Petition to the EU regarding perfume regulation

Save Perfume’s Soul.” That is the plea behind a well-crafted, factually detailed, and heavily researched petition to the EU on the issue of perfume regulation. It has been put together by the people at Parfumo.net, and I was rather hoping that a few of you may take a moment to sign it.

The petition begins with the following arguments:

The EU Commission should protect health, AND the cultural asset perfumery:

We, the undersigned consumers, hereby voice our objection to the amendment currently proposed, which would render colourless the range of European perfumery.

Accordingly, we strongly oppose any further ingredients restrictions.

Please be advised that we, the undersigned, support the contribution by the “Consumers’ initiative for the protection of perfumes as a cultural asset“.1 This contribution has been presented as part of the public consultation on fragrance allergens pursuant to Regulation EC No 1223/2009 on cosmetic products.2, 3

With our signatures, we request that the decision-makers obtain a comprehensive perspective beyond the scope of the narrow confines of the Scientific Committee on Consumer Safety (SCCS) opinion.4 This broad and complete perspective must include the following considerations and interests:

  • Consumer protection,
  • Cultural identity,
  • Economic considerations,
  • Consumer interests above and beyond mere health and safety.

I have to applaud the individuals behind this petition. They have clearly spent a massive amount of time doing their research, annotating the petition with links, and being very strategic about how they have presented things. I think my favorite part was when they used German governmental findings (from the German Federal Environment Agency [Bundesumweltamt]) against the EU bureaucrats in Brussels:

Research has demonstrated that it is impossible for an allergic event to be triggered through the use of perfume by a third party in proximity to a susceptible individual. The pertinent study, conducted by the German Federal Environment Agency [Bundesumweltamt], concluded that the mere act of inhaling potential contact allergens did not, in fact, result in the development of allergic symptoms by the test subjects.

From a legal perspective, I think it was also very astute of them to phrase one of the upcoming labeling proposals as the potential first step on the road to a de facto ban:

Three substances are currently scheduled to be prohibited under the proposed amendment (Lyral® and [Chloro-] Atranol, thereby oakmoss and treemoss). Further substances (including elementary substances such as Geraniol, Coumarin or Linalool) are to be labelled above the threshold of 0.001% in leave-on products. This miniscule allowance is tantamount to an outright ban in most cases, insofar as the concentration is so minute as to render the ingredient undetectable by the human nose in the finished product. A labelling requirement which demands that a trace amount of an ingredient be listed, is the first step toward a de facto ban, to the extent that the tiny concentration permitted is virtually undetectable. This would also affect about 90% of all essential oils because these substances are primary components. [Emphasis added by me.]

Legislators and judges are always very influenced by whether the indirect effect of something amounts to total exclusion, so I think they have been very strategic, indeed.

Signing the petition itself takes less than a minute, followed by another minute to check your Spam folder for email confirmation that you subsequently have to click on. That’s all it takes.

However, I wanted you to know that the Petition does require one to list one’s country of residency. I raise this only because I wonder if the EU would really care what someone outside its borders might think? Would they not be more convinced if the signatories all appeared to be EU citizens and, thus, from their voter base? Just to be clear, I’m not telling you to lie. Please follow the letter of the law. I’m merely raising the theoretical possibility that government legislators may care more if the signatories appeared to be their own constituents. Purely hypothetically, of course. I would never suggest that you … er… just casually … er… put down a different country than your own. Oh no, not at all.

At the end of the day, the bureaucrats in Brussels will do what they want to do, but a petition like this can’t hurt. So, please, if you can, sign it, spread the word, and pass it on.

45 thoughts on “Petition to the EU regarding perfume regulation

  1. Dear Kafkaesque,

    Thank you! I’ve certainly signed it and am spreading the petition all over the web 😉 What a well written petition, a joy to read and sign!! Now lets hope we can make enough noise to change things for the better.

    Fragrant greetings!
    Nina

    • Thank you for spreading the word, Nina. Every little bit counts! Let’s all keep our fingers crossed that someone in Brussels will listen.

  2. Thank you for this excellent blog post on the subject!
    Difficult to tell whether or not the EU would care about signatures by non-EU citizens. However, to add my two pence here, it might indicate how much demand there is outside the EU for perfumes produced in the EU, and the economical impact of this legislative is surely an issue to be considered by the Commission.
    Also, the regulatory authority tasked with evaluating public sentiment regarding the law is actively soliciting contributions to the debate by “any interested party” (see: Public consultation on fragrance allergens).

    With warm, fragrantly combatant regards,
    Mia

    • I grinned enormously at the “fragrantly combatant” regards. It does feel a little like we’re all preparing for war, doesn’t it? Hèlas.

