From - www.cropwatch.org
The EU Biocidal Products Directive 98/8/EC and Essential Oils – The EU Machinery
Gets It Wrong Again!
§1. Alarm Bells Ring.
Poor publicity surrounding the passing of the EU Biocidal Products Directive 98/8/EC caught many in the EU commercial sector off-guard. For example an European Federation of Essential Oils (EFEO) communication (Nov 2003) drew attention of its members to yet another piece of legislation potentially affecting the free & unfettered use of essential oils: “The EU rules on biocidal products (EU Directive 98/8/EC, Regulation 1896/2000/EC) and the follow up piece of legislation OJ L 307 of 24th November 2003, accessed via http://europa.eu.int/eur-lex/en/oj/index_20031124.html, means that under Annex III , and as far as we can understand the situation at present, the following oils - subject to clarification - cannot be used in the Community Market as Biocides after 1st September 2006*:
Basil oil, Cajuput oil,
Cedarwood oil, Celery oil, Chamomile oil, Citronella oil, Clove leaf oil,
Coriander oil, Cornmint oil, Cumin oil, Cypress oil, Eucalyptus oil,
Juniperberry oil, Neem oil, Pinus oils, Lavender oil, Lemongrass oil,
Geranium oil, Litsea cubeba oil, Melaleuca oil, Pine oil, Black
pepper oil, Palmarosa oil, Patchouli oil, Pennyroyal oil, Peppermint oil,
Rosewood oil, Rue oil, Spearmint oil, Thyme oil, Valeriana officinalis
oil, and many, many other natural oils or natural extracts.”
information in this 2003 communication may have subsequently been updated -
please check the appropriate websites.
§2. Preamble: Biocides and Legislation: a Potted History
The EU Biocidal Products
Directive (BPD), is aimed at harmonising the EU internal market for biocides,
affording a high level of human, animal & environmental protection, being
adopted by the European Parliament in April 1998; member states were supposed to
transpose the rules of this into national law by 14 May 2000. Biocides are
products that destroy,
deter or render harmless, harmful organisms by chemical or biological means, or
otherwise control or prevent their action. The BPD covers similar product types
to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) in the US.
The model for the BPD was the Plant Protection Products Directive 91/414/EEC (PPPD), which came into force in July 1993, aiming at harmonising regulatory information. Here, active substances used in PPP’s were individually evaluated and a dossier is constructed containing all the safety studies for the active substance(s), as defined by the directive. Approved substances, are then listed in annex I. A 12-year review process was begun, intending to evaluate all active substances by July 2003; PP’Ps. Fees paid by producers wanting to support an individual PPP were in excess of £125,000 (British Pounds). A guidance document for borderline products between the BPD and the PPPD is available at http://ecb.jrc.it/biocides/
Returning to the BPD – the
directive describes four main groups of products, divided into 23 categories of
biocidal product types which fall within the remit of the Directive – this is
extremely wide-ranging and can be viewed at
http://ecb.jrc.it/biocides by clicking on
'Directive 98/8/EC’, but for convenience these categories are set out below:
MAIN GROUP 1: Disinfectants and general biocidal products
Product-type 1: Human
hygiene biocidal products
Product-type 2: Private area and public health area disinfectants and other biocidal products
Product-type 3: Veterinary hygiene biocidal products
Product-type 4: Food and feed area disinfectants
Product-type 5: Drinking water disinfectants
MAIN GROUP 2:
Product-type 6: In-can
Product-type 7: Film preservatives
Product-type 8: Wood preservatives
Product-type 9: Fibre, leather, rubber and polymerised materials preservatives
Product-type 10: Masonry preservatives
Product-type 11: Preservatives for liquid-cooling and processing systems
Product-type 12: Slimicides
Product-type 13: Metalworking-fluid preservatives
MAIN GROUP 3: Pest
Product-type 15: Avicides
Product-type 16: Molluscicides
Product-type 17: Piscicides
Product-type 18: Insecticides, acaricides and products to control other arthropods
Product-type 19: Repellents and attractants
MAIN GROUP 4: Other
Preservatives for food or feedstocks
Product-type 21: Antifouling products
Product-type 22: Embalming and taxidermist fluids
Product-type 23: Control of other vertebrates
Substances deemed “suitable”
for use in biocidal products are set out in Annex I of the BPD - the European
Chemicals Bureau produced an initial non-exhaustive list of active substances.
