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EU amendment to sharpen restrictions on fragrance allergens

Re: People With Allergies Do Not Wear Perfume 9 years ago
Sherapop:
Here's a link to my manifesto on this topic: PEOPLE WITH ALLERGIES DO NOT WEAR PERFUME

Most likely they know better. The EU's argument is, however, not only the 1-3 % of overall population that actually react allergically need to be protected but also any others that might develop an allergic reaction.
Apparently consumers can not be trusted with self-determined actions. Evil or Very Mad
Re: People With Allergies Do Not Wear Perfume 9 years ago
MiaTrost:
Sherapop:
Here's a link to my manifesto on this topic: PEOPLE WITH ALLERGIES DO NOT WEAR PERFUME

Most likely they know better. The EU's argument is, however, not only the 1-3 % of overall population that actually react allergically need to be protected but also any others that might develop an allergic reaction.
Apparently consumers can not be trusted with self-determined actions. Evil or Very Mad

Only this morning I received a comment on that post which appears to have been written by an IFRA shill!

Shocked
Last edited by Sherapop on 07.02.2014, 05:18; edited 1 time in total
9 years ago
Wonderful job peeps … keep it up!!
I wish I had the time to get more involved again but at the moment my schedule is chaotic! I've signed the petition and will keep an eye on this topic so that I can offer my help if time pressures recede!

xoxoxoxo
9 years ago
Coutureguru:
I've signed the petition

Just to clarify … the petition I signed was the one located in the material elsewhere on this page. I will sign any petition related to this cause … please let us know when yours has been drafted Mia and Cryptic!!

xoxo
9 years ago
Mia, Cryptic, you two have done a wonderful job on this! I know That Stinks hasn't seen much activity lately but perhaps some of this material and the links could be posted there? Anything I can do?

Sorry to be MIA for such long periods but for the past couple of months my work life has been impinging on personal life and vice versa. Sometimes I come to Parfumo just to wander aimlessly and escape for a while...
9 years ago
Mia, thanks for the fantastic blog article! Hope you don't mind me adding my two cents here.

So much work has gone into the petition that I believe we should consider maximizing the impact of everyone's effort by adapting it to different purposes. Last week Subway, an American sandwich chain, removed a chemical from all of its products largely as the result of a petition which was initiated by a prominent food blogger. Here's an article that will fill you in on the details.

www.cnn.com/2014/02/06/health/subway-bread-che mical/

That got me thinking that maybe we should be targeting some of the larger perfume houses in addition to the European Parliament. It concerns me that we've heard very little in the way of complaint from the industry (other than a few brave niche/indie perfumers) regarding the proposed EU legislation, when one would expect them to be apoplectic over it. Perhaps a petition with numerous signatures might galvanize a Chanel or a Guerlain to get involved? As CG and Grey have pointed out, we each have careers and lives, and as much as I love this hobby it would be nice to see the industry whose livelihood I'm supporting get involved here. Idea
9 years ago
Last year when the crew at That Stinks sent email letters to houses large and small we received a variety of responses. For liability protection many said something to the effect: "we follow the law and are concerned about the health and safety of our customers" or, the most depressingly blunt, "we don't get involved in politics."

Chanel sent this response:
"Thank you for taking the time to contact Chanel.

Each perfume composition is a highly complex formulation that can contain between 30 and 50, and sometimes even up to 200, perfume ingredients. Chanel complies with international legislation, which requires listing the term fragrance (perfume) on the packaging label.

In addition, the presences of 26 substances with a high allergy risk are clearly stated on the packaging. The purpose is to allow consumers who know they are allergic to one or more of these substances to make an informed choice of product. These substances may be natural or synthetic in origin."

Frederic Malle replied with the most defiant, yet heartening, response: "We're also mobilized against this bill together with other major brands of perfumes according to the principle "unity is strength".

Unfortunately the overall rate of response was about 50% and not one response included any encouragement to act much less information of gov't entities to contact.
9 years ago
Yes, I was advised the same thing; that work was being done behind the scenes by at least one of the large European houses to oppose the pending legislation. And I appreciate the need for a certain degree of secrecy on the industry's part because it would be bad PR if word got out that Guerlain, for instance, was trying to undermine what is being billed as a health and safety regulation no matter how ill-founded and unscientific. Nonetheless, my confidence in their endeavors is somewhat limited based upon their unsuccessful track record. This is not the first wave of allergen restrictions nor will it be the last. IMHO, it's time to employ some different tactics unless we are willing to accept further reformulations and discontinuations. If the perfume community is unwilling to petition the likes of Chanel and Guerlain, perhaps Coty would be an acceptable alternative. I don't think there's any denying that a petition with an attendant threat to boycott can produce results.
9 years ago
A threat to boycott is a rather large item.

