In February, The European Commission proposed tighter regulation of the $31 billion fragrance industry with a series of bans, labeling requirements and research projects aimed at protecting consumers from allergies.  Earlier this month The International Fragrance Association, the perfume industry’s self-regulatory body, proposed alternatives to the Commission’s fragrance-allergen proposal.   Here we will take a quick look at what both groups want and how they see the industry moving forward.

The European Commission

The EU Commission proposed a ban on molecules contained in popular perfume ingredients in order to protect consumers from potential allergies. The report:

  • Called for drastically reducing the use of many natural ingredients found in perfumes, on the basis that 1 to 3 percent of the EU population may be allergic or may become allergic to them
  • Recommended restricting the concentration of 12 substances – including citral, found in lemon and tangerine oils; coumarin, found in tropical tonka beans; and eugenol, found in rose oil – to 0.01 percent of the finished product
  • Proposed an outright ban on tree moss and oak moss, which provides distinctive woody base notes in Chanel’s No.5 and Dior’s Miss Dior
  • Seeks to conduct further research to determine what level of concentration should be used for those 12 ingredients and for another eight. These ingredients represent the spine of about 90 percent of fine fragrances, according to experts
  • Desires to have a ban of atranaol and chloroatranol, molecules found in oak moss and tree moss, two of the most commonly used raw materials because of their rich, earthy aroma and ability to ‘fix’ a perfume to make it last longer
  • Looks to ban HICC, a synthetic molecule which replicates the lily of the valley aroma and which has also been widely used by perfume makers
  • Aims to significantly lengthen the list of molecules and ingredients perfume makers have to label on the packaging of their products to warn potentially sensitive users
  • The proposal, which will effectively take the form of an amendment to the Cosmetics Regulation adopted in 2009, will undergo a public consultation period of 12 weeks and could be adopted as early as the end of this year
  • The expanded list of banned ingredients could include upwards of 80 established or likely contact allergens

 The International Fragrance Association (IFA)

The IFA  is advocating for the EU and the industry to work together to implement a program that would limit consumer confusion, be of greater assistance to sensitized individuals and impose less of a burden on industry, instead of a law banning critical ingredients.  The IFA believes that:

  • Indicating the fragrance allergens in the list of ingredients labeled on the product is not the most effective and appropriate means enabling the allergic consumers to make an informed choice as to which fragranced product to use with confidence
  • The EU approach tends to confuse consumers and is burdensome for industry, which faces compliance challenges due to limited space on product labels, as well as the potential need for costly relabeling if and when their product formulations or production processes change, new scientific information surfaces or additional allergens are identified
  • The industry is prepared to comply with the EC’s proposed ban on atranol and chloratranol, which are components of oak moss extract and tree moss extract, respectively, and hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC), a synthetic scent similar to lily of the valley
  • With implementation of Good Manufacturing Practices, the problematic moss extract components will not be present above trace levels, and all products on the market will be compliant by the deadlines set out in the EC’s proposal
  • Extending labeling requirements for fragrance allergens is a concern, as they may not improve the level of information for consumers nor enable future enhancements
  • Substance labeling on product packaging is rarely helpful or effective at preventing allergic responses and would  like to see the use of pictograms on-pack warnings and links to web-based sources targeting allergy sufferers in a way that is interesting, easy to understand, credible and action-oriented
  • The listing of fragrance ingredients that are potential allergens on products also brings up the issue of maintaining trade secrets

Moving Forward

The European Commissioner for Consumer Safety believes they have found a way of proactively ensuring consumers are safe while protecting the industry.  In the meantime some brands have already started modifying their formulas accordingly.

1938 is the online magazine blog for Well-Kept Beauty, formally entitled Primer.

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