Cropwatch Newsletter 4 - Red Alert Issue
§12. International Fragrance Research Association (IFRA): Now Merely a Cog in the EU Bureaucratic Machine?
Introduction. We start by asking whether the hugely influential organisation IFRA still represents the interests of the world-wide perfumery manufacturing trade in 2006. For various reasons we no longer think that it does – but we can start off by saying that up to now IFRA has largely been concerned with the management of risk within (Western) Corporate Perfumery, formerly, at least, based on devising policies for its members from RIFM’s findings, and issuing a Voluntary Code of Practice which is set out at http://www.ifraorg.org/Guidelines.asp.
RIFM was established in the ‘Sixties by the American Fragrance Manufacturers Association and is/was billed a non-profit-making international organisation, collecting, producing & publishing data on fragrance materials, including data on essential oils. From this data, REXPAN, an international body consisting of dermatologists, pathologists, toxicologists & environmental scientists “with no ties to the fragrance industry”, evaluates, makes a risk assessment & recommendations for individual substances used in fragrances & produces guidelines for the individual fragrance ingredients for IFRA’s members in the fragrance industry.
The Voluntary Code of Practice. Formerly IFRA’s Voluntary Code of Practice represented a golden age in perfumery – allowing enough artistic freedom for creative perfumery to prosper within sensible set of voluntary guidelines. In the past few years, career toxicologists & dermatologists have demolished this situation, implying that IFRA policy over the decades had failed to protect the public from the toxicological outcomes from applied fragranced products, such as skin sensitisation. Ian White, professional dermatologist & the Chairman of the SCCP, wrote in 1997:
“The enormous problem of skin sensitivity is a clear demonstration that voluntary regulation has failed. By forceful moral pressure on the industry and by controlled use of the Annexes in the Cosmetics Directive it will be possible to improve on the present sorry & unsatisfactory situation. ” (White 1997).
White (via the influence of the dermatology lobby, the SCCP & the Brussels Regulatory Machine) is seeing his ambition of destroying Voluntary Regulation in Perfumery achieved, via the removal of both ‘banned IFRA’ ingredients (completed) & restricted ingredients (under way) into the appropriate Annexes of the Cosmetics Directive. Still continuing the same theme five years later, White is quoted in the Sunday Express newspaper (Fletcher 2000):
“Fragrance is now the most important allergen in cosmetics. Ten percent of eczema cases are a direct result of allergy to perfume and we believe that more than two percent of the population could be sensitive to perfumes in beauty & household products. There needs to be better control of fragrance ingredients which are causing great concern.”
Whether the number of adverse effects from fragrances can be shown to have declined, following these described regulatory changes (& others) over the last several years, is pretty doubtful, in view of the huge increase in allergies generally, especially in children (Foggo 2006), & the use of perfumes in public places is still currently considered a health threat in Ottawa at least (Rupert 2006). The latter move in Ottawa may largely be the result of perceptions by a chemophobic sector of the community about synthetic aroma chemicals, (see http://www.users.globalnet.co.uk/~nodice/new/magazine/chemophobia/chemophobia.htm) the use of which for various reasons will have actually increased in fragrances (to the disadvantage of naturals) under White’s chairmanship. What we can say also is that the delisting & restrictions on ingredients inventories have effectively destroyed the art of perfumery as a free creative art form, and modern perfume launches often rely on celebrity endorsement to hype-up their marketing image, to conceal the fact underneath the expensive packaging, many of them smell like toilet cleaner – a direct consequence of this progressive elimination & restriction of useful aroma chemicals (especially natural botanical materials).
EU Regulations. To firm up the facts behind the copying of inventories of substances listed in IFRA’s Voluntary Code of Practice directly into EU law, according to IFRA Information letter IL 748, part of the scope of the SCCP's (formerly the SCCNFP) brief was to consider the subject of fragrance allergy and all IFRA prohibited materials have been moved into Annex II of the Cosmetics Directive 76/768/EEC as a result of Opinions SCCNFP/0320/00 final and SCCNFP/0711/03. Restricted materials are now in the very process of being moved over into Annex III of the Cosmetics Directive on the basis of Opinions SCCNFP/0392/00 final, SCCNFP/0770/03, SCCP/0868/05, SCCP/0871/05 and SCCP/0872/05. This is the slippery slope. Although, arguably, the IFRA Code of Practice might always have had the potential of quasi-legal status in National Member States of the EU - or this was the prediction of several lawyers previously - it now looks like the EU Cosmetics Directive will mirror (but always be slightly behind, time-wise) the IFRA Code of Practice.
