Tuesday, August 12, 2014

Updates Moved to Anya's Garden Perfumes

All updates for the Natural Perfumers Guild will be found at http://AnyasGarden.com/blog

Saturday, May 18, 2013

Join the Natural Perfumers Guild and Celebrate Our Seventh Anniversary with Us

The Natural Perfumers Guild will be seven on June 1, 2013, and we'd love to have you join us Our membership categories include Professional Perfumer, Associate, Supplier and Friend. 

We're the only international association dedicated to the promotion, protection and pro-active vision of 100% natural fragrance.  Do you sometimes use some synthetic aromachemicals in your perfumes and have a separate page for them?  We still love the fact you use mostly naturals, and we urge you to consider the Associate category, we only ask you don't display the Guild logo on those pages.  All of our members immediately enjoy access to dozens of vintage perfumery and fragrance books and articles for download - a great perk!

The iconic logo of the Natural Perfumers Guild
The iconic logo of the Natural Perfumers Guild
Artisan perfumery has grown spectacularly in the past 10 years.  Join us and celebrate the next 10 as we move forward in establishing us as a self-regulating organization that works to protect your aromatic business.

Please visit the Guild website and take advantage of the discounted membership fees through June 1st.  If you have any questions, please contact us through the G

Saturday, February 9, 2013

Updated Blog Posts Are Now on Anya's Garden

My blogs are being consolidated on my new Wordpress blog at http://anyasgarden.com/blog Please visit there and subscribe to receive all the latest news about natural perfumery from The Natural Perfumery Institute and the Natural Perfumers Guild.

Friday, June 29, 2012

Allured Books 30% off Summer Sale

SHARE with your perfumer and B&B friends - Allured Books is again offering a great discount to make your summer cool!
Read below:

SUMMER DISCOUNT: 30% through September 15, 2012
Coupon Code:anya30

All Alluredbooks including new ones below. A few sample pages on the title page (links below) will help youdecide if the book is right for you.

Of course - Arctander Perfume and Flavor Materials of Natural Origin- still in stock!

New Books: Coloring the Cosmetic World

Practical Modern Hair Science

Essential Oils Volume 9

Preservatives for Cosmetics (regulatory and preservatives may be of special interest.)

Sunday, June 24, 2012

The Perfume Commune: Natural Perfumers Guild perfumer Alexandra Balahoutis and LeLabo's Fabrice Penot

This is a must-read!  I'm delighted and heartened by this meeting of the minds  Thanks to Cafleurebon for once again scooping everyone and getting these two perfume giants to tell all in an interview.  Plus, there's a giveaway :-) 

Tuesday, June 19, 2012

Nothing New Under the Sun: Adulteration of Essential Oils for Perfumery - Sophisticated Trickery

I was looking for vintage aromatics on eBay, and came across the ad, below. I didn't save the image, so I googled and found the one above.   It seems that the firm of Magnus Mabee and Reynard was sued for adulterating their oils in 1914, and they lost.  The history of the herb and spice trade, and then the essential oils/absolutes/attars trade have historically been rife with adulteration.  I learned about this when as an undergraduate, completing studies in economic botany I found out that the word "sophistication" had its roots in this price-gouging, false-advertising practice.  From Dictionary.com: 


adjective (after what you would expect, i.e., worldly), comes:

3.deceptive; misleading.

and sophisticate -

verb (used with object)
3. to make less natural, simple, or ingenuous; make worldly-wise.
4. to alter; pervert: to sophisticate a meaning beyond recognition. 

Here's the recent ad that sparked this blog post (note: it is no longer viewable on eBay):

Antique Early 1900's Bottle from Magnus, Mabee, and Reynard eBay http://www.ebay.com/itm/ws/eBayISAPI.dll?ViewItem&item=170855254303 

Very RARE very early 1900's bottle This bottle is from the Magnus, Mabee, & Reynard company-Importers and Manufacturers in New York, U.S.A.

This is a 4 OZ Bottle       The label also says Purity and Strength      OIL CAJEPUT Tenth Revision
The bottle was made before the screw on caps and THE ORIGINAL CORK IS VERY MUCH INTACT!.
The history of Magnus, Mabee, and Reynard shows that they were sued in Federal Court "U.S. v. Magnus. Mabee, & Reynard" for adulterating their pure oils.
In court they pleaded guilty and were fined $150. I will include the paperwork. The suit covered the ADULTERATION AND MISBRANDING OF OIL
This is court document F.D. No. 3594 issued March 5th 1914. This bottle of Oil of Cajeput may or may not have been a part of this discovery of misbranding and adulteration
but I will include copies of the documents I found just for conversational sake and for a bit of the history of the company
Cool Bottle, Great Condition, UNIQUE History!

Cajeput is such an inexpensive oil, ditto rosemary.  Imagine the adulteration that can go on in expensive oils like rose, tuberose, etc.  We've all heard stories of s-t-r-e-t-c-h-e-d oils, tweaked and tinkered oils, and outright false advertising.  

This problem is particularly problematic for natural perfumers.  Not only do we have to source the highest grade/best smelling oils, we need to provide our customers and clients with a sense of security and trust that what they are buying is 100% natural.

The natural perfumer needs to train their nose, find reputable suppliers and work diligently to source 100% natural oils.  The recent trend towards buying 'blends' has me particularly concerned.  Whether an accord blend from a supplier, or a scent doppelganger, e.g., strawberry, raspberry, the chance of adulteration by a sophisticate is pretty high.  Hundreds of years of history have proven that the singular oils/herbs/spices are subject to adulteration, so premade compounds seem even more susceptible to this practice.  If the seller can't supply you with a COA (actually this might not cover compounds) or some sort of certified, sworn-to statement about the ingredients, DON'T BUY IT.  That's just me, and I'm really wary of sophisticates ;-)

What do you think? As a natural perfumer or customer, I'm hoping you are diligent and educated about this subject, and that you take care to avoid bunk oils/blends.

Wednesday, May 16, 2012

Definition of Natural Isolates for Fragrance Determined by Members of the Natural Perfumers Guild by a Majority Vote

The Natural Perfumers Guild, the world’s largest organization for natural perfumery, is defining the scope of natural aromatics in accord with the vision of our art. Natural isolates are aromatics consisting of odor molecules from natural materials. Members voted on what constitutes a natural isolate to meet challenges to the "naturalness" of isolates. The Guild position serves to guide members and to assure the public of the Guild’s commitment to high standards of the art of natural perfumery. The Guild's standard exceeds ISO 9235, the International Organization of Standardization publication on standards for aromatic raw materials.

Miami, FL, May 15, 2012 --(PR.com)-- The Natural Perfumers Guild, the largest organization of natural perfumers in the world, is defining the scope of natural aromatic isolates in order to assist its professional natural perfumers as they move forward with their desire to use these scent materials. Natural isolates are single odor molecules that are extracted from natural raw materials using distillation techniques. They are obtained from botanicals such as rose, mint, and citrus. These isolated aromatics can add unique character and lift to natural perfumes.

Not within the definition of natural isolates, according to the Guild, are those isolates that are produced by various laboratory processes, including isolates that are produced using bacteria and fungi, or those created from other processed natural aromatic material (which can include using chemicals to process them).

The Guild Standards Committee worked through an extensive research and exploratory process to define natural isolates to a standard that reflects the mission and philosophy of both the Guild and its members. International standards were examined for the processes used worldwide in defining natural isolates. The Committee was unanimous in approval of the new standard, and the voting body of Guild members approved their recommendation by a 78% vote. This new standard adopted by the Guild exceeds the ISO 9235 standard for natural aromatic raw materials.

The definition of a natural isolate as it applies to the members of the Natural Perfumers Guild states:

A natural isolate is a molecule that was removed/isolated from a natural fragrance material, as delineated by the Guild in its definition of natural perfumery that contains the isolate. Processes that are acceptable for removing/isolation are: fractional distillations, rectifications, and molecular distillations of natural fragrance materials, also as defined by the Guild.

“This was a sensitive and deliberate process, and Guild members had many different opinions,” says Guild President Anya McCoy, "and the final vote was 78% for the least-processed isolates that were closest to the parent raw material." The Guild has updated its 2008 Definition of Natural Perfumery position paper, (which can be viewed at the link in the previous paragraph), to reflect this change. “I will be reformulating my best-selling perfume StarFlower by removing the isolate from it that I had thought was natural (in 2007).”
Contact Information
Natural Perfumers Guild
Anya McCoy


Wednesday, February 1, 2012

Love the Guild - membership event now through February 14th


We'd like to invite you to join the Natural Perfumers Guild during one of our rare membership events.  Now through February 14th, all new members will enjoy 12% off the membership fee, and will be eligible for the drawing of natural perfumery-related gifts. Please visit http://naturalperfumers.com and use the code 1B6DE36B0C for the discount. 

The Natural Perfumers Guild is an international organization dedicated to all aspect of natural aromatics - history, growing, distillation and extraction, supply, regulations, perfumers, associates, suppliers and friends. 

Now in our fifth year, the Guild boasts a dynamic community discussion forum, several committees that address issues and opportunities and high Internet visibility due to several successful and thought-provoking blogging events such as the Mystery of Musk, Outlaw Perfume, Brave New Scents, Joy in January and more. 

Please visit our website and let me know if you have any further questions.  We hope to see you in the Guild!

Thursday, January 5, 2012

The Natural Perfumers Guild Welcomes French Natural Perfume House Honoré des Prés and Nose Olivia Giacobetti as Professional Perfumer

MIAMI, Florida /January 5, 2012

Noted French Natural Perfume Company Honoré des Prés Joins the Natural Perfumers Guild

Honoré des Prés’s perfumer Olivia Giacobetti’s is recognized as attaining Professional Perfumer status in the Guild.

The Natural Perfumers Guild is an international Association dedicated to perfumes and fragrance products made only with natural aromatics. The Guild is pleased to announce that Honoré des Prés, a leading French fine fragrance company, has joined the Guild.

Honoré des Prés was established by Christian David in 2008 with a goal to create 100% natural and artistic perfumes with an urban flair.  All Honore des Prés scents are eco-certified and don’t contain any synthetic aromachemicals, colorants or phthalates. The fragrances are composed by renowned perfumer Olivia Giacobetti. Honore des Prés has been widely lauded for its commitment to the global environment and is a favorite among celebrities such as Jessica Alba and Rachel Zoe.

Honoré des Pré has launched two lines since 2008:

- We Love New York collection: Vamp à NY, Love Coconut and Love Les Carottes.
- “Les Verrines d’Honoré”: Sexy Angelic, Honoré’s Trip, Nu Green and Chaman’s Party.

