2016 Fragrance Labeling Requirements...

Dorje123

Basenotes Dependent
Feb 15, 2011
...Seem to have changed. I just got a Fragrance with a 2016 release date and there are a lot of things on the list I've never seen on a fragrance label before.

 

Dorje123

Basenotes Dependent
Feb 15, 2011
One nice thing to see on there is iso e super... I don't like it when used in larger quantities. I'm assuming the list is in order from largest to smallest quantities used, so now if iso e is near the top of the list I'll know to stay away. As used in Aeon 001 it's not at all obvious.

Also, you can certainly make a pretty long list of notes from the label... not sure how perfumers feel about this, they may be required to list ingredients they would rather keep secret!

It is educational though, I didn't know pogostemon cablin is patchouli, also lavendula (lavender) is at the top and it's so well blended I couldn't pick it out without seeing it on the label, but apparently there's a lot of lavender in Aeon 001. :)
 

adam090273

Basenotes Dependent
Jul 27, 2013
Probably it's a good thing I'm oblivious to all of that! :grin:

Me too. I never look at ingredients etc. on boxes or packaging. They could put anything in a bottle and I'd be oblivious.

But I don't suffer any allergies so it's not something I need to be worried about.
 

DuNezDeBuzier

Basenotes Dependent
Nov 7, 2009
I believe the current requirement is REGULATION 1223/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 November 2009 on cosmetic products (OJ L 342, 22.12.2009, p.59) -- Chapter VI - Consumer Information - Article 19 - Labelling - 19(1)(g)... Which (in my laymen's reading)

1. requires the listing of perfume as ‘parfum’ or ‘aroma’;
2. requires any of the 26 allergen causing materials as indicated in its Annex III (think oakmoss, treemoss, etc.) to be listed if the material is in the mix at 10 PPM or more;
3. may include other materials used, including colorants, on the list;
4. requires a descending order (by weight) for those materials in the mix at 10,000 PPM or more; and
5. any materials either required to be on the list or voluntarily included on the list at less than 10,000 PPM may be included in the list in any order.

I'd think it's reasonable to think that the listing the OP provides is sorted by descending amount in composition... but that's an assumption. Providing they're in compliance, all we can really be certain is that:
1. of the 26 allergen causing materials, the following are included in the composition at 10 PPM or more: geraniol, benzyl cinnamate, citronellol, limonene, linalool AND of the 26, the following are not included in the composition at 10 PPM or more: amyl cinnamal, amylcinnamyl alcohol, benzyl alcohol, benzyl salicylate, cinnamyl alcohol, cinnamal, citral, coumarin, eugenol, hydroxycitronellal, hydroxymethylpentyl-cyclohexenecarboxaldehyde, isoeugenol, anisyl alcohol, benzyl benzoate, farnesol, hexyl cinnamaldehyde, lilial, methyl heptine carbonate, 3-Methyl-4-(2,6,6-trimethyl-2-cyclohexen-1-yl)-3-buten-2-one, oak moss, and tree moss.
2. lavandula officinalis, citurs reticulate, cyclomethicone, citrus bergamia, santalum album, vetiveria zizanoides, cupressus semppervirens, laurus nobilis, pogostemon cablin, cananga odorata extracts, musk ketone, safraleine, cupressus sempervirens, lilestralis, isopropyl myristate myrrh resinoid extracts, iso e super, benzoin siam extracts, citrus x paradise, boswelia serrata, and jasminum sambac are all listed voluntarily.

Further, independent from the EA labelling requirement, IFRA standards:
1. (45th amendment) allow for the use of musk ketone as long as musk xylene is not present, as an impurity, at 1,000 PPM in the musk ketone -- for environmental reasons.
2. (43rd amendment) restricts the use of conanga odorata (ylang ylang) extracts to 8,000 PPM -- for sensitization reasons.
3. (48th amendment) restricts the use of lilestralis to 18,600 PPM -- for dermal sensitization reasons.
4. (47th amendment) restricts the use of myrrh resinoid extracts (opoponax) to 4,500 PPM -- for sensitization reasons.
5. (43rd amendment) restricts the use of iso e super to 214,000 PPM -- for sensitization reasons.
Perhaps we can assume compliance in that the use of these ingredients do not exceed the restricted amounts?