      Thank you for the point that you raised re. demand outside of the EU for perfumes produced within its territory. I had considered that aspect, but I think I’m too much of a cynic these days to think that governments care about anyone but their own voters. Perhaps I have been living in America too long, since the government legislators here certainly wouldn’t care what someone outside their borders thought about US policies. Hopefully, the EU is less… well, less something or another, and they will care about international/foreign opinion.

      However, since I *am* a cynic, I … er… may or may not… have signed a few days ago giving my old EU nation of residence. If I remember correctly, the end result showed that country’s flag, not a U.S. one. All hypothetical, of course…. *ahem* 😉 😀

      Anyway, thank you and all the Parfumo members who worked on this petition. Thank you from the bottom of my heart, and Brava on a truly excellent job.

      • Kafka, if I may share my view, unless the commission members are very naïve, they’ll realize that creating an overly-regulated, hostile business environment in the EU courts the risk of flight to a more friendly setting. Andy Tauer has already insinuated that if this measure is enacted, he won’t be shipping his perfumes to the EU any longer. As successful as Tauer has been, I can see other perfumers following his lead. It may even reach the point where perfume houses find it practical to relocate to non-EU countries in order to avoid draconian regulations.

        • First, welcome to the blog, Cryptic. Second, I’m glad you shared your more optimistic perspective. It cheers me up a little after the gloom I felt at the fact that IFRA/EU regs. are spreading like a plague to the Middle East, and have already impacted Amouage’s attars. Let’s hope that you are right, and that the EU members may think that the potential economic damage is a sufficiently serious risk.

  3. Signed. Had wavered when I’d read the petition two days ago, wondering if a US citizen’s signature would mattered. Mia’s point above is a good one.

  4. Thank you, I signed the petition. Perhaps someone could post the link over on Fragrantica as I am sure lots of readers there would sign the petition also. Have a nice weekend with lots of perfume to enjoy. L.

    • I read that a Basenotes thread which posted the link was taken down for “illegal electioneering” or something, so perhaps Fragrantica has the same sort of rules. Either way, the more people can spread the word in general, the better. Thank you for signing, Larraine! 🙂

      • I suspected that would be the case. It’s rather unfortunate. However, we can still spread the word on places like Twitter. I’ve already sent a Tweet under the blog’s name with a direct link to the petition on the Profumo* website. Hopefully, others can do the same and we can reach more people that way.

        Edited to add: Parfumo, dammit. Sorry, I must have been thinking of the Italian perfume house.

        • Dearest Kafka, you write so eloquent and have gift with words but you mispelled the website. It is Parfumo and not Profumo. He he he

          • HAHA!!! Thank you. I amended the comment. At least I got it right in the actual post, though I admit that I did rush to double check after I read your words. 😀 The problem is that, ever since I did a whole series on the Profumo perfume house (La Via del Profumo), the PARFUMO website gets jumbled up in my mind with the perfume house. Actually, basically anything that sounds the same seems to get automatically translated in my mind to “Profumo.” LOL. It didn’t help that I was talking to a friend just 2 days ago about the house and Abdes Salaam attar.

            Bottom line, thank you for pointing out the mistake. But I’m sure I will continue to make it many more times in the future as well, so don’t hesitate to remind me, “German Website, not Italian perfume house!” lol 😀 🙂

  5. I posted a link both to this post and to the petition on Facebook. I’m not hopeful that anyone on the receiving end will care about a petition. I would love to see (and smell) people marching in the streets wearing vintage frags with oakmoss in them.

    I hope you don’t mind me making light of this. I’m not, as I think the regs are part of the corporate fascism that is taking over the world. I think demonstrations would be great, though I don’t see them happening, but then again, I’m an American, and my fellow Americans have ceased to demonstrate about most things. Perhaps in France?

    • julesinrose, Perfumed Dandy had the rather brilliant idea of seeking UNESCO protection for perfumery on the ground that it is an imperiled European cultural asset. (See: Comments section of Kafka’s 2/14/14 blog article, http://www.kafkaesqueblog.com/2014/02/14/the-eu-proposes-to-act-on-perfume/). To me, this is a clever approach that ought to be pursued. As an American, I’ve no idea as to how to go about it, however. If anyone has suggestions or advice, please feel free to get in touch on Facebook. My handle is “Cryptic Perfume” there.