Individual commercial products containing these substances will require
authorisation under the Directive within Member States. If proponents wish to
support a substance through a review process under the Directive, then they have
had to 'notify' the active substance to the European Chemicals Bureau,
indicating biocidal product type they wanted to support the active for. If
proponents did not want to support the substance through a review then there was
the option to 'identify' the active substance. The lists of notified and
identified active substances are available in the Second Review Regulation.
Annex I of the Second Review Regulation contains the list of existing active
substances which have been identified, and Annex II of the Second Review
Regulation contains the list of existing active substances which have been
notified. This can be found at:
Three possibilities emerge:
1. For active substances
that have been notified, products containing them can continue to be placed
onto the market subject to any requirements under existing national legislation,
until the review has been completed. If the
substance is successful in gaining listing on Annex I, then products containing it will need to be authorised under the Directive in Member States. Once authorised, any approvals given under older national schemes will lapse. If the substance does not gain Annex I listing then products containing it will have to be removed from the market.
2. If an active substance has been identified but not notified, or notified but not for the product types in which products are marketed, such products can continue to be placed on the market, subject to any existing national
rules, until 1 September 2006.
3. If an active substance has been neither identified nor notified, then products containing that active substance can no longer be legally placed on the EU market after 14 December 2003 (i.e. the date that the
Second Review Regulation entered into force).
Although many low risk biocidal products may not have needed supporting, Knight (2000) gives details showing the estimated the cost of supporting an active substance through a BPD review at the time as £1.48 million and for the whole EU program of active substances as £370 million. Other estimates included one of 3 million Єuros ($2.6 million) price tag for each active ingredient in cosmetics formulations should they not be exempt (Scott 2002). Basically this has meant that large concerns such as Rohm and Haas, BASF, and Lonza were capable of supporting their biocidal product range, whereas many small producers closed down or were acquired by competitors.
A list of biocidally active chemicals where restrictions of marketing and use applies under Directive 76/769/EEC includes:
· Arsenic (Directive 2003/2/EC)
· Creosote (Directive 2001/90/EC)
· Organic tin compounds (Directive 2002/62/EC)
· Mercury (Directive 89/677/EEC)
Failure of eleven national governments to transpose the EC commisions 1998 BPD into national law or failing to adopt certain measures to its dangerous substances directive, has resulted in a series of legal threats against Luxembourg, Austria, Germany, Greece, Luxembourg, the U.K. etc. and legal action against France by the European Commission in the European Court of Justice (Brown, 2001; European Report 2003, York 2002).
The biocides market is mature, growing at
some 5% per annum. Freedonia Group (2000) predicted that the US demand for
biocides would reach $2.2 billion in 2004 with halogenated products (chloroisocyanurates,
iodophors etc. – used in water treatment) constituting the largest group.
§3. Some Aspects of the After-Effects of the BPD.
It is impossible within a short space to set out the full
implications of the legislation on the EU commercial sector, and indeed on EU
citizens, but here below are a few considerations:
Pesticides: Scott (2002) predicted that there would be an 80% reduction in the number of biocides available in the commercial market, removing small tonnage active products for niche markets, and letting in products which were non-specific for the task and which had to be applied in larger volumes. The deep misgivings of learned horticultural experts with respect to the effects of the incoming legislation were widely reported in the UK daily press. Pook (2002), reported a statement by the Royal Horticulture Society that “many well-known garden chemicals would disappear not because of safety but because of the high cost of gaining approval for sales in a relatively small market EU ruling will cut range of pesticides”. Elsewhere in the article Pook predicts that the number of approved substances would drop from 800 to 300. Other press criticism included remarks in Metro July 30 2002 concerning risk of the rise of resistant super-pests, prompting Prof. Paul Jepson to speculate that “public pressure might change once the production of a range of crops is no longer sustainable”. By July 8th 2003, the Guardian (p8) predicted chaos as lawnfeed and weedkiller products sold by large UK stores were banned by an unpublicised European directive, and had to be disposed by local authorities whose local councils were unaware of their new responsibilities.