Since re-establishing the Guild in 2006, President Anya McCoy has seen the list of perfumers grow to an international group of highly-skilled and creative force. “With Honoré des Prés and Olivia Giacobetti now joining the Guild, our heightened presence in the international perfume community is obvious. We welcome them not just due to the obvious beauty of their perfumes, but also because of their commitment to using natural aromatics.”


For more information, contact:
Name: Michelyn and Didier Cholay
Phone:  516 208 2411

Sunday, January 16, 2011

Blog Updates for Anya's Garden Natural Perfumery Institute - now at Anya's Garden blog

We're consolidating all of the blog announcements for Anya's Garden Natural Perfumery Institute at http://PerfumeClasses.com and the Natural Perfumers Guild http://naturalperfumers.com at Anya's Garden blog http://anyasgarden.blogspot.com

Please click on http://anyasgarden.blogspot.com Thank you

Thursday, December 16, 2010

Innovative Perfumery Raw Materials Supplier Ecomaat of Bulgaria has joined the Natural Perfumers Guild

Certified Organic products that include those used in perfumery, aromatherapy, medicine, and the flavorings industries.

In early summer, 2009, I contacted a Bulgarian aromatics supplier, asking for samples of some of their very exotic raw materials.  I was particularly interested in the lilac CO2, and some SCO2 extracts of rose alba, linden blossom and others.  I blogged about the lilac here.  I gave them feedback, and started a correspondence with them, as they were astounded they had gotten feedback - they say people either buy or they never hear from them again.  I felt they were innovative and taking chances, and I support any supplier in the industry who does that.  I do believe the lilac CO2 has a place in aromatherapy - the fleeting nature of the top note wouldn't matter too much if the psychological effect for a jolt of scent memory was all that was needed.

During the evaluation session noted in the lilac SCCO2 blog, the student and I also went through the other materials, and the linden blossom knocked us out.  The honey note was incredible, and since neither of us is familiar with linden blossoms, we took it at face value as a terrifically beautiful material.  So imagine my delight when I read, over the past few months, that Guild founder Mandy Aftel partnered with old Internet buddy perfumer Andy Tauer to create a perfume based on that linden blossom! 

Imagine my greater surprise when, about a month ago, the folks at Ecomaat applied to join the Guild.  It's official now, they're Guild-approved suppliers and we welcome them and their gorgeous materials.  They don't just carry aromatics, they have a number of related products, including a UV-inhibitor I wish to check out.  I'll probably host a Guild group buy so that our members can sample Ecomaat's aromatics, some of which are not listed on the website.  I can easily see linden blossom and the rose alba on the buy. 

They also produce a line of bio-cosmetics under the Spa Maat line, and I must try some of them soon, they look wonderful!

Ecomaat and companies like theirs are to be commended for their pioneering spirit in the aromatics industry.  It's a positive sign that the natural perfumery industry will continue to be supported by this type of supplier who has a spirit to match ours - we will go forward in the 21st Century with even more raw materials than we could have dreamed of just a few short years ago.  I like to dream, and I encourage the folks at Ecomaat to keep those dreams going, beautiful, scented dreams.

Tuesday, December 14, 2010

Natural Perfumers Guild deal: Liability Insurance for the Bath and Beauty Microbusiness Community

I am posting this ad for Stratus Insurance. I was in negotiations with them for both the Natural Perfumers Guild and the Yahoo Natural Perfumery group and the natural perfumery community at large.

They're offering great rates to the Guild, and some folks might want to join to save over non-Guild rates.

For Guild members $1/M/$475
non-Guild: $1M/$525

BTW, if you have a business that is not 100% natural perfumery, you can still join in the Stratus deal. I did negotiate on behalf of the NP community, but I realize many here may use fragrance oils or aromachemicals. You can still get this insurance.

Just make sure you use this page to apply:

At the bottom of the page, if you're not a member of the Guild, check off if you are a member of the Yahoo NP group. I will work with Natasaha Gray to confirm Guild members at this time, since we've had about a dozen new members in the past week and they're not listed on the website yet. In the future, the Guild will have a separate application page. Also, for the non-Guild and non-NP group members, they're going to reword this to be more inclusive in the future, perhaps "Found via a link from Anya's Garden."

For Guild members $1/M/$475
non-Guild: $1M/$525

Limits are as follows:
$1,000,000 General Aggregate Limit
$1,000,000 Products-Completed Operations Aggregate Limit
$1,000,000 Personal and Advertising Injury Limit
$1,000,000 Each Occurrence Limit
$100,000 Fire Damage Limit
$5,000 Medical Payments
For additional $55 they can increase Aggregate and Products to $2,000,000 at any time during the policy.

Monday, November 15, 2010

Giveaway drawing and 20% off Natural Perfumers Guild membership through February 14th, 2010

The Natural Perfumers Guild is having a membership drive. There are vintage and contemporary perfumery books and article included in the membership, plus many prizes to be awarded in a random drawing of the names of the new members. Fees are marked 20% off the usual rate, and can be found at here. The dozens of books and articles that new members can download are listed here.

Deadline to join at the reduced membership rate and be in the drawing is Nov. 30th. Winners may state their choice of prize from the following list:

*Five one-year Basenotes Supporters memberships A $59 value*

Thinking of starting a perfume business? Take part in the chat on the most active perfume site on the Internet. The Basenotes Plus (née Basenotes Supporters) is a great way to connect to the community.

*One Basic Natural Perfumery textbook A $500 value*

This is the textbook for Guild President Anya McCoy's Basic Natural Perfumery course. 349 full-color pages. Winner will be emailed a .zip file of charts, forms, alcohol regs in several countries, MSDS and CoA forms and much more.

*Gift basket from Arly's Naturals A $95 value*

Pamper yourself with these all-natural aromatic goodies.

ARLYS Gold Oval Gift Basket containing:
1- 16 oz. Awakening Shower Gel
1- 4 oz. Bulgarian Rose Hydrosol
1- 10 ml. Serenity Synergy
1- Travel Pocket Diffuser
1- Nefertiti Mini Perfume Bottle
1- Sm. Lavender Sachet

*Catalogues from Mandy Aftel's exhibit at Bendel's NYC *

These illustrated catalogues are collector's items for the natural perfume lover.

*Eden Botanicals Aromatics Kit #2 A $190 value *

These kits are created for Anya McCoy's Basic Perfumery course and contain 59 essences. Winner will be emailed supporting aromatics monographs and information.

Note: this current offer is open to new members only, not renewals.

Sign up here.

Outlaw Perfume Project - A Natural Perfumers Guild Artistic Statement

Anya McCoy here, president of the Natural Perfumers Guild, and I'd like to introduce you to our latest project, Outlaw Perfume.

Soon after I started blogging in 2006, I began to write of the incredibly restrictive and unreasonable "guidelines" of the International Fragrance Association, and the resultant laws from the European Union that effectively killed perfumery.  True, they also ranked some synthetics as "dangerous" (brain disruptions), but the list of naturals, which had been used for centuries without major problems, was overwhelming.  I rarely bother to blog about these issues anymore.  I discovered I was the ONLY perfumer doing so at the time, and it cast a bit of a bitter pall over my blog.  I'd rather be blogging about the beauty and luxury of naturals, so here I am.

I passed the ball on to other bloggers! Nine bloggers will be participating this week, and you can find their links at the end of this post.

They're all insightful, intelligent and passionate about perfumery.  Their readership far outstrips mine, and the Outlaw Perfume project is a great way for them to spread the word about this abomination against natural aromatics. They also get to sample the gorgeous perfumes created by the Natural Perfumers Guild members (disclaimer: I'm the president of the Guild) and offer a giveaway of the Outlaw Perfume on their blogs. 

I've always been someone who challenges authority. In the 60's, I marched for civil rights, against the Vietnam War, and for women's rights.  This IFRA and EU-driven blacklisting agenda against naturals must stop.  Readers, please remember that they're stomping on *your* rights to choose what you put on or in your body.

Anyone can use common sense and not put perfume on skin that is exposed to sunlight, so, there, the photo-sensitization problem of some of the citruses, angelica root, etc., solved ;-)  Think you may be a bit sensitized to oakmoss? Wear the perfume in your hair, or on your clothing, or in a perfume jewelry piece. 

I'm taking photos of vinaigrettes and perfume lockets that I'll share later this week.  They're a beautiful addition to a jewelry wardrobe, and serve a double purpose of gently releasing your perfume. It's all about our choice, and not bowing down to nanny-state governments.  How simple if a warning label, some perfume dabbed in your hair, or on your clothing, or in a piece of pretty jewelry solves this problem.  Or, if you're a daring outlaw like me - wear it on your skin!

The bloggers will be posting their commentaries and reviews Nov. 15 - Nov. 21, 2010.  I'm delighted by the prospect of lively and informed posts by readers.

Participating Perfumers:


Participating Bloggers:


Guild Perfumer's Blogs:


Tuesday, October 12, 2010

A Perfumer's Dream: Arctander's Perfume and Flavor Materials of Natural Origin 35% off through Nov. 15

Hi Everyone:

I'm posting this ad for the Allured folks. The Guild members 
Allured Books are very generous with discounts, and they're 
overly-generous this month! Thanks much to the good folks there 
for offering the  Steffen Arctander book for $226 plus shipping.

This first link to the Arctander book, is time sensitive. The 
coupon for 35% off will expire November 15, 2010
use the code anya35 at checkout.

There is a longstanding general coupon for 30% off that will last 
until December 31, 2010 on all Allured Books. Use the code anya30 
at checkout.

Wednesday, August 18, 2010

Contribute to the Lobbying Effort to Defeat the Safe Cosmetics Act of 2010 - SCA2010

The Natural Perfumers Guild is onboard to help fund the effort to defeat
the Safe Cosmetics Act of 2010. We've registered a recurring monthly donation to the lobbying fund, and I urge you all to do the same because the future of your business is in jeopardy due to the SCA2010.

The Handcrafted Soap Makers Guild has started an advocacy fund so that they may hire a lobbyist to go and fight this Act. See the page at the link below.At the bottom of that page there is a link that connects you to a place where one can make a donation, the smallest increment being $5.00. The donations can be one time, monthly, etc.


Tuesday, August 17, 2010

The Natural Perfumers Guild is Opposed to the Safe Cosmetics Act of 2010

This bill, as written, will effectively destroy all small businesses that produce natural care products, such as natural perfumers, aromatherapists, soapers, etc. The Natural Perfumers Guild is opposed to the passage of this bill, and urges everyone to sign the petition against it at http://www.thepetitionsite.com/1/oppose-hr-5786-safe-cosmetics-act-of-2010/

Due to an ongoing family crisis, I have been unable to blog for some months now, since I have to focus my energies on the healing process for my mother.  On July 27, 2010, I posted a link, via the private forum for the members of the Natural Perfumers Guild, to the petition against the Safe Cosmetics Act of 2010.  Shortly after that, I started a blog on the subject, wanting to state the Guild's position and to link with others opposed to this egregious Act that will put us out of business, but I was pulled off the post by my family obligations - I just didn't have the time, nor could I focus to write a good, informative blog.

