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Monday, April 6, 2009

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.

46 comments:

  1. Lord have mercy.

    BTW- you are VERY right about 'what is said in public'.....

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  2. Anonymous15:52

    Oh thank God someone is speaking in a sensible tone! And taking an informed stance on the situation to boot. As much as I love a sensational statement I swear I would scream and rush out of the door if I hear yet another conspiracy theory by now.

    As always you do not disappoint, Helg. Welcome back.

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  3. Anonymous16:00

    your thoughtful and well researched commentary is so on target, Helg. About an hour ago I call it 'Luca Turin's Apocalypse Now' on twitter.

    Mr. Turin, who i respect very much for his expertie, does seem to love the smell of naplam in the morning..

    Seriously, it is an obstacle, but true ART always finds its way around obstacles. Les Poets Maudits of the 21st century shall emerge

    Michelyn

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  4. Anonymous16:14

    Oh one more comment, a year ago I asked this question about the regulations that were being imposed in an interview with Bertrand Duchaufour. He was unfazed. He said "I create and these regulations will not stop me from creating...."

    michelyn

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  5. http://outlawperfumer.com ;-)

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  6. Anonymous16:33

    Helg, please excuse me for writing yet another comment, but I do have a lot to learn on this subject matter (since I joined in relatively late). I'm going to toss in a couple of observations here and there if you don't mind.

    1. Yes, the subject has been fought and discussed for years. Now that I understand IFRA is composed of some members from the Big Boys it totally makes sense why the lobbying effort went the way it went. But one question remains: suppliers like LMR and Biolande are owned by the mega firms too and their sales would be directly affected by the legislations. (Jasmine, citrus, and oakmoss sales would inevitably decrease I deduce.) But it seems counter-intuitive for the coporate members to pass rules which would lower their profits from the subsidiaries. Shedding any light on the situation would be greatly appreciated.

    2. Look forward to your oakmoss piece. I seriously need to be even more informed on this issue, period.

    3. I now see the futility of bypassing the EU laws by creating North American exclusives. Is the FDA making its move as we speak, or do we still have to wait for yet another Internet storm to brew on that front?

    4. Speaking of the Da Vinci painting...you do know that the Louvre is brining out a film inspired by the masterpiece, right? "Visages" will debut at this year's Cannes Film Festival:

    http://www.nytimes.com/2008/12/27/movies/27face.html

    It's in the post production stage right now--the team is busy working in a Paris studio located in the 17th arrondissement. Already writing to the director in extreme excitment (and he wrote back too, which is absolutely cool).

    5. I know your stance on the following issue...but I think some people need to know that their beloved citrus notes won't be reformulated because those notes are largely synthetics to begin with. (Yup, grapefruit for one.)

    A

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  7. I remember in "Perfumes: The Guide" Luca Turin said, a propos of one I liked (Eau du Sud I think?) that EU restrictions on certain citrus derivatives were going to mean that in a few years it would smell nothing like it does now. How many others will have the same fate?

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  8. Anonymous17:17

    Hi E!

    Very interesting reading. Thank you for posting.

    IMO, your bottom line pretty much says it all. ;0

    Speaking of pissing, there's a quote I heard from Judge Judy:

    "Don't piss on my leg and tell me it's raining."

    Hugs babe!

    Dawn

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  9. I hardly know what to say, E, except to thank you for yet another insightful, rational, highly informative post on this huge issue. I can't decide whether I find it all sad or funny. A bit of both, I suppose.

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  10. Thank god for some sense. I'm so tired of people parroting LT and sneering at TS, as if they're not two people simply expressing their opinions.

    Still, I've got to look at my beloved classics and think, "DAMN!"

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  11. Perfumeshrine,

    I'm glad you are addressing this issue by exposing IFRA members and the lobbying of the big fragrance companies patenting potentially lucrative molecules, more profitable than natural ingredients they don't own.

