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  1. #31
    gecko214's Avatar
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    Default Re: Oakmoss restrictions as per 2013?

    I had been meaning to start the thread on this question at some point, that is the question of whether one "must" follow IFRA regulations if one does not want to be a member of IFRA. Actually, I imagine NOT following the --increasingly-detested-at-least-on-basenotes -- IFRA regs might be a good (niche) marketing strategy. I know it would appeal to me as a consumer, as long as everything were properly labeled. In terms of being sued, I fear this less in Europe than in the US, because in the US the sums are so astronomical and people seem more quick to sue. On the other hand IFRA has no (am I right?) jurisdiction in the US.

    Was there not an "outlaw perfume" project at some point that sought to explore non-IFRA compliance (I think it was natural perfumery, but not sure...)?

    Also, I wonder if one could market in Europe selling perfume for use "on clothing" and not for skin (as it was once used anyway, I think Dominique Durbano points this out -- I also imagine he pointedly, if quietly, ignores IFRA, and he seems to get on just fine). Would this not qualify as "category 11" in IFRA?

    Personally I would like to see the industry regulated for serious toxicity and ecological requirements (e.g. "will it give you cancer?" ; "Birth defects?"; "will it turn frogs hermaphroditic?"; "will it cause 3-eyed fish?") SEPARATE from possible skin rash issues, which, --I am sorry skin rash sufferers --I just don't see as that critical to the planet or human survival. Possible rash-causing ingredients should just be labelled, like peanuts are in a breakfast cereal. If the wrong person eats peanuts it can kill them. I don't think the same is true for wearing Mitsuko.

  2. #32

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by janmeut View Post
    In case you work for a small group of customers I think you could bend the IFRA rules. In case you want to sell this in the EU you have of course to find a cosmetic chemist who allowes you to do this; every single cosmetic in the EU, even if you make only one bottle of a bespoke perfume has to be assessed by a professional with the right diplomas. If she thinks 0.2% (or 20%) is safe, and has the scientific data to prove that, then there is no problem with the law.
    +


    Quote Originally Posted by janmeut View Post
    I don't know the situation in all EU countries, but in the Netherlands a large amounts of any cosmetic produced does not even conform to the EU cosmetics legislation, and that IS law. Therefor I can assure you that there is a lot of perfume around that is NOT IFRA compliant, probably even illegal. No care at all and a lot of simple ignorance. No theory, but practice (based on an investigation of the Dutch government organisation that has to keep our products safe; in 2007 they checked all cosmetics companys in the northern part of the Netherlands, almost half of them did not meet even simple, easy to fulfill demands of the law)

    On the other hand: almost every real large company in the western world is IFRA compliant for the simple reason that they or their suppliers are IFRA members. There is of course a good reason for that, the IFRA and RIFM have the most knowledge about the dangerous aspects of fragrance. Their advices are sound. In general it is the best to be IFRA compliant. The only exceptions I think can be products made in small amounts. The risk of problems is in these cases limited because the limited number of users.
    The reality is that one won't easily find a toxicological chemist willing to break the law together with you, therefor many 'companies' just skip that step all together. The risk here in NL is quite small, the non-complying companies got away with just a written warning. It's because there is no money to be invested in checking up on all those venues, especially now with the internet: everyone can set shop and sell whatever wares at the (online) flee market.

    I guess it takes a certain kind of personality and 'doesn't give a shit attitude' to do that.
    Before I knew what kind of stuff exactly gave me blisters I came very close on suing these kind of irresponsible crappy merchants, just to prove a point.
    Now I just find out it's easiest for me to just stick with well-known, well-tested big brands or make my own.
    @SomethingSmelly

  3. #33

    Default Re: Oakmoss restrictions as per 2013?

    If there is guidance/obstructiveness present as an industry expected standard, then if one wishes to make a living from perfumery, there is no choice but to conform for the main bulk of ones products.

    If one then provided a special service where additional oak moss is put in if requested privately by the client, then surely that would be a private matter. It would be interesting to know if it would still be violating the restrictions.

    The problem isn't so much making a non compliant perfume as selling it and insuring it. There are plenty of other smells to be had without the bother. I shall design my oakmoss loaded perfume products one day for gloves and garment wear only...
    Currently wearing: Gilda by Pierre Wulff

  4. #34

    Default Re: Oakmoss restrictions as per 2013?

