THE FIRST TRULY INDEPENDENT WATCHDOG FOR THOSE WORKING WITH NATURAL AROMATIC MATERIALS
E: info@cropwatch.org T: ++44 (0)7771 872521
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.
28.08.2005
Dear Mr. Wagstaffe,
Re : Cropwatch Objection to SCCP Opinion on Tagete Extracts & Oils
(SCCP/0869/05; June 2005).
The Precautionary Principle has been extended too far in this SCCP Opinion against Tagete Extracts & Oils, which concludes that these commodities are not safe in cosmetics at any concentration. In fact the evidence points the other way, to the fact that the previous IFRA recommendation of 0.01% maximum concentration in fragranced cosmetic products not washed off the skin and exposed to sunshine (based on a NEOL of 0.05%), was a perfectly good strategy, as evidenced by the lack of dermatological evidence of photo-toxicity in the exposed cosmetic-buying general population.
Further, the continuing attack on natural ingredients by SCCP Opinions is endangering jobs in the natural aromatic material supply industry, and wrecking the art of perfumery, which needs these vital ingredients to function.
The technical shortcomings in the SCCP Opinion mentioned below also need addressing, and Cropwatch is asking that the committee take a re-look at the issues involved.
Most disappointing is that the SCCP did not make recommendations for a way forward for Tagete commodity producers. For example, the committee might have encouraged producers to develop low thiophene Tagete oils during an ‘amnesty period’, to see if the alleged photo-toxicity problems could be reduced. As it is, the committee gives Tagete growers little hope for the future.
Please find below the text of the initial Cropwatch response to this matter.
Best regards,
Tony Burfield
On behalf of Cropwatch.