Fragrance labeling that refers sensitized individuals to informative web pages would be a greater public service than an exhaustive list of potential allergens proposed by the European Commission, the International Fragrance Association asserts in a May 9 position paper.

The paper was issued in response to the EC’s February proposal to amend the European Cosmetics Regulation to ban three fragrance allergens while potentially adding to the list of 26 established contact allergens that must be identified on product labeling when present above certain thresholds for leave-on and rinse-off products.

The expanded list could include upwards of 80 established or likely contact allergens as recommended by the Scientific Committee for Consumer Safety Also see "EC Proposes Tighter Regulation Of Fragrance Allergens, Ban On Three" - HBW Insight, 24 February, 2014..

Extending EC labeling requirements for fragrance allergens “to all the additional ones established on humans” is a concern, as they “may not improve the level of information for consumers already sensitized, nor enable future enhancements.” – IFRA

Aside from the 26 established contact allergens that must be labeled by name, fragrances, aromatic compositions and their raw materials are generally referred to as simply “parfum” or “aroma” in product ingredient lists on packaging, according to current provisions in the Cosmetics Regulation.

“IFRA is of the opinion that … indicating the fragrance allergens in the list of ingredients labeled on the product is not the most effective and appropriate means enabling the allergic consumers to make an informed choice as to which fragranced product to use with confidence,” the trade group says.

Moreover, such an approach tends to confuse non-sensitized consumers and is burdensome for industry, which faces compliance challenges due to limited space on product labels, as well as the potential need for costly relabeling if and when their product formulations or production processes change, new scientific information surfaces or additional allergens are identified.

IFRA says industry is prepared to comply with the EC’s proposed ban on atranol and chloratranol, which are components of oak moss extract and tree moss extract, respectively, and hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC), a synthetic scent similar to lily of the valley.

With implementation of Good Manufacturing Practices, the problematic moss extract components will not be present above trace levels, and all products on the market will be compliant by the deadlines set out in the EC’s proposal, IFRA says.

However, extending labeling requirements for fragrance allergens “to all the additional ones established on humans” is a concern, as they “may not improve the level of information for consumers already sensitized, nor enable future enhancements,” according to the group’s paper.

IFRA holds that substance labeling on product packaging is rarely helpful or effective at preventing allergic responses in sensitized individuals. Instead, the organization advocates the use of pictograms, on-pack warnings and links to web-based sources, targeting information directly to allergy sufferers in a way that is “interesting, easy to understand, credible and action-oriented.”

IFRA agrees with current regulations mandating that the 26 most frequently reported allergens should be labeled on products with their INCI name when their use is above certain thresholds. But for other allergens, “we would recommend, through an ‘easy-to-read mention’ (pictogram or short reference), that the sensitized consumer be prompted to consult the brand’s web site (or other freely available sources of meaningful information),” the group says.

That method would represent more effective intervention on behalf of sensitized consumers and allow for the provision of more relevant information, the paper suggests.

“In this way, the information will be proportionate, simple, workable and easy to update/adapt,” IFRA says. “A web site and its database will also be more useful, accessible and easy to use by dermatologists.”

In addition, such a web site could offer all consumers information “on the sustainable and safe use of cosmetic products,” the group notes.

The listing of fragrance ingredients that are potential allergens on products also brings up the issue of maintaining trade secrets.

Firms have been under pressure to defend their need for trade secrets amid calls for greater transparency and ingredient disclosure ([A#02131209007]).

In Europe, IFRA has supported an EC proposal to harmonize and enhance protection of trade secrets across member states ([A#02131223001]).

IFRA Floats Alternative To EC’s Fragrance-Allergen Labeling Proposal

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