The CTPA doesn't set the rules though, it's the EU. The CTPA helps its members to understand them and to comply with Regulation (EC) No 1223/2009 which came into force on 11 July 2013.
You can download the Directive from the EU's website. It's not an easy read, but it's essential for anyone operating inside the EU.
Yes, people would need to provide their complete formula.
One person did say "but you'll see my secret formulas!" Someone has to. But here, Triona will run the reports, not me, via her IT organisation. I'm not interested in other people's formulae, as I've got plenty of my own that I want to create, and I don't have time or the inclination to do any of this myself when I could be mixing lovely things.
What happens is that the multi-level database I use has the entire up to date IFRA database on one level, and the perfume formula is cross-checked against this to calculate how much geraniol, citral etc is in the fragrance...
This gives the data on what needs to be declared on the label, and also what strength it's legal to use it at within the different categories. (Skincare, leave on, rinse off, perfumery etc.)
For example, some of mine turn out to be legal at 40% strength, and some only at 8% because of the levels of citrus essential oils I'm using.
It sounds simple, but it took me then Triona a year to crack it completely.
This is whey we'd like to share it.
1. It cost me over £2K of my heard earned copywriting cash but I simply could NOT find another practical way to get my own perfumes compliant. You can get it from DataEssence but I'll warn you know that their customer support is based on the principle that the customer is really stupid, and their user help guide assumes that you already know exactly how it works.
I've already invested that money, and have to pay £500 a year for updates. every time IFRA changes something. Why not share?
2. I've heard from a bunch of perfumers who don't know that there are any laws to comply with, or that the laws don't apply if they're using natural materials.
There's an aromatherapist selling aromatherapy blends at a small craft shop near me and she's happily (obliviously) breaking every regulation in the book. I tried to explain and she simply didn't believe me, and proudly tells me that hers are such good value because she's using 35% essential oils in her perfumes.
3. I know more perfumers who are where I was two years ago, knowing that I had to do something about it but having no idea where to start.
I looked into having my formulae checked and rubber stamped by some UK cosmetic chemists, at £250 a shot, and anyway they just turned me down. They said they were too busy with their current clients' work. So I was forced to look for another solution.
The problem is that for us little outsiders, access to the kind of information we need can be very expensive. £500 + VAT for an IFRA certificate and a toxicology report is nothing for the big guys, but a huge investment for us.
What Triona can't do is the toxicology report that the EU demands. But if you have your IFRA certificate, then getting a toxicology report is much much easier. (Without IFRA it's nigh on impossible.) If you're outside the EU, then an IFRA certificate should be fine.
I'm also going to this:
Maybe see some of you there?