April 04, 2012

Ingredient obsession

by Robert Tisserand

I am not against transparency in labeling. I think it’s a subject that could use a lot of discussion. But I am against ingredient obsession. In a society that allows alcohol, tobacco and firearms to be freely purchased, and that turns a blind eye to the widespread use of illegal drugs, why are we concerned about whether a consumer product might contain a few parts per million of chemical X? Should we not be concerned, rather about whether the product itself is safe?

Ingredient tunnel vision is seriously bad for your health. It will turn you into an obsessive, paranoid, vicious, spitting fireball of righteous indignation. You will write searing blog posts, develop gastritis or worse, lose sleep, and die young. And for what? Essential oils and their constituent chemicals are very frequent targets. Because essential oils contain chemicals, and because almost all chemicals are, to some people, toxic by definition, many bloggers in the green movement have become anti-fragrance and anti-essential oils. For a while I though that, when they realize that linalool is found in lavender oil, and that limonene is in lemon oil, they will relent. I was wrong. Obsession is, in fact, relent-less. It allows no release, no vacation, no light side. It is all-consuming!

Because essential oils are alleged to contain “allergens”, they are also favorite targets of regulators and legislators, especially in Europe. And, we in North America know full well that whatever happens in Europe must be good, because Europeans are more intelligent. Their accents prove this. Since I have been living in the US (12 years now) my accent has slowly become less English English, and more American English, and my mental faculitoes have detturiated protortionisely, as you kan see.

More on Europe soon. But first, a new study financed by Silent Spring Institute, written by Robin Dodson et al, and published in Environmental Health Perspectives. EHP claims to be peer-reviewed, but if this report is anything to go by, its reviewers need replacing. In fact, they might as well not bother with peering, since it clearly accomplished nothing. The report is entitled: Endocrine Disruptors and Asthma-Associated Chemicals in Consumer Products. Classes of chemicals that were tested for include UV filters, cyclosiloxanes, glycol ethers, parabens, phthalates, alkylphenols and fragrances. The “fragrances” tested for include these essential oil constituents:

For your edification, I have highlighted one essential oil and also some foods that naturally contain said chemical. No rationale is given for why these particular substances were selected. This is important, not only because they have now become what might be called “target chemicals of concern”, but because the list could have been so much longer. It could include almost every essential oil constituent in existence. Now, at a rough guess, this is in the region of 1,000. The above list is said to represent “asthma-related chemicals”. This is not defined anywhere, but the article begins with “Laboratory and human studies raise concerns about endocrine disruption and asthma from exposure to chemicals in consumer products” and it goes on to talk about “asthma-related chemicals.”

Fragrance chemicals do not cause asthma, but they can exacerbate asthmatic symptoms. Many fragrance chemicals have this potential because they are very mild respiratory irritants in concentration. It’s the nature of the beast. However, listing limonene, isobornyl acetate, terpineol etc., is not helpful. If you are asthmatic, and you tend to react badly to fragrances, then you stay away from fragrances. Mounting a new campaign to list particular fragrance ingredients on consumer labels will not accomplish anything. It will not meaningfully make fragrances safer, and if consumers need a warning that a product is fragranced, this can be accomplished in either one word: “FRAGRANCE”. Or two: “CONTAINS FRAGRANCE”.

The paper states that, if a compound is “available from plant materials”, it was described as natural, and if “commonly synthesized”, then it was described as synthetic. But there is no list! No classification! So we don’t know which they regard as natural, and which as synthetic! In the text, limonene is mentioned as being natural (correct), isobornyl acetate as synthetic (incorrect) and hexyl cinnamaldehyde as natural (incorrect, since it is always synthesized. It is also spelled wrongly throughout the article. I’m Just saying…).

No direct evidence is provided for any adverse health effects for any of these compounds, and there is no discussion of the factors involved, although several papers are cited: “Fragrances, particularly terpenes such as limonene, are associated with secondary chemical reactions in indoor air, and can contribute to the production of formaldehyde, glycol ethers, ultrafine particles, and secondary organic aerosols (Nazaroff and Weschler 2004; Singer et al. 2006). Exposure to fragrances has been associated with a range of health effects, including allergic contact dermatitis, asthma and asthmatic exacerbations, headaches, and mucosal symptoms (Heydorn et al. 2003; Kumar et al. 1995; Steinemann 2009).”

