The Latest Developments on IFRA and EU Perfume Regulations: Inside Job or Not?

"The idea that IFRA is an inside job to kill the natural raw material side of the fragrance industry may seem like an attractive conspiracy theory at first, but upon even cursory examination, this idea falls apart.
Natural fragrance materials represent a sizeable chunk of the fragrance and flavour industry’s profits (and this includes the main IFRA members). Creating new aroma chemicals is extremely costly, a big risk, and burdened with its own regulatory pressures. Never mind the all too real possibility that an aroma chemical you have brought to market gets restricted or even banned by IFRA in the future if it is found to be problematic by their standards.
If IFRA were an inside job, this sort of thing would never happen."

via

The low down on the European Union and IFRA regulations on fragrance and potential allergens as of this very minute is on Basenotes, as written by the knowledgable Pia Long. Please take a look if you haven't by now.

I have personally preached (forgive the emphatic word, I do consider myself an educator and an eternal student first and foremost) the complexities of the matter and the simplistic context of "just follow the money". It's more than that. You can find some of my old articles when the furore online first started under the Restrictions tab.

But perfume is considered such a frivolity by so many people that the greater issues that the industry itself experiences seldom get the limelight. It's high time that we sat down, ignored getting our panties in a wad for once and gave it some balanced attention.

Regulatory Developments in the Front of Perfumery Restrictions & IFRA: Doom or Boom?

The front of perfumery restrictions on raw materials is a potential minefield for both the perfume lover and the conscientious journalist, as chronicling all steps of the way can so easily be tinged with either scientific falsities, emotional panic or a sensationalist approach meant to benefit only the one doing the sensational shout out. But beyond that, little had been done to pay it forward and actually do something about it. Up until now. A group of dedicated perfume lovers contributing to the respected Parfumo.net platform where they gather to discuss their favorite hobby has come up with an official petition to address to the decision makers in Brussels so as to stop the paranoia and reconsider some options beyond banning this or that on the basis of its potential allergenic or rather sensitizing effect on 1% of the population. One of the arguments that is presented (and it's one taking into consideration) is that because of that small potential irritation the whole of humanity will be left with no cultural imprint of the perfumery of the last 130 years or so. Preserving perfume's identity is a cultural (as in "patrimonial heritage" for many European countries and industries) and on a higher plane also a political issue (cosmetics & perfumes are the third largest exporter of the French industry), not merely a social or health-focused one.

You can find the petition Save Perfume's Soul on this link (in English) and you're encouraged to join us into spreading the word about options for a better solution to the problem of reactive ingredients in perfumes for sensitive individuals, such as extensive obligatory labeling.

And if you think that this is merely unicorn hunting and only a plea of hardcore aficionados, you will be psyched to hear that at the instigation of the French Federation of Beauty Companies the French and European cosmetics industry was concerned enough with the regulatory changes that could compromise their field that on April 7th they held a round table discussion about the Scientific Committee on Consumer Safety guidelines with many interesting results, so read on and take courage.

According to reportage by the Luxury Society: "Michèle Elbaz, Delegate Director Regulation and Safety at Chanel, has reviewed the perfume substances whose legal status is under review whether in application of the Cosmetics Regulation or in application of REACH.

Some of these substances correspond to series for which the European Commission questioned the Scientific Committee [2] some years ago and which are still under discussion, waiting for regulatory measures (Tagetes minuta, patula; Methyl -N -methyl anthranilate; Vetiveryl acetate; Acetaldehyde).

Some substances also fall under the scope of Article 15 of the Regulation on cosmetic products, which prohibits the use of CMR substances classified in category 1A (known CMR effect on humans), 1B (Suspected CMR effect on humans) or 2 (suspected CMR effect, but the available information is insufficient).

Furthermore, some substances are also impacted by some additional REACH procedures besides registration, namely Substance Evaluation and Harmonized Classification and Labelling. This is the case, for example, of BMHCA, Furfuryl alcohol, Citral and Citronellal. “However, this does not necessarily mean that these substances are about to be prohibited or restricted,” said Michèle Elbaz. Indeed, the deadline of their assessment may be delayed, depending on priorities, or they may be removed from the list if their REACH dossier has been fulfilled."

Furthermore, public consultation has been requested on the issue of perfume allergens by the European Commission who has published its proposed measures and is awaiting feedback from the concerned parties (manufacturers of cosmetics products, producers of fragrances and consumers associations)  till May 14th. This is a complex issue with the International Fragrance Association informing and influencing the Commission's proposal. Therefore as Vincent Gallon states, "Taking the consultations into account, the proposed changes to the Cosmetics Regulation in the form of an implementing act will be subject to a vote by the Member States in the standing Committee on Cosmetics. Once the measures are approved by the Member States, the European Parliament and the Council will have three months to exercise their right of scrutiny. If the proposal is not opposed the formal adoption of those changes is expected at the end of 2014/beginning 2015."

According to Luxury Society, Cosmetics Europe is proposing "a series of solutions which, while being very pragmatic, will ensure that consumers be properly informed,”  as per Florian Schellauf.
In particular, "Cosmetics Europe suggests that companies may choose to label the list of allergens on the package or to provide this information electronically. A logo (left) could inform concerned consumers that the information they need is available online.
“The general revolution of providing information in electronic format has progressed in such a manner that a majority of consumers today prefer this way of receiving information. Accessing information electronically has become a fact of life and an integral part of society”, said Florian Schellauf.

Cosmetics Europe also supports a change in the INCI nomenclature, in order to allow abbreviations. The European Association also requested a transition period of at least 6 years for products already placed on the market.

An Insidious Thought on IFRA Restrictions

Much discussion is being conducted again in perfume loving circles over IFRA restrictions which will surely change things as we know them, should they pass through and become EU directive (Currently they're not one and the same, please note). The alert bell chimed on February 13th, as published in several French papers (You can see one of them here).

There are lots of ingredients on the chopping block, some already rationed heavily, some introduced recently. The list contains many naturals, but (here's the catch) it also includes many synthetics, i.e. man produced aromachemicals. This seems to blow a bit the argument that it's all a ploy to make naturals die and only champion aromachemicals. {IFRA lists the bulk of perfumery ingredients on this link].
It is however dire for many perfumes as we know them and indeed I had written so a year ago myself.

The reigning reception so far is that an expanded labeling system will be put into action anyway. The United Nations have proposed as counter argument that lots of of regional producers will be thus left out of business and out of work, cutting down on significant national revenue in some cases, a good argument that seems convincing to Brussels, certainly more convincing that perfume is a product of the intellect (especially since High Court decided against intellectual properties of the perfumes' formulae in the all too recent past in cases of "dupes").

