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IFRA has also withdrawn the Standard for Vanillin, which was first put in place with the 44^th Amendment. This Standard was put on hold on 1^st December, 2009, has now been officially withdrawn.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

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

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.

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.

Interview with a perfumer: Andy Tauer from Tauer Perfumes

People know Andy Tauer from his marvelous perfumes (click for reviews:L'air du desert marocain, Rêverie au Jardin, Le Maroc pour elle, Lonestar Memories and Orris), his informative blog and generous sampling program for all and his completely adorable character that simply slips through everything he touches.
It was thus with great pleasure that I interviewed him for Perfume Shrine one quite evening and he kindly provided us with an insight into the fascinating world of Tauer Perfumes and his mind.
Sipping Earl Grey tea and studiously going over his replies I can see just how attentive to detail he is, yet retains some spontaneity of character that accounts for his open nature.
Alors, then!

PS: Hello Andy! Nice to chat with you.
There is something that people have been curious about and ask me from time to time. Those who have been reading your blog know that you do have another job apart from perfumery. Yet you do dedicate a large part of your time and work into creating those lovely compositions that have perfume lovers going "ahhh" all the time. What prompted you to first start up on this?

AT: Hello to you and your readers! I started making scented alcoholic solutions a couple of years ago. I call them scented alcoholic solutions because know, looking back with a smile, I would not call them perfumes anymore. My first steps into the world of perfumery were rather embarrassing; hopeless trials to make something coherent with only natural materials. Later, I was introduced to Vero Kern, my perfumery friend and body in arms. Pascal Wehrle, the shop owner of Medieval art& vie in Zurich, introduced me to her and it was the beginning of a friendship at first sight. I owe her a lot: She introduced me (me being a chemist!) to the world of synthetics. And it was she who showed me how to turn "the light on" in compositions. Pascal Wehrle on the other hand, a dear friend since close to 20 years now, was the kick starter to make a fragrance for a shop, his shop. I was unemployed in 2004, having lots of time and no job for quite a while. It was his idea to come up with a scent for his shop where he sells (among other things) Moroccan crafts. Le Maroc pour elle was my first "commercial" scent, and it was born during dinner at my place. What followed is a funny story, still developing, somewhat absurd in a sense, never really planned. I tend -regular readers of my blog know this- not to take things too seriously. This attitude helped me a lot to cope with mistakes and try the impossible. Create and produce outstanding perfumes at a reasonable price.

PS: Indeed it is so. And you have been blogging for two years! Do you find blogging on perfume to be a reward unto itself? Readers compliment your candour and your letting them glimpse into the creative process (I know I do!). For you personally, is it rewarding to share these thoughts? Do you appreciate the feedback or get ideas from readers?

AT: Looking back, it was the internet and a somewhat personal online presence in my blog that made all the difference. Again: I had no plan and started a somewhat naif blog, because I liked the idea of sharing thoughts and ideas. Later, I got to know part of the perfume lovers community and I liked the idea getting folks involved. To blog has become important for me. Sometimes, when writing about a trial and the disastrous result, I get new ideas by just writing about it. I love it when my readers comment and bring in their ideas, or wishes.
Of course, at the end of the day, I will always follow my nose and my own vision for a new fragrance. But I remember for instance Maria B.'s comment on a frankincense trial, wishing more patchouli! Which at the end turned into a new twist. Sometimes, perfume lovers comment on something that I would not have expected. For instance: I published a prototype picture of my new Lonestar Memories label for the flacon. I got -contrary to what I expected- somewhat negative comments. Thus, I
decided to come up with alternatives for the label and have folks vote on it. Finally, although I am not a native English speaker (the blog is in English), I love to write. It helps me to get along with "la condition humaine", to deal with life.

PS: Yes, I think it helps us all. Now, a question I always ask when dealing with perfumers ~ do you find that the quality of the ingredients is of lesser, equal or greater importance than the innovation or beauty of the formula? In short: could one create great art with cheap paints or great music with garbage like Stomp do, if we translate the concept in perfumery? Or is this impossible?