We can all therefore mentally eliminate 'Voluntary’ as in ‘Voluntary Code of Practice' as a historic concept & replace it with the word ‘Mandatory’.
A Lack of Independent Scientific Input. The EU Commission is a self-perpetuating regulatory machine whose very raison d’ętre is the continual production of legislation & red tape (via successive EU Directives). Cosmetics legislation is fed by the outpourings of career toxicologists, dermatologists, pathologists etc. who have interests in toxicological data perpetuation to guarantee their continued employment and their professional status. Corporate members of expert committees too have an interest in excessive red tape generation – since their large sized employers are the only sector that can afford to provide the regulatory staff, computer programs, reformulation technicians etc., which are needed to manage the effects of excessive red tape generation. The losers are the smaller companies (who do not have the financial resources to keep up with this excessive legislation without uncompetitively increasing their costs), and of course perfumery itself.
No independent experts input on whether the whole rate & tenure of the cosmetics safety regulatory process is either under- or over-employed, and indeed whether much of it is even necessary. The result is our present state of excessive cosmetics regulation that serves to keep all these above mentioned people in a job, but is frequently based on the over-use of the precautionary principle & a confusion of hazard with risk.
40th IFRA Amendment: “No-One Expects the Spanish Inquisition!” A Python-esque situation is reported in a current trade magazine whereby IFRA potentially becomes inquisitor to any IFRA member whose retailed products do not adhere to the IFRA Code of Practice (as determined by third party analysis). If true, this should completely put an end the pretence that there is anything Voluntary about its Code of Practice. Cropwatch feels additionally that this development would represent some sort of watershed for Perfumery, which may effectively divide the Corporate Perfumery & Artisan Perfumery Sectors.
Meanwhile if non-IFRA members want to find out what is in the 40th IFRA amendment and don’t wish to wait 6 months before it appears on the IFRA website, you will find the bare bones set out at http://www.perfumerflavorist.com/news/3237691.html
Opinion: IFRA Does not Represent Worldwide Perfumery Any More: Discuss!
Complete freedom to use any perfumery ingredients of course still exists in many parts of the world that are untouched by either the IFRA regulations or EU Directives etc., and some perfumery educational establishment and fragrance houses openly boast of this fact as a big plus. Certainly the education of perfumery students will be incomplete without an appreciation of what can be achieved artistically without ingredient restrictions.
However the subject of safety of aroma materials should be under continual review. What was considered safe decades previously, on the basis of no acute toxicological effects from a single dose, may not be considered safe now based on the different perspective of sub-chronic exposure, CMR properties or eco-toxicity.
On this basis, reappraisal of IFRA positioning & Annex II & III listings in the Cosmetics Directive is currently undergoing some behind-the-scenes discussion by aroma scientists. Lets look at one or two examples.
Melissa oil. IFRA have decided this minor essential oil (please note: which is actually derived from Melissa officinalis subsp. officinalis L. to distinguish it from M. officinalis oils of other subspecies which have different compositions) rests in the category of ‘not to be used as or in perfumery/safe conditions of use have not established’. It was previously listed amongst 14 recommended essential oils (correct subspecies indicated) to generate income for developing countries in FAO’s Agricultural Services Bulletin 94 Minor Oil Crops.
Baker (2006) comments that Melissa oil (subspecies not defined) is ‘not used in perfumery’, presumably based on IFRA’s conclusions from a usage enquiry of trade organisation members. However its top-note profile was previously used in the creation of the perfume “Coeur-Joie” (Nina Ricci) who’s launch date some put at late 1930’s (e.g. Arctander 1961), others later at 1946. The comment quoting IFRA, saying that Melissa oil is not used in perfumery is different from saying that the ingredient is not used at all in the whole of perfumery (i.e. in natural perfumery or in artisan crafted cosmetics where is it is used to fragrance creams & lotions etc.). If Corporate Perfumery has shown little current interest in the oil of M. officinalis subsp. officinalis – the use of which dates back to the Ancient Egyptians, and which has monographs in respected reference tomes like Arctander & Guenther - it may simply be because its’ keeping qualities are poor, that it is difficult to find unadulterated & its fresh citrus note can be mimicked more cost effectively by alternative materials (i.e. it’s over-expensive!). Estimates of annual production figures for Melissa officinalis subsp. officinalis L. vary widely, ranging from 2.5Kg/year (FAO), 40Kg/annum (Aqua-Oleum, undated). Cropwatch has 200Kg/annum for 2004 for Melissa officinalis subsp. officinalis L.; but for the different oil Melissa officinalis subsp. altissima Dawson the annual output for 2004 was estimated at 30Kg (Cropwatch, unpublished information). RIFM would presumably be reluctant to spend valuable research funds on such a minor aroma material, and a request for a SCCP Opinion would not therefore be likely to materialise.