“Safe biocides” is of course a relative term - weedkillers used in farming being washed into rivers and carried down to were blamed for erosion of salt-marshes threatening the coastal defences in the SE of England according to Prof Chris Mason of Essex University as reported by Geraint Smith Evening Standard 23 June 2003 p18. Even The Times reported that superbugs threaten our potatoes and carrots (Times Tues July 30th 2002 p7) quoting Professor Ian Chute of Rothampstead, who said that “it is certainly quite possible that a combination of resistant insects and removal of insecticides through regulation could leave us vulnerable to a situation where we would have to bring these articles in from abroad”.
Niche applications of natural products (e.g. garlic vegetable processing waste used against aphids in the cut flower industry; various essential oil-water-natural surfactant emulsions against rust in vegetable & herb crops) are known in the essential oil trade; these applications tend to be minor use “trade secrets”.
Food trade. Campden & Chorley Wood (Anon 2003) wrote a brief piece reporting on the significant costs to disinfectant manufacturers caused by the requirements of the BPD, additionally noting that currently there is no requirement for disinfectants to be approved for use in the UK, and that the responsibility to provide assurances on efficacy was down to the producer. But they also noted that the European Standards Organisation (CEN) have produced new disinfectant test methods which are published by the British Standards Institute, the methods including disinfectant use throughout the food chain, including efficacy against bacteria and their spores, fungi and viruses.
Cosmetics Industry & Biocides
Dweck (SPC 2003) subtitled his paper to the SCS Symposium
2003 as “The Reality of the Futility of Natural Preservatives”, pointing
out the hoops that have to be jumped through for a natural material to attain
natural cosmetic preservative status. Thus the prospective ingredient would have
to appear in Annex VI Part 1 of 2 of the EEC Cosmetic Directive 76/768/EEC,
including the 7th amending Commission Directive 94/32/EC, have a beneficial
effect on the skin and have a positive effect on the total preservative
requirement of the formulation, if it is declared as a natural active as ‘a
parfum’. Notwithstanding, Dweck goes on to list the potential antimicrobial
activity of a huge range of plants and extracts.
Earlier David Roper (Manufacturing Chemist 1996)
had suggested that reliance on preservatives in cosmetics might be reduced via
formulation strategies such as adding salt or glucose; maintaining pH levels at
5.5; using metal ions such as silver, or using natural antibiotics such as neem
tree seeds, herbs, spices and terpenes.
These two examples confirm the position of certain natural aromatic products as being biocides by technical experts working in the field.
The Aromatherapy position wrt Biocides: Previously Sylvia Baker of the Aromatherapy Trades Council (currently representing some 53 essential oil distributors) produced an information sheet together with Phillip Clarke of the Health & Safety Executive in Dec 1998 which explored the position of the BPD and the practice of aromatherapy. At the time it was expected that essential oils used in UK practice would appear to fall under the scope of the Medicines Act 1968 and would not be affected by the BPD. Creams, lotions and massage oils were expected to fall within the Cosmetic Products (Safety) Regulations and again not be affected by the BPD. An appeal to ATC members to list essential oils used as insect repellents was made in Jan 1999 so that the could be included in a BPD positive listing and remain on the market after May 2000. A Nov. 2003 legislation udate by the ATC at http://www.a-t-c.org.uk/pages/index.cfm?FuseAction=ShowPage&sec=6&page=190 states: “These Regulations are likely to only affect those aromatherapy companies that produce products whose prime function is that of insect repellents rather than cosmetics”.
Essential Oils Trade.
The essential oils supply industry has already been under pressure from intolerable demands for documentation and EU red tape with respect to 7th Amendment to the Cosmetics Act (26 allergens issue), Transport & Packaging regulations, GMO certification, foodstuffs regulations (naturalness certification, heavy metal content, pesticide levels, PCB’s levels, dioxin levels) etc. etc. and many oil traders have disappeared altogether or have been taken over by larger concerns. In spite of the efforts of bodies like European Flavours & Fragrances Association, many oil traders are still completely unaware of the BPD, or in the current state of low morale, regard it as another just nail in the coffin for the industry. The opening communiqué from EFEO above in §1 gives a flavour of a harassed and overstretched industry trying to cope with increasing demands for paperwork which detract from its’ core activity of producing & trading essential oils.