AT: You know~ I always use the analogy to painting. Creating fragrances is like painting with scents and molecules. Maybe this analogy is close to me because I like to paint. At least I did when I had more time. I have no doubt that you can leave a great painter for a week in the desert with nothing else than water, food, char coal and a nice flat stone to draw upon with the coal. At the end of the week you will find a masterpiece in the desert.
{At this point I find myself nodding in agreement.}

Now, to answer your question, we might want to look for another analogy: Music. The perfume formula is like the notes on a piece of paper. To make a symphony alive you need musicians and instruments. Good musicians and good instruments. The music that you hear is then the manifestation of the notes on paper and -to finish the analogy- the fragrance you smell is the materialisation of an idea, written down as formula. You need a good formula to make a good scent, coming up with the formula is the creative act. The better the formula, the more robust it is, allowing for minor quality of certain ingredients. The shorter the formula the more difficult it will be to compensate missing ingredients quality.

And then he animatedly goes on to express himself more clearly saying that a perfume formula is robust when it allows for small changes in ingredients (whether this is amounts or quality) without major changes in the detected scent quality. Therefore it MUST be robust !he stresses that~ otherwise its production would be difficult.
I have no problem understanding that. It seems logical enough: The more robust a formula is the more it will allow for individual components to be of minor quality. It seems therefore to be that a good formula allows for minor quality of some (not all!) ingredients. This explains some comments on niche or upscale perfumes that talk about synthetics that yet manage to smell terrific.

But then {he goes on}: Can you make a masterpiece with cheap stuff in perfumery? I don't think so. Can you make good perfumes with cheap ingredients? Yes, for sure! Can you make dreadful perfumes with the most expensive ingredients? Yes, unfortunately, yes.

PS: This is often the pitfall of many! {I laugh}

AT: Maybe one last aspect: It depends what you want to do with-let's say: Jasmine. You need it to round up edges and give a little twist, then you might use your everyday jasmine, pumped up with some synthetics. If you want your jasmine to dominate and be a shining column, holding your fragrance together, you might go for the Moroccan quality.

PS. Since you mentioned jasmine, and this is probably something that you get asked all the time: what are your favourite notes and ingredients? Do they evoke something particular for you or do they pose some technical challenge that makes them intriguing to work with?

AT: Well, I feel I change my favourite notes like my shirts. One day it is frankincense, one day vetiver or okoumal. But I have my notes I always come back to. I love my woods, and I love my rose and ..jasmine. When composing I always try to integrate new notes, and while doing so I learn how to master them. But like for every perfumer things boil often down to the usual suspects. And I must admit: I still love my naturals. These natural extracts are so inspiring. One day you snifffrankincense and you discover the terpene like citrus line. One day it is the hint of a tar note. I often get natural oils and absolutes and concretes, knowing that I will never build them into a scent, but I use them for inspiration.
There are, however, a few scents that I hardly ever work with: Styralyl acetate is one of them. I just don't like it. Thus, I skip it. I know it, but I don't use it.

PS: Can't blame you! It's hard to work with something one doesn't like. Regarding composition: Do you have some prototype in your head when composing? Or do you go along with what your nose is telling you to do? I have read about how Jean Claude Ellena is never testing things in the lab, but just pops his notebook out of his pocket and writes down ideas of accords and percentages and ratios of molecules and ingredients and then gets the assistants at the studio do the mods. Do you find yourself distanced from such a practice or not and why?

AT: Sometimes I wished I had an assistant, a busy bee, mixing what comes out of
my head, like Mr. Elena and most perfumers have. Well, I have not and there are advantages. It helps you staying close to the matiere premiere, the molecules and naturals. I usually start by thinking. How to reach a certain idea. I then sit in front of the computer, type in the formula in Excel, that does some calculations and tells me for IFRA restricted ingredients where the limits are and then I print it out and start to mix. While doing so I sniff. Often I follow the Excel formula blindly and start modifying once I have the mixed soup in front of my nose. But, when mixing, I allow myself to also follow my instinct or intuition and change things on the go. Usually, when done, I add a little drop on my hand, because I am impatient, to learn how the scent develops on the skin. But as I use a lot of naturals in my compositions, I must allow my soups to mature for at least two weeks before I can tell how a new mixture behaves. That's why things need time in perfumery.

