Fragrance Ingredients as Allergens: Update & Recap

This subject concerns the EU developments with respect to cosmetics and perfumes, but I understand that developments are being monitored by the FDA. There are repercussions for AT here, which will gradually unfold... The subject of allergens in cosmetics & perfumes hit the national news in the UK on 12.12.2000 (Radio 4), concerning the information given to sensitised consumers, especially with regard to perfume labelling. At present as you already may know, in the EC the only requirement under Article 6(1)(g) of ththe Cosmetics Directive, is for "contains perfume" to be indicated on the label, and there is a debate as to whether this is now sufficient. During the past several months there has been some activity on SCCNFP's position whereby several fragrance ingredients are considered allergens, and thereby should be classified as skin sensitisers by the EU's Dangerous Substances Directive. I considered the subject so serious, I devoted 10 minutes of my NAHA workshop in Seattle, on Odour Profiling of Essential Oils, to these very developments. A number of substances that occur in essential oils are covered by this list, including coumarin, eugenol, geraniol, citronellol, cinnamic aldehyde, isoeugenol, anisyl alcohol, benzyl benzoate, d-limonene, farnesol, linalol, benzyl salicylate, benzyl cinnamate etc. There is a proposition that these ingredients would carry changes of labelling with respect to Risk phrases, for example eugenol would carry risk phrases R38-43. As has been previously mentioned, the occurrence of linalol and limonene is ubiquitous in essential oils at least, so the implications are far-reaching. At present the wording of the discussions has been couched in terms of synthetics, but for hazard labelling of perfume mixtures, all ingredients have to be considered i.e. the linalol contained in lavender oil presumably cannot be discounted just because it is part of an essential oil. This change of status will have a direct bearing on perfume compounds produced by fragrance houses, and must have implications for essential oil blends used by AT's as well in my opinion, perhaps for single essential oils as well. (At least this is how fragrance clients of aroma houses are interpreting it). The role of IFRA has also been discussed, following the publication of a proposed list of materials published by SCCNFP of materials not to be used in cosmetic products. These include verbena essential oils and derivatives (i.e. concrete and absolute), alantroot oils and derivatives chenopodium oil and fig leaf preparations (already banned IFRA). The discussion has centred around the need for SCCNFP to bring out a list anyway, since the IFRA regs are already seen by some as perfectly adequate, and have been in operation for 25 years. There has also been some discussion as to whether the IFRA guidelines should be part of the EU-Cosmetics Directive.

I will try and produce another update shortly, showing the confusion in our own camp, where I believe leading aromatherapy commentators (who are not toxicologists nor are well versed in health and safety matters) are giving views and advice, and publishing material contrary to the spirit of these developments. Basically we are now into position taking: I believe we need to discuss and possibly distance ourselves from these individuals, or regulation will be imposed on us. It may already be too late.