IFRA certificates for us little guys

    IFRA certificates for us little guys

    post #1 of 31
    Thread Starter 
    At 4160Tuesdays we've had an interesting time getting our safety certification organised. It's been two years of frustration and expense. I wouldn't wish it on anyone else.

    But we've cracked it. Or rather my long time friend and IT whizz Triona has cracked it for me.

    She has worked out how to use the excruciatingly expensive and complex software I bought. I'd managed to get it to list the EU allergens we have to declare on the label, and the IFRA approved legal strengths. Triona can produce complete IFRA certificates for me so I've handed responsibility to her.

    I know from here on Basenotes, and from people who have contacted me directly, that most aspiring perfumers have no idea just how very complicated and stringent the rules are.

    (One woman thought it was fine to use a 20% rose absolute blend and that all the EU needed was to label it "parfum". This would be very very illegal in the EU, and also breaks quite a few IFRA guidelines so wouldn't get a safety certificate.)

    It generally costs £250+ to get an IFRA certificate in the UK. And that's only if you know your blend is already compliant. It can be rejected, you have to alter it and resubmit for another £250, with no feedback.
    In my experience most people have no idea if their blends are compliant or not.

    It's perfumery catch 22.

    So, here's the question.
    If Triona were to charge £45 per Safety Data Sheet, including the list of allergens you need to put on your EU compliant label, the concentration you're allowed to use it at, IFRA certificate plus feedback on what to change if yours doesn’t pass first time, would you be interested in that as a service?

    Get in touch if you'd find this useful.

    Let's get more indie scents out there!
    post #2 of 31

    Interesting - well done!

    And well done on the distribution too.

     

    It sounds like a useful and helpful service.

     

    Presumably, people will need to provide a complete formula for each fragrance?

     

    The CTPA rules are not something that I'm yet totally familiar with, apart from the IFRA ones!

    post #3 of 31
    Thread Starter 

    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.

    For example:

    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:

    http://www.tsgeforum.com/event-detail/?ee=22

     

    Maybe see some of you there?

    post #4 of 31

    Thanks for the info., it sounds like quite a time-saving idea!

    There may be other formula-related issues that members may need to consider.

    post #5 of 31
    I assume NDAs come standard with this service?

    Sorry to hear it was such a pain to get the software to work; in my experience the only thing companies like that really have to offer is their databases.
    post #6 of 31
    Thread Starter 
    Absolutely, everyone can have an NDA.
    Triona used to run the UK Institute of IT Security so she's got a brilliant track record you can check out if you like.
    Mind you, a lawyer once told me that if you feel you need one you probably shouldn't be doing business at all as they are in fact totally worthless. You need to find people you really trust.
    Look us up. :-)
    post #7 of 31

    It is my intention to make the following comments in a respectful manner:

     

    Please, someone, tell me, why would small perfumers want to be IFRA-compliant? 

     

    1.  Do you believe that the IFRA safe levels of concentration are correct, and that is why you follow them?

    2.  Or do you disagree with some of the restrictions, but you are afraid of lawsuits filed by consumers for causing allergies?

    3.  Do you fear losing sales if you don't become IFRA compliant?  Is this because retailers won't stock your products or consumers won't buy them?

    4.  Do you think the majority of the public knows what IFRA-compliant means?  In America, they don't.

    5.  Do you think the IFRA restrictions will put irresponsible perfumers out of business for selling dangerous products?

     

    The reason I ask is because you are going through so much hard work and expense to prove you are compliant, and what will you get for it?  

    It seems unfair to your budget and restrictive to your art unless the rewards are a reasonable exchange.  I am genuinely interested in knowing why it is a good idea for you to comply.

    I do not mean to be judgmental.  Please tell me your rationale.  I will accept whatever you say.

    post #8 of 31
    Quote:
    Originally Posted by 4160Tuesdays View Post

    Mind you, a lawyer once told me that if you feel you need one you probably shouldn't be doing business at all as they are in fact totally worthless.
    That's the truth in most cases.