At this point I interrupt to revert to the recent IFRA restrictions that have plagued the perfume world with dismay and raised so many questions.
He wants to be fair. He clarifies obligingly.

AT: Here, we need to cool down and look at IFRA (and other regulating bodies) in an open minded and in a fair way. I feel a lot of missunderstandings are around. Let me use an example: Oakmoss extracts.
If you want to sell perfumes in the EU countries, you have to label oakmoss
extracts, if the amount of oakmoss is beyond a threshold. There is no way around it. But you are free to use as much oakmoss as you would like in your fragrances! Thus, for us niche perfumers, this means a lot of freedom. I think this makes sense. It allows consumers who are sensitive or allergic to oakmoss extracts to make a decision based on facts. I want my customers to be able to make this decision. Most consumers do not worry about these declarations because they are not sensitive. And, because many EU label compound are present in naturals (like linalool), in a sense, a long EU declaration is almost a sign of quality! Contrary IFRA (IFRA LINK) the International Fragrance Organization: If you follow IFRA's recommendations you should not use more than 0.1% oakmoss extracts in your fragrance. Right now this is considered a safe level, at which no sensitizing happens. Now, this is a pity, of course!, and many of the big classics used oakmoss at higher concentrations. What to do now? If a perfumer does not want to follow IFRA's recommendation: He or she is totally free to do so. There is no law binding us niche perfumers to follow IFRA. I tend to follow the IFRA recommendations, because most make very much sense to me; most of them consider toxic, cancerogenic or sensitizing compounds. And so far, I have not reached a limit in expressing myself. Later, this might change, because IFRA is very much guided by big companies, having specific needs that are less important for niche perfumery.

This is very enlightening and encouraging at the same time I have to admit to him.

PS: From your own creations, is there one that holds your heart above the others? Why?/why not?

AT:There is one baby I love the most: L'air du desert marocain. I love it on the W.-factor (my friend), and I still admire the composition. I find it really well done and others seem to find this, too. So far, L'air du desert marocain is the best seller. Maybe I love it for this reason, too!

PS: {laughing} Touchee!! What are the iconic perfumes that made you dream and which are the ones you admire youself?

AT: I love the classics and also some exceptions. One of my favourites is Knize Ten, a leather fragrance with a perfect composition. Then there are the good old Guerlains, or Carons. One exception is Series Red, Palisander from Comme des Garcons. I love it for somewhat unclear reasons! Most of the stuff that comes out these days on a weekly basis, I find not good, I must admit. Hence, I have a little bit given up sniffing these new editions. I rather focus on my Jicky and try to learn there.

PS: Is Eau d'Epices you informed us on your blog the only new perfume to expect for now or are you toying with other things as well?

AT: Well..... Honest answer? I do not know. I have my doubts. The W.-factor, my friend, tells me to go forward with the Eau d'epices. But time will tell. I have not made my mind up. There is no need to hurry things. There are a few fragrances in work, either in batch mode or rather actively. Two of the almost finished scents are the hyacinth/mechanic and the frankincense. But again: No hurry. I like to let my fragrance prototype sit for a while. And then, after a few months, I look at them again and make up my mind.

PS: Glad we cleared that up. So...aces up your sleeve! And your plans for the line in the future? Regarding additions, possible limited editions, distribution and positioning?