So here's an insidious thought for you: could the mad panicking and hoarding of recent stock might eventually only benefit the grey market and the companies who will unload all their leftover stock that was sitting unclaimed? ;)

As always this page advises the use of caution and common sense.

Perfume-Makers Fear EU Legal Blow to the Industry Due to New Restrictions

"(These ingredients are) the spine of about 90 percent of fine fragrances," said Pierre Sivac, Chairman of the International Fragrance Association (IFRA), whose members include America's International Flavors & Fragrances and Switzerland's Givaudan. [source thanks to T.Sanchez]

Perfume-makers fear EU legal blow to the industry and the fear of restrictions is increasing:“All citizens are entitled to the same protection,” SCCS Working Group chairman Ian White, said. It recommended restricting the concentration of 12 substances – including citral, found in lemon and tangerine oils; coumarin, found in tropical tonka beans; and eugenol, found in rose oil – to 0.01 per cent of the finished product. And it proposed an outright ban on tree moss and oak moss, which provides distinctive woody base notes in Chanel’s No.5 and Dior’s Miss Dior."

“It is essential to preserve Europe’s olfactory cultural heritage,” LVMH said in an e-mailed statement, stressing nonetheless the well-being of consumers was a “major concern”.

What's more important is this: Any new laws curtailing the use of natural scents would also impact fragrance-producers such as Givaudan and Firmenich as well as Germany’s Symrise, Japan’s Takasago and Robertet in France’s scents-producing town of Grasse. Basically all the bulk buyers of raw materials, making the growers and developers of the banned essences obsolete and irrelevant in the market game.

Industry sources say they expected regulatory proposals by January 2014. However, the Commission declined to comment on a time frame for possible legislation. Trade associations including IFRA and Cosmetics Europe, whose members are perfume and cosmetics companies such as LVMH, are aiming to submit a joint industry proposal to the Commission by the end of 2012.

Of course it needs to be pointed out that the classic Miss Dior is nowhere to be found (at least on the mainstream circuit, it's still visible on the official site under Miss Dior L'Originale tag) in favor of the re-named Miss Dior Cherie (which circulates as simply Miss Dior now, so a marketing decision sounded the death knoll rather than the formula itself) and Chanel No.5 has been changed as well through the years.

Robert Piguet's Bandit to be Reformulated (Again)

The Robert Piguet company is compelled to revise the formulation of one of their beloved classics by perfumer Germaine Cellier, the bracing ‘Bandit’ perfume due to compliance with the latest regulations on allergens/irritants in the fragrance industry.

                                           

According to Basenotes: The current formulation was praised by Luca Turin and Tanya Sanchez in their perfume guide, but with changing regulation the company says it needs to address the issue: “The IFRA regulations on oakmoss make things so difficult for that perfume” says [Joe] Garces [CEO of Fashion Fragrances & Cosmetics] “If you keep changing and keep tweaking things you could end up with a different thing. I don’t want to spoil it so I’ve asked [perfumer] Aurelian [Guichard] to look at the whole thing again, to go back to the very original formula and take it from there.”

 Given Guichard's delicate impressionist hand as opposed to the brutal fauvism of Cellier, could this pose a risk on effacing the sharp character of Bandit? Remains to be seen. Let's be hopeful and hope that we can sample for ourselves soon.

Related reading on Perfume Shrine: Bandit by Robert Piguet perfume review & history, Robert Piguet news & reviews

IFRA 46th Amendment is Out

The International Fragrance Association (IFRA) has officially issued the 46^th Amendment to the IFRA Code of Practice as part of the industry's ongoing safety program*.
There are six new restrictive Standards based on the Quantitative Risk Assessment (QRA)** and one new Standard prohibiting the use of 2,4-Octadienal.
IFRA has also withdrawn the Standard for Vanillin, which was first put in place with the 44^th Amendment. This Standard was put on hold on 1^st December, 2009, has now been officially withdrawn. Following the Vanillin Standard's notification additional information was submitted, which allowed for a re-evaluation of the material. After further additional testing and a critical evaluation of all available data today, IFRA has decided to withdraw the Standard and not set a revised Standard.
IFRA has also updated various guidance documents as part of the 46^th Amendment.

• QRA Information Booklet Version 6.0 Final 2011 (including guidance on classes for IFRA Certificates)
• Annex 1 to the IFRA Standards which has been updated with contributions from other sources for o-Methoxycinnamaldehyde and Safranal
• Index (list of all IFRA Standards)
• Standard Operating Procedures (SOP) for the implementation of IFRA Standards

All the new Standards and related guidance documents are freely available on the IFRA website: http://www.ifraorg.org
1.    Six new Standards, based on the QRA

CAS             Name                                      Status
                                                            
    7492-44-6     alpha-Butylcinnamaldehyde                   
    39189-74-7    2-Heptylidene cyclopentan-1-one                  NEW
    1504-74-1     o-Methoxycinnamaldehyde                       RESTRICTED
    68922-13-4    3-Methyl-2-(pentyloxy)cyclopent-2-en-1-one      (QRA)
    13257-44-8    2-Nonyn-1-al dimethyl acetal
    13144-88-2    1-(2,4,4,5,5-Pentamethyl-1-cyclopenten-1-yl)
                  ethan-1-one

2.    One new Standard prohibiting the use of 2,4-Octadienal

2,4-Octadienal has been reviewed by the RIFM Expert Panel and, due to lack of adequate data (Dermal DNA Adduct study), it was concluded that it should not be used as or in fragrance ingredients in whatever application until additional data is available and considered sufficient to support its use. The presence of a structural alert as defined in the Human Health Criteria Document justifies this ban which already concerns several materials of the same structural family.

CAS           Name                     Status

    30361-28-5    2,4-Octadienal            PROHIBITED

How the whole thing works, for those who missed our previous posts on the subject of perfumery ingredients restrictions:
The fragrance industry's safety program is founded on testing fragrance materials and either establishing 'Safe Use Levels', or prohibiting their use, based on studying their potential effects on people and the environment. Currently the safety program contains 186 'Standards', which restrict, or prohibit, the use of selected fragrance materials.
To ensure that the fragrance industry adheres to its safety standards the International Fragrance
Association (IFRA) has a Compliance Program. Every year 50 products from a selection of 450, gathered from stores in 10 different countries, are tested. If a product does not comply with its Code of Practice and Standards, IFRA works with the manufacturer to ensure compliance.
The IFRA Code of Practice is a comprehensive document that supports the IFRA commitment to provide products that are safe for use by the consumer and to the environment.
The Code of Practice applies to the manufacture and handling of all fragrance materials, for all types of applications and contains the full set of IFRA Standards. Abiding by the IFRA Code of Practice is a prerequisite for all fragrance supplier companies that are members of IFRA (either directly or through national associations). The majority of client companies (including producers of toiletries and household products) expect their fragrances to comply with IFRA Standards as set out in the Code.
The IFRA Code of Practice is distributed worldwide and is in the hands of all member associations and their member companies, in addition to governmental regulatory bodies and many other stakeholders. It is also available to all on our website: http://www.ifraorg.org

**Quantitative Risk Assessment (QRA)

In 2005 IFRA introduced a new Quantitative Risk Assessment or QRA approach to restrict fragrance materials that have a potential to induce contact sensitization. This new approach is a much more refined approach for evaluating sensitizing materials, and so provides more precise guidance on use levels of materials depending on the situation and the product in which they are used; ultimately it should better protect the consumer from becoming sensitized to a specific material.

