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

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

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

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

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

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

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

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

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

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

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