislative framework to ensure the highest level of safety.

Acknowledgments

This study was supported by the European Union-NextGener-ationEU, through the National Recovery and Resilience Plan of the Republic of Bulgaria, project № BG-RRP-2.004-0007-C03

Additional information

Conflict of interest

The authors have declared that no competing interests exist.

Ethical statements

The authors declared that no clinical trials were used in the present study.

The authors declared that no experiments on humans or human tissues were performed for the present study.

The authors declared that no informed consent was obtained from the humans, donors or donors’ representatives participating in the study.

The authors declared that no experiments on animals were performed for the present study.

The authors declared that no commercially available immortalised human and animal cell lines were used in the present study.

Funding

No received funding.

Author contributions

All authors have contributed equally.

Author ORCIDs

Stanislava Ivanova https://orcid.org/0000-0003-1282-7868

Kalin Ivanov https://orcid.org/0000-0002-5689-2920

Yana Gvozdeva https://orcid.org/0000-0002-7622-6060

Radiana Staynova https://orcid.org/0000-0002-8466-3236

Daniela Grekova-Kafalova https://orcid.org/0000-0002-4105-9485

Maria Hristozova https://orcid.org/0000-0001-9815-1496

Data availability

All of the data that support the findings of this study are available in the main text or Supplementary Information.

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