SOURCE: The International Fragrance Association (IFRA), Brussels 27th June 2011

National Toxic Encephalopathy Foundation respond to IFRA opposition

The National Toxic Encephalopathy Foundation (NTEF), at the request of the Nevada Assemblyman who introduced the bill, AB234, has provided the science and legalities regarding the bill.

The fragrance industry is grasping at straws, over the Nevada Bill that addresses indoor barriers under the Americans for Disability Act. (ADA).
The bill entitled "Revises provisions governing places of public Accommodation", expands upon an existing state statute regarding accessibility for disabled residents.
The intent of the bill is to remove all air fresheners, air scented branding, fragrance, candles, etc., to comply with both state and federal laws regarding the ADA. Industry's standard response to any type of impediment to remove fragrance is by referencing Multiple Chemical Sensitivity, which is acknowledged on a case by case basis by various government agencies. The bill is for the protection of those with clearly defined and fully covered disabilities relating to the brain, neurological and respiratory systems. IFRA-NA's letter just muddled through with nothing to prove that their products are indeed not barriers, under the ADA.
The NTEF's response cited numerous independent peer-reviewed studies and government agencies, referencing that these have negative effects, even when used as directed.

The fragrance and air freshening industries, would like the public to think they are safe and fully researched. When in fact they are not required by law to test or list all the ingredients. The public needs to realize that the number of people with hidden/non perceivable disabilities outnumber the more readily identifiable ones.
No disability should ever be denied access to public accommodations.

The full response can be read at NTEF-USA.Org.

National Toxic Encephalopathy Foundation is a 501(c)(3) , non-profit organization
whose core purposes are to provide research, education and services to the growing segment of the population who are adversely affected by everyday chemicals and toxins in our environment. Established in 1998

info via press release

The IFRA 45th Amendment: Not What You Expected

The sensationalist titles and the panic woes across the Net about perfume reformulation due to perfumery restrictions issued by regulatory body IFRA (International Fragrance Association) bring on more traffic, furore and fame to the authors than positive results for the industry and the consumer, but that's an old story. True to form and confirming our previous balanced and rational treatment of the subject, the latest amendement of IFRA regulations comes with only 7 changes which will not impact the industry as significantly as claimed.

Critically, the rumours on new policies regulating methyleugenol and fyrocoumarins are not verified by the official source.
“This year’s Amendment will hardly affect the palettes of perfumers,” said Jean-Pierre Houri, IFRA director general. “Previous years have seen quite heavy Amendments due to the change over to our new Quantitative Risk Assessment (QRA)* approach. However, this is nearly complete and is reflected in this year’s very light Amendment,” explained Houri as featured on Perfumer & Flavorist.

In regards to whether all companies are bound by the policies of IFRA, let us state that the regulatory restrictions are mandatory for the companies who are members of IFRA (IFRA began as a self-regulatory body and the vast majority of perfume companies are adherening therefore to its rules)

*Quantative Risk Assesment is a process through which fragrance materials suspect for skin contact sensitisation are rationed and was introduced in 2005.

You can read the whole text of the IFRA 45th Amendment announcement follow this link.
Please refer to this link for ingredients restricted and that link for ingredients prohibited.

Related reading on Perfume Shrine: Restrictions part 1, Restrictions part 2

Perfumers have the European Commision Irritating the Hell out of Them

Thus is -more or less*- titled the article by Nicole Vulser entitled: "Les créateurs de parfums ont la Commission européenne dans le nez" on Le Monde, which I was alerted to by erstwhile perfumer (and combatant) Sandrine Videault.
In it the matter of IFRA restrictions is rehashed with the emphasis on perfumers who are almost at the brink of a revolution (their words) because of them. IFRA, the International Fragrance Association, as you probably know if you've been following this blog, is a self-regulatory body which every June publishes a list of ingredients that have been deemed by a panel of doctors, allergiologists, specialists on envionmental matters and assorted experts as worthy of banning, restricting or heavily rationing. Based on these findings published the European Comission decides on what laws to implement for the cosmetics and perfume industry. To clarify matters on what this body is exactly I'm quoting: "The European Commission acts as an executive of the European Union. The body is responsible for proposing legislation, implementing decisions, upholding the Union's treaties and the general day-to-day running of the Union. The Commission operates as a cabinet government, with 27 Commissioners. There is one Commissioner per member state, though Commissioners are bound to represent the interests of the EU as a whole rather than their home state. [...] The Commissioners and their immediate teams are based in the Berlaymont building of Brussels". Furthermore, there is the RIFM [Research Institute for Fragrance Materials] annual report which provides info and supplements. The interesting part is all major companies are part of RIFM and IFRA, as well as every aromachemical company (and therefore their subsidiaries and bought-out smaller aroma-producing firms from Grasse etc.)
This is no laughing matter, as it proves the matter is much more complex than the much brandied about opinion that it's all about money, substituting expensive naturals for synthetic substitutes. Several synthetic substitutes are also heavily rationed, you see, and the conglomerates also control companies who are living and breathing in naturals!

Several perfumery ingredients have been banned over the years: The animalics (castoreum, real deer musk and civet) certainly have for long. (Any niche perfumer using covertly using them must be relying on old stock bought at previous decades). Heavily restricted is oakmoss (see two articles on this), Peru balsam, coumarin derivatives, fig leaf absolute and benzyl alcohol (a very common ingredient in several perfumes, classic and modern). Also rationed are geranium essence, jasmine (to extreme limits under the upcoming IFRA 44th Amendment), lavender (gosh, lavender, the 1st aromatherapy oil proposed to just about any novice), cade oil (used to render natural leather notes) and the extract from tea leaves.

