Citrus Oils set to disappear in Cosmetics -- from Cropwatch

[Guest guest]

I hope this comes through in a readable form. The

letter Tony attached is in .tif format, and that

cannot. Dadsjuana tried to submit this earlier

today, but the forwarding of this, which I

believe was done on a Mac, just became gibberish,

unreadable. If this does not post to the group

in a readable form, I'll be putting it in the Files in a day or two.

 

Citrus oils set to disappear in cosmetics

 

 

 

Cropwatch Newsletter April 2007

 

 

 

Citrus Perfumery Ingredients Now Set to Disappear.

 

Tony Burfield April 2007.

 

 

 

§ 1. Executive Summary.

 

Banning citrus oils from perfumes would be a

drastic move from which perfumery would never

recover. But according to a communication written

on 4th April 2007 by Sabine Lecrenier, Head of

Unit for the Cosmetics Sector to Cropwatch

(attached to this newsletter), this unthinkable

step is precisely the outcome which the EU

Cosmetics regulators have decided upon – by

placing a restriction on certain furanocoumarins

(FCF’s) such that their content in finished

cosmetics cannot collectively exceed more that 1

ppm, in line with the previous recommendations of

the 2001 SCCP Opinion & SCCP Opinion 0942/05. In

our view, this once more confirms the Brussels

‘anti-naturals’ fragrance ingredients machinery

is operating in over-drive, becoming a vendetta of scandalous proportions.

 

 

 

In spite of the fact that this is potentially the

most serious situation that the perfume trade has

ever faced, any open resistance to this move is

likely to be weak. The (confessed trade

independent) SCCP / DG Entr. personnel do not

have an authoritative overview of the fragrance

industry and do not fully comprehend the

implications of the regulations that they help

impose on the cosmetics trade. IFRA and EFFA are

part of the problem too, becoming alarmingly

right-wing/authoritarian and threatening member

companies with severe measures if they do not

follow their Codes of Practice, which feed into

the EU Cosmetic Directives. A non-scientific

Cropwatch survey of the attendance of

professional perfumery organization meetings

(<?xml:namespace prefix = st1 ns =

" urn:schemas-microsoft-com:office:smarttags " />UK

/ US) shows a membership increasingly dominated

by regulatory affairs personnel rather than

perfumers – the significance of these measures on

the perfumery art will be totally lost on these

types of technical employees. And as we have

previously proven, the trade press is largely

loyal to IFRA and panders to the interests of

corporate dinosaurs, and not to interests of

cosmetics consumers. The trade essential oil

organisations have angered many essential oil

producers by their obedient submission of

technical data to EU regulators, which has

enabled progressive forms of restrictive

legislation to be passed against the very trade

that they are supposed to represent.

 

 

 

It may very well be the case that industry as a

whole chooses to ignore this legislation as being

completely destabilising & unworkable, but

Cropwatch has to work on a worst possible

scenario, and therefore we consider that it is

only the sophistication of the fragrance consumer

lobby itself which offers any real hope of true

resistance & reform. Cropwatch is therefore

launching the ‘Campaign for Real Perfume’ any

hoping for consumer support to counteract what we

have to see as philistinic regulatory crimes against the perfumery art.

 

 

 

§ 2. A Brief Historical Note on Citrus Oils in Fragrances.

 

Citrus oils are absolutely vital ingredients in

perfumes. Citrus colognes were originally

constructed by immersing various plant materials

in alcohol, the alcohol concentrated by

distillation, distilling the major part off

(often down to one third of the original bulk),

and citrus and other oils were added e.g. as in

the popular fragrance type: Millefleurs. These

early perfumes were somewhat unstable and prone

to oxidation due to the high monoterpene

hydrocarbons content (Simonis 1984), but the

development of concentrated & terpeneless citrus

oils was said to overcome these problems.

 

 

 

Unless specifically treated, many essential oils

derived from species of the Apiaceae & Rutaceae

(including citrus oils, angelica & a few others)

will contain a furanocoumarin (FCF) content –

apparently even those labeled “FCF-free”.

