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March 23, 2007

Cosmetics “Hotlist”

The Cosmetics Division at the Consumer Product Safety Bureau, Health Canada have published a March 2007 version of their “Cosmetics Hotlist” replacing the previous May 2005 version. If a substance in the Hotlist which appears in a marketed cosmetic, then the manufacturer is advised to take remedial actions from a range of options which might include removing or reducing the concentration of the offending ingredient, or being prepared to prove that its use is safe for the purpose intended.

Several of the Hotlist inclusions on the aromatic ingredients side seem to have been poached from previous Brussels regulatory developments. For example, one of the items on the previous 2005 Hotlist is benzyl cyanide, a substance now moved into Annex II of the EU’s Cosmetics Directive. Benzyl cyanide is a naturally occurring substance which appears in the headspace of many flowers, and is a component of certain perfumery absolutes, including the much-sought after and difficult to source karo karunde from Leptactina senegambica Hook. f., and genet from broom flowers Spartium junceum L. It is also given off in large volumes by the sickly sweet & decidedly unpleasant odour of the yellow flowers of mustard seed rape (Canola), grown in Europe for its fixed oil. As I have mentioned elsewhere, since I used to live next to a rape field, and thanks to the local farmer, I did not escape an annual toxic communal gassing from cyanides & isocyanates which these flowers emit for 12 consecutive years. Of course no legal action can ever be taken against farmers, but the cosmetics industry, responsible in my case for considerably less than a millionth of the annual body-load dosing that farmers are responsible for, has restrictions placed upon it. 

Next, no doubt, the authorities will be banning bringing flowers into our houses - many of which, of course give off the alleged rodent carcinogen methyl eugenol, already heavily restricted in cosmetics by IFRA, and on the Canadian Hotlist since 2004. Most leafy trees give off large annual volumes of alpha- & beta-pinenes to the extent that these are measurable in normal atmospheric air. So no doubt trees and flowers will be soon be classified as hazardous to health on the basis that they emit dangerous chemicals which are already restricted or banned in cosmetics. Presumably this explains why no legal action is ever taken against logging companies who are doing a fine job in many parts of the globe of ridding the planet of our forests, err, I mean, dangerous botanical hazardous chemical emitters.

Returning to the Hotlist, you will also see that the Canadian Cosmetics Division have (in the new 2007 list) copied across new restrictions on chemicals toxic to children, namely camphor (limited to 3%) and eucalyptus oil to (limited to 25%). The eucalyptus species is not identified by a Latin binomial (going against their own stated policy guidelines) but the CAS No. indicates that the ruling pertains to Eucalyptus globulus.  The status of other high-cineole containing eucalyptus oils e.g. E. polybractea & E. smithii which are also listed as eucalyptus oils in many national pharmacopoeias is not clear, and Cropwatch has written to Health Canada for clarification.

Previously, the previous May 2005 Hotlist had included several allegedly photo-toxic ingredients such as methyl N-methyl anthranilate, and an oil which contains large amounts of this substance, Citrus reticulate leaf oil (mandarin petitgrain oil). The previous list had also included tagetes oil & absolute, going further than IFRA/the SCCP opinion by banning it completely on photo-toxicity grounds. As with many of these precautionary-principle type restrictions, arising from the conclusions of in vitro studies, Cropwatch has previously been unable to find a single literature reference to any end-user adverse reaction(s) due to the inclusion of tagetes oil in cosmetics. 

Posted by Tony Burfield on March 23, 2007 in Regulatory Issues | Permalink

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