That leaves the majority of classic fragrances already mutilated, which brings us to the frantic hunting of vintage specimens as long as the reserves hold. But what will happen next? When these dry up will it mean that several of the perfumes with which generations grew up will have no possible footprint in history? This is a sad and foreboding proposition, much like thinking that Galleria Uffici is vacated in lieu of posters depicting the images that were once "real". The matter is complex, as François Demachy points out that "some perfumes were developed because there were no penalised constraints". More or less it meant that perfumers were mapping territories and were free to roam however they pleased on the world of naturals and synthetics. Guerlain's Thierry Wasser laments: "Among the perfumes we sell, the oldest is over 150 years old. If some day Brussels opposes the essence of rose, what am I to do? There is rose in almost all our perfumes… It is a heritage we need to defend" adding "Jean-Paul Guerlain composed Parure for his mother. We were obliged to discontinue it because we could no longer use the ingredients necessary to produce it. It’s heart-breaking.” The French are certainly very proud of their patrimonie olfactive (olfactory heritage) and that factor might come into play if some "preservation project" gets whipped up for the safe-keeping of historical perfumes. L'Osmotheque is a perfume museum but maybe something on a larger scale with other attributes that would allow more people of different walks of life to be able to partake in this rich tradition. Maybe have some recreations of historical fragrances on display (but not sale, since they won't meet with the criteria)? Maybe devote a line of recreated perfumes in some form that doesn't come in contact with skin or gets pulverised into air? I don't how this could be implemented, I'm just thinking aloud.

The matter of restrictions poses threats to modern perfumes as well (and not only those manufactured within the European Union, because very often the licenses and the sales directive involves Europe too, the most sophisticated luxury-consuming market of them all). Sylvie Polette, the marketing vice-president of Parfums Jean-Paul Gaultier, says: “Brussels will be killing off part of the profession: We aren’t able to rebuild everything in the same manner. This will instigate research, but it translates as a real constraint.” Frédéric Appaire, international marketing manager of Paco Rabanne states: "Our palette is diminishing. This is comparable to telling a painter he’s not allowed to use red, then blue or yellow".

Luckily for us these two prominent perfumers, under the aegis of LVMH no less who oversees classic fragrance houses, Thierry Wasser, in-house perfumer of Guerlain, and François Demachy, overseesing perfumer at Parfums Dior, are quoted in what is essentially a serious reference French newspaper, Le Monde. This means something, as it was often referenced that the industry "had been caught sleeping on the wheel" when these regulatory bodies were first founded, as per the words of a renowned perfumer.
It is also perhaps of some significance that there is a strong rumour that Tony Blair, former Prime Minister of the UK, after having quit M6, will be counseling for the giant LVMH luxury house in 2010 with a monetary recompensation that will run "into the six figures" (according to British Telegraph magazine and reported across the media). His aim will be to open the luxury brands into new markets, which basically means Asia (and possibly South America), come to think of it. Blair is already a JP Morgan consultant for Chase and Zurich Financial. The move ~if to be materialized, as it is neither confirmed nor denied for now~ recalls the announcement of Claude Chirac in the direction of PPR and the more recent one of the return of Patrick Ouart, counselor to Nicolas Sarkozy, as right-hand to Bernard Arnault at LVMH.

Whatever the case might be, there is some commotion happening across the luxury industry (LVMH in particular) which might be translateable into changes that might be beneficient to us, the consumers. On the other hand, if there has been speaking up, it most certainly has been with the proviso that every single quote has been carefully monitored by headquarters, as is the usual practice. Which might defeat the purpose, indicating part of a strategy. Let's wait it out and see.

For a complete list of IFRA restricted materials click this IFRA link. And here are the materials in use as of 31 Dec.2009.

For French-reading readers, here is the Le Monde article, in its entirety.

*The idiomatic phrase, which is very a propos in French (as "nez" means nose and also perfumer) indicates a major annoyance.

pics of Belayrmont building via wikimedia commons, Ed.Munch painting The Shout via last.fm.

The Strange Case of Dr.Oakmoss and Mr.Citrus (part 2)

We talked about the latest restrictions and how oakmoss is one complicated issue and tried to disentangle it a bit in Part 1. But there are more resticted ingredients, whose pros and cons we hope to analyse here. Yet revelations happen with the sudden “swoosh” of pyrotechnics.

The very perceptive Pat from Olfactarama sent me this most eye-opening comment:

“I poked around a little and came up with the RIFM's [Research Institute for Fragrance Materials] annual report. You may already have seen this document, but if not, there is a lot of interesting info here. I'm wondering if this organization isn't one of the ways the labs are funneling research funding into these studies, which may then be used to strongarm the fragrance industry. Since annual reports must be available to the public, it's possible to bypass the "members only" logjam at the site's opening -- I believe some of the publications papers are also available for reading. The list near the back gives RIFM's "partners," and most of the big fragrance manufacturers (Chanel, Estee Lauder, et. al.) are on it. Here is the link: RIFM.Org

I urge you to click the link (it's NOT the well known IFRA amendement, it's a different organisation) and read the participating members on the last page; blink a little and read again!

Chanel….The one company who profited by the downfall of Guerlain to the eyes of many perfume enthusiasts. The one company who salvaged their reputation through the hardships of having to appeal to mainsteam tastes and all with easy elegance. Now, there is proof that they do not oppose the restrictions which are set to harm them most: the jasmine restrictions (as well as the coumarin, ylang ylang, eugenol, oakmoss et al). Octavian had succintcly put it:

“Remember that not only the perfume extract contains a great amount of French jasmine but also this is at the heart of all marketing stories of Chanel. Chanel always insisted on the quality of its jasmine, being one of the very few to use the French type, also cultivated by Chanel” and from a marketing point of view, how can you communicate about jasmine now? Can you show the fields, the extraction and write articles about No5 history and quality when IFRA tells that "jasminum grandiflorum" is "poison"?

It’s a problem. The continuation of the myth will necessarily have to be a covert lie.

However Chanel in either an attempt to salvage what they can (how? I’d advise the Wertheimer brothers to make a statement to that) or to retain their market share without increasing prices are condoning the reformulations. I do know that they are rigorous in preserving quality and just as there are different grades of foodstuff so there are in perfumery ingredients, so they will use the best available. But still the question is: what will there be available?

And Lauder is also a member of RIFM. This makes the futile hope of people in the US that American made perfumes might retain their formula unchanged just that…futile. It was plainly to see before, since Lauder fragrances are made by IFF (who belongs to IFRA), but since not all people know that tidbit, it’s worth mentioning now.

