lundi 13 avril 2009

The Human Repeated Insult Patch Test

When I first saw the name, I envisioned Band-aids hurling abuse or mumbling snarky remarks to test my composure. In fact, the Human Repeated Insult Patch Test is one of the methods by which dermatologists evaluate the allergenic potential of substances, by applying them on the skin repeatedly over a certain period of time…

I know. I’ve been there. Allergy is my lifelong companion. As a child I tested positive to a bunch of things, including dust mites, cats and perfume. My parents decided to change nothing in our lifestyle – we keep the cat and the dust-gathering books, two things they deemed impossible to live without.

I feel the same way. So what if I get the sniffles once in a while? I’m still alive. With one cat, several billion house mites and a couple hundred bottles of perfume.

When I developed a facial rash, I went back to consult, though. I spoke to the allergist about my perfume habit, and she tsk-tsked sternly, reminding me of the nuns in high school – she had the white, chopped off hair and pallid skin I’ve only seen in nuns, come to think of it. You’ve no idea how much allergists detest perfume: they seem to view it as a futile reason to give them more work. And this one clearly steered clear of most cosmetics.

Well, it wasn’t the fragrance mix. I never knew what caused the rashes, but I suspected my fancy-pants wrinkle creams, so I radically simplified my skin care routine… My problem’s pretty much cleared up.

The moral of this story? I was exposed since childhood to allergens and didn’t die (I’m not saying people don’t die of allergies; I was lucky it wasn’t severe). And when I get a rash, I AVOID the suspected products. Simple as that.

But as it is, I feel repeatedly insulted by the members of IFRA[1], who seem to consider that putting an allergy warning on a box (like food manufacturers for peanuts, which can get some people dead, admittedly a worse problem that a rash) is not an option. No, they’d rather fantasize on a “zero-risk” approach, as though that existed. And they demonstrate the same blatant disregard for their heritage that they’ve expressed throughout the years by sneakily reformulating their products – which is, in itself, a repeated insult. I’m not talking about the people at the creative end of the process: those people are crying.

Now, the big labs have been suspected of having pushed for stricter IFRA directives in order to sell more synthetics. It’s possible, but none of us was there to witness the lobbying, if any.

That said, most of the restricted materials are either naturals (jasmine, ylang-ylang, oak and tree moss), or present in naturals in concentrations significant enough to indirectly restrict the use of those naturals.

Furthermore, most of the synthetic materials on the Amendment 43 list are “old” molecules -- hence their presence in the classics -- and thus, not under patent. They will still be made, as there is some demand, but presumably in lesser quantities. (Thanks to Octavian Coifan for checking up on this).

So the big, shiny, expensive new synthetics still under patent will presumably sell more. But the labs are responsible for composing the reformulations – the brands don’t pay for this work to be done. And as they won’t be willing to pay more for the oil either, it won’t just be a matter of removing the allergenic materials and finding combinations to replace them: if an expensive synthetic goes in, something has to be made cheaper elsewhere. If the lab produces the synthetic, it’ll be less expensive than if they have to buy it from another lab… In short, it’s a complicated matter.

So, is Big Aroma entirely responsible for the thrashing of one century of perfumery?

Or is it also the craven “zero-risk” mentality of our society, coupled with the explosion of allergies-- including a record number, it seems, of potentially fatal anaphylactic shocks, none of which are triggered by fragrance, by the way?

Is it a symptom of a more general intolerance of all by all, in a world in which we suffer repeated human insults great and small? Perfume is a sneak: it is perceived by a passive sense. And it can be a blatant revealer of intolerance (just as it can be a WMD if over-applied). You can choose not to wear it if it gives you rashes, but you sure as hell can’t escape smelling it. Which is, I suspect, the pinch: the neo-puritans aren’t petitioning to get a rash-free Mitsouko at long last -- they’re out for the old girl’s skin… And because fragrance is an elective product, and a gloriously useless luxury, it can be hurt by a puritan, anti-fragrance backlash. The money people know this.