    The original idea behind the 26 Allergens was exactly that gecko. To point out to people who were allergic to one of those materials to stay away from the product. It is estimated that between 1 and 3 percent of the population has an allergy that shows as dermatitis. What percentage of the population is allergic to any one of these materials, I don't know. By the way the 26 were chosen by dermatologists as being the most common causes of contact dermatitis, no doubt people are allergic to other things. The 26 are there to warm people who already know about their allergies. The 26 will not necessarily cause an allergy if you do not already show on, although they might. When the EU first brought in this regulation many companies (many of our customers) demanded totally allergen free fragrances. When the repercussions of this was pointed out they changed their minds. There seems to be so many knee jerk reactions to this subject, and has been pointed out Mitsouko never killed anyone, a Snickers bar could.

    Sine Wave; Oakmoss and Treemoss are both extracts (solvent extracts) from a specific Lichen. Oakmoss grows on Oak trees, whilst Treemoss grows on Pine trees. They smell different, but both have a leathery animalic and green odour. They both contain two chemicals; Chloroatrinol and Atranol-2 which have been shown to cause contact dermatitis at very low levels to those people allergic to Moss. This is what all the fuss is about. At least one supplier of Mosses has been trying to reduce the levels of these materials whilst maintaining the quality, with some success. However the new IFRA regulations will reduce the permitted level of Atrinols even further, and it is not known if it will be possible to remove the offending chemicals whilst keeping the smell the same, and without the price going through the roof.

    The problem with finding a toxicological chemist is mainly one of cost; it ain't cheep to have your fragrance tested. Also it would have to be tested on animals; big no-no.

  5. #35

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by David Ruskin View Post
    The original idea behind the 26 Allergens was exactly that gecko. To point out to people who were allergic to one of those materials to stay away from the product. It is estimated that between 1 and 3 percent of the population has an allergy that shows as dermatitis. What percentage of the population is allergic to any one of these materials, I don't know. By the way the 26 were chosen by dermatologists as being the most common causes of contact dermatitis, no doubt people are allergic to other things. The 26 are there to warm people who already know about their allergies. The 26 will not necessarily cause an allergy if you do not already show on, although they might. When the EU first brought in this regulation many companies (many of our customers) demanded totally allergen free fragrances. When the repercussions of this was pointed out they changed their minds. There seems to be so many knee jerk reactions to this subject, and has been pointed out Mitsouko never killed anyone, a Snickers bar could.
    Indeed, so one needs to list those allergens. Meaning as a perfumer you must know about what materials contain those allergens and what the % of the allergens is present in the finished product.
    As the science on the matter is progressing, the disclosure list will get longer with time. I'm all for disclosure, especially an informed choice. But I agree that the consumer needs to be given the choice. I'd rather have IFRA and the EU authorities spend the money involved in 'banning decisions' on sustainability, better GMP and finding alternatives for animal testing.

    Quote Originally Posted by David Ruskin View Post
    The problem with finding a toxicological chemist is mainly one of cost; it ain't cheep to have your fragrance tested. Also it would have to be tested on animals; big no-no.
    That is not what I meant David. The problem is finding a toxicological chemist that will put her/his signature under an assessment knowing fully upfront that the end product is not safe by law (how stupid that law might be). That's why many rogue companies skip this step.

    Also a safety assessment by a toxicologist does not imply animal testing, animal testing is banned in the EU. The assessor however must base his/her decision upon scientific data. Some of that data includes research of toxicity of aromatic ingredients done on animals. Unfortunately there are not many people that would volunteer to be injected with the newest aromatic, before it hits the market. And the alternatives to animal testing are still too few.

    That's why claims like 'cruelty free' will also need to be backed up by science, according to the upcoming 2013 legislation. Not a bad thing imho as too many companies have no clue and use that to improve sales (just like all the other stupid 'free of' claims).
    @SomethingSmelly

  6. #36

    Default Re: Oakmoss restrictions as per 2013?

    There is one aspect of this debate that has not been discussed: Trading Standards. I know wholesalers and retailers who have had their perfumes and oils stock seized for non-compliance with labelling requirements. I've also known them to randomly test products. lf they decide to adopt the 2013 IFRA guidelines, this could have serious implications, as they WILL take court action.

  7. #37

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by Abu Ayoob View Post
    There is one aspect of this debate that has not been discussed: Trading Standards. I know wholesalers and retailers who have had their perfumes and oils stock seized for non-compliance with labelling requirements. I've also known them to randomly test products. lf they decide to adopt the 2013 IFRA guidelines, this could have serious implications, as they WILL take court action.
    They will have to. In the new 2013 write up, the 'responsible person' is the key:

    http://eur-lex.europa.eu/LexUriServ/...09R1223:EN:NOT

    Especially quoting
    (11) In order to establish clear responsibilities, each cosmetic product should be linked to a responsible person established within the Community.