      • If I may, I actually raised the issue of cultural protection akin to a historic landmark on a previous post on the EU issue back in January of 2013. http://www.kafkaesqueblog.com/2013/01/01/perfume-news-2013-the-eu-reformulations-perfume-makers-secrets/ I did not feel it was polite to mention that to the Perfume Dandy at the time, especially as then — like now — I don’t understand how it can be handled on a practical basis in terms of legislative crafting. As a lawyer, I see the pitfalls in terms of scope, definitional standards, sliding scales, biases in judging, and more. However, as should be clear by now, I’m rather a cynic, so that definitely influences my views on the practical aspects of legislation such as that. Perhaps others won’t be blinded by cynicism and can see a clearer path when it comes to the technicalities.

        • Awesome! We’re members of the same tribe. 😉 Kudos for coming up with such a fiendishly good idea, and Perfume Dandy’s subsequent comments are proof that great minds think alike. Agreed that the UNESCO approach would be a logistical nightmare, but I’m still not deterred. I have a friend who practices law in the Hague and with your permission, I’d like to run your fine idea by him. He may be in a position to tell us how feasible it would be.

          • Please do, I’d love to hear his thoughts because I really struggle at the practical realities. I mean, how would it actually work in terms of the perfumes chosen for protection? Once you go past Chanel No. 5, Shalimar, L’Heure Bleue, Fracas, the already destroyed Opium (which currently deserves no protection whatsoever), and the like, then what? Thierry Mugler’s Alien? Viktor & Rolf’s Flowerbomb? Acqua di Gio (God forbid!)?

            What do we use to choose? Luca Turin’s 5 Star reviews?? Well, I, for one, don’t agree with a lot of them. But let’s say, purely hypothetically, that we did. Let’s say we agree fully and give his 5-star rated Davidoff Cool Water protected status as an iconic heritage fragrance (shudder), then what? All the perfumers whose creations are on the 4-Star list will argue for inclusion and protection as well. Where does it end from there?

            Who will be the arbiters of taste and value? That is the biggest question of all. Panels comprised of experts, no doubt, but perfume is one of the most subjective things of all, and it would be an utter nightmare of epic proportions when it comes to selection. Judging by the recent FiFi awards, I simply do not trust in the tastes of many of those who have been anointed as judges of perfume worth.

            And you really cannot select just a handful based on historical dates — like, ie, only things like the early Guerlains and Chanels — because that raises questions of inequality, discrimination, and unfairness.

            So, yes, I remain fully unconvinced by the Historical Protection proposal in terms of its practical realities. It’s all well and good in theory, but ONLY as an abstract theory, imo.

    • No, I don’t think you’re making light of it at all. Sometimes, one has to laugh grimly at things. It’s either that, or bang one’s head against a wall in despair. *wry smile*

  6. Kafka, many thanks for spreading the word about the petition as well as your earlier article of 2/14, which generated a flood of interest on the subject. We need voices like yours to promote this cause, and your assistance is greatly appreciated. 🙂

    • You’re very welcome. I’ve actually been writing about the EU situation since January 2013, a few weeks after starting the blog in the first place. I also talked about it in a post in Oct. 2013 talking about the practical impact of the IFRA/EU regulations on an actual perfumer (Viktoria Minya) and providing the percentages of some of the ingredient ceilings already in existence.

      Obviously, other bloggers have spoken up as well, well before me in fact. It is only lately that people have decided to issue a call to arms, for the understandable reason that the deadline is now close at hand. But we’re all in this together, so the more voices the better, no matter what the timing. 🙂

  7. Signed (seem to be signing lots of petitions these days). Big thanks Kafka. Cynics or no – if we can’t exercise a modicum of people power then we may as well simply just go back to sleep. I jealously guard and protect my right to effective (and hefty) scent-therapy! Gxx

    • Thank you, my dear. I’m very grateful that you signed it. May you waft on in powerful sillage for years to come! 😉 🙂

  8. I’m with you, Gaia, Kafka, and the rest of us who will also jealously guard our rights to spread sillage unencumbered!!! In addition, we should also have the right to protect our beloved fragrances from turning into cheap, crap chemical-aromas!!!! Those formulations/reformulations do NOT produce perfume!!! All of this B.S. Is becoming just too damned much!!!
    Petition signed, word being spread…

  9. Fuck the IFRA and fuck the EU ! I prefer to dye with perfumes than with GMO, aspartam, air pollution, pesticides or other freakies !

  10. Thank you for spreading the petition, Kafka. Even though I currently don’t live in the EU, I am an EU citizen and so I used this as my location.

    The petition is not limited to EU residents only, however, I agree with your assessment that the legislators would probably give more weight to signatures from EU residents. This is quite natural considering their mandate to serve the public of that region. I am certain the US and any other country would have the same views and considerations.