Guild Associate Robert Tisserand has graciously allowed me to post his recent blog on the matter here, and on the Guild blog, and use it as the Guild's position on this matter.  Thank you, Robert, for coming to my aid in this time of stress.  Robert helped me co-author a position paper against the proposed 40th Amendment of IFRA in 2007, and I always appreciate his logical and precise way of getting to the heart of the matter and writing in a lucid manner about a subject.

Here is the link to Robert's blog: http://roberttisserand.com/2010/08/the-safe-cosmetics-act-2010/

Here is the text of his blog:

The Safe Cosmetics Act 2010

The Safe Cosmetics Act of 2010 (SCA 2010), now before the House of Representatives, is an inappropriate and seriously flawed attempt to make cosmetics safer. You can read the full text here. The thinking behind it is identical to a bill that was proposed (and defeated on March 1st this year) in Colorado (see Tunnel vision). Both are the brainchild of a group including the Campaign for Safe Cosmetics (SFSC) and the Environmental Working Group (EWG) which are in turn linked to the Skin Deep database. SCA 2010 is being opposed by groups representing small businesses such as Opposesca.com, the Indie Beauty Network and Personal Care Truth which also reflects the views of many cosmetic chemists. A petition opposing SCA 2010 can be found here.

SCA 2010 is unscientific, unworkable, and if passed as is, would likely cause widespread job loss in the cosmetics industry. Far from being a step in the right direction, it would be a leap into regulatory chaos, as well as targeting small businesses and natural products.
Yes, cosmetics could and should be safer, and cosmetics labeling in the USA does need more transparency. Safety can always be improved in any field, especially in the light of new scientific data, but SCA 2010 over-reaches what is needed to such an extent that, with the possible exception of distilled water, I cannot think of any cosmetic ingredient that would be acceptable under its terms.

These require that there is “data demonstrating that exposure to all sources of the ingredient or cosmetic present not more than 1 in a million risk for any adverse effect in the population of concern”. Unfortunately, “population of concern” is not defined, but SCA 2010 further states that, in establishing a safety standard, “no harm will be caused by aggregate exposure for a member of a vulnerable population to that ingredient or cosmetic.” “Vulnerable populations” are defined, and include “pregnant women, infants, children, the elderly, and people with compromised immune systems.” Would “infants” include pre-term babies? Would “people with compromised immune systems” include those who do not get sufficient sleep, or who suffer from frequent colds? Much of the wording of the bill is vague and open to many possible interpretations.


“Ingredient” includes every substance present in an ingredient “at levels above technically feasible detection limits.” This last phrase is not defined, but it could be as low as one part per billion (ppb, 0.0000001%) or one part per trillion (ppt, 0.0000000001%). SCA 2010 specifically mentions contaminants, and in foods and beverages they are commonly measured at these levels.

Most essential oils contain about 100 constituents. The above data – for example no more than 1 in a million risk – must be demonstrable for each one of these constituents. Otherwise, the essential oil may not be acceptable in cosmetics, according to the terms of the bill. I can think of of no substance, natural or synthetic, that is known to cause no adverse reaction of any kind in less than 1 in a million people. In human tests for skin reactions, there are sometimes data covering tens of thousands of patch tests. But, that’s still a long way from a million, and there is no cosmetic ingredient that, if patch tested on one million people, would cause no more than one reaction. Except for distilled water perhaps.

“Any adverse effect” is not defined, but is not as simple as it might seem. Linalool, for example, has caused CNS depression when inhaled by animals. (Alcohol is the classic CNS depressant – in large enough amounts, it causes loss of muscular control, slurred speech, stupor and other effects.) Linalool is one of the most common constituents of fragrant herbs and flowers, inhalation of which could therefore be regarded as hazardous under the vague terms of SCA 2010. In reality, linalool has no more than a mild calming, anti-anxiety effect when inhaled by humans. It’s one of the main constituents of lavender oil.

The issue of dose and concentration is not given much consideration. “The Secretary shall presume that any ingredient or cosmetic that induces cancer or birth defects or has reproductive or developmental toxicity when ingested by, inhaled by, or dermally applied to a human or an animal has failed to meet the safety standard.” This is a complete reinvention of the science of toxicology, which up until now has been based on the principle of dose and of threshold levels. Above certain amounts toxicity may occur, below them it will not. This is why there are permissible levels for substances such as hydrocyanic acid (”cyanide”, restricted to 1 ppm) which naturally occurs in some foods.

There’s also the question of the interaction between the constituents of a natural substance. Basil herb, for example, contains two known carcinogens – estragole and methyleugenol. Pesto is a particularly concentrated form of basil, yet the WHO has determined that the amounts in basil/pesto are so small that they present no risk to humans. Since that ruling, research has been published demonstrating that basil herb contains anticarcinogenic substances that counter any potential toxicity of the two carcinogens, and is itself anticarcinogenic (Alhusainy et al 2010, Dasgupta et al 2004, Jeurissen et al 2008). Some basil essential oils have been shown to have anticarcinogenic effects (Aruna & Sivaramakrishnan 1996, Manosroi et al 2005).

Probable or known human carcinogens, such as acetaldehyde and benzo[a]pyrene (BaP) are ubiquitous in fruits, vegetables, dairy products, meat and fish at low ppb. I’m not saying this is a good thing, I’m just saying it’s a fact, and these foods are not regarded as dangerous, because the toxins are present in such minuscule amounts. BaP is one of the many carcinogens found in cigarette smoke, but it is also found in American drinking water at 0.2-2.0 ppb, and in olive oil at about 3 ppb. Olive oil is actually anticarcinogenic, because of its content of antioxidant polyphenols, squalene, β-sitosterol and linoleic acid (Sotiroudis & Kyrtopoulos 2008). It’s the same story with fruits and vegetables – they are generally anticarcinogenic due to a very much higher content of antitoxic substances.

Many essential oils, herb extracts and foods contain tiny amounts of single constituents that alone, and in substantial amounts, are known to be toxic, but the parent natural substance is not toxic. However, this scenario is not taken into consideration by the CFSC or EWG. These organizations are, wittingly or unwittingly, campaigning to have natural substances banned from use in cosmetics because of their “tunnel vision”  and “parts per billion” approach to safety.
The thinking behind the wording of SCA 2010 is naive because there is an assumption that substances are either “safe” or “toxic”, and that if we simply eliminate the toxic ones from personal care products, the world will be a better place. It may seem like an excellent idea, but once you start talking about parts per million or lower, it is unnecessary and unrealistic. Not even foods are regulated to that degree, and our exposure to foods is far greater than our exposure to cosmetics.

SCA 2010 requires that every constituent or trace contaminant of every ingredient be listed onthe product label. This arguably discriminates against natural products, since their ingredient lists would have to include hundreds of substances, if they could be proved to be safe under the terms of the bill, and if there was some way of actually listing that many ingredients on a label. A product containing what would normally would be regarded as five ingredients – olive oil, blue chamomile extract, and essential oils of orange, rose and vetiver – would require an ingredient list looking something like this:
oleic acid, palmitic acid, stearic acid, linoleic acid, linolenic acid, squalene, hydroxytyrosol, tyrosol, oleuropein, ligstroside, elenolic acid, acetoxy-pinoresenol, oleocanthal, α-tocopherol, herniarin, hyperoside, umbelliferone, methylumbelliferone, caffeic acid, chlorogenic acid, quercetin, rutin, flavanone, isorhamnetin, quercimeritin, anthemic acid, choline, triacontane, patuletin, patulitrin, apigetrin, apigenin-7-glucoside, apigenin-7-apiosylglucoside, luteolin-7-glucoside, apigetrin-7-acetylglucoside, luteolin-4-glucoside, luteolin, patuletin, matricin, matricarin, galacturonic acid, d-limonene, citronellol, geraniol, myrcene, linalool, α-pinene, sabinene, β-phellandrene, geranial, neral, decanal, citronellal, (Z)-β-ocimene, β-pinene, valencene, β-elemene, terpinolene, dodecanal, γ-terpinene, β-sinensal, α-sinensal, δ-cadinene, α-copaene, γ-muurolene, nerol, δ-3-carene, (Z)-3-hexenol, perillaldehyde, octanol, cis-sabinene hydrate, undecanal, nonadecane, heneicosane, 1-nonadecene, 2-phenylethanol, (E)-β-ocimene, methyleugenol, eugenol, 1-heptadecene, eicosane, trans-linalool oxide, β-caryophyllene, 1-tricosene, α-terpineol, α-farnesene, farnesyl acetate, citronellyl formate, pentadecane, α-guiaiene, benzaldehyde, (Z)-β-farnesene, terpinen-4-ol, geranyl acetate, isogeranyl acetate, farnesyl propionate, methyl salicylate, citronellyl acetate, hexanol, α-humulene, methyl geranate, α-terpinene, cis-rose oxide, isogeraniol, β-bergamotene, δ-2-carene, cis-linalool oxide, octadecane, heptadecane, α-phellandrene, cis-rose oxide, β-maaliene, ethyl benzoate, geranyl acetone, 3-methylbutanol, docosane, 1-heneicosene, p-cymene, 1-eicosene, bourbonene, γ-cadinene, hexadecane, 1-tricosene, octanal, nerolidol, 2-undecanone, benzyl benzoate, α-muurolene, 2-phenylethyl phenylacetate, farnesol, geranyl formate, guaiol, heptanal, allo-ocimene, 1-octadecene, 2-phenylethyl-3-methyl valerate, hexadecanol, hexanal, 3-hexenyl formate, 2-phenylethyl benzoate, khusimol, vetiselinenol, cyclocopacamphan-12-ol (epimer A), α-cadinol, α-vetivone, β-vetivenene, β-eudesmol, β-vetivone, khusenic acid, β-vetispirene, γ-vetivenene, α-amorphene, (E)-eudesm-4(15),7-dien-12-ol, β-calacorene, (Z)-eudesm-6-en-11-ol, γ-amorphene ziza-5-en-12-ol, β-selinene, (Z)-eudesma-6,11-diene, salvial-4(14)-en-1-one, khusinol, cyclocopacamphan-12-ol (epimer B), selina-6-en-4-ol, khusian-ol, δ-amorphene, 1-epicubenol, khusimene, ziza-6(13)-en-3β-ol, ziza-6(13)-en-3-one, 2-epi-ziza-6(13)-en-3α-ol, 12-nor-ziza-6(13)-en-2β-ol, α-vetispirene, eremophila-1(10),7(11)-diene, dimethyl-6,7-bicyclo-[4.4.0]-deca-10-en-one, 10-epi-γ-eudesmol, α-calacorene, (E)-opposita-4(15),7(11)-dien12-ol, prekhusenic acid, 13-nor-eudesma-4,6-dien-11-one, isovalencenol, spirovetiva-1(10),7(11)-diene, 2-epi-ziza-6(13)-en-12-al, (E)-isovalencenal, preziza-7(15)-ene, (Z)-eudesma-6,11-dien-3β-ol, intermedeol, isoeugenol, isokhusenic acid, elemol, eremophila-1(10),6-dien-12-al, juniper camphor, khusimone, eremophila-1(10),4(15)-dien-2α-ol, eremophila-1(10),7(11)-dien-2β-ol, (Z)-isovalencenal, allo-khusiol, methyl-(E)-eremophila-1(10),7(11)-dien-12-ether, (E)-2-nor-zizaene, (Z)-eudesm-6-en-12-al, funebran-15-al
No contaminants have been shown here, only natural constituents of the five ingredients. Whether this list of 200 chemicals would be useful for consumers is debatable, and it would be one of the shorter lists, since most natural products contain much more than five ingredients. Even single synthetic chemicals are not really single chemicals at all – they also contain some minor and trace constituents. Most fragrance chemicals for example are about 95% pure, the other 5% consisting of “impurities” which of course would have to be listed. So synthetic chemicals are not exempt from this challenge.