Dodson and friends do not mention that moderate-to-high levels of ozone are required for these reactions to take place, nor that cleaning products (which can also contain volatiles such as formaldehyde, benzene, toluene and xylene) are the only ones that have been reported to cause actual health problems (Nazaroff and Weschler 2004). Ozone-limonene reactions can produce hydroxyl radicals, and these in turn can contribute to formaldehyde formation (Fan et al 2003). However, this was only observed under conditions that were admitted to be not typical of “nonindustrial indoor environments.” And, the statement that terpenes such as limonene can contribute to the formation of glycol ethers is not true. Nazaroff and Weschler (2004) state that both terpenes and glycol ethers were found in some cleaning products, not that one is formed from the other! And while I’m on my soapbox,, ultrafine particles and secondary organic aerosols are the same thing. Now, if I can find this many holes in a research paper without breaking a sweat, where is the so-called “peer-review”? And how much credence can we give any of the findings?

The Kumar et al (1995) study did find exacerbation of respiratory symptoms in asthma patients when they smelled perfume scent strips, as used in magazine advertising. And other research shows that if you give asthma patients strong fragrances to inhale, they may react adversely. The same is true for people with multiple chemical sensitivity, but it is not true of the general population.

Under extreme conditions terpenes such as limonene and pinene do form particles that are respiratory irritants. These conditions require (a) moderate-to-high ozone, and (b) substantial quantities of vaporized terpenes. These may be hazardous for vulnerable individuals, such as babies, older people, or people with asthma. However, it’s a leap to assume that fragrances cause health problems. They don’t. Yes, a fragrance could trigger an asthma attack in a person with asthma. But it cannot cause asthma. In a mostly supportive Forbes blog post based on Dodson’s article, Amy Westervelt quotes the following lines:

“This study presents a clear example of biased, advocacy-based research,” says William Troy, Ph.D., Scientific Advisor the International Fragrance Association North America. “It is a repackaging of older information and the methodology used defies basic principles and standards of scientific protocols and investigations. The advice to consumers based on study findings is simply wrong,” said Dr. Troy.

“There’s been a lot of work done on exposure to these chemicals in average households, and we know that these chemicals are found in air and dust in peoples’ homes, and the CDC [Center for Disease Control] has shown that we find them in our bodies as well,” says the study’s lead author Dr. Robin Dodson. “Now we’re trying to understand where the chemicals are coming from, and how people are exposed to them.”

There is a degree of naivete in this last statement. As far as the fragrant compounds are concerned, they are naturally found in some common foods (see Table), so that could be one reason that they are found in our bodies. Limonene and pinene are ubiquitous simply because so many trees produce them. If you have pine furniture, it is giving off limonene and pinene vapors. If you have paint thinned with turpentine, same deal, because turpentine is made from pine trees. If you live near trees…basically, if you’re breathing, you are inhaling limonene and pinene. How much you are inhaling, what the ambient ozone level is, and whether or not you have asthma are all considerations in whether these vapors might present a hazard. Some advice:

  • If you are asthmatic, beware of strong fragrances.
  • In high-ozone conditions (usually hot weather combined with factory exhalations and/or much vehicular traffic) beware of exposure to high levels of fragrant molecules.
  • When using cleaning products, paints, glues or varnishes, ventilation is important.
  • Note that some types of office equipment, such as photocopiers and fax machines, give off ozone.

Dodson advises avoiding fragranced products, and looking for ones with plant-based ingredients. So would that include or exclude essential oils? I’m baffled.

Dodson R, Nishioka M, Standley LJ et al 2012 Endocrine Disruptors and Asthma-Associated Chemicals in Consumer Products.

Fan Z, Lioy P, Weschler C et al 2003 Ozone-initiated reactions with mixtures of volatile organic compounds under simulated indoor conditions. Environmental Science & Technology 37:1811-1821

Heydorn S, Johansen JD, Andersen KE et al. 2003 Fragrance allergy in patients with hand eczema – a clinical study. Contact Dermatitis 48:317-323

Kumar P, Caradonna-Graham VM, Gupta S et al 1995 Inhalation challenge effects of perfume scent strips in patients with asthma. Annals of Allergy Asthma & Immunology 75:429-433

Nazaroff WW, Weschler CJ 2004 Cleaning products and air fresheners: exposure to primary and secondary air pollutants. Atmospheric Environment 38:2841-2865

Steinemann AC 2009 Fragranced consumer products and undisclosed ingredients. Environmental Impact Assessment Review 29:32-38

Robert Tisserand is internationally recognized for his pioneering work in many aspects of aromatherapy since 1969 and frequent contributor to the aromaconnection blog.

