LH. I am pleased to have had the opportunity to clear up some of the misperceptions surrounding IFRA UK and its policies. I’d like to thank Persolaise for taking the time to speak with me – a meeting I greatly enjoyed.
I welcome the comments made by visitors to the Basenotes forum. It was especially good to hear from people who took the time to ask questions and gain a greater understanding about IFRA UK – people like Mimi Gardenia, who wrote: “I am beginning to understand the IFRA a little bit more now” and from Saintpaulia who commented: “It does appear from this interview that some of us have been blaming the wrong organization”. And I must thank rogalal who said: “Wow, am I literally the only person in all of Basenotes who thinks that the IFRA has a valid point?” Well, rogalal, no you are not but we still have some way to go it seems in convincing some others that IFRA protects the perfume industry and is not its enemy.
Before responding to particular questions, I’d like first to comment about labelling as this was an issue mentioned by many people. Some bespoke perfumers and others believe that labeling rather than restricting materials is the way forward. We believe that labeling doesn’t help, not just because people don’t necessarily read labels but also because some consumers may become sensitised to some ingredients. Instead, our aim is to ensure materials are used below the level at which they readily cause sensitisation – and therefore allow a larger population to enjoy fragrances safely and prevent some people from developing an allergy in the first instance. We believe that is the sensible and safe approach.
I offered to answer specific questions...
Q. Is tree moss more of an allergen than oak moss?
LH. Sensitizers are always labeled as regulations dictate. We regard both materials comparable regarding their ability to induce sensitization. This is why both IFRA Standards are almost identical, and the same with regards to the permitted use levels as well the permitted level of atranol and chloroatranol (the impurities assumed to be the driving force for the allergic potential). Further, the Standards are linked, so the use of both oak and tree moss together combined cannot be higher than that which is permitted in the individual Standards.
Q1. What do you think about the proposition that certain fragrances, formulated prior to a certain cut-off date and meeting certain (yet-to-be-determined) criteria would be granted 'legacy status' and allowed to be manufactured and sold using their original formulas? (I can immediately see that this isn't cut-and-dry because of issues such as nitro musks but I do think the idea has serious merit and could be considered).
LH. This is an interesting concept but in our view not really workable. If substances are found to be unsafe for humans or the environment when used in certain quantities, then those materials should be restricted or banned. Just because a material has been used for years unwittingly though deemed unsafe now, doesn’t make it okay even if labelled. We wouldn’t want to return to using lead based make up or drinking our water from lead taps, for example. Science moves on and so does our knowledge and understanding.
Q2. Do you think that some manufacturers blame IFRA recommendations for why they've had to reformulate - when, in fact, they have been doing it all along to cut costs?
LH. There are many reasons why manufacturers reformulate. These may have to do with costs in some cases; raw materials prices have soared in recent times, some by as much as 400 per cent. But equally raw materials availability provides restrictions together with the need to protect endangered plants. Usually, the reason for altering a formulation is changing trends and tastes. Manufacturers have to keep up with what the market requires and customers demand.
Q3. What would you say to claims that the IFRA recommendations encourage the trend towards declining natural material production and, thus, increased prices of whatever crops remain (which, in turn, feeds into the scenario above). Isn't this bad for the growers and bad for the industry? Should there not be some attempt at conservation and protection of these traditional practices?
LH. No this just isn’t the case. Many of our members who are engaged in sourcing raw materials actually help the growers in very practical ways. I’d urge Basenotes visitors to view the following videos and there you will find answers shown more graphically than words I can write here and view the Earthoil film about organic fairtrade mint, just one example of the ways in which the industry works with farmers
On the wider questions of material production and supply as well as restrictions of some materials, I’d like to point out that IFRA has delivered some startlingly positive results. Far from banning certain materials and thus changing irrevocably some fragrance compounds of old, IFRA has in fact been protecting these materials.
A material such as oakmoss would have disappeared if it hadn’t been for IFRA. The EU would have abolished their use. In fact, thanks to our intervention, they are still capable of being utilised as part of the palette of 3000+ materials which perfumers can employ in their creative art.
There are restrictions on the use of some substances but, these are justified when balanced with the safe enjoyment of fragrances for all. Where fragrances have been discontinued it is almost always because they no longer had the following they once enjoyed. Quite simply, fragrance is highly susceptible to the vagaries of fashion; so it’s no surprise to those in the industry that perfumes come and perfumes go as trends dictate.