So, in fact, this may well be a matter of censorship, with the industry caving in, in the hope that by chirping “but our products are perfectly innocuous”, they’ll escape the chopping block of the pleasure police.

At any rate, I’ll continue poking around and asking questions – if I can figure out which questions to ask: it’s an insanely complex matter and not one where I’m likely to get any answers – especially about the studies that IFRA based itself on to issue the directives.

In the meantime, I’ll be getting back to fragrance reviewing by the end of the week. If my allergies let up (hay fever season again!).

[1] Just to clear up a point that seems to confuse a lot of readers: The International Fragrance Association (IFRA) is an organization whose members include practically every company (be it a lab or a brand with an in-house perfumer) who produces fragrance and aromatic materials. All members must comply with its guidelines, and IFRA compliance is considered by most countries to be a sufficient guarantee for the safety of the product. So we’re not talking about a law that is imposed by European legislators. This is just the industry shooting itself in the foot.

40 commentaires:

  1. Aaaaaaarrggghhhhh!!!! This whole thing is making me crazy!!! Yes -- if you're allergic to something, stop using it! Why is this difficult? Please forgive my vulgarity, but why can't people wipe their own @$$*$ anymore???

    As to the possibility of the industry doing this to us to line its own pockets, I am just left sputtering with rage. I'm going on record here saying I'll support a boycott by all perfumistas to make our point.

  2. Hello, D -- yes, the concept of "repeated human insult" takes on new meaning here. :-)

    Thank you for clarifying the regulatory role of the IFRA. As you point out, the IFRA standards are essentially a form of self-policing by the industry. However, my understanding is that the EU also has a regulatory framework called the "Cosmetics Directive," which does, I believe, put the force of law behind certain restrictions. It's rather dense reading, but some of it can be found starting here:

    I get the sense that the Cosmetic Directive essentially follows the IFRA guidelines.

    Meanwhile, from what I can tell, there *is* supposedly a rigorous scientific framework for risk assessment and evaluation that informs the IFRA regulations. There is a "science-based, non-for-profit" Research Institute for Fragrance Materials (RIFM) that is supposed to engage in research to evaluate the safety of fragrance materials. Though the RIFM itself was established in 1966 by the fragrance industry, it is apparently guided by an independent expert panel (REXPAN) made up of scientists with expertise in "dermatology, pharmacokinetics, toxicokinetics, toxicology, pathology, and environmental science." In any case, I bring this up because the research upon which the IFRA bases its guidelines is supposedly published in peer-reviewed scientific journals, so with some digging, one should theoretically be able to find these original papers to review. (That said, I have been having a hard time actually finding the papers). (This information about RIFM and REXPAN in relation to IFRA comes from:Bickers DR, Calow P, Greim HA, Hanifin JM, Rogers AE, Saurat J-H, Sipes IG, Smith RL, Tagami H. The safety assessment of fragrance materials. Regulatory Toxicology and Pharmacology 2003:37;218-273).

    What I get from all of this is that there are multiple actors involved here: not just the industry and IFRA, but also scientists (RIFM and REXPAN) [with all the attendant complexity of where these scientists get their funding], legislators, and consumers. I have a sense that the scientists are coming from a conservative toxicology or clinical dermatology framework where any risk is too much risk, and these considerations are driving the regulatory guidelines.

  3. StyleSpy, yes, there *is* that nagging feeling that the money men in the labs said: "Oh, you want to restrict those materials? Well, that's fine with us, we're not making that much out of them anyway..." Of course, due to the insanely complex process that lead to the guidelines, we may never, ever know...

  4. Jarvis, thank *you* for this outline (which I somehow didn't have the courage to explain in yet another footnote).
    Two things, to me, stand out in what you say:
    - Who is funding the research?
    - The conservative mindframe in which this research was conducted.

    I haven't worked out yet if the new guidelines establish a distinction, for instance, on the surface of body to which a product is applied -- clearly it is smaller in the case of an extrait than in that of a body lotion, for instance. I don't know if that would be relevant.