However, Melissa oil is a flagship aromatherapy essential oil, has useful properties in aromatherapy & herbal medicine, & any doubts about its’ safety in a perfumery application would appear inconsistent with its widespread & fairly untroubled history of use in aromatherapy practice for the past several decades. There is something wrong when Corporate estimates of usage start to determine our attitudes to ingredients (although, of course, provided you are not a member of IFRA there is nothing to stop you using it in fragrances or cosmetics within the EU).
Santolina oil Santolina chamaecyparissus L. Similarly added to list of other ingredients with ‘non-supported use’ as witnessed in the 40th Amendment to IFRA (i.e. presumably translating as ‘no one responded to our circular’). But Cropwatch would like to point out that there are hundreds of other minor oils currently used in perfumery which RIFM/IFRA/SCCP have not either investigated or opined about, including Leptospermum petersonii, Backhousia citriodora, Backhousia anisata, Aglaia odorata, Agathis fragrans, Olea euopaea leaf absolute, Clausena anisata, Lantana camara, Buddleja asiatica, Amorpha fruticosa etc. etc. It would be unfortunate if useful minor essential oils were continued to be excluded from mainstream fragrances & cosmetics on the basis of little (perceived) Corporate use; however before any actual legal prohibition of use in the EU can occur, it would of course have to follow an SCCP Opinion.
Other natural botanicals listed by IFRA with zero reported use, and to be deleted from INEL include Shallot oil, Acetylated Bois de Rose oil, Opoponax tincture, Linaloe wood oil (from Bursera delphechiana Poiss. etc.), Arnica absolute & Turmeric oleoresin (from Curcuma longa L.). N.B. This is not an exhaustive list of removals.
Benzyl cyanide is also in Annex II, but conversely is a component of much sought-after exotic florals such as karo karunde absolute from Leptactina senegambica Hook. f. (which was found to contain a staggering 4.75% by Laurent (1986) and an even larger 5.2% in genet absolute from Spartium junceum L., according to Shibamoto et al. (1982). In real life I (Tony) happen to live next to a potent benzyl cyanide generator, which in spring/early summer drenches the neighbourhood with toxic fumes. The source of this annual chemical insult is called a ‘mustard seed rape field’ – termed ‘canola’ in the US - and the perpetrator of the annual community seasonal gassing is the local farmer. I calculate the benzyl cyanide dose that I (and millions of others who live in the country) receive annually is several millions times the dose I receive to my body from any applied fragrance. This example shows the irrelevance of such legislation.
Safety in cosmetics should not all be about what happens big industry, but unfortunately there is no one directly involved in the regulatory process to represent any other sector but the dinosaurs of the aroma world.
Actander S. (1961) Perfume & Flavour Materials of Natural Origin” Elizabeth NJ.
Baker S. (2006) “Regulations.” Aromatherapy Times Summer 2006 1(69), 26.
Guenther E. The Essential Oils vol. 3 "Oil of Balm" ISBN No 0-88275-163-8.
Fletcher V. (2000) “Come clean on the Chemicals in Perfume that give us Rashes.” Sunday Express 02.04.2000 p8.
Foggo D. (2006) “Number of Children Treated for Nut Allergies Soars” Sunday Times 02.04.2006
Rupert, Jake (2006): Ottawa Citizen 30.05.06.
Shibamoto T. et al (1982) Proceedings of the 8th Congress of Essential Oils, Analytical Techniques ed. Fedarome 1982.
White I.R (1997) “Fragrances - Future Aspects” in Fragrances, Beneficial & Adverse Effects (eds). Frosch P.J., Johansen J.D., White I.R. pub Springer p223.
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