I'm sending this to my three favorite forum hosts - please feel free to post or excerpt from it. The Natural Perfumers Guild will be joining Cropwatch in renewed efforts to call attention to, and hopefully, and end to, such Draconian policies that we term bad science. These policies, outlined below, will destroy the perfumes we love.
Below is a letter I just received from Tony Burfield of Cropwatch. Feel free to redistribute it.
Citrus Oils: the Situation
Cropwatch is directly opposing IFRA's Risk Assessment on furanocoumarins, and its proposals to severely restrict citrus oil usage in cosmetics products. Unfortunately, because of the lack of transparency exercised by RIFM, IFRA and the EU Commission over this matter. it means that unless you, dear reader, belong to a professional association, probably won't get to see IFRA's information letter IL799 on the topic, or the Risk Assessment that the EU Commission was given in late 2007 by IFRA. IFRA have apparently suggested a cosy future chat with the EU Commissioners, some unnamed industry moguls and fragrance consumers (presumably IFRA or RIFM members) to 'explain matters' - presumably code for agreeing their highly restrictive citrus oil proposals (see below) with the EU regulator. Nobody with an independent or contrary opinion is to be invited.
In a nutshell, the alleged photo-carcinogenic & photo-mutagenic effects of furanocoumarins (mainly from citrus ingredients) contained within cosmetic preparations are causing concerns to the cosmetic regulators. The previous proposal with the SCC(NF)P 00329/00 Opinion to limit all furocoumarins & furocoumarin-like substances to 1 ppm has been dismissed on all sides as unworkable, since not all fur(an)ocoumarins are phototoxic, and nobody has a clue about the furanocoumarin content of citrus ingredients they use. Nobody knows either, what "furocoumarin-like substances" are. Similar critical remarks apply to the next stab that the SCCP made at the subject (SCCP 0942/05).
Now IFRA propose to limit any combination of 6 furanocoumarins markers in finished cosmetics, to 5 ppm for leave-on products, and 50 ppm in rinse off products. The 6 furanocoumarin markers are surrogates for the total furanocoumarin content of the cosmetic preparation, and are identified as follows: bergapten, bergamottin, byakangelicol, epoxybergamottin, isopimpinellin & oxypeucedanin.. In other words, the use of citrus oils in alcoholic perfumery is finished. IFRA are proposing to agree an analytical method for furanocoumarin estimation in cosmetic ingredients by Spring 2008. IFRA are also proposing the use of UV-absorbers to counter the phototoxic effects of furanocoumarins, but these are already in use for many categories of cosmetic products.
IFRA-RIFM are busy demonstrating to us all that they know as much about terpene chemistry as they have previously shown they do about botany! In the real world, furanocoumarin concentrations vary in citrus products from zero to several thousand ppm depending on processing, botanical origin down to varietal level, geographical location, growing conditions & history etc. Further, furanocoumarins interconvert & degrade during processing and in the finished cosmetic product, making matters even more complex. IFRA-RIFM have also been essentially dishonest in ignoring the fact that much of the citrus product on the market is adulterated, and they have not discussed the implications of this for furanocoumarin occurrence in citrus ingredients & the toxicological consequences thereof. Luckily the subject is extensively covered in the scientific literature by real experts in the field.
Previous IFRA & RIFM statements (which are often conflicting) on citrus oil photo-toxicity and essential oil composition have been collected in the accompanying data-base document, together with independent findings from workers in the field. This will be progressively updated.
Cropwatch has further collected items on individual furanocoumarins, and on relevant photo-toxicological topics so that (a) we assess whether IFRA-RIFM have properly represented the total available knowledge on the subject, and (b) so we can all follow the arguments presented. This will be progressively updated as well.
Our main conclusion thus far, is that IFRA is not presenting a policy for citrus oils which is in the best interests of the fragrance industry. Rather, it is presenting over-precautionary safety proposal which is in the best interests of toxicologists. Much of the available scientific data available on furanocoumarins is slanted towards so-called 'evidence' from repetitive & relatively extreme medical treatments for serious skin diseases, such as PUVA. There is very little explanation of the relatively low incidence of adverse photo-toxicological effects from furanocoumarin-containing essential oils, the role & interplay of protective & anti-carcinogenic effects of the other components within essential oils, an area which is still little investigated & little understood. The essential oil & fragrance industry has thus been badly served by these developments & could have reasonably expected a vigorous defence of citrus ingredients, not their consignment to the dustbin.
Cropwatch will continue to campaign for a sensible & proportionate policy for citrus ingredients. Cropwatch supporters outnumber the total IFRA, RIFM & EFFA membership combined and from the contacts we had with perfumers, soap-makers, cosmetics manufacturers etc., we believe they will ignore these proposed IFRA restrictions as both unworkable & unnecessary. .
The Cropwatch Team. --
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