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  12. Anonymous19:49

    "Bottom line, obituaries might be a little premature and indignation with no suggestions offered is akin to pissing in the wind." -- TOTALLY AGREE: I WOULDN'T THROW IN THE TOWELS JUST YET. (In fact if I'm brave enough I might just the newest Mitsouko parfum and see if it is an improvement on the new EdT, which doesn't work for me. Perhaps Turin was referring to the parfum having a bread-like top note and a more pronounced iris effect? Did get it in my EdT, but then again that's the only available edition in my town so I'll have to phone Toronto for the parfum.)

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  13. Anonymous19:51

    Oops...that's "Did not get it in my EdT".

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  14. Ida,

    I believe the situation is entangled and there are too many angles to look this from. But we should be careful of what we say. We might be taxed with it!

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  15. Thanks A.
    Well, I believe as much as the situation is tough, there are several covert interests in the regulations, the big manufacturing companies ousting the small ones, the suppliers etc. It's not easy to entangle...

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  16. My dear Michelyn,

    thanks for the encouragement, it means a lot to me.

    I respect Luca as well and this is why I prefer him to focus on solutions rather than napalm, as you say :-)

    If Duchaufour is unfazed, it's heartening. Thanks for mentioning it!
    I really think Les Poets Maudits will emerge. I'd hate the little guys getting shut down due to lack of suppliers, though...That I can't condone.

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  17. Outlaw is as outlaw does! LOL

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  18. A,

    your observations are always interesting.

    Let's see if I can reply:

    1.I believe those Grasse companies you mention are small: they employ what? 120 people (B) and 36 people (LMR)? Who says what they're thinking concerning them....I will return with more as info is organised, don't despair.


    2. The ingredients and oakmoss in particular are a fascinating issue on which there is much confusion, indeed.

    3.FDA can't decline to conform for ever. In fact it's known to be one of the toughtest control organisations on the planet and political correctness is a US specialty so I am sure there will be lots of petitions of people "allergic" to perfumes who will condone sticter measures which began with other directives on the agenda ;-)

    4.Visages sounds fascinating. You know my weak spot, don't you! That's cool indeed, bravo.

    5.Citruses will be covered in the follow up, need to be, alas. :-)

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  19. L,

    It was on Eau d'Hadrien and it's been already pummelled on the spring supplement.
    It's like Goutal is being punished for using high levels of naturals, huh? But they're working on rectifying the problem and work with the restrictions without compromising the juice, so it's only a transitory product and they assured me they are doing their best. There's hope. :-)

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  20. My dear Dawn,

    hi there and thanks!

    The quote you bring on board puts a new meaning on all those regulations, right?
    Seriously, this is our time to support the little guys! I had been saying it all along, it's never good to trust the government to tell you what to do. ;-)
    But then my nature and upbringing are a little...unconformist.

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  21. M,

    I am terribly saddened on the classics too. I have been wearing My Sin and thinking, why oh why did things have to change.....

    But you know, only diamonds, infinity and human stupidity don't change and I'd rather put my bet on the first two rather than the third. So, for all purposes, let's do all we can to preserve what can be preserved (even as museum pieces, even as non-contact little shrines to old glamour) and let's see what can be done ahead!

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  22. A,

    the thing is Luca didn't specify which concentration by Flechier was so darn wonderful. I wish he did!
    I did't have the heart to go through all new vesions, but the edp I tried is decent if not great. Still my old extraits cannot be compared to that.
    BTW, I liked the old EDT. It had a spicy bite that wasn't in the EDP. (But parfum was really best)

    Anyway, Mitsouko has largely become the emblem of a black-clad chorus of women swaying their heads to and fro chanting "Noooooo" in some ancient Greek drama, and although I'm raised with those images in my psyche, I'm not sure I like to continue to see it that way! It's getting...miserly.

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  23. Anonymous20:33

    Elena, I would like you and others read my response.

    Thanks,

    - Alex (student perfumer in Grasse)

    ReplyDelete
  24. Garde Rose,

    glad you liked it! Indeed the big companies are doing what they please. The inclusion of the companies as IFRA members skews the game, doesn't it? (this is why I included that quote, it's spelled out for us to see)

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  25. A,

    of course I will give due attention to anything you have to say on the topic.