    (12) Ensuring traceability of a cosmetic product throughout the whole supply chain helps to make market surveillance simpler and more efficient. An efficient traceability system facilitates market surveillance authorities’ task of tracing economic operators.

    (13) It is necessary to determine under which conditions a distributor is to be considered as the responsible person.

    (14) All legal or natural persons in the wholesale trade as well as retailers selling directly to the consumer are covered by reference to the distributor. The obligations of the distributor should therefore be adapted to the respective role and part of the activity of each of these operators.
    This is all just the beginning in the new era of transparency (that will probably/hopefully override the knee-jerking banning). And that includes fragrance!

    I look forward to this all!
    @SomethingSmelly

  8. #38

    Default Re: Oakmoss restrictions as per 2013?

    Question: This doc is from 2009. Does this mean that these regulations have been around since then, but not yet adopted/enforced, or is there another doc since updated?
    These regs will have some interesting effects - suppliers (that I use) from the US presently refuse to even supply MSDS for their fragrance compounds because they are not necessary over there. To comply, I would need to have all of their products tested here in the UK - the cost would be prohibitive. Also there are many suppliers from Asia and the Middle East who have the same lax approach. They will either have to amend their policies, or risk losing a large number of customers. Maybe this is will turn out to be a much-needed boost to the UK perfumery manufacturers/suppliers.

    - - - Updated - - -

    Sorry, I've just answered my own question:

    Dates: of document: 30/11/2009
    of effect: 11/01/2010; Entry into force Date pub. + 20 See Art 40.1
    of effect: 11/07/2013; Implementation See Art 40.2
    of effect: 01/12/2010; Partial implementation See Art 40.2
    of effect: 11/01/2013; Partial implementation See Art 40.2
    end of validity: 99/99/9999

  9. #39

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by Abu Ayoob View Post
    Question: This doc is from 2009. Does this mean that these regulations have been around since then, but not yet adopted/enforced, or is there another doc since updated?
    These regs will have some interesting effects - suppliers (that I use) from the US presently refuse to even supply MSDS for their fragrance compounds because they are not necessary over there. To comply, I would need to have all of their products tested here in the UK - the cost would be prohibitive. Also there are many suppliers from Asia and the Middle East who have the same lax approach. They will either have to amend their policies, or risk losing a large number of customers. Maybe this is will turn out to be a much-needed boost to the UK perfumery manufacturers/suppliers.

    - - - Updated - - -

    Sorry, I've just answered my own question:

    Dates: of document: 30/11/2009
    of effect: 11/01/2010; Entry into force Date pub. + 20 See Art 40.1
    of effect: 11/07/2013; Implementation See Art 40.2
    of effect: 01/12/2010; Partial implementation See Art 40.2
    of effect: 11/01/2013; Partial implementation See Art 40.2
    end of validity: 99/99/9999
    Indeed. On fragrance allergens the most recent publication is this:
    http://ec.europa.eu/health/scientifi...sccs_o_102.pdf

    It will indeed become harder and harder to not comply, from top to bottom. As a customer I would also be wary of non-EU fragrance products being exported to the EU.

    The only thing that has been delayed is the ban on animal testing on (some) ingredients, due to too little alternatives atm.
    @SomethingSmelly

  10. #40

    Default Re: Oakmoss restrictions as per 2013?

    I'm sure there would be a little more compliance if it was easier to comply... the whole thing is so very complex ... that even the most willing and compliant perfumer is in for a tough job to know how to comply accurately, without a struggle.

    There is always a way around any rule, so it would be better to allow reasonable freedom but to lawfullly demand it was labelled properly, such as peanuts are to foodstuffs. Those who wish to flout anything are not going to obey any rulings anyway.
    Currently wearing: Gilda by Pierre Wulff

  11. #41

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by mumsy View Post
    I'm sure there would be a little more compliance if it was easier to comply... the whole thing is so very complex ... that even the most willing and compliant perfumer is in for a tough job to know how to comply accurately, without a struggle.
    I think it's because traditionally most perfumers work inside a company with a separate legislation unit that takes care of that, like David explained above.

    The independent self-taught perfumer without formal training that ventures to sell perfumes is quite a new phenomenon and in this case I would warmly recommend to work together with a consultant (cosmetic) chemist that has experience with legislation. And/or a formulation software that includes the restrictions and can be updated to keep up with changes. David addressed this above as well.

    In Dutch we have a saying that I loosely translate: 'if one says A, then one should be prepared to say B as well'. It's the Dutch equivalent of 'In for a penny, in for a pound.' I just realized that this also applies for the peeps that don't give a damn LOL
    @SomethingSmelly

  12. #42

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by Abu Ayoob View Post
    I hope that's not the case in the UK? Would that mean that even a bespoke perfume created for a single client would have to be tested? PANIC!
    Yes, the UK are part of the EU so every perfume, including bespoke perfumes has to be assessed, no exceptions.