How many of the public consumers (the ones who have not signed a PARFUMO petition) are really following through?
9 years ago
In the case of the Subway example cited above, nobody is following through with a boycott because the objectionable ingredient was removed by Subway voluntarily after a prominent food blogger raised a ruckus about it. Sometimes that sort of successful result is achieved when the public raises a stink over an issue. In other instances no corporate action will be taken, but at least an attempt by consumers was made. Although I have nothing but praise for the work being done by the German members targeting the European Parliament, I'm not a fan of putting all the eggs in one basket and I don't see how a multi-faceted approach detracts from their endeavor.

What we have to contend with are restrictions on substances that may cause an allergic skin reaction in an extremely small percentage of the population. These "allergens" have been used in perfumery for many years. If they continue to be restricted and/or banned, perfumers will be forced to come up with alternatives that in addition to not smelling as nice, have been less well-tested than the ingredients they were meant to replace and thus could potentially be more harmful, as Vmarshmellow very astutely pointed out. I could go on at length about how flimsy the research is supporting the existing and proposed restrictions, but instead I'll refer you to an excellent analysis of the defects in the SCCP opinion RE: Coumarin.

www.cropwatch.org/nlet4art4.htm
9 years ago
I have no problem with restricting the use of irritants/allergens in skin and hair care products and make-up. In this instance, they have absolutely no benefit for skin, can be downright harmful in larger doses by causing inflammation (even if your skin seems to be tolerant) and they are primarily used to fragrance a product for marketing purposes or to mask the smell of other ingredients to make the product more aesthetically pleasing. There's a bounty of peer-reviewed scientific evidence to back this up. Paula Begouin (the "Cosmetics Cop") has a lot of well researched information about how harmful/pointless fragrance is in skin care products on her Beautypedia website and books.
I don't use fragranced skin care products for this reason (plus I prefer to smell my perfume, not my foundation!).
The problem with just declaring ingredients on the, usually tiny, label of skin cream or make-up, is that most people aren't dermatologists and wouldn't be able to evaluate a beneficial from a non-beneficial ingredient.
However, perfume is not skin care. You don't put it on your face (I hope) or on large areas of skin. We're not expecting it to do us good or protect our skin. We apply with caution and the expectation that it just might cause a reaction. Perfumes need these ingredients to function as perfumes!
The problem seems to be the umbrella term "cosmetics" which includes everything you might apply to your body, regardless of the product's function. I don't want essential ingredients restricted in perfume (unless they're proved to be truly bad for health - carcinogenic etc) but I'll happily do without fragrant irritants in my moisturiser.
9 years ago
Cryptic:
.. maybe we should be targeting some of the larger perfume houses in addition to the European Parliament. It concerns me that we've heard very little in the way of complaint from the industry (other than a few brave niche/indie perfumers) regarding the proposed EU legislation, when one would expect them to be apoplectic over it. Perhaps a petition with numerous signatures might galvanize a Chanel or a Guerlain to get involved?

The Subway example is a fabulous demonstration of consumer power. However, I wonder if it is suited as reference in our case. The dough conditioner Subway used in the US was legal but not favoured by consumers. To demand that a company ought to publicly oppose legislation that restricts certain ingredients with reference to consumer protection, is a different matter.

The likes of Chanel and Guerlain are already involved. IDEA Workshop Participants
About IDEA: "The recommendations made in" the SCCS's "Opinion was eye-opening for the industry which became even more aware of the communication gap existing between all parties and, as a consequence, the knowledge gap of all on fragrance allergens and, more specifically, on the methods to characterize them, assess them and diagnose them. (...) The intent of this initiative was strategic: a consumer adequately protected and safely enjoying fragrance products is the best way for the industry to secure its business and preserve its competitiveness. (...) IDEA consists of a series of two to three-day workshops bringing leading international scientists together to reach consensus on improving existing methodologies."
Wouldn't you agree that there may be more than one way to skin a cat?

Cryptic:
.. my confidence in their endeavors is somewhat limited based upon their unsuccessful track record. This is not the first wave of allergen restrictions nor will it be the last. IMHO, it's time to employ some different tactics unless we are willing to accept further reformulations and discontinuations. (...) I don't think there's any denying that a petition with an attendant threat to boycott can produce results.

