We have been discussing the latest perfumery restrictions on ingredients these past few days. [You can catch up here and here]. Today's post is useful and practical advice before you rush to buy everything tagged "vintage" on Ebay or stores, especially on anything that says it has a "note" of oakmoss (many of them do not have oakmoss to begin with, as a "note" is not an actual ingredient ~meaning the effect of "oakmoss smell" can be replicated aproximately with other ingredients, some synthetic, some natural). To set things straight therefore, let me say the following.
Oakmoss is ~according to the latest restrictions applicable from January 2010~ only resticted, not prohibited. Let me repeat: oakmoss is not being completely eliminated from perfumes! The direction simply states that it needs to be drastically lowered. What that means: it's allowed to 0.1% of the formula compound AND at the same time the oakmoss extact has to contain no more of 100ppm atranol and chloroatranol (those two are the sensitising parts of the natural essence) But oakmoss has been steadily getting lowered in the last 10 years at least! Even if it means perfumes with high levels of it in the formula have to change again, those are the very perfumes which have already changed a lot, sometimes to the point of unecognisability as many fans have noticed! (Miss Dior, Ma Griffe, Cabochard etc.). After all the Scientific Committee on Consumer Products (SCCP) adopted the following during the 2nd plenary meeting of 7 December 2004: "The European Commission received a letter from the University Louis Pasteur, Strasbourg, France, with data demonstrating that chloroatranol is a potent fragrance allergen in cosmetic products. The European Flavour and Fragrance Association (EFFA) submitted a study “Local Lymph Node Assay (LLNA) – Sensitisation dossier on Atranol and Chloroatranol” and information on the levels of these substances in oak moss and tree moss" (the latter is exactly the study on which Dr.Rastogi was featured and please read on to find out more). Therefore this is known since at least 2004! In fact there is a very brief post on this link that announces it (with an email to the proper recipient, so it's not like they couldn't have been contacted!): Department of Environmental Chemistry and Microbiology, National Environmental Research Institute, Roskilde, Denmark. (email@example.com) And another from 2003!
So do you think perfume companies hadn't already wisened up seeing the developments that were impending? Surely not! They were already doing reformulations!
On what concerns Mitsouko in particular Mme Sylvaine Delacourte (artistic director for Guelrain) had the good grace to provide a quote regarding the reformulation of Mitsouko with only tree moss, setting things straight (and I translate):
"Our house has honoured two values for decades: Tradition and Modernity. Tradition denotes the quality of olfactive construction of each of our perfumes with savoir-faire and heritage. Modernity denotes the scrupulous and rigorous respect of the European regulations in the constant concern for our clients. Mitsouko has benefited in 2006 from the most recent olfactory innovations which respect our heritage while at the same time repressing the incomfort tied to certain raw materials. Therefore current Mitsouko responds to the European directives".
Perfumes can theoretically still include oakmoss (evernia prunastri or mousse de chêne) in the formula at the approved levels and I quote from the 43rd amendment of IFRA:
“For this material, for pragmatic reasons, restrictive levels allowed by the QRA for certain categories but actually being higher than those already in place before applying the QRA, will temporarily not be implemented until the end of a 5 year monitoring phase. At the end of the 5 years the position will be reevaluated again. […]Introduction of an additional purity requirement in the Standards on Oak moss extracts and Tree moss extracts.”
The "black" point is that since 2007 IFRA accepts big boys as members and this is the real news: Givaudan, Firmenich, IFF, Takasago etc. can be members who have a say in the regulation of perfumes. The perfumes which they themselves produce. Is it about the concern for consumers' health? It might but most importantly it's about money. How could this happen?
Like Anya McCoy told me:
"Perfumery is being forcibly mutated into a beancounter-driven business with an extremely limited palette. Afraid of lawsuits from consumers if they dare refuse to reformulate classics or create new fragrances with the limits placed upon them, big perfume houses have capitulated. This is a quote from a retired perfumer I interviewed two years ago, the one who blithely answered "we were asleep at the wheel" when I queried why the perfume industry allowed so many regulations to pile up. IFRA, at first golden and shiny with the promise of providing an industry regulatory system that would give the world of perfumery professional and governmental status, botched the deal ~badly!"
"Based on the submission by EFFA1 of a study "Local nymph Node Assay(LLNA)-Sensitisation dossier on Atranol and Chloroatranol", the Scientific Committee on Consumer Products (SCCP) adopted at its 2nd plenary meeting of 7 December 2004 an opinion (SCCP/0847/04) on Atranol and Chloroatranol present in natural extracts (e.g. Oakmoss and Treemoss extract) with the conclusion:“Because chloroatranol and atranol are components of a botanicalextract, oakmoss absolute, it has been impossible to trace exposure. Chloroatranol was shown to cause elicitation of reactions by repeated open exposure at the ppm level (0.0005%) and at the ppb level on patch testing (50% elicit at 0.000015%). As chloroatranol and atranol are such potent allergens(and chloroatranol particularly so), they shouldnot be present in cosmetic products."
"In recognition of the fact that contact allergy to oakmoss/treemoss is important, product ingredient labelling is required. Such labelling, as a secondary measure to prevent disease, is helpful only to that group of the European population who have a recognised contact allergy to oakmoss/treemoss (following diagnostic clinical patch testing). Labelling is not helpful to the group who have unrecognised contact allergy".