In today’s marketplace, fragrances are often expected to
possess beneficial properties apart from merely possessing a pleasant odour -
mood changing perfumes, for example, are now quite commonplace. Biocidal
perfumes have been with us for a long time – in fact a forty-year-old article on
the properties of Eau de Colognes (Rovesti P. 1961) explores & celebrates this
very concept. Nevertheless, it would seem that this area needs to be better
explored, in order not to suppress potential commercial applications.
A number of small UK companies use formulations containing
essential oils as insect repellents for human and animal use (horses, dogs, cats
etc.); a literature review of these applications is currently in preparation by
the author. Most of these companies contacted by the author in 2003-4 were
unaware of the BPD.
In a private letter to the BPU (Dec 2003), the author
pointed out that one of the principle anti-malarial drugs (artemisinin) is
derived from the extract/essential oil of the plant Artemisia annua,
extensively used in Chinese medicine for over a thousand years as an
anti-malarial (Trig 1989) – which does not figure in the BPD Annexes. This
litmus test failure shows that leaving the construction of an exhaustive list of
biocides to industrial input has been largely unsuccessful (this being just one
example of many).
Why draw attention to the Biocides issue? It is important
because the EU citizen’s right to use natural products is being continually
eroded, often by legislation which is seen by some outside experts to be highly
contentious or distinctly in favour of Corporate interests. It isn’t a great
step to empathise with ‘conspiracy theory’ supporters who suspect that the power
and influence of large chemical and pharmaceutical concerns (via lobbying in
Brussels etc.), is actually influencing and distorting the proper and fair
process of EU law-making, and affecting the free choice and human rights of the
EU buying public to buy natural products.
Essential oils as biocides.
A literature search will reveal whole libraries-worth of
material supporting the traditional multi-faceted global role of essential oils
and other aromatic products as biocides – for elimination of food crop pests,
for their human topical anti-fungal properties, for actions against human
bacterial pathogens, their uses in vetinary applications against parasitic
infestations, and as disinfectants and preservatives as well as uses as insect
repellents and attractants.
To quote a couple of examples, the use of essential oils
as an alternative to methyl bromide fumigation for food crop produce was the
subject of an article by Landau (1999), and the death kinetics of
Staphylococcus aureus bacteria to tea tree oils was reported by Christof et
al. (2001). How can it be then that the existing EU legislation is in denial
over these properties, seeking to cover up biocidal properties by filing away
natural products in other pieces of legislation – such as General Medicines Act,
or by regarding them as cosmetics. Scientifically, essential oils are
biocides – it’s an irrefutable fact. Why then do we have to tolerate pieces
of EU legislation such as the BPD, which requires an impossibly large input of
effort by non-EU officials, in order to give EU legislators concerned an
exhaustive positive list of biocides which includes natural products?
Well that’s not strictly true, they would argue. Whereas
you could be forgiven for assuming that the BPD had been drawn up 100%
exclusively by input from the synthetic chemical industry [indeed the standard
text book on the Biocides Business (Knight & Cooke 2002) - does not even
mention essential oils!] defenders of the existing legislation (if there
are any) would point to Annex 1 of the Directive, where some essential oils have
been listed. The problem is, with so many possible potentially biocidal
essential oils – who exactly has time to list them all (basically for zero
potential reward)? And why aren’t they listed there for potential use as a block
category, by a competent EU official?
EU legislators would argue that those with vested
interests in using essential oils in retailed products specifically for a
biocidal purpose would be the people to have registered the oils in Annex 1. But
the real answer is of course that the situation is driven by economics. “Big
Industry” cannot generally make serious amounts of money out of marketing
applications of commonly used essential oils as biocides – as their applications
are often enshrined in traditional use, and therefore the applications are
prospectively not covered by patents. Conversely small retailers of biocidal
products, who might benefit from niche applications, are unlikely to be able to
afford the enormous prospective costs of the complete registration process with
their slender economic resources, and so are prevented from pursuing their
legitimate commercial interests. Clearly an uneven playing field discriminating
against small concerns, created by the requirements and procedures of the EU
Anne Ashton (2004) has advised that a Niche Market Working
Group has been set up by the EU Commission to investigate and take forward the
issue of low volume/niche market uses of biocides – however the problem is one
of identification & notification of interested parties who may not belong to
trade associations or other concerned groups.