    These regulations amount to industry decimation and it really is the European economy that would suffer the most. Some perfume houses have already limited or totally pulled products from the EU market because of the new regulations.

    I find it hilarious that the EU is spending taxpayers money on this when they have much bigger issues to resolve. I haven’t seen yet a comprehensive ban on smoking even though the side effects to the public are very well documented and scientifically supported. Could it be that Philip Morris and Co. have mastered the art of lobbying? It seems the fragrance industry needs to have a close chat with the tobacco industry and get some lobbyist numbers.

    • Thank you for signing, Scent Bound. The thing about the perfume industry and lobbying is that it seems that the perfume industry — by and large — is in bed with the aromachemical giants. IFRA is totally supported and funded by Givaudan, Firmenich, IFF, Symrise, and the rest, and their vested interested tend towards…. well, other paths than protecting natural ingredients. If anything, my personal feeling is that IFRA has become a lobbyist for Givaudan.

      I’ve written elsewhere about the split in the perfume industry with companies like L’Oreal staying quiet for the same reasons that drive Givaudan, while Chanel and LVMH are working frantically on the other side to save the stuff that goes into their Guerlain, Chanel, other creations. The wealth on the anti-regulation side of the aisle would seem to be AS big, if not MUCH MUCH more than the money on the other side. Particularly if you include natural ingredient producers like the wealthy Robertet and cities like Grasse which is also trying to mobilize support. So, the money trail isn’t clear to me at all. The only thing which IS clear to me is that IFRA is not on the side of the angels, no matter how much they may try to pretend or claim otherwise.

  11. I signed this a couple of days ago when Portia posted it on FB, but I got my hubby to sign it via your site as well. Just in my personal meanderings I’ve run right up against public perfume bans in the past 2 months: at a new PT office I was met by a large and prominent sign at the reception window forbidding patients to wear any perfume due to “severe allergic reactions by staff and patients” and more troubling, the entire Portland State University campus (where I have gone back to school as a “mature!” student) is a perfume wasteland following their campus-wide ban. Appalling.

    What is also extremely scary given the number of people (myself included) who reference the WebMD website, is their doom laden offering on the subject:
    http://www.webmd.com/allergies/features/fragrance-allergies-a-sensory-assault

    “Those symptoms, [she] tells WebMD, can range from classic “allergic” reactions, such as sneezing, runny nose, and watery eyes; to headaches, inability to concentrate, and dizziness; to respiratory issues, such as breathing difficulties and wheezing; to skin reactions, such as itching, hives, and other rashes. According to the American Academy of Dermatology (AAD), fragrances are considered the leading cause of cosmetic contact dermatitis. As a health problem, this sensitivity alone affects more than 2 million people, and studies suggest that sensitivity is on the rise.”

    And my favorite pronouncement:
    “Experts theorize that one reason fragrance allergies appear to be increasing is that fragrances themselves have become such a prominent part of our world. According to the AAD, some 5,000 different fragrances — and countless other fragrance combinations — are used in products today. And they can be a powerful, toxic brew.”

    One imagines oneself cackling madly when opening one’s bottle of No. 5, intent on reducing unsuspecting members of the public to hacking, itching, boil covered victims. After all, women were burned at the stake hundreds of years ago for less. I’m quite looking forward to becoming the Wicked Witch of the Pacific Northwest tomorrow when I head to class, doused in my TBOTD (Toxic Brew of the Day)…

  12. This issue is really important, and very relevant to those of us who are NOT residents of the EU. Our company supplies fragrances to many cosmetic manufacturers here in Australia (Yes! The world of perfumery extends beyond the realm of Fine Fragrance into Industrial perfumery!). Many of our clients export their cosmetics and hair care products to countries in the EU. As a consequence we have to fill out mounds of paperwork to assure the precious EU that the perfumes that go into beauty & personal care products exported from Australia conform the the EU demands for labelling. We also work strictly within IFRA’s guidelines/standards. If this legislation goes through imagine the labelling nightmare for the cosmetic makers?!
    I posted this page with its link to the Petition on our Damask Perfumery Facebook page a couple of hours ago and already people are commenting and sharing… so the word is spreading!
    T.H.

    • Thank you for helping to spread the word! That’s wonderful, and I agree that the consequences of the EU decision spread far outside the EU itself.

  13. Perfume is so beautiful and brings brief moments of pleasant distraction. I hope that one day this is reversed. That would be wonderful.

  14. Is it too late to sign this petition, what can I do to make a difference, surely we as consumers have a voice?

    • I’m afraid it’s too late, as the government group in question focused on or addressed the issue a long time ago.

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