As you probably know, essential oils are made up of chemical constituents, as found in nature. There has been a move, within the EU, to limit the use of these oils in perfumery, by going after these components, and therefore mandating the use, only, of the isolated constituents deemed "safe."
There is move to counter this, and the letter is replicated below. If you would like to add your name, please read and download, and go to the link to add your signature.
Chemicals Strategy for Sustainability: An Open Letter from Perfumers
We, perfumers, and fragrance creators, are writing to you about some of the proposed concrete actions under discussion within the European Green Deal.
We are committed to environmental safety and the protection of human health. We agree with you on the overarching goals of the European Green Deal and the EU Chemicals Strategy for Sustainability. These are central themes in our work and the primary concern for any fragrance we create is its safety – without that there is no product.
The essential benefits of fragrance are so integrated to our daily lives that they may feel difficult to quantify or understand. If you have ever smiled when you get a burst of fragrance in the shower, if you have felt relief when a scent has masked a malodour, if you feel cared for when your body lotion smells soothing, if your hair feels healthier because the fresh scent in a shampoo enhanced your experience; if you've ever wept when smelling the perfume of a missed loved one - these are just a handful of the incalculable number of essential experiences created and enhanced by fragrance that are under threat from revisions of REACH, CLP, and downstream product regulations like the Cosmetics and Detergents regulations. Fragrance is a key benefit to society that improves the mental and physical well-being of billions of users on this planet.
If we were to adopt the proposals currently in discussion, over 400 materials could be banned.
This potential limitation of our palette would not improve fragrance safety, consumer safety or environmental safety, as our work in these areas already ensures fragrances are safe. The abandonment of expertise in this matter would not be justified on public health grounds and would have collateral effects on the preservation of EU’s cultural heritage and the agricultural and industrial sectors deriving from it.
The fragrances we create are inspired by nature. By volume 50% of our palette of fragrance ingredients are substances identical to nature. Fragrance chemists who create new molecules focus on safety, sustainability and renewability which are the guiding principles of modern fragrance innovation. We challenge suppliers and chemists to provide us with safe and renewable ingredients, and when they do so, we reward them by using these innovative ingredients in our formulae.
We are guided by the expertise of our trade body International Fragrance Association (IFRA) an its independent research body (RIFM: The Research Institute of Fragrance Materials) consisting of toxicologists, chemists, data scientists, environmental scientists and more. Our industry is the only speciality ingredients industry to have voluntarily instituted safety requirements. If there is a valid reason to ban or restrict a material, we act accordingly, and still create fragrances that delight the consumer.
Perfumers follow standards set by RIFM and communicated to us by IFRA. In our daily work of fragrance formulation, we use complex analytical tools and software to calculate the chemical composition of our fragrance creations. We see, and can control, the levels of materials included in such a way that the finished fragrance represents no risk to the consumer as used. The levels of
individual fragrance ingredients in cosmetic and household products are often well below 0.01% of the finished product. The level of exposure determines risk.
We have serious concerns about the proposals about reclassifying natural complex substances (essential oils, natural extracts) as intentional chemical mixtures. This change, along with the abandonment of the risk doctrine would result in significant negative consequences for European citizens.
We also have serious concerns with ECHA’s approach to grouping chemicals using non-scientific methods to speed up their efforts to define and restrict hazardous materials via the CLP Regulation, and downstream use regulations such as the Cosmetics and Detergents regulations. This has the potential for mistakenly identifying chemicals and naturals with an inappropriate hazard, while also potentially missing other chemicals where hazards should be added.
A good example of why it is important to group substances for classification purposes by using transparent and appropriate criteria is p-cymene. It is a constituent present at 0.3% or above in over 350 natural complex substances (including fruits, vegetables, and spices). Banning it and any “chemical mixtures” it is contained in, would subsequently cause the ban of these natural materials. Lemon and thyme oils for example would now be classified as too dangerous to include at any level.
Human beings are in daily contact with many of the chemicals that form part of the perfumer's palette - through food, flavours, and nature, not fragrance. Encounters with chemicals used in fragrance are at a much lower level than something as ordinary as peeling an orange. Limonene is a major chemical constituent of citrus fruits. Citrus oils are used as fragrance ingredients. Peeling one orange a day is equivalent to 140 sprays of a modern women’s fragrance (that is at 12% in alcohol and includes limonene as one of its components).
We are in full agreement on the goals for environmental safety and human health. However, the key elements of the CSS as currently proposed would not deliver on these goals. In fact, they could be counterproductive. If it goes through as it currently stands, the CSS would threaten consumer choice for no additional safety or environmental gain.
The above reasons are why we oppose the idea of abandoning safe use and minimal exposure as consumer product safety concepts, as these are the very foundations on how product safety can be determined rationally and scientifically.
We would welcome the ability to collaborate with The Commission to help find more workable solutions for fragrance ingredients that would prevent the unintended consequences we have described above.
We call on you to reconsider these policies and are ready to work with you to achieve our mutual aims.
Yours sincerely The undersigned
Sign the letter here: https://bit.ly/perfumersopenletter