Launched in March 2023, the CMA’s probe into suspected anti-competitive conduct in the supply of fragrances and fragrance ingredients underscores the regulator’s commitment to fostering fair competition.
In the ever-evolving world of consumer goods, the fragrance industry plays a pivotal role in enhancing everyday products like perfumes, soaps, and cleaning supplies. However, recent developments from the UK’s Competition and Markets Authority (CMA) have cast a spotlight on potential misconduct within this niche.
As experts at The Competition Lawyers, we break down this high-stakes investigation to help businesses and stakeholders navigate its implications.
At the heart of the CMA’s scrutiny are reportedly three major global players: Firmenich International SA, Givaudan SA, and International Flavors & Fragrances Inc., along with their UK subsidiaries. These companies dominate the market for supplying fragrances and fragrance ingredients used in household and personal care products. The allegations centre on potential breaches of Chapter I of the Competition Act 1998, reportedly including coordinated behaviours that could stifle innovation and inflate costs.
A significant expansion is understood to have occurred in January 2024, when the investigation broadened to examine suspected unlawful “no-poach” agreements—reciprocal arrangements among these firms to restrict hiring or recruitment of key staff. Such practices, if proven, could limit talent mobility and hinder the sector’s dynamism. Notably, in May 2025, the CMA closed its review of Symrise AG on administrative priority grounds, allowing the focus to sharpen on the remaining trio. As of September 2025, the case remains active, with no statement of objections issued yet, signalling that evidence gathering and analysis are ongoing.
Delving deeper, the CMA’s examination encompasses the entire supply chain for fragrances and fragrance ingredients, from raw material sourcing to final formulation for consumer applications. This includes visitations, information requests, and state-of-play meetings with the involved parties, all aimed at uncovering whether anti-competitive pacts have distorted market pricing or reduced product variety.
The probe’s extension to staff recruitment issues reportedly highlights a growing regulatory trend: treating labour markets as critical competition battlegrounds. If substantiated, these findings could lead to fines up to 10% of global turnover, reshaping hiring norms in the fragrance sector.
With the next update slated for March 2026, businesses in adjacent industries—such as cosmetics and detergents—should monitor closely, as ripple effects could influence ingredient costs and supply reliability.
For companies reliant on fragrances and fragrance ingredients, this investigation serves as a cautionary tale about the perils of informal collaborations. Potential outcomes include not only penalties but also mandated behavioural remedies, like enhanced compliance programs or divestitures, to restore competitive balance. Consumers could stand to benefit from lower prices and more innovative scents if fair play is enforced, yet short-term disruptions in supply chains remain a risk.
From a legal standpoint, this case exemplifies the CMA’s proactive stance in proactive enforcement, aligning with EU and global antitrust trends. It reminds industry leaders that even subtle agreements can trigger intense scrutiny, emphasising the need for robust internal audits and legal counsel.
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