Oh good news. Sounds like they are being rational. Very strange behaviour on their part. Thanks for the info.
Thread: EU Regulations Update from SSS
from Laurie Erickson @ Sonoma Scent Studio:
"Reports are coming out that the EU has decided, at least for now, to continue to allow the low atranol version of oakmoss and tree moss while only banning moss that has not had the allergens atranol and chloroatranol reduced. Most perfumers (myself included) already switched to the low atranol version of oakmoss years ago when that standard was first set by IFRA, so there will be no change for us. IFRA not only requires the use of the low atranol type but also places a limit on the percentage of use of the low atranol type. Even at the IFRA level it is useful though, and I have the low atranol natural moss in many of my perfumes. I am glad to hear they are not banning it. Suppliers are actually getting better at removing atranol and chloroatranol to the point where it is difficult to detect any at all in the treated moss; I’m hoping as detection methods improve perhaps the low atranol moss will someday be deemed zero atranol moss and remain usable for the future.
The EU also decided not to implement the drastic restrictions on a number of ingredients, like citral and eugenol, that would have made it virtually impossible to use naturals anymore. They are going to conduct more research so this saga will continue, but at least the pace has slowed and better studies will be done.
Lyral (a synthetic lily of the valley ingredient sometimes referred to as HICC, short for hydroxyisohexyl 3-cyclohexene carboxaldehyde) will be banned. It was already heavily restricted and this move was expected, so I doubt anyone will be surprised. I do not use Lyral in any of my scents and never have used it, so this issue does not affect my formulations.
It sounds like the EU still wants to require labeling for over 80 allergens rather than the current 26, but they may allow the allergen listings to be made online rather than on the product boxes. There will still be a lot of work to comply with the EU rules, but this is overall very good news, at least for now. I think the great outpouring of concern over the proposed regulations helped persuade lawmakers to do further research before taking those drastic steps.
I’m not selling in the EU so these rules don’t technically apply to me at the moment, but I believe that the EU is setting precedents that may well migrate to the USA eventually. Also, the IFRA and EU ingredient regulations affect what is considered “currently accepted practices” for product liability insurance purposes, so the standards do have an effect on all perfumers whether directly or indirectly."
Oh good news. Sounds like they are being rational. Very strange behaviour on their part. Thanks for the info.
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That is good news indeed of sorts.
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Very good news indeed, although several fragrances have already been ruined beyond repair. Looks like the EU are seeing, a sort of, sense.
Somewhat good news... thanks for sharing!
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Good to know, thanks for posting this!
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Very good news. Thanks for the info.
Who slipped sanity drugs into the regulators food and water supplies and can we up the dosages?
Last edited by Paul P; 7th June 2014 at 07:29 AM.
The whole premise of IFRA is ridiculous. Just put allergy labels on fragrances and move on. Next they will ban alcohol denat in fragrances because some underage nimrod out there might drink it lol.
I fear Laurie Erickson may be a bit over-optimistic with regard to oakmoss and tree moss. The reports she refers to in her blog post are one article in Happi magazine, where it states: "The Commission is planning to ban, in its original form, oak moss and tree moss".
I am afraid the use of low (chloro-)atranol mosses is not discussed in Ms. Erickson's source.
The Commission's currently proposed amendment suggests a complete ban of (chloro-)atranol.
Un parfum doit avant tout sent bon. - Guy Robert -
On the EU's amendment to sharpen restrictions on fragrance allergens
What will the white coats do now for amusement?
We can still eat peanut butter potentially causing fatal reactions....
Perhaps they can ban aging and we will all live forever.
As Europe once again goes down the path to " Everything within The State and nothing outside The State." Circa 1930.......
And they say the US conservatives are Fascists?
Hi, this is Laurie. I did not notice this thread until today. IFRA already banned oakmoss and tree moss in its "original form" several years ago and required the use of the low atranol/chloroatranol version instead, so most brands already made that switch. The EU at least for now is not banning the use of the low atranol moss, and they are holding off on the proposed very tight restrictions on ingredients like eugenol, found in many naturals. They are going to conduct more research, so they could decide to ban or restrict more of these things later, but at least the initial proposal did not go through unchanged and more research will be done.
Suppliers are already able to remove atranol/chloroatranol to extremely low levels in moss, and I hope that as their methods of treatment and detection improve, they will be able to offer an "atranol-free" version of moss instead of a "low-atranol" moss. Then moss would continue to be available even if the EU did ban atranol. Many of the larger brands no longer use natural moss, but niche and artisan brands do still use it and I hope it will remain available to us.