AT: My plans are very specific as far as my time is concerned that I devote to perfumery and building the business. By end of October I will reduce my other "normal" job. With more time at hand I want to follow some ideas as far as distribution channels are concerned. (And I want from time to time a free weekend..) But very carefully. I do not want to be present in too many places and I have a set of excellent distributors right now. But a perfumery here and there might not harm. About adding more fragrances to my portfolio.Hmmmm...... Sure there will come more. Sooner or later. But -as mentioned before- there is time. If I think of L'air du desert marocain and my zero marketing so far, then I feel that there is a huge untapped potential. Of course, it is fun to create perfumes and then think about labels and packaging. And bringing a new scent to the market is really exciting. But from a business point of view, I should not forget my babies that are sitting on the shelf already.


We stop here this interesting discussion with the promise to catch up when his Eau d'epices is finally out.(Of which I have been privy of testing and I can tell you dear readers, he has another hit on his hands! But more later on!).
I can safely say that knowing a little of Andy Tauer has been great and it was very rewarding talking to him. I just hope he is as satisfied from this glimpse into his world as we are. Thanks Andy!



Pic of Andy Tauer by himself.
Pic of Flyer for Reverie au jardin by Andy Tauer

European Parliament Question re:Allergens in Perfumes

The matter of increasing control of suspected allergens in perfumes is both taking wings (with increased  vigilance on the part of the industry) and starting to face opposition by concerned parties (perfume lovers, raw material growers, manufacturing companies etc). Here is the latest I came across regarding a formal plea to the European Parliament apropos the use of Calabrian bergamot in the fragrance and flavor industry.

via www.thekitchn.com

European Question to the European Parliament
4 January 2013
E-000022-13
Question for written answer to the Commission Rule 117
Cristiana Muscardini (ECR)
Subject: A bergamot-tinged war? Answer(s)

Here we go again, according to some newspaper reports. The lobbies of certain chemical industries are declaring, via the European Union, that between 1 % and 3 % of the European population are 'potentially' allergic to some ingredients found in perfumes. The proposal to reduce the concentration of essential oils from 12 % to 0.01 % would sound the death knell for bergamot and would see this traditional product disappear from Calabria, the only region in the world that is able to produce this citrus fruit, from which the oils that form the base of many perfumes are extracted. One is tempted to say: 'Here we go again!'
There was an attempt, in the past, to stop pizzas from being cooked in wood-fired ovens, for health reasons. There was also an attempt to harm the production of chocolate eggs containing a 'surprise', this time for reasons to do with the safety of children, who could have swallowed the small 'surprise' objects. Now another attempt is being made with a natural production process that is unique in the world and concentrated along a coastal strip, around 80 km long and 10 km wide, in the region of Calabria. That means that 650 farms, 7 000 workers and 1 300 hectares used for plant production are affected, not to mention the numerous perfume houses that use bergamot essence to establish a fragrance's bouquet.
The industry would like to replace this natural product with a synthetic product, which obviously has nothing to do with the Citrus Bergamia Risso citrus fruit, better known as bergamot.

1. Can the Commission confirm whether the news is true?
2. Does it really intend to support the arguments put forward by certain chemical manufacturers, against a natural product that has kept the perfume industry going for centuries without ever being harmful to health?
3. Can it say whether bergamot essence is patented or recognised by the various EU arrangements for recognising protected origin?
4. Does it not believe that the tea industry will also be compromised, given that bergamot peel is used for the aromatic Earl Grey blend?

[Original language of question: Italian]

EN E-000022/2013
Answer given by Commissioner Tonio Borg on behalf of the Commission (14.2.2013)

The Commission would like to clarify, in response to the first question, that an opinion on fragrance allergens in cosmetic products was issued in June 2012 by the Scientific Committee on Consumer Safety (SCCS). This opinion updates the list of fragrance allergens (including natural extracts) relevant to consumers, while confirming that the 26 fragrance allergens already regulated in the Cosmetics Directive[1] are still of concern.