IDEA is a rather new approach. There is yet no track record to refer to in order to assess success. I am, however, sure a threat to boycott can produce results. But I am pretty certain that any potential there may be for fragrance companies to side with consumers in this matter, would be smashed to pieces if we were to target them in such a way – that would do us no service, would it?
Last edited by MiaTrost on 13.02.2014, 08:33; edited 12 times in total
9 years ago
Great food for thought, Triffid! I am sure I can safely claim none of us has any intention to fight consumer protection where it is indeed necessary. We merely intend to oppose protection based on restrictions and prohibitions when it comes to fragrance allergens in perfumes, given, of course, they aren't lethal. We believe information is sufficiently suited for anyone with contact allergies to prevent any such reaction by avoidance behaviour.
9 years ago
Mia, my strong feeling is that the big companies and houses will not openly support this cause without some powerful motivation to do so. As Chanel stated in their response to That Stinks, they abide by all safety regulations. That's their public position, and to oppose allergen legislation would be in direct contradiction of it. It's not going to happen without some intervening factor such as the threat of losing many customers in the event that they continue to adhere to their current policy of blindly adopting unscientific, bogus ingredient restrictions.

That Stinks spent a great deal of time trying to offer support and assistance to various houses on behalf of the perfume community in fighting the allergen legislation. By and large, they wanted no part of it. As Grey posted, even the small niche houses that didn't outright refuse the offer of support offered no encouragement or guidance.

I understand that the course of action I've advocated may not appeal to everyone, or to anyone for that matter. It was simply an idea inspired by a pretty impressive consumer victory against Subway, the largest sandwich chain in the United States. Good things like that can happen, but not without a lot of people behind them, unfortunately.
8 years ago
Good news (relative to the concerns previously justified on basis of the recommendations made by the Commission's advisory body)!

The European Commission propose that:
- The three substances which were found to be unsafe should be banned from cosmetic products,
- Additional allergens should be subject to the obligation of individual labelling on the package of a cosmetic product. In other words, they have to be mentioned in the list of ingredients, in addition to the words 'parfum' or 'aroma'.

Excerpt from the Press Memo of the European Commission, February 13, 2014

Translation for ordinary mortals such as I:

To be banned:
- Chloroatranol and atranol, the main allergenic constituents of Evernia prunastri (oakmoss) and Evernia furfuracea (treemoss).
- HICC / Lyral, a waxy floral fruity accord with excellent diffusivity that gives good body. Lyral features notes such as lily of the valley, cyclamen and linden blossom.

To be indicated in the list of ingredients when their concentration exceeds the homoeopathic dosage of 0.001% in leave-on products:
- Cinnamal, the organic compound that gives cinnamon its odour
- Cinnamyl Alcohol, found in esterified form in cinnamon leaves, Peru balsam and storax
- Citral, present in the oils of several plants, incl. many citruses such as petitgrain, lime, lemon and orange
- Coumarin, found naturally in many plants, notably in high concentration in the tonka bean
- Eugenol, naturally occurring fragrance compound found in clove oil, nutmeg, cinnamon and bay leaf
- Farnesol, present in many essential oils, e.g. citronella, neroli, cyclamen, lemon grass, tuberose, rose and tolu
- Geraniol, the primary part of rose oil, palmarosa oil, geranium oil, lavender oil, jasmine oil and citronella oil
- HICC / Lyral when occurring naturally
- Hydroxycitronellal, occurs naturally, e.g. in lavender
- Isoeugenol, occurs in the essential oils of plants such as nutmeg and ylang-ylang
- Limonene, the rind of the lemon, like other citrus fruits, contains considerable amounts of this compound
- Linalool, over 200 species of plants produce it, mainly mints, scented herbs, laurels, cinnamon, rosewood and citrus fruits, but also birch trees

The EU Commission acknowledged that further scientific work is needed to define safe concentration limits of chemicals of special concern, i.e. for the twelve above and another eight natural extracts.

If the proposal is not opposed, the formal adoption of those changes is expected to take place by the end of this year/early 2015.
Last edited by MiaTrost on 24.02.2014, 07:29; edited 3 times in total
8 years ago
I try and stay out of the politics of the hobby. It pisses me off, so since I can't succeed in convincing anyone of anything, I find it pointless these days.

What I do want to TRULY KNOW is this : Are the ONES who are systematically banning ingredients the same ONES ( or at least affiliated ) who are currently supply the new, non allergenic ingredients or replacement ingredients?

If this is so, they are no better than the government or mafia for that matter. I'm inclined to believe they are one in the same, but I could be remiss.