2. Safety issues
The fact that the world is not yet a healthier place in
spite of the commencement of the Chemicals Policy of the EU has been the subject
of recent press comment, as for example the frequency of the incidence of
cancers continues to rise (including breast cancer: Ruddell 2003; Hodgekins
lymphoma, prostate & testicular cancer & multiple myeloma: Page 2004), and
asthma attacks and allergies reach alarming levels Europe-wide. This was a
stated reason why the Chemicals Policy was introduced in the first place (see:
http://europa.eu.int/eur-lex/en/com/wpr/2001/com2001_0088en01.pdf). Whilst it
could and probably should be argued that it is early days for this policy just
yet, the effects of the legislation may well lead to human body loading of
higher amounts of “safe” synthetic chemicals with unknown prospects for human
health over the long term.
Another negative aspect of the BPD legislation is the fact
that as well as the requirement to register actives, risk assessments will have
be carried out in relation to human health and the environment, whilst efficacy
will also be valuated. Ann Ashton notes (2004) “It was not the EU Commission or
the Competent Authority's responsibility to ensure all actives are listed, but
Industries’ responsibility to choose which actives they wished to list”
(presumably therefore only the profitable ones will be listed). This, to my
mind, thoroughly mis-comprehends the expected role of industry in this matter by
the BPU. The fact that there is no actual industrial economic incentive to list
natural actives has been already dealt with above. But more seriously, the fact
is that the safety of essential oils is already thoroughly reviewed &
established elsewhere, and it seems stupid to reinvent the wheel for this
essentially specious purpose here. In any case, many aspects of safety of
essential oils are, however, quite contentious: the 26 allergens issue (within
the 7th Amendment to the EU Cosmetic Act) is considered by many in
the aroma trade a thoroughly bad piece of legislation based on shaky scientific
evidence generated by identifiable dermatologists with vested professional
interests and an obviously poor comprehension of aromatic & terpene chemistry.
Curiously the Act has been passed (perhaps, it could be cynically argued, that
it came along at a convenient point to be fitted within the scope and aims of
the EU Chemicals Policy), in spite of the accumulation of scientific evidence
suggesting the science behind listing of certain substances within the 26
allergens list is patently incorrect (for example in the cases of linalool,
coumarin, benzyl salicylate etc). This particular piece of legislation has had a
negative effect on the overall volumes of natural essential oils incorporated
into cosmetic formulations as fragrance components in the past year or two,
letting in Corporate Aroma companies with the resources to produce “safe”
synthetic molecules, and driving us evermore towards a synthetic perfumery
future. The art of natural perfumery – and hence the rights of consumers to
avoid un-natural synthetic aroma chemicals - has been made almost impossibly
difficult to work by this divisive legislation.
The requirement to demonstrate efficacy of the “identified
actives” in the BPD – reveals even more evidence of the synthetic chemical
lobby’s influence in the very wording of the legislation. “Identified actives”
in essential oils are 100% of the contents of the oil, because of the symbiotic
biocidal activities of the individual components making up the oil. Whereas
essential oils are distinctly useful as biocides, they may not be sufficiently
wide-spectrum in their range of actions, may not have rapid kill times, and
their minimum inhibitory concentration values may not be in the same range as
chemical disinfectants. Does this mean they should be excluded from the
definition of disinfectant just because their mode of action is not widely
appreciated or not fully elucidated? The range of mechanisms displayed by
essential oils for bacterial kill (for example Knobloch et al. 1987 suggested
terpenoids inhibit electron transport, proton translocation, phophorylation
steps and other enzymic reactions within the cell) surely means that they
justify occupying a separate category of biocides all on their own? In
particular cell mortality via potassium ion leakage has been established as a
mode of action by tea tree oil (Melaleuca alternifolia) against E.
coli and Staph. aureus by Cox et al. (2000), although other workers
have explored other possible modes of action (i.e. Carson 2002); these may prove
useful in fighting drug-resistant human pathogenic fungi etc. such as Candida
albicans (see Mondello F. et al. 2003). It seems that purely commercially
orientated definitions of active components, disinfectants, antiseptics etc. is
going to lead to the distorted world of corporate science, which has little
relationship to the absolute of pure science and truth.
