www.cropwatch.org

THE FIRST TRULY INDEPENDENT WATCHDOG FOR THOSE  WORKING WITH NATURAL AROMATIC MATERIALS

To: Mr P. Wagstaffe,

Head of Unit,

European Commission,

Health and Consumer Protection Directorate-General

Genevestraat,

B-1140 Brussels.

cc. Mr. A. Carvalho

Commission Européenne,

DG Enterprise and Industry, Unit F3
B-1049 Bruxelles.

cc. Mr. S. Breier.

Commission Européenne,

DG Enterprise and Industry, Unit F3
B-1049 Bruxelles.

07.09.2005

Dear  Mr. Wagstaffe,

Re : Cropwatch Objection to SCCP Opinion on Commiphora Erythrea Glabrescens Gum Extract and Oil (Opoponax) (sensitisation only)

Adopted SCCP 0871/05 (March 2005)

Cropwatch raises a serious objection to this SCCP Opinion, as it is based on an outmoded and outdated comprehension of botanical systematics and phytochemistry which cannot be supported. Specifically, Opoponax qualities do not derive from one single species, as is suggested in the quoted (& much-criticised) 2001 Update of the Inventory of Cosmetic Ingredients.

According to which authority is consulted - see detailed report below – Opoponax qualities commonly derive from 2-3 (up to 5) main Commiphora species, and may be adulterated with others. Until pure opoponax oils and extracts have been made from correctly botanically identified Commiphora spp. and an audit trail can be established between plants and researcher, to prevent the common practices of supplier blending/adulteration, and when these extracts and oils have been chemically analysed and dermatological testing has taken place with each opoponax quality: then, and only then, can we establish which (if any) of the commodities is associated with sensitisation problems.

The ‘evidence’ cited as ‘proof’ of the sensitisation potential of opoponax oils & extracts in the SCCP Opinion lacks scientific rigour, since botanical sources are not adequately investigated, no chemical analysis data is presented, no likely sensitising agents are identified and no criteria for purity and lack of adulteration are established. Further the dermatological testing protocols do not differentiate between potential false positives due to cross-reactions and do not distinguish opoponax as the causative agent.

A number of recommendations are made below in this third exploration of SCCP Opinions which thus far, are found seriously wanting by Cropwatch. The SCCP committee must be populated by experts who are capable of authoritative over-view. At present this is simply not the case, and these flawed Opinions do not deserve to be respected by the aroma trade.

Tony Burfield

On behalf of Cropwatch.