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

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

via

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

82 New Allergens in Perfumes: The Death Toll on Fragrances as we Know Them

Although I'm not one for the sensationalist approach,  the escalation of concerns for the potentially allergenic properties of perfumery compounds looks very grim indeed for every perfume lover out there. The classic Miss Dior, Shalimar, Mitsouko and many Guerlains, Angel, Opium, Bellodgia, perfumes with tonka beans and anything with lots of citral (look out for lemon and tangerine "notes") are to be irrevocably changed. If there is something that you absolutely love (and get no adverse reaction from) in its current -already reduced- state, better stock up, because within 2013 lots of fragrances are in for a major rehaul.

via lefigaro.madame.fr

If you thought that oakmoss only, i.e. evernia prunastri, was the crux of the matter, you're in for a major surprise. Treemoss, i.e. evernia furfuracea (which acted as mossy note in the post-2008 reformulated chypres that demanded it) is coming into axing and the low-atranol versions of oakmoss have not really managed to convince perfumers of its ability to pose convincingly for what is lost in translation from the older formulae.

Of course one could argue that some classics are already semi-ruined: The classic 1947 Miss Dior (now sold as Miss Dior L'original) is already sent to the back-burner Peoria of limited distribution, but its upstart (the renamed Miss Dior Cherie) isn't safe either; the youthful cheekiness has been effaced and the best-selling Dior smells more like Chanel's Coco Mademoiselle than its own self. The famous YSL Opium, already in transvestite gear, is set to become a eunuch, due to the eradication of eugenol and isoeugenol, spicy molecules naturally present in cloves, mace, bay leaves, rose oil, basil and other plants. As to Chanel No. 5, which raised the flag of the press, thanks to its constant on the front of everyone's mind when thinking "perfume", the truth is it has been so attenuated through the years that any claim on Grasse jasmine and adherence to the 1921 formula sounds perfectly ridiculous to anyone who has some vintage bottles stashed in their fragrance closet. If a shiver of fear went down your spine reading that jasmine and rose are to be restricted as well, fear not: most commercial perfumery (even the very best brands) just use hedione and phenyl ethyl alcohol with citronellol for those two notes respectively, with a garland of something else to boost them this way or that; I have already stated how the industry uses the same 20 ingredients over and over resulting in fragrance sameness....It's no accident.

Although the fervor with which the European Commission is inspecting scented products instead of some of its rotten political realities, which have effectively created a chasm between North and South and have posed a risk for the very solidarity of the European Union, seems misplaced, the issue isn't totally without scientific basis.

"Based on the review available and on multiple cases of allergy reported by dermatologists, the SCCS [Scientific Community on Consumer Safety] identified 82 substances (54 chemicals and 28 natural extracts) that can be categorised as 'established contact allergens' in humans, including the 26 that were already on the list." The document goes on to highlight that, based on the combined results from animal experiments and the analysis of their chemical structure, 26 other individual chemicals where categorised as “likely contact allergens”. The SCCS also reveals that in addition, 35 individual chemicals and 13 natural extracts were also categorised as “possible contact allergens” with three further specific substances recognized as being “potent allergens” and not considered safe in consumer products." [source: SCCS publishes fragrance allergen fact sheet]

The above showcases one common misconception concerning the restrictions of certain ingredients in perfume & scented products manufacturing (including skin care, detergents, hair dyes and the like), namely that it is natural extracts that are being axed due to reasons of high costs. This is plainly NOT the case. It's much more complex than that and litigation as well as technical problems within the industry, as mentioned before, factor in. As you can see above, by the numbers given, plenty of synthesized molecules (nature-identical or synthetic) are also being axed; in fact the synthetics to be eradicated outnumber the naturals greatly (54 to 28)!
What is most alarming is that this is showing no signs of stopping there: 26 other individual chemicals are categorized as "likely contact allergens". In addition 35 individual chemicals and 13 natural extracts are also categorized as possible contact allergens with 3 further specific substances recognized as being "potent allergens" not considered safe in consumer products.