On what concerns citrus restrictions, the kerfuffle is too much for no special reason in most cases. Many people exclaim –justifiably-: “Ridiculous! I get more orange essence on my hands by peeling an orange or on my mouth by eating it than by using perfume!”. True, but there’s a catch: Most citruses in perfumes are synthetic already! Yes, yes, even those you think are naturals. Yes, yes, even some very respected brands (Shalimar anyone? Mitsouko?) . And you know, the difference isn't that perceptible to the majority of even discerning noses and bergamot in particular has been substituted for years due to its photosensitizing begaptene. Which is why I witnessed the groves in Sicily and Calabria being a waning craft...
Yet some citrus essences can be realistically replicated. Want proof? Go smell In Love Again by Yves Saint Laurent. Great realistic grapefruit note, huh? 100% synthetic. But that doesn't diminish the artistry of it, nor should it deter you from using it.

Of course there are several niche and small perfumers (notably the all-naturals field) who continue to use natural extracts and they'e taking a hard blow with the latest; this might make them outlaw indeed! Anya McCoy said:

"There are few willing to take a stance on this. I will. I will continue to use all of the aromatics I wish, with a warning label. If, as it seems it will, the regulations come to the USA, and the FDA enforces them, I will protest and am willing to become a legal case, if necessary. I dare others to join me. That is my solution to the oakmoss, orange, rose, ylang ylang (ad infinitum materials) problem."

Of course that means solely Internet sales... No brand which hopes to have their scents in brick and mortar stores can afford this, since they are subject to import laws (from either the EU or the US).

Brands which use a high degree of natural extracts, citrus and otherwise, such as Annick Goutal, Miller Harris, and Ormonde Jayne are facing a very real problem, hitting them like a ton of bricks. Their buying of raw materials will be seriously challenged thanks to the tale-over of the Grasse companies of raw materials (as discussed here) and due to their drastic change in the formula they will have a hard time adjusting to the changes. You might stock up on those as well. In fact a MUA poster, Alabasterkitten, has noticed a bunch of them at Loehmann's last night, $50 for 1.7 oz - Songes (jasmine, ylang ylang), Mandragore (bergamot), Eau de Hadrien (lemon and citruses, oakmoss), Petite Cherie (pear synth), Gardenia Passion (oakmoss, jasmine) and Nuits d'Hadrien (citrus)!

As to other ingredients, there are many but there are ways around them without much compromise. Verbena has been singled out in online discussions, because it's a common aromatherapeutic infusion and oil and it created the question how it could be regarded as a "bad" thing. Well, litsea cubeba has a bracing lemony note that could sufficiently substitute it and in fact it extends the effect nicely into the middle notes, a trick often used by pefumers to extend tangy aspects. So, no problem there.

Hydroxycitronellal (lily of the valley) is on the chopping block, as is majantol. Obviously lily of the valley will suffer as a note, not mentioning Lilial (by Givaudan) and Lyral (by IFF), which have also been examined regarding their sensitizing properties. Lily of the valley is a more common note than one would suspect, because it both opens up the bouquet of classic perfumes and it imparts a collateral “clean” note to modern ones (perhaps due to its mega presence in functional cleaning products). Diorissimo has already changed it packaging to denote the change that has been implemented to the levels of hydroxycitronnelal: the newer white packaging with pink “oval” bearing the name states hydroxycitronellal further behind other ingredients instead of the slightly older batch of pink packaging with white oval. The change is subtle and very cunning: while right now the packaging can be an indicator of batches, the introduction of a different colour schema is an optical blurring, ready for further –and final- chopping off! The consumer will never be able to realise without minutely examining the allergens list, which -let’s face it- is not what most people do.

Ylang Ylang is that rare thing: a comparatively inexpensive natural. Which poses a question over its impending restrictions. Baffled there.

The most serious aspect however and I don't know how it can be bypassed is jasmine....
Jasmine grandiflorum will be limited to 0.7% and jasmine sambac to 4%, under the latest 43rd amendement of IFRA. They are potent, so even a little helps, but 0.7% is getting pretty low...Jasmine is the emblem of quality French perfumery, a whole mythos behind many famous classics (No.5, Joy etc.) as stated so passionately on Grain de Musc and sadly both the grandiflorum and the sambac variety come under the latest restictions. And since Grasse jasmine was used in only the extrait of those classics, if you absolutely love those, you might stock up. Although don't be fooled, they have already been altered numerous times. No.5 has been stated to have changed its musks (eradicating the nitromusks so maligned by environmental studies) but smelling olde batches confirms that it’s not only them that changed. Since P&G (who belong to the RIFM oganisation, as stated in the above PDF) are the licence owners for parfums Patou, Joy is also to be changed irrevocably, probably to the great chagrin of resident perfumer Jean Michel Duriez.

The matter is terribly complicated, but....Plus ça change, plus c’est la même chose!

Pic of Dr.Jekyl and Mr.Hyde cover via sbfmedia.relationalhost.com. Diorissimo through photobucket search. Jasmine by Perfumeshrine, all rights reserved.

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...

Why Crusading Against Perfumery Restictions is an Exercise in Omphaloscepis

In regards to my previous post Perfume Restrictions and Why Everything We Say in Public Matters, Tania Sanchez, the co-author of Perfumes the Guide and a logical mind to be reckoned with, had the good manners and grace to honour me with a direct response. She brought many interesting points to the discussion and although I replied to her in the comments section I do feel that some of my points deserve some air-time for the benefit of those who do not customarily read the comments section. So, bear with me and we might disentangle some finer points.

Tania told me:

"The *future* of perfumery is not the issue. Perfumers have a massive palette and their creativity is proven every time we sit down with new perfumes full of ideas we've never smelled before. It's the obliteration of the past that is the wretched shame. As someone who has suffered all my life from a lot of allergic contact dermatitis (oddly, not to fragrance but mostly to skincare and cosmetics) I understand from my own study and experience that it is impossible to create a product that causes no allergies. The word "hypoallergenic" has no regulated meaning and something that causes rash in one person of "sensitive skin" will be the perfect product for another such self-confessed. We understand, when it comes to all other cosmetics, that when we try something and it gives us a rash, the sensible thing is to abandon it. Not ban it. The question is why these grand works of perfumery art, about which some of us care very deeply and which give us such happiness, must be vandalized solely to prevent some people's rashes, when those people can simply avoid the product by choice. Toxins, carcinogens, and other things that cause irreversible injury absolutely should be eliminated from the perfumer's palette, no question. But skin allergens? Why, when there is a very simple alternative: (1) a full list of ingredients and (2) advising a 24-hour patch test?"

Certainly this is the level-headed approach it is a pleasure conducting dialogue with. So let's take the points one by one, so my ~perhaps nebulous before~ stance becomes clearer.

