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Naturals in Europe

By: Marie Alice Dibon
Posted: April 19, 2010, from the April 2010 issue of GCI Magazine.

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Though the industry seems to be willing to go beyond consumer demand and adapt to this new environment, it remains that the regulatory constraints imposed on new, and especially on active, ingredients could definitely become enormous roadblocks in the near future.

Robert Anton, also present at the SFC meeting and a pharmacognosy expert with a chair at the Strasbourg University, has consulted with many major cosmetic and pharmaceutical companies through the years, and sat on or is still seating in a number of committees and commissions, both at the European and French level. He shared the experience he has had recently with nutritionals. “In order to make claims on supplements, you will soon have to use clinically proven ingredients. There are thousands of ingredients that fall under those new regulations. I sit on the commission in charge of re-validating these ingredients. To this day, we have reviewed 250 products containing natural plant extracts. Not one of them has passed the clinicians’ evaluation. They are hard-core clinicians, coming from pharma, and they apply the same principles to naturals. So if something is not proven by their standards, it is as good as trash. If we keep at it, everything will be refused, and we will have to either give up on claims, or give up on supplements. REACH is doing the same thing to cosmetic ingredients.”

The root cause for this is that now what Europeans call “the precaution principle,” which is part of the EU’s constitution. This means that unless a company can prove a zero risk, it holds off using anything. It is, in theory, a good principle, but it is also easy to see that, had this principle been used for every human endeavor in history, far less progress would have been achieved.

REACH can be, indeed, a complete nightmare when it comes to naturals. Laurence Mulon, a consultant in Paris who specializes in regulatory matters, made a complete review of what it takes to register a natural substance in REACH. For now, a few major hurdles are in the way. One is that the substances are looked at much like single-chemical entities—the principle is “one substance, one registration”—and they are trying to be “simplified.” The example of essential oils is very telling, showing how the European federations of Fédération Européenne des Huiles Essentielles and Association Européenne des Parfums et Arômes offered to establish a grouping by main chemical compound for aromatic compounds and EO, such as esters, alcohols, adehydes and so on.

Moving ahead

The bottom line is that the beauty industry is now dealing with a situation where there is an enormous divide between market reality and regulatory expectations. Though Europeans are used to dealing with naturals in a fairly scientific way, natural substances have always been considered reliable remedies, and consumers also love the other aspects of naturals, including the ideas of reconnecting with nature, of doing the right thing while consuming, of the story behind the plants and of the sourcing.