That's how I see it, at least.
 

Dorje123

Basenotes Dependent
Feb 15, 2011
I believe the current requirement is REGULATION 1223/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 November 2009 on cosmetic products (OJ L 342, 22.12.2009, p.59) -- Chapter VI - Consumer Information - Article 19 - Labelling - 19(1)(g)... Which (in my laymen's reading)

1. requires the listing of perfume as ‘parfum’ or ‘aroma’;
2. requires any of the 26 allergen causing materials as indicated in its Annex III (think oakmoss, treemoss, etc.) to be listed if the material is in the mix at 10 PPM or more;
3. may include other materials used, including colorants, on the list;
4. requires a descending order (by weight) for those materials in the mix at 10,000 PPM or more; and
5. any materials either required to be on the list or voluntarily included on the list at less than 10,000 PPM may be included in the list in any order.

I'd think it's reasonable to think that the listing the OP provides is sorted by descending amount in composition... but that's an assumption. Providing they're in compliance, all we can really be certain is that:
1. of the 26 allergen causing materials, the following are included in the composition at 10 PPM or more: geraniol, benzyl cinnamate, citronellol, limonene, linalool AND of the 26, the following are not included in the composition at 10 PPM or more: amyl cinnamal, amylcinnamyl alcohol, benzyl alcohol, benzyl salicylate, cinnamyl alcohol, cinnamal, citral, coumarin, eugenol, hydroxycitronellal, hydroxymethylpentyl-cyclohexenecarboxaldehyde, isoeugenol, anisyl alcohol, benzyl benzoate, farnesol, hexyl cinnamaldehyde, lilial, methyl heptine carbonate, 3-Methyl-4-(2,6,6-trimethyl-2-cyclohexen-1-yl)-3-buten-2-one, oak moss, and tree moss.
2. lavandula officinalis, citurs reticulate, cyclomethicone, citrus bergamia, santalum album, vetiveria zizanoides, cupressus semppervirens, laurus nobilis, pogostemon cablin, cananga odorata extracts, musk ketone, safraleine, cupressus sempervirens, lilestralis, isopropyl myristate myrrh resinoid extracts, iso e super, benzoin siam extracts, citrus x paradise, boswelia serrata, and jasminum sambac are all listed voluntarily.

Further, independent from the EA labelling requirement, IFRA standards:
1. (45th amendment) allow for the use of musk ketone as long as musk xylene is not present, as an impurity, at 1,000 PPM in the musk ketone -- for environmental reasons.
2. (43rd amendment) restricts the use of conanga odorata (ylang ylang) extracts to 8,000 PPM -- for sensitization reasons.
3. (48th amendment) restricts the use of lilestralis to 18,600 PPM -- for dermal sensitization reasons.
4. (47th amendment) restricts the use of myrrh resinoid extracts (opoponax) to 4,500 PPM -- for sensitization reasons.
5. (43rd amendment) restricts the use of iso e super to 214,000 PPM -- for sensitization reasons.
Perhaps we can assume compliance in that the use of these ingredients do not exceed the restricted amounts?

That's how I see it, at least.

Wow, thanks for that.

I guess I've never seen voluntary inclusions on a label, or never noticed it, but that would explain why so many more ingredients are on the label. I wonder why they would list them?

Also interesting that ingredients under 10k ppm can be in any order...

On the iso e super, 214,000 PPM = 21.4%, I'm guessing that's the final mix including alcohol, water, etc? I know some have much higher percentages, but afaik that's the percentage of iso e in the pure perfume oil, before it's diluted....
 

DuNezDeBuzier

Basenotes Dependent
Nov 7, 2009
^ yes... iso e super restricted to 21.4% "in the finished product"... so IFRA represents.

With all the convoluted detail... I wonder just how useful these labels are to people? Do 1 in 10 find it of use, 1 in a 100, 1 in 1,000,000 or virtually none at all? I get the well meaning intent, but wtf good is it all if it's lost on those it's designed to serve?