3. A (past) glimmer of hope? - Essential and Minor
If you go to
http://www.hse.gov.uk/hthdir/noframes/biofact11.htm you will see that under
the heading of Essential and Minor Use Products:
“At a meeting of the competent authorities in Dec 2001,
there was some discussion about the difficulties some Industries may have in
supporting active substances that are considered to have minor or essential uses
as biocides. Essential oils, pheromones and Product Type 22 (embalming and
taxidermy fluids) were mentioned as examples. Whilst the EC is clear that there
are no derogations under BPD for such uses, it does appreciate that there may be
difficulties and that an alternative way forward may need to be found. With this
in mind, the advice the EC is giving is that active substances with uses such as
biocides should at least be identified before 28 March 2002. After this date the
EC would look at the issue again. The best option is still to notify in case it
is not possible to agree a different way forward.”
If this is indeed a way forward, it seems that not many
outside specific EC committees know of it.
4. Attempts at reform.
The following extract from a personal mail was sent to the
BPU in Dec 2003 by the author:
“The existing list of notifiable substances which you
referred me to at
is in great need of editing by someone with technical knowledge. For example,
Clove oil is un-necessarily down twice, once under its unused former Latin name.
Cedar oil is down twice (as CAS No: 68890-83-0: Texas Cedarwood oil and
8000-29-7: Virginian Cedarwood oil, but this isn't made clear) but none of the
genuine cedarwood oils are listed [for example Atlas Cedar Cedrus atlantica,
Himalayan Cedar Cedrus himalaya etc.]. This is unfortunate because
Cedrus deodara is used in Indian to combat sheep mange, and as a
molluscicide. Does this non-listing mean that a farmer in the UK who wants a
natural preventative to combat sheep mange in his flock cannot use the oil of
Cedrus deodara after September 2006?
Really the list of actives is not a defining document, does not include Latin names, chemotypes or geographic origins of essential oils which are universally recognised as being required to properly define them, and mixes US and EU listings of CAS numbers. Further, the comprehensive listing (as claimed) of all uses of essential oils used as Biocides is probably not technically possible as I indicated earlier unless expert input is employed, and is especially not attainable in a short timescale, by merely relying on inputs of busy technical departments of those manufacturers who are aware of the regulations.”
At the time of writing (31.05.04), many of the EU internet
links on Biocides are not working, so any subsequent reforms made to overall
scientific accuracy of the information currently presented cannot be checked
§5. Concluding Thoughts.
As we have seen above, enactment of hasty and badly constructed EU legislation implementing aspects of the Chemicals Policy (such as the “26 allergens” issue & the BPD) has benefited the large industrial concerns and has caused the collapse and acquisition of many smaller EU companies unable to financially support their products. In certain cases currently known to the author, large Corporations are just waiting for the biocidal product patents of small concerns to expire, or for the companies to bleed to death financially because of BPD requirements, before jumping in and patenting the products for themselves. In this respect the EU is certainly living up to its reputation as “a rich mans club” and is actively discriminating against small concerns by setting them impossible conditions for the continuance of business.
The frightening aspect of the BPD legislation, as with
other aspects of EU bureaucracy, is the sheer impotence of the European citizen
or small craft industry in being able to make the slightest difference the
eventual outcome of any due EU legislative process. The European citizen has
been effectively disenfranchised by a Brussels mindset which prefers to deal
exclusively with professional organisations and industrial representatives. In
practical terms, notifying a completely exhaustive list of
essential oils with biocidal properties to Annex 1 might theoretically take an
ethno-botanist with a team of helpers a year or so to complete – adding safety
information (where available) might take a lifetime. In any case much safety
information on essential oils used in perfumery and flavourings is already
available, and some of these same assessed oils are also used for biocidal
purposes. So why exactly should we EU citizens be denied the potential use of
essential oils as biocides in the future, because inappropriately experienced
officials in the EU with no authoritative overview for this area want a positive
list? Essential oils are already used in many hospital and health care
situations – and so the sheer absurdity of this measure coming so quickly after
the “26 allergens” fiasco, can only sour the relationship between an aroma
industry overworked with red tape, and - in the author’s judgement, the whims of
a somewhat under-performing and misdirected Health and Safety officialdom.