    - - - Updated - - -

    Quote Originally Posted by mumsy View Post
    If one then provided a special service where additional oak moss is put in if requested privately by the client, then surely that would be a private matter. It would be interesting to know if it would still be violating the restrictions.
    In theory changing a fragrance would be making a new one. As long as you do that at home for private use I think it would not be considered bringing on the market and therefore it would be a case outside the law. In case you would do this as a profession, or for someone else, for instance your neighbour, it would probably bringing it on the market and therefor illegal, because it is a new cosmetic and you would have it to be assessed.

    - - - Updated - - -

    Quote Originally Posted by David Ruskin View Post
    The problem with finding a toxicological chemist is mainly one of cost; it ain't cheep to have your fragrance tested. Also it would have to be tested on animals; big no-no.
    The service of a cosmetic chemist is usualy not free. Depending on the formulation and the country in which the assement is made it could be as cheap as 50 euro I suppose (Some Eastern European countries still are that cheap), or very, very expensive.

    With exception of a very few cases that are ending in 2013 animal tests for cosmetics are illegal in the EU. So in case animal testing would be needed (but that is usualy not the case) it would be a no-no for every cosmetic even if you had milions on hand. Then: they usualy are not needed.

    - - - Updated - - -

    Quote Originally Posted by Irina View Post
    Indeed. On fragrance allergens the most recent publication is this:
    http://ec.europa.eu/health/scientifi...sccs_o_102.pdf
    Please note that the SCCS publications are not law, they simply advise and sometimes the politicians decide to ignore the advise.

    - - - Updated - - -

    Quote Originally Posted by Irina View Post
    I would warmly recommend to work together with a consultant (cosmetic) chemist that has experience with legislation.
    You can contact us at De Hekserij, we help our Dutch and Flemish customers with these issues, with or without the help of Belgian and Dutch cosmetic chemists. They all have a lot of experience with the legislation.
    Last edited by janmeut; 28th September 2012 at 01:45 PM.

  13. #43

    Default Re: Oakmoss restrictions as per 2013?

    I just want to get something clear for future reference... So every single fragrance of every single range has to be individually assessed and signed for before it can be sold at all? What about simple single blends? What about small niche perfumers only selling a few bottles?

    I have a feeling it costs a fortune to do that here... I think about £300 per frag??? (I could be wrong).
    Currently wearing: Gilda by Pierre Wulff

  14. #44

    Default Re: Oakmoss restrictions as per 2013?

    Yes, (in the EU) every formulation has to be assessed. So if you mix 96% alcohol with 5% patchouli oil and sell it such that it is legaly a perfume you have it to be assessed. In case you change to 4 or 6% patchouli you need a new assessment

    I think 300 GBP might be a fair price for an assessment, assuming the formulation is not very difficult, only common ingredients are used and you have all needed or wanted documentation (SDS, PDS, CoA/CoC, IFRA statement, allergens specs) for every ingredient available. Of course there is space for creativity and reuse of assessments, for instance you could have an assessment for a fragrance that may or may not have up to 1% of a list of say 40 ingredients. In that case a lot of different formulations would fit under one assessment. In my patchouli example you could have one assesment made that you allows to use any percentage patchouli oil up to 15%, in that case the 4, 5 and 6% perfume would all fit under the same assessment.

    Besides an assessment you need a product information file that contains information about the ingredients (for instance purity, needed), you need to keep track of any complaint about your product, have the correct ingredient declaration on the bottle. It has to be produced according to the GMP cosmetics rules (or an alike level of production quality). There are no exceptions for bespoke or niche perfumes, even in case you only sell one perfume only once you legaly have to fulfill all demands of the law.

    In 2013 you also have to notify every cosmetic (that includes perfumes) to the CPNP (http://ec.europa.eu/consumers/sector...p/index_en.htm)

  15. #45
    Basenotes Member ION's Avatar
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    Default Re: Oakmoss restrictions as per 2013?

    Janmeut, out of experience how often this procedure is violated by people who sell custom made perfumes? I mean I can't believe all the perfume sold in the market or through the internet has gone under all this.
    Also, what's your opinion (or anyone else's opinion) about this article here: http://www.ewg.org/notsosexy
    which basically says that even big firms which are completely compliant with all the bureaucracy required in EU, America, Middle east e.t.c still sell fragrances that are not safe for human health and contain chemicals that are not assessed for safety .
    I really wonder whether an individual who uses the raw materials the fragrance companies use, who makes sure his perfume is ifra compliant (in order to be covered and avoid hassle) and then sells his product through the net in Europe and America how much risk he's realistically taking.
    Last edited by ION; 28th September 2012 at 10:50 PM.
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  16. #46

    Default Re: Oakmoss restrictions as per 2013?