This is one of the reasons that a naturally-occurring chemical is not the same as a synthetic one – the impurities present in the synthetic version. Synthetic coumarin, for example, causes skin allergies because of the impurities it contains (Vocanson 2006, 2007). But, SCA 2010 treats all chemicals of the same name as equal, which may be expedient if you are trying to pass legislation, but it’s not really scientific.

SCA 2010 proposes that hundreds of ingredients should be assessed for safety in unrealistically short amounts of time, with no proposal as to what form this assessment process will take, who will undertake the work, and exactly what criteria will be used. The wording of the bill shows very little understanding of either toxicology or cosmetics science. It also assumes that any existing legislation in other countries must be good legislation, when in fact nothing could be further from the truth.

I happen to believe that incremental legislation is generally a good thing. It at least allows for the possibility of public debate, and for finer points to be properly considered. Legislation as sweeping as SCA 2010 will cause chaos in the cosmetics industry, especially since States will be given the option to add further safety standards as they see fit. So, each State could have different standards – a manufacturer’s nightmare, and a pointless provision. Even without it, how any agency could enforce legislation involving hundreds of thousands of existing products, with hundreds of ingredients to consider for each one is mind-boggling.

SCA 2010 will cost unknown millions or billions of dollars which the consumer will ultimately pay for. It will probably have no more than a negligible effect on cosmetics safety, but it poses a serious threat to many businesses especially those making natural products, those supplying natural ingredients, and the farmers that grow the plants they come from.

In health news...

SCA 2010 is especially onerous to small businesses (any corporation with a turnover of $7 million or less.) It requires each manufacturer to not only declare every constituent chemical of every ingredient on the label, but to also test each finished cosmetic to ensure that there is not even a trace amount of some toxic chemical that might have been formed during the making of the product. Most small personal care product businesses will not survive if SCA 2010 passes, a fact that may possibly be attractive to larger corporations.

However, the bill has been criticised by Lezlee Westine, President and CEO of the Personal Care Products Council, which represents the larger cosmetics companies. Her statement includes the following: “We are concerned that the Safe Cosmetics Act of 2010 as written is not based on credible and established scientific principles, would put an enormous if not impossible burden on FDA, and would create a mammoth new regulatory structure for cosmetics, parts of which would far exceed that of any other FDA-regulated product category including food or drugs. The measures the bill would mandate are likely unachievable even with the addition of hundreds of additional FDA scientists and millions more in funding and would not make a meaningful contribution to product safety.”

The Skin Deep database, mentioned in the first paragraph, gives an insight into the thinking of the CFSC and EWG. Skin Deep exaggerates toxicity by being selective in its reporting. For example, limonene, the major constituent of citrus essential oils, is flagged as being developmentally toxic in large doses. This is true, since when pregnant mice were fed 2,363 mg/kg limonene by stomach tube on days 7-12 of gestation, there was an increase in the number of fetuses with skeletal anomalies and delayed ossification (Kodama et al 1977).
However, what is not stated by Skin Deep is that in the same report, when pregnant mice were given a lower dose, 591 mg/kg/day, there was no developmental toxicity. The higher dose is equivalent to daily human ingestion of 5.7 oz of limonene, and the lower dose is equivalent to 1.4 oz. If ingestion of 1.4 oz per day for 6 days is known to be non-fetotoxic, then there is no reason to believe that the use of limonene in cosmetics is likely to be in any way hazardous during pregnancy; in fact, quite the opposite (especially since stomach tube feeding generally increases toxicity).

The Skin Deep page on limonene also mentions, under “cancer” that“one or more tests on mammalian cells show positive mutation results.” One reference is given. However, this ignores the fact that eleven other studies found no evidence of mutagenicity or genotoxicity for limonene (Anderson et al 1990, Connor et al 1985, Florin et al 1980, Haworth et al 1983, Myhr et al 1990, Pienta 1980, Sasaki et al 1989, Sekihashi et al 2002, Turner et al 2001, Watabe et al 1980, 1981), and two further studies reported antimutagenic effects (De Oliveira et al 1997, Kim et al 2001). This 13:1 “score” is part of the weight of evidence used to assess risk in toxicology.

Mutagenicity testing is used to identify substances that may be carcinogenic. However, 85% of substances that are not in fact carcinogenic test positive in a least one mutagenicity test (Kirkland et al 2005). These are “false positives”, and present no risk. The one study cited by Skin Deep for limonene is a false positive.

If you want to imply risk, it’s possible to do so simply by being selective about which facts you choose to report. Many small cosmetics manufacturers have become disenchanted with the manipulative ways of the CFSC and EWG. If they were sincere in caring about cosmetics safety they would welcome any pertinent opinions and facts, but they don’t. They either ignore or stridently oppose anything that does not accord with their fear-driven political agenda. It’s a shame, because a few of their concerns are genuine and well-founded, but their focus has become highly distorted.

I urge you to oppose the Safe Cosmetics Act 2010. Here are some steps you can take.


Alhusainy W, Paini A, Punt A et al 2010 Identification of nevadensin as an important herb-based constituent inhibiting estragole bioactivation and physiology-based biokinetic modeling of its possible in vivo effect. Toxicology & Applied Pharmacology 245:179-190

Anderson BE, Zeiger E, Shelby MD et al 1990 Chromosome aberration and sister chromatid exchange test results with 42 chemicals. Environmental & Molecular Mutagenesis 16(Suppl. 18):55-137

Aruna K, Sivaramakrishnan VM 1996 Anticarcinogenic effects of the essential oils from cumin, poppy and basil. Phytotherapy Research 10:577-580

Connor TH, Theiss JC, Hanna HA et al 1985 Genotoxicity of organic chemicals frequently found in the air of mobile homes. Toxicology Letters 25:33-40

Dasgupta T, Rao AR, Yadava PK 2004 Chemomodulatory efficacy of basil leaf (Ocimum basilicum) on drug metabolizing and antioxidant enzymes, and on carcinogen-induced skin and forestomach papillomagenesis. Phytomedicine 11:139-151

De Oliveira AC, Ribeiro-Pinto LF, Paumgartten FJ 1997 In vitro inhibition of CYP2B1 monooxygenase by b-myrcene and other monoterpenoid compounds. Toxicology Letters 92:39-46

Florin I, Rutberg L, Curvall M et al 1980 Screening of tobacco smoke constituents for mutagenicity using the Ames test. Toxicology 15:219-232

Haworth S, Lawlor T, Mortelmans K et al 1983 Salmonella mutagenicity test results for 250 chemicals. Environmental Mutagenesis 5:3-38

Jeurissen SM, Punt A, Delatour T et al 2008 Basil extract inhibits the sulfotransferase mediated formation of DNA adducts of the procarcinogen 1′-hydroxyestragole by rat and human liver S9 homogenates and in HepG2 human hepatoma cells. Food & Chemical Toxicology 46:2296-2302

Kim MH, Chung WT, Kim YK et al 2001 The effect of the oil of Agastache rugosa O. Kuntze and three of its components on human cancer cell lines. Journal of Essential Oil Research 13:214-218
Kirkland D, Aardema M, Henderson L et al 2005 Evaluation of the ability of a battery of three in vitro genotoxicity tests to discriminate rodent carcinogens and non-carcinogens I. Sensitivity, specificity and relative predictivity. Mutation Research 584:1-256

Kodama, R, Okubo A, Araki E et al 1977 Studies on d-limonene as a gallstone solubilizer (VII). Effects on development of mouse fetuses and offspring. Oyo Yakuri 13:863-873

Manosroi J, Dhumtanom P, Manosroi A 2005 Anti-proliferative activity of essential oil extracted from Thai medicinal plants on KB and P388 cell lines. Cancer Letters 235:114-120

Myhr B, McGregor D, Bowers L et al 1990 L5178Y Mouse lymphoma cell mutation assay results with 41 compounds. Environmental & Molecular Mutagenesis 16(Suppl 18):138-167

Pienta R J 1980 Evaluation and relevance of the Syrian hamster embryo cell system. Applied Methods in Oncology 3:149-169

Sasaki YF, Imanishi H, Ohta T et al 1989 Modifying effects of components of plant essence on the induction of sister-chromatid exchanges in cultured Chinese hamster ovary cells. Mutation Research 226:103-110

Sekihashi A, Yamamoto A, Matsumura Y et al 2002 Comparative investigation of multiple organs of mice and rats in the comet assay. Mutation Research 517:53-74

Sotiroudis TG, Kyrtopoulos SA 2008 Anticarcinogenic compounds of olive oil and related biomarkers. European Journal of Nutrition 47:69-72

Turner SD, Tinwell H, Piegorsch W et al 2001 The male rat carcinogens limonene and sodium saccharin are not mutagenic to male Big Blue rats. Mutagenesis 16:329-332

Vocanson M, Goujon C, Chabeau G et al 2006 The skin allergenic properties of chemicals may depend on contaminants – evidence from studies on coumarin. International Archives of Allergy & Immunology 140:231-238

Vocanson M, Valeyrie M, Rozières A et al 2007 Lack of evidence for allergenic properties of coumarin in a fragrance allergy mouse model. Contact Dermatitis 57:361-364

Watabe T, Hiratsuka A, Isobe M et al 1980 Metabolism of d-limonene by hepatic microsomes to non-mutagenic epoxides toward Salmonella typhimurium. Biochemical Pharmacology 29:1068-1071

Watabe T, Hiratsuka A, Ozawa N et al 1981 A comparative study on the metabolism of d-limonene and 4-vinylcyclohex-1-ene by hepatic microsomes. Xenobiotica 11(5):333-344

Sunday, June 6, 2010

Cropwatch: The Role of Risk Aversion in the Decline of the Perfumery Art - presented at the World Perfumery Congress, 2010

The Role of Risk Aversion in
the Decline of the Perfumery Art

Tony Burfield, Cropwatch www.cropwatch.org

Click here to download the pdf of this post

World Perfumery Congress, Cannes

2nd June 2010.

