Cropwatch - Citrus Oil Crisis Deepens - furanocoumarins (FCFs)

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(Please use the Cropwatch link to view the

attached letter mentioned in this report, as this

group does not allow attachments to avoid viruses).

 

Citrus Oils in Cosmetics – The Crisis Deepens.

 

Tony Burfield May 2007.

 

 

 

This a shortened newsletter, whilst Cropwatch

continues to talk to citrus oil producers

worldwide, and discusses possible courses of

action with organisations which we have

discovered are similarly opposed & deeply

concerned about the proposed banning of citrus

ingredients in cosmetics by the EC regulators on spurious safety grounds.

 

 

 

Recap & Update on the Citrus Oil Crisis.

 

Whilst new 2007 perfume industry launches

continue to prominently feature citrus notes,

especially in a new range of colognes, the EC

Cosmetics sector regulators are still taking

steps to effectively prohibit the use of

traditionally prepared citrus oils in fragrances.

In a letter to Cropwatch of 26.04.07, copy

attached, Head of Unit Sabine Lecrenier denies

all FCF’s will be banned, but then goes on to

specify six furanocoumarins (FCF’s) which will

(the list now apparently includes angelicin),

because they are allegedly linked with

photo-carcinogenic potential. These six

(psoralen, angelicin, bergapten, xanthotoxin,

oxypeucedanin and epoxy-bergamottin) are all

found to a greater or lesser extent in the major

citrus oils used in perfumery, and are to be

regulated to 1ppm concentration in finished

cosmetics. The case against the carcinogenicity

of individual FCF’s, as presented in previous

SCCP Opinions such as SCCP 09542/05, remains

scientifically non-robust, and there is a lack of

supporting knowledge, understanding &

experimental & technical data. For FCF’s

occurring in natural aromatic products, matrix

effects & the anti-carcinogenic potential of

other co-occurring substances remain unclear.

 

 

 

The restrictive legislation proposed by Lecrenier

et al. as described above is actually unworkable

since no comprehensive data on the distribution

of FCF’s across the range of perfumery

ingredients, citrus or otherwise, is available in

the public domain, merely scrappy bits of

information. In any case, any minutest health

risk which might be present to fragrance-wearing

consumers is best approached by labeling,

advising the wearer to avoid actinic light for 12-24 hours after application.

 

 

 

Most disappointingly, whilst health risks from

FCF’s in cosmetics remain so minute as to be

virtually incalculable (provided reasonable

precautions are taken), Lecrenier et al. seem to

have completely ignored the catastrophic effect

to the perfumery art of effectively removing

citrus ingredients from the perfumer’s palette,

as outlined in Cropwatch’s April 2007

Newsletter. Many have likened this threat to

culture as a parallel situation to the burning of

books by Nazi-sympathising students on by May

10th 1933, but we have yet to hear anything on

the subject from Brussels, apart from repeated

invitations to submit evidence on ‘the safe use’

of FCF’s in cosmetics. The latter isn’t likely

to happen since the research required is complex,

extensive & time-consuming and requires

sophisticated & expensive equipment & substantial

funding, but because industry has failed to come

up with the appropriate data, it is being

‘punished’ with a blanket restriction (read ban)

on FCF’s in cosmetics. This outcome is a childish

& unprofessional response - we need regulators

who can work with industry at a technical level

to find a way forward in a difficult situation - or resign.

 

 

 

Cropwatch Takes Action.

 

According to our information, its seems to be the

case that no aroma-connected organisation we have

contacted is able to maintain a satisfactory

technical dialogue with the EC Cosmetics sector

regulators, and indeed, leading figures of some

well-known organisations have voiced this fact

publicly at professional gatherings. The problem

is, therefore, not so much what we do about FCF’s

in citrus oils. The problem is what we do about a

non-communicative <?xml:namespace prefix = st1 ns

= " urn:schemas-microsoft-com:office:smarttags "

/>Brussels regulatory machine, which is imposing

unnecessary, costly & unworkable cosmetics regulation.

 

 

 

Cropwatch is therefore carrying out the following courses of action:

 

 

 

1. A copy of Cropwatch’s (longish!) reply to the

latest mail from the Cosmetics Head of Unit (see

attached – & please read) is already forwarded to

the EU Ombudsman. The content not only deals with

the FCF issue, but lists out a number of

Cropwatch’s points & arguments that have been

consistently ignored although we have made some of them several times.

 

 

 

2. We have additionally asked the Cosmetics Head

of Unit for a status report on a promised review

of the SCCP (see mail attached), which Cropwatch

has extensively argued is ‘not fit for purpose’.

 

 

 

3. Cropwatch is currently negotiating with other

aroma-connected organisations to unite on issues

connected with the restriction of natural

ingredients, and lack of technical dialogue with

regulators. Cropwatch is actively seeking to

establish an office, or at least representation, in Brussels.

 

 

 

4. Following on from (3) above, the water is

being tested for a Europe-wide vote of no

confidence in the EU Cosmetics regulators, as

they have failed to take the appropriate measures

& strike the correct balance in ensuring the

safety of cosmetics to the general public..

 

 

 

5. Proposals to launch The Campaign for Real

Perfume, as mentioned in the April Cropwatch

Newsletter, are being circulated to natural

perfumery companies, green-image orientated

cosmetics companies etc., and we are already in

negotiation with interested parties (if

interested please contact Cropwatch at

<infoinfo).

 

 

 

6. Cropwatch staff are now accepting lecturing

engagements on ‘regulatory madness’ issues

surrounding natural aromatic ingredients. So far

the following have been accepted:

 

 

 

12th Sept 2007: 38th ISEO Conference, Gaz, Austria.

 

6/8th Nov 2007: WFFC Meeting, Saddle Brook NJ., USA (provisional)

 

 

 

 

 

All other issues are held over until the next

Newsletter in view of the seriousness of the FCF issue.

 

 

 

Tony Burfield

 

On behalf of Cropwatch.

 

<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/