    Janmeut makes excellent points. £300-£500 per assessment per perfume formulation is very common and a fair price. Most specialists are highly educated and have a level of experience and knowledge that justify a salary of £100 per hour.

    The costs are lower if you only use well known EO's. Just like if you use FO's that are made in the EU thus being covered as far as the specs go.

    The costs will rise if you use handmade tinctures or extracts, less known/documented EO's, absolutes, plant extracts and/or aromachemicals. The chemist must look up a lot of information unless he/she is specialized in fragrance. The extra time the chemist needs to invest to calculate MOA's (“mode” or “mechanism” of action of individual chemicals to predict dose response characteristics of mixtures in order to assess toxicity) is bigger thus more expensive.

    Based on knowing this my guesstimate is that about 95% of the international indie niche and flee market fragrances are rogue and don't follow the EU legislation. This is very bad business for all the industry, because the more rogue cosmetic products are out there, the bigger the chances are for problems to arise that will reflect badly on all industry. I see it with 'all-natural', 'handmade' and/or 'organic' cosmetics all the time: badly designed and poorly preserved DIY products that are most likely to give a rash due to bacteria, fungi, oxidation etc.
    The whole EU regulation came to life in order to minimize this kind of problems.

    As for http://www.ewg.org/notsosexy

    never ever believe anything written by ewg. It's your purest non-scientific fear-mongering mass hysteria bs, nails on chalkboard horror for anyone working in the established cosmetic industry.

    Bottom line: if you really want a fragrance with 50% oakmoss, do it yourself! Then you can save yourself the money otherwise squandered on rogue stuff and if you do get a rash, there is none else to blame but yourself.
    Last edited by Irina; 1st October 2012 at 08:59 AM.
    @SomethingSmelly

  17. #47

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by ION View Post
    It would be helpful to have it as a fast reference.
    26 allergens to be labelled when above a certain amount:
    This is the full list:
    Amyl cinnamal (CAS No 122-40-7)

    Benzyl alcohol (CAS No 100-51-6)

    Cinnamyl alcohol (CAS No 104-54-1)

    Citral (CAS No 5392-40-5)

    Eugenol (CAS No 97-53-0)

    Hydroxy-citronellal (CAS No 107-75-5)

    Isoeugenol (CAS No 97-54-1)

    Amyl cinnamyl alcohol (CAS No 101-85-9)

    Benzyl salicylate (CAS No 118-58-1)

    Cinnamal (CAS No 104-55-2)

    Coumarin (CAS No 91-64-5)

    Geraniol (CAS No 106-24-1)

    Hydroxy-methylpentylcyclohexenecarboxaldehyde (CAS No 31906-04-4)

    Anisyl alcohol (CAS No 105-13-5)

    Benzyl cinnamate (CAS No 103-41-3)

    Farnesol (CAS No 4602-84-0)

    2-(4-tert-Butylbenzyl) propionaldehyde (CAS No 80-54-6)

    Linalool (CAS No 78-70-6)

    Benzyl benzoate (CAS No 120-51-4)

    Citronellol (CAS No 106-22-9)

    Hexylcinnam-aldehyde (CAS No 101-86-0)

    d-Limonene (CAS No 5989-27-5)

    Methyl heptin carbonate (CAS No 111-12-6)

    3-Methyl-4-(2,6,6-tri-methyl-2-cyclohexen-1-yl)-3-buten-2-one (CAS No 127-51-5)

    Oak moss extract (CAS No 90028-68-5)

    Tree moss extract (CAS No 90028-67-4)

    I think it might be helpful to add this to the IFRA compliance sticky thread even though the list has nothing to do with IFRA, so I'll do that in a minute. I have put all this plus a lot of additional information into a post on my blog called The 26 Ingredients for those occasions when Basenotes is hors de combat.
    Last edited by Chris Bartlett; 1st October 2012 at 06:09 PM. Reason: Added link to blog
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  18. #48

    Default Re: Oakmoss restrictions as per 2013?

    I checked for new data: in 2010 62% of all checked Dutch cosmetics companies did not meet all demands of the law, thereby breaking it. I have no data for other countries, but it is well known that for instance France is very strict in these matters. Of course it is only applicable to perfumes sold in the EU.