Posted by Blogmistress on April 4, 2012 in Aromatherapy, Essential Oils/Plant Extractions, Perfumery, Safety/Toxicity, Standards | Permalink | Comments (4) | TrackBack

November 19, 2009

One More Time: There Are No FDA Certified Pure Therapeutic Grade Essential Oils, Part I

I thought we had cleared up this misconception years ago, however, it seems there are a number of essential oil purveyors claiming to carry essential oils  that are specifically certified as therapeutic grade by the FDA and show this seal below as proof.  Don’t be fooled.  They are not telling the truth.  In reverse order, this is one path to their deception.

 imageThis last trademark has been registered (as a word mark) by DoTERRA Holdings, LLC, 370 W. Center Street,  Orem, UT 84057.  Filed on March 4, 2009, published for opposition on July 1, 2009 and official registration granted on October 6, 2009.  This registration has the disclaimer, “No claim is made to the exclusive right to use ‘certified pure therapeutic grade’ apart from the mark as shown.

A third trademark has been registered (as a word mark) CPTG Certified Pure Therapeutic Grade also by DoTERRA Holdings, LLC, 370 W. Center Street,  Orem, UT 84057.  Filed on March 4, 2009, published for opposition on July 14, 2009 and official registration granted on September 29, 2009. This registration also has the disclaimer, “No claim is made to the exclusive right to use ‘certified pure therapeutic grade’ apart from the mark as shown”. There is a long list of products shown to be associated with this word mark.

A second trademark has been registered (as a word mark) CPTG also by DoTERRA Holdings, LLC, 370 W. Center Street,  Orem, UT 84057.  Filed on March 31, 2008, published for opposition on June 10, 2008 and official registration granted on May 9, 2009.

image A first trademark has been registered (as a word mark) CPTG also by DoTERRA Holdings, LLC, 1145 South 800 East, Ste. 134,  Orem, UT 84057.  Filed on March 31, 2008, published for opposition on June 10, 2008 and official registration granted on May 9, 2009. Under the trademark registration, they show application to the following products: Essential oils; Essential oils for household use; Essential oils for personal use; Lavender oil; Massage oil; Massage oils; Natural essential oils; Aromatherapy oils; Bath oils; Body oils; Cosmetic oils; Cosmetic oils for the epidermis; Essential oils for flavoring beverages; Essential oils for food flavorings; Essential oils for use in manufacturing of gelcaps and other dietary supplements; Essential oils for use in the manufacture of scented products; Oils for cleaning purposes; Oils for toiletry purposes; Skin and body topical lotions, creams and oils for cosmetic use; Food flavorings prepared from essential oils; Oils for perfumes and scents; Peppermint oil; Perfume oils; Tanning oils.

DoTERRA, LLC is yet another multi-level marketing natural products company based in Utah who has applied through the U.S. Patent Office to “own” (exclusive use) a registered word mark.  This registered word mark has not been provided to them by the FDA as they claim and is meaningless in proving that an outside certifying body has declared or designated that DoTERRA’s essential oils are certified pure therapeutic grade.  DoTERRA, LLC owns the right to exclusive use of the mark (however not the exclusive right to the actual words “Certified Pure Therapeutic Grade” which is revealing)  This seal or word mark is nothing more than a commercial trademark that they have registered and paid a fee for.  However, DoTERRA is purposefully misinforming potential customers and down liners by email by claiming FDA approval and that the FDA has provided them with the label that they, themselves registered and own.  The FDA does NOT certify the quality of essential oils by therapeutic grade and they do not provide a certifying label as claimed.  Following is an email from DoTERRA sent to a potential customer:

---------- Forwarded message ----------
From: dōTERRA Member Service <service@doterra.com>
Date: Mon, Nov 16, 2009 at 5:01 PM
To: Recipient Name and Email Removed for Privacy