(Anya's note: I've muddled thru the pdf and powerpoint of this speech Tony gave at the WPC and have to the best of my abilities, made a decent facsimile of the original so that the content may be archived on the internet. To read the original, please download the pdf, linked. PS We're very proud to have Tony as a member of the Natural Perfumers Guild, and I have collaborated with him previously in attempts to expose the bad science and bad politics of the EU, IFRA, et al.)

Cropwatch’s actions.

Cropwatch is a 6-7 year old non-financed independent watchdog for the aroma & natural products trades. It has waged campaigns against (amongst others):

• Over-exploitation of rare & threatened aromatic species (see Cropwatch website for A-Z data-base).
• Impending citrus oil FuroCoumarin (FC) legislation.
• The 26 allergens legislation (EU Dir 2003/15/EC). Has criticised:

• IFRA’s overly-bureaucratic QRA system (also much faulted by the SCCP in Opinion 1153/08).
Has dismissed as scientifically unsound:
• A number of SCCP Opinions & IFRA Standards (e.g. on Pinaceae, tagete oil, opoponax, melissa oil, coumarin, vanillin, oakmoss etc.).
Has forced improvements & corrections:
• To EU Cosmetics ingredients lists, policies etc.

Hand-cutting lavender in the UK, before anybody had heard of the term: ‘acute contact dermatitis’!

QC lab. in the days before the concept of
‘Health & Safety at Work’ – note lighted cigarettes dangling from lips of staff!

A bit of history…
•  The failure to create a European Fragrance Commission with a brief to protect & maintain the cultural inheritance and art of European perfumery, has meant DG-Enterprise & Industry has been relatively free to create a framework of regulatory toxicology for the safety assessment & regulation of fragrances within the Cosmetics industry umbrella. The sale of cosmetics is primarily regulated under the Cosmetics Directive 76/788/EC, compiled between 1973-5 & adopted in 1976, & successively amended (to become supplanted by the new Cosmetics Regulation, to be in force by mid 2013). The approach taken mimicked that for the regulation of food
and pharmaceuticals i.e. is partly based on safety of ingredients and the adoption of lists (Lanuza undated). The outfall from this regulatory approach has been in the form of ingredient restrictions which have had a negative effect on “the art of the possible” in perfumery in recent years, thus damaging fragrance creativity & attainments.
•  Toxicological testing requirements for cosmetics are not specified, although the SCC(NF)P / SCCS ‘expert’ committee offers opinions (usually with the help of carefully selected evidence, spoon-fed by trade-funded professional organisations like EFFA, before its demise) to DG-Ent’s
posed questions on the safety & allergenicity of individual cosmetic ingredients. The end result has been a continuing series of amendments to the EU Cosmetic Directive limiting the use of aroma ingredients on (often) scientifically contentious, disproportionate & over-precautionary grounds (see Cropwatch Files).
•  Industry has been openly criticised for its timidity (Durodie 2004) in failing to oppose these regulatory impositions and the attendant bad science,
and the underlying culture of toxicological imperialism which drives it.
SME’s locked out of safety policy considerations.

•  Although a few larger aroma concerns refuse to belong to the privately-funded IFRA organisation & its affiliates on principle, many SME’s who feel differently often cannot afford the membership fees to professional organisations such as RIFM, IFRA, Perfume Manufacturing Organisations etc. which are more suited to the
budgets of the aroma corporates & mega-corporates. These SME’s are effectively locked out of the ‘health & safety culture’.
•  Yet substantial consumers of natural aromatic materials include the (virtually unregulated) aromatherapy profession, as well as candle- makers / soap-makers/ incense traders / pot pourri makers / hand- made cosmetics makers / general cleaning product makers / natural perfumers / organic perfume makers – all SME's.
•  In the US, the Colorado State Safe Personal Products Act HB10-48, which included a proposed zero tolerance policy for CMR’s in cosmetics (with large fines for non-compliance), was defeated in Feb
2010 by a small number of SME’s and their advocates, who wrote to the Colorado Legislature complaining that the act would put them out of business (it is however being re-written for proposed re- introduction, and up to eleven other US States currently have similar bills in the offing). They complained that constantly scrutinising changing lists of ingredients put out by authoritative bodies, hiring legal advisors, and reformulating their products to keep up with these changes would force their products costs up, and they would become uncompetitive and collapse. The situation described above is, of course, similar to that for European SME’s.

EU Cosmetics Commission Policy.

• So far, the EU Cosmetics Commission has stuck to a code of practice where it refuses to measure or quantify individual ingredient risks, assess ingredient risk-benefit balance considerations (apart from for preservatives), assess cost-benefits of risk assessment (if any), clearly relate technical / biological end- point criteria to protection objectives, or consider adverse user effects data. Over-deployment of the Precautionary Principle can be counted amongst other short-comings.

• Whether this situation may change as a result of the ICCG now helping the EU Commission to explore a 2009 initiative by SCHER to promote harmonisation across the SCCS, SCHER and SCENIHR wrt reassessing risk assessment procedures, and the more effective communication of risk-related issues, remains to be

[Acronyms: ICCG Inter Committees Coordinating Group
SCHER Scientific Committee on Health & Environmental Risks
SCENIHR Scientific Committee on Emerging &
Newly Identified Health Risks].
So, its all going according to plan then…

• Ian White (1998): “A think tank has been set up consisting of a balanced representation of dermatologists, fragrance compound manufacturers and users (?) to address aspects of the problems and needs.” [Note the absence of independent scientists with the appropriate cross-disciplinary skills].
• According to documents dated 1998 seen by Cropwatch referring to the ‘think tank’ meetings, DG-Ent’s requirements were reported to include (amongst others) a total list of ingredients used in fragrances banded by volume, and a simplification of fragrance ingredient (chemical & botanical) descriptions.
• IFRA made their 2009 Fragrance Industry Ingredients List (3163 substances) public in Jan 2010, compiled as it is from the 2008 returns of (an unknown proportion of an unknown number of-) affiliated IFRA members. The list incidentally includes ingredients now classified as originating from threatened species, & ingredients that are “banned IFRA”. Ingredient volume information is now available from various sources. In Cropwatch’s opinion, the separate COSING/INCI list of cosmetic ingredients demonstrates the EU Commission’s approach to the simplification issue mentioned above, via a policy of botanical reductionism (see later slides) reflecting their lack of expertise in botany & botanical nomenclature (the latter fact actually admitted to Cropwatch by the EU Commissioner, Brussels, 2007), and additionally in economic botany.
SME’s in other areas.

• In other regulatory areas, economic discrimination against SME’s remains effectively unaddressed. The EU Commission (“The Rich Mans Club”) has long funded its H&S policies by using industry as a cash-cow, in order to pay for them. For example the  high costs
of registering & supporting essential oils or natural aromatic extracts as biocides under the Biocidal Products Directive (BPD)
98/8/EC, drove the majority of natural biocide companies out of the business. As a result essential oils commonly used as insect repellents (=biocides) such as citronella, neem & tea tree oils, can no longer be used for this purpose under the BPD – exactly the outcome the synthetic biocides industry wanted.
• The Traditional Herbal Medicinal Products Directive (THMPD) EC Directive 2004/24/EC seeks to regulate traditional herbal products used in Ayurveda, Unani & Traditional Chinese Medicines, as well as in Western traditions. But from 2011, under the likely terms of full implementation of the Directive, products which were previously regulated as botanical food supplements will be regulated as if pharmaceuticals, involving high costs for registration and compliance (and thereby eliminating a large number of SME’s involved in the traditional herbal drugs trade). A legal challenge to the Directive from the Alliance for Natural Health International is underway (now with the support of Chinese & Indian medical group interests see ANH Press Release (2010)); UK Member State ratification at herbal practitioner level is thought unlikely as the result of a forthcoming human rights challenge.

Neem tree Zanzibar (extracts not supported as permitted EU biocide).

Traditional herb seller in Sikkim,
smiling (as not affected by THMPD!).

The FDA & the EWG.

•  In the US, the 1938 Food, Drug, and Cosmetic Act was the first Federal initiative to regulate cosmetics; since then the FDA and industry have cooperated to build a regulatory regime which has a lack of pre-market supervision and relies heavily on the self-regulation of industry (slightly paraphrased from Daum 2006).
•  But the US cosmetics industry's self-regulatory approach and lack of ingredient safety substantiation has not been without its critics, such as the increasingly influential environmental organisational groups of the Environmental Working Group (EWG), Skin Deep & The Campaign for Safe Cosmetics (CSC). According to the EWG website the aim is "to use the power of public information to protect public health and the environment”. The EWG offer a detailed cosmetic ingredient database on their website which displays comprehensive references to information about research on specific cosmetic ingredients, but this information lacks objective
interpretation, overview or risk analysis of the data contained within any of the publications that they cite. This information source, combined with
aroma ingredient information from sites such as The Good Scents
Company, has spawned a new breed of speculative internet health
commentators, many of whom (it is pretty obvious) have no background in science or medicine.
•  The CSC’s commissioned report “Not So Sexy - The Health Risks of Secret Chemicals in Fragrance” (CSC 2010) produced by Commonweal, Environmental Working Group, Breast Cancer Fund, Women’s Voices for the Earth & Anne Steinemann (University of Washington), attempts to link fragrance chemicals with adverse health effects, and has been rebuffed by the Fragrance Manufacturing Association (FMA 2010) amongst others. Although full of scientific inaccuracy and unsubstantiated innuendo, the report will add pressure to an already over-regulated industry.

The Declining Perfumer’s Palette.

• As time progresses, the most commonly used fragrance ingredients in company formulations are increasingly associated with hazard & risk coding (as illustrated by Osbiston 2010) and therefore progressive limitations in their potential range of use.

• Vey (2009) maintained that if IFRA didn’t introduce their “voluntary” Standards for the fragrance trade, the EU Commission would introduce more draconian regulation.

[Cropwatch considers this proposition is pretty doubtful - as illustrated by the initial objection made by EU officials to putting Rosewood (Aniba rosaedora Ducke) into CITES Appendix II (CITES CoP 15 Qatar, March 2010) on the basis that such a policy ‘couldn’t be policed’. This
reveals an underlying situation where the Customs & Excise / H & S / Trading Standards staff of most European member states are untrained in taxonomic techniques
and forensic analysis. If this dearth of technical ability amongst enforcement officials is correct, it will be increasingly unable enforce complex EU cosmetic & general product regulations].

