ALLERGEN ARTICLE: COULD THIS BE THE END FOR NATURAL PERFUMES?
Copyright © John Stephen, Cotswold Perfumery July 2004.
Pre-amble: Cropwatch is indebted to John Stephen who has kindly agreed permission for this article (written in 2004) to be reproduced from the Cotswold Perfumery website. The subject matter is the EU’s Seventh Amendment to the Cosmetics Act, which incorporated the controversial and scientifically questionable SCCNFP Opinion on the 26 (alleged) allergens, and its devastating effect on the craft of perfumery from an insider’s viewpoint. Now read on….!
ALLERGEN ARTICLE: COULD THIS BE THE END FOR NATURAL PERFUMES?
By John Stephen, Cotswold Perfumery July 2004.
We are all used to hearing about the often absurd laws that emanate from Brussels, to the point where nothing would really surprise us. Well there is another batch on its way, due in March 2005. This time it’s about perfume, and it could threaten the quality and variety of the perfumes that we all wear.
The new regulations require manufacturers of fragrant products to label those products if they contain allergens. All well and good you say - we don't want to wear perfumes that make our skin itchy, and what’s more, it would be nice to know which perfumes they are so that we can avoid them. In theory I agree. In practice I don’t think it is going to work, and worse, it could end our use of natural ingredients in perfume.
The problem is that the occurrence of the materials that have been sited as allergens is simply too wide. Let me give you an example – there are 26 allergens on the initial list and geraniol and limonene are two of them. Here at The Cotswold Perfumery we have 600 raw materials in stock that we blend together to create our fragrances. The majority of these materials are natural and yet at the last count only three of them - sandalwood, cedarwood and patchouli - did not contain either geraniol or limonene. So in practice virtually all natural materials will be affected.
We have to ask ourselves here whether we have taken our eye off the ball. Is there really any benefit in warning the public about ingredients that are present in every natural product? If so, why don't we just have a label that says “Warning - contains natural materials” and be done with it.
At this point it would probably be helpful to clarify our stance. Firstly, we totally agree with the principle of a safe product. All our products conform to the recommendations regarding concentrations of known allergens in perfume and always have done. And we are also aware that there is a significant minority of the population who suffer from allergies, the effects of which should not be under-estimated. In the food industry, allergies to nuts for example are very serious indeed, and in some cases can be a matter of life or death. Labelling food products that contain nuts is therefore essential. Similarly, in our own industry, some natural perfume oils are photosensitive and are therefore carcinogenic if exposed to sunlight. Again, there is no compromise here, and they simply should never be used in perfume over the recommended level.
When it comes to materials that might make your skin itchy, it is true that there are some that affect a large percentage of the population. As a creative perfumer I either avoid these altogether, or use them at or below the recommended level. This level is set by the industry research organisations (see below) who say that if used at this level, the number of people affected will be so small as to make it statistically acceptable. This mathematical calculation is essential because whatever material you pick, there will always be someone, somewhere who will be allergic to it. There is no such thing as 100% allergen free, and the only practical solution is to make sure that the size of the group of people who do react to a particular material is sufficiently small.
Then we come to the question of how small is small? If you make it very small, then virtually everything falls into the net and becomes an allergen. Is this the way we are moving? It would certainly fit the pattern of over-caution that has swept through our lives in the last few decades driven it would seem by the ever increasing presence of a litigation culture. What’s the next step - are we to be sued for using the flowers in the garden and the fruits on the trees? It’s perfectly feasible. But what is more absurd is that the law only applies to fragrances, not food.
If we use orange oil in our perfume and you apply it to your skin, you are going to have to be warned by us that it contains limonene if we use more than 0.001%, which is actually a very small amount indeed! On the other hand, if you go down to your local supermarket and buy an orange, even though your hands will be dripping in many thousand times as much limonene when you peel it, you don’t have to be warned about that apparently. I suppose I should add here that if any policy makers are reading this, I am not advocating the marking of all oranges and lemons with black crosses!