Although FCF’s may be associated with beneficial

properties in specific situations, there are

concerns that some may be associated with

photo-toxic & , some suggest, possibly

photo-carcinogenic reactions, although this

situation is hardly new. To our certain knowledge

people have been putting perfumes containing

FCF’s on their skins for more than 600 years –

for example the lemon peel & angelica containing

(and therefore FCF containing) Carmelite Water

was formulated in 1379 at Abbaye St. Juste.

Certainly by the mid 1500’s citrus oils were

widely produced & used for fragrancing such that

individual fragrances based on mixture of citrus

oils were developed (e.g. Eau de Carmes), and by

1709 we have the example of major citrus oil

perfume deployment in Eau de Cologne (“4711”) by

Gian Paolo Feminis, the story of which needs no

introduction from us. Slightly later, the use of

citrus oils is demonstrated in Eau Impériale

(Guerlain 1861) – created by Guerlain for

Emperess Eugenie (wife of Napoleon III). Nowadays

many publications recount the early uses of these

materials in the perfumery art, such as that of

Burfield (2002) & Williams (2004). Felix

Buccellato wrote an excellent review of the

importance of citrus oils to the development of

Western perfumery over the last eight of nine

decades which can be found

at

<http://www.fmi.bz/citrus_oils_in_perfumery.htm>http://www.fmi.bz/citrus_oils_in\

_perfumery.htm.

Cropwatch attempted to put together what we

commonly know about the FCF content of fragrance

ingredients at

<http://www.cropwatch.org/newslet3.htm>http://www.cropwatch.org/newslet3.htm.

 

 

 

§ 3. The Regulators Plot Together.

 

According to IFRA's recent information letter (IL

722) of March 16th 2007, DG Entr. will ask the

SCCP for an updated Opinion on whether 1ppm of

the furanocoumarins psoralen, bergapten

(5-methoxypsoralen or 5-MOP), xanthotoxin

(8-methoxypsoralen or 8-MOP) and angelicin,

determined either individually or in combination, is safe in cosmetics.

 

 

New and separate data for isopimpinellin

(5,8-dimethoxypsoralen) & bergamottin, it is

understood, is also being considered by the SCCP,

but data for oxypeucedanin and epoxy-bergamottin

is not being presented, apparently due to lack of

test material of the appropriate purity (read

this as the industry failing to cough-up enough

of the appropriate purified samples for studies).

 

 

 

§ 4. Sabine Lecrenier Reports to Cropwatch.

 

§ 4.1 Lecrenier for the EU Cosmetics section

reports in her 4th April 2007 letter to Cropwatch

(attached), that the intention to restrict

bergapten (5-MOP) and xanthotoxin (8-MOP), either

individually or additively, to 1ppm in finished

fragrances, even where naturally present, has

already been decided. This is a breath-taking

decision which will, for example, affect many

suppliers & end-users of expressed, distilled and

supposedly FCF-free citrus oils.

 

 

 

§ 4.2 Lecrenier also reports that the same

remarks also apply to psoralen and angelicin, although:

 

 

 

“…for angelicin, we may consider it differently

in view of the results of the public consultation

of the Committee on herbal medicinal products on

this substance. I enclose the hyperlink to this

consultation

(http://www.emea.eu.int/pdfs/human/hmpc/31791306en.pdf)

A new consultation of the scientific committee may thus be necessary.”

 

 

 

[Cropwatch comments: This is surely ‘clutching at

straws’ – the above cited report merely reflects

on the lack of knowledge, understanding & studies

in the photo-carcinogenic area, and on the

situation wrt taking (daily) oral herbal

preparation(s) containing FCF’s – which cannot be

directly comparable to an occasional or a one-off

dermal fragrance application containing FCF’s].

 

 

 

§ 4.3 Lecrenier also refers to new studies by

‘part of the industry’ on isopimpinellin &

bergamottin which are apparently being presented

by April end 2007, although we are apparently not

allowed to be party to them [the SCCNFP

previously gave an Opinion (SCCNFP 0743/03) on

bergamottin, which concluded there was

insufficient data on photo-toxic potential to come to an opinion].

