Tuesday, April 14, 2009

The Strange Case of Dr.Oakmoss and Mr.Citrus (part 1)

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. (scr@dmu.dk) 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.”

And category 11 (encompasses all non-skin contact or incidental skin contact products) is unrestricted! If we solemnly swear to only spray on clothes? This is why Luca finished his article with the wittisism “don't spray on skin”.

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!"

There is a PDF available for download (mail me if you want to read it!): It’s the study that Luca talked about in his article, the one I referenced above and of which Dr Rastogi is one of the paticipants. It opens with:

"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."

The study talks about 2 ppm though and I quote:"The main identified allergens in oakmoss are chloroatranol and atranol. The ‘typical’ levels of these chemicals have been reduced to levels described". And it concludes with the very logical matter which we tried to explain the other day on why a simple warning label doesn't cover the issue and I quote (bold is mine):

"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".

And tree moss which also contains the sensitisers has to be in tandem restricted so that the combined sum of essences does not exceed 0.1% in the formula.
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). "

Roxana Villa of Roxana Illuminated Perfume has assured me that she has created an accord that mimics oakmoss sufficiently, composed of natural materials that are within limitations and if her Q is anything to go by on how her woody, green mossy blends go I am very optimistic! Liz Zorn of Soivohle' Perfumes is also another artisanal independent pefumer who is capable of creating oakmoss accords through the combinations of other ingredients: "It doesn’t take a rocket scientist to figure out how to dupe oakmoss, or even jasmine for that matter. Natural a combination of natural and man made or all man made."

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?

To be continued with other questionable materials...


  1. Hi E!

    It's early and I'm still too sleepy to give your post the attention it deserves. I will, today.

    I appreciate your voice of reason amidst all the howling (some from me, I admit.)

    It has occurred to me that most things are about money; the perfumers who work for the corporations know this is their livelihood. That's why the appear to be passive.

    Great as usual!

  2. Fiordiligi13:41

    Trying to post a reply again - the last one disappeared, as did yesterday's....

    Dear E, thank you for providing such informative material, as always, even though as a professed non-scientist my head now hurts a little!

    There has been such a lot of hysteria lately about the new (and not so new) legislation that it is refreshing to read such a sensible and balanced evaluation, though perhaps it is easy for me to say this given that I have enough vintage Guerlain to last several lifetimes.

  3. Independent perfumers like myself will not have to follow the regs, that seems to be lost in the fury, but still --- the big companies are capitulating, ruining the classic perfumes.

    They have the big pockets that the lawsuit-happy public loves, and no backbone to fight IFRA.

    Still - the biggest problem may be, as I noted, the disappearance of small growers/distillers. That is why I am trying to rally people to somehow set up a worldwide network to identify and work to support these people. If the demand for naturals goes down, they'll stop growing and processing our raw materials.

    What history will say about this dark period of overreaction and shortsightedness!

  4. To add: I started a group on Facebook that addresses both issues: http://www.facebook.com/home.php#/group.php?gid=65087962875

  5. Hi, E. Thanks for posting these thoughtful comments. I'd be curious to read the pdf of the study (which, by the way, has an amusing typo above:

    "Local nymph Node Assay(LLNA)-Sensitisation dossier on Atranol and Chloroatranol",

    I'm assuming that's "local LYMPH node assay." *Imagines the messy job of capturing nymphs and satyrs, and assaying them for fragrance sensitization*.

  6. Hey Helg!

    Lovely article as usual! You have given me a lot of new info so I'll have to re-read it a couple more times to get all the facts straight. But here's what I know:

    1. As you know I have a batch of IFRA complient oakmoss and it seems like a good representation of the traditional oakmoss. I haven't tried the Biolande oakmoss so I can't vouch for its authenticity (I think Octavian agrees with you however).

    And as you know established houses like Chanel, Hermes, Guerlain, Patou can always ask LMR for special commissions of natural ingredients that are chemically tailored to their needs. I've been enlightened on a few but obviously it's none of my beeswax at the end of the day :-)

    2. As for Chanel 31 rue Cambon...while I obviously can't pick Polge's head, the official story is that oakmoss isn't used because the nose of Chanel doesn't like the smell of oakmoss (it's mentioned in that WWD article when Les Exclusifs first came out I think).

    3. The advice on stocking up on extrait de parfum is a good one, especially since some houses have different formulations for each editions and natural oakmoss is most likely used in the parfum.

    4. As for hair mist I think it is an interesting idea. It is as you know offered in the Coco Mademoiselle line.


  7. Hi E,

    Didn't realize that the Big Six only became IFRA members in 2007, since it's not on their website. So before that it was just the trade associations? Who represented, among others, those companies in Grasse that just got swallowed up? The plot thickens.

    This all reminds me of the mergers and acquisitions in the American tobacco industry after tort lawsuits threatened to seriously erode profit margins. Cigarette manufacturers had to band together for the purposes of legal representation, and then, all of a sudden, what do you know, there were only five companies left. In that instance, they were reacting to an extremely serious public health crisis; in this instance, it's more a preventive measure against a much less serious potential public health issue. But, in any case, it's quite an opportunity for those companies that have the deepest pockets and the best lawyers.

    Allergic reactions? Sensitization? I have no doubt that the environmental scientists who are testing all these raw materials are deeply passionate about these subjects. Gotta wonder, though, whether any of the other players in this drama really care about those matters at all. To me, they seem more and more like means to an end.

  8. Charlotte Vale, you make some really good points. And thanks E for pointing out the Grasse issue, the plot truly thickens. I think you are right when you say...

