If you produce e-liquid in Indonesia and you have been hearing more about CMR substances recently, this article is for you. The regulations are changing and the compounds inside your flavor concentrates matter more than they did couple of years ago.
Here is what CMR means, which compounds are on the list, and what you need to do.
What CMR Means
CMR stands for Carcinogenic, Mutagenic, or Reprotoxic. It is the classification system used by the European Chemicals Agency to identify chemicals that may cause cancer, genetic damage, or harm to reproduction.
There are two categories. Category 1 means the harm is confirmed or strongly indicated based on scientific evidence. Category 2 means there is reasonable suspicion of harm based on available data.
Under EU law, Category 1 CMR substances are prohibited in consumer products above very low concentration limits. Under the EU Tobacco Products Directive, any substance with CMR properties is prohibited in e-liquid entirely, regardless of concentration. There is no permitted level. The prohibition is absolute.
Indonesia’s own PerBPOM 18/2025, which takes full effect on July 26, 2026, requires full ingredient disclosure to BPOM and laboratory-verified proof that your additives are safe. If your formula contains a CMR substance, you will not be able to meet this requirement.
Why This Matters for Your Business
There are two practical consequences.
The first is export. If your e-liquid contains a CMR substance in its flavor formula, it cannot enter the EU, UK, or any market aligned with those standards. This applies regardless of how small the concentration is in the final bottle.
The second is domestic compliance. From July 26, 2026, you are required to disclose every ingredient in your product to BPOM and provide safety testing evidence. CMR substances will fail that test.
The 21 Compounds on the List
The following compounds have been identified by Argeville’s regulatory team as CMR-classified substances found in flavor samples from the Indonesian and Southeast Asian market. Each one is a real flavor ingredient used in real products. Many of them appear in flavors that are popular and widely used right now.
Acetaldehyde is a fresh, fruity aldehyde found naturally in fruit and coffee. It is classified as a Category 1B carcinogen. It is specifically tested for in EU and UK e-cigarette emissions assessments and is not permitted in regulated e-liquid formulas.
Acetophenone provides sweet, almond, and floral notes used in fruit and nut flavors. It is classified as Category 2 for reproductive toxicity.
Anisaldehyde delivers sweet, floral, and anise-like character used in oriental flavor profiles. It is classified as Category 2 for reproductive toxicity.
Benzaldehyde is the compound behind cherry and almond flavors. It is one of the most widely used flavor chemicals in e-liquid globally, found in around 31% of products tested in published research. It is classified as Category 2 for reproductive toxicity. Its widespread use makes it one of the most commonly present CMR substances in undocumented flavor concentrates in Indonesia.
Cumin aldehyde provides warm, spicy, and herbal notes from cumin. It is classified as Category 2 for reproductive toxicity.
Cyclamen aldehyde is a synthetic compound used in floral and green applications. It is classified as Category 2 for reproductive toxicity.
Delta-3-carene is a terpene found in pine and citrus oils contributing fresh, woody, and sweet notes. It is classified as Category 2 for reproductive toxicity and is a known respiratory irritant at higher concentrations.
Diphenyl oxide has a floral, geranium-like character used in certain floral formulations. It is classified as Category 2 for reproductive toxicity. Testing of Indonesian market samples has found it at concentrations between 0.2% and 0.6% inside flavor concentrates. That is a significant level for a compound with this classification.
Estragol is found naturally in basil, tarragon, and anise and provides sweet, herbal, and spicy notes. It is classified as a Category 1B carcinogen. Research on e-liquid composition has found estragol at levels high enough to present a calculated cancer risk in some products. Under the EU TPD it is not permitted in e-liquid at any level.
Furfural provides warm, woody, bready, and almond notes used in coffee and caramel profiles. It is classified as a Category 2 carcinogen. It has been detected in e-cigarette aerosol in published studies, and its levels increase with device power and the presence of sweeteners in the formula.
Gamma-terpinene is a citrus terpene from thyme and coriander contributing fresh, herbal notes. It is classified as Category 2 for reproductive toxicity.
Heliotropin, also known as piperonal, provides sweet, floral, vanilla-like notes and is used widely in dessert and oriental profiles. It is on the IFRA restricted list and international buyers are increasingly requiring zero inclusion as a condition of purchase.
Hexane is an industrial solvent that can appear in flavor concentrates as a residual from natural extraction processes. It is classified as Category 2 for reproductive toxicity. Its presence in a concentrate means the raw material was not sufficiently purified.