 

 

 

§ 4.4 We are also informed by Lecrenier that

oxypeucedanin & oxy-bergamottin are also to be

banned unless Cropwatch or other organization can

provide data indicating safe use by April end (2007).

 

 

 

§ 5. Cropwatch’s Reaction to Limiting FCF’s in Cosmetics.

 

The SCCP seems to apply different objectivity

criteria in executing its’ various Opinions,

presumably for undisclosed political reasons. The

SCCP (2001) Opinion on FCF’s was widely

dismissed, amongst other things, for failing to

distinguish the different properties of linear

FCF’s (xanthotoxin, psoralen etc.) from angular

FCF’s (e.g. angelicin). The further SCCP Opinion

0942/05 is a substandard & disappointing rag-bag

of previous assumptions & presumptions, not

universally endorsed by all workers in this area.

(e.g. bergapten is ‘probably carcinogenic’ (IARC

1987), an assumption not based on any robust

evidence). One of the main features of the

0942/05 document is a listing of FCF occurrence

in some (mainly citrus) products, but the data is

not comprehensive over the total range of

FCF-containing (citrus) ingredients available to

perfumers i.e. does not cover the various

mechanically prepared single expressed oils

(pellatrice, sfumatrice, scorzella, machine

process or whatever), the various concentrated

(deterpenated) oils, terpeneless oils,

sesquiterpeneless oils, solvent extracted oils,

distilled oils etc. etc. Most importantly the

Opinion is embarrassingly short of any actual

proof whatsoever of in vivo human FCF

photo-carcinogenicity. Further, its conclusions

are at variance with those of other workers

Chouroulinkov et al. (1989), Dubertret et al.

(1990), EMEA (1990) etc. as pointed out

previously by Cropwatch. No single case study of

photo-carcinogenicity from the application of FCF

containing oils e.g. expressed bergamot oil, has

yet been identified (as many observers have

pointed out in mails to Cropwatch). This SCCP

Opinion therefore is rejected by Cropwatch as

being not of a standard of evidence sufficient to

support the restriction of FCF’s to 1ppm in cosmetics.

 

 

 

Bear in mind also that a watershed for the

precautionary principle approach has been reached

over a previous SCCP Opinion on Tea Tree Oil

(SCCP Opinion 08438/04) which predicted tea tree

oil was not safe in cosmetics – now proven

completely incorrect by an extensive analysis of

end-user data. Having proven that this predictive

methodology doesn’t work, Ian White (Chairman of

the` SCCP, and in Cropwatch’s opinion, well

overdue for replacement) has to halt these flawed

SCCP Opinions right now, and a better, more

reliable evaluation system for the toxicological

assessment of fragrance ingredients has to be devised.

 

 

 

It is quite clear, too, that our supporters

believe these measures are totally ‘over the

top’. Bergamot oil for example has an almost

ubiquitous use in fragrances (see below) so where

are all the predicted adverse fragrance end user

reactions? We haven’t actually got a citrus oil

derived photo-chemical cancer epidemic on our

hands - quite the opposite - we have a near zero

reporting of adverse reactions from modern

citrus/FCF-containing perfumes. Others supporters

point out that a simple measure such as a

labeling requirement would have sufficed instead

of an unworkable 1ppm limit – after all it works

for thousands of clients receive aromatherapy

body massages annually, where up to 2.5% of

citrus oils in carrier oils are used. Clients are

merely instructed to strictly avoid actinic light

for the next 12-24 hours. There seems, therefore,

no need to further undermine the natural

aromatics sector in such a heavy-handed manner by banning crucial ingredients.

 

 

 

In conclusion, and although this may sound a

little melodramatic, it is hard not to put these

unsound regulatory decisions on furanocoumarins &

their effects on the fragrance trade in the very

strongest of condemnatory terms. On balance, we

have to consider these decisions as to tantamount

to regulatory philistinism, and we cannot dismiss

them as anything less than a crime against the perfumery art.

 

 

 

§ 6. Cropwatch’s Position & Further Action on FCF’s.