What I foresee happening is that the large, wealthy house will comply utterly because there is too much to lose. The independents and small timers however may choose to say "up your ass" and become fragrance outlaws. They have less to lose. Can you imagine the money these "outlaws" would make just from word of mouth on boards like this....before big brother closed them down?
8 years ago
Mia, that's fabulous! Thank you for letting us know. Very Happy
8 years ago
The more I think about it, the more it seems a pretty clever move to let everyone believe they'd restrict all these fundamental substances and natural extracts. And now, after announcing they probably won't, I can't help it but think I have been tricked into feeling relieved, almost rejoicing at the Commission's moderation to "only" ban oakmoss and lyral?! Shocked
The work stream is going to have a close look at the amendment in order to fully comprehend its implications for perfumery.
Interesting blog about schisms in the industry 8 years ago
Kafka - in her blog - recently wrote about the situation.

akafkaesquelife.wordpress.com/2014/02/14/the-e u-proposes-to-act-on-perfume/
8 years ago
Cryptic:
Mia, that's fabulous! Thank you for letting us know. Very Happy

Fabulous indeed.

I've been a victim of red birch trees but I doubt that ingredient would prevent me from buying the perfume I want with that ingredient listed. Everybody wins, thanks Mia.
News from the work stream 8 years ago
Dear all,
We intent to participate in the Commission's public consultation on fragrance allergens because none of us can be sure that the SCCS's recommendation to drastically restrict many fundamental ingredients, is off the table once and for all. As it stands, the proposal can remain as it is, or be changed in either direction. Furthermore, we not only want to oppose the ban on oakmoss and lyral but also to make the consumer's voice heard.

We will have to rework the petition content, which was already finalised but addressed an amendment based 1:1 on the SCCS's opinion and not the recent proposal. The petition is supposed to flank our evaluation, which we are going to submit to the Commission and will hopefully serve to lend weights to our submission. We hope to be ready to go public with petition and letter template by mid March.

"Never let go of a good thing without a fight."
~ Jarod Kintz
Last edited by MiaTrost on 25.02.2014, 11:03; edited 2 times in total
8 years ago
Thanks for your very informative posts, Mia!

Would it be possible to mention a few perfumes in which lyral plays an important role?
8 years ago
Sure, Sleuth. Lyral, also leerall, is reminiscent of lily of the valley but also features notes such as cyclamen, linden blossom or lily. Because of its extraordinary tenacity and diffusivity, it is a powerful blending agent giving richness throughout all dryout phases of a perfume composition - there is nothing like it. Although used abundantly in perfumery, its role as a potential allergenic constituent was unknown before 1995. Its usage in perfume was subsequently restricted by the IFRA.

Some examples for perfumes with Lyral as key element (prior to reformulation):
"Pour Femme" by Lacoste
"Classique" by Gaultier
"Noa" by Cacharel
"Le Mâle" by Gaultier
"Nightflight" by Joop
"Jaïpur" by Boucheron
"Background" by Jil Sander
"Poison" by Dior and all its flankers
"Boudoir" by Vivienne Westwood
"Rush" by Gucci
"Freedom for Her" by Hilfiger
"Dolce & Gabbana pour Homme" by Dolce & Gabbana
"Coco" by Chanel
"Le Bain" by Joop
"Aventus" by Creed
Last edited by MiaTrost on 24.02.2014, 07:12; edited 3 times in total
8 years ago
Excerpt from Grain de musc: Europe and fragrance allergens: don't panic, it's not as bad as we thought!

What’s happening now?
IDEA (International Dialogue for the Evaluation of Allergens), a work group of stakeholders including scientists from different fields (dermatologists, toxicologists, immunologists, computational modelers, etc.), has been put together at IFRA’s initiative to determine more robust methodologies to assess the risks of fragrance ingredients, based on real-life exposure, not only for allergies but for genotoxicity, reprotoxicity, etc. This approach will be valid not only in Europe, but worldwide.

Will authorized concentrations be one-size-fits-all?
No, the SCCS proposal is off the agenda. Each ingredient on the “hit list” will be analyzed according to the methodology determined by IDEA. Some materials might even have higher authorized concentrations than previously. At this stage it is the methodology that is under discussion: it is impossible to evaluate how long it will take to get results.

How will these concentrations be determined?
While the SCCS opinion paper proposed limiting concentrations based on whether they elicited allergic reactions in people who are already allergic, the methodology all stakeholders have agreed on developing will be based on the level required for inducing allergies in people who were not allergic previously. In the first, worst-case-scenario, many fragrance materials would have indeed been so restricted that it would have been useless to even make perfume. In the second, accepted scenario, concentrations can be higher.

~~~~~~~~~~~~

So, if the SCCS's recommendation are indeed off the table and the new approach to risk assessment is according to IDEA, then this amendment might actually be an improvement to the status quo, at least in some areas. How likely is that, I wonder.
Sonoma Scent Studio has a blog 8 years ago
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