What I mean is... There is a huge disconnect between the EA regulations and the IFRA industry standards. The industry provides the following restrictions in final product of perfume, presumably in good conscious, however the gov't requires labelling of the ingredient if present in amounts (10PPM) that are so far away from what the industry has restricted, one glaring conclusion a reasonable person can make is that the gov't believes the industry is much too liberal in setting its self-regulatory restrictive boundaries, and often by magnitudes at that. YET, since the gov't is not requiring any indications of the relative PPM included within for any of the 26 materials required to be listed, by example, any fully-informed potential geraniol sufferer can only conclude that there is between 10 and 53,000 PPM worth of geraniol in this product. I ask, just how is that labelling requirement useful?

Allergen (per the EA) - applicable IFRA code/standard / Restriction
Geraniol - 42nd amendment / restricted to 53,000 PPM
Benzyl cinnamate - 42nd / 21,000PPM
Citronellol – 42nd / restricted to 133,000PPM
Limonene – peroxides must be kept at the lowest possible levels (whatever that means)
Linalool – 38th / limit on peroxides
Amyl cinnamal - 47th / 10,700PPM
Amylcinnamyl alcohol - 42nd / 16,000PPM
Benzyl alcohol – 42nd / 27,000PPM
Benzyl salicylate – 42nd / 80,000PPM
Cinnamyl alcohol – 43rd / 4,000PPM
Cinnamal - 47th / 500PPM
Citral – 47th / 6,000PPM
Coumarin – 43rd / 16,000PPM
Eugenol – 43rd / 5,000PPM
Hydroxycitronellal – 47th / 10,000PPM
Hydroxymethylpentyl-cyclohexenecarboxaldehyde -
Isoeugenol – 43rd / 200PPM
Anisyl alcohol – 48th / 6,800PPM
Benzyl benzoate – 42nd / 267,000PPM
Farnesol – 40th / 12,000PPM
Hexyl cinnamaldehyde – 47th / 107,000PPM
Lilial – 48th / 18,600PPM
Methyl heptine carbonate – 43rd / 100PPM
3-Methyl-4-(2,6,6-trimethyl-2-cyclohexen-1-yl)-3-buten-2-one – 48th / 316,700PPM
Oak moss / Tree moss – 43rd / 1,000PPM, provided atranol & chloroatranol levels are each below 100PPM in the oak/tree moss extract​

Thinking it through... perhaps all those people that are already sensitive to geraniol will have a reaction if exposed to amounts as little as 10PPM and that is what the gov't hopes to cover... whereas, IFRA's restrictive amount is meant to be amount of ingredient the vast majority of the population (97%) will not develop a sensitivity to regardless of repeated exposure over time. Hmmm, that would make more sense obviously.

Honestly, this is as far as my mind goes on the subject. Can anybody familiar with the IFRA/RIFM scientific methodology extend the discussion further?
 
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David Ruskin

Basenotes Dependent
May 28, 2009
It used to be that if one of the 26 allergens was present in a fragrance above a certain amount it had to be listed, but it didn't matter whether the allergen was added as such or was part of an Essential oil. Now, if the allergen is present as part of an oil both the allergen and the oil use be listed, hence the inclusion of lots of latin names of plants.
 

Mattoligy

Basenotes Member
Mar 6, 2016
Why have lots of companies (YSL) reformulated fragrances in there line for the worse if all they have to do is list allergens on the box? La Nuit De L'Homme for example. Why can't it go back to its former largely better formulation with all "allergens" listed on the box?
 

gandhajala

Basenotes Dependent
Sep 3, 2010
Why have lots of companies (YSL) reformulated fragrances in there line for the worse if all they have to do is list allergens on the box? La Nuit De L'Homme for example. Why can't it go back to its former largely better formulation with all "allergens" listed on the box?

Reformulations occur for a variety of reasons, compliance with regulations and/or recommendations being just one.
Labelling doesn't give you carte blanche to include whatever you like in whatever quantities you wish; you still have to abide by regional laws.
 
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