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“Our whole philosophy is one of transparency.” —Valerie Jarrett
In the four heavy tomes of the International Cosmetic Ingredient Dictionary and Handbook, entries are given International Nomenclature Cosmetic Ingredient (INCI) names for labeling purposes on finished product packaging. Consumers may not know exactly how to interpret much of what’s on the label because the INCI names can be intimidating, but at least the information is there—and they can easily learn more if they want to. In all the thousands of entries, only two totally ambiguous names survive, shrouded in mystery, one of which we’ll discuss herein: Fragrance (parfum)—the other being flavor.
This ambiguity is perfectly legal. According to 21 CFR 701.3(a), “The label on each package of a cosmetic shall bear a declaration of the name of each ingredient in descending order of predominance, except that fragrance or flavor may be listed as fragrance or flavor.”
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Conforming to the letter of the law is good, but is it enough for satisfying the needs of a new generation of consumers?
The beauty industry decided that self-regulation was the best path forward in the mid 1960s, and by the early 1970s a workable framework was in place for two segments of the overall industry. In cosmetics, the result was the International Cosmetic Ingredient Dictionary and Handbook, product labeling and the Cosmetic Ingredient Review (CIR) To assure fragrance safety, the Research Institute for Fragrance Materials (RIFM) launched a testing program and published the results in peer-reviewed journals. The International Fragrance Association (IFRA)issues guidelines for fragrance suppliers based on the RIFM testing and analysis of data. These guidelines may ban a material, impose quality standards or limit dosage in different applications. When computers and the Internet made it practical, a database was created summarizing all the available safety information for every material used in fragrances.
In 1970, changes were underway that fundamentally altered the fragrance landscape. The world of perfume technology pre-1970 was a very different one. Formulas were written by hand, the process of creating fragrances was almost a cult only practiced by a small group of initiates, and duplicating a fragrance accurately was a difficult process involving many hours of an experienced perfumers’ time. The results were never 100% accurate. And so it was quite reasonable that companies were firmly opposed to revealing the ingredients, and even if the ingredients were disclosed, a fragrance can have more than 100 components, so labeling each would be almost impossible.
In 1970, however, the GC-MS was introduced to the industry, dramatically lowering the barrier to duplicating a fragrance. A fragrance is a mixture of many chemicals intimately blended in a homogeneous liquid. The GC (mass chromatograph) separated the mixture into its individual components, allowing backwards engineering of the composition.
The GC output is initially just lines on paper, and someone can sniff at the output vent and identify the components, or a lot of known materials can be put through the machine so peaks can be identified by their location on the graph. Quantities can be estimated by the area contained by the peak. The MS (mass spectrometer) takes the individual peaks, blasts them apart and generates a component analysis. There still must be a computer library to clarify the output, and an experienced perfumer or chemist to complete the task, but it is all efficient and accurate. If the fragrance is in a product such as a shampoo or lotion, it can be separated with solvents and then analyzed. Every company does these duplications routinely both as a response to projects (“I want something that smells like Hypothetical Shampoo”) or to have the accords in the perfumers arsenal (“Here’s the report on the new Hypothetical Air Freshener). Consumers don’t copy fragrances, companies copy each other’s fragrances.
So fragrances are not really secret intellectual property anymore, at least not from the competition. The fragrance ingredients are only secrets to consumers—and modern consumers hate secrets, especially when it involves something they smell or put on their skin. This opens the door wide to industry critics, one of which describes fragrance as “an unspecified mix of chemicals likely to contain phthalates and allergens.” Not true, but how do we, the industry, correct the misconception that spreads to our consumers? Besides technology and the Internet itself, the biggest change since 1970 involves the level and speed of which consumer activism spreads. And the spreading of false or misleading information is easier than communicating facts.1 The science of fragrance safety is harder to promote than hot button words such as parabens, phthalates, endocrine disruptors and “chemicals” and the connotation of “bad.”
The only way to win in a battle such as this is complete disclosure. A fragrance formula may be cumbersome to put on a label, but not to place on a website. Some companies have made an effort to get fragrance information on their sites, with limited success due to push back from within the industry itself. The only way to make disclosure a reality is for a critical mass of brand owners to demand the information is open and available. Nomenclature is a valid issue to be examined. Some fragrance names do not trip off the tongue, for instance methyl 2,6,10-trimethylcyclododeca-2,5,9-trien-1-yl ketone—but undecylamidopropyltrimonium methosulfate doesn’t seem a problem for cosmetics. So long, ugly names work in practice.
Fragrance materials have diverse safety profiles, from those so bad they have been banned, to those good enough to eat. Though by cruel irony, being edible doesn’t necessarily imply safety to the skin, as they involve radically different exposure routes. It is counterintuitive, and a fine example of why the science of safety is so challenging. Communicating the science clearly and simply is a necessary adjunct to disclosure.
To its credit, IFRA, including IFRA North America (IFRA NA, formerly FMA), have cooperated with the transparency effort.2 IFRA has made public a list of 3,163 fragrance ingredients used globally, and IFRA NA has provided EPA with a list of more than 600 materials used in air fresheners and more than 1,500 materials used in EPA-registered pesticide products.
These organizational actions, laudable as they are, need the support of all industry players. And let us be perfectly clear and scream it from the rooftops, fragrances are very safe. We are infinitely less likely to have a harmful reaction from a fragrance than from a peanut, shellfish or strawberries, so this is, in a sense, a tempest in a teacup. But by disclosing ingredients and making the safety criteria imposed on fragrances as transparent as possible, the single greatest criticism of the industry is removed.
The justifications for secrecy, valid in 1970, have long ago expired. Full and public disclosure will bring the industry one step closer to proving what it first thought in the 1960s—that it is best to self-regulate.
- S Herman, Chemical Reaction: Toxicology in the Age of Twitter, GCI 179 2 54–55 (March 2011)
Steve Herman is president of Diffusion LLC, a consulting company specializing in regulatory issues, intellectual property, and technology development and transfer. He is a principal in PJS Partners, offering formulation, marketing and technology solutions for the personal care and fragrance industry. He is an adjunct professor in the Fairleigh Dickinson University Masters in Cosmetic Science program and is a Fellow in the Society of Cosmetic Chemists.