Private communication from Tony B - citrus, ethanol, 40th amendment

[Guest guest]

I got this the other day, and in the hoo-ha over the cropwatch

newsletter about citrus oils being restricted, forgot to post this.

 

40th Amendment. I wrote to many of the worlds principle perfumery

organisations in the last few weeks asking them to boycott the 40th

Amendment and obtained details of who attended their meetings. The

findings of this exercise will be presented in the next Cropwatch

Newsletter, where we will present evidence that voluntary adherence

to perfume regulation is now just a sham. Basically in the 42nd

Amendment a time concession to small companies (SME's) is made - so

we can jointly claim a small victory - but this singles out SME's as

being unable to achieve the industry norms (i.e. adherence to the

40th Amendment) and so will work against them. The only instance in

which it might work is for micro-companies, where (in the nicest

possible way) the fragrance customer base may not fully comprehend

the issues around the 40th Amendment.

 

The Proposed Banning of (some?) Citrus Oils in Cosmetics. The word on

the street in Brussels is that a modified SCCP Opinion on limiting

FCF's to 1 ppm in finished cosmetics will go through at least for a

number of identified FCF's. Trying to prevent this outcome, his has

been a major exercise for Cropwatch in the past couple of weeks and

we hope to bring out an short newsletter/update shortly. Without

pre-empting the findings in the update, Cropwatch is in negotiations

with several of the worlds leading citrus producers and users, and

meetings have been arranged in a few instances. Here below is the

initial contact letter which Cropwatch has been circulating - any

help in contacting citrus oil producers appreciated!

 

Ethanol in Cosmetics - Further Developments. Here is an edited

extract from something I put on a soapers group as an update to a

piece I wrote on Aromaconnection on banning ethanol in cosmetics -

see Feb 28th 2007 entry at

<http://www.aromaconnection.org/regulatory_issues/index.html>http://www.aromacon\

nection.org/regulatory_issues/index.html.

" CMR 1 & 2 substances are banned in cosmetics under Directive

67/548/EEC. So it (banning ethanol) hasn't been batted off for the

flavours industry solely to worry about after all (although worried

about it they are - some whiskey distilleries are currently

organising panic meetings). Now its up to the industry lawyers,

perhaps, to find clever reasons for not classifying ethanol as a CMR

substance, or excluding them from the Directive. No doubt they will

find a way 'round, but if they can for ethanol, why not for other

natural ingredients - citrus oils for example (see above).... The

problem is that the regulators can see why banning ethanol in

cosmetics/perfumery would be disastrous, but their (the regulators)

perfumery education doesn't extend to them also understanding that,

say, banning bergamot oil, a unique bridging substance between herbal

& citrus notes, as well as blending with florals, ambers & mossy

accords. would be a blow from which the perfumery art would never

recover. The problem is, as you can see, industries are controlled by

regulators who have no experience of the trades they are regulating,

and these trades are policed by regulatory affairs managers who's

continued employment depends on applying the regulations, rather than

fighting them as the nonsense they are.

OK that'll do for the moment.

 

Here's Tony's letter to the citrus producers:

Here's the letter to citrus manufacturers:

 

" Forgive me contacting you out of the blue - but I'd be interested to

know what you think about the (2001) SCPP Opinion to limit

furanocoumarins to 1ppm in cosmetics? Any comments you may have can

remain confidential between us.

 

According to IFRA's recent information Letter IL 722, DG Entr. will

ask the SCCP for an updated Opinion on that 1ppm of psoralen,

bergapten (5-methoxypsoralen), xanthotoxin (8-methoxypsoralen) and

angelicin, determined either individually or in combination, is safe

in cosmetics. New and separate data for isopimpinellin & bergamottin,

we understand, is also being considered by the SCCP, but data

oxypeucedanin and epoxy-bergamottin is not being presented,

apparently due to lack of test material. The opinion on the street,

that the likelihood that the SCCP Opinion limiting FCF's to 1 ppm

will go through into a Directive, is high.

 

Reading between the lines, this has put IFRA in the situation of not

knowing quite what to do, and they have warned members in IL 772 that

several (citrus?) materials may eventually disappear from

cosmetics/perfumery usage. Many of us aromaphiles have little

sympathy for IFRA's position, as it was this organisation that

previously introduced a 15ppm limit on furanocoumarins in finished

perfumes (which few cosmetic/fragrance companies seem to adhere to).

 

Cropwatch would like to rally the citrus oil producers in some sort

of defence against these measures - the perfumery industry will never

recover if these key materials are eliminated. IFRA is seeking

information from citrus producers regarding the possibility of

reducing furanocoumrin levels in their citrus (and other) products.

However Cropwatch previously had an assurance from Sabine Lecrenier,

Head of the Cosmetics Unit at Brussels, that an SCCP Opinion with

divisive policies/legislation, which effectively discriminated

against the economic means of small (citrus) producers, would not go

through to regulation. The sequence of events since Lecrenier's

statement does not particularly suggest that this eventuality will hold up.

 

It is only the aroma material producers, or perhaps the

fragrance-buying public, via the application of negative feed-back on

fragrance producers, who can do anything here. We can write-off the

perfumery & essential oil organisations, who have become so

emasculated by EFFA's & IFRA's increasingly authoritarian insistence

that they adhere to their Codes of Practice, which they think will

ensure 'perfume safety'. But as one citrus oil distributor said to me

this morning, where are all these perfume victims, so affected by

FCF's in retailed fragrances? "

 

I'd be pleased to hear if you have any comments.

 

Best regards,

 

Tony Burfield

Cropwatch.

www.cropwatch.org

 

 

The latest newsletter isn't up on the cropwatch site yet, but here it

is on the Guild site:

http://www.artisannaturalperfumers.org/news.htm

 

of Natural Perfume

Artisan Natural Perfumers Guild http://ArtisanNaturalPerfumers.org

Natural Perfumers Community Group

 

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