A new report recommends that the number of fragrance allergens subject to compulsory individual labelling when they are present in cosmetic products should be increased from the current 26 to around 130 — and that three should be banned altogether. Alex Gazzola reveals the 300-page report’s key findings, looks at how those sensitive to fragrances — up to 5% of the population — can protect themselves against ‘parfums’, and examines the likelihood of the recommendations becoming law.
In 1999, the Scientific Committee on Consumer Safety (SCCS) (at the time known as the Scientific Committee on Cosmetic Products and Non-Food Products) identified 26 fragrance allergens used in cosmetics which it felt ought to be made known to consumers when present above certain concentrations — rather than remain unnamed under the guise of the catch-all terms ‘parfum’ or ‘fragrance’.
The SCCS is an independent body set up by the European Commission to advise it on the impact on human health of personal / consumer products. It took some years for the SCCS’s recommendations to be acted on, but in 2005, through an amendment to the EU Cosmetics Directive, it became law that the 26 fragrances identified must be individually named on all cosmetics when present in concentrations of at least 10 parts per million (leave-on products) or 100 parts per million (wash-off products).
Some fragrance chemicals are added as ingredients in their own right, and some occur naturally in essential oils used in skincare products. The Directive called for the 26 to be named in either case, with the source essential oil also included as an ingredient in the latter (over half of the 26 are found naturally in essential oils).
Our listing of the 26, consisting of 24 fragrance compounds plus two natural extracts of oakmoss and treemoss, can be found here.
Now, in a new report published in August 2012, following a review of clinical and research studies from the last decade which the SCCS was asked to undertake, an additional 30 chemicals and 26 natural extracts have been identified as contact allergens in humans — while the original 26 have all been confirmed as allergens that should remain on the ‘warning list’.
New problem fragrances
This would bring the total confirmed human fragrance allergens to 82 — 54 of which are fragrance chemicals and 28 natural extracts or essential oils.
Of the 54 fragrance chemicals, the Committee found 12 to be especially problematic, some of which are both naturally occurring and can be manufactured synthetically too. For most of these, between 100 and 1,000 documented cases of allergy were found in the literature and trials reviewed by the Committee. The twelve, with examples of the botanicals in which they are found, are:
* Cinnamal (occurring in cinnamon)
* Cinnamyl alcohol (in cinnamon, balsam of Peru)
* Citral (in lemongrass, citrus, cardamom, petitgrain, ginger)
* Coumarin (in tonka, sweet clover, stone fruit, strawberries)
* Eugenol (in clove, nutmeg, cinnamon, rose, basil and bay)
* Farnesol (in neroli, rose, palmarosa and ylang ylang)
* Geraniol (in rose, citronella, palmarosa, and geranium)
* Hydroxyisohexyl 3-cyclohexene carboxaldehyde / HICC (synthetic)
* Hydroxycitronellal (in citrus fruits, petitgrain and ylang ylang)
* Isoeugenol (in clove, nutmeg, ylang ylang)
* Limonene (oxidised) (in citrus)
* Linalool (oxidised) (in citrus, rose, neroli, coriander, spearmint, cypress, chamomile, ylang ylang …)
The newly identified fragrance HICC was singled out, having been found responsible for an “exceptionally high” 1,500 cases of contact allergy. The SCCS stated: “Continued exposure to HICC by the consumer is not considered safe, even at concentrations as low as 200 parts per million. HICC should not be used in consumer products in order to prevent further cases of contact allergy … and to limit the consequences to those who already have become sensitized.”
Of the 28 natural extracts and essential oils, 8 were found to be especially reactive:
* Cadanga odorata (ylang ylang)
* Eugenia caryophyllus (clove leaf / flower)
* Evernia furfuracea extract (treemoss)
* Evernia prunastri extract (oakmoss)
* Jasminum grandiflorum / officinale (jasmine)
* Myroxylon pereirae (balsam of Peru)
* Santalum album (Indian sandalwood)
* Turpentine oil (usually from pine trees)
Controversially, the Committee was of the opinion that treemoss and oakmoss extracts should no longer be permitted in consumer products “because they are extremely potent allergens” and the presence in cosmetic products of their two respective allergenic constituents “are not safe”. Allergy to the two extracts is especially prevalent in eczema sufferers, it was noted.
The banning of these two extracts could have huge implications on the luxury perfume market, as Cosmetics Design Europe reported in November.
Treemoss and/or oakmoss are also used by many natural and ‘free from’ skincare companies, including Bodhi, Bulldog and Mama Mio.
Overall, although there is not enough data on individual fragrance ingredients to establish safe thresholds, the SCCS felt that a level of 0.01% — especially with regards to the most problematic allergens — would limit the problem significantly, and reduce the likelihood of reactions and new sensitisations. That said, even these levels may not help the most sensitive, and it recommended that the allergens should always be labelled, even below this level.
The Scale of the Problem
Although the numbers of allergic reactions recorded may not seem large given the timeframes of the research and number of international publications reviewed, the Committee pointed out that “Only a minority of the cases seen by clinicians is published and only a (small) proportion of those with allergic contact dermatitis seeks or has the possibility to seek medical attention.”
The report writers estimate that fragrance allergy in the general population stands at 1-3%, but these figures are based on limited testing with only eight common allergens. With dozens of possible fragrance allergens in products, the real figure could be 5% or higher. Tellingly, the report stated that 1 in 6 eczema patients are sensitised to fragrances.
In addition to the 82 established human contact allergens, the Committee found evidence in animal studies suggesting that additional fragrance substances can be expected to be contact allergens in humans — even though human evidence is lacking. Further, another group of fragrances may be a cause for concern, based on predictions drawn from their molecular structure and limited studies.