Although ever since 2003 there has been a series of 26 individual ingredients which have been identified as allergenic and are required by law in the EU and in the US to be mentioned on the label (things like coumarin, hydroxycitronellal, Lilial, citronellol, etc), the percentage of people with some form of allergic sensitivity to consumer products with a scent is calculated to be 1 in every 3 Europeans.
Even though the usual repercussion of skin contact with these questionable ingredients in perfumes usually results in topical redness and a rash, it can escalate to eczema, a more severe allergic immune system reaction which even when treated can remain dormant for a lifetime, waiting to be re-triggered via another exposure to the allergen that first made it erupt. It is important to note that even though some ingredients do not cause a reaction in vitro, they can potentially do so in vivo thanks to the interaction with sunlight, air or even the body's own biological processes which turn them into allergens. But there is an inconsistency.

 ‘While I do think the consumer’s health and wellbeing should always be our first priority, imagine if Brussels authorised for all nut products to be banned or restricted because a few people are allergic,’ Roja Dove, a prime industry figure and a manufacturer of luxury niche fragrances, says. ‘Just look at basil. I have to list it on the back of packaging if I use more than a certain percentage because it’s one of the original list of 26 the European Commission decided must be declared. ‘But a chef can take a huge bunch of basil, chop it up and sprinkle it over food, and their hands will be covered with basil oil. There are no guidelines there.’

Thankfully it is claimed that an exposure level in cosmetic products of less than 0,01% (or 10 mg/100g of cosmetic product) would prevent allergic reactions in the majority of cases. As such, the use of kojic acid (a skin lightener for cosmetic use on melasma and age spots) for instance is considered safe in concentrations of 1% in compound of leave-on creams for use on face and hands.
According to The Times, the European Commission are expected to propose new regulations within the fragrance industry in January 2014, when considerations of both the economic importance of perfume (earning £1.5 billion a year for France alone) and the actual number of perfume-induced allergies occurring might be put into perspective. The sheer process of re-evaluating all the formulae currently on the market and reformulating all those perfumes at no monetary compensation should definitely sting for all the fragrance companies.

It remains to be seen whether a subtle visual twist in packaging (as before) or an augmented list of allergens on the label will be the deciding factor in signaling the changed formula of any given perfume. At any rate, consider yourselves warned.

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

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

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

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

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

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

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

Good News on the Regulations Front: Macrocyclic and Cinnamyl Phenyl Propyl fragrance Ingredients Proven Safe

"The Research Institute for Fragrance Materials, Inc. (RIFM) now has available, from its web site at www.rifm.org, human health safety assessments on Macrocyclic and Cinnamyl Phenyl Propyl fragrance Ingredients. Found in the Publications section of the RIFM site, Toxicologic and Dermatologic Assessments for Three Groups of Fragrance Ingredients: 1) Macrocyclic Ketones, 2) Macrocyclic Lactones and Lactides, 3) Cinnamyl Phenyl Propyl was published in Food and Chemical Toxicology, Vol 49, Suppl 2S, Dec 2011 and is already one of the journal's top ten downloaded publications. Included in the review of the three groups are 24 related Fragrance Material Reviews (FMRs).  Printed copies can be ordered from the RIFM Online Store."

These popular materials, used in different scented uses (fragrance, functional products, air care,cosmetics) and carrier/disolving purposes have proven to be "practically nonirritating, have a low sensitization potential, no genotoxicity potential and a low order of repeat dose toxicity".

Read more here: http://www.sacbee.com/2012/05/01/4456540/macrocyclic-and-cinnamyl-phenyl.html#storylink=cpy

News via  The Sacramento Bee where you can read the whole article.

photo showing the hull of a boat that was painted with a coating containing macrocyclic lactones, with the exception of the stripe down the middle via gizmag.com

Read more here: http://www.sacbee.com/2012/05/01/4456540/macrocyclic-and-cinnamyl-phenyl.html#storylink=cpy

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