The Commission is currently reflecting on how to implement this opinion so that it contributes to consumer information and safety in the most adequate and proportionate way, while maintaining innovation and the competitiveness of the cosmetics sector. To this end, it is thoroughly assessing the social (in terms of protection of consumers, availability of products and employment) and economic impacts of possible options, taking into account also vigilance data and additional elements of consumer exposure.
As for the third question, Bergamotto di Reggio Calabria Olio essenziale is registered at EU level as a Protected Designation of Origin in the group of essential oils[2].
In relation to the fourth question, the Commission is aware that some food flavourings when used as fragrances in cosmetics may be dermal sensitizers. However, there is generally no concern on allergic reaction via oral exposure. The Commission does not therefore believe that the tea industry risks to be compromised. |

[1]|Council Directive 76/768/EEC of 27 July 1976 on the approximation of the laws of the Member States relating to cosmetic products, OJ L 262, 27.9.1976, p. 169.|

|[2]|Commission Regulation (EC) No 509/2001 of 15 March 2001 supplementing the Annex to Regulation (EC) No 2400/96 on the entry of certain names in the 'Register of protected designations or origin and protected geographical indications' provided for in Council Regulation (EEC) No 2081/92 on the protection of geographical indications and designations of origin for agricultural products and foodstuffs, OJ L 76, 16.3.2001, p. 7.|

You can draw your own conclusions.
For what is worth, here is an interview with Stephen Welter from IFRA (the International Fragrance Association) from July 2012 where he maintains that the premium goal is the ensuring of safety for consumers (and where it transpires that IFRA is the final testing body which receives applications/suggestions on banning things from SCCS and other lobbies).
This is a most interesting excerpt from it, as per Stephen Weller:

"IFRA has in fact delivered some very positive results. Far from banning certain materials, IFRA has in fact been protecting them from potential bans. A material such as oak-moss would have disappeared if it hadn’t been for IFRA. The EU would have abolished it. In fact, thanks to IFRA’s work, many materials are still capable of being utilised as part of the palette of more that 3000 materials which perfumers can employ in their creative art. There are restrictions on the use of some substances but these are justified when balanced with the safe enjoyment of fragrances for all."

The text of the Parliament question can be found on this link.

Related reading on Perfume Shrine: Allergens and Perfume Industry Restrictions, The Bergamot Series

Poached this reference on the Fragrantica boards via member Kitty48

Outlaw Perfume: Revolutionizing the Industry One Step at Time

If you are one among the many perfume enthusiasts who in the last few years has been informed of the restrictions which have been self-imposed by the International Fragrance Association and the lobbying at Brussels in the European Union of several groups concerned with the allergens, hormone disruptors and other assorted impending signs of the coming Apocalypse in your humble Eau de Toilette, and have been severely icked, irrated and all around cussing beneath your breath, wielding your fist at the powers that be who nanny this existence for you, then read on. And rejoice, because not all is black and doom. A handful of perfumers (natural perfumers of the Guild on this occasion, but how far can more mainstream perfumers be?) are rebelling against perfumery restrictions which do not make much sense.

We're not talking about materials which have been proven to cause brain damage (a miniscule amount already banned since many many years), but of such innocuous and traditional ones such as citrus essence or lavender. Outlaw perfumery is not about being irresponsible, but about being level-headed. In a world where nuclear power risks and air pollutants pose a far greater risk, it seems adhering to a noli me tangere frame of mind is becoming unreasonable and ultimately laughable. If by any chance you had been a castaway these past 3-5 years in the middle of the Pacific or haven't really understood what this furore is all about, you can read all about it on these pages under Restrictions and under IFRA.