    It's some help if you're doing something fairly unique and don't want it duped by the business who's contracting you though. There are some legitimate and trustworthy companies out there who would never break an NDA, but if given a formula for review without one, would just assume it was non-exclusive/had no conditions attached to it/was part of the bargain you had going with them.

    It's generally not so relevant to companies who are just doing assessment work for you, but still my gut reaction tends to be to get an NDA signed for any commercial formula that's let out of your own care.

    I've had salespeople pitch me other companies' products as examples of use before...it's not in the long run a tremendous issue but it's made me leery. lipsrsealed.gif
    post #9 of 31
    Thread Starter 
    On NDAs. Yes, Happy to do them.

    It's a separate company from mine and I won't be involved. Triona hasn't joined Basenotes yet. She's not that fussed about fragrance herself, she's just really good at IT so I said I'd put it up here and ask on her behalf to see if it might be a goer.

    Wow, that is appalling that a company would show someone else's work! I'll make up some fake examples for Triona to use.


    On why I need to be IFRA compliant for 4160Tuesdays:
    Hello purplebird. Good questions and fair points.
    If you want to sell any perfume at all in the EU, which I'm doing, we have to follow EU law. The EU takes IFRA and adds more conditions on top. I can make non compliant perfumes for direct customers, but not for retail.
    Without IFRA certificates I stand no chance of complying.

    I also need to declare the lists of EU recognised allergens on the labels - no matter how silly we think it is - or I'm breaking the law. So really, to have any kind of business here without the risk of being closed down, it's IFRA plus all the rest of the laws. I need a whole file of information for every product. Safety data sheets, shipping info...

    The public know very little about IFRA and probably care even less.
    But I'm sure you'll understand that this makes no difference over here. IFRA compliance is voluntary but EU regulations are not, and EU regs are based on IFRA.

    Sometimes I think I ought to move to the US, or, even better, the middle East where they don't bother with the regs at all.

    So the reason everyone in Europe has to go to this expense, not just us, is that without it, we can be closed down in an instant and lose all our business. There isn't a choice.

    Sad but true. If you do it as a hobby you're fine. If it's a business, no matter how small, as soon as you sell one bottle you're subject to EU law.
    post #10 of 31

    Please excuse my continued ignorance, 4160Tuesdays - roughly how much does it actually cost to launch a single compliant retail fragrance in the U.K. at the moment, all costs considered?

    post #11 of 31

    Just read this. Wish I could offer something of value but I can't. However let me say the woman behind the 4160 Tuesdays is a truly amazing woman. I have championed her from day one, she never ever stops, she knows her stuff, she is producing oustanding perfumes and simply put she is a big inspiration to me. Feels daft not being able to address you by your name here though 4160 Tuesdays!! Adam

    post #12 of 31

    So, I have no plans to be IFRA or EU Compliant.  At least for my current products in the PK Perfumes line.  Maybe I'll make something less adventurous for EU, but nothing I have now would get dumbed down.

     

    It looks like though I might get into Ukraine, does anybody have a clue on their laws?

    post #13 of 31
    4160Tuesdays this is wonderful news and I hope many perfumers come in contact with you for that certificate and extra pieces of advice!
    post #14 of 31

     i'm interesting  can IFRA be responsible for their mistakes and pay compensations to  customers and manufacturers?

    post #15 of 31

    4160 Tuesdays:  Thank you for your answer.  There's no use debating the differences between U.S. and E.U. business and regulation environments, so I will merely (and sincerely)  wish you the best of luck in your endeavor to become compliant.  I certainly will visit your website for samples.

     

    Masha:  Good point.  What if the IFRA levels are wrong?  However, then I am afraid they will ban fragrance, altogether. 

    post #16 of 31
    Thread Starter 




Loving perfume on the Internet since 2000