Therefore since oakmoss is again to be reviewed in 2013, this means that there is a window frame for companies to conform and for us to think about this and decide with a cooler head than today's panic.
But there is hope for oakmoss notes yet! Although the patented synthetic Evernyl is not a satisfactory substitute, there is another oakmoss synthetic, Orcinyl 3, which if used together with Evernyl could do the trick.(And it’s only $2400/kilo).
Laurie Erickson, an artisanal pefumer from California for the Sonoma Scent Studio line, also told me: “The big difference for oakmoss with the 43rd amendment is that people who want to use natural moss have to switch to a low allergen moss like the Biolandes product with less than 100 ppm of atranol and less than 100 ppm of chloroatranol (the Biolandes is the only currently available natural moss I know of that meets this standard). If you use the low atranol moss below the maximum usage level and perhaps add a smidge of Evernyl/Veramoss and/or your other favorite mossy ingredients, you can create a pretty nice oakmoss note and still be within IFRA standards; I’m just starting to work with the new moss but so far I’m quite optimistic. I do wish they’d make some exceptions for the old classic formulas and I’m very concerned about the direction we’re heading with all these restrictions on so many materials, but I think we can still create moss notes in new perfumes even under the new guidelines if this low atranol moss turns out to be as promising as it seems right now. I’m just going through all my formulas to substitute the low atranol moss for the regular moss that I was using, and I’ll know more as I continue that process. I had been skeptical before sampling this moss because I’ve been disappointed with the low allergen versions of lavender and bergamot I’ve tried (though I hear better bergamot is available now), but I was pleasantly surprised when I sampled this moss and I ended up buying some.”
Ayala Moriel, another artisanal naturals perfumer has interesting commentary:
"As of the end of last year, neither of my oakmoss suppliers were no longer carrying complete oakmoss absolute. The sensitizing elements were removed, as per IFRA's regulations. Which is not surprising, since oakmoss is grown and harvested in the EU (mostly in former Yugoslavia), and most of the perfume industry at large is still concentrated on that continent. To my pleasant surprise, even at this manipulated state, oakmoss still presented the full spectrum of performance it always had, and was just as good as ever for creating chypres, fougeres and adding nuances to florals, orientals and citrus".And she likes the Biolandes oakmoss as well! This is what she stated to me:
"1) IFRA is not scheduled to review oakmoss again until 2013, so I have no reason to believe there will be any changes to the current oakmoss regulations before than
2) I checked with my suppliers and they are not aware that this material is about to become unavailable in the near future
3) Since last year, the oakmoss absolute sold in the market was one with the sensitizing molecules removed, namely atranol and chloroatranol and resin acids. This
is also the reason why combining both oakmoss and tree moss is restricted (tree moss contains resin acids, so if it is used in a formula in a conjunction with oakmoss the concentration of oakmoss will be even lower). "
Alex, a perfumery student who writes J'aime Le Parfum had a lovely quote:
"I do not remember whether it was me or a fellow classmate who asked Jean Claude Ellena several months ago about his feeling about IFRA, and he basically said “I don’t really care, and it does not stop me from doing my work.” I think what he says is key here, and it has to do with creativity. You do not need jasmine to give your fragrance “naturalness” or “richness.” You do not need iso e super to do perfumery. You do not need oakmoss to do perfumery.You do not need majantol* to do perfumery." (*majantol is a synthetic lily of the valley ingredient.)I have personably been in the fortunate position to have smelled the new Biolandes low-atranol oakmoss and compare it to the traditional oakmoss essence and it does seem to perform well, although perhaps not perfectly “photocopied” but a talented perfumer can certainly put it to good use. AlbertCan is also one who has worked with both and corroborates the potential. Technology is on our side if we give it time and who knows what the future holds?
Since reportedly the Chanel Company controls Biolandes, did they just opt for re-creating a chypre with no oakmoss in their 31 Rue Cambon instead of relying on this new low-atranol material? It goes to show how boundaries need to be crossed for something to be created anew or how they cannot be sure on further developments ruining a newly launched product.
The big news is however something else entirely: the raw materials suppliers at Grasse (who mostly dabble in naturals) have been bought out by the big companies! Laboratoires Monique Remy is owned by IFF. Robertet bought Charabot and so on...It figures, doesn't it.
Like Anya Mc Coy says again: "Another wrinkle is the buying up of all the small- to medium- size processing houses, from Charis to Charabot. The pipeline that is in place to bring the extracted aromatics to the perfumer, from the distiller with a field unit in the jungle of Indonesia, to the jasmine plants in Egypt are more and more under the control of corporate conglamorates. If they - the corporations - find it easier and cheaper to use synthetics and the demand for naturals dries up, so will the pipeline. Price fixing, as with vanilla absolute, is firmly in place, in my opinion."
So practical advice: If you need to stock up on favourites from big companies, don't rush to buy whatever has been produced in the last 6-7 years at least. And even then, it's good advice to save up your money for extrait de parfum only, the most concentrated version and therefore the one in which the limitations would pose a greater problem. Do continue to support the artisanal perfumers, now more than ever.
And another suggestion for the perfume industry this time: Have you thought of the vast potential of hair mists and oils?