The ‘Zero-Risk Mindset.’

“(EU) Regulators apply - (or appear to have been pressurised into, by ‘invisible’ lobbyists) a disproportionate & excessive degree of regulation wrt aromatic ingredients, which appears to be an attempt to construct a clean, risk-free and largely synthetic-based safer-than-nature world of their own. That is not the world that most of us wish to inhabit, and Cropwatch believes that many will ignore any restrictions which deny us the use of those familiar natural materials which we associate with our lives, our heritage & our traditions.” – Tony Burfield (2010).

“Absolute reassurance and ‘no-risk’ policy is however contributing to the risk aversity of our society and triggers biased regulation, which will not deliver substantial environmental or health benefit.”
- Jostman (2007).

Withdrawal of Fragrance

• High toxicological testing costs (REACh etc.) means that many ingredients, are or will be, unable to be supported by producers.

• Rising raw material costs are reducing demand for the more costly aromatic ingredients.

• Ingredient hazard & risk coding is making many materials increasingly unattractive to employ in fragrance formulations.
• The situation of progressive ingredient unavailability
/ withdrawal (especially for naturals) is neither a
challenge nor an opportunity to the perfumer - it is
an unmitigated disaster - which should be
vehemently opposed by anyone who cares about the
art of perfumery.

Derelict vanilla plantation, Seychelles.
EU/IFRA policy will repeat similar scenes.

Old clove distillation works, Zanzibar before eugenol was classified as R36-43.
Subsequently became twice as derelict!
Who cares about the restriction of fragrance ingredients, & anyway, how would we ever find out?

• - Well probably not from the trade press! Cropwatch’s view is that because of existing commercial publishing arrangements (e.g. between Allured Publishing Corp. & RIFM) many of the industry’s leading journals & magazines have failed to address burning issues affecting the fragrance industry because of commercial ties. Rather, the impetus has been left to bloggers & fragrance interest groups on the Internet. Anger & frustration amongst
brand-loyal customer to the reformulation of classic perfumes (e.g. Guerlain’s Mitsouko – see Turin 2007), about which the brand owners themselves are often in-denial, and the constraining
effects of the IFRA Standards on fragrance creativity felt by French perfumers, have been recently discussed by informed commentators.
• IFRA, and until recently, EFFA (whose fragrance brief has now been transferred to IFRA-Europe), are/were unlikely to petition the EU Commission about the removal of fragrance ingredient restrictions. This is because the raison d’être of the Commission is, after all, to continually pass legislation (or they become purposeless), and IFRA is engaged on its continual exercise in authoritative toxicological imperialism (which Cropwatch is confident will see practically all fragrance ingredients classified
as hazardous, restricted or banned within a short period).

The Declining Perfumer’s Status.
• Perfumers used to be highly motivated & outspoken artists, with senior company positions, including board membership

• Many of today’s perfumers are of declining importance, being merely the obedient manipulators of fragrance legislation-software, tinkering with formulae to reduce labelling risks, substituting for expensive, withdrawn or
‘hazardous’ ingredients, and often with a brief to
minimise the use of natural materials. After some
possibly unguarded remarks made by aroma company
employees in the late nineties concerning musks and
their environmental fate, they are now unable to comment
to the media on any current H&S issue (a task taken over
by their trade organisation’s nominated ‘experts’), or to
publish any material without their employer’s express
• In short perfumers have become emasculated and their professional organisations undemocratic - in that they are not brave enough to openly sympathise or express the private views of their members, for fear of upsetting their masters.
Creative Limitations due to Hazard
Classifications of Ingredients.

• ‘The Overdose’ technique (excessive utilisation of a single synthetic ingredient) is under threat.

• The citrus FuroCoumarins (FC’s) situation - potentially a severe limitation in use of expressed citrus oils (bergamot, lemon etc).

• Limitation of allowable concentrations of weak rodent carcinogens (methyl eugenol, safrole, methyl chavicol) in natural aromatic ingredients.
• The labelling of sensitisers, alleged & otherwise.

• R50/53 substances allegedly ‘dangerous to the environment’.

• The fragrant mosses situation, the vanillin situation, the coumarin situation, the tea tree situation …

The Overdose.

• Martin Gras as Senior Perfumer at Dragoco, wrote two important articles (Gras 1990; Gras 1991) on “The Overdose” – ingredients used in alcoholic perfumery in overdose proportions naming 16 ingredients in the first article & 16 in the second (with some repeats in the second).

• Gras (1990) commented: “Luckily in perfumery, there are no limits. Few substances are prohibited or restricted by RIFM or IFRA recommendations.” In
2010, the above comments made some 20 years
previously are no longer valid – IFRA standards or hazard / risk labelling codes limit the allowable
concentrations of many of the cited ingredients.
The Overdose II.

Here are a few examples from Martin Gras’s articles (1990 & 1991):

• Tonalid to 11% in Fahrenheit Dior 1968 & 30%) in Tide
Bleach (P&G 1989). Now Xn, N, R22-50/53.
• Galaxolide 29% Lux Beauty Shower Soap Now N, R50/53.
• Lyral (HMPCC) 10% in Red Door (Arden 1989) & 15% in Joop (1987). Now Xi, R43, 52/53. Restricted under 44th IFRA Amendment to 0.02% in QRA Category 1. The restrictions on this ingredient are having a huge effect on fragrance composition in the fine fragrance area.
• Lilial (BMHCA) 16% in Eternity for Women (Calvin Klein),
20% in Calyx (Prescriptive 1986). Now Repr. Carc. Cat. 3, Xn,
N, R22,38-43-51/53,62. Restricted under 43rd IFRA Amendment to 0.1% in QRA Category 1. Similarly the restrictions on this ingredient are having a huge effect on
fragrance composition for all types of applications from
household, to detergents to fine fragrance.
• Iso E Super 20% in Tresor (Lancôme 1990). Now N, R51/53.
Restricted under 43rd IFRA Amendment to 1.34% in QRA Category 1.

Citrus Oils: a Double Whammy

1.. The EC Cosmetics Commissioner wrote to Cropwatch (25.05.2009) stating that FC’s were to be banned in cosmetics except for their presence in natural essences. Limits would be fixed via the monitoring of seven marker FC’s: bergapten, bergamottin, byakangelicol, epoxybergamottin, isopimpinellin,
oxypeucedanin & xanthotoxin. These FC’s would be limited to
5ppm in leave-on products and 50ppm in rinse-off products. The
anomalous final line “Each of the seven FC’s should be present
at a level no more than 1ppm” invalidates the whole proposal,
but has never been withdrawn or corrected.

Drastically limiting FC's in fragranced products would result in the effective removal of indispensable natural (citrus) ingredients which Cropwatch has described as cultural vandalism against the perfumery art. Fragrance types such as Eau de Colognes, Eau Fraiche and citrus-based compositions would disappear, and chypre & fougère fragrance types which employ citrus ingredients (especially bergamot oil) in their characterising accords would be severely affected.

2. Under DPD/DSD (soon to be under CLP 1272/2008/EC), R50/53 environmental labelling (dead fish & tree symbols) has had a serious impact on usage of citrus oils & their terpenes, which have been traditionally employed in many types of perfumes for household & air care products for their diffusion, lift & fresh character.

Citrus Oils II.

• SCCP Opinion 0942/05 on FC’s in cosmetics was, in Cropwatch’s view, a rag-bag of unsubstantiated assumptions & prejudices, which failed to provide any direct evidence whatsoever of in vivo human photo-carcinogenicity from citrus FC's.

• The SCCP’s stated conclusions on photo- carcinogenicity in 0942/05 are at variance with the findings of other researchers such as Chouroulinkov et al. (1989), Dubertret et al. (1990) & the EMEA (1990).

• It remains the case that no single in vitro test currently exists which can predict the photo- carcinogenicity of FC’s. Conversely, photoclastigenocity has been associated with other very commonly used cosmetic materials such as zinc oxide (Dufour et al. 2006) and titanium dioxide (Theogaraj et al. 2007).
Citrus oils III.

• Most perfumers are unaware of the FC content of the citrus oil qualities that they use, and their employers do not have, and cannot afford, access to sophisticated analytical equipment to determine them; likewise for many small citrus oil producers. In 2007 the Cosmetics Commissioner, Sabine Lecrenier, stated in a mail to Cropwatch “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 FC’s would not go through.” We have seen no further mention of any public consultation.

• Cropwatch has suggested a labelling solution for the FC problem by advising users of FC-containing fragrances to cover up affected skin areas from actinic light for 12-
24 hrs. This is already standard practice in the aromatherapy profession, where 0.5 to 2.5% of (citrus) essential oils may be applied to the skin in a body massage, and seems to work satisfactorily.

Restrictions are severely limiting the deployment of natural aromatic ingredients containing alleged carcinogens, within fragrance formulations (information below abstracted from IFRA- IOFI Labelling Manual 2009). This policy is having a negative impact on the ability to create spice notes in fragrance formulae.

• Safrole T, R45-22-68. Arguably the weakest rodent carcinogen cited (see 'Safrole: Human Carcinogenicity Overstated?' in Cropwatch Files). IFRA limit for safrole + isosafrole + dihydrosafrole in consumer products is 0.01% (based on conclusions of Scientific Committee of Cosmetology of the EEC Sept. 1980; Communication to the EEC Commission ENV/521/79).

Duke (2002): The human carcinogenic potential of safrole, if not quite negligible at low doses, is considerably less than that of ethanol (Duke 2002).

Cropwatch (2009): The classification of safrole as a Category 2 human carcinogen and its association with risk phrases R22-45-68 seems disproportionate to the risks involved to humans, considering the history of human exposure via its occurrence in spices, foodstuffs, beverages, flavourings and fragrances.
Safrole - occurrence.
Safrole is present in: (N.B. this list is not exhaustive)

•  Chinese Angelica (Angelica sinensis L.)
•  Betel oil (Piper betle L.) to 6.45%
•  Brown & yellow camphor oil (fractions of Cinnamomum camphora L.) Yellow oil to 20%; brown oil to 80%
•  Cangerana oil (Cabralea cangerana Saldanha)
•  Cinnamon leaf oil & bark oils (Cinnamomum zeylanicum Blume) both to 2%
•  Ho leaf oil (Cinnamomum camphora L. var. linaloolifera Fujita) to 0.88%
•  Kuromoji oil (Lindera spp.) to 12%
•  Mace oil (Myristica fragrans Houtt.) to 2%
•  Mango ginger oil (Curcuma amada Roxb.) to 9.5%
•  Nutmeg oils [E.I. & W.I.], butter & oleoresins (Myristica fragrans Houtt.) E.I, oil to 2%; W.I. oil to 0.3%
•  Pepper oil, black (Piper nigrum L.) tr.
•  Phoebe oil to 0.7%
•  Piper auritum HBK oil to 90%
•  Sassafras oils (Sassafras albidum (Nutt.) Nees to 95%.
•  Sassafras oil Brazilian: Ocotea pretosia (Nees) Mez, to 92%.
•  Star Anise oil (Illicium verum Hook f.) to 0.15%
•  Ylang-ylang oils, absolutes (Cananga odorata (DC) Hook. f et Thoms - ssp. genuina) tr.

