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Commentary on the IFRA 49th Amendment

Last week, the International Fragrance Association (IFRA) — an industry organization funded by the world's largest flavor and fragrance companies — released the 49th Amendment to their Standards, which are self-regulatory restrictions for safety in consumer products manufactured or sold by their members.

Membership in IFRA is contingent on strict adherence to their Standards. As a result, when IFRA bans or restricts the usage of a perfume material, most if not all of the world complies. In the United States, indie perfumers who are not IFRA members are NOT bound, legally or otherwise, to comply with IFRA standards (other countries, however, tie their own state regulations to IFRA). As such, I am not bound to comply with any IFRA restriction.

Nevertheless, a self-regulating organization made up of trillion-dollar corporations that together control over 80% of the perfume market share would certainly err on the side of caution in any decisions they impose upon themselves, with respect to consumer safety — hopefully. And for that reason, it's a smart idea for indie perfumers to earnestly consider the changes IFRA puts out, as do I.

So, many perfume fans have been anxiously awaiting the definitive news on what changes were coming down the mountain, and now they are here. After spending a few days piling through the changes, I'd like to provide a summary of some of the highlights, and possible changes to my studio lineup as a result:

1. Three of the most-impactful natural floral ingredients, Jasmine grandiflorum, Jasmine sambac, and Ylang Ylang, have all seen minor reductions to their safe use levels. The reasoning given for this reduction is "dermal sensitization," which means that it is the belief of IFRA that exposure to these ingredients at levels higher than the new safe use level might, at some point or over time, provoke an irreparable sensitization response in certain individuals.

However, despite taking years to agree upon and publish the 49th Amendment, as of this writing, IFRA has not updated or made publicly available the research on why the reduction was instituted.

In every case of determining whether a change to publicized safe use policies is rational or ridiculous, it's hard to parse without publicized scientific research. This is the type of behavior which fuels throughout the fragrance community the conspiracy theories that IFRA operates more with money or monopoly in mind than safety.

2. Despite acrimony by multiple sources, including some notable perfumers and "influencers," oakmoss and treemoss have seen no change to their safe use levels, remaining at .1%.

However, IFRA reaffirms that certain toxic chemicals naturally present in these moss products MUST be removed if used for perfumery. For this reason, I urge collectors to avoid applying to their skin any work by perfumers which employs studio-made tinctures of moss or similar lichen that have not been subject to further rectification. The harmful, sensitizing chemicals will be present and, based on decades of proven scientific research, are known to damage your skin.

Moreover, though a small, but vociferous number of indie perfumers bemoan the restriction of .1%, using it as a fulcrum to complain about IFRA's existence, you should know that oakmoss and treemoss are high-impact materials. While this number seems small on paper, its functional contribution to a perfume is quite great. To shove exponentially more into a perfume is often to turn an oboe into a bludgeon.

3. Several restricted materials have now had their safe use levels increased. The incredibly important white-floral aldehyde, Hydroxycitronellal, crucial to an endless list of blue-chip, classic perfumes, can now be used at a 2.1% level, compared to 1%. Similarly, rose ketones, super high-impact chemicals which create outstanding floral and fruity effects, can now be used at a .043% level, increased from .02% — more than double. This is great news and I welcome the change, especially since it is in line with earlier research that has argued these restrictions were too tight.

4. Certain celebrated chemicals have seen tightening. The methyl ionones, as well as Iso E Super and its isomeric cousins, are now all further restricted, to 30% and 20%, respectively, from 31.67% and 21.4% — gargantuan amounts of a single chemical, still, which should immediately trigger an eye-roll toward anyone who complains about these minuscule modifications.

5. Upsettingly, other stalwart chemicals have seen new restrictions which, on their face, do feel a little nonsensical. Sandalore, a popular sandalwood chemical in wide use, now has an introductory restriction of 1.2%, but lacks any research to back it up. Similarly, cedrene, a key natural chemical present in almost every wood oil, vetiver, sandalwood, and others, is now restricted to 1.5%. Both restrictions state it's for reasons of sensitization.

6. Overall, at least one chemical or natural material in every perfume I have released to-date is affected somehow by IFRA 49.

You can then imagine how many OTHER perfumes worldwide will be affected, too, and likely subject to a mandatory reformulation by IFRA member-producers. By and large, there is a temporary period before full compliance by IFRA members is mandated. But for anyone hellbent on collecting a perfume in a formulation that you enjoy now, "now" is always the time to buy it before it's gone from the shelves and reformulated.

With respect to my own releases, before anything is re-produced, current safety guidance is always researched and evaluated for changes. In concert with my public policy on Materials Availability in Indie Perfumery, when a formula changes in a manner that greatly affects the subjective experience of that perfume, collectors will be notified accordingly and the perfume name will be retired.

It is still too early to say whether or not any new batches of my thus-far launched fragrances will be reformulated, as I await IFRA's hopeful publishing of their research, and must subsequently inspect and compare certificates of analysis of any new materials procured against the updated Standards. Both Quasi una absurdia and Bluer Skies (Whenever You're Around) contain the aforementioned floral ingredients, jasmine and ylang, and, conservatively speaking, stand to be the most susceptible to retirement or reformulation.

Once IFRA updates its databases to reflect the new research for their decision, indies, like myself, can make a better-informed decision about concordance with their findings. It is my hope that IFRA, indeed, decides to publicize the entirety of its research to better assure consumers of its actual commitment to safety and transparency in public health matters.

(Published January 15, 2020)