Since perfumery as an art form has been proclaimed dead, there is of course the rush of panic in an average person's mind of "Hell, what now?? Shall I abandon my pefume hobby? And will everything produced from now on be soul-less?" The focus of my article therefore was to dispel a little of that panic. I think it managed it in some degree, if I say so myself. Then, there is the greater issue of the massacre of classics. There is no dispute on that as I am as much a collector of classics myself, several of them vintage or rare. I collect them, dust them, look at them with dreamy eyes and wear them with a nostalgic pang of someone who was born long after the Summer of Love. A nostalgic pang which is unexplicably shared by many. It is the nature of man (and woman!) to "gloss over" the past and idolise it as better times. Ah, the Golden Age of Cronus...and the continuous decline of man... subject of mythological themes in as far back as 1000BC. Nothing new. We idolise that which we have not experienced first hand. But even if we have, psychology tells us we like to forget the bad, hold on to the good and reminiscence life in idyllic terms. The more we age, the more we do that and it is a sign of our vanity and coming to terms with mortality. We want to be able to say "I had it good, I saw the beauty, reaped its core!". It's understandable.

So what does all this have to do with perfume? It does, in relation to our collecting classics and insisting on their unaltered state of eternal beauty, their own immortality being a small indication of the belief that we, too, can be immortal if only in a small, miniscule piece: that of the beauty ideal we hold. But here is the catch: When wearing a vintage classic I do not claim to re-live an experience of a woman who wore the same juice in the 1930s. It doesn't matter if my juice is authentic, if it is well-preserved, if I am in the right frame of mind or even if I am holding a bakelite cigarette case and wearing a Lelong gown! In essence (no pun intended) I cannot replicate the experience of wearing a classic of that time the way the people who wore it in that age did. Like we discussed with Jean Claude Ellena in our interview, it's not possible to make this "true" to either the maker's intention or the spitit of the era, as numerous factors conspire to make the experience different. How's that? One cannot have read Satre or Genet and go back to seeing things the way people saw them before WWII. The bleak and the existentialist gloom has changed our souls, even if though the memory of written, not lived, word. One cannot have lived through women's movement or reaped the benefits of it in their personal and professional lives and graft themselves back to the time of La Belle Epoque when women didn't always think for themselves. One cannot see the vintage classics (and for our purposes here I mean the ones which are bought in this almost contraband business of ebaying and antiques scouring) as anything else as a glimpse of history. Are they accurate? They are only in the degree which we allow them to be; which we are able to allow them to be. Seeing (even carefully touching, if you're on the inside frame of the business) the Cloisters Apocalypse manuscript at the Metropolitan Museum of Art in NYC is not the same as being a monk fixing the gold-leaf in a musty, wooden bank-seat at Cloisters wearing the monk's cloak. The experience is vastly different! Imagine therefore how much more different the experience is when a classic pefume's formula has been already adjusted numerous times through its history ~sometimes even right after its official launch!~ and not only in the last 10-15 years!! Those reformulations, which ALL the classics have endured at some point or another, are due to other factors than the latest IFRA regulations: lack of "bases" for the perfumers ("bases" are ready-made and commercially available "accords" that give a specific "note" or effect, so that the perfumer doesn't have to sit down and start from scratch each and every time); loss of materials due to suppliers' changes; arid or wet seasons influencing the naturals' quality, yield or vibance, much like in wines; adjustments that have to do with economizing or tastes when the brand changes hands.... The hunt for the perfect photocopy of a 1919 Mitsouko (or any such) is therefore impossible! Unless we were transpoted back to 1919 à la H.G Wells ~while being at an age with our full capacities intact~ sniffed some, taken a little with us and then being transported back to the present to analyse, see how to replicate 100% and manage to actually do it, everything else is basically an exercise in futility. We can regard the classics not as the classics that were, but as the classics we loved. The one version which we have liked, which we have come to love ~whatever that might be and however time-specific it might be. (You all realize that it is getting more and more difficult, now I broke this down in those terms, huh?) Man and woman loves what they are familiar with. They love that which has first touched their heartstrings and even if it was not perfect it will always hold a dear place in their memories. It's almost impossible to pin down what version each of us loves however, so perfume companies adjust to the widest denominator. And plus, not even L'Osmotheque has the 1921 Ernest Beaux Chanel No.5 and that's a fact!

So, what do I propose? Eradicate the classics? Of course not! But insisting on our part, our perfume enthusiasts' part, our perfume connoisseurs' part (call it whatever you like) that we want the real Joy, the real No.5 etc is a populist stance that reminds me of a kind of "free fragrance!" activism. Is this viable and what's more is it effective? I think on the whole pefume companies want to please the consumers, if only because they rely on them for sales -yes, even the discerning ones sometimes!- and if they see an interest they will adjust to the best of their margins from a business point of view (I realize miracles cannot happen). Therefore it's good to provide some actual means of voicing that concern, which is what I did by providing some data on how to reach some people. I'm sure more people will chime in and offer theirs as well.

I don't know if the authors of the Guide are already lobbying in a "free fragrance" campaign and therefore are preparing us for something on which they will need our support in whatever form. I only recall the now defunct blog of Luca in which he had said something along the lines of there being an hierarchy of worries: First you worry about the really big things: war, death, famine, etc. Once those are out-of-mind, we start to worry about smaller things: cars, safety seats, allergens. In a turmoiled world in which the economic crisis is having several people sacked and jobless with families to raise and when earthquakes destroy whole blocks of flats collapsing in L'Aquila, Italy while the Baths of Carakalla in Rome suffer damages, the matter of IFRA and reformulating is becoming small potatoes. But even if there is a crusade going on concerning the irrationality of the spirit of the restrictions, the latest Spring Supplement to the Guide which is full of mentions of reformulations is proof positive that the previous pleas by the authors, in the first edition of Pefumes the Guide and before, have met with deaf ears.

Concerning allergens there is some confusion among the public. Let me straighten it out to the best of my non-medically trained ability. Allergen is something that causes an allergy. Allergy is according to Medicine Net:"A misguided reaction to foreign substances by the immune system, the body system of defense against foreign invaders, particularly pathogens (the agents of infection). The allergic reaction is misguided in that these foreign substances are usually harmless. The substances that trigger allergy are called allergen. Examples include pollens, dust mite, molds, danders, and certain foods. People prone to allergies are said to be allergic or atopic". Allergies are largely hereditary and usually manifest themselves fairly early on in life. Sensitizers on the other hand is a completely different issue and this is what IFRA is trying to regulate. Let's see the definition according to the Occupational Health and Safety Administration: "A sensitizer is defined by OSHA as "a chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical." The condition of being sensitized to a chemical is also called chemical hypersensitivity. Therefore here is the interesting part which a perfumer highlighted in the comments yesterday: "Sensitization is the term used to describe a sudden allergenic reaction to something that you previously tolerated well. The chemical substance builds up in your system, and then, on day 563 of use, perhaps 10 years in (days and years chosen randomly, of course) you get a bad response. It may even occur with a new perfume that you've never worn before, but it contains the lavender oil that you've been using for 10 years, and bingo - now you're sensitized to lavender. You're not allergic to it, you're sensitized."