    ReplyDelete
  26. Anonymous21:20

    Thank you, thank you, thank you for this post! As upset as I am about the new restrictions, I think the doomsday-like predictions about the supposed end of perfumery are unproductive and a little hysterical. Will we see changes? Sure. Some of our favorite formulations will be altered (but like you said, many already are). But this does not mean that perfumer-as-artists will cease being innovative and creative. They will still be able to create new masterpieces. Perhaps this is the final death of a progressively dying era in perfumery. But perhaps also it will signal a new creative era of different, but still great, fragrances.
    Again, great post.
    Molly

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  27. Molly,

    glad you enjoyed it.

    I guess you said it best: idooms-day predictions are unproductive. I'd rather hear specific instuctions on how to construct a conforming formula so as to know what to seach for, or solutions on how to make something viable, or at least a petition for a museum line-up. Oh wait, they already thought of that, L'osmotheque, so there's not much to suggest in that line.

    I think we're upon a brave new world and that's not always that bad. It could be good if we make ourselves heard in a consise, level-headed, polite and sane manner.

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  28. Hi, Helg,

    Thanks for weighing in. 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?

    T

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  29. Dear Tania,

    thanks as always for taking the time and for having the sensibility to address the article in level-headed and logical steps. I wouldn't expect less from you!

    Since perfumery as an art form has been proclaimed dead there is of course the pang 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, you bring the issue of the massacre of classics. There is no dispute on that as you must know I am as much a collector of classics. 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. 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. One cannot have read Satre or Genet and go back to seeing things the way people saw them before WWII. One cannot have lived through women's movement or reaped the benefits of it 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 (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. Seeing (even 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 moist wooden bank at Cloisters wearing the monk's cloak. The experience is different!
    Imagine therefore how much more different it is when a formula has been adjusted numerous times through its history and not only in the last 10-15 years!! (due to other factors, as you surely know: lack of ready-made bases, loss of materials due to suppliers' change, arid or wet climate influencing the naturals, adjustments when the brand changes hands....) The hunt of the pefect photocopy of a 1919 Mitsouko (or any such) is therefore impossible. Unless we were transpoted back to 1919 while being at an age with our full capacities intact, sniffed some, taken a little with us and then 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.
    Is that illuminating my point of view more?

    So, what do I propose? Eradicate the classics? Of course not! But insisting (not you, I mean in general) 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 pefume companies want to please the consumers -yes, even the discerning ones sometimes- and if they see an interest they will adjust to the best of their margins (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.
    Unless you're actually already up and lobbying about it and you're not revealing it to us, but hinting on it so that people are "prepared" when you do announce it?
    But judging by the last time when those reformulations concerns were voiced, I can't say it has brought significant results, alas...Your Spring Supplement (which I have linked for people to download, if you noticed, and I hope you get many "hits") is proof of that!

    Concerning allergens: I am of course sympethizing with your condition. I can't say I am not sensitive-skinned either. Therefore I have eliminated a few things off my routine, such as is the logical thing to do.
    However, you say: "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?"
    To that I will disagree with less than scientific merit but backed by received knowledge and you will have to excuse any vagueness on my part due to that.
    First, as you know companies cannot divulge the full list of ingredients. 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 cyptic 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 because the consumer is not at ease or in knowledge to know what anisaldehyde is etc. If they did, imagine what it would do to consumers and even to a few critics too!! No more smarty stuff!!
    Secondly, allergens do not perform in the either/or way you suggest above. Since you have personally suffered from them, you might know that one thing could be perfectly all right 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 EVEY TIME!) Can you imagine that for perfume use? "Spray this on a dot on your elbow each time you want to wear the perfume and if you feel no redness, prickling or burning sensation in the next 24 hours, you can wear your perfume ~THIS TIME!" Yeah, great bunch of help that would be!!

    So you see, although theoretically I am agreeing that labelling is allowing an informed choice and all that (and I'm all for informed choices!), the matter is more complex than all that. Simplistic "easing it up" is not helping, therefore.