These additional substances totalled over 40. That would bring the overall number of problematic fragrances to almost 130.
It’s important to obtain a proper diagnosis, from a dermatologist via patch testing, of potential fragrance allergies (or allergies to other cosmetic ingredients). Skins Matter covered this in a previous article, Cosmetic Ingredients and Dermatitis.
Diagnosis is key as dermatologists will identify allergens precisely, and also advise against using others on your skin to which you may be susceptible to cross-reactions. It may also be important to avoid other fragrance allergens to prevent further sensitisations.
Those diagnosed or advised to avoid fragrance allergens face an equivalent problem to those with food allergies who need to avoid food allergens: labelling can be confusing.
“The expression ‘parfum’ — or ‘aroma’ for a flavouring, for instance in lipstick — must be used on ingredient labelling if perfume, aromatic compositions or their raw materials are included in the cosmetic product,” says Dr Emma Meredith of the Cosmetic, Toiletry and Perfumery Association (CTPA) (www.thefactsabout.co.uk).
“If essential oils are added for their fragrance, ‘parfum’ should be used again. But if a manufacturer is using an essential oil for its skin benefits, such as its conditioning properties, and it happens to incidentally impart some fragrance, then it is a judgement call. They may not choose to use the word ‘parfum’.”
She adds: “However, irrespective of whether ‘parfum’ is used, if any of the 26 fragrance allergens are included in the formula at concentrations greater than those specified by EU legislation, then they must be listed. Even if the fragrance allergens are being used for non-fragrance reasons, this doesn’t absolve manufacturers of the requirement to label them.”
Mostly, the fragrance allergens appear at the end of the ingredients listings, often asterisked and with an explanatory note reading ‘natural component of essential oils’, or similar. In the example on the right of Barefoot SOS Face & Body Rescue Cream’s very clear label, most of the fragrance allergens appear at the end (eg geraniol, citral, citronellol). These are all naturally occurring within essential oil ingredients, as the very clear ‘free from’ box confirms, as no synthetic fragrances are present.
Problems for those with sensitive skins
There are two problems to bear in mind.
First, some companies may argue they are adding essential oils for ‘non-perfuming’ purposes, so do not need to include the word ‘parfum’ in the ingredients, and in this case consumers have to read the full ingredient list to identify essential oils or individual fragrance allergens.
Second, and in regard to the extra 100 potential fragrance allergens identified by the SCCS, if these are included in any cosmetic for fragrance purposes, they need not yet be individually named on the label, and can be described merely as ‘parfum’. Until the new opinion is translated into legislation — and it may take several years, if it happens at all — consumers sensitive to these fragrance allergens have to make enquiries with manufacturers, though none are under any obligation to divulge their specific ‘parfum’ ingredients, which are often guarded secretively.
Other terms found on packaging may not be much help, either. “The term ‘hypoallergenic’ doesn’t have any legal definition,” says Dr Meredith. “When used on a product it gives the consumer a sense that manufacturers will have worked from a palette of ingredients not traditionally known for causing allergies. But individuals can be allergic to pretty much any ingredient, so there are no guarantees.” Hypoallergenic products, however, are unlikely to contain any of the 26 current fragrance allergens.
Terms such as ‘unscented’, ‘unperfumed’ and ‘fragrance free’ may mislead too, as products so described may contain a little fragrance to ‘mask’ any undesirable natural smell. You still need to look for ‘parfum’ or for essential oils in the ingredients if trying to avoid all fragrance.
Is Natural Better?
Many assume natural fragrance is better than artificial. Although most ‘free from’ cosmetics companies avoid synthetic fragrances, on other products it may not be easy to tell from a label whether natural, artificial or a mix of both have been used. Besides, says Dr Meredith: “The body responds to a fragrance allergen in the same way if it is artificial or natural — it can’t tell the difference.”
There are some who believe the natural version is likely to be less allergenic in practice, however. Pat Thomas, author of Skin Deep, argues that “in the matrix of an essential oil there exist substances … which seem to reduce the potential of an allergic reaction. These co-factors are not present when a substance, such as geraniol or limonene, is extracted and used singly or when it is synthesised in the lab.”
The natural cosmetic community, for its part, has already challenged the SCCS’s opinion. NaTrue — an international association promoting natural and organic cosmetics — issued a statement suggesting that the report risked creating a misleading image of natural fragrance substances and cosmetics among the consumer, and that thresholds should be based on more robust evidence. Its president, Klara Ahlers, in a separate statement suggested the report risked ‘blurring’ the value of natural and organic cosmetics.
It is clear from the evidence gathered that many valued natural oils and fragrances are highly allergenic substances, and pose a potential threat to some consumers. It will be interesting to see whether the natural cosmetic community, perhaps with the unlikely ally of the perfumery industry, moves to resist or lobby against any actioning of the SCCS opinion in years to come — concerned as they may be over what they might perceive as the negative connotations any associations to allergies may bring upon them — and how this may negatively impact on consumers sympathetic to natural cosmetics, but allergic to some of its key components.
Fragrance Free Products and Ranges
Ranges which are free from fragrances are hard to come by, but these are worth exploring:
The EC’s public consultation documents on fragrance allergens in cosmetic products can be found here.
The SCCS Opinion on Fragrance Allergens in Cosmetics Products (PDF) is here.
The Cosmetic, Toiletry and Perfumery Association has lots of information for the consumer and dermatologists on skincare, allergies, labelling and ingredients. Visit here.