In several threads and throughout fragrance fora and blogs there are several misconceptions about IFRA restrictions and the EU regulations. Especially the difference between the 2 doesn't seem to be clear.
Below I will try and explain those, to the best of my abilities. This information comes from the (brief) experience as an insider from the fragrance industry. For the last 2 years I have been involved in several tasks and worked closely with both perfumers, fragrance chemists, scientists and regulatory bodies. So I hope to shed a bit of light.
I always stand corrected if other insiders care to join in and give their point of view.
I will however do my best and keep facts and personal opinions separated.
The facts:
IFRA stands for International FRagrance Association. It is a body that officially represents the fragrance industry as a whole. Besides informing the public on fragrance and fragrance materials, their main focus is the safety of fragrance materials. That particular work is done by their scientific body RIFM = Research Institute for Fragrance Materials.
Most important detail: ONLY companies that are a member need to abide by their safety restrictions. Truth is: most big companies are indeed a member.
However many indie perfumers are NOT a member.
~~~~~
EU stands for European Union. Within the 23 countries that are a member of the EU there is legislation for the manufacturing and selling of cosmetic products. Perfume is a cosmetic product. The legislation is called the EU cosmetics directive.
The word legislation says it all: this is a law, it is NOT a guideline for members only. ALL companies that are either located in the EU or sell to the EU MUST follow that law.
Shortly: for companies selling fragrance to or within the EU, the EU law must be followed, while IFRA restrictions are OPTIONAL = for members only.
Where do all these misunderstandings come from?
There is a BIG difference between the IFRA restrictions and the EU cosmetics directive.
IFRA describes many different safety levels of several fragrance ingredients. They also prohibit around 90 fragrance ingredients.
The EU cosmetics directive also currently known as 76/768/EEC prohibits less fragrance ingredients (around 30).
Since 1976 the EU cosmetics directive has undergone a few changes. One of them was known as the 7th Amendment to the Cosmetic Directive of the European Union (EU). In 2003 the directive has added 26 new ingredients to the Annex III List of Substances Which Cosmetic Products Must Not Contain Except Subject to Restrictions and Conditions Laid Down."
With the exception of 4 fragrance ingredients that are restricted to certain levels, it only says that 26 fragrance materials have been identified as perfume allergens. Thus all 26 MUST be disclosed on the label of a cosmetic product, but ONLY if their quantity in the fragrance exceeds a certain level (for perfume that level is 0.001%).
Click here and search for example 'fragrance' and see the exact materials.
For example oakmoss is one of those perfume ingredients. A perfume sold in the EU that contains 50% oakmoss, may be sold in the EU as long as 'oakmoss' is listed on the label as being 1 of the ingredients.
However in order to maintain uniformity IFRA also tightened their restrictions, although from the EU point of view, they didn't need to.
Why is the EU in the news regarding fragrance?
The EU cosmetic directive will change again entering July 2013. This new piece of legislation differs quite a bit from the other.
Click here to see the original document regarding this new law called (EC) No 1223/2009
Before this piece of new legislation will become reality the EU consults with Scientific Committee on Consumer Safety = SCCS. In June 2012 this committee has entered a paper regarding the latest on dermatological research regarding possible fragrance allergens. Click here to read the original paper
In the official document the SCCS does offer several solutions for allergy suffers, prohibition being just 1 of the possibilities. However keep in mind that the SCCS is only an advisory body, it does NOT make the law.
This paper did raise concerns with the fragrance industry and attracted much media attention.
Therefor the EU released this official summary to the public:
click here to read this summary
It looks like prohibition is off the table and the restrictions are only limited to disclosing more fragrance materials on the label, again only if their use exceeds a certain level.
Personal opinions/insights:
The EU legislation changes all the time. The economic climate dictates much of the outcomes. It seems too easy to blame the 'Brussels bureaucrats' for changes occurring in the fragrance industry. Much more is going on. Bad journalism is all about chasing sensational stories and stating things black and white in order to get attention. The practice differs, in my experience much is considered before law becomes reality.
And then there is always the fact that not everyone follows the law. And that there are differences in how each EU country puts the law into practice, including monitoring safety.
Another issue is the way many of the big fragrance manufacturers are hung up on protecting secret formulas.
Read here the latest on trade secrets & the fragrance industry on the IFRA website
When more needs to be disclosed to the public, those fears will have a ripple effect. So how can a consumer actually comprehend the many layers of the truth if media is thriving on fear? And who knows who is actually feeding those fears to the media? And to what intent?
Also some manufacturers may see this as yet another opportunity to either cheapen a formula or prevent unnecessary future problems, for example out of fear of getting sued. Even if the IFRA nor the EU don't dictate those changes.
A friend of mine that is a journalist told me once: 'if you want to know the truth, follow the money or power'.