The guidelines of the International Fragrance Association (IFRA) and the laws of the European Union (EU) have created an era of vapid, soulless, synthetic perfumes due to the banning or severe usage level limits they have placed on historic perfume ingredients that are used in leave-on or wash-off fragrance products. Rose, jasmine, oakmoss and many other aromatics are now allowed only in tiny amounts, and their scentual presence is dimmed. Independent perfumers are not members of IFRA, but if they are in the EU, they have to abide by the rules. Independent perfumers are also aware of safety issue due to photosensitization, allergenic sensitization and irritation, et al. The Natural Perfumers Guild takes the stand that a warning label should be enough to allow us to use citrus, oakmoss, jasmine, rose and other cherished perfume materials in our creations. If a warning label is good enough for the potentially-deadly peanut, it should be good enough for a perfume that may give you a rash.
One among the perfumers, Anya McCoy, the president of the Natural Perfumers' Guild, says "Just by being a natural perfumer, I’m an outlaw in the eyes of the perfume establishment. I don’t use their synthetic materials and I am self-taught. It’s not a surprise I would not follow the dictates of the International Fragrance Association (IFRA) or the European Union (EU)"
A warning label suggested would perhaps read: “Warning label: Enjoy your Outlaw Perfume! It may contain aromatics or alcohol that could cause a slight skin reaction, so it be used with caution. Don’t apply perfume and go out in sunlight. As you would with any scented product, we recommend a patch test or you may spray the perfume in your hair, on an item of clothing, or on a small piece of cloth to tuck into a pocket or sleeve.” In fact isn't the Victorian idea of wearing perfume on a handkerchief, a locket or on hair a very romantic notion? Eschewing skin contact, our beloved perfumes can be reclaimed as our own! If they only let us...

So from this coming Monday November 15th expect to see news & reviews of Outlaw perfumes submitted by a pleiad of natural perfumers under a collective umbrella, crafting compositions that disregard the excessive fear and litigiousness of IFRA on these participating venues:

Gaia at The Non Blonde
Donna at the Examiner.com
Felicia at Fragrance Belles Lettres
Carol at Waft by Carol
Ida, Mark and Monica at Ca Fleure Bon
Lucy at Indie Perfumes
Beth at Perfume Smellin Things
Pat at Olfactarama


In fact I would be personally interested to hear your suggestions for the industry's perfumed products Warning Labels: keep them coming!!

pic originally uploaded on MUA

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 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...

Perfumery Restrictions: More on IFRA 45th Amendement

The industry standard, Perfumer and Flavorist Magazine, did a post concerning the latest restrictions on perfumery ingredients, as determined by the International Fragrance Association (IFRA) in its 45th Amendement (You can read about past restrictions and ramifications clicking the label IFRA or Restrictions). We had breached the subject with saying it is not as severe as past version, but we're reverting with specifics.

The latest installment features seven changes. Of the announcement, IFRA president Jean-Pierre Houri said, “We have seen quite large Amendments in the past due to the change-over to our new Quantitative Risk Assessment (QRA) approach. This change-over process is now nearly complete and therefore we have a smaller Amendment.”

Newly Restricted (QRA) materials include:

*Dimethylcyclohex-3-ene-1-carbaldehyde (mixed isomers); CAS# 68737-61-1, 68039-49-6, 68039-48-5, 27939-60-2, 67801-65-4, 36635-35-5, 68084-52-6, 35145-02-9
*alpha-Methyl-1,3-benzodioxole-5-propionaldehyde (MMDHCA); CAS# 1205-17-0
*3-Phenylbutanal; CAS# 16251-77-7

Revised Restricted (QRA) materials include Verbena absolute (Lippia citriodora Kunth.), the culprit being its eye and skin sensitisation properties.

Revised Specifications include:2,2-Dimethyl-3-(3-tolyl)propan-1-ol (otherwise known as Majantol, which was used previously up to 20%, specifically for lily of the valley notes and in fruity-floral compositions especially for functional products), Musk Ketone which is prohibited, as well as Quinoline ~chemically speaking C9H7N~ due to its risk of skin sensitisation (The quinoline family mainly produces leather notes in fine fragrance such as in Shalimar or Bandit, but not Cuir de Russie which relies on birch tar -previously restricted)

Oakmoss, Treemoss and Chypre: you've come a long way baby!