    I haven't clearly understood, in the Risk Assessment Protocol for research on allergens, if the samples to be tested must be of a specific grade of purity?

    In which case, as Octavian indicates in a reply to one of his own posts, no provision seems to have been made for distinction between various grades of a material -- some are clearly less allergenic than others: O. states the case of coumarin, in which it is the artifacts produced by the synthesis, and not coumarin itself in that specific grade, which are allergens.

  5. You make a great case for "scentsorship" when it comes to testing. The dismay expressed by several fragrance bloggers makes one wonder if making a case for the invisible requires visible means (i.e. You Tube)on top of top notch investigative journalism.

  6. Michelle... "Scentsorship" is a great word, and I'll reuse it! YouTube is an idea... Investigative journalism, definitely, and I'm putting together a letter to try and interest the scientific media...

  7. I'll be concise: allergens-free synthetic molecules might cause cancers, hormonal disorders, sterility after 20 or 30 years of exposure.
    Allergens from natural ingredients in perfumery it's such a joke. Easy to detect, these relatively harmless natural allergens don't get the support of big corporate lobbies...perfect scapegoat for IFRA!

  8. C'est dans l'air: I'll be concise too. "Might".

    Also: this is the link to the 43rd amendment

    Count the synthetics. There are lots. Also restricted.

  9. carmencanada,

    did you know synthetic molecules and chemicals are the culprit of chronic diseases including cancer, neuro-degenerative diseases, male sterility etc.?

    When it comes to allergenic natural ingredients it doesn't take years of research studies and millions of dollars to prove oakmoss causes skin rashes to less than 1% of the population. Besides noone owns their patents, it's a loss of profits for big fragrance and flavor companies.

    Nobody knows anything about chemical molecules unless it's already too late. Many consumers activist groups are concerned with the staggering number of synthetic chemicals we have in our bodies compared to what it was 40 years ago.

  10. C'est dans l'air, consumer groups are worried, and rightly so. It is because consumer groups are worried that they are also targeting fragrances. And that baby jasmine is also getting thrown out with the bathwater, because if you're going to test materials, you're going to test them all, and if you test enough, you're bound to find enough people who are allergic, including to stuff that's been around for millenia.
    Hey, I'm violently allergic to pollen right now, and that's natural, but I'm not asking the city of Paris to chop down the trees in the Champ de Mars.

  11. First comment on your wonderful blog. I just became aware of it and am now digging around your archives. Sounds kinda creepy, actually.

    Honestly, I don't know much about all of this business. However, I know that I get a small, itchy irritation from Tom Ford's Purple Patchouli, the first perfume ever to have that effect. And, considering how it smelled, I'm not sure I care. I'd certainly put up with a few hours of irritation for the smell. That's a bit extremest for most people though, I know.

    I don't know why we have to just jettison the entire allergy list. My mother is allergic to nutra-sweet, specifically phenylalanine. That doesn't mean they have to reformulate Diet Coke for her. She just won't drink it.

    Incidentally, they released a Diet Coke with Splenda, to which she isn't allergic, but that's besides the points. If you're allergic, move on. There aren't only three perfumes out there. There are gads of them.


  12. It bears noting that the population prevalence of oakmoss allergy (e.g. 1.6% in some recent European surveys) is not the same thing as the probability that someone will develop an allergy to oakmoss after repeatedly applying an oakmoss-containing perfume to their skin over months and years. The relatively low population prevalence reflects the fact that not everyone in the population is exposed to oakmoss to the same degree. From a risk assessment perspective, I can see how it would be more useful to know how likely it would be that someone would become sensitized given that they were using an oakmoss containing product. This is presumably determined using that "human repeated insult patch test." That said, I still haven't been able to find published data on the results of this kind of testing with oakmoss or jasmine absolute (for example). My understanding is that these tests are usually conducted with a handful of "volunteers," but that brings up other concerns. Who are these "volunteers"? Are they likely to be like the general population, in terms of their likelihood of developing allergic sensitization? Have they previously volunteered for other repeated insult patch tests? Is it possible that they might more readily develop allergic sensitization, if they've already been repeatedly insulted with other allergens?

