CMA Timetable Update Shows Chapter I Investigation into Fragrances and Fragrance Ingredients Supply, Open Since 2023, Still Ongoing Against Firmenich, Givaudan and IFF
The Competition and Markets Authority opened its formal investigation into suspected anti-competitive conduct in the supply of fragrances and fragrance ingredients on 7 March 2023, under Chapter I of the Competition Act 1998. The investigation names Firmenich International SA, Givaudan SA and International Flavors & Fragrances Inc; a fourth party, Symrise AG, was dropped from the case in May 2025 on administrative priority grounds. In January 2024 the CMA extended the scope to cover suspected unlawful coordination on the hiring and recruitment of staff involved in the supply of fragrances and fragrance ingredients. The case (reference 51257) remains open: its timetable was most recently updated on 29 September 2026, with the investigation described as ongoing.
Why this matters
A Chapter I CA98 investigation signals the CMA suspects a prohibited agreement, concerted practice, or decision by an association of undertakings, potentially price-fixing, market-sharing, or information exchange. The fragrance ingredients sector supplies inputs across FMCG, personal care, and luxury goods, meaning downstream effects could be wide. CMA investigations at this stage carry significant reputational and legal risk for any parties involved, even before any statement of objections is issued.
On the Ground
Competition lawyers will be advising clients in the fragrance supply chain on dawn-raid preparedness, legal privilege, and leniency applications under the CMA's immunity programme. Trainees would typically assist with document preservation notices, privilege logs, and reviewing internal communications for potentially sensitive materials. The investigation may also prompt parallel reviews in EU member states under ECN+ cooperation mechanisms.
Interview prep
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“What are the immediate steps a fragrance supplier should take on learning it may be within scope of a CMA Chapter I investigation?”
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