 

You will remember that Cropwatch had previously

established (see

<http://www.cropwatch.org/newslet3.htm>http://www.cropwatch.org/newslet3.htm)

that many, if not most, perfumers are unaware of

the FCF contents of their ingredients, and they

are not helped by the ingredient (citrus oil)

producers, who often do not know either. We also

established that leading perfume chemists even

argued about whether FCF’s were steam distillable.

 

 

 

§ 6.1 Cropwatch had previously pointed out to the

Cosmetics Head of Unit in Brussels that removal

of FCF’s in citrus oils was not affordable

technology for many small essential oil

producers, and Cropwatch received the following

concrete assurance on this matter from Sabine

Lecrenier (written on 11th Dec 2007 for the EU Cosmetics Commission):

 

 

 

“… Lastly regarding furocoumarins, no decision

has been taken at this stage regarding the

implementation of the SCCP opinion 0942/05. My

services are still considering the matter taking

into account your remarks and we will keep you

informed regarding developments. Furthermore, if

a restrictive measure would be envisaged, a

public consultation, via our website, on economic

impact would need to be carried out. that because

of this threat of financial discrimination, the

measure to limit FCF’s would not go through.”

 

 

 

We are unaware, or perhaps may have missed the

notification of any public consultation on this

issue (?), but the sequence of events since

Lecrenier's mail had not particularly convinced

us that this assurance on the grounds of

financial discrimination was going to hold up.

Furthermore, there is no mention of this public

consultation eventuality in Lecrenier’s letter to Cropwatch of 4th April 2007.

 

 

 

§ 6.2 Further Action. Cropwatch has recently

written to a number of leading citrus oil

producers and end-users and will be meeting with

a number of these over the coming weeks. It

appears that the reported EFFA position (that

manufacturers will be able to produce FCF free

oils to the required limits) is an option only

open to the economically privileged producers,

and can be safely dismissed as not being a

universally applicable solution. Cropwatch will

be supporting those producers who cannot afford

the technology to produce FCF-free oils to the

standard demanded, and has written to the FAO and

the WHO to ask if financial assistance for citrus

producers will be available for those producers

who are potentially economically discriminated

against by this particular EU policy. We will be

looking to see what further action is possible

against these unfair prospects.

 

 

 

§ 7. The Importance of Citrus Ingredients to Perfumery: Spelling It Out.

 

Frerot & Decorzant (2004) of Firmenich somehow

predicted in advance that the EU would limit

FCF’s to 1ppm (how did they know this was going

to happen? – we were sold a different story), and

presented a published paper quantifying FCF’s in

citrus products using sophisticated analytical

technology that many small citrus producers are

unable to afford - HPLC coupled with UV,

fluorescence, and mass detection. Sure enough,

the SCCP Opinion 0942/05 then conveniently cites

the Frerot & Decorzant (2004) paper as the way to

assess FCF’s in essential oils. Cropwatch, with

its’ watchdog’s hat on, is extremely worried that

this is yet another example of an emerging

discriminatory technical divide between the

corporate dinosaurs and small producers, and the

situation might involve collusion between big

business and EU lawyers to suit their individual

positions. This eventuality, of course, would be

working against the interests of free competition & trading within the EU.

 

 

 

Meanwhile here are some brief notes & indications

on how absolutely vital citrus ingredients are to

perfumery (N.B. this is not an exhaustive FCF

containing ingredients list – see

<http://www.cropwatch.org/newslet3.htm>http://www.cropwatch.org/newslet3.htm

for a more comprehensive account).

 

 

 

§ 7.1 Bergamot Oil. According to the SCCNFP

07403/05, ‘bergamot oil’ – type & origin not

specified - contains 2.2% bergamottin, but is

also notorious` for its bergapten content (0.3%

within a total FCF content of 3.0%: ref Forlott,

unpublished data). Bergamot oil also contains bergaptol.

