The European Green Deal could potentially remove more than 400 materials from the perfumer's palette for 'safety' reasons. Is this a necessary precaution or regulatory overkill?
The European Green Deal, a comprehensive policy initiative by the European Union, aims to create a sustainable and climate-neutral economy. While the deal presents opportunities for the fragrance industry, such as aligning with consumer demands for eco-friendly products and fostering innovation in sustainable practices, it also poses significant challenges. These challenges include potential ingredient restrictions, increased production costs due to sustainability measures, and the need to navigate complex supply chains.
While well-intended and important in principle, the proposals for how chemical safety in consumer products would be approached could lead to the abandonment of the concepts of safe use, minimal exposure and risk assessment as we know it - leading to a needless loss of materials, and ignoring the ways in which our profession already determines fragrance safety and limits.
The European Green Deal, although well-intentioned, presents significant challenges for the fragrance industry. The emphasis on sustainability and environmental regulations may inadvertently stifle creativity and innovation within fragrance formulation. Stricter regulations on ingredients could limit the diversity and complexity of scents that perfumers can create, potentially hampering their artistic expression. Moreover, the resources required to comply with the Green Deal's sustainability requirements, such as sourcing eco-friendly ingredients and implementing greener production methods, could lead to substantial cost increases for fragrance manufacturers. These higher costs may ultimately be passed on to consumers, making fragrance products less accessible to a wider range of people. While environmental concerns are important, it's essential to find a balanced approach that allows the fragrance industry to continue flourishing creatively and economically without being overly burdened by stringent regulations.
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Here are a few of of our favorite excerpts:
"We live in a chemical world and life itself is chemistry in action."
"By volume, 50% of the palette of perfumers today is nature identical. "
"It surprises many people to learn that rose oil is not a single substance, but instead a combination of around 350 molecules."
"We, as a society, have become used to relating to the word “chemical” with apprehension - as though the concept of “natural” would be its opposite. "
"Any toxicologist will tell you that to determine whether something is harmful is an exposure-based conclusion, not a hazard-based conclusion. Even the most hazardous substances are not harmful if the dose is low enough. Conversely, even the most innocuous-seeming natural or synthetic chemical can harm a person if the conditions allow it. It won’t take long for all of us to think of scenarios where water has been deadly, for example."
"A good example of why it is important to group substances for classification purposes by using transparent and appropriate criteria is p-cymene. It is a constituent present at 0.3% or above in over 350 natural complex substances (including fruits, vegetables, and spices). Banning it and any “chemical mixtures” it is contained in, would subsequently cause the ban of these natural materials. Lemon and thyme oils for example would now be classified as too dangerous to include at any level."
"Human beings are in daily contact with many of the chemicals that form part of the perfumer's palette - through food, flavours, and nature, not fragrance."
"Encounters with chemicals used in fragrance are at a much lower level than something as ordinary as peeling an orange. Limonene is a major chemical constituent of citrus fruits. Citrus oils are used as fragrance ingredients. Peeling one orange a day is equivalent to 140 sprays of a modern women’s fragrance."