Potential allergens therefore do not perform in the either/or way suggested. One thing could be perfectly all right for yeas and through repeated exposure it can escalate into becoming a sensitiser. So a patch-test is not enough. Even in hair-dyes where a patch-test is de rigeur, one can accumulate a sensitivity and it might burst at any second (this is why they advise doing a patch test EACH AND EVERY TIME! Even for products which you have been using all the time) Can you imagine that for perfume use? I can imagine the labels "Spray the product on a dot on your elbow or behind the ear each time you want to wear the perfume and if you feel no redness, prickling or burning sensation within the next 24 hours, you can wear your perfume ~THIS TIME!" Yeah, great bunch of help that would be!! So, although theoretically I am agreeing that labelling is allowing an informed choice (and I'm all for informed choices!), the matter is more complex than that. Simplistic "easing it up" along the terms of "just slap on a label, for Pete's sake!" is not very helpful.

Listing the full ingredients list isn't very helpful either. First because of the obvious, as explained above: one can be perfectly fine with something and yet get a reaction out of the blue. Life is scary and then we die. We all take our risks and I don't advocate not to. But perfume companies already list the most common allergens and therefore if one knows about something specific not agreeing with them, they can avoid it. The rest they have to risk. Yet the full ingredients list is not something companies want to do for another two reasons: Even in food-stuff (which is scarier to use compared with perfume) you cannot find out the exact formula down to percentages or origin of any ingredient. And sometimes there are cryptic labellings such as "natural aroma of fruit" (what exactly? how was it derived? how much?) or even misleading "no added salt" (yeah, but the sodium percentage is huge anyway!). Fragrances are not going to list everything because the mystique is a great part of the whole business. And also because the consumer is not at ease or has sufficient knowledge to know what anisaldehyde or Iso-E Super is etc. Several people ~on perfume boards even~ protest "I don't want my pretties converted into a chemistry lesson!". And just think what the listing of a full list of ingredients would do to consumers and a few perfume critics as well: No more smart-ass stuff!!

Basically the outcry for the latest regulations is justified because they stand to close some of the little guys (always a bad thing in a democracy), and they are threatening to have several raw materials suppliers out of business ~and therefore even if the little guys want to construct a perfume that bypasses the regulations they will not have the materials to do so!

But it also opens up two interesting arenae, which to me sound full of job potential for specific people: legislative consultants (people who will deal with all the paperwork necessary for the implementations in big companies and with prior experience in law, insurance, that sort of thing) and an ultimate atbitrer of taste who is equipped in chemistry, has a connoisseurship of perfume and a couple of publications on the subject under their belt.


We will continue with posts on the oakmoss and other ingredients problem and offer some clarification and altenatives.

Perfumery Restrictions and Why Everything We Say in Public Matters

There is a show on Greek TV called “Proof” in which famous journalist Nikos Evaggelatos reveals the scandals of various industries by having reporters infiltrate and report back in audio and video every gory detail to the shock, repulsion and wrath of the audience. Actual names are not revealed, no one is brought to task in practice and although there is an expert’s panel and a participating audience at the studio, no specific solution is proposed at the end of the show and the issues are left hanging there.

In more ways than I would be comfortable with, the latest NZZ Folio article by Dr.Luca Turin, proclaiming “Perfumery, a hundred-year-old art, has taken a long time dying, but on January 1, 2010 it will be officially dead”, reminded me of that sensationalist approach. The issue has been already addressed and the restrictions had been warned of, premonitored and fought against by several writers and activists. It’s not really news, especially to Turin-reading perfume enthusiasts, since he has been writing about it at every opportunity for years. My dissenting voice is not disputing the seriousness of the latest reformulations in the industy (yes, they’re dire and largely irrational) but an attempt to bring logic to what is apparently an impassioned subject that makes us momentarily lose our powers of reasoning.

A brief recap: Regulatory body IFRA (International Fragance Association) regularly issues a catalogue of perfumery ingredients’ guidelines with which major manufacturing companies (ie.the companies who make the juice, such as IFF, Givaudan, Takasago etc. as opposed to those who commision it ~the Lauder Group, LVMH Group who owns Guerlain and Dior among others, the Gucci Group etc.) comply with, so as to minimise potential consumers’ complaints & lawsuits; a stance that has been sanctioned as law by the EU Commission at Brussels, which is the real “news”. Now let’s go back a few years: In Nov.2004 a NZZ Folio Duftnote by Luca warns about the reformulation of one of Guerlain’s masterpieces (Mitsouko). His newly-published blog "Perfume Notes" debuts in 2005, pronouncing "The End of Civilization as We Know it” concerning the changes at Guerlain: the perfume community sounds its barbaric yawp through the rooftops of the world and Guerlain PR Isabelle Rousseau's mail gets spammed. For many this was a first; oblivious to the inner workings of the industry, whatever doubt they had on the altered smell of their favourites was not directly attibuted to reformulation. But the approach created an unprecedented turmoil within the perfume community and it indirectly acted as a test of power. Although in mid-2007 the pneuma of the original Mitsouko was pronounced living on in the reformulated juice (by Edouard Fléchier) by Luca, it seems brought back to task just now in April 2009, along with other perfumes.

What changed in the interim? The perfume community came together tight as a fist (commendable), perfume blogging in general became a springboard for careers (predictable), Luca Turin close a book contract (desirable) and perfume companies have continued –or, should I say, escalated- reformulating their juices regardless on their merry way to the bank (lamentable). If anything the historical scope proves that forceful articles and community outcries do not hold the power to inflict changes in the industry!

All written word in the public domain and transmitted through a network of interested parties should have a purpose. If the purpose is not informational journalism (the issue is well known and addressed in the latest supplement of Pefumes the Guide, while the IFRA amendments are downloadable for all to see) or activism manifestation (to which we have already seen that the corporate world pays little attention to), I am at a loss on what purpose that latest article serves!
A couple of issues obscure the justified plea for change and the criticism on Dr.Rastogi: Demonization (environmentalist chemist Suresh Chandra Rastogi, Scientific Committee on Consumer Products, IFRA itself, the perfume companies), argumenting ad hominem (“I am not disputing the veracity of Dr Rastogi’s research, though it makes mind-numbingly dull reading”), argumenting ad populum ( “fragrance has no demonstrable benefit other than beauty” and “beauty cannot be measured” with which readers en masse agree), and of course first and foremost argumentum ad verecundiam, aka appeal to authority ~ that of the author himself! Is the biblical simile of The Man Who Cried Doom lost on everyone but me?