 

Suppose for a moment that bergamot oil might be

effectively banned as a perfumery ingredient, as

currently seems more than possible. Bergamot oil

has both a citrus & herbaceous character and

mixes seamlessly with the palette of citrus oils

and many herbaceous notes especially lavender &

basil, making it particularly useful in masculine

fragrances. It is also is useful in fresh top

note accords in floral fragrances. It also mixes

well with mossy and ambery notes, and because it

has this herbal dimension to its character, it is

the cornerstone of the eau de cologne & chypre

perfumes. Its place in perfumery is unique. Its

employment in male fragrances is virtually

ubiquitous and represents a lot of the fresh

fragrance character - examples CK One (Calvin

Klein 1994), Cool Water (Davidoff 1988), Eau

Savage (Dior 1966), and in female fragrances it

is also virtually ubiquitous as part of top note

accords e.g. Chanel 19 (Chanel 1970), Anais-anais

(Cacharel 1979), Rive-Gauche (Y. Saint-Laurent

1971), Obsession (Calvin Klein 1985). Bergamot

oil is also of course used to flavour Earl Gray

tea – but no doubt suitable reasons will appear

to prevent this flavoured beverage from being

banned. However, in perfumery, bergamot oil is not capable of being replaced.

 

 

 

§ 7.2 Bitter Orange oils. Contain ‘large amounts’

of oxypeucedanin (Naganuma et al. 1985). The main

application for bitter orange oil is in eau de

colognes where it imparts a sharp freshness to

the citrus cologne character, and generally in

citrus accords, for the same sort of effect on the top-notes of fragrances.

 

 

 

§ 7.3 Lemon oils. Cold-pressed lemon oils vary

widely in their FCF content. Naganuma et al.

(1985) principally found begapten (range 4 to 87

ppm) & oxypeucedanin (range 26 to 728ppm) to be

responsible for the photo-toxicity, indicating

that the phototoxic potential of oxypeucedanin

being a quarter of that of bergapten. Whereas

bergamot oil has a middle & top note presence,

lemon oil is a wonderful fresh top-note material

used widely in men’s fragrances e.g. Paco (Paco

Robanne 1996), Kenzo pour Homme (Kenzo 1991),

often in combination with other citrus oils (such

as bergamot, lime & mandarin). Lemon oil is also

used in women’s fragrances; it is widely used for

its supremely fresh natural character in personal

care & toiletry products, particularly in foam baths, shower gels & shampoos.

 

 

 

§ 7.4 Lime oils. According to the SCCNFP ‘cold

pressed lime oil’ – type & origin not specified -

contains 2.5% bergamottin. However Naganuma et

al. (1985) indicate oxypeucedanin as the

principle FCF. Minor FCF’s such as

oxypeucedaninyl acetals in Key Lime type A or

oxypeucedanin methanolate are still in the

process of being characterised in processed oils

(Feger et al. 2006). Lime oil expressed can be

used in perfumery to add notes to eau de cologne,

straight citrus blends for foam baths etc.,

washing up liquid perfumes, men’s fragrances,

although washing up liquid and foam fragrances

can often be constructed with distilled lime oil.

For example Tommy (T. Hilfinger 1995) contains

bergamot, lemon, lime, mandarin & grapefruit, and

Eau de Patou (J. Patou) contains lemon & lime as

well as bergamot & mandarin in its fresh citrus

complex. Lime oil blends well with other citrus

oils particularly bergamot and lemon, also with

lavender and aromatic herbal notes such as

armoise and as such is used frequently in men’s’

fragrances. Lime is usually used in its cheaper

forms (lime terpenes, lime oil washed q.v.) in

toiletries and household fragrances. Lime oil in

not often used now in soap & detergent perfumery

because of its’ poor stability and has been

superceded by fragrance chemicals with lime odour

profiles such as dihydromyrcenol (Burfield 2007).

 

 

 

§ 7.5 Grapefruit oils. Cold pressed white

grapefruit oils contain up to 1.5% FCF’s (mainly)

including bergamottin. Some varieties of

‘Sweetie’ grapefruit oils also contain FCF’s.

White grapefruit oils have a number of small

applications in perfumery, including uses in male

fine fragrances for citrus theme top notes and

generally minor application in citrus cocktail

perfumes, although since it has been ten to

fifteen times more expensive than orange oil in

recent years, these uses have been restricted.

