Europe: A Hostile Environment for Perfumery

[Guest guest]

Cropwatch Jan. 2007.

 

Europe: A Hostile Environment for Perfumery & Natural Aromatics Trading. The

aroma trade (perfumes, flavourings, essential oils, aromatherapy, herbal

medicine etc) has gone through a critical period in the last few years.

Large aroma manufacturers are deserting Europe, and raw materials

manufacturing in India & China has blossomed, to the extent that it now

represents the future focus of the industry. Part of the reason for this

manufacturing migration is to do with market place economics, lower labour

costs etc, but part of it is also due to the hostile environment that

Brussels regulators have created for the aroma trade with its high level of

hyperbureaucratic technocracy. Perfumery especially, has become so bound by

red tape that the profession spends more time working with software safety

programs, than it does with smelling strips. The rise of newly important

posts in aroma concerns, like that of the 'Regulatory Affairs Manager', has

further devolved focus and power away from perfumery

excellence, as company executives worry more about anti-fragrance

campaigners & regulatory complicity, than they do about the integrity of the

perfumery art.

 

The Quantitative Risk Assessment (QRA) Approach. We now have to accept that

IFRA are part of the Brussels regulatory regime. As part of the 40th

Amendment of the IFRA Code of Practice, we have the prospect of even more

red tape - the incredibly complex QRA approach to perfume safety (see

http://www.ifraorg.org.:80/News.asp). Many perfumers consider there was

nothing wrong with the previous leave on/wash off system for perfumery safe

working, but it seems that we poor technical drones now have to dance to

whichever is the latest tune being played by career toxicologists &

dermatologists, who seem to be so very, very overly influential in cosmetics

regulatory affairs. No-one concerned actually thinks to ask whether the

fragrance trade - especially its smaller concerns - can actually cope with

mountains of paperwork these regulatory requirements generate, and the

essential oil traders & aroma ingredients sellers are caught up in this

legislation too, traders having to provide detailed IFRA Certificates for

each ingredient to each customer.

 

Cropwatch has been considering evidence for whether this continual paperwork

avalanche of cosmetics legislation & 'best practice' has actually made

retailed fragrances any safer - believing, at this point, that the answer is

most probably no, since, for example, fragrance sensitivity continues its'

upward rise in many EU countries. Nobody in the SCCP seems to have resigned,

however, over this failure, although to her credit, the Cosmetics Sector

Head of Unit, Mrs. Sabine Lecrenier has taken up Cropwatch's request for

SCCP reform with the Secretariat of the SCCP. This follows submitted proof

of the SCCP's abysmal & inadequate track record to date (flawed Opinions on

natural aromatic products).

 

Cropwatch has subsequently pointed out that we feel that the SCCP is hardly

in a position to properly investigate itself, and to remedy its own failings

& shortcomings, and we believe that the EU Ombudsman will agree with us.

Amusingly, readers may have seen the detail in the announcement that IFRA is

to organise the independent analysis of retailed perfumes of IFRA member

companies in various countries, in order to force its members to adhere to

IFRA's perfumery standards, or be publicly named & shamed on the IFRA

website. Well, we have some advice for existing IFRA members.

 

LEAVE!

 

If they do so, we strongly recommend that they join Cropwatch to help to

generate alternative policies for perfumery safety which will not destroy

what's left of the industry & further, to help us oppose faulty SCCP

Opinions on perfumery ingredients. Behind the scenes, Cropwatch has already

forced some changes in moves relating to Cosmetics sector legislation, and

has helped stop regulatory moves which have defied common-sense - help us to

do more! In a development that must worry the existing Corporate Perfumery

Industry - Brussels Lawyers Alliance, manufacturers of natural aromatic

ingredients, too, are starting to work with Cropwatch to see if, together,

we can produce strategies for the production of aromatic commodities which

circumvent or eliminate the basis of the existing regulatory restrictions on

the materials, and keep natural ingredient producers in continued

employment. In this way, Cropwatch is attempting to be part of the solution,

rather than part of the problem, unlike the

SCCP.

 

Boycott Call.

 

Meanwhile we are floating the possibility that an ad-hoc group could be

formed to resist universal implementation IFRA's 40th Amendment, on the

grounds that it discriminates against small industries, which cannot afford

the time and effort to put it into practice. Many of us, of course, have

fundamental misgivings about the

science involved anyway. Please get in touch with at info if

you would like to support us in this. Implicit in this, is the belief that

existing fragrance safety studies largely benefit the continued employment

prospects of toxicologists, whereas studies of adverse reactions in

end-users probably deserves far more attention (such an input has been

previously promised by Ian White, Chairman of the SCCP, but, of course, has

never materialized in any effective way).

 

Our two proposed main area of focus:

1. To form an Opinion on whether perfume safety has measurably increased (or

not) in recent years, in spite of excessive EU regulation/increasingly

restrictive IFRA mendments on fragrance ingredients.

2. To critique the QRA protocol, and to compare adverse end-user fragrance

reactions under the QRA proposals, vs. adverse end-user reactions under the

more familiar leave on/wash off system. These studies would provide evidence

to support our intended petitioning of the Ombudsman later this year,

claiming that excessive EU cosmetics regulation is serving no safety

purpose, is costing industry a huge amount of money it hasn't got, and is

causing unnecessary hardship & unemployment for natural aromatic

ingredient producers.

 

The Pro-Synthetics Stance of the EU Cosmetics Sector.

 

The ongoing policy direction of the Cosmetics section of the EU Commission

then, is effectively condemning EU cosmetic/fragrance consumers to a

synthetic chemical future, via the progressive & continuous assaults, often

on dubious toxicological grounds, on the freedom to use, formulate with, &

to buy, products which contain natural aromatic ingredients. These

regulations against natural ingredients are biting deeper & deeper, such

that incoming new perfumers do not have the skills to create fragrances with

natural materials any more, as they are only expert in synthetic (Corporate)

perfumery.

 

Cropwatch believes the right for EU fragrance consumers to choose natural

perfumes composed entirely of natural ingredients, is a basic human right,

and this principle should be tested in law. The current demand for 100%

natural perfumes - and now even a demand for 100% organic perfumes - is high

in the EU marketplace. However perfumery companies cannot legally place many

traditional natural perfume types on the marketplace (e.g. citrus colognes,

fougeres etc.) because of existing regulations and red tape which work

against formulation with natural ingredients. But fragrance consumers don't

want 100% synthetic perfumes - they have noticed that they smell unfinished,

'chemical' & disgusting - they want perfumes composed either of both natural

& synthetic ingredients, or of 100% natural ingredients, and Cropwatch can't

see why EU

fragrance consumers should have them.

 

Final Call!

 

The prospect is that the 40th IFRA Amendment will eventually become

incorporated into the EU Cosmetics Directive. This seems to be the pattern

with other IFRA policies which are effectively rubber-stamped by the SCCP,

labeled as an " Opinion " , and adopted into the regulatory framework. Its time

to stop this excessive intrusion of bureaucracy dead in its tracks - these

assaults on formulatory freedom in perfumery are as moronic as the burning

of books: so let's restore perfumery as a high art form once more and ignore

these turbulent regulators!

 

Tony Burfield

 

on behalf of Cropwatch

 

www.cropwatch.org