  13. Anonymous: I agree. If you're allergic, you read the labels, and avoid.
    For Purple Patchouli (or any other fragrance you adore and might cause a reaction): spray fabric! A scarf, a teeshirt... I do that for frags that tend to fade too quickly, but no reason not to use the method if you suspect it of being the cause of the small rash.

  14. Jarvis, again, thanks for the added precisions. From what I know, it's mostly med students who volunteer for that kind of test? Or is it like for phase III clinical trials, patients recruited by their physician?

    If you download the 43rd amendment on the IFRA site, you'll find the literature for each material is referenced in RIFM reports. I don't know if those reports are accessible to the public, though.

  15. It would be better if "la Presse Féminine" tells consumers what's going on instead of scientific would be Really great if consumers, perfumistas...tell in the everyday press what's going on...

  16. Anonymous: I was just thinking along the same lines this morning. But women's magazines will NEVER cover a story that has a negative impact on their advertisers. I know, I've worked in those magazines.

  17. Hi, Denyse --

    Thanks for that link to the IFRA Amendment. To help interpret the various acronyms and various testing procedures, it may be helpful to refer to the papers in this special issue of Regulatory Toxicology and Pharmacology, linked here from the RIFM website:

    There are several informative articles in here on the Quantitative Risk Assessment process, the protocol used for a HRIPT (human repeated insult patch test). The last article walks through an example of the risk assessment data for Citral.

    One of the things I got from this is that the HRIPT is really focused on establishing a NOEL (no observed effect level). So it is really geared towards finding a level at which NO sensitization effect is seen. (This rests on an assumption that all individuals are equally likely to develop sensitization, which may or may not be true).

    Anyway, I'm finding that there is a LOT to learn about this process, but in a way I am glad to hear that there is a process, and that these determinations are not completely arbitrary.

    Re: volunteers for HRIPT. I'm not sure who the volunteers would be? For research conducted in an academic setting, you're right: the "volunteer" subjects are often medical students. RIFM is based in Woodcliff Lake, NJ; I'm not sure who they are getting as volunteers. I'm curious about whether the same volunteers are taking part in different studies (although the HRIPT protocol does have "induction" and "challenge" phases that supposedly should help to identify people who are pre-sensitized).

  18. Jarvis: if the "no adverse effect level" is the level that is indicated in the new directives, that means that, in effect, IFRA is aiming at "zero risk".
    It also means that "zero risk" is deemed much more important than being consistent with what you're selling. You sell a different juice under the same name with the same bottle, but you don't tell consumers.
    Who will basically be getting screwed.

  19. Wow! I'm impressed.

    Just to chime in, in my experience "volunteers" are students (if the research is conducted in an academic setting or on a campus) or people culled from the general population via ads in newspapers, etc. I see these all the time in our daily paper here. I've heard that some people "volunteer" for medical research for a living, but can't really back that up with any facts that I know of.

    I can't help but wonder what confounding variables these kinds of "volunteers" bring to a study.

    Also, the subject populations are often small. Many studies you'll see quoted all the time in general media are based on, for example, 12 Harvard undergraduates, who were required to volunteer for the subject "pool" if they majored in any social science.

  20. I've written to D about this via email, so this will be repeat info to her. But I want to comment to everyone else.

    If you read through the IFRA website, it's clear that their main "allergic" concern is dermatological. People getting a rash or irritation from using perfume or cosmetics on their skin. And this is not an allergy anyway, this is irritation/sensitivity! If the IFRA were really concerned about allergies, they would be working with allergists, and their concerns would be asthma and anaphylaxis, medical problems you can die from! You don't die, or have significant ill effects from contact dermatitis. As others have pointed out, you stop using the product and move on.

