Cropwatch Newsletter May 2007.
Citrus Oils in Cosmetics – The Crisis Deepens.
Copyright © Tony Burfield May 2007.
This a shortened newsletter, whilst Cropwatch continues to talk to citrus oil producers worldwide, and discusses possible courses of action with organisations which we have discovered are similarly opposed & deeply concerned about the proposed banning of citrus ingredients in cosmetics by the EC regulators on spurious safety grounds.
Recap & Update on the Citrus Oil Crisis.
Whilst new 2007 perfume industry launches continue to prominently feature citrus notes, especially in a new range of colognes, the EC Cosmetics sector regulators are still taking steps to effectively prohibit the use of traditionally prepared citrus oils in fragrances. In a letter to Cropwatch of 26.04.07, copy attached, Head of Unit Sabine Lecrenier denies all FC’s will be banned, but then goes on to specify six furanocoumarins (FC’s) which will (the list now apparently includes angelicin), because they are allegedly linked with photo-carcinogenic potential. These six (psoralen, angelicin, bergapten, xanthotoxin, oxypeucedanin and epoxy-bergamottin) are all found to a greater or lesser extent in the major citrus oils used in perfumery, and are to be regulated to 1ppm concentration in finished cosmetics. The case against the carcinogenicity of individual FC’s, as presented in previous SCCP Opinions such as SCCP 09542/05, remains scientifically non-robust, and there is a lack of supporting knowledge, understanding & experimental & technical data. For FC’s occurring in natural aromatic products, matrix effects & the anti-carcinogenic potential of other co-occurring substances remain unclear.
The restrictive legislation proposed by Lecrenier et al. as described above is actually unworkable since no comprehensive data on the distribution of FC's across the range of perfumery ingredients, citrus or otherwise, is available in the public domain, merely scrappy bits of information. In any case, any minutest health risk which might be present to fragrance-wearing consumers is best approached by labeling, advising the wearer to avoid actinic light for 12-24 hours after application.
Most disappointingly, whilst health risks from FC’s in cosmetics remain so minute as to be virtually incalculable (provided reasonable precautions are taken), Lecrenier et al. seem to have completely ignored the catastrophic effect to the perfumery art of effectively removing citrus ingredients from the perfumer’s palette, as outlined in Cropwatch’s April 2007 Newsletter. Many have likened this threat to culture as a parallel situation to the burning of books by Nazi-sympathising students on by May 10th 1933, but we have yet to hear anything on the subject from Brussels, apart from repeated invitations to submit evidence on ‘the safe use’ of FC’s in cosmetics. The latter isn’t likely to happen since the research required is complex, extensive & time-consuming and requires sophisticated & expensive equipment & substantial funding, but because industry has failed to come up with the appropriate data, it is being ‘punished’ with a blanket restriction (read ban) on FC’s in cosmetics. This outcome is a childish & unprofessional response - we need regulators who can work with industry at a technical level to find a way forward in a difficult situation - or resign.
Cropwatch Takes Action.
According to our information, its seems to be the case that no aroma-connected organisation we have contacted is able to maintain a satisfactory technical dialogue with the EC Cosmetics sector regulators, and indeed, leading figures of some well-known organisations have voiced this fact publicly at professional gatherings. The problem is, therefore, not so much what we do about FC’s in citrus oils. The problem is what we do about a non-communicative Brussels regulatory machine, which is imposing unnecessary, costly & unworkable cosmetics regulation.
Cropwatch is therefore carrying out the following courses of action:
1. A copy of Cropwatch’s (longish!) reply to the latest mail from the Cosmetics Head of Unit (see attached – & please read) is already forwarded to the EU Ombudsman. The content not only deals with the FC issue, but lists out a number of Cropwatch’s points & arguments that have been consistently ignored although we have made some of them several times.
2. We have additionally asked the Cosmetics Head of Unit for a status report on a promised review of the SCCP (see mail attached), which Cropwatch has extensively argued is ‘not fit for purpose’.
3. Cropwatch is currently negotiating with other aroma-connected organisations to unite on issues connected with the restriction of natural ingredients, and lack of technical dialogue with regulators. Cropwatch is actively seeking to establish an office, or at least representation, in Brussels.
4. Following on from (3) above, the water is being tested for a Europe-wide vote of no confidence in the EU Cosmetics regulators, as they have failed to take the appropriate measures & strike the correct balance in ensuring the safety of cosmetics to the general public..
5. Proposals to launch The Campaign for Real Perfume, as mentioned in the April Cropwatch Newsletter, are being circulated to natural perfumery companies, green-image orientated cosmetics companies etc., and we are already in negotiation with interested parties (if interested please contact Cropwatch at firstname.lastname@example.org).
6. Cropwatch staff are now accepting lecturing engagements on ‘regulatory madness’ issues surrounding natural aromatic ingredients. So far the following have been accepted:
12th Sept 2007: 38th ISEO Conference, Graz, Austria.
6/8th Nov 2007: WFFC Meeting, Saddle Brook NJ., USA (provisional)
All other issues are held over until the next Newsletter in view of the seriousness of the FC issue.
On behalf of Cropwatch.
Link to pdf Cropwatch reply to the Head of Unit, European Commission