1. That essential oils as class of biocides be treated as a special case.
2. That essential oils should be enabled to classified as the disinfectants and antiseptics that they undoubtedly are.
3. That all essential oils should be classed as potential biocides per se in the BPD, and not shunted off into other categories with secondary biocidal properties appended (such as cosmetics).
4. That toxicological evidence and matters surrounding the safe use of essential oils as biocides be adopted by reference to the experience and experimental studies of other user industries (perfumery, flavourings, pharmacology etc.).
5. That a referee is appointed within the EU Commission to review and amend existing legislation, in order to prevent “Corporate and Vested- Interest Science” ever again distorting the basis of absolute scientific truth required for EU legal processes.
That the fundamental right to free choice for EU
citizens in being able to purchase commercially retailed items containing
ecologically sound natural products rather than synthetic chemicals be addressed
by the EU.
Anon (2003) “CCFRA can help
with disinfectant choice” Food Trade Review 5/1/2003
Ann Ashton, BPU (2004) –
Brown J. (2001) “Brussels
Threatens Action over Biocide Directive”
Carson CF et al. (2002) “Mechanism of action of Melaleuca alternifolia
(tea tree oil) on Staphylococcus aureus determined by time-kill, lysis,
leakage, and salkt tolerance assays and electron microscopy” Antimicrob.
Agents Chemother. 46(6), 1914-20.
Christof F., Stahl-Biskup E. & Kaulfers P.-M. “Death Kinetics of Staphylococcus
aureus exposed to commercial Tea-Tree oils s.l.” J. Essen Oil Res. 13,
98-102 (Mar/April 2001).
Christy (1992) quoted by
Kiesche, Elizabeth S. “Regulations create a hairy environment for biocides”
Chemical Week 7/22/1992.
Cox SD et al. (2000) “The mode
of action of the essential oil of Melaleuca alternifolia” J Applied
Microbiol 88(1), 170-175.
1/21/2003: Environment: Luxembourg warned over pesticide legislation.
Freedonia Group (2000) Research studies - Biocides
Freedonia Group Inc Cleveland, Ohio.
Konbloch K. et al (1988) “ Mode of Action of Essential Oil Components on Whole Cells of Bacteria” Bioflavour 1988 pp287-299.
Knight Derek J. and Cooke Mel (2002)
The Biocides Business - Regulation, Safety &
Applications ed. by pub. Wiley-VCH 2002 ISBN
Knight Derek J. (2000) “Active
Control for Biocides” Chemistry and Industry 8/7/2000.
Landau P. (1999) “Essential
oils prove natural substitute for methyl bromide” Chemical Market Reporter
(1997) “Preventing Microbial Contamination”
Mondello F. et al. (2003) “In vitro and in vivo of tea tree oil against azole-susceptible and –resistant human pathogenic yeasts” J Antimicrob Chemother. 51(5), 1223-9.
Morrison S. (2002) “Biocides
rule confuses suppliers to cosmetics sector” Chemical Week 3/20/2002.
Page J. (2004) letter to The Guardian 28th
May 2004 p27.
Pook S. (2002) The Guardian
16th Sept 2002 p7.
Rovesti P. (1961) “Aromatherapy and the Antiseptic Properties of Eau de Cologne” International Commemorative Symposium on Eau de Cologne SPC Year Book 1961 pp. 7-9 & 16.
Ruddell R (2003) “Environmental Pollutants & Breast
Cancer” Environmental Health Perspectives June 2003.
Scott A (2002) “Group fears EU
policy may decimate industry” Chemical Week 10/30/2002
SPC (2003) “Prevention & Cure: Cosmetic micro-biology – reducing your growth potential” SCS Symposium 12-13th May 2003 Soap, Perfumery & Cosmetics Sept 2003.
Trig P.I. (1989) Qinghaosu
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