Oakmoss has got to be the most controversial ingredient in perfume in recent history. For years used for its mossy, sensual quality and an integral constituent of chypre compositions married to a citrusy top note, traditionally bergamot, it has gone under the strict scrutiny of European regulations and IFRA -the regulatory body for scent materials. And it became the controversial issue in relation to the alleged reformulation of classic Guerlain perfumes, resulting in brouhaha of gigantic proportions. Let's try to sort the mess out a bit.

Basically oakmoss is a type of light green to green black lichen, a fungus growing on trees found in many mountainous temperate forests throughout the Northern Hemisphere, including parts of France, Portugal, Spain, North America, and places in Central Europe (Yukoslavian oakmoss was very popular). It forms clumps of bushy thalli. The growth of such lichens indicates good air-conditioning in those areas, as the organisms abhor pollution.
Oakmoss grows primarily on the trunk and branches of oak trees, hence the name (mousse de chêne in French); but lichen is also commonly found on the bark of other deciduous trees and conifers (fir and pine). Technically oakmoss belongs to the genus Evernia and is named Evernia prunastri, differentiating it from its cousin tree moss growing on pines and firs, Evernia Furfuracea. Interestingly, this last ingredient has been found packed into Egyptian mummies.

In perfumery oakmoss has been prized for its aroma, heavy and oriental-like at first, becoming very refined when dried, reminiscent of bark, seashore and foliage. It imparts a wet forest floor aroma in compositions resulting in a naturalness and rich earthy, damp and creamy undercurrent when used with restraint. Its remarkable quality is its ability to render a velvety softness to floral bouquets, green fragrances and heavy orientals alike, also possessing fixative properties imparting longevity in the perfumes that contain it and anchoring the more volatile notes.

Francois Coty, contrary to popular myth, was not the first one to capitalize on its fragrant properties in his Chypre in 1917, which inaugurated a new fragrance family. He did make it popular though and is indirectly responsible for the birth of many wonderful spawns, so a belated huge thanks is in order.
Chypre means of course Cyprus, the greek island of Venus with the rich history, and this is where the composition originated, albeit in a less standardised form, even from the time of Romans who created a mix of storax , labdanum and calamus (ingredients also present in chypre perfumes) in the island of Cyprus; this gave rise to the Middle Ages and Rennaisance alloys with oakmoss at its base.
We learn from Ayala’s excellent Smelly blog that as early as the 12th century AD pastilles and “Oyselets de Chypre” (Chypre Birds) were made by mixing labdanum (a resinous material combed off the hair of goats grazing on cistus labdanum/rockrose), styrax and calamus, with the addition of tragacanth. This was burned as incense, alluding to the ancient ritual origins of perfume “perfumum” (=through smoke); while the birds served decorative purposes and scented the air. It wasn’t until the 14th century that oakmoss was added to these pastilles. Two recipes from 1777 for chypre compositions include oamoss as well as civet, ambergris, musk and various resins and plant aromatics, two of which are rose and orange blossom.

With Coty’s Chypre though a new direction emerged resulting in a plethora of variations with such prestigious members such as Femme, Mitsouko, Bandit, Jolie Madame, Tabac Blond, Cabochard, Cuir de Russie, Aromatics Elixir, Miss Dior, Diorella, Knowing, Ma Griffe, Paloma Picasso and hundreds of others.
The inclusion of oakmoss in those compositions was a foregone conclusion.

However the European Union allergens regulations have changed our understanding of that last part. Deeming oakmoss - and not only that one- an ingredient that has been tied to specific dermatological averse reactions they issued a list of restricted ingredients. The Colipa site and especially the 7th and 36th amendment are of great interest to anyone researching this issue.
More specifically the IFRA regulation states that