    I think this merits its own post. You brought interesting points.

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  30. I don't really have anything to add because this so well written- great piece, very well thought through.

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  31. Helg, you touch upon the allergen issue as defined by Tania, but I would like to correct you both a bit: it is sensitization that is the long-term culprit, not allergenic response.

    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.

    Not being a doctor, I cannot make a sweeping statement about the following, but I, and others I know, believe that using liver-support herbal supplements help us avoid both allergenic and sensitization issues. My oakmoss sensitization is not responding to the regime, but my mango pollen problem is.

    Our liver helps us eliminate all toxins from our body that should not be there. I'm just saying that I believe in the herbs and will continue to take them. Unless, of course, some regulatory body decides they're to be regulated. Then I will grow them and take them. Heck, I could wind up sensitized to strawberries or shellfish after years of consumption, so I want to extend my indulgence timeline for all yummies and smellies as long as I can.

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  32. There is an old story that goes like this: A city slicker has decided to take up farming and needs a mule. He notices that the farmer next door has one for sale. He goes to look at it.

    The seller praises this mule to the skies. He's the smartest, most hard-working mule ever, he says. The city slicker says, "show me." The farmer calls to the mule. The animal just stands there. He clucks to it, gestures to it. No response. Finally, he picks up a board and slams the mule right between the eyes with it.

    The farmer is horrified. "Why'd you do that! he screams.

    "Well, first," the farmer says, lighting his pipe, "you gotta get his attention."

    I think all the hoopla might get somebody's attention, not that it would do much good. Business is business.

    Further, I think it's important to consider who exactly is funding all of these allergy and toxicity studies.

    Back in September I wrote about the differences between the art supply industry, which lets artists make up their own minds about lead and heavy-metal based pigments and so on, as opposed to this one which appears to want to nanny us. It just doesn't add up. I'm not a conspiracy theorist, but I do believe that this is about money, has always been, will always be.

    Your voice of rationality is welcome and leads to real, thought-based discourse. Still, I'm looking at my collection and wondering if I've got enough vintage and pre-reformulation perfume to last me.

    Fleabay might be the real winner here.

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  33. Thanks for your analysis - it's very helpful for me as a fragrance lover trying to understand what's actually going on in the midst of various personal crusades, obituary outcries, passionate panic and such.

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  34. Anonymous16:39

    Thank you for bringing clarity and for being a voice of reason to a complex issue. A good read, as always!

    Sincerely,

    Carole

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  35. Anonymous18:39

    Dear Helg,

    I think various aspects associated with the IFRA regulation have been thoroughly covered (thanks so much again) but I just want to throw in my two cents on a few things extra.

    Firstly, I really appreciate that some remedies are being proposed: I gives me hope that the industry will evolve once again. After all, I think some of the greatest artistic triumphs are created in the midst of religious, economic, sociological, and even artistic restrictions. For example, few will dispute the beauty of Shakespearean sonnets, yet the rules governing the genre, including the rhyming schemes, meters and forms (quartets & couplets), all of which can be interpreted as restrictions in the first place. (And let's not forget the political issues associated with some topics during that era: direct negative allusions to the politically powerful, for one, would be a lethal taboo and could result in publication bans or even death.) So while I'm in no place to tell anyone what to do or think I, for one, is being positive that talented perfumers can rise above the challenge and even come up with some praise-worthy creations for years to come.

    Secondly, I too see a huge challenge associated with labelling the complete formula, although the idea has its own merits. Here are some of the issues based on my observation over the years:

    1. Some established designer brands are very, very nervous about the concept of fragrance formula to begin with, let alone labelling them. While the fear can be a bit irrational at least one account exec I know just won't touch that subject, period. So I think the proposal will face some oppositions as a result.

    2. Even if we can manage to convince some industry players and implement the labelling practice I still think some additional issues will exist. Aside from the issues you've raised bases such as aldehyde C-14 has so many alternative names that it's hard for some consumers to keep them straight, let alone other chemicals with similar naming practices. So unless we have a clear naming convention upon labelling reading the list will be one extra hurdle that the consumers will have to get through.