I thought the decision was overall good news, and now we just have to see what the research brings. I agree that a lot of damage has already been done, which is very depressing. It would have been even more devastating though if the proposed new regulations had been enacted.
Pity, adults just can't choose for themselves - but rather have regulatory overlords taking care of them.
And this passes for democracy?
Again , didn't Europe try this once before in the 30s?
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I just wanted to add a couple more things.
First, I noticed statements on blogs that imply perfumers have to remove atranol/chloroatranol from their perfumes themselves and that it would be too expensive for small brands to do that. But the oakmoss we buy already has the atranol/chloroatranol removed. I have been buying my low-atranol moss from Biolandes for years. It meets the IFRA guidelines and it is important to many of my formulas. It is more expensive than untreated moss but not nearly as expensive as many other naturals we use and is indeed available even to small artisan brands. Similar low-atranol moss products are available from other wholesale suppliers besides Biolandes and even through online retailers like Eden Botanicals. Some small artisan perfumers still use the older untreated moss with high levels of atranols, but most of us switched to the treated moss years ago. If this low-atranol moss had been banned now in the EU, it could have lead to moss becoming unavailable altogether and that would affect all of us. I hope that by the time the EU wants to ban atranol/chloroatranol altogether, suppliers like Biolandes will have developed atranol-free moss (the current low-atranol moss has only very small traces of atranol). The other proposed restrictions were just as important to perfumery as the moss issue (eugenol, etc), so it was good news to put off the decision on those ingredients. Although low-atranol moss is financially in reach to small brands, there are many other regulations in the EU that make it very hard for small brands to sell there, so that point is valid but not for the moss reason.
Second, even though I believe the recent decision gives us some more time, I am not optimistic for perfumery in the long-term. We have been on this path toward more regulation and ingredient restrictions for many years and I don't see a happy ending. This recent decision was good news that bought us some more time. I hope something will happen to change the long-term outlook, but I am not optimistic. It is all very sad.
back on topic- As I've said before; one doesn't spray on perfume and cover it with a patch to maintain its strength for extended periods of time. Just saying.
Last edited by kumquat; 15th June 2014 at 04:11 PM.
Can you tell us the differences (in smell, longevity, general behavior in a perfume) between natural oakmoss and the low atranol/chloratranol versions? I'm curious to hear this from a perfumer's perspective.
And how does it relate to this:
"....the scent profile of oakmoss is very complex, and much like ambergris, it can present a wide range of distinctive notes: animalic, leathery, forest floor, lichenous like notes, a slight marine type salinity, but these notes and the way they present themselves has a lot to do with the concentration of oakmoss in a fragrance and its synergy with other elements. For example, while oakmoss does not have a heavy animalic note per se, in absolute form, it has quite a complex scent profile, part of which is a persistent leather-like undertone. Oakmoss can and frequently does deepen and complicate the animalic component of fragrances it is added to by the persistence of this leather-like undertone from the top notes through to the drydown, and, of course, how prominent such an undertone is depends on how much the use of oakmoss absolute is diluted within any particular fragrance and its synergy with other animalic or leathery type notes....many people are worried that its facile substitution in the place of oakmoss in fragrance formulas will simplify the complexity of fragrances and finally their aesthetic qualities....oakmoss has unique fixative qualities in that its presence tends to be extend throughout the entire drydown with its own odor profile adding to the to the whole feel and distinctive nature of the fragrance it occurs in, hence, the category of chypres. However, while oakmoss gives fragrances a distinctive enduring character, in many ways, though, oakmoss is the universal fixative par excellence in that while it asserts its distinctive character throughout the drydown of the fragrance it is present in, unlike other fixatives, to a large extent, it leaves the scent profile of the other constituents in the fragrance relatively unmodified allowing them to shine through and persist longer and more intensely even as it works synergistically with them. In many ways, its own scent profile remains a kind of background note. The only other fixative that has this characteristic is civet...."
Last edited by pluran; 16th June 2014 at 05:16 AM.
(Pssst...wanna buy some oakmoss...dime bags man...vials actually.)