I believe that the truth lies somewhere in the middle between making a living and gathering more money or power. Meanwhile I tend to stick to the facts.
Below I will try and explain those, to the best of my abilities. This information comes from the (brief) experience as an insider from the fragrance industry. For the last 2 years I have been involved in several tasks and worked closely with both perfumers, fragrance chemists, scientists and regulatory bodies. So I hope to shed a bit of light.
I always stand corrected if other insiders care to join in and give their point of view.
I will however do my best and keep facts and personal opinions separated.
The facts:
IFRA stands for International FRagrance Association. It is a body that officially represents the fragrance industry as a whole. Besides informing the public on fragrance and fragrance materials, their main focus is the safety of fragrance materials. That particular work is done by their scientific body RIFM = Research Institute for Fragrance Materials.
Most important detail: ONLY companies that are a member need to abide by their safety restrictions. Truth is: most big companies are indeed a member.
However many indie perfumers are NOT a member.
~~~~~
EU stands for European Union. Within the 23 countries that are a member of the EU there is legislation for the manufacturing and selling of cosmetic products. Perfume is a cosmetic product. The legislation is called the EU cosmetics directive.
The word legislation says it all: this is a law, it is NOT a guideline for members only. ALL companies that are either located in the EU or sell to the EU MUST follow that law.
Shortly: for companies selling fragrance to or within the EU, the EU law must be followed, while IFRA restrictions are OPTIONAL = for members only.
Where do all these misunderstandings come from?
There is a BIG difference between the IFRA restrictions and the EU cosmetics directive.
IFRA describes many different safety levels of several fragrance ingredients. They also prohibit around 90 fragrance ingredients.
The EU cosmetics directive also currently known as 76/768/EEC prohibits less fragrance ingredients (around 30).
Since 1976 the EU cosmetics directive has undergone a few changes. One of them was known as the 7th Amendment to the Cosmetic Directive of the European Union (EU). In 2003 the directive has added 26 new ingredients to the Annex III List of Substances Which Cosmetic Products Must Not Contain Except Subject to Restrictions and Conditions Laid Down."
With the exception of 4 fragrance ingredients that are restricted to certain levels, it only says that 26 fragrance materials have been identified as perfume allergens. Thus all 26 MUST be disclosed on the label of a cosmetic product, but ONLY if their quantity in the fragrance exceeds a certain level (for perfume that level is 0.001%).
Click here and search for example 'fragrance' and see the exact materials.
For example oakmoss is one of those perfume ingredients. A perfume sold in the EU that contains 50% oakmoss, may be sold in the EU as long as 'oakmoss' is listed on the label as being 1 of the ingredients.
However in order to maintain uniformity IFRA also tightened their restrictions, although from the EU point of view, they didn't need to.
Why is the EU in the news regarding fragrance?
The EU cosmetic directive will change again entering July 2013. This new piece of legislation differs quite a bit from the other.
Click here to see the original document regarding this new law called (EC) No 1223/2009
Before this piece of new legislation will become reality the EU consults with Scientific Committee on Consumer Safety = SCCS. In June 2012 this committee has entered a paper regarding the latest on dermatological research regarding possible fragrance allergens. Click here to read the original paper
In the official document the SCCS does offer several solutions for allergy suffers, prohibition being just 1 of the possibilities. However keep in mind that the SCCS is only an advisory body, it does NOT make the law.
This paper did raise concerns with the fragrance industry and attracted much media attention.
Therefor the EU released this official summary to the public:
click here to read this summary
It looks like prohibition is off the table and the restrictions are only limited to disclosing more fragrance materials on the label, again only if their use exceeds a certain level.
Personal opinions/insights:
The EU legislation changes all the time. The economic climate dictates much of the outcomes. It seems too easy to blame the 'Brussels bureaucrats' for changes occurring in the fragrance industry. Much more is going on. Bad journalism is all about chasing sensational stories and stating things black and white in order to get attention. The practice differs, in my experience much is considered before law becomes reality.
And then there is always the fact that not everyone follows the law. And that there are differences in how each EU country puts the law into practice, including monitoring safety.
Another issue is the way many of the big fragrance manufacturers are hung up on protecting secret formulas.
Read here the latest on trade secrets & the fragrance industry on the IFRA website
When more needs to be disclosed to the public, those fears will have a ripple effect. So how can a consumer actually comprehend the many layers of the truth if media is thriving on fear? And who knows who is actually feeding those fears to the media? And to what intent?
Also some manufacturers may see this as yet another opportunity to either cheapen a formula or prevent unnecessary future problems, for example out of fear of getting sued. Even if the IFRA nor the EU don't dictate those changes.
A friend of mine that is a journalist told me once: 'if you want to know the truth, follow the money or power'.
I believe that the truth lies somewhere in the middle between making a living and gathering more money or power. Meanwhile I tend to stick to the facts.
thank you for reading!