So we have to label our products – so what, it’s no big deal. Well actually, I fear that it might be. The real tragedy may be yet to come. All it takes is some over zealous reporting, a few sensation seeking TV programs highlighting the “dangers” of perfume, and you can just imagine the media response. Allergens are bad; we don't want bad things in our perfume so we want allergen-free perfume. The link is easy to make and the next stage will be that the marketing guys will want to be able to claim it's allergen free, so will be pushing manufacturers like us to create allergen free fragrances.
We can of course make allergen free perfumes – no problem – it’s just that the quality and range will be seriously reduced. When I sit in my lab I have in front of me 600 oils to choose from – just like the notes on a piano keyboard to a composer. Now imagine asking the composer to write a song with 60% of the keyboard removed. The gaps wouldn’t be uniform either – sometimes a whole octave might be gone. Songs could still be written of course, but you couldn’t expect anything like the same range.
With no limonene, all my citrus notes would have been taken away at a stroke, so Eau de Cologne types with that fresh, punchy zing will be a thing of the past. With no geraniol I wouldn’t be able to use most of the major components of floral compositions like Rose, Jasmin, Narcissus, Geranium and so on.
From a perfume creation point of view, natural materials have one great advantage over man made chemicals – they are interesting. Human beings are complex sophisticated animals that get bored quickly, and it is the complexity of natural materials that keeps our interest - it makes them “liveable with” over time. When did you last go out into the garden and turn your nose up at the smell of a rose?
Man made aroma chemicals certainly have a crucial role in perfumery. Indeed, we use them ourselves where appropriate - to replace animal ingredients for example - but they are anything but complex. Where a natural oil may contain hundreds or even thousands of chemical components in a single oil, an aroma chemical will contain just one!
There is no doubt in my mind that perfumes created solely from aroma chemicals will not hold our interest in the way that naturals can and do, and there are whole ranges of odour types that cannot be achieved without using some of the materials on the allergen list. It is not just the major components of natural oils that are significant; it is the hundreds of components that are present in tiny proportions, the trace materials that make natural oils what they are - beautiful, subtle, complex, unique and, yes, interesting. We have been using these natural oils for over 6,000 years now – it would be tragic if we lost them now.
But there is another view you can take. It is possible that the legislation may backfire. There is evidence from other labelling campaigns that over-exposure is a real possibility, to the point where no-one takes any notice of what is written on the pack. After all, writing “Smoking Kills” on cigarette packs does not seem to have had much effect on reducing levels of smoking. Again, we are back into litigation territory and the cynical view is that the warnings are only there to cover the manufacturer’s backsides.
So what conclusions can we draw? If we assume that even though the numbers may be very small, there is a problem with allergens in perfume, will the legislation help? My view is that it won’t. I simply cannot see any tangible benefit in warning the public about everything – I think they will probably ignore it.
As for a solution, I believe that this is more likely to come from the institutions we use now. There already exists an extensive body of genuinely useful information available to perfume compounders (as we are called) from RIFM (Research Institute into Fragrance Materials) and IFRA (International Fragrance Research Association). These organisations publish recommendations for the maximum percentage of known allergens that should be used in a perfume. This is where real benefits are achievable – at the source. At the moment they provide recommendations, not regulations, so following the guidelines is not compulsory, only advisory. Why not make it compulsory?
It seems though that for now the grey suited men in Brussels will have their way and you can expect a list of the dreaded allergens on your perfumes in future. It will get worse too because there is no way that they will stop at 26 – this is just the beginning. More and more materials will be added, so you can expect larger labels too. My only plea is not to be scooped up into the frenzy of Health & Safety, or to worry about these warnings unduly if you are one of those who are not normally affected by allergies. Take a balanced view of the arguments, resist attempts to steer you away from naturals on principle; expect the odd sensation seeking TV program that will emerge to “enlighten you” to the dangers of perfume; and continue to enjoy your fragrances in all their natural beauty.
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