Dear Recipient Name Removed for Privacy,

We apologize if one of our consultants has mislead you in anyway (sic).  All of our oils are FDA approved as being Certified Pure Therapeutic Grade (CPTG). DoTERRA's, CPTG essential oils are 100% pure natural aromatic compounds carefully extracted from plants.  They do not contain fillers or artificial ingredients that would dilute their active qualities and are free of contaminants such as pesticides or other chemical residues.  All of our products are taken through a series of tests including  AFNOR and ISO standards for purity, and all of our manufactures must maintain a GMP certification.  Therefore, we are passing government regulations.  The FDA has provided us with the label of CPTG. We hope we have resolved your concern.

Member Services
doTERRA International, LLC
370 West Center Street
Orem, Ut 84057

Clearly this company is misleading people by claiming that they have a designation and approval provided to them by the FDA that in my expert opinion simply does not exist.  Stay tuned for part II of this series which will focus on FDA regulations that actually apply to essential oils and the part III will provide you with questions to ask a supplier that will ascertain their knowledge of essential oils and expertise in the industry.  

We at Samara Botane and many others in the essential oil trade have are dismayed about the misrepresentation of facts surrounding essential oils that occurs here in the United States, especially within the multi-level marketing industry.  We encourage people to diligently research any essential oil company before choosing them as a supplier.

Marcia Elston
Samara Botane/Nature Intelligence

Please feel free to repost this message in its entirety, unedited, on your blog as well as social media outlets and newsgroups. 

Posted by Blogmistress on November 19, 2009 in Certification, Essential Oils/Plant Extractions, Regulatory Issues, Standards | Permalink | Comments (9) | TrackBack

May 19, 2009

Cropwatch at the SCS Symposium, Grantham UK, 2009

Tony Burfield gave a talk entitled “Legislators & Natural Aromatics: a Modern Day Vendetta” at the Symposium on Cosmetic Controversies –Seeing the Whole Picture organised by the Society of Cosmetic Scientists, May 17-19th 2009. Power Point and pdf versions of the above presentation can be viewed in the newly reorganised Cropwatch Files section of the Cropwatch website. Matthias Vey of IFRA spoke immediately after Cropwatch, his talk being entitled “How Safe are Fragrance Raw Materials? The IFRA Principles for Safety Assessment.” In the interests of balance, we hope it eventually becomes possible to run both talks side by side, and for both parties to answer the other’s criticisms.

Looking to the future, Cropwatch has plans to become a funded operation later this year. Although we continue to expand our available data on natural products on the Cropwatch website, and to attract new Cropwatch Newsletter subscribers, and we continue to regularly receive pledges of support from many quarters, we feel that there is a limit to what can be practically achieved without funding. Our intention therefore is to run a series of courses in order to raise the necessary finance, which is to be spent on research into some of the contentious areas of aroma ingredient toxicity, which Cropwatch has previously identified. We hope to be able to announce the subjects and venues for the courses in due course.

Tony Burfield

Posted by Tony Burfield on May 19, 2009 in Aromatherapy, Essential Oils/Plant Extractions, Lavender/Tea Tree/Gynecomastia, Perfumery, Regulatory Issues, Safety/Toxicity, Standards | Permalink | Comments (0) | TrackBack

February 19, 2009

NSF's 'made with organic' standard becomes an American National Standard

Cosmeticsdesign.com (as well as lots of other sites) report that NSF's 'made with organic' standard becomes an American National Standard. This is the organic standard that was being promoted by Dr. Bronner’s Soaps that we blogged about last year. The “made with organic” bar is set fairly low, with only 70% of the ingredients required to be organic.  Products covered by the standard include rinse-off and leave-on personal care and cosmetic products, as well as oral care and personal hygiene products. You can read the original press release from NSF at their site.

The 58 page standard (NSF/ANSI 305-2009) was published February 10 by NSF, but unfortunately costs $100.00 USD for a printed or PDF version. The Table of Contents is available in PDF format for free. The current TOC appears to essentially be the same as that in a draft from early 2008 that I have a copy of (R6), but differences in the actual content are unknown. It would appear that anyone interested in claiming compliance with the standard will have to spring for the $100 for a copy.  However, if the certification process is anything like that planