What is really going on with EU fragrance regulations


11th June, 2015

Jean-Michel is 45. He gets up every morning raring to go. He adores his job. He performs his morning routine, eats a croissant and drinks a cup of very dark coffee, then heads off to work for one of the world’s largest fragrance and flavour manufacturers. Every day offers a new challenge. Today he will be trying to convince EU bureaucrats that rose oil should be banned so that his company could corner the market with a new aroma chemical.

Jean-Michel is fictional. No such person exists. The idea that IFRA is an inside job to kill the natural raw material side of the fragrance industry may seem like an attractive conspiracy theory at first, but upon even cursory examination, this idea falls apart.

"The idea that IFRA is an inside job to kill the natural raw material side of the fragrance industry may seem like an attractive conspiracy theory at first, but upon even cursory examination, this idea falls apart."
Natural fragrance materials represent a sizeable chunk of the fragrance and flavour industry’s profits (and this includes the main IFRA members). Creating new aroma chemicals is extremely costly, a big risk, and burdened with its own regulatory pressures. Never mind the all too real possibility that an aroma chemical you have brought to market gets restricted or even banned by IFRA in the future if it is found to be problematic by their standards.

If IFRA were an inside job, this sort of thing would never happen. In fact, the cost and other issues surrounding bringing a new aroma chemical to market are so serious that the production of new aroma chemicals has slowed right down and can be partly blamed for more-of-the-same fragrance launches lately.

Fragrance chemist Charles Sell told a recent BSP audience that it is best to prioritise regulatory compliance over every other aspect, even odour, when designing new aroma molecules. That’s the reality now – unless the material can leap over the regulatory hurdle, nothing else matters. That famous Beaux quote “The future of perfumery is in the hands of chemists. We’ll have to rely on the chemists to find new chemicals if we are to make new and original accords” has a bittersweet tang in today’s world.

Finally, having to reformulate a fragrance falls within the remit of the fragrance supplier – not the brand that markets the product (unless the brand creates its fragrances in-house; a rare situation) – which means it would be sheer insanity to deliberately push for ingredient bans. The cost of replacing a single material can be extremely high, especially if it has been ubiquitous across several products and categories.

The cost of reformulating everything to remove natural materials entirely would be astronomical. Entire businesses would simply stop being able to function. That’s not to say reformulation doesn’t happen all the time. Sometimes it’s because a new IFRA amendment has come into effect and certain materials have to be replaced or adjusted. Sometimes a new material becomes available which allows tweaking of the formula to make it cheaper to produce, or to restore an element previously lost to regulatory or cost pressures.

There is a constant race to produce replacement materials for key banned or restricted ingredients – but it’s important to understand that those replacement materials are subject to the same pressures as new, novel molecules. It is an expensive business and it would usually make much more sense to stick to the original ingredient. Sometimes fragrances are reformulated in an attempt to calibrate the scent to better suit modern tastes. Sometimes it’s easier to discontinue a product than to reformulate the fragrance. I sometimes talk about ‘zombie perfumes’ – scents which have been killed but are still walking around. It would be a kindness to let them go.

"Sometimes it’s easier to discontinue a product than to reformulate the fragrance. I sometimes talk about ‘zombie perfumes’ – scents which have been killed but are still walking around. It would be a kindness to let them go."
The regulatory landscape is quite complex. Most perfume enthusiasts – and sometimes even people who work for fragrance brands and cosmetics companies – seem to mainly talk about IFRA, and often misunderstand what is really behind the changes, or what IFRA is really trying to do.

In fact, it does seem that public perception of fragrance regulations israther muddled – but understandably so. It’s not a topic that naturally lends itself to great stories. It’s not something that anyone who wishes to be thought of as fun at parties would willingly discuss at length in a social setting.

Nevertheless, with such an increased interest in what goes on ‘behind the scenes’ in the fragrance industry, the last few years have seen more than one article and blog post pop up about the impact of fragrance regulations on our beloved perfumes.
The first thing that these articles often get wrong is the structure of the regulatory scene; where the pressure is coming from, and how the regulations and recommendations inter-relate. The real picture is quite complex and the worry is perhaps placed in the wrong area of it. There certainly are gloomy potential outcomes, but the situation is not as it first may seem.

Structure of the fragrance industry

Above is a simplified overview of how the fragrance industry is structured. In the above context, DIY indie perfumers would fall under “manufacturer/retailers”. A more common path for a fragrance ingredient to end up in a consumer product would be grower → distiller → importer (which can sometimes be the fragrance manufacturer itself) → fragrance manufacturer → brand → contract manufacturer → retailer → consumer.

Ingredients come from rose fields, orange groves and chemical plants and can go through a long journey from source to shower gel. One way for a drop of rose oil to end up in a consumer product would be:

  1. The local rose grower harvests his crop and takes it to the distiller; gets paid for his harvest
  2. The distiller sells his rose oil direct to a fragrance manufacturer
  3. The rose oil gets used in a winning fragrance brief by the fragrance supplier
  4. The fragrance compound is sold to a brand who gets their contract manufacturer to put it into a product.

Along the way, the oil will have come under several laws and regulations. The finished product that contains it will have to pass a safety assessment before it can be sold to consumers. This is where IFRA certificates come in; they are required by safety assessors.

What would it take for us to live in a completely risk-free society?

Just think about that for a moment. When you have a shower, you might scald yourself. When you drink your morning coffee, you might choke on it. When you step out and walk along the pavement, you might get hit by an out-of-control vehicle. When you sit down at your desk, you could spill your glass of water on your laptop and get electrocuted. I could go on – but it’s fairly obvious that we just can’t remove all risk from our lives.

It does seem baffling that some bureaucrats seem to try, and in some countries the idea of protecting the general public has perhaps gone too far.

In Finland, cinnamon is a traditional topping for rice pudding, which is frequently served at school. Recently cinnamon was banned in schools because of its coumarin content. Would the general public of Finland be aware of the chemical constituents and potential toxicity of a familiar and much-loved spice? No. Does the amount of coumarin in the typical amounts of cinnamon ingested represent any significant risk to most people? No. When children are concerned, perhaps it’s a grey area. They have smaller body mass after all, and may therefore end up with more coumarin in their system from eating an amount that would not be considered harmful to an adult. It does seem a bit like cracking a walnut with a hammer. Finland is famous for taking the cosseting of consumers too far. Of course there were cries of “but we’ve always eaten it and nothing has happened!”

Appeal to tradition is not logical though, or we would still be sweetening our wine with lead, as the Romans did. Not everything that we’ve done happily in the past, unaware of the harm we were causing to ourselves or the environment is okay to continue doing today, once we become aware of the dangers. Smoking was once advertised as a healthy habit. Not even the staunchest of smokers can credibly claim that any more.

It’s hard to know what the right thing to do is when new information becomes available which shows a substance previously loved and heavily used has some dangerous, even toxic properties. Surely the correct thing would be to raise awareness and let people make their own decisions?

When it became apparent that the PPD (paraphenylenediamine) in hair dyes could lead to anaphylactic shock (a life-threateningly severe allergic reaction), permanent disfigurement, or even death; hair salons and box-hair-colour manufactures in the EU had to add warnings to their products and instruct consumers to perform a hair colour allergy test before applying the product. Yet most consumers seem to ignore these warnings, with the thought being “I’ve used it for years and I’ve always been fine.” This is a potentially deadly mistake. Allergies develop over time. Some allergies develop slowly, and only become apparent after years of repeated exposure. One day a woman who has dyed her hair with the same brand of hair colour for 10 years might suddenly react to it because her body has finally developed an allergy to it.

Anaphylaxis is quite a serious allergic reaction, and people have really died from it. Yet the ingredient was not banned. Is it right to allow such a material to be used so widely when the general level of understanding of its danger is poor? Is it okay to leave it in a commonly used product when most people do not understand that just because they were not allergic to it before doesn’t mean they won’t become allergic to it in the future?

When we are exposed to an allergen, our body develops an immune response to it. In some cases, over time, this develops into an allergy – and the next exposure to the allergen triggers it. Subsequent contact with the allergen can have the same or a more severe reaction.

Sometimes we may experience temporary irritation rather than a full-blown allergy, though the terms tend to be used rather interchangeably by consumers.

The PPD situation does represent an interesting comparison in relation to some fragrance ingredient bans we’ve had. If the bureaucrats’ care about our health and safety was consistent, then surely PPD should be banned, along with peanuts. The main difference may be in how we become exposed to fragrance allergens and in how fragrances are perceived by the EU.

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Fragrance ingredients could be thought of as the regulatory casualty of the general public’s love of perfume in almost every product

Shampoo, conditioner, body lotion, deodorant, shaving foam, aftershave, shower gel, bath foam, hand soap, spray tan, laundry detergent, fabric conditioner, face cream…

We don’t just adore fragrance – our perception of a product’s effectiveness is greatly influenced by its scent. If the shine-boosting shampoo we use has a well-chosen scent, we are convinced our hair is shinier compared to the fragrance-free version; if the laundry detergent has an appropriate scent, the whites look whiter, and our face cream is much more rejuvenating when it smells just so. Fine fragrances can enhance our self-confidence so much that the effect is perceivable by others. The perfume of a long-lost loved one can offer a great deal of emotional comfort. Oddly, even though the EU SCCS (Scientific Committee of Consumer Safety) has consulted the industry when setting their recommendations, they appear to disregard this aspect of fragrance entirely. They seem to think of fragrance as an unnecessary risk with no benefit to the consumer.

We are constantly exposed to fragrances in everyday toiletries, cosmetics, personal care products and household products. As reported in the industry journal Perfumer & Flavorist the global flavour and fragrance market totalled $23.9 billion in 2013, and is expected to reach $25.3 billion in 2014 and $35.5 billion in 2019. Most perfumery work goes into functional fragrances, though the largest exposure for the individuals using fine fragrances comes from the application of those. Then again, by simply peeling an orange, you’ll get exposed to plenty of allergens from the orange oil stored in the peel. In fact, there was a study which showed that we are exposed to more limonene through peeling oranges than through fragranced products. In the eyes of the regulators, the risk of that is worth it because oranges have a benefit to the consumer. They’re food - nutritious and good for us, so the risk is outweighed by the benefit.

When regulators decided on the first 26 EU ‘allergens’, dermatologists’ testing kits were heavily involved; using fragrance mixes and patch tests to determine reactions. It has since been argued that some of the substances on the list aren’t allergenic, and that some other substances not on the list are far more risky. Certain materials occur naturally in so many essential oils, and are used as isolates, too, that they end up in millions of products and their industry-wide usage is extremely high. This increases our exposure to them and therefore also the likelihood of allergies developing. Other materials like Lyral and Lilial are just so universally loved by consumers, and so useful in popular accords, that they get everywhere, too.

So where do IFRA and the EU fit in, exactly? Who is in charge of deciding what ingredients we are allowed to have in our fragrances?

The United Nations sets global chemical safety regulations which cover transport and industrial safety. The current system is the Globally Harmonised System (GHS), which is an attempt to unify how chemicals are labelled and handled everywhere. Of course the GHS has not been adopted by all countries as of yet, and its local interpretations vary. The interpretation we use in Europe is called the Classification, Labelling and Packaging (CLP) Regulation. It covers exactly what the name suggests, and you may have seen CLP hazard symbols on your bathroom cleaner or air freshener bottles. Household products fall under the CLP regulation, and one of the challenges to perfumers in this area of the industry is the creation of fragrance blends which have fewest hazard labels possible. Those warning pictograms don’t look attractive in a consumer product.

What do you think this material might be?

  • Flammable Liquid, Hazard Category 3
  • Skin Corrosion / Irritation Category 2
  • Sensitization - Skin Category 1
  • Aspiration Hazard Category 1
  • Hazardous to the Aquatic Environment - Acute Hazard Category 1
  • Hazardous to the Aquatic Environment - Long-term Hazard Category 1
  • Flammable liquid and vapour.
  • May be fatal if swallowed and enters airways.
  • Causes skin irritation.
  • May cause an allergic skin reaction.
  • Very toxic to aquatic life with long lasting effects.
  • Dangerous for the environment.
  • Harmful.
  • Keep away from heat, sparks, open flames and hot surfaces. - No smoking.
  • Keep container tightly closed.
  • Ground/bond container and receiving equipment.
  • Use explosion-proof electrical, ventilating and lighting equipment.
  • Use only non-sparking tools.
  • Take precautionary measures against static discharge.
  • Avoid breathing vapour or dust.
  • Wash hands and other contacted skin thoroughly after handling.
  • Contaminated work clothing should not be allowed out of the workplace.
  • Avoid release to the environment.
  • Wear protective gloves/eye protection/face protection.
  • IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician.
  • IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing.
  • Rinse skin with water/shower.
  • Do NOT induce vomiting.
  • If skin irritation or rash occurs: Get medical advice/attention.
  • Take off contaminated clothing and wash before reuse.
  • In case of fire: Use for extinction: Foam, Dry chemical, Carbon dioxide.
  • Collect spillage.
  • Store in a well-ventilated place. Keep cool.
  • Store locked up.
  • Dispose of contents/container to approved disposal site.

Sounds like a really nasty chemical you certainly wouldn’t want in your house. Alas, it is information taken from the safety data sheet for sweet orange oil. However, if you had a bottle of it at home and your toddler drank it, it could be deadly. In fact, even an amount as small as 10ml can cause major problems if it is aspirated. There are some inconsistencies in the regulations. If you put pure orange oil into a container, label it a natural de-greaser and sell it as a household product, you’ll have to have all those scary pictograms and various warnings on the bottle. If, however, you bottle pure orange oil and sell it as an aromatherapy product, it might not carry any warnings at all. It’s a baffling situation and it could be said that it’s actually quite dangerous to sell essential oils to people who may have no idea of the risks.

If a drum of orange oil sprung a leak in a warehouse, it could pose a serious health and fire hazard. You would also have to inform the local water board of the hazardous waste going down your drains and it could cause a serious problem.

The first area of concern with fragrance safety is not, what the industry would call the ‘end user’. First, we must look at safe handling in industrial settings and in road and air transport.

Chemical spills happen all the time, as do industrial accidents and long-term cases of chemical poisoning at work. These are no laughing matters. The disaster does not have to be in the scale of Bhopal (1984) for it to have disastrous environmental and health effects. Many common (natural and synthetic) fragrance materials are flammable, corrosive, toxic, suspected carcinogens or at the very least irritating to skin and eyes undiluted. Some materials are in fine powder form – and any fine powder is irritating to the lungs when inhaled; some are hazardous and even toxic. Nitro musks are problematic partly due to being explosive. As much as I might love the smell of musk ketone in my fragrance, working in a lab with 200kg of it in a tub next door feels quite different.

Who can honestly say they wouldn’t want safe working conditions and a clean environment?

"What we do to natural materials to get the volatile oils out of them is not natural; it is processing. Arguments about safety should not be confused with aesthetic arguments"
It is entirely reasonable to demand that employers make their workplaces safe for the workers, and that safety precautions are followed when disposing of or transporting harmful chemicals. As natural as orange oil is, dumping it into the river would be deadly to wildlife, and so is quite rightly a crime; and it is important to not get caught up in sentimental, ‘natural versus synthetic’ debates about these matters. Orange oil in its natural context is safely stored in the peel and ‘Nature’ never intended for the oil to be extracted and used in concentrated form, so we can stop insisting that natural raw materials should have special protection from a safety perspective. What we do to natural materials to get the volatile oils out of them is not natural; it is processing. Arguments about safety should not be confused with aesthetic arguments.

As beautiful as natural orange oil smells, and as useful as it is as a flavouring material – when it’s extracted and stored in industrial quantities, it quite rightly falls under chemical regulations.

On the other hand, it is perfectly sensible to examine whether the safety precautions and regulations are reasonable. That’s where I feel we should be spending our energy - not on trying to insist that naturally produced chemicals aren’t chemicals.

I am not sure how much we can do about the seemingly excessive measures which the EU seems to want to take. Many view the attempts to change EU bureaucracy as a futile exercise. It’s true that the debate over the next ‘allergens’ is now really about how they will be implemented, not about whether they will happen.

On the other hand, many of the public reactions to this topic were rather over-the-top – it’s mostly about labelling, and only a couple of bans are on the cards. Even for the banned substances, there are already developments in place to provide workable substitutes (atranol and chloroatranol-reduced oakmoss, for instance). There is no major revolution about to happen with our beloved fragrances; just more bureaucracy and a slow march towards less irritating, less allergenic fragrances in our everyday products. Some existing bases and scents will have to be reformulated. There is a growing market for natural reconstructions (using natural isolates to re-build an oil without its offending constituents). Perfumers will be frustrated. However, most consumers will not notice a thing.

The main delay in this matter is about the logistics of it all – once you increase the mandatory labelling requirement of allergenic constituents to over a hundred materials, a standard package cannot hold all the text, so there has been talk of peel-off labels, apps for smart phones and the like. The debate is still ongoing about how best to list all the allergens.

It does also seem unlikely that these new labelling requirements will actually protect consumers. The logic seems shaky:

  1. Since allergy develops over time and we can become allergic to substances we’ve been fine with before, how will labelling protect consumers from developing an allergy? It can’t. The intention of labelling is to alert allergic individuals, not to prevent allergy. There are more worrying implications about this – there are talks about limiting the total number of ingredients in order to prevent allergy
  2. How many people do you know who actually check allergens on a product label and know precisely what they should be avoiding?
  3. Once a person develops a fragrance allergy, they often choose unscented alternatives just to be sure or keep experimenting with products until they find something they can tolerate.

Of course, labelling is a better alternative than a total ban.

In this issue, there’s another grey area; aromatic materials added to cosmetics and aromatherapy products as part of the formula, rather than as ‘fragrance’ allow devious manufacturers to market so-called ‘fragrance-free’ products which actually contain fragrant materials.

The main regulatory structure currently looks like this:

  • United Nations
    • Globally Harmonised System (GHS)
    • International transport regulations
  • European Union
    • European Chemical Agency (ECHA) which governs REACH (Registration, Evaluation, Authorisation & restriction of Chemicals).
    • Local interpretation of GHS – the Classification, Labelling and Packaging of substances (CLP) Regulation.
    • Cosmetic Regulation.
    • Scientific Committee on Consumer Safety (SCCS) Opinions which may lead to bans and recommendations. This is one of the expert committees of the EU Government. The Opinion on fragrance allergens in cosmetic products, 2011, kicked off a long consultation process with the industry about the increase of mandatory fragrance allergen labelling on cosmetic products from the current 26 to over 80, and the ban of atranol and chloroatranol (the two main allergenic substances in oakmoss), as well as Lyral (a widely used synthetic fragrance material). If sufficient concern has been raised by dermatologists and other medical professionals about reactions and allergy, the SCCS will be consulted for an opinion. Once given, the government has to respond in some way (often in the form of regulations).
  • National Governments
    • Country-level trading standards laws and regulations (packaging, trade descriptions, etc).
    • National chemical safety laws and workplace health & safety laws (for example COSHH in the UK).
  • Industry
    • The Research Institute for Fragrance Materials (RIFM) is a nonprofit organisation dedicated to researching and producing reports on fragrance materials.
    • IFRA uses RIFM data to help decide on new recommendations. Following IFRA recommendations is voluntary to non-IFRA members and compulsory to members. However, with the new, tightened cosmetic safety assessments and Product Information Pack requirements within the EU, most safety assessors insist on IFRA conformity as part of the assessment. Products cannot be legally placed on the market in the EU without a safety assessment.

REACH has hit ingredient suppliers hard – and since aroma chemicals and essential oils are both ‘substances’ which fall under this regulation, it is continuing to seriously affect all of the fragrance industry, not just chemical manufacturers (though of course its impact is really felt when producing new aroma chemicals). REACH is costly, excessively bureaucratic and poorly understood. Producers and importers of essential oils and aroma chemicals have to register their substance with REACH once the quantity (produced or imported) per annum reaches one tonne. REACH is an utter nightmare for raw material producers and while its costs and logistics may be absorbed by large manufacturers with relative ease, this is not the case with smaller businesses.

The Cosmetic Regulation covers fine fragrances and anything else classified as a cosmetic product. The CLP Regulation (see above) covers household products.

When a new cosmetic product is being designed and is about to be brought to market, there is now a requirement for a mountain of paperwork and for it to pass a new, tightened safety assessment. The allergens (which are decided by the EU) have to be listed on the packaging, and an IFRA certificate is needed for the fragrance to pass the safety assessment. Fine fragrances – liquid perfumes in pretty bottles – are classified as cosmetic products.

There have been some suggestions that perhaps we’d be better off if everything was covered by the CLP Regulation, and instead of allergen warnings and IFRA recommendations, we’d have warning diamonds and hazard statements on our perfumes. It would probably hurt sales quite a lot. Perfumers working on air freshener fragrances already struggle to create formulas which won’t result in warning pictograms. I wonder how consumes would react if their perfume boxes had pictures of exploding chests and upside down dead fish on them? All you’d have to do is add some orange oil and the box would look terrifying.

Let’s face it – the majority of perfume shoppers have absolutely no idea what IFRA is, or that fragrances are constantly subject to scrutiny by dermatologists and regulators, and would be scared by the warnings. Upsetting hazard statements and pictograms on fragrance packaging would in some ideal utopia teach the chemophobic campaigners that maybe everything is potentially hazardous after all, and perhaps the hazards need a bit of context. We can safely assume that even though rose oil – one of the most wonderful fragrance materials there is – contains a suspected carcinogen methyl eugenol, applying a few drops of a fragrance containing it on our skin isn’t going to give us cancer. Back in the real world, we know that putting hazard diamonds on packaging would get fragrances banned everywhere (as they already are in some places).

Problems arise when safety issues are taken out of context

I am as frustrated by the extreme scare-marketing by well-meaning but ignorant anti-chemical NGOs and businesses, as I am by the excessive consumer protection we seem to be heading towards as far as fragrances are concerned. I also don’t think these issues exist in a vacuum – I think they’re connected.

On one hand consumers are demanding everything to be 100% risk-free (which is impossible), and on the other are complaining when fragrances are getting over-regulated. Consumers and brands also complain when fragrances don’t smell good, which can be the worst part of making ‘safer’ scents. We can’t have it both ways.

As you can see from the above list, IFRA does not and cannot set any legal requirements, but it does aim to make fragrances as safe as possible while still allowing the use of potentially problematic materials. IFRA is also trying to convince the bureaucrats that the industry knows what it is doing, and is capable of protecting consumers without excessive government nannying.

 

 

I am fairly confident that if the EU could get away with it, they’d probably ban all fragrance as an ‘unnecessary risk’

I am sure they view fragrances as a trivial vanity for which there is no reason to expose people to any risk of harm, however small. According to the SCCS, approximately 3% of the EU population experiences fragrance allergy.

Speaking of the harm fragrance allergies can cause, many perfume enthusiasts can be heard saying “it’s only a rash”, but the effects can be so severe as to be permanently disfiguring. In some cases the conditions can result in loss of work and seriously affect quality of life. I don’t think trivialising these problems helps anyone. We are also highly suggestible, and some studies have shown that when we are told that smelling a particular smell is harmful to us, our airways constrict and we have a real physical reaction, whereas if subjects are told the smell is beneficial to them prior to smelling it, no such negative effect is experienced.

This is an important piece of information. Anyone out there brainwashing people into believing that inhaling perfume is harmful is actually causing some of the harm. If a person believes that smelling perfume will give them an asthma attack or a migraine, they can suffer those effects due to the belief they have (and that doesn’t make those effects imaginary).

People are not allergic to the smell; the allergy develops on skin. No known respiratory allergens are used in fragrances. However, inhaling vapourised liquid can be very irritating to the respiratory system; even tiny water droplets can cause problems to someone with a chest complaint. The effect of the irritation is often described as being allergic but it’s not actually an allergic reaction.

As briefly mentioned before, allergy develops over time. RIFM is trying to find the ‘no observed adverse effect level (NOAEL)’ of fragrance materials - data which is passed to IFRA to evaluate and make recommendations based upon. This means finding a dose of the ingredient at which point no allergy starts to develop.

Some materials end up with such low maximum recommended levels as to be rendered unviable, whereas in some cases IFRA recommendations have actually rescued materials from being cast aside altogether. Many fragrance materials are so potent that they can still have a noticeable effect at very low doses, and on the other hand, the NOAEL level of some materials is high enough that the IFRA recommendations hardly affect the formula.

It is in nobody’s best interest to continue putting allergenic substances into cosmetics and household products. If we make large populations allergic, they will stop buying our products. From an industry point of view, it is important for cosmetic manufacturers and their safety assessors to be confident that a formula they don’t have access to has in some way been declared safe. Formulators should really know what is going into their products, and they need to be able to create products with least possible risk of irritation and allergy. The cosmetic regulation states that cosmetics must be ‘safe’, and includes a statement about vulnerable groups. A safety assessor can request the fragrance formulation if they feel it is necessary, so an IFRA certificate may not be enough. Obviously it is preferred by fragrance manufacturers to rely on IFRA certificates if possible.

Are there ways in which IFRA is not ideal?

Of course. In some ways that’s because of how the industry itself is set up. The industry is still extremely secretive – the structure and day-to-day operations cast many businesses as each others’ partners and competitors. This makes relationships and insider knowledge extremely valuable, and businesses hold on to trade secrets tightly (even in the age of Gas Chromatography-Mass-Spectrometry there are many tricks of the trade to throw would-be-copiers of perfumes off the scent and a GC-MS readout is not like a supermarket receipt).

I have witnessed conversations in which both parties are selling something to one another (a fragrance compound is being bought by one, and an essential oil by other); there are traders whose main business it is to match and cheapen scents, and this isn’t some black market operation, it’s business as usual. That means it is almost impossible to get the industry to form a coherent lobby to talk some sense into Danish dermatologists and EU regulators. It means that on matters of public education and communication, the void is filled by misinformation and scaremongering.