In talking about Dr.Rastogi’s work, Luca says “you discover some real but minor problem in a fragrance ingredient. Nice work and you can tell your family when you get home”. That’s the main difference between Rastogi and Turin: reach! Dr.Turin has been given a public podium read by a specific niche of readership who cares very much for those issues and who accepts any such news with fear, panic and wrath (“In another scientific paper titled “The Composition of fragrances is changing” Dr Rastogi analyses old and new perfumes and notes that his work is having an effect”). Dr.Rastogi has not. For what is worth I can see that he is Senior Reseach Scientist at the National Environmental Research Institute of the Ministry of the Environment at Roskilde, Denmark and he has a solid body of publications on allergens research, so I deduce he is serious. In all probability nevertheless his self-defence will be conducted through closed doors of university laboratories and scientific publications which, as a fellow scientist of another field, I know are only read by a specific niche: namely, scientists in the field ~ergo not the perfume enthusiasts’ community. The fight is thus unequal and it feels like a test of power. I would hate to see it as a Philippic interpreted à la Jacqueline de Romilly (ie. a raison d 'être) and thus I am giving both Luca and Rastogi every benefit of a doubt till further notice.

The 43rd IFRA amendment includes several “threatening” essences: jasmine absolute (both sambac and grandiflorum), ylang ylang, heliotropin, frankincense, eugenol and isoeugenol (spicy notes)…. . Please note nevertheless that Restricted is not the same as Prohibited. Restricted means allowed to be used up to certain levels and under certain circumstances. Costus had no chance in any form (oil, absolute or concrete), nor does masoia bark for flavours; but neither does the very new Majantol (a quite new lily of the valley synthetic). Oakmoss/mousse de chêne however somehow might and we will talk about it and other ingredients in some length in the following post.
IFRA was imposing recommendations for a variety of compounds such as oakmoss for a while, the industry following them resulting in numerous reformulations across the brands for at least 10 years now. Thus, for most modern fragrances these standards are not a big issue.

The dream of bypassing the EU by making perfumes on non-EU soil however is futile: the EU cosmetics legislation would only move to the American FDA. It's all about economics and the location of the target market of any specific house. In the words of independent pefumer Andy Tauer:

“Who are the members of IFRA? You will see that the big industry is in there, as members, like IFF*. Thus, all regulations are basically influenced by the big industry, too. There seems to be a mutual interest (commission/big industry) and the entire process is driven by industry, too. I feel that the EU Commission is just proving once more that it does not really care about economic growth, about the citizens it's representing, or small and medium -sized enterprises ( SMEs) but rather plays its game with the big ones, meeting with the who is who; thus the smaller enterprises have to either accept what comes out of these dances or perish.” *{quote from IFRA page: Since the GA of October 17, 2007, companies may also become Direct Ordinary Members of IFRA"}.

It has to do with papework as well, because several cosmetics and toiletries are produced locally for tax reasons, so not all products of one brand are produced at one place.
IlseM points out on the Perfume of Life board which is ruffled:

“IFF is being sued by hundreds of microwave popcorn factory workers because the diacetyl in their butter flavorings caused those workers to contract the irreversible lung disease bronchiolitis obliterans. I remember when Consumer Reports tested fragrances for phthalates after they were supposedly removed from all fragrances. CR found them in many of those fragrances and even in ones where
the companies claimed never to have used pthalates. In a few cases the level was even higher than when testing was done before their removal! It's hard to believe that the fragrance industry is motivated by product safety concerns.”

But the perfume community itself has responsibilities too! When perfume writing broke into the Internet and Press scene in 2005 ~an epoch seemingly as far back as the Pleistocene for most people’s memories~ there was heated discussion concerning the use or not of aromachemicals (ie.materials synthesized in the lab for use in perfumery) as opposed to natural ingredients. Authors breaking into the scene championed synthetics ~deeming them no less important or more important than naturals. I distinctly remember people saying that it didn’t matter what their perfumes were composed of, “as long as they smelled good”. Those words are now coming to kick them in the butt in a not-as-nice way. Why the delayed outcry on the axing of several natural essences? We’re catered for with what we asked!
“Smelling good” is a relative term and perfumers can create new compositions tapping as yet unknown resources and new frontiers -which might produce the classics of tomorrow; it would be both hypocritical and rushed on our part to en masse condemn everything that comes out of the labs of companies as an original composition complying to the newest regulations. After all, some fragrances which have been deliberately constructed to bypass restrictions have already gained critical acclaim. Some, like Futur by Piguet, have even been reworked with the help of Luca Turin himself! As mentioned by the president of Piguet, Joe Garces, on Sniffapalooza magazine March 19th 2009:

"With the help and guidance of the most diverse fragrance critic from across the pond who loved “Futur” from its original launch, I have been fortunate to find the final road map with his guidance to the glamorous fragrance that once was. Because of the genius and passion of Luca Turin we will present the perfect “Futur”.)

Although restrictions have really gone over the edge and this is shared as a concern by all the perfumers with whom I have been in discussion, not everything is doom and gloom. In a previous interview with Sandrine Videault, when asked about it, she told me new perfumers have no great difficulty working with the palette proposed, as they do not feel restraint in not being able to use what they have not worked with before. The creativity will change. On top of that, small niche firms can continue to use questionable ingredients in higher ratios than those complied with by the bigger firms (provided they can still source the supplies, which is the main issue. To quote Tauer again: “The restrictions imposed by EU will kill many suppliers or essential oils and absolutes, as the longer the regulations remain, the more a burden. Thus, I am faced with a narrowing market for high quality essential oils”. Outlaw is like outlaw does! So the real problem is classics coming from big brands. But those have been already seriously altered, which is something we have been witnessing for decades now and reporting. Classics will remain a museum piece by their very evanescent nature; it’s inevitable, alas. In the words of Jean Claude Ellena who is taking the modernist approach (and who makes interesting perfumes with the questionable ingredients, such as Iso-E Super, at well-below recommended ratio, bless his heart) “we can’t build the future only on history”.
If you need to do something about it you can mail Société Française des Parfumeurs: 36, rue du Parc de Clagny 78000 Versailles, France. Tél: (+33) 01 39 55 84 34 Fax : (+33) 01 39 55 73 64. Or the Commission for Cosmetics and Legal devices, mail to: staffdir@ec.europa.eu

Bottom line, obituaries might be a little premature and indignation with no suggestions offered is akin to pissing in the wind.


©Elena Vosnaki for the Perfume Shrine.