IFRA helps perfumers by fiercely standing up for the continuing use of certain fragrance raw materials. The Scientific Committee for Consumer Safety (SCCS), the advisory group to the EU Commission, and other groups may sometimes receive representations from lobby groups including allergy experts and dermatologists, for instance, suggesting a ban or restriction on fragrance ingredients. When that occurs, IFRA globally and the Research Institute for Fragrance Materials (RIFM) review the substance, gather views from perfumers and form a group to review the situation. We then conduct extensive testing if required and, if these tests reveal a positive result, then further detailed tests are undertaken to investigate the tipping point and establish the level at which the substance could be safely used by most people. The independent RIFM Expert Panel reviews the findings of this research, makes recommendations to the IFRA Scientific Committee and the evidence is then submitted to the EU Commission. We recommend the parameters for safe usage.
What makes IFRA such a strong organisation is the fact that it leads the way by issuing its carefully researched Standards. IFRA’s safety dossier, which recommends limiting usage of a material to a certain level, is then issued as one of IFRA’s Standards. And these Standards are not mere guidelines; they are mandatory for IFRA members.
The benefits are obvious – for consumers, retailers, manufacturers right through the supply and usage chain. If an IFRA member develops a perfume, it is deemed safe not just in the UK but across Europe and beyond. For global brands this has hugely important and positive implications.
And for consumers and health professionals it provides a guarantee that the highest possible safety standards are being adhered to.
Finally for perfumers, creative as they are, a restriction shouldn’t have a dampening effect but could be expected to spur them into doing what they do best thanks to IFRA Standards, in a safe and assured fashion using materials from a palette of 3000 substances some of which might otherwise have been thrown out - forever.
Far from being destroyers of the perfumer’s art, we are very much the champions and protectors. We help ensure that this wonderful, creative process can continue to be enjoyed both by the perfumers and by those whose lives are enhanced by the safe enjoyment of fragrances, whether these scents are in fine fragrances or everyday household products”.
Examples of items that would have risked being banned* by the EU if it were not for IFRA were –
· Dimethyl Anthranilate (contained in mandarin oil)
· FuroCoumarins (affecting all citrus oils containing higher levels of FCs)*
· Tagette (marigold)
· Tree moss (as affected as oakmoss)
· Verbena absolute
· Vetiveryl acetate
* in case of FCs being so heavily restricted that it equals a ban
Q4. Do you think IFRA helps to calm down the phenomenon of chemophobia and perfume-phobia (where perfume has become akin to secondary smoke or worse in some areas of the world and people are banned from wearing it at work or in public places). If so, how does IFRA help? Or do you think it actually legitimises perfume-phobia?
LH. On the contrary, IFRA works tirelessly to promote the enjoyment of perfume. In the UK for instance, we have been in touch with Asthma UK to name just one example. They certainly understand that fragrance can and should be used safely and do not condone any ‘banning’ of fragrance in the workplace or public places. Like us, sound organisations such as this one, promote moderation and consideration for others as being the way to pursing good practice.
Q5. Do you think using the precautionary principle is the most effective way in which to determine fragrance material risk? If so, why?
No. The precautionary principle is a legal construct designed to be used by regulatory authorities as a last resort, when all other avenues of assessing risk have been exhausted. The use of the precautionary principle as an overriding principle is not conducive to innovation and in fact can actually adversely affect it.
IFRA Standards are based on risk assessments. The precautionary principle is not used as a guideline since our risk assessments provide adequate guidance on the safe use of the materials.
Another writer asked:
Q6. Why has the ingredient quality dropped so dramatically in recent years to the extent that most new perfumes just do not smell good to anyone with experience?
LH. Speaking as a perfumer, I think this is just not the case. Remember that as we get older, our acuity is not so strong and so scents do just smell different as we age. Where fragrances do change this is often due to changing trends. I think it is a little like older generations saying that the music of their youth was ‘more tuneful’. To them it is; but not to a younger generation.
Q7. And to end where we began with the writer who asked: “Wow, am I literally the only person in all of Basenotes who thinks that the IFRA has a valid point?”
LH. I would answer that IFRA UK has a clear mission to defend and to promote the industry. I think that fragrances haven’t until recently had a vocal champion and so misunderstandings have arisen. We’ve been so busy doing the work in the way that an Association should, that it seems perhaps we’ve failed to involve and inform everyone who should understand what we’ve delivered.
Thank you Persolaise and Basenotes for at least allowing us to kick-start that process of telling people what we do and why. You may agree or disagree, but it’s important that you know and understand what we aim to do. So, if you have read this far, thank you for your time.