It means that IFRA is perhaps the only representative body fighting on behalf of retaining some control over fragrance formulations in the hands of experts (instead of people who may be well-meaning about public safety but understand absolutely nothing about fragrance). On the other hand, since IFRA is meant to be a neutral entity, it cannot interfere in the running of its member businesses, which means its position in the industry is peculiar. Not to mention that when you talk to perfumers about IFRA, most opinions are coloured by frustration. IFRA works hard to lobby governments in an attempt to prevent unnecessary and unhelpful regulations. In the absence of another unified front, IFRA is it.

Who is getting rich out of all this? Bureaucrats, consultants, regulatory professionals (fragrance regulation is now a full-time job in all but the smallest businesses). And who is paying for all this? Consumers, of course!

The fragrance industry has so far absorbed all of the costs and difficulties, adapted, and carried on – and sure, there are hundreds of exciting materials left for us to work with – but since we’re heading towards greater transparency, greater regulation and therefore greater risk for the fragrance industry, some proactive measures wouldn’t hurt. I’ve been in Britain for too long. What I really meant to say was: it is time for the industry to wake up! We can’t afford to go through the motions; to be complacent and to trust that it’s going to be business as usual for the next 100 years.

What would be a reasonable way to let those who wish to take the risk to keep enjoying their fragrances?

"...it is time for the industry to wake up! We can’t afford to go through the motions; to be complacent and to trust that it’s going to be business as usual for the next 100 years."
Perhaps we should have two levels of regulation – one, much stricter set for functional fragrances (where we would find it difficult to avoid exposure because these products are so ubiquitous) – and another, much more permissive, for fine fragrance that people who are concerned about fragrance allergies (and those already sensitised) could just avoid using altogether or be sufficiently warned of the risk. Fine fragrances could carry a warning label (though we’ve seen from the hair dye example what good those do). On the other hand, air fresheners and body sprays are classed as functional fragrances, but it is their main job to fragrance – so perhaps the distinction should be “what is the primary function of the product?”.

One thing that could be made easier from within the industry is the way in which indie perfumers are supported (or not); for us to prevent the banning of important fragrance materials, we must find some way to work with IFRA and the EU – and for us to do that, we must assist smaller businesses in following regulations.

IFRA serves the needs of the wider industry (where fragrances are manufactured by one company, put into a product by another, and sometimes even marketed by a third). It therefore makes sense for there to be a paper trail and some degree of protection for the supplier of the fragrance compound (‘this is safe according to IFRA’. Ergo: we’re okay). In some ways IFRA therefore exists to protect large fragrance manufacturers.

During its journey from the lab to the shop shelves, a fragrance formula (and the product it is going into) will come under a complex set of regulations:

  • The manufacturer or importer of the raw material must deal with REACH, if applicable.
  • The storage of the materials falls under health and safety, fire safety and chemical safety laws.
  • The fragrance formula must comply with the client’s end application (if it’s an air freshener, the client has most likely requested a hazard-pictogram free formula, which is tough to create since almost everything is classified at least as an irritant. If it’s a cosmetic product fragrance, the brand might be looking for a product with an allergen-free fragrance. If it’s a fine fragrance, the brief might include requests that are tricky to fulfil without going over IFRA limits). So depending on the brief, CLP, EU Cosmetic Regulation and IFRA would be involved.
  • When the fragrance compound leaves the facility, it will fall under CLP labelling and appropriate transport regulations on its way to the product manufacturer. At the product manufacturer’s end, it will need to be correctly handled and stored (so the health and safety, fire safety and chemical safety laws again).
  • When the fragrance is put into a product (or bottled as a fine fragrance), it will have to pass a cosmetic safety assessment before it is sold to the general public (IFRA certificates are required at this stage).
  • When the product is packaged and put on the shelf, its packaging and labelling must comply with Supply of Goods and Services Act, Weights and Measurements Regulation, Trade Descriptions Act, and CLP/EU Cosmetic Regulation (depending on whether it’s a household product or a cosmetic product).

Small indie perfume brands where everything is made in-house, and nothing is sold on to third parties still have to tackle the same amount of regulatory hoopla. If IFRA and the EU wish for total compliance, some of the bureaucracy should be broken up and put together again – this time keeping smaller businesses in mind. Making the regulations so arduous will not lead to fewer people having a go; it will lead to more people deciding not to comply. And if we end up with a large ‘black market’ of non-compliant products (which is already establishing itself), fragrance allergies will increase, law makers will decide that perhaps an industry body (IFRA) is not sufficient to self-police after all, and then we’ll be in real trouble.

If the industry fails to proactively address all the problems and loopholes in current fragrance regulations, the future of fragranced products is unlikely to be endangered entirely, but it will most likely be boring. We’ll look back to a time when everything didn’t smell of the same few dozen ultra-safe substances and wonder why we didn’t organise ourselves and do something sooner.

So now what?

 

 

Thank you

This article wouldn’t have been possible without the training and help provided by Penny Williams at Orchadia. Penny has over 24 years of experience in the fragrance industry, across all areas of creative and technical perfumery, analytical, technical, systems and ISO, legislation and regulatory affairs and marketing. This includes 19 years as a perfumer and a position as chief perfumer at an international fragrance house.

Any mistakes that remain in the text are the author’s.

Sources and links

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About the author: Pia Long

Pia Long is a perfumer, freelance writer and an experienced cosmetics industry professional.

Originally from Finland, she has been in the UK since 1992 and qualified from London College of Fashion in 1996. For her continuing professional development she has read the entire CLP and COSHH regulations and several EU Opinions; completed a CLP course, is studying on an IFRA course with Orchadia Solutions and attends every lecture on olfaction and fragrance chemistry she can. She won the first David Williams Memorial Award for her work on the IFEAT Diploma in Aroma Trade Studies, is a Council member of the British Society of Perfumers and has been nominated for the Jasmine Award twice.

While working for Lush Cosmetics, Pia created some of their best-selling product perfumes, including HQ “the smell of a Lush shop in a bottle.” She is a regular contributor to Basenotes and her own blog can be found at volatilefiction.co.uk

Website: http://www.volatilefiction.co.uk

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    Comments

      • Vinrambo09 | 11th June 2015 21:59

        What a useless article !

        The writer is an obvious shill for IFRA.

      • hednic | 11th June 2015 22:11

        I found the article entertaining to say the least!

      • Le vagabond | 11th June 2015 23:30

        Reads like propaganda. It would help if there was a counter argument.

      • rogalal | 12th June 2015 06:34

        Pia has been a contributor and friend of BN for something like 10 years now. I remember reading about her trials going to perfume school and still have some of the samples she sent to us from her first job years ago. Anyone who calls her ethics to question simply doesn't know her history here.

      • NeoXerxes | 12th June 2015 07:19

        The article carries the unmistakable stench of propaganda, whether it was intentional or unintentional. Not only does the author thank Penny Williams (a member of the fragrance industry who just so happens to be deputy Chairperson on the IFRA UK Technical Advisory Group) for her "training and help", but the arguments portray the IFRA as a protagonist entity that is preferable to all possible alternatives. And the scare tactics... If the author was not intending to write a piece that reads as propaganda for the IFRA, she should go back to the drawing board.

        Some of my favorite quotes from the article:

        "If a drum of orange oil sprung a leak in a warehouse, it could pose a serious health and fire hazard."

        "As natural as orange oil is, dumping it into the river would be deadly to wildlife, and so is quite rightly a crime; and it is important to not get caught up in sentimental, ‘natural versus synthetic’ debates about these matters. Orange oil in its natural context is safely stored in the peel and ‘Nature’ never intended for the oil to be extracted and used in concentrated form, so we can stop insisting that natural raw materials should have special protection from a safety perspective. What we do to natural materials to get the volatile oils out of them is not natural; it is processing."

        "I wonder how consumes would react if their perfume boxes had pictures of exploding chests and upside down dead fish on them? All you’d have to do is add some orange oil and the box would look terrifying."

        "There is no major revolution about to happen with our beloved fragrances; just more bureaucracy and a slow march towards less irritating, less allergenic fragrances in our everyday products. Some existing bases and scents will have to be reformulated. There is a growing market for natural reconstructions (using natural isolates to re-build an oil without its offending constituents). Perfumers will be frustrated. However, most consumers will not notice a thing."

        “As you can see from the above list, IFRA does not and cannot set any legal requirements, but it does aim to make fragrances as safe as possible while still allowing the use of potentially problematic materials. IFRA is also trying to convince the bureaucrats that the industry knows what it is doing, and is capable of protecting consumers without excessive government nannying.”

        "It means that IFRA is perhaps the only representative body fighting on behalf of retaining some control over fragrance formulations in the hands of experts (instead of people who may be well-meaning about public safety but understand absolutely nothing about fragrance). On the other hand, since IFRA is meant to be a neutral entity, it cannot interfere in the running of its member businesses, which means its position in the industry is peculiar. Not to mention that when you talk to perfumers about IFRA, most opinions are coloured by frustration. IFRA works hard to lobby governments in an attempt to prevent unnecessary and unhelpful regulations. In the absence of another unified front, IFRA is it."

        "One thing that could be made easier from within the industry is the way in which indie perfumers are supported (or not); for us to prevent the banning of important fragrance materials, we must find some way to work with IFRA and the EU – and for us to do that, we must assist smaller businesses in following regulations."

      • adam090273 | 12th June 2015 07:31

        Society is the mostly to blame for these restrictions, like other restrictions in everyday life. There is always someone out there ready to complain or take legal action.

        I am not sure about other parts of the world, but over here Insurances are driving many people out of business, especially small business.

      • Alasse | 12th June 2015 08:21

        I agree with NeoXerxes on this - lots of scaremongering in this article (whether intentional or not)

        I am all for regulating my shower gel and skin care (like say - Lush - ironically a company using tons essential oils) but perfume? This is a product that adults can easily test out in stores without putting their whole body/face in harms way. I just don't buy the arguments "orange oil spill in warehouse a fire hazard" - ok - as opposed to olive oil?

        And another quote from the article: "Surely the correct thing would be to raise awareness and let people make their own decisions?" - absolutely, awareness is great - but regulations make it impossible for people to make their own decisions - which is the point.

      • laph | 12th June 2015 08:47

        Great article thanks Pia. Can you tell me, does IFRA actually decide which substances are allergens or does it only suggest controls after the EU make the "allergen" decision?

      • Mark_Trail | 12th June 2015 08:57

        Strange piece of writing, especially if authors credentials are what someone earlier stated in this thread.

        Smells a lot like spin doctoring to me

        -Mark.

      • Le vagabond | 12th June 2015 09:23

        The art of perfumery was founded on the use of naturals from this earth. Any lobbying to governments should be to guarantee reasonable levels of naturals in products called 'perfume'.

        All synthetic is not a problem, just call it that so that we know.

        High-quality perfumery should be protected so that it doesn't become extinct. I find it increasingly difficult to find the quality that I expect and, if the money men get their way, this might get even worse with new bans/restrictions on naturals.

        Maybe in the future my ancestors will be drinking synthetic wine and eating synth cheese.

      • Nukapai (article author) | 12th June 2015 11:04

        Thank you for everyone who has taken the time to read through this rather long piece. It came out of sheer frustration - as some Basenoters of old will remember, I've had a long journey from a perfume enthusiast to perfumer, much of which has been documented here and in various blogs and articles over the years. In the sorts of jobs I do now, I have to understand what is really going on behind the scenes and therefore attend training courses and symposiums and whatnot.

        I went to an IFRA day a while back now (must have been 2013!), hoping I'd come out of there a little wiser. Well, I suppose I did, but I also came out of there with pages and pages of notes and more questions than I went in with. It was obvious that many of the industry representatives in the room were frustrated about all the restrictions; didn't feel that the EU's actions - while well-meaning - were really protecting consumers as intended and just causing lots of extra pressure... and nobody seemed to be able to present a comprehensive overview of how all these parallel regulatory requirements fit together. So I decided to have a go at gaining a better understanding.

        What became obvious was that there are no black-and-white "good guys" and "bad guys" and that there were lots of inconsistencies, even loopholes, and the whole thing seemed in parts to be over-protective but in others, curiously obscure. I needed to learn more for my work anyway, so read through everything I could, asked subject matter experts to help spot errors in my facts (hence the fabulous Penny - who since has offered me a job; nothing to do with this piece, just the fact we've had a growing friendship and mutual respect over time and I happen to have skills which she can use).

        I held back from finishing the article until I'd attended lots of extra training and spoken to many people who know more than I do.

        And yet, any failings (such as the sad way in which this piece seems to have come across as scaremongering or propaganda - or most confusingly, as a piece advocating the use of synthetics over naturals... that's certainly not the message)... any failings are mine alone, and it's been an interesting education to see just how tough it is to communicate complex topics like this from an informed position. The irony is that in order to understand something like this, one has to get knowledgeable enough that to many people one can appear like an industry shill. That I am not. My desire is to understand and I certainly don't speak for the industry.

        I hope this piece will generate healthy debate and discussion. I'm not the slightest bit offended by some of the more frustrated comments here; it is to be expected and I understand.

        What I'd love to hear is your take on the final question I pose. "So now what?"

        What do you all think would be a reasonable and realistic way to protect perfumes from over-regulation while protecting the consumers? Is it a totally naive idea to reason with the giant bureaucracy monster? Who do you think would be in the best position to protect the industry's interests AND reassure consumers that their products are safe?

      • Nukapai (article author) | 12th June 2015 11:05

        There are two parallel things going on:

        Allergens in the EU are part of the Cosmetic Regulation.

        IFRA acts independently based on the recommendations from RIFM to set recommended use levels for materials of concern. There are of course overlaps and the pressure goes in both directions.

      • David Ruskin | 12th June 2015 11:39

        I found the article well balanced and well researched. I am very surprised at the hysterical reactions of other comments. IFRA was originally se up in an attempt to keep the Fragrance industry self regulating, and independent of the law. For many years it worked. Unfortunately this has now changed, the Law and the organisations who make the Law knows nothing and cares less about Perfumery. Maybe if IFRA had been stricter, earlier, the present situation would not have arisen.

      • Kaern | 12th June 2015 11:41

        The ironic thing is that you are more likely to suffer an allergic reaction the more 'naturals' are used.

        The chemists are making sure the synths comply with the regulations and this will be the way forward -- it's too risky for the Houses or 'independents' to use otherwise -- and they all want to cut down on costs.

        'Natural' oils will be used less and less. Analysed and then replicated molecules from substances or flowers that have been placed in a vacuum is what is happening.

      • Gblue | 12th June 2015 12:06

        This is the most useful article on the reality of the industry I've read in quite some time.

        As a fellow long term enthusiast AND someone who works behind the scenes in the world of perfume, it's refreshing to see some actual transparency about how things work - it's cleared up some of the confusion for me, too, and I'll be able to explain more clearly next time someone asks about regulations.

        To everyone claiming Pia is a shill or that this piece promotes synthetics over naturals, you should probably re-read the piece. Pia is not "pro-chemical", but pro-truth and pro-science.

        The industry is a confusing place, because information like this isn't available easily. Thank you to Grant for publishing and Pia for taking what must have been hundreds of hours on this one!!

      • lapel roll | 12th June 2015 12:39

        Overly-long. There have been many chemical-consumer health and safety issues in the past that came about because of weak regulation and now the EU (which everyone hates with a knee-jerk reaction) works to improve it. Multi-billion dollar/pound/euro businesses hate the EU because they limit their profits, many others hate it because they read too much rubbish about it and parrot the usual right-wing or libertarian claptrap about how it infringes on everyone's glorious freedom (freedom to poison ourselves unknowingly no doubt?).

        The perfumery of the past did no have access to even half of the chemical knowledge or chemical substances currently available; neither was the consumer base so wide as it is now.

        This utterance from your article: "I am fairly confident that if the EU could get away with it, they’d probably ban all fragrance as an ‘unnecessary risk," is the sort of nonsense that unduly raises people's ire. Perhaps if you lived in places where chemical use is much less regulated (China, parts of Africa) you'd see things differently.

      • Irina | 12th June 2015 12:45

        Well done, Pia! I truly hope you don't take the crappy comments to heart....

        (and post/save this wonderful article elsewhere as well, as basenotes.net unfortunately keeps having technical troubles)

      • iodine | 12th June 2015 15:13

        Interesting and complex read, thank you.

        (I wonder where the people who know THE TRUTH have gotten their informations. It would have been correct to put some trusted references.)

      • DuNezDeBuzier | 12th June 2015 15:23

        What a reasonable and rather comprehensive effort! I'm most surprised by the number of offhand sour comments. For those, a challenge: start a thread in the gen'l forum picking apart any of the author's assertions, observations, and conclusions. Please use facts or verifiable and credible accounts from credible sources. If done well, that might be a good read too. Otherwise, it's just more whining in the echo chamber.

      • cytherian | 12th June 2015 18:31

        Fascinating. Clearly the author did a lot of research on this topic. There are interesting facts enclosed, but also some rather subjective statements, many of which were appropriately recited by others.

        I absolutely appreciate how natural oils are derived in man-made ways, that their concentrations are unnatural and therefore aren't much different from synthetic chemicals. But... this seems more of a concern with processing and manufacturing, rather than the final product. If a case of perfume bottles is damaged and leaks, it's not going to be a severe and sweeping environmental impact.

        Where I find the disconnect is how the major perfume houses are responding to the IFRA restrictions. These are houses that rely upon 3rd parties for creation of synthetic ingredients. If a much higher cost gets passed onto them, wouldn't they all be up in arms about it? That natural essential oils should not be banned? They're all indifferent about it and a few even embracing it. Only a few niche experts have really complained. THAT is what is causing the impression that there's a subversive money interest in doing these bans, underneath a few legitimate concerns about allergens.

      • NeoXerxes | 12th June 2015 20:29

        You do realize that propaganda doesn't necessarily include the use of lies, right? It's about how information is presented, and how arguments are made.

        I believe I provided sufficient commentary on why these quotes are objectionable. Perhaps you don't see it the same way.

      • artandolfaction | 12th June 2015 20:45

        What a thorough article- even if one disagrees with what Ms. Long is saying, it's great that someone is taking the time to even attempt to unpack the insane amount of information and opinion involved in these policies and their effects on the industry.

        Before passing comment beyond that, I'm going to reread it a few times to make sure I understand... Maybe a few more times, even, than I care to admit. ;)

        - Saskia

      • Cali | 13th June 2015 20:39

        It's very evident that the writer devoted a great deal of time and research into a huge undertaking. She writes in an understandable way, presents the facts clearly and objectively, and most importantly, includes the concerns and interests of professional artisan companies. A significant contribution to the community. Much appreciated.

      • David Ruskin | 14th June 2015 11:38

        I'm afraid I don't. When you imply that the truth is objectionable, because it differs from what you would like to believe, I get worried.

      • Alasse | 14th June 2015 12:14

        Which absolute truth are you referring to? This would be the only case for "worry" - as otherwise it would just constitute a difference in opinion. He simply refers to the selective use of facts - not absolute truth.

        Obviously it is a loaded subject for many - and I applaud the author for her commitment to the issue - I also see no problem with his remarks.

      • David Ruskin | 14th June 2015 12:19

        Nor do I. All I was commenting on was that the list of "favourites" (i,e those things he objected to) were all true. I don't think I ever mentioned "absolute truth", what ever that means

        "I believe I provided sufficient commentary on why these quotes are objectionable. Perhaps you don't see it the same way." No I don't. That's all.

      • Alasse | 14th June 2015 17:17

        "When you imply that the truth is objectionable, because it differs from what you would like to believe, I get worried". --> implies something you can't argue with, and I don't see any issues with objecting to the way in which facts ("the truth") are presented.

        Its not because XYZ are true, that X-Y-Z are connected and that X-->Y-->Z form a sufficient argument/have some sort of causal relationship.

        Anyway - like I said - its an incredibly difficult topic and a commendable effort.

      • cytherian | 14th June 2015 19:14

        Yes, it is a difficult subject to debate because of an inherent lack of facts to pull the whole picture together.

        * Contention #1: IFRA/EU rules are needed as-is, because they are protecting us from possible dangers in the repeated use of certain aromachemicals. While people may say "but it hasn't harmed me yet" is akin to a smoker saying "they haven't killed me yet"... and we all know how long term smoking will in MOST cases result in either an undesirable chronic condition, amputation of a body part/organ, or premature death. If repeated use of a certain aromachemical triggers an allergic reaction at some point that remains chronic, then there's a potential lawsuit at hand. These restrictions are meant to protect the public health and businesses from potential lawsuits, nothing else.

        * Contention #2: IFRA/EU rules are too restrictive, and are ruining the fragrance industry. They are putting in restrictions on natural essential oils that have been with us for decades, where only an extremely small number of people have cited allergic reactions. It is such a small percentage as to be considered irrelevant, as those who have had problems are mostly people who are already sensitive to a myriad of other allergens and would normally, as a point of common sense, exercise restraint on application of anything (including fragrances). The IFRA board is heavily populated by representatives of corporations in the perfume industry, who coincidentally have a significant edge over smaller competitors in the arena of synthetic formulations. Yes, it is an expensive proposition to come up with a synthetic substitute to a natural essential oil, but once done it is a "cash cow", and can be reused over and over again. Then, such a maker can license out this product and continue to make money on it. What telegraphs complicit behavior is how these large perfume corporations react either indifferently to the new restrictions, or even applaud them. Curious, how the smaller perfumers with little stake in the making of synthetic aromachemicals are the ones who are expressing dissatisfaction with these new restrictions.

        I haven't seen a good argument that addresses both of these, arriving at a definitive conclusion as to which one is "closer to the truth."

      • david | 14th June 2015 19:28

        The irony is that EU still allows tobacco/ cigarettes to be sold. No regulation, apart from age concent and a warning that it can kill. Plus the fact that tobacco is addictive !... but european government regulators turn a blind eye to this one because it earns them "too much money" in taxes.

        This "nanny state"/ "united states of europe" stinks.

        Just put a simple health warning on the side of perfume packaging, perhaps an age concent, (if you must)....and let consumers decide for themselves. Like you do with tobacco.

        ...which, (by the way) is much, much more harmful.

      • cytherian | 14th June 2015 19:35

        I agree wholeheartedly. There hasn't been, as far as I know, a precedence set for a health warning on the side of a perfume box. Do the perfume makers have some extreme sensitivity to doing this, fearing it will tarnish the marketing appeal and scare away potential sales? That it may incorrectly infer that people need to be concerned about perfume contents, thus driving away those who irrationally assume it's just not worth taking the risk any more? Cigarettes have the warnings, but people would still smoke them, because the nicotine addiction would override the possible fear of risk. It wasn't until banning took place to make it significantly inconvenient to smoke, PLUS the financial burden of high taxation to make it financially painful to many, before we started to see a societal downward shift in the number of people who regularly smoke. The only addiction possible with perfume is psychological... the habitual need to apply, or believing one can't smell fine without it. I don't think there are any ingredients which cause a physiological dependency... thus, perfumes don't have the addictive edge that cigarettes have,

      • Alasse | 14th June 2015 19:36

        I can see the regulations coming.. no spraying perfume in restaurants and bars.... WOOPS.

      • julian35 | 14th June 2015 19:53

        Thank you for your work on this Ms. Long.

        I appreciate recieving reliable information and education on this extremely complex subject.

      • Maggie Mahboubian | 14th June 2015 21:15

        Thank you for going out on a limb to frame this complex issue. There's a dearth of objective information on the subject and I appreciate your willingness to share!

        The fact of the matter is we're heading towards greater regulation in cosmetics. The question is, who's taking the lead? So far it's big business because they have the means to lobby for solutions that better suit their needs (i.e. restricting or banning ingredients instead of requiring the labeling of POTENTIALLY irritating constituents). But what about everyone else (artisan makers, connoisseurs, etc)? Where do we fit in? Are we going to sit idly by while Rome burns and lash out at each other (like Pia)? We need to demand information and clarification. We need transparency. So far, IFRA has been somewhat opaque like the industry it represents. We have the right to learn about the science and methods of obtaining results. Why doesn't IFRA have an informational website where one could learn about lavender, for example and its potential for sensitization, how that could happen, the reasons for restricting it's use and alternatives that are recommended. Without any objective information on the subject I find myself becoming inherently suspicious when the alternative to naturals "happen" to be a synthetically derived components, but still, I'd like to see the science. That kind of outreach would be a starting point.

        As an artisan maker and advocate (I founded FRAGments to raise awareness for artisan perfumery), I'd like to educate myself on the subject in an objective way. I want to learn all I can about the materials I use, how to handle them safely and ensure they will be safe for others to enjoy. But I also want to create art and have freedom to explore the medium.

        Is it too much to ask?

      • NeoXerxes | 14th June 2015 22:35

        My objections were clearly stated. You are welcome to disagree, however these statements only marginally can be called "the truth", and only if you are willing to overlook the included spin and the context in which the information is presented. It reeks of propaganda, whether this was intentional or not (and I'm willing to assume the latter).

        You are welcome to your own opinions, but please don't imply that I am deceiving myself. It's rude and unnecessary, whatever you believe about the article.

        Incidentally, I agree with the other David that the EU nanny state is a joke. This political claim is relevant because it demonstrates the sheer hypocrisy and monied interests at work in banning certain fragrance ingredients while only applying sin taxes to cigarettes (which are inarguably deadly products).

        Also, if you (and I don't mean you personally) happen to be in the business of manufacturing synthetic alternatives, your business model will inevitably profit from the banning and/or restriction of naturals. I'd suggest that there is an immediate conflict of interest in these companies supporting the IFRA in any way.

      • Geco | 14th June 2015 23:22

        Hi,

        excuse me for my bad english. i'm agree with many observations here : this is a good editorial but, i think, a bit "IFRA oriented" point-of-view.

        I'm agree for "safety consumer", i'm agree for rational approach to save perfumes, etc.etc.

        But :

        1 ) In the world exist profict, money and interests, that's not a little problem...

        2) In the city of Bruxelles live about 15.000 lobbyes-people, and their time are very occupied ,only for "safety consumers" and "people interests" ? I dont know...

        This article is very technical but not enough "political", this is its weakest point,

        my 2 cents, hi

        Geco

      • NeoXerxes | 15th June 2015 00:31

        Hi Geco,

        I agree with you completely. We should at the very least be suspicious of the interests at play here.

        By the way, welcome to Basenotes :).

      • Toujours Mink | 15th June 2015 03:15

        Pia, thank you for this article. I found it very interesting and educational. I appreciate the effort you put into it.

      • Kiliwia | 15th June 2015 05:14

        I totally agree with rogalal.

      • pluran | 15th June 2015 05:46

        Has nothing to do with protecting your health. Has everything to do with billions of dollars a year being made by substituting more costly naturals with less costly synthetic molecules. Easier to make, transport, use, etc. Never ending things that can never replace the need for natural ingredients in order to make the complexity needed for great fragrance. Simple pre-composed bases (not basenotes) throughout the fragrance, everything anchored by Iso E Super, sugary molecules and not very costly musks. No matter how much money you give them, most perfumers today couldn't conceive of making one of the classics.

      • Nukapai (article author) | 15th June 2015 11:01

        Just popping in to say thank you to everyone who has read and commented on this so far.

        As for the replacement of naturals with synthetics - I briefly mention in the article that due to current chemical regulation (REACH) + due to the existing costs of R&D for new, novel materials + due to the risk that a new, novel material might later be found to be IFRA-restriction worthy after all (thereby removing a lot of its value)... creating new aromachems is not actually a viable solution to replacing naturals at all. It's incredibly complicated and expensive. What is happening, though, is that when certain synthetic materials have been banned or restricted, new synthetics to replace them have to be created (folione -> neofolione, for instance).

        With naturals, reconstructions, fractions or special grades can sometimes replace the whole oil (for instance furanocoumarin-free bergamot).

        I am absolutely not advocating the use of synthetics over naturals in this article - only pointing out that we must not pretend they're not all chemicals, regardless of the source. We must join forces and consider whether we can lobby for more reasonable regulations overall and to do that has to come from a base of scientific argument, not from one of emotional appeal.

        Aesthetically, I adore naturals and love to use high proportions of them in my work when the brief allows it. I don't know any perfumer who doesn't love naturals. The brief, budget (and base product if not fine fragrance) dictate the work when you work behind-the-scenes.

        At the moment, there are only a few people who seem to be at pains to get to the bottom of things and to argue from a position of reality. A lot of the bureaucracy seems to be set up to be seen to protect consumers (rather than actually protecting them) and a lot of the anti-IFRA (or anti-EU) lobbying seems to be a kind of marketing exercise to highlight the use of naturals in one's brand.

        Until we operate from a base level where we engage with reality and join forces despite our differences we will be a divided bunch with a few weak, mewling voices which will remain largely unheard.

      • Paul P | 15th June 2015 11:36

        Let's put reality to the side for a minute.

        If all current Chanel No. 5 bottles were removed from the market, and a vast stash of 50,000 unopened old bottles of the vintage original were found somewhere, all perfectly preserved. These old bottles were put up for sale and sold within one week. That means there are 50,000 people out there now using the deadly vintage No.5.

        From a health perspective, what sort of reactions, illnesses, diseases etc. can we expect from these 50,000 people because of using this fragrance, over a period of 1 year, 5 years, 20 years ? Death, cancer, respiratory issues, contact dermatitis etc. ? This is a serious question.

        It seems to me that the whole EU / IFRA enterprise is just massive overkill. Enjoying vintage fragrances is a fairly benevolent pastime, compared to a host of other pastimes.

      • Avoirdupois | 15th June 2015 14:37

        I'm still laughing out loud at the opening paragraph; in particular the sentence "He gets up every morning rearing to go.".

        No doubt you meant RARING to go. What a gaffe!

      • Inolvidable | 15th June 2015 15:00

        I couldn't stop laughing at the writer's second paragraph: "He gets up every morning rearing to go.".

        HUH? Obviously she doesn't know that the expression is "raring to go". The idea of this imaginary 45-year old man "rearing" to go every morning is hilarious (and very embarrassing for the writer).

        The article is overly-long by FAR and never seems to come to any point. I lost interest about 60% of the way through it, gave up.

      • Nukapai (article author) | 15th June 2015 15:17

        Thank you for pointing out the typo. I'll ask Grant to fix it. I do have these articles looked at by an ex Sunday Times sub before they are submitted (because English is not my first language), but the odd blooper sometimes gets through. Always happy to see people are reading with enough care to spot this stuff.

      • mahboub | 16th June 2015 05:15

        Thank you for going out on a limb to frame this complex issue. There's a dearth of objective information on the subject and I appreciate your willingness to share!

        The fact of the matter is we're heading towards greater regulation in cosmetics. The question is, who's taking the lead? So far it's big business because they have the means to lobby for solutions that better suit their needs (i.e. restricting or banning ingredients instead of requiring the labeling of POTENTIALLY irritating constituents). But what about everyone else (artisan makers, connoisseurs, etc)? Where do we fit in? Are we going to sit idly by while Rome burns and lash out at each other?

        We need to demand information and clarification. We need transparency. So far, IFRA has been somewhat opaque like the industry it represents. We have the right to learn about the science and methods of obtaining results. Why doesn't IFRA have an informational website where one could learn about lavender, for example and its potential for sensitization, how that could happen, the reasons for restricting it's use and alternatives that are recommended. Without any objective information on the subject I find myself becoming inherently suspicious when the alternative to naturals "happen" to be synthetically derived components, but still, I'd like to see the science. That kind of outreach would be a starting point.

        As an artisan maker and advocate (I founded FRAGments to raise awareness for artisan perfumery), I'd like to educate myself on the subject in an objective way. I want to learn all I can about the materials I use, how to handle them safely and ensure they will be safe for others to enjoy. But I also want to create art and have the freedom to explore this medium.

        Is that too much to ask?

      • david | 17th June 2015 00:45

        THIS....which is why I gave the example of tobacco/ cigarettes. It's not about health safeguards. It's all about money.

      • theperfumegarden | 17th June 2015 10:43

        Thank you for such an in-depth article Pia.

        As an artisan perfumer, I understand and share the frustration and the animosity that many people have towards IFRA. Whilst I use some synthetics in mixed media fragrances when creating for other organisations, my own passion and my own business focus is in all natural perfumery in the UK, so the regulations are particularly hard to adhere to when attempting to design quality all-natural fragrance. In this respect, I do not particularly care about the natural vs synthetic debate, to me is a matter of doing what I love most, but using only naturals makes it so much harder!

        Is IFRA a friend or a foe? To be honest I am inclined to think it's a friend to some, but a foe to others. Having been affected so severely, both artistically and financially, by IFRA and EU regulations, I personally feel a lot of animosity, and yet, I still see the need for some regulation, as I do agree that there is an increasing risk of over exposure that could get out of hand because of the number of products that contain theses allergens. We all know that over exposure can lead to sensitisation so we need to take this issue seriously, but I wish that IFRA would actually care to support small and artisan producers like many of the people commenting on this article, so that over-regulation doesn't drive us out of business, and completely insane in the process.

        Marina~

      • creativeaccord | 17th June 2015 13:49

        The SCCS recently published their opinion on tagete extract and oil for cosmetic leave-on-products. When I was examining the level of thiophene derivatives in a tagete oil, I thought to myself, the use of tagete in cosmetic products will decline due to their opinion. The beautiful odor of tagete might become a note more commonly found in vintage fragrances rather than contemporary fragrances. In todays’ global market place, the banning, restriction, and general regulations on cosmetic products and fragrances is a shame, yet the need for compliance cannot be ignored. When planning to comply with the regulations for cosmetic products and fragrances the task has become significantly more challenging.

      • Robert Tisserand | 18th June 2015 23:11

        Thank you Pia, I like some of your ideas, such as different labels for different situations. In this increasingly regulatory environment, I have sometimes wondered whether "contains fragrance" might be sufficient for most situations. There is a thing called "evidence-based medicine". It means that, in spite of all the in vitro evidence, in vivo evidence, pre-clinical trials and various phases of clinical trials - does the treatment actually accomplish what it's supposed to accomplish when administered to patients? Sometimes the answer is, surprisingly, no. In the case of EU and IFRA regulations, we are at the equivalent stage of in vitro and in vivo evidence only for many substances - we have not even got to "clinical trials". We have little idea how much risk fragrance materials actually present, or whether no-adverse-effect levels exist for human populations in the real world. I would argue that we don't know, in spite of IFRA's elaborate modeling, where these levels actually lie, and patch testing is an extremely blunt instrument, in which results are highly dependent on the brand of patch used. Does restricting citral or cinnamaldehyde in a consumer product actually protect consumers from adverse skin reactions? In theory, it should do. But does the medicine actually work? Considering the size and extent of the regulatory industry, you would think we might have an inkling of an answer by now. I know there are continuing attempts to broaden the palette of suspect allergens to be tested. But in an important way, this misses the point. Where is the evidence that prohibition or restriction meaningfully protect consumers? As yet, there is no end in sight to fragrance regulation. It's time for a reality check.

      • cacio | 19th June 2015 07:35

        A very interesting and informative piece. As an economist, I was also under the assumption that the whole IFRA thing was a way to manipulate the market in some ways. But I think you've made a good case that this is not the main story.

        Reading through your apologetic tone (which I think most BNers will object to), I understand your thesis as: regulators gone wild while the industry doesn't care. Safe perhaps water, everything else can pretty much cause reactions of some type, so there's no limit to what expanding regulators can do. But the second part of the thesis (which the article didn't talk much about) is that the industry doesn't seem to care. After all, industries are pretty good at limiting regulations (via lobbying, as somebody was pointing out).

        But, to cite a case, Mr A of LMVH fame couldn't care less. After all, he was cheapening his stable well before IFRA came screaming.

        cacio

      • pluran | 19th June 2015 09:02

        Hilarious.

        All world events revolve around five things: M-O-N-E-Y. At approximately $35 billion a year and rising approximately another $5 billion a year, perfumery qualifies as a massive world event. Chandler Burr's book The Perfect Scent makes it perfectly clear that modern perfumery is predicated on lies and the withholding of information. The EU/IFRA stuff is just another extension of it.

      • Nukapai (article author) | 19th June 2015 10:39

        Dear Robert, thank you for your comments. Following from your analogy, perhaps it could be said that the current 'medicine' is really a placebo and nobody has the money or stamina to do anything else. The placebo seems to be working in a way, so that's what we've got.

        Perhaps it's not quite that bad, but after the amount of reading I've done for this, one would have hoped to see a bit more robust evidence of consumer protection (the intent is certainly there, but the tools and the logic aren't always as robust as they could be).

        I agree that it's time for a reality check. In a utopia, people from all parts of the fragrant world would form a lobby group based on reality (rather than emotional arguments and conspiracy theories) and try to address our apparent slide to 'safer' fragrances. Here is where the money question really comes in. How would such activity be funded? The research required to understand what is really going on, what is really needed, and to set up the logistics side, resources and education necessitated by an overhaul..... where would the money for that come from?

        My fear is that if those questions are asked, left hanging in the air, and the players go back to dealing in the 'that'll have to do' placebo solutions, we risk getting to a point where the logical progression of our 'disease' (stretching your analogy to its limits) will demand an amputation or three. It feels like it's time for a re-think.

      • Dorje123 | 19th June 2015 17:29

        Good article, I think it sheds some light on the issues the industry is dealing with.

        I think the last paragraph is a good summary:

        "If the industry fails to proactively address all the problems and loopholes in current fragrance regulations, the future of fragranced products is unlikely to be endangered entirely, but it will most likely be boring. We’ll look back to a time when everything didn’t smell of the same few dozen ultra-safe substances and wonder why we didn’t organise ourselves and do something sooner.

        So now what?"

        I like the proposed solution where there is a second set of rules that would allow natural/classical perfumery to exist and I think it's fair if warning labels must be used. Of course even then it shouldn't be a free-for-all as we don't need to use ingredients that disrupt hormones and cause cancer, but stuff like oakmoss where it's an issue with skin allergies in a very small percent of the population should be allowed.

        However, I don't think it is completely true that the origin of the chemical doesn't matter when we are dealing with synthetics that don't exist in nature, these kinds of chemicals are new, humans have never been exposed to them before and it seems our reaction to them can be far more unpredictable and potentially harmful vs chemicals that occur naturally. For instance the nitro musks have been studied for many years, it took decades after they were "invented" to get an idea of what the effects are and I'm not sure the effects of having synthetic, bio-accumulative musk compounds in our environment have been fully understood. The phenomenon of chemical sensitivity is growing worldwide and it is not fully understood either. So, just like the Romans drinking from lead cups, we may be inadvertently poisoning ourselves with chemicals IFRA and EU think are just fine right now. Personally, I'd rather take my chances with naturally occurring ingredients in my fragrances whether they are from natural sources or not. The fact that a great majority of fragrances contain non-naturally occurring synthetics is more worrisome to me than natural substances that may produce less harmful and well-understood allergic reactions.

      • mumsy | 19th June 2015 20:03

        I don't think there is any easy way to neutrally present all of these complex issues. This article is a good attempt to reveal many issues and is presented from the authors perspective. There is nothing wrong with that. The more constructive opinions and counter opinions that get presented in this thread as a result, the better the reading is.

        I am an amateur perfumer who is fond of naturals and hand made ingredients made from plants in and around the garden. I'm sure there is very little that I could make myself that would ever satisfy any of those bodies stated. Even if one wished to follow them all to the letter, the costs to a small one man band who is presenting an indie perfume, are near prohibitive.

        The 'black market' mentioned is caused in part by the discerning customer getting fed up with their forced restricted choice. A situation made possible by a litigeous society who are too scared to let the individual do as they please and the potential customer to choose as they please. Informing the customer of any prospective 'dangers' is one thing and making something so restricted that it becomes a sue-able offence to use is another.

        Peanuts are the most equivalent produce that is genuinely life threateningly dangerous to those unfortunate allergic persons. Yet these are liberally littered on all isles in all shops and in much produce with a mere warning label. Perfumes should be only restricted along these same lines of a warning. These discrepancies we let happen and the laws and regulations we allow within our society are quite frankly ridiculous.

        Freedom of choice is rapidly becoming a thing of the past and true creativity will be following suit. Maybe one day we will all end up as pink blobs in bubblewrap with only a thumb poking out to operate the computer cursor. We will not move for fear and everything will be made and delivered by robots. Perfume will of course by then be of no value.

      • Birdboy48 | 29th June 2015 09:06

        I must say, the media (or the fragrance industry) has done a shamefully effective job of concealing the many fragrance disasters and disfigurements which clearly must have been happening on a sadly regular basis for all of these years. Perhaps the real truth will come out someday, and we'll all do our duty to help the walking wounded among us, who's sorry fate has been hidden from sight for so long.

      • The Islands | 7th July 2015 02:13

        The EU is way overbearing. It initially began as a union serving to make trade between European countries easier and more efficient. Now they're more like a government that governs over most of Europe and tries to pass crazy laws and regulations.

      • highnote | 13th April 2016 10:14

        The author explained the issue well from both sides. It is a moderately long piece, but overall it is written fairly.

      • Marial | 10th May 2016 18:16

        Hello

        thank you for this interesting article

        In EU

        what about fragrances used in candles?

      • David Ruskin | 11th May 2016 10:08

        Every fragranced product is covered by EU regulations. At the very basic level you can divide fragrances into "on skin" and "not on skin"; different regulations apply, but regulations, there are.

      • Bigsly | 11th May 2016 10:17

        David, do you know if is it possible to create a product meant to be sprayed on paper card and placed next to you, a sort of limited area "room spray?" And if so, would this be a way around the European restrictions for "on skin" products? I suppose that here in the USA, I could create a scent in a box with a bunch of paper cards and "directions" on use on the back of the box, so long as it contained the traditional perfumery ingredients, right (other than perhaps things like nitro musks)?

      • David Ruskin | 11th May 2016 10:56

        That would probably be covered by card air freshener. The regulations concerned with on-skin products are covered by cosmetic regulations (not sure about detergents which are regarded as on-skin); air fresheners are covered by the same regulations that cover household cleaning products. Concentration of fragrance is the most important point. Labelling requirements will be different too. However, you could probably get away with it.

        I'm sure that it is possible to find all the regulations somewhere on the internet; but I have no idea where. It is not made easy for ordinary folk (as opposed to EU mandarins) to find out anything about EU regulations.

      • Please check your facts | 6th November 2017 18:48

        In regard to the misinformation that fragrance itself is not an inhalent allergen, I believe you are quite misinformed. I live with someone who has documented carvone allergy and it affects her whether inhaled, ingested or comes in contact with her skin. So, please do not dismiss the allergy to being contact only. This, I truly believe, is the reason Why limiting fragrance in everything is necessary. She, and others I have met, must isolate themselves from society because of the over use of fragrance on all products.