The cheaper ‘Sweetie’ Grapefruit oils have been

used by some perfumers as a substitute for white

grapefruit oils, but annual production volumes are limited (Burfield 2007).

 

 

 

§ 7.5 Mandarin oils. Cold-pressed mandarin oil

contains 250 ppm bergapten: IFRA. Mandarin oils

are used in perfumery for top notes in fine

female ­fragrances, and in large amounts in male

fragrances to produce fresh notes, particularly

in combination with woody accords e.g., Dune for

Men (Dior 1998), Freedom for Men (Hilfiger 1999).

Terpeneless mandarin ­oil was especially prized

in perfumery for its aldehydic notes, but

nowadays ­is an extremely expensive perfumery

material (and probably virtually unusable because

of the new restrictions on methyl-N-methyl

anthranilate). In flavours it has­ considerable

usage, especially in liqueurs, chocolate and

baked products. Italian mandarin oils are made

from fruits of varying ripeness­ giving rise to 3

basic oils: green, yellow, and red, but

Argentinean mandarin oil ­is only made from ripe

fruit, and so is reddish-orange (Burfield 2007).

 

 

 

§ 7.6 Tangerine oils. Cold-pressed tangerine oil

contains 50ppm bergaptene (IFRA). Perfumery uses

are as for mandarin oil – in any case, many

unscrupulous traders pass one off as the other to non-discerning customers.

 

 

 

§ 7.7 Angelica oils. Academic studies of lab

prepared root oils of Angelica archangelica L.

ssp. archangelica var. sativa (Miller) Rikli

reveal the presence of the angular

furanocoumarins angelicin & archangelicin, as

well as lesser amounts of linear furanocoumarins.

Solvent extracts (often passed off as essential

oils) contain angelicin, bergaptene, imperatorin,

oxypeucedanin hydrate, xanthotoxin and

xanthotoxol. However, overall evidence for (any)

FCF content in commercial angelica root oil

qualities from various species & origins is

conflicting (see

<http://www.cropwatch.org/newslet3.htm>http://www.cropwatch.org/newslet3.htm).

Angelica qualities (root or seed oils of various

geographic origins & species, solvent or CO2

extracts, absolutes etc.) are not widely used in

perfumery, and their power is such that when they

are employed, they are generally present at

relatively low levels e.g. 0.1%, rarely more.

However angelica oil has been used to good effect

in chypres to enhance spicy peppery accords; and

it also finds some uses in masculine fougeres.

Angelica oil blends well with many aromatic raw

materials woody including patchouli, vetivert and

clary sage, and many workers consider that this

property is, in part, due to synergistic effects

imparted by the macrocyclic lactones (Burfield 2007).

 

 

 

§ 8. IFRA’s Position on FCF’s.

 

Reading between the lines, IFRA do not seem to

appear to know quite what to do about FCF

containing perfumery ingredients, and they have

warned their members in Information Letter IL

772, that several (presumably, largely citrus)

materials may eventually disappear from cosmetics

/ perfumery usage. Many of us aromaphiles have

little sympathy for IFRA's position, especially

after the Prance Internet article which seemingly

revealed IFRA’s true colours, confirming IFRA’s

support for synthetics over naturals, an article

which was subsequently rather hastily withdrawn

(for references see Cropwatch Newsletter March

2007). After being tarred with an anti-naturals

reputation, IFRA now appear anxious not be seen

as responsible for this current demise, and

appears to be engaging in a blame-shifting

exercise – by suggesting a ‘pow-wow’ between

(citrus) producers and end-users as a way of

deciding a strategy for the FCF situation. But

many of you will remember that it was the IFRA

organisation that got us into this situation in

the first place, by introducing a Standard

imposing a 15ppm limit on FCF’s in finished

perfumes on 1st Dec 1996 (which few

cosmetic/fragrance companies seem to either been

aware of, or have subsequently adhered to).

 

 

 

§ 9. ‘The Campaign for Real Perfume’ is launched.

