Once upon a time, the Scientific Committee on Consumer Safety (SCCS), followed by the EU, decreed that there should be 26 fragrance chemicals that were so allergenic they could only be present in cosmetics at a designated maximum concentration and that their names should be printed on the label of any cosmetic that contained them. Sixteen of these chemicals occur in essential oils – although some in very few. There was, and still is, much debate about the criteria used when these fragrance ‘allergens’ were selected, and the criteria have never been made clear.
In 2017, the SCCS concluded that one of the listed fragrances, hydroxyisohexyl-3-cyclohexene carboxaldehyde (also known as HICC or Lyral), along with atranol and chloroatranol (natural components of oakmoss and treemoss extracts), that were not restricted nor prohibited under the current regulations, although oakmoss and treemoss extracts were, had caused the highest number of contact allergy cases in recent years. Therefore, the European Commission updated the regulations to prohibit the use of these three fragrance allergens from August 2021. As the ban was implemented before the end of the transition period it will continue to apply in the UK as retained EU legislation.
OK – perhaps this all seems a bit boring, but consideration is being given to increasing the list to 82 materials that “…can be categorised as established contact allergens in humans…”, of which 28 are ‘natural extracts’ ie essential oils/absolutes. Some are in general use as fragrances and include: bergamot, lemon, sweet orange, jasmine, lavender, geranium, rose and sandalwood. What I find particularly concerning is that, even if an essential oil is not in itself allergenic, if it contains chemicals that can become allergenic when oxidised it is to be treated as an allergen.
If you make your own retail cosmetic products, then the proposed increase in the number of allergens that have to be declared (if their concentration is greater than 0.001% in a leave-on product or greater than 0.01% in a rinse-off product) will only affect you if the UK government chooses to adopt the same extended list of ‘allergens’ or you want to sell into the EU. Although it should be pointed out that many countries around the world adopt the EU allergens list. Of course, the existing list of declarable allergens continues to apply in the UK as retained EU legislation.
Don’t ask how the additional allergens are going to get onto a product label – that’s for another time!
naturalscienceconsultants.org 