Safrole - dissenting opinion

• In the Eastern USA, many sassafras tea drinkers and traditional root beer makers regard the use
of natural safrole-containing sassafras flavouring
ingredients as their inherited cultural right, regarding the 1976 FDA ban as a purely political device (i.e. to control the movement of safrole which is a recreational drug precursor). There is no evidence of an increase in cancers from sassafras tea-drinking in this part of the US (see Cropwatch’s Safrole Bibliography in Cropwatch Files).
Allergens - alleged and otherwise.

• The SCCNFP (Opinions SCCNFP/0017/98 & 0329/00) identified
26 fragrance chemicals (16 of which occur in natural products)
associated with a mandatory labelling obligation for allergens
where the concentration in the final product (where added as
such, or present as part of a natural complex ingredient) is
<0.01% in products rinsed off the skin, or <0.001% in leave-on
products. These limitations were incorporated into Council
Directive 2003/15/EC, but the basis for the inclusion of these
chemicals as allergens has never been explained by the SCCP
(Storrs 2007).
• About 220 essential oils, absolutes & resinoid ingredients in the IFRA-IOFI Labelling Manual 2009, carry an R43 (sensitiser) classification. The desire of cosmetic manufacturers/fragrance customers to avoid excessive (hazard) product labelling has led to some decline in the overall usage of essential oils, absolutes & resinoids in cosmetics.
• But independent papers / peer-reviews (those by Schnuch, Floc’h, Vocanson, several by Hostynek & Maibach) have indicated that there is no robust clinical or experimental evidence to support many of these 26 ingredients as frequent allergens. Schnuch (2008) asked the EU to rethink their policy.
Allergens Revisited?
•  The SCCS has recently been asked for an updated scientific opinion on the
mandatory labelling of 26 fragrance substances passed into Annex III of the
Cosmetics Directive by the 7th Amendment 2003/15/EC. This was described as a spin-off from the public consultation resulting from the draft form of SCCNFP Opinion SCCNFP/0017/98 and its 1999 conclusion, which divided allergens into two groups, 13 frequently reported (List A) well recognised and of most
concern, & 11 less frequently reported (List B). Two other raw material fragrance ingredients (oakmoss & treemoss) were also added, making the 26. Demyttenaere (2009) summarised the differences in classification according to SCCNFP Opinion (by reported frequency) against the findings of a study by Schnuch et al (2007), part of a multi-centre project by the IVDK,  indicating five major classification contrasts for farnesol, citronellol, benzyl cinnamate, benzyl alcohol and benzyl salicylate.
•  However the tenfold reduction of  the concentration of the strong sensitiser isoeugenol in fragrances from 0.2% to 0.02% (1998) by the adherents of IFRA Standards had not reduced the incidence of patch test positivity after 2-3 years (Dillarstone effect); it actually increased in a 5 year study of 3636 subjects in
2001-2005 (White et al. 2007), which the authors blamed (but no actual evidence was cited) on isoeugenol substitution in fragrances, which hydrolyse to isoeugenol. The rise in patch test positivity is true also for other ingredients
including Peru balsam (but production volume halved at source since 1982 when IFRA introduced Standards for Peru balsam).

•  The SCCS were asked:
Does the SCCS consider the list of allergens in Annex III are the ingredients that they should be aware of?  Is there a threshold for safe use? Are there substances where processes (arising from metabolism, oxidation and hydrolysis) may lead to cross-reactivity and new allergens that the public should be aware of?
Allergens – what now?

Cropwatch’s view: No sign then, of an apology for one of sloppiest episodes in EU regulatory history, where the regulators appear to have been coerced by easily identifiable lobbyists into passing unnecessary and scientifically unsubstantiated legislation on allergens. It also appears (not for the first time) that individual members of the SCC(NF)P have acted as witness, judge & jury in this matter (see 5th European Framework Programme Fragrance Allergy Contract QLK4-CT-1999-01558). The whole fiasco has cost the trade millions of Euros in relabelling & reformulation costs & depressed essential oil sales for years. No sign either of any acknowledgement of the body of work by Schnuch, Hostynek & Maibach & others on this topic, who have cast doubt on the true allergenic status of many of the original 26 listed allergens. The
3rd question (previous slide) to the SCCS would presumably provide an entrée for the work of Hagwall et al. (2008), Hagwall
(2009) & others, on the possible metabolism of linalol in-product / in the dermis (critiqued in ‘The trouble with theories about the oxidation of essential oils’ in the Cropwatch Files). The Hagwall work is put forward in spite of contrary evidence of the justification of linalol as an allergen (Hostynek & Maibach 2008).

Conclusions: 1. An independent examination is required for the clinical relevance of fragrance patch testing.
2. As things stand, the SCCS would seem to be in acute danger of making the same mistakes on this subject all over again.
Other natural product allergens.

Whilst toxicologists & legislators argue over the regulation of weak allergens, and many of us privately consider whether they are really weak allergens at all, or just moderate irritants, the problem allergens in natural products remain largely unrecognised & unconsidered (certainly by RIFM). These include:
• Coniferyl benzoate (benzoin Siam; Peru balsam qualities)
• T-cadinol (Schinus molle; ylang-ylang oils)
• Sesquiterpene lactones (costus qualities; extracts from plants of the Compositae).
• Coniferyl alcohol etc.

Cropwatch has been working with some aroma product manufacturers to attempt to reduce levels of these powerful allergens in natural commodities to produce safer products. And whilst there are seemingly unlimited funds to help impose regulation because of existing hazardous substances contained within natural aromatics, there seems to be no available public money to look at processing methods which could help reduce these levels.

Substances allegedly ‘Dangerous for the Environment’.

• Pine, fir & spruce needles & other green leaves of plants & trees; roses, stocks, carnations and other flowers; the aerial parts of herbs, brassica farm crops like rapeseed etc., put millions of tons of volatiles into the atmosphere & soil per annum (but are not regulated). In spite of the shown biotoxicity of monoterpene hydrocarbons such as limonene, concentrations of limonene in biota are generally 250 to 20,000 times lower than the lowest EC50 value (Potter et al. 2005); the authors of the latter Swedish study concluding at the accumulation of limonene in the environment is of minor importance. The R50/53 ingredient labelling status for limonene is therefore unjustified. Looking at aquatic risk, Herman (2008) concluded “fragrance material & its use does not add up to an environmental issue”.
• By comparison to the volume tree & plant volatile emissions, relatively smaller amounts of chemicals from aroma industry discharges, ‘grey’ water from personal care & laundry products, household chemicals & aerosols etc. enter the environment from regulated commodities. Whilst microbiological transformation & degradation, photochemical reactions etc. will eventually metabolise the majority of these aromatics harmlessly away to carbon dioxide & water, a small number of problem substances (e.g. polycyclic musks like HHCB & AHTN found in human adipose tissue & breast milk) have caused, and continue to cause, concern (Ueno et al 2009). It is likely that these substances accumulate in adults from application of personal care products.
N.B. α-Pinene and limonene have both been found in human breast milk.
Spicy Issues.

• A large number of essential oils & complex natural products are classified as R43 sensitising and/or R38 irritant, and
their use in fragrances has to be restricted to avoid
compulsory labelling. For example  ingredients such as
cinnamon leaf & clove oils were used to impart spice notes
in pot pourris & candles, but R43 issues with cinnamic
aldehyde & eugenol contents etc. mean that their use is
• The classification of methyl eugenol as a rodent carcinogen has also affected the use of methyl eugenol-containing spice oils in fragrances, such as clove bud, pimento leaf & pimento berry. The relevance of rodent data in predicting human carcinogenicity from methyl eugenol has been questioned (Robison & Barr 2006).

• The classification of safrole as a rodent carcinogen has curtailed the use of cinnamon leaf & nutmeg oils.
• The net effect of these classifications has had a severe impact on the construction of natural spicy notes in traditional masculine  perfumes, particularly for spicy accords where nutmeg/mace and  clove qualities has played a key role (e.g. mace in Cacharel Pour Homme (Cacharel
Naturals: Are Supplies Running Out?

• Another factor limiting the perfumers palette is the increasing demand for natural aromatic ingredients, against a background of limited production capacity, increased internal market usage by producing countries with large populations, such as China & India, rising ingredient costs (including increased fuel and packaging costs), extremes of climate variability, catastrophic geophysical events and the general over-exploitation of natural resources.

• So, in spite of rosewood & guaiacwood being passed into CITES Appendix II (CITES CoP 15, March 2010), many other natural ingredients face serious over-exploitation. By the time threatened species are Red Listed by the IUCN or listed in a CITES Appendix, it is often too late to preserve their full genetic diversity. Current examples: Asian styrax, agarwood oil
(various spp.), sandalwood oil East Indian, sandalwood oil East
African (Osyris spp.), Cedrela odorata oil, copaiba balsam,
gurjun balsam, candeia plant spp. (used by the German
pharmaceutical industry as a source of α-bisabolol), costus
qualities, Parmelia (fragrant lichen) qualities, some
frankincense yielding spp. (e.g. Boswellia papyrifera),
chaulmoogra oil and many others (see Cropwatch A-Z data-
base on Threatened Aromatic Species).

Toxicity studies on individual natural ingredients
– welcome to the world of make-believe!

•  Few toxicological studies on natural aromatic ingredients are available where the source botanical has been expertly identified, batch-
tracked, & has been sufficiently evaluated as 100% derived from the named botanical. This is true of many of RIFM’s  toxicological
assessments of natural ingredients which utilised non-batch tracked industry-donated commercial materials of unknown purity & origin, & many do not have an associated and sufficiently detailed chemical
analysis profile to be useful. The majority of these studies can be
dismissed as non-scientifically robust.
•  40-60% of natural aromatic ingredients are adulterated (Cropwatch
2009), yet RIFM has yet to carry out a single study on how this
widespread practice might affect the toxicity of fragrance ingredients.
•  A number of aromatic ingredients derive from-, or are co-gathered with-, more than one botanical species; virtually no formal studies exist which distinguish how toxicity is affected e.g. co-gathered Juniperus sabina berries with J. communis berries to make alcoholic extracts / distilled  liquor for gin-making in Central Spain (Casares
1964); opoponax from  “Commiphora Erythrea var. glabrascens Engler” (according to IFRA IL 815); in practice opoponax is sourced in markets and consists of a number of  mixed Commiphora, and other species.
Reductionism in Botanical Classification.