 

In a world where the perfume industry is now run

by regulatory affairs managers and lawyers,

feeding off the results of dermatologists &

toxicologists, and the trade media dances to the

tunes of the regulators, how can the perfume

consumers demand non-synthetic perfumes and avoid

all the disappointing regulatory-conformist

remakes of established conventional perfumes (for

example Guerlain’s reformulation of Mitsouko,

first minus the nitro-musks and now, more devastatingly, minus the oakmoss).

 

 

 

We have to remember that some of us have been

here before. In the UK, the world’s most popular

beverage (beer) was under threat from the big

brewers set to maximize profits by producing a

bland processed product designed to keep for

weeks in a pubs & clubs setting, stored in metal

kegs, and dispensed under pressure with carbon

dioxide. The ‘Campaign for Real Ale’ was launched

in the 1970’s and proved successful in convincing

the public that real traditional cask-conditioned

ale, kept in cool cellars, and dispensed by

beer-engines mechanically hand-pumped by

publicans was the superior form of beer.

 

 

 

It is not an inconceivable step to imagine that

this same rationale could be applied to perfumes,

as a result of consumer back-lash, so that

‘perfume’ should be composed of wholly natural

ingredients (natural perfumes), or a mixture of

naturals and synthetics (conventional perfumes).

Natural ingredients should not be discriminated

against by legislators who are over-represented &

over-influenced by career toxicologists,

dermatologists and regulatory affairs managers,

nor should we have a situation where legislators

have the continuity of their own careers

uppermost in their minds when rubber-stamping

precautionary principle-based health & safety

legislation which has neither been tested nor

statistically proven at the user-end.

 

 

 

These steps would enable us to get back to

producing & marketing crafted real

perfumes. Please help by contacting Cropwatch

at <infoinfo

 

 

 

References.

 

Burfield T. (2002) Natural Perfumery Module 1. AIA UK private publication.

 

 

 

Burfield T. (2007) Natural Aromatics – Odours &

Origins edn 2. AIA private publication. 2007.

 

 

 

<?xml:namespace prefix = st2 ns =

" urn:schemas:contacts " />Chouroulinkov I., Lasne

C. & Nguyen-Ba (1989) “Study with 5-MOP, bergamot

& Bergasol in mouse skin carcinogenicity tests.”

In Psoralens: Past, Present & Future of

Photochemoprotection & other biological

activities. Eds: T.B. Fitzpatrick, F. Forlot,

M.A. Pathak & F. Urbach pp345-355. John Libby Eurotext. Paris.

 

 

 

Dubertret L., Serraf-Tircazes D., Jeanmougin M.,

Morliere P., Averbeck D. & Young A.R. (1990)

“Phototoxic properties of perfumes containing

bergamot oil on human skin. Photoprotective

effect of UVA and UVA substances.” J. Photochem.

Photobiol. B: Biology. 7, 251-259.

 

 

 

Feger W, Brandauer H, Gabris P, Ziegler H. (2006)

" Nonvolatiles of commercial lime and grapefruit

oils separated by high-speed countercurrent

chromatography. " J Agric Food Chem. 22. 54(6), 2242-52.

 

 

 

Frerot E & Decorzant E. (2004) “Quantification of

total furocoumarins in citrus oils by HPLC

coupled with UV, fluorescence, and mass

detection.” J Agric Food Chem. 17, 52(23), 6879-86.

 

 

 

IARC (1987) Monographs on the Evaluation of

Carcinogenic Risks to Humans. 5- Methoxypsoralen

and 8-Methoxypsoralen plus ultraviolet irradiation. Suppl 7, 242-245, 1987.

 

 

 

Naganuma M., Hirose S., Nakayama1 Y., Nakajima K.

& Someya T. (1985) " A study of the phototoxicity

of lemon oil " Archives of Derm. Res. 278, 1, 31-36.

 

 

 

Simonis, Cynthia Clare (1984) “Eau de Cologne

Past & Present” Dragoco Report 4, p113- 121

 

 

 

Williams D.G. (2004) Perfumes of Yesterday Micelle Press, Weymouth 2004.