    "Do continue to support the artisanal perfumers, now more than ever." And I would add to that, especially those who use naturals, it seems like the big guns want to get rid of them so we need to support those indie perfumers who continue to support the suppliers of those beautiful essences.


  9. Hello P!

    Thanks for saying so and hope it puts some balance to everyone's "now what?" aporia.
    I would never descibe your voice as "howling" though, as you always seem to bring interesting points!
    And yes, too much passivity indicates either a throwing of the towel or some assurance that the job will go on regardless (and how much better than raising a storm and getting sacked, huh?)
    Ah well...

  10. D,

    I am so sorry honey the comment disappered! Is Blogger acting up again? Hopefully it won't do it again.

    It's true that sometimes I get a bit carried away in the thoroughness I aspire to and write looooong, boring posts full of data and not go for the snarky or the humorous side. I apologise to all my readers I tired, I guess you could get the girl out of academia, but you can't get the academia out of the girl. LOL!

    Anyway, thinking out loud now and indeed, I have some vintage juice tucked too, for a rainy day, so why am I saying all these things? But still, if at least one person thinks before making the leap on an overpriced bottle claiming "vintage" (when in fact is made in 2002 for instance) then my efforts weren't totally wasted.

  11. A,

    the point on the suppliers you raised is the most crucial. Because where there's a will there's a way, but how could artisanal people make those revolutionary products without the proper building blocks? It's worth pondering on.

    The closing up of the little guys is always a sad, bitter tale...

  12. Oh and best wishes for the Facebook group. (if I weren't that inept and negative with all those social things, I might join)

  13. J,

    of course I will be mailing the study to you shortly. It's quite interesting and not too difficult to follow really. It exhibits how the experiments were performed on rats and then on humans as well (which is a great bit of another clue, no?)
    But try as I might I didn't find a typo with Nymph. (I do make a lot though, rushed as I am usually). But what a witty observation you made! That would be trully hilarious indeed! *chuckles imagining*

  14. A,

    thanks so much! You do bring great points always, I do appreciate it.

    1.I think your batch comes from indirect supplying from Biolandes (no one less produces the low atranol oakmoss to my knowledge ~they buy from Biolandes).
    Indeed specially tailored ingredients are not unheard of (Jean Claude Ellena does this for a fact for Hermes) and it seems like it's very...en vogue! ;-)

    2.I vaguely recall this being discussed someplace in the past. I do wonder about Cristalle EDP though; very mossy!

    3.Oh yes. No need to go overboard hoarding questionable things (and this goes for jasmine as well, but more on that later)

    4.Yup, indeed there is. As there is in Allure, in Angel, in many frags. In fact that's not even a new concept. Many of the vintage Helena Rubinstein perfumes were available as hair brilliantines!

  15. A,

    as you say, the plot thickens. I do hear cetain things and report my deductions, although of course I don't know everything but some things seem to corroborate others.
    I was that close to mentioning Jeffrey Wingang the other day, but I refrained as it might be unfair.
    But your point is well taken and I do see the similarities myself (in fact coumarin is very much an ingredient that was both in cigs and frags, so there is the 6 degrees of Kevin Bacon for you!)

    And yes, I am sure that to the scientists involved it's fascinating job. How any discovery is used is left to more practical men than scientists. Like that hydrogen desctructive thing....

  16. T,

    thanks and I am glad we have thinking people in our ranks who can put two and two together and reason. Issues are never one-sided nor simplistic and as long as we try to get as much info as possible, it's all for the best.

  17. Hello again E --

    Thanks for the kind words.

    I forgot to ask for a copy of the study, could you send me one? Thanks!

  18. Sure thing! Sending it to you!

  19. Hi, E. Thanks for sending the paper. I see from the Introduction that the typo I mentioned is in the original paper:

    Based on the submission by EFFA1 of a study "Local nymph Node Assay (LLNA)- Sensitisation dossier on Atranol and Chloroatranol" (emphasis added)That should of course be "local lymph node assay (LLNA)."

    The LLNA is a methodology for animal testing of the potential of compounds to elicit contact hypersensitivity. Mice are treated with a test compound on the ears for for several days, and then hypersensitivity is assessed by injecting radio-labeled thymidine into a tail vein and measuring thymidine incorporated into lymph node cells draining the ears. (This does, by the way, involve killing the mice and harvesting their lymph nodes). The LLNA is typically used to develop a dose-response curve to narrow down the range of concentrations for subsequent human testing using the Human Repeated Insult Patch Test (HRIPT) (which of course doesn't involve killing the subjects and harvesting their lymph nodes).

  20. Ah...I was looking at my own typing in the first paragraph and you meant the quote coming directly off the study. NOW I see! Thanks!

    Yes, that's what I surmissed from the paper as well: mice ears' being scrutinized and then humans subjected to patch tests. (and yes the killing is actually mentioned in the study itself, I was feeling rather sorry for the poor things by that point!)

  21. Helg,

    You raised a good point about Cristalle EdP. In that case (and Chanel No. 5 EdP for that matter) the house has a tradition to encourage the current nose to respect the heritage as much as possible. It's only when a nose is doing semi-flankers will there be a more drastic change (witness the current Eau Premiere and Eau Verte). Oh yeah, don't quote me but I bet an "Eau" semi-flanker for No. 19 is the logical next step :-)


  22. A,

    thanks for chimming in and sorry I saw this late. Definitely your logic sounds perfectly reasonable and yes, an Eau for no.19 seems plausible: however I wonder how that might be since CEV is already a "green eau" in there and there are at least a couple of orris scents in the stable.

  23. Anonymous11:11

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