EU Classification Update

9 Feb

When we began coordinated engagement through the World Trade Organisation's (WTO) Technical Barrier to Trade (TBT) process in October 2025, our objective was clear:

To ensure the EU’s proposed classification of Tea Tree Oil was understood internationally not as a narrow "industry issue", but as a measure with significant and disproportionate trade impacts.

We can now confirm that this effort has materially disrupted business as usual in Brussels.

Friction in the System

To give a sense of the current atmosphere: during the recent CARACAL meeting, EU officials reportedly remarked that some of their most complex and high-profile regulatory files included ATP 24. While the tone was informal, the comment underscores a genuine reality that ATP 24 (which includes Tea Tree Oil) is no longer progressing quietly through the system and is generating visible friction.

The European Commission has been taken aback by the volume and coordination of international engagement. Tea Tree Oil is no longer just another file on the desk.

Turning the Tide: Unprecedented Pressure

While the EU retains discretion in how it proceeds, we have significantly raised the political, trade and reputational cost of moving forward without properly addressing the scientific and procedural concerns. Pressure is now being applied across multiple fronts:

Government-to-Government Engagement — The Hon Julie Collins MP, Australian Minister for Agriculture, has formally written to the European Commission expressing concern that the proposed classification is not supported by current scientific evidence and would have disproportionate trade impacts on Australian primary producers. This intervention significantly strengthens the credibility of the industry’s position.
International Trade Pressure from Five countries — Australia, China, the United States, South Africa and Israel have now raised concerns through the WTO TBT process. It is rare to see this degree of convergence on a chemical classification issue. ATTIA’s input and coordination, through Tim Valentiner from Alltruix, ATTIA’s Regulatory Committee and Australia’s Brussels Mission, has played a central role in informing these submissions.
Public and Economic Narrative — Australia's national broadcaster's (ABC) Landline program is currently filming a segment on the potential impact of the EU proposal on the Australian tea tree industry, expected to air later this month. In parallel, ATTIA has contributed data to IFEAT’s socio-economic impact work to demonstrate the regional employment and supply-chain consequences of the proposal.

The Science: A Constructive Off-Ramp

Alongside trade and diplomatic engagement, we continue to engage constructively on the science.

At CARACAL, Tim Valentiner presented the Tea Tree Oil Scientific & Regulatory Roadmap — an expert-led proposal to address the data gaps acknowledged by EU bodies themselves. The roadmap has been developed with input from an international panel of technical and regulatory experts (including five toxicologists) and is supported by several major global brands.

This positions the industry not as opposing regulation, but as offering a credible pathway to resolve scientific uncertainty in a way consistent with the EU’s own regulatory principles.

A Note on the SCCS Opinion

You may have seen the recent SCCS Opinion confirming the safety of Tea Tree Oil for use in cosmetics. This is an important validation of the existing safety data and supports continued market access under the Cosmetics Regulation.

However, it is important not to conflate this with the CLP hazard classification process. The proposed Category 1B classification remains a separate regulatory track. While the SCCS Opinion strengthens the case for exemptions under the Cosmetics Regulation, it does not resolve the classification issue itself.

The Reality & The Road Ahead

The EU regulatory system is large and procedurally complex. There remains a real risk that the proposal could advance despite the issues raised.

That said, the process is no longer frictionless. The trajectory has slowed and meaningful scrutiny has been introduced.

In the coming days, ATTIA will submit a detailed background and technical report to the European Commission outlining key scientific and procedural inconsistencies in the underlying assessment. Parallel legal and procedural options are also being explored to ensure all available avenues remain open.

This progress is the direct result of coordinated industry action. Continued engagement over the coming months — through government channels, trade processes and scientific dialogue — will be critical as the proposal moves closer to an adopted decision in Europe.

How You Can Support This Work

Several ATTIA members have asked how they can assist as this process continues.

This engagement is being supported through a combination of ATTIA coordination and in-kind and technical contributions from across the global essential oils and cosmetics sector.

We have benefited from valued input from international partners, including EFEO and from access to EU-based regulatory consultants made available by several major brands. Other companies have also contributed data, technical insight and regulatory contacts to help ensure the industry’s case is well informed and effectively communicated.

At present, ATTIA’s regulatory and scientific coordination role — including engagement with EU institutions, WTO processes and CARACAL — is supported through a time-limited external consultancy arrangement with Alltruix (Tim Valentiner). Current funding covers this work through to 15 February.

If ATTIA members, their customer’s, or other interested parties wish to contribute to extending this engagement to maintain momentum through the next critical phase of the EU process, ATTIA would welcome expressions of interest in providing additional financial support. Any such support would be managed transparently through ATTIA and applied solely to regulatory and scientific coordination activities.

If you are interested in discussing this further please contact ATTIA (ceo@attia.org.au) or an ATTIA Board member.

ATTIA team