I know: it's long, it's not particularly sexy reading and I promise I'll get back to more distracting perfume topics next week. Meanwhile,this is the 2nd part of Stephen Weller’s answer to my letter. To read Part I, click here.
Why isn’t the industry involved in a more pro-active public campaign to disprove the bad science which supports the claims of anti-fragrance lobbies?
Aren’t the EU regulations of REACH, which compel “all manufacturers and importers of chemicals [to] identify and manage risks linked to the substances they manufacture and market”, the real problem?
I think it is important to clarify the regulatory issue here. It is not REACH. The fragrance industry is quite able to deal with the demands of REACH, albeit at a cost. The real issue lies with the Directorate General for Consumer Protection (DG Sanco) and the Scientific Committee for Consumer Safety (SCCS), which I mentioned earlier. It has a stated policy aim to reduce the risks any product poses to EU consumers, including contact dermatitis. Studies have shown that allergies to fragrances affect less than 2% of the population. However, the European Union is committed to ensuring that citizen’s health and safety are properly protected and any risk, it seems is too high. This is the political reality faced by all manufacturers of all products, not just the fragrance industry. Many of the materials we have to address at IFRA are due to a direct request for data from the SCCS. They tell us that there could be a problem with a material and we then have to provide data to support the continued use of that material. This is how it works in the EU. We at IFRA spend our time defending molecules for perfumers.
Several of the natural materials listed in Amendment 43 (or concerned because they contain listed molecules in high proportions) have been used for centuries without, apparently, decimating entire populations. Couldn’t there have been a communications campaign, directed towards political authorities and the general public, on this point? After all, one of the main causes of allergy is hay fever, and no one is campaigning to pull out trees from cities. Contact dermatitis is easier to avoid than breathing in pollen-laden air…
I can assure you that it does not matter to a regulator if a material has been used for centuries, quite happily, without harming anyone. They will regulate based on the current data on a material and the results of a Risk Assessment. Where the data is wrong or incomplete, we at IFRA along with RIFM endeavor to correct it and usually do. We cannot get away from the fact that some fragrance materials, be they natural or synthetic, elicit contact dermatitis in some people. This has to be addressed in order for fragrance to survive at all in the modern regulatory environment.
Some general comments:
You mention that you are not aware of any anti-fragrance campaigns [in my letter, I was referring to the situation in France, and stating that these campaigns seemed to me to be predominantly Anglo-Saxon and Scandinavian], but I can assure you there are many. I do not wish to give oxygen to their campaigns here but I encounter them daily and we do our best to respond. It is not an Anglo-Saxon issue, it is a global issue. A trend beginning in
I would be happy to enter into a dialogue on these subjects. I realize that there are many, many people interested in this subject and I feel that they should have the facts. As you rightly say the problem is the wish for a 'risk-free' society. This is the political reality we face globally. The fragrance industry is doing its best to navigate this regulatory environment and keep as many materials available as possible for the creation of fragrances. The conspiracy theory you mention simply does not make commercial sense. All fragrance houses use synthetic and natural materials. Some are captive and under patent but most are not. The system of patents ensures continued innovation and R&D for new molecules. Without a patented period there would be very little return on investment and thus no incentive to innovate. This is true for most industries not just fragrance.
I hope this has answered your questions.
Director of Communications
International Fragrance Association (IFRA)
 What’s the difference between “hazard” and “risk”? According to the Aromatics Online website, “The hazard associated with a chemical is its intrinsic ability to cause an adverse effect. Risk is the chance that such effects will occur. For example, whilst a chemical may have hazardous properties, provided it is handled safely under contained conditions, then any risk to human health or the environment will be extremely low.”
Image: Moskene. When you Google it you get nothing but "contact allergy" articles. It is strictly verböten.