    Regarding the EWG article:
    - according to IFRA over 4000 fragrance materials are used, not 3100
    - yes, in fragrance industry it is uncommon to be clear about the formulation of the fragrance, to make it harder to copy. This is not illegal in the EU, you may refer to any mix of fragrances in cosmetics as 'Parfum'.
    - a lot of synthetics are actualy made from natural terpenes, other are petrochemical, for their safety and environmental impact that is hardly interesting, only a bit from a point of renewability, but then the use of petrochemicals for fragrance use is very low
    - so to find only 38 ingredients that are not listed makes me think that it was a very basic analysis, I would expect at least 10 times more ingredients that are not listed
    - Diethylphtalate is according to the newer, harder, sticter EU rules (REACH) still not a even hazardous material, where almost all essential oils are
    - Musk ketone is one of the few fragrance materials that is realy restricted in use in the EU, so yes, there I can share at least some concern
    - Because in the EU it is not needed to declare all fragrance materials used on the label there is probably nothing 'clandestine' here
    - because most consumers are completely ignorant about the pro's and con's of any substance, due to the lack of good quality education in chemistry and biology, the lack of good books about cosmetic ingredients, the abundance of nonsense told about cosmetic ingredients in many popular books about cosmetics and lots of internet sources I don't think it makes a lot of sense to add all ingredients used to the label: only a very few people are well informed and could do anything sensible with this information
    - yes, some companies did (and maybe still do) abuse the fragrance (or other components) to hide ingredients, for instance they add preservatives to the fragrance as a fragrance material and then claim the product to be preservative free on the label. In the EU they made some new rules to make this despicable practices harder to perform, but in this article I see no evidence that this is the case here: diethylphtalate is a common part of fragrance components, for instance as solvent for natural resins, musk ketone is an important aromachemical.
    - some fragrance materials may indeed cause health problems, for instance Rosemary EO may damage the unborn child and Cinnamon leaf oil may cause cancer. I think however that more people die every year because of choking in the cap of a fragrance bottle than of any ingredient used

    The EWG article however points out a real danger for society: the complete and utter ignorance of almost the complete population regarding toxicological matters: not to be able to make even a reasonable estimation about the real dangers of any substance. Most people here on this forum know me as the man from De Hekserij, a supplier of fragrance materials, but the main target of De Hekserij is to help people to understand the science behind al the common products we use. The EWG article made clear again that there is a long road ahead.

  19. #49

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by mumsy View Post
    If there is guidance/obstructiveness present as an industry expected standard, then if one wishes to make a living from perfumery, there is no choice but to conform for the main bulk of ones products.

    If one then provided a special service where additional oak moss is put in if requested privately by the client, then surely that would be a private matter. It would be interesting to know if it would still be violating the restrictions.
    My understanding of the situation is that, strictly speaking, any cosmetic product sold, whether to private commission or otherwise has to comply with all the EU laws, labelling requirements etc. even if only one is sold. It does not follow from this that everything has to comply with the IFRA regulations though that undoubtedly makes safety assessment easier. You also have to be realistic about the likelihood of enforcement or prosecution for non-compliance in a case where only one of a product is sold to an individual consumer who requests that it should be the way you have made it . . .

    Quote Originally Posted by mumsy View Post
    The problem isn't so much making a non compliant perfume as selling it and insuring it. There are plenty of other smells to be had without the bother. I shall design my oakmoss loaded perfume products one day for gloves and garment wear only...
    The first part of this is absolutely right - legally selling and practically insuring for product liability are the issues.

    However if you look at the guidance about 'borderline products' it seems to me that the get-out-of-jail-free card of stating that your fragrance is only for use on clothing or selling pre-perfumed gloves will not help. Since both clothing and gloves come into contact with the skin, the law will regard these as 'vehicles through which a cosmetic product is delivered'. Given this, I don't see any real value in this attempt to circumvent the rules: you have to either ignore them and hope for the best, or comply (or some combination of those things).
    ďA person who is nice to you, but rude to the waiter, is not a nice person
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    Chris Bartlett
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    www.perfumedesigner.co.uk
    Twitter: @PellWallPerfume

    If you are looking for a perfumery consultation Iím happy to quote: if you want free advice, thatís what these forums are for
    You can also join my blog if you wish to ask questions of me.

  20. #50

    Default Re: Oakmoss restrictions as per 2013?

    This is exactly why I remain a hobby perfumer and probably always will. I cannot afford to pay £300-£500 every single time I make up a perfume. It did cross my mind to re-train as a pharmacy chemist at the same time as perfumery training.

    I can only assume that any previously unknown perfumer who sells a whole line of perfumes on the internet must have a pet chemist, be married to one, has won the lottery or has a company investment. How does one remain legitimate and commercially viable otherwise?