    And instead of restricting natural essences (unless it does have proven toxicity at certain levels like bergamot), put a freaking label on your product warning the public that skin irritation might occur, cover your a$$ (CYA as we call it in health care) and call it good.

    Arg! I'm with StyleSpy! Boycott major corporate perfume (and instead support small artisan perfumers!!)

  21. Olfacta, there was an IFRA meeting reported on some time back in Perfumer & Flavorist, in which a professor questioned the research (population representativity, different standards, etc.). I'm thinking of contacting this professor, who's certainly more qualified to evaluate this.

  22. Trish, I wonder if the CYA clause is sufficient in Europe... No idea, but another reader, who's a lawyer, seemed to think not.

    Looking through the RIFM website and various presentations you can find on the net, materials are also tested for other issues: inhalation,presence in the environment, etc...

    But I agree, rashes seem to be the main concern.

  23. CYA is just slang here in the US. Something we say between providers. Like "you better chart that to CYA"



  24. Hi, Denyse. Based on what I'm reading, I would say that it is definitely the toxicologists' and clinical dermatologists' perspective to establish that "No Adverse Effect Level" (NOAEL -- I left out the "adverse" in my earlier post). It's interesting to me that this requires that there be absolutely NO adverse reactions at all, as though we could imagine there being a clearly defined threshold, below which no one reacts, and above which everyone reacts. In reality, I imagine that it is more of a slippery slope, with more sensitive people reacting at a lower concentration, and less sensitive people not reacting until they were exposed to higher concentrations. Of course, it's difficult to imagine how to define a cutoff for policy making if one allowed for a distribution of susceptibility in the population.

    The RIFM papers specify a range of issues they are concerned with, not limited to contact dermatitis, but also including respiratory allergies, photosensitization, phototoxicity, and mutagenic/carcinogenic effects. I believe that allergists and immunologists do consider contact dermatitis to be a type of allergic reaction (delayed type hypersensitivity reaction). In the protocol for the HRIPT (human repeated insult patch test), there is an "induction" period and "challenge" period of exposure to the test substance. If symptoms appear during the induction period (when the substance is first applied to skin), the reaction is considered either due to physical or chemical irritation or pre-sensitization. Reactions during the "challenge" phase are the ones that are of direct interest for establishing allergic sensitization.

    I agree with Olfacta that sample size is a big concern here. Although the RIFM papers suggested that an ideal HRIPT study should have at least 100 subjects, it's clear from the review of the Citral evidence in the same journal that many studies have much smaller sample sizes.

    I suspect from the history of the RIFM, the focus on dermatological effects is in part due to there having been a lot of dermatologists and toxicologists involved from the beginning. In contrast, I don't see there being much of a population-based perspective involving epidemiologists. (My personal pet-peeve, being an epidemiologist).

    As for the issue of consistency, it's a sort of wooly headed thinking on the part of fragrance companies, isn't it? Sort of a "maybe if we don't tell them it was reformulated, most of them won't notice?" LOL.

  25. Jarvis: yes, from what I understand "pre-sensitization" is why you can apply something for ages and all of a sudden you get a rash from it (my own story with purple eye-shadow -- don't ask, it was the 80s..).

    Now here's what my own googling yielded: on the 10 experts of REXPAN, 7 are dermatologists, one is a toxicologist, one a zoologist specialized in ecotoxicology, and I couldn't find the last one.
    Now I don't know what the hell use that is to know, but now we know.

  26. Since their arguments don't make any actual sense, and since I am unaware of a consumer group pushing this vital legislation to save us from ourselves, I've reached the conclusion that it's somehow in the best interests of the perfume makers themselves (patented ingredients? some of them are very expensive). Certainly the great houses haven't been up in arms about it.

  27. March: Sources intimate to me have put me in a position to disclose... well, in plain English, I've been hearing from the way the big labs work and it's not as clear-cut as all that.
    1/ The labs bear the cost of reformulating
    2/ This means pulling out the formulas of each and every pre-directive formula (going back to last summer when the first news leaked out);
    3/ Throwing out the batches of what had already been produced;
    4/ Disposing of banned materials, if any

    ALSO: The big labs own the major natural materials labs which will be finding less of an outlet for their product.