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4. Le Labo Patchouli 24
5. Amouage Opus VII
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7. Masque Milano Russian Tea
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Sure, I can try to add my thoughts on that. First, both untreated moss and low-atranol moss are natural. The low-atranol version has not had anything synthetic added, so it is still natural. Both versions are absolutes that have a very thick, semi-solid form in various shades of green/brown. The scent varies a bit with the place of origin and the conditions during extraction. I usually pre-dilute mine in some perfumer's alcohol to make it easier to work with. Both treated and untreated versions are similar in appearance.
The treated moss does have something missing in the scent -- you can tell the difference and I do prefer the untreated. But the treated is still quite beautiful and is very close to untreated moss, especially compared to synthetics like Evernyl that are completely different than natural moss. The synthetic Evernyl (also called verimoss) is more sweet and powdery compared to natural moss, and natural moss is much earthier and more complex. I think the treated moss gets you so much closer to true chypre character than combinations of synthetics. I would hate to see the treated moss removed from our palette.
I would be happy to send samples of both treated and untreated moss to someone to start a sample pass if some of you would like to sniff them for yourself. I could put in some Evernyl too so you could see what I mean about the synthetics. Of course, perfumers would use an accord rather than plain Evernyl to approximate moss, but it would help you to sniff one of the commonly used ingredients in oakmoss-free oakmoss accords. I'll have to look and see if I have an open bottle of untreated moss to make a sample. I have a large unopened bottle of untreated moss stashed away from the days before low-atranol moss came out, but I'd rather not open that yet. I'll see what I have. I have lots of the low-atranol moss.
Or, for those who are curious to sample, Eden Botanicals carries the low-atranol moss and they sell samples. I think White Lotus Aromatics carries an untreated moss (though it is pre-diluted).
Both treated and untreated moss are very good long-lasting fixatives, and both versions add complex earthy, mossy, and woodsy notes.
I worry about this strategy of trying to remove all allergens from naturals though. At some point we will not have enough naturals left to make perfumery worthwhile.
Last edited by gardengirl; 16th June 2014 at 06:54 AM.
Thanks very much, Laurie. Interesting!
I have a follow-up question. Since the low atranol version of oakmoss maintains some of the true character of oakmoss, and is superior to synthetic substitutes, why then do we see such a devastation in the nature of true chypres? Is there more going on than just the oakmoss issue? It seems that perfumers could get much closer than they are by using existing ingredients.
That's a really good question. The problem is that not only did IFRA say we must use the low-atranol moss instead of untreated moss, but they also ruled that we could only use 0.1% of the low-atranol moss products total in a formula (the sum of oakmoss and tree moss). Old formulas like vintage Mitsouko used far more oakmoss than this. It is hard to do a lot with such a low limit. Even at that percentage it helps though, and many artisan perfumers use more than the IFRA allowance. The large brands that belong to IFRA must follow its rules though, so the classics have been hit hard.
Please note that all sample passes need to be referred to stuigi before being initiated and they are only allowed in the Male or Female Fragrance discussions.
How was the 0.1% value decided?
What happens at concentrations greater than that? Did the EU furnish any evidence that using a concentration of 0.11% was harmful?
Thanks, lpp! I didn't know the rules on sample passes. I won't bring it up again, but if anyone wants to organize one in the appropriate manner I am happy to provide the oakmoss materials.
noggs, I am not sure how they arrived at 0.1%. There was at least one study done after that decision that showed some people had allergic reactions, but many of the studies they have done were apparently flawed, so I doubt that they really know for sure what the limit should be. I think that's why they agreed to do more research with a different protocol. It is possible they will decide that there is no safe limit for atranol/chloroatranol and ban them altogether sometime in the next year or two. We'll have to see what their research finds.
I'm editing this post to add a link to a study that used 1% moss (not 0.1%) and found it caused allergic reactions, but that was in people who were already known to be allergic, and it sounds like they put a patch on rather than using a normal perfume type of application exposure. Maybe if they do more appropriate studies at 0.1% and in the general population they will be able to show that 0.1% is very minimal risk.
Last edited by gardengirl; 16th June 2014 at 09:23 PM.
I'm sure that if they sprayed a little bit of any classic perfume on anyone walking down the street (and did NOT paste a patch on the perfume to maintain strength and prevent normal evaporation) there would be zero negative effects on 99.99% of people.
Remember when they changed lighters so they were childproof and then nobody could operate them? Now they just have a warning label and they operate normally again. People with arthritis are relieved as is the adult world in general. Whew!