 

 

 

 

 

Other News: the 42nd IFRA Amendment (the 40th IFRA Amendment Revisited).

 

Details of the 42nd IFRA Amendment (- a

continuation of the immensely complex IFRA 40th

Amendment) can be found

at

<http://www.perfumerflavorist.com/news/6789072.html>http://www.perfumerflavorist\

..com/news/6789072.html.

Although the Cropwatch petition against the 40th

IFRA Amendment is, of course, unacknowledged (but

now appears with 872 signatories see

<http://www.ipetitions.com/petition/ifra40/>http://www.ipetitions.com/petition/i\

fra40/),

it appears that Cropwatch might have won a point

for small businesses (SME’s). This is because

there are some concessions announced on timings

for implementation of this exceedingly complex

and unnecessary piece of technical

hyperbureacracy (the QRA system). Cropwatch

doesn’t necessarily see this concession as

advantageous for all SME’s – since it basically

draws attention to the fact that SME's might be

unable to presently achieve the industry norms

(i.e. adherence to the 40th Amendment) and this

aspect of apparent uncompetitiveness against

larger organisations might well work against

them. The only instance in which it might be

advantageous is for micro-companies, where (in

the nicest possible way) the fragrance customer

base may not fully comprehend the issues around the 40th IFRA Amendment.

 

 

 

Voluntary Regulation of Perfumery now Revealed as Obsolete.

 

As several national perfumery organizations in

the last few weeks have asked their individual

constituent members to submit a Directors letter

from their companies pledging blind allegiance,

sorry, to strictly abide, by IFRA / EFFA Codes of

Practice, or presumably face unstated

consequences, it is clear that any claim of

voluntary adherence to perfume regulation is now

just a sham. So let’s have no more pretence on this issue, shall we?

 

 

 

Tony Burfield, April 2007.

 

Cropwatch – the Independent Watchdog for the Aroma Industry.

 

<http://www.cropwatch.org/>www.cropwatch.org

 

of Natural Perfume

Artisan Natural Perfumers Guild http://ArtisanNaturalPerfumers.org

Natural Perfumers Community Group

 

Natural Perfumery Blog http://AnyasGarden.Blogspot.com/

 

 

 

[Guest guest]

Hi Folks,

 

I suggest that people begin contacting some action organizations that

are focused around the health and natural products industry.

 

Some of them, such as the Organic Consumer's Association:

http://www.organicconsumers.org/ have proven track records when it comes

to organizing enough people to fight stupid legislation such as this

stuff we've been talking about.

 

Here are a couple more links:

http://www.citizens.org/

http://www.nrdc.org/action/

http://www.healthfreedomusa.org/

 

The more people who contact these organizations and ask for them to help

by making these issues action alerts, the closer we'll be to actually

getting something accomplished! THEY have the power in numbers that we

need! So lets get them interested ...

 

*Smile*

Chris (list mom)

http://www.alittleolfactory.com

[Guest guest]

---

In , Christine Ziegler

<chrisziggy wrote:

>

> Hi Folks,

>

> I suggest that people begin contacting some action organizations

that

> are focused around the health and natural products industry.

>

> Some of them, such as the Organic Consumer's Association:

> http://www.organicconsumers.org/ have proven track records when it

comes

> to organizing enough people to fight stupid legislation such as

this

> stuff we've been talking about.

>

> Here are a couple more links:

> http://www.citizens.org/

> http://www.nrdc.org/action/

> http://www.healthfreedomusa.org/

>

> The more people who contact these organizations and ask for them

to help

> by making these issues action alerts, the closer we'll be to

actually

> getting something accomplished! THEY have the power in numbers

that we

> need! So lets get them interested ...

>

> *Smile*

> Chris (list mom)

> http://www.alittleolfactory.com

>

Chris,

Can I take your advice to the perfumery group? Because I know there

are manyu people from that list here, but plenty more there that are

not. So if these people pay attention to that, when we unite one

plus one is much more than two.

It might work

Can I?

Ane*

from Brazil