    The 'borderline product' idea wasn't so much intended as a negative get out of jail free card or a negative avoidance issue although obviously it is an attempt to 'circumnavigate the rules'. It was more thinking along the lines of a preservation of an artistic freedom of expression and the ability to deliver a true historical product without the skin allergy constrains.
    Last edited by mumsy; 2nd October 2012 at 09:22 AM.
    Currently wearing: Gilda by Pierre Wulff

  21. #51

    Default Re: Oakmoss restrictions as per 2013?

    I'm not sure that every single perfume has to be approved, simply that the materials used in them have to be.

  22. #52

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by mumsy View Post
    I can only assume that any previously unknown perfumer who sells a whole line of perfumes on the internet must have a pet chemist, be married to one, has won the lottery or has a company investment. How does one remain legitimate and commercially viable otherwise?
    As far as I know the highest % of non-compliance is among indie self-taught perfumers. A formally trained perfumer will most likely have a bigger network of people that can assist, help and/or invest.

    If my last calculations are right the minimum budget for releasing a line of 5 complex fine fragrances, alcohol based, that include natural & synthetic aromatics + manufacturing costs + packaging + minimum marketing (website) + insurance = 20000 euro. That's why there is no way that any not-mass oriented compliant fragrance could be profitable if sold for less than 100 euro per bottle.
    @SomethingSmelly

  23. #53

    Default Re: Oakmoss restrictions as per 2013?

    It's almost as if IFRA wants to discourage the small independent perfumer; can't imagine why!!

  24. #54

    Default Re: Oakmoss restrictions as per 2013?

    Could it be because so few of us can afford membership?
    ďA person who is nice to you, but rude to the waiter, is not a nice person
    ― Dave Barry

    Chris Bartlett
    Perfumes from the edge . . .

    www.perfumedesigner.co.uk
    Twitter: @PellWallPerfume

    If you are looking for a perfumery consultation Iím happy to quote: if you want free advice, thatís what these forums are for
    You can also join my blog if you wish to ask questions of me.

  25. #55

    Default Re: Oakmoss restrictions as per 2013?

    Could it be that the major sponsors of IFRA are the major movers in the Perfumery business?

  26. #56

    Default Re: Oakmoss restrictions as per 2013?

    David, may I remind you: the EU and IFRA restrictions on oakmoss are different. The EU is much stricter. Imho the only explanation for the EU restrictions are the toxicology reports from RIFM + the upcoming REACH framework. Historically these initiatives were funded by the big players as a counter reaction to the growing fear of 'chemicals in cosmetics' that spread a lot faster with the growing popularity of the internet. It is a very complicated issue and shouldn't be oversimplified.

    I agree that small entrepreneurs should rather be encouraged to comply than being scared away by the fees. The industry for example can put together a fund for innovation or offer some kind of discount on the safety assessments for innovative perfumers. In the Netherlands there are such funds and possibilities, especially when it comes to innovation and technology. But one needs to be able to show entrepreneurial spirit, creativity and business sense.

    However by just breaking or 'bending' the rules, a non-compliant perfumer will not only shoot themselves in the foot but create distrust towards such initiatives as a whole, thus ruining it for the honest guys. Most professional perfumers are aware of this, because it is a hot topic often discussed in any formal training I came across, including the one I am lucky to enjoy myself. If one is self-taught such ethics are lost in translation. And that is a bad thing that should never be encouraged imho.
    @SomethingSmelly

  27. #57

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by David Ruskin View Post
    I'm not sure that every single perfume has to be approved, simply that the materials used in them have to be.
    Every formulation has to be approved. This has nothing to do with IFRA, it is EU law, IFRA does not ask for such strict rules.

    The story behind it is long but has mainly to do with a few serious accidents in France the most important being described here: http://en.wikipedia.org/wiki/Hexachlorophene

    It is about 40 years ago this happened, but you understand that the French people afterwards made quite rigid laws. When the EU cosmetics directive was made the European law makers took the most strict legislations and started from there. This was and still is backed up by consumer organisations and environment interest groups, especialy the most populist ones. My very personal opinion: Some of these organisations are not interested anymore in their goals, but in the power they have. The only way to keep this power is by being supported by lots of people and spreading fear always was the best way of doing that.

    As I pointed out only very few people have the knowledge to make realistic decisions regarding any substance, so most people decide for other reasons who they do believe and therefor we have this absurd fear of ingredients in cosmetics.

    The cosmetic industry hardly ever fights these absurd accusations, because they don't want their products in a negative story. Don't forget that cosmetics are emotional products, therefor mainly marketing driven. Therefor they are ideal victims for these interest groups, most cosmetic companies will simply do what these groups will. That can be seen as succes for these interest groups, therefor: victory, more power!

