Public Consultation - Opoponax

[Guest guest]

From Tony today on the opoponax battle with the regulators who don't

seem to get much right, even the form of the aromatic.

 

Hi all,

 

The Public Consultation about moving natural ingredients into Annex

III of the Cosmetics Directory - another step towards legal

restriction of naturals in Europe - contains a number of errors.

Cropwatch is trying to use these as a reason to halt the process.

Here is the letter sent today, below about opoponax (listed

incorrectly as opoponax gum in the Public Consultation). Our letter

was accompanied by the original Cropwatch objection the SCCP Opinion

on opoponax (SCCP/0871/05),.now available as a Word file to anyone

interested for any purpose!

 

Cheers

 

www.cropwatch.org

 

 

Dear Sirs,

 

As described in the Public Consultation pdf, the proposal to restrict

Commiphora Erythrea Glabrescens Gum (CAS no 93686-00-1) to 0.6% in

fragrances and move it to Annex III of the Cosmetics Directive is

legally unsafe. This is because Commiphora Erythrea Glabrescens gum

(opoponax gum) as described, is not used in perfumery. Rather it is

the oil, absolute, resinoid and extracts which are used in perfumery.

 

Further, opoponax qualities of commerce derive from three to five

different species of Commiphora as described in the Cropwatch

critique of the faulty SCCP Opinion on the alleged sensitising

properties of Opoponax (SCCP/0871/05). The critique was forwarded to

the Head of Unit at the EU Cosmetics Commission, but subsequently

ignored, and is to be included in a bundle of evidence to the EU

Ombudsman that the EU Cosmetics Commission discriminates against

evidence provided by Cropwatch. In any case, the original RIFM work

which the SCCP rubber-stamped in their Opinion, did not distinguish

any botanical verification of the origins of the opoponax commodities

examined, and failed to provide evidence of individual lot

tracking - and therefore the findings of the RIFM work & the SCCP

Opinion should be regarded as scientifically unsafe. This is because

we still do not know specifically which particular species, or indeed

if all of the five possible Commiphora species, commonly known!

as opoponax, contain substances which are allegedly sensitising.

,

It is hoped that the Public Consultation will find in Cropwatch's

favour - but it is felt that basic gaps in the botanical perfumery

knowledge of RIFM/SCCP/DG Ent which lead to administrative errors

must be rectified, and Cropwatch is now asking how you are going to

ensure that such repeated mistakes like this are prevented in future,

in the interests of regulatory professionalism. Damage has already

been caused to the Peru balsam industry because of previous errors by

Brussels personnel. Cropwatch has already privately indicated, in an

unpublished letter to Head of Unit, Sabine Lecrinier (08.01.07), the

following points with regards to incorrect botanical nomenclature in

the Cosmetics Inventory:

 

" Thank you for taking note of the Cropwatch criticism of the

Cosmetics Inventory following the disastrous lack of authority shown

in the SCCNFP/0389/00 1st update - we are keeping a watching brief on

further SCCP updates in this area. Due to poor levels of scholarship

in the previous SCCP Opinion, any further scientifically poor

listings will, in future, be notified to international professional

botanical organisations by Cropwatch, for possible censure by the

academic community worldwide. This is primarily because it is simply

not acceptable for an EU expert body to work to internationally

recognised (IUPAC) standards in chemistry, but not in botany, just

because the members of the SCCP have no apparent demonstrable

botanical expertise in this area. "

 

The above letter subsequently received a minimal response from

Barbara Mentre of the Cosmetics Unit, with almost no points answered

- further ammunition for our case of discrimination against Cropwatch

by EU Cosmetics Sector officials. [Even if the SCCP are acting on

some of Cropwatch's botanical corrections of the Cosmetics Inventory,

it is clear that these have not filtered through to those responsible

for organising the data in the Public Consultation].

 

Regards,

 

Tony Burfield

on behalf of Cropwatch

www.cropwatch.org

 

Anya McCoy

of Natural Perfume http://anyasgarden.com

Artisan Natural Perfumers Guild http://artisannaturalperfumers.org

Natural Perfumers Community Group