"Oak moss extracts (e.g. absolute, resinoid, concrete, etc.) obtained
from Evernia prunastri should not be used such that the level in consumer
products exceeds 0.1%. In the presence of tree moss extracts the level of oak
moss has to be reduced accordingly such that the total amount of both extracts
does not exceed 0.1% in the final product.
Furthermore, oak moss extracts
used in perfume compounds must not contain added tree moss. Tree moss contains
resin acids. The presence of resin acids can be detected by using a routine
analytical method available from IFRA*. However, traces of resin acids are
unavoidable in current commercial qualities of oak moss. As an interim standard,
these traces must not exceed 0.1% (1000 ppm) dehydroabietic acid (DHA).
This
recommendation is based on test data on the sensitising potential of oak moss
and tree moss extracts, their cross-reactivity and the absence of sensitisation
reactions when tested at 0.6%. In addition, it has been shown that oxidation
products of resin acids contribute to the sensitising potential. This adaptation
to the Standard aims at reducing exposure to resin acids, while waiting for the
final outcome of a current research program.”

This ascertains that it is not oakmoss that is the culprit here, but probably its combination with tree moss. The issue however puts a spin on the reformulation of certain perfumes. Since the rise of the controversy it has been suggested that a warning label on the box of the perfume stating those specific ingredients included (more on that will be the theme of another article) might be the saving grace for those well-respected, nay treasured formulae of yore, especially the historic Guerlain ones. Mitsouko and Parure were prime candidates for a sweeping metamorphosis that would leave them harmed beyond any recognition. Lots of others as well. The official line of Guerlain PR had been denial of any reformulation up to a certain point in time, while in the last couple of years they admitted that the whole commercial line would be re-vamped by the end of 2005 to conform to IFRA regulations. No matter what solution might be suggested the result is that some amount of reformulation has indeed taken place (for the record, some people were in favour of the inclusion of the potential allergens with a warning on the box; others were championing the idea of including them only in parfum concentration or in the boutique exclusives, an idea that frankly reeks of elitism to me).

How could one preserve the use of oakmoss and where would one find it still then?
The “quenching” hypothesis is a fascinating proposition (Opduke as far back as 1976) and consists of the suggestion that inclusion of the anti-inflammatory azulene (naturally occurring in soothing chamomile) might cut down the risk of irritation presented by various objectionable ingredients.
However the odour profile of azulene coupled with its blue colour have presented the perfumer with a challenge as how to incorporate it in such a way as to remain in the wings.
The inclusion of eugenol and limonene at defined ratios to some other sensitising agents (cinnamaldehyde, citral, phenylacetaldehyde) is also worth exploring in regard to oakmoss.
It is debatable if the risk of a rash is so great a concern to warrant complete ban on specific ingredients for everyone. After all fyrocoumarin in elevated doses is also as much a suspect and even methyl eugenol which occurs in basil and rose oil has been called a systematic carcinogen. I do not see a ban on those however.
Many products still use Evernia prunastri (oakmoss) in their formula , they even state so on the box, often with tree moss also included in defined ratios, while others capitalize on the alluring notion of bringing out our inner dryad while using this sensuous forest ingredient still.
Master perfumerArcadi Boix Camps claims to have succeeded in substituting oakmoss for other combinations that produce a comparative smell, however there is not enough searchable info on what exactly that might be.
Natural perfumers are continuing to use oakmoss absolute rendered by solvent extraction and state its constituents as evernic acid, d-usnic acid, atranorine and chloratronorine. According to Robert Tisserand it is indeed a dermal and mucous sensitiser that should be avoided in pregnancy and epilepsy, but its risks for general use are in direct proportion to the manner of use and ratio in a mix.
Like with everything else, an informed choice is the way to go and hopefully some aspects of oakmoss have been highlighted here.
A newer crop of perfumes that assume the identity of chypre under the alias “mossy woods” in Michael Edwards' classification of perfumes has cropped up in recent years resulting in offerings such as Narciso for Her, Lovely by Jessica Parker, Lauren’s Pure Turquoise and Comme des Garcons White. Those pleasant perfumes substitute oakmoss with a grassy background of patchouli and vetiver that somehow does not smell distinctly chyprish like the classic ones. Whether this is the only way to go for the chypres of tomorrow or there is still a place for traditional oakmoss-laden chypres remains to be seen.

Pic of oakmoss growth from biopix.com