Isophorone is a minty, camphoraceous ketone used in some complex flavor applications. It is classified as Category 2 for carcinogenicity.
Keto-isophorone is a related compound used in floral and woody applications. It is classified as Category 2 for carcinogenicity.
Methyl benzoate is a fruity, floral ester found naturally in cloves and ylang-ylang. It is classified as Category 2 for reproductive toxicity.
Methyl eugenol provides sweet, spicy, and clove-like notes found naturally in basil and cinnamon. It is classified as a Category 1B carcinogen. Under the EU TPD it is not permitted in e-liquid at any level.
Methyl salicylate is the compound behind wintergreen flavor, widely used in mint and cooling profiles. It carries a specific EU restriction for products accessible to consumers under 18. For any brand selling internationally, its presence requires documented justification.
Para-cymene provides warm, spicy, herbal notes from thyme and cumin. It is classified as Category 2 for reproductive toxicity.
Styrene is an industrial chemical that can appear in e-liquid as a contamination or degradation product from certain flavor components or heating processes. It is classified as Category 2 for carcinogenicity. Traces have been detected in e-cigarette vapor in multiple studies. Its presence in a formula requires immediate investigation.
Toluene is a solvent that can appear as a residual in flavor concentrates made from certain aromatic raw materials. It is classified as Category 2 for reproductive toxicity with well-documented effects on fetal development. Like hexane, its presence indicates a purification problem in the source material.
The Most Important Question to Ask Right Now
Do you know whether any of these 21 compounds are present in the flavor concentrates you are currently using?
Most Indonesian producers cannot answer that question. Their supplier never provided the compound-level documentation needed to know. A general product description or a food-grade safety certificate does not tell you which specific chemicals are in the formula.
The only way to get a definitive answer is GC-MS analysis of the actual flavor material. This test separates the concentrate into every individual compound it contains and identifies each one. It tells you exactly what is in your formula, including anything your supplier did not disclose.
What You Should Do Before July 2026
Ask your flavor supplier for a full technical datasheet showing every compound in the formula and its regulatory classification under EU REACH and IFRA standards. A supplier with properly documented, compliant formulas will have this document ready.
If your supplier cannot provide it, get your flavors tested independently before you submit anything to BPOM. Finding a CMR compound after you have already filed your ingredient disclosure is a far more difficult situation than finding it now while you still have time to reformulate.
Reformulation takes time. Re-registration takes time. Starting now puts you in control of that process.
If you are based in Indonesia and need access to GC-MS testing or compliant flavor documentation, we are based in Bandung and work with a certified R&D laboratory in France. We are happy to help.
Are all 21 compounds on this list equally serious from a regulatory standpoint?
No. The most serious are the Category 1B carcinogens: acetaldehyde, estragol, and methyl eugenol. These are prohibited in e-liquid under the EU Tobacco Products Directive at any concentration. The Category 2 substances are subject to concentration limits under REACH, but under the TPD’s categorical prohibition for e-liquid they are also not permitted without strong justification. The solvents, hexane, toluene, and styrene, indicate a purification problem in the flavor manufacturing process rather than an intentional addition, and their presence needs to be investigated at the source.
Many of these compounds are natural. Why are they classified as CMR?
The CMR classification is based on the chemical properties of a compound and the evidence about its biological effects. Natural origin does not change those properties. Estragol occurs in basil. Methyl eugenol is in cinnamon. Acetaldehyde forms naturally during fermentation. The regulatory position is that for products designed to be inhaled, the safety standard is higher than for food, and that natural occurrence in food does not provide an exemption from CMR classification or the inhalation prohibition.
My supplier says their product is food-grade. Is that enough?
No. Food-grade compliance and e-liquid inhalation compliance are two different standards. A substance can be fully approved for use in food and still be prohibited in an inhalation product. Food-grade status was never assessed with inhalation in mind. A supplier declaration also reflects the formula as intended, not what analytical testing of the actual material would find. GC-MS analysis of the concentrate you actually receive is the only way to know what is really in it.
Does finding a CMR compound in my flavor mean my product has harmed consumers?
Finding a CMR compound in your formula does not mean your consumers have been definitively harmed. What it means is that your product cannot legally enter regulated export markets, and that it will not pass the additive safety testing required by PerBPOM 18/2025. The purpose of identifying these compounds is to give you the information you need to make the right decisions going forward, while you still have time to act on them.