    Large companies that are member of the IFRA need smaller companies: these smaller companies find out what people want, the new market trends. Smaller companies can make unusual blends without a lot of cost. Smaller companies in fragrance may take 0.1% of the market or less, so no problem there, and in case they grow, well: purchasing a blooming business is probably one of the best investments a large company can make.

    the EU and IFRA restrictions on oakmoss are different. The EU is much stricter.
    The EU restriction for oakmoss absolute is that you can use any amount, as long as you mention its occurence on the package (when over a certain concentration), the IFRA restriction is that you cannot use more than 0.1% in most cases. Please explain to me why the EU rules on oakmoss are stricter to your opinion when the EU rules allow the use of 1000 times more oakmoss than IFRA.

  28. #58

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by janmeut View Post
    The EU restriction for oakmoss absolute is that you can use any amount, as long as you mention its occurence on the package (when over a certain concentration), the IFRA restriction is that you cannot use more than 0.1% in most cases. Please explain to me why the EU rules on oakmoss are stricter to your opinion when the EU rules allow the use of 1000 times more oakmoss than IFRA.
    You're right. The EU legislation on oakmoss is about labeling, the maximum authorized concentration in the finished cosmetic product is left blank. I think I mixed up sources here Will ask our toxicology expert as I remember reading on some recent studies about this, just don't know if the articles can be viewed open-source.

    Thank you for sharing that part of cosmetic history, I knew it had to do with a disaster in France, just forgot the details.

    Totally agree with you about small companies bringing in innovation, that's why in the Netherlands there are so many possibilities to get funds and investors for innovation.
    But I don't understand if you also think that even small companies should comply with the EU law on cosmetics?
    @SomethingSmelly

  29. #59

    Default Re: Oakmoss restrictions as per 2013?

    I think this is a fantastic discussion because even though there is often an element of devils advocate abounding. In the main, most wannabe perfumers, whether intending to be commercial or not, would surely like to be as compliant as humanely possible with any safety laws when using human skin as their palette, but without compromising the perfumers endeavour and creativity.
    The main issue seems to be the perfumers ingredient constraints are nudging into the latter when foodstuffs such as peanuts are not subject to such constraints.

    Back to the safety certification. For the sake of this discussion and understanding, it would seem plausible then, to create one blend, using a blend of named and previously deemed safe A - Z ingredients. This gets sent off and correctly passes the tests and obtains it's certificate of safety covering those 26 ingredients. This could then technically cover a frag using only ingredients A-G, H-J and K-Z and supposedly using any combination of those A-Z ingredients as long as there are no others added, because the frag is still the same frag but minus ingredients, rather than plus.

    Am I understanding that correctly?
    Currently wearing: Gilda by Pierre Wulff

  30. #60

    Default Re: Oakmoss restrictions as per 2013?

    Quote Originally Posted by mumsy View Post
    For the sake of this discussion and understanding, it would seem plausible then, to create one blend, using a blend of named and previously deemed safe A - Z ingredients. This gets sent off and correctly passes the tests and obtains it's certificate of safety covering those 26 ingredients. This could then technically cover a frag using only ingredients A-G, H-J and K-Z and supposedly using any combination of those A-Z ingredients as long as there are no others added, because the frag is still the same frag but minus ingredients, rather than plus.

    Am I understanding that correctly?
    I think that is mostly correct, not sure about the consequences of leaving ingredients out, this could reflect in the end % of the 26 allergens in the end fragrance. So I guess it depends on the ingredients? As far as I can understand the safety assessment for a fragrance is given for a set formula. Flexibility depends on the formula and different assessors have different ways to reflect that in their fees. It also depends on changes of legislation, a qualified assessor will stay in touch with you about those that may affect you.

    The bit of news from my colleague had to do with how safety assessments work. Here are some links she provided:
    http://www.safetycourse.eu/
    there you can see the issues that are relevant and are being discussed atm.

    A safety assessor will not only look at the law and % in the EU directive but also several other toxicological studies, some that do appear in the EU directive updates like from SCCP that basically summarizes the most recent scientific information and brings out an advice.
    For example here:
    http://ec.europa.eu/health/ph_risk/c...sccp_o_131.pdf

    Most assessors do go the extra mile and take this advice further to their customer (the perfumer), as they just want to do their job well. No professional I have ever met in this industry wants to be involved in unsafe cosmetic practices, law suits or consumer disgruntlements.

    She also reminded me that technically if you look at the minimum budget of any starting investment for introducing 1 finished fine fragrance to the market (take that minimum of 2500 euro), only 10-20% of that budget goes towards the safety assessment part, loads less than packaging & marketing (at least 30-50%).
    @SomethingSmelly

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