    It's hard to imagine ALL the big labs rubbing their hands, each waiting to pop out the expensive patented molecules that will replace everything -- ok, so you never know, but still. Mostly those new molecules are used in new compositions, especially since:

    5/ The brands won't pay a cent more for a reformulated product.

    A possibility is that they are anticipiting REACH, a new regulation which I will look into shortly: it's apparently a lot more strict.

  28. Hi, D. Thanks for commenting on the whole profit motive. As I read more and more of this literature, I have a sense that what we're dealing with here is the madness that ensues when worlds collide (toxicologists, dermatologists, fragrance manufacturers, regulatory bodies, etc.)... I'm not discounting the profit motive of companies, but I don't need to posit a Machiavellian master plan to see how the varying agendas of those parties could give rise to this situation.

  29. Jarvis, if you go to the French version, you'll see a comment from Jeanne at in which she explains the following:
    Dermatologists, she confirms, have very powerful lobbies, especially in Scandinavian countries, and have a historically anti-fragrance bias.
    Whereas the fragrance industry has never managed to present a united front, because it is engaged in a fierce competition. Unlike, for instance, the food industry, which has extremely powerful lobbies, and so, can use toxic ingredients in all impunity.
    Like you, I think that the Machiavellian masterplan hypothesis can't stand.
    What it does reveal, though, is that the fragrance industry has little to no regard for their consumers, and even less for their compositions.

  30. Ha! Thanks for the laugh of the day! You and your secret sources. I commend your discretion.

    Reading your response to me and your discussion with Jarvis then simply leads me to the depressing conclusion that you're right -- that the manufacturers and houses couldn't organize their way out of a paper bag and are too busy fighting with eachother to mobilize themselves and consumers to pitch a fit. If I can have acceptable amounts of cockroach parts and beetle dyes in my food, why can't I have allergans in my perfume? I think they should do what gun-shy American food producers have done for the allergic (slap a peanut/tree nut warning on everything to avoid being sued) and slap a big ol' THIS MAY CAUSE AN ALLERGIC REACTION on the side of the box, but maybe that only works in the US.

  31. March, the more I look into it, the more I think that's the problem.
    The main IFRA discourse seems to be that they want to be pro-active to fight an anti-fragrance backclash. Seems Anglo-saxon and Scandinavian countries are leading the way on that one. It could be, apparently, the next anti-smoking type campaign... The suits are clearly quaking in their suits.

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  33. I changed my mind a bit after reading perfumeshrine's post on the subjet (well, a bit), which was an interesting post out of the chorus. Apart the real "poisonous" stuff, on which everyone seems to agree, I didn't know there was more than just allergy concerns (see: sensitizing) for which patch tests are not useful, nor did I think too much about the fact that historic vintage perfumes are in fact one and many (due to continuous reformulations throughout their history) so in fact the "save the species" appeal seems a bit out of place (or an ill-posed appeal at least).
    I think the real problem is the wild reformulation habit without adequate information, and it makes me sad to think about the disappearance of certain perfume notes (actually mainly due to sustainability or animal concerns rather than allergy), and that the face of the business is changing giving more and more power to big, patent-oriented, chemical companies.

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  35. (The above comment was suppressed because of a double posting).

    Zazie: the main recent disappearance of a material motivated by the preservation of the species was, to my knowledge, Mysore sandalwood, to which there is no adequate substitute so far. Animal ingredients are practically not used any more except by micro-niche brands and in Middle-Eastern perfumery, I suppose. Although I would surmise that Chinese traditional medicine is the main culprit here.

    Of course, formulas have ALWAYS been tampered with throughout the 20th century, increasingly so in recent years. And of course, it is easier to put more reliable (in terms of sourcing, cost and consistency) synthetic ingredients in formulas than natural ones: this would definitely appeal to the money men.