IFRA name /
species cited (if any).

Armoise: Artemisia alba; A. vulgaris - according to IFRA-IOFI labelling manual 2009 CAS No
68991-20-8 (both species). [A. herba alba extract also listed separately].

INCI name / COSING “perfuming name”: species cited.

COSING: Armoise not listed as such, but lists Artemisia herba- alba herb oil CAS No: 84775-75-7; Artemisia herba-alba oil
INCI: Artemisia herba-alba herb oil leaf oil CAS No: 84775-75-7.

Actual species used.

Mainly Artemisia herba-alba Asso
A. mesatlantica Maire; A. atlantica Cross. Dur.; A. vulgaris L.

Cedarwood oil Chinese. No botanical origin cited in IFRA-IOFI labelling manual CAS No: 8000-27-
9; EINECS-CAS No: 85085-29-6.

Ho oil (shui). No botanical origin cited in IFRA-IOFI labelling manual
2009. CAS 8022-27-9; EINECS-CAS No: 91745-89-0.

Litsea cubeba oil

Opoponax qualities from Commiphora erythraea Engl. var. glabrescens Engl.  – according to IFRA Standards Oct 14th 2009
COSING: Cupressus funebris wood oil from twigs of Cupressus funebris. CAS No: 85085-29-6.

COSING: Cinnamomum camphora linalooiferum wood, leaf and root oils all listed.

Litsea cubeba fruit oil from berries of Litsea cubeba. CAS No: 68855-
99-2; EINECS-CAS No: 90063-59-6

COSING: Commiphora erythrea Engler var. glabrescens Engler gum extract and oil CAS No 93686-
INCI: Opoponax oil is the volatile oil obtained from Commiphora erythrea or related species. CAS
8021-36-1; EINECS-CAS: 100084-
Mainly Cupressus funebris Endl. Also Juniperus chinesis,
J. formosana,
J. vulgaris.

Cinnamomum camphora L. var.
linaloolifera Fujita;
C. camphora Sieb var. glavescens

From several Litsea spp. Including Litsea cubeba (Lour) Pers., L. enosma & L. mollifolia Chun.

Commiphora erythrea Engl. var.
glabrescens. Also:
C, kataf (Forssk) Engl.
C. guidotti Chiov.
C. holtiziana Engl. holtiziana
C. pseudopali JB Gillet
Reductionism in Botanical Classification II.

IFRA name /
species cited (if any).
INCI name / COSING “perfuming name”: species cited.
Actual species used.

Santolina oil – botanical sp. not specified in IFRA Standard

Savin oil Juniperus phoenicea L. according to IFRA-IOFI Labelling Manual 2009. CAS No: 68916-94-9.

IFRA Standards: Savin oil should not be used as a fragrance ingredient if prepared from Junperus sabina L. Only oils prepared from Juniperus phoenicea L. should be used,

Linaloe wood oil
CAS 8006-86-8. Botanical sp. not specified in IFRA-IOFI Labelling Manual 2009.
INCI: Santolina Chamaecyparissus Extract is an extract of the Garden Cypress Santolina chamaecyparissus L. Asteraceae CAS No: 84861-580-

Savin oil not listed [Juniperus phoenicea L. wood oil rectified is listed].

Bursera Fagaroides wood oil is an essential oil obtained from wood
of the Linaloe, Bursera Fagaroides
syn. (?) B. glabrifilia, B. delpechiana Burseraceae CAS No:
Santolina chamaecyparissus L. S. chamaecyparissus ssp.incana S. chamaecyparissus ssp.
S. chamaecyparissus
- All produce eo’s with different compositions

Savin oil comes from Juniperus sabina L.
Cropwatch maintains that Savin oil has never been associated with J. phoenicea, which is commonly known as Phoenician Juniper.

Bursera aeoxylon (Schneide) Engl. wood and/or berry oil; also from other Bursera spp. including:
B. delphechiana Poisson
B. glabrifolia HBK
B. simaruba L.
Tarred with the same brush.

Although no credit was given, the author has been
instrumental in providing evidence to convince the UK & EU
authorities that citronella oil should be placed in Annex I of the Directive 91/414/EEC (Plant Protection Products) arguing
that, in contrast to Citronella oil Sri Lanka (Cymbopogon nardus (L.) Rendle), Citronella oil Java-type (Cymbopogon
winterianus Jowitt) has a zero to 0.05% methyl eugenol
content, and is therefore suitable for use as a crop protection substance for placing on the market.

Similarly revised safety assessment outcomes potentially exist for β-asarone-free calamus oils (EU regulations for
karotypes of Acorus calamus L. & A. europaeum for food &
beverage use under review), santolina oils from various
Santolina chamaecyparissus L. subspecies, tagete  qualities

from various Tagetes species, and many others.
IFRA’s 44th  Amendment

IFRA appeared to have had trouble convincing some of its members about either the need, or the validity of, a number of the contained Standards in the 44th Amendment to its CoP.
•  Vey (2010) publicly apologised for the mistaken banning of melissa oil.
Its is now unnecessarily restricted instead (see Robertet’s test data in
Cropwatch Files),
•  Similar concerns about the restriction of estragole have led to some policy revisions. The restriction leaves a hole (requirement for ingredients with an anisic odour profile) not easily filled by other ingredients (e.g. canthoxal) which may have their own restrictions.
•  An outcry against the severe restriction of the extremely weak allergen vanillin (an ingredient which could perhaps be added to any update of Martin Gras’s Overdose concept), led to the temporary suspension of the measure with a pledge of allotting more time in future for industry consultation to IFRA Standard revisions.
•  The restriction of benzaldehyde was predictable from a survey of previous patch testing publications, but again, leaves a gap in the odour spectrum for (bitter cherry etc) which is difficult to fill.
•  This comes on top of previous contentious restrictions for atranol & chloroatranol in oakmoss & treemoss qualities, and in other regulatory areas for coumarin, tea tree oil, peroxides in oils from the Pinaceae
etc. - and many we are still waiting for (especially in regard to FC’s in citrus oils).


•   BPD Biocidal Products Directive (as amended) Directive 98/8/EC
•   CLP Classification, Labelling & Packaging Regulation EC No. CLP 1272/2008
•   CMR: substance which is Carcinogenic, Mutagenic or Reprotoxic
•   COSING is the European Commission database with information on cosmetic ingredients
•   DG-Ent: Directorate General (Branch of European Commission responsible for Industry)
•   DPD Dangerous Preparation Directive 1999/ 45/EC
•   DSD Dangerous Substances Directive 67/548/EC
•   EMEA European Medicines Evaluation Agency
•   EWG Environmental Working Group
•   FC: FuroCoumarin (syn. FuranoCoumarin)
•   FDA Food & Drugs Authority (US)
•   ICCG Inter Committees Coordinating Group
•   IFRA International Fragrance Association
•   INCI International Nomenclature of Cosmetic Ingredients
•   QRA Quantitative Risk Assessment
•   RIFM Research Institute for Fragrance Materials
•   SCCNFP Scientific Committee on consumer Products and Non-Food Products
•   SCCP Scientific Committee on consumer Products
•   SCCS Scientific Committee on Consumer Safety
•   SCHER Scientific Committee on Health & Environmental Risks
•   SCENIHR  Scientific Committee on Emerging & Newly Identified Health Risks
•   SME Small to Medium-sized Enterprise
•   THMPD Traditional Herbal Medicines Product Directive


•      ANH Press Release (19th May 2010): ANH gains positive response following visit to China - see  http://www.anh- europe.org/node/3019?utm_source=The+Alliance+for+Natural+Health&utm_campaign=ab9f7f4046-
•      Casares R. (1964) “Juniperus sabina” Food Cosmet Toxicology 2, 680-681.
•      CSC (2010) – see  http://safecosmetics.org/article.php?id=644
•      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.
•      Daum C.M.L. (2006) “Self Regulation in the Cosmetics industry. A necessary reality or a cosmetic illusion?” Submitted paper for Havard Law Degree School 3rd year course work.
•      Demyttenaere C.R. "Recent EU legislation on flavours & fragrances and its impact on essential oils" in: Baser
K.H.C. & Buchbauer G. eds Handbook of Essential Oils: Science, Technology, and Applications p 923.
•      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.
•      Dufour E.K., Kumaravel T., Nohynek G.J., Kirkland D. & Toutain H. (2006) "Clastogenicity, photoclastogenicity or pseudo-photo-clastogenicity: Genotoxic effects of zinc oxide in the dark, in preirradiated or simultaneously irradiated Chinese hamster ovary cells." Mutat. Res. 607(2), 215-24.
•      Durodie B. (2004) “The timid corporation – why business is terrified of taking risk.” Risk Analysis 24(1), 2004
•      Floc’h F. (2002) “Coumarin in plants and fruits: implications in perfumery.” Perf. & Flav. 27 (Mar/Apr 2002), 32-36.
FMA (2010) “U.S. Fragrance Association Finds New Cosmetics Report Misleading –
Fragrance Safety Is No Secret” May 13th 2010  http://fmafragrance.org/sub_pages/CSC_release2.pdf
•      Gras M. (1990) “The Overdose” Dragoco Report Nov/Dec 1990.
•      Gras M. (1991) “The Overdose II” talk presented at WPC, May 14-17, Palma de Mallorrca.
•      Hagvall L., Sköld M., Bråred-Christensson J., Börje A. & Karlberg A.T. (2008) "Lavender oil lacks natural protection against autoxidation, forming strong contact allergens on air exposure." Contact Dermatitis. 59(3), 143-50.
•      Hagvall L. (2009) Formation of skin sensitizers from fragrance terpenes via oxidative activation routes: Chemical analysis, structure elucidation PhD Thesis University of Gothenberg.
•      Herman S. (2008) “A deep breath.” – see www.stephen-herman.com/085.pdf
•      Hostynek J. & Maibach H. (2008) “Allergic contact dermatitis to linalool” Perfumer & Flavourist  33, 52-56.
•      Hostynek J.J. & Maibach H.I. (2003) "Is there evidence that anisyl alcohol causes allergic dermatitis?" Exog.
Dermatol. 2, 230-33.
•      Hostynek J.J. & Maibach H.I. (2003) "Is there evidence that amylcinnamic aldehyde causes allergic dermatitis?"
Exog. Dermatol. 3, 35-46.
•      Hostynek J.J. & Maibach H.I. (2003) "Is there evidence that linalool causes allergic dermatitis?" Exog. Dermatol. 2,
•      Hostynek J.J., Maibach H.I. (2004) “Is there evidence that geraniol causes allergic contact dermatitis?” Exog.
Dermatol. 3(6), 318-331.

References cont’d.

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