    Come to think of it, I think the best solution is for the IFRA to create a small but user-friendly division that continually educates, informs, and supports the consumers in regards to perfumery ingredient issues on a full-time basis (if it isn't available already). Truth be told we don't need heated arguments anymore. What we need is exactly what we are doing right now--thorough, honest dialogues with the facts laying all out on the table to the best of our abilities.

    A

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  36. K,

    thanks for saying so. I did think about it before writing it ;-)

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  37. A,

    thanks for the distinction. Indeed there is one and I hope that my next post highlighted it: allergen and sensitiser are not the same.
    I want to extend my indulgence timeline for all yummies and smellies as long as I can as well!

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  38. P,

    you bring a very valid point into this and thank you for it: the awareness of the issues by the public. It's not always easy and sometimes one needs to spell something out for people, because everyone is so peoccupied with their own affairs.
    The funding of the tests I believe is not directly related to the regulatory bodies but is fueled by the hysteria on sanitizing every aspect of our lives, which is so PC at heart. Then the regulatory bodies have to assess those studies and conform/be flexible as much as allowed (aheam!) There is money to be made by the big companies so the nannying is due to that. And I am certain that sellers on Ebay will go on a frenzy tagging everything vintage for the panicked people who are rushing to stock up before Dies Irae!

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  39. Proximity,

    thank you very much for stopping by. I hope to give practical advice later on as well.

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  40. Carole,

    thank you for saying so. A little sang froid is sometimes necessary when pondering an issue. Then we can panic all we like :-)

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  41. A,

    excellent points.

    I think labelling is just not very viable, you know? It meets with several obstacles, as analysed. And most people will just get confused anyway...I know it makes it easy for the hard-core fans like us (and a little egotistical side in me likes that prospect), but in the greater scheme of things it's a little like "squaring the circle".

    Your idea about a training division within or with the sanction of IFRA might work you know. If there is some greater education on the subject, then some of the hysteria from both sides might subside and there might be some more awareness and informed choices. And that would be a good thing! (pinchforks were never my thing! LOL)

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  42. Anonymous02:20

    Hear hear!

    I like what you said about Turin's attack on Dr. Rastogi. No matter what Rastogi has done it takes years of hard work to get papers published in refereed journals. It is entirely unfair that Turin seeks to discount all Rastogi's work in just a few paragraphs.

    Having done economics as my first degree my take to these restrictions is that they are actually "trade barriers". Instead of levying higher import taxes on raw ingredients, which would violate many trade agreements, the governments put restrictions on the contents of consumer products. As a lot of the raw ingredients are produced in China and India, I can understand why the EU and US govt are so keen on introducing new laws that would lower import of these ingredients. Any thing that helps to lower trade deficit is good, isn't it?

    elaborate@mua

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  43. Elaborate,

    thanks for chimming in!

    I agree that it's not easy to get published in those journals (and L should know) and therefore it's a little unfair to discount it in such a condescending way. I am sure all those scientists really do believe that there is actual harm done through those sensitisers/allergens etc. even though we don't.
    But what I said in the body of the article bears repeating: there's no contest in the popularity stakes in the community and L knows it. But if we stoop to popularity contests ~and the industry doesn't work on the same premises or fsvourites as the community ;-)~ then something gets lost, no?

    Your point about points of dale/production and the desire to circumvent them is not wasted. There is some truth to what you say. Then again the buying off of Grasse producing firms (revealed in the subsequent articles with the IFRA/restrictions tag) is very alarming, because it shows a desire to close down on anyone who makes materials non controllable by the big ones.

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  44. Points of sale, duh....no coffee yet, what do you expect :/

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  45. Mystic Knot22:55

    Dear Elena

    Thank you for the most comprehensive and understandable article on the IFRA and the 43rd amendment. Excellent reading !

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  46. MK,

    glad you enjoyed!
    Trust me on this, this WILL be referenced in regards to future developments for certain people, shall we say, INTO things. I would be nodding "I told you so!" then, but it's a thankless role. ;-)

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