    The bottom line is that perfume companies have been pulling wool over the eyes of consumers for years by sneaky reformulations, and will not communicate on these further reformulations if some sort of public stink isn't raised in the mainstream media.
    If anybody cares, that is, except the anti-perfume campaigners.

  36. Hi D, another fascinating post and conversation. Having lived through the last 8 years here with people committed to dismantling and remandtling laws to make the highest possible profits for Big Business, with the help of the most Business Friendly Supreme Court of all time, you can imagine how cynical I am.

    It is very easy to skew the perception of fragments of research to support whatever you need it too, coupled with the coercions of people who pour tons of money into "research" and lobbyists efforts etc.

    Sadly, this issue, which to us is a perfume issue is really nothing of the kind, it's Business plain and simple, aided and abetted by normal people's natural fears and reverence for "scientific research," so it can easily appear as if it is regulation meant to protect us. What we see with drug companies over here, outlawing natural substances in order to protect their synthetic substitues tells the story.

    Bizarrely, people's reactions to the most egregiously chemical scents can be used to butress this insane legislation which restricts naturals! I sat behind a grown woman at the theatre the other night wearing an absolutely disgusting gourmand candyfloss number, and I had a hangover from it the next day.

    If I wasn't aware of the huge differences between scents produced for $1 a bottle and their distant cousins, I could unknowingly stand behind legislation to restrict perfume, thinking it would protect me, not realizing that it will only exascerbate the problem, as we have found out the hard way over here.

    I'm sure you've all heard about Michelle Obama planting an Organic Garden at The White House being condemned by chemical companies saying she has to use chemicals on her organic garden in order to show The People that there is truly Better Living Through Chemistry. Luckily this White House doesn't have "advertisers" to stand behind (yet) and she is continuing.

    The $10 Billion dollar perfume industry has a lot to gain from this legislation, and people's well-being is not on their list. You can imagine the amount of clout our beloved Serge Lutens (or even Guerlain?) has on the IFRA compared with their gigantic suppliers!

    Sorry to be so cynical, I just can't help it!


  37. Wendy, I'm not exactly sure what the industry has to gain from this legislation, frankly: as I've explained above, the IFRA guidelines, which were integrated by the European Cosmetics regulations, will, at least initially, cost suppliers a great deal more than it will benefit them. And there are many more synthetics than naturals in the restricted materials list.
    In Europe, regulation begets more regulation, and the perfume industry does not have strong lobbies.
    I realize from an American point of view this may seem outlandish, as America (and much of the Anglo-saxon world) has seen crazy deregulation over the past years, but the matter is very different in Europe, where the EU is a mad regulation metastatic generator.
    To me the real problem is that the decision-makers in the industry don't care enough about their own history (not to mention their artistic integrity) to fight back.

  38. The human ability to wallow in paranoia is incredible! 'The synthetic producers are manipulating IFRA to drive the natural producers out'. 'This is all about profits for the fat cats'. You guys would not believe how far off base you are. The whole industry regulatory process is much more straightforward, and is founded on principled actions that seek to do the right thing for, first, the consumer, and second, everybody else. I appreciate that it is easy, from the comfort of your keypad, to heap scorn on those who, indeed, are trying to save 'an industry' (but perhaps not the industry of 20years ago that you would like it to be). If you have a magic solution for dealing with the European Commission, which is sponsoring the legislative assaults on fragrance, write it here. If you have the answer for dealing with the unreasonable NGO's who are out to destroy fragrance, write it here. If you are passionate about fragrance, don't just sit there and carp; do something!

  39. Anonymous: I suppose that you are reacting to reader comments rather than to my post. I never subscribed to the "conspiracy theory" and have only reported on it.
    The more I delve in the subject, the more I am aware that the "zero-risk" policy EU authorities are aiming for is responsible for this situation, along with lobbying and campaigning on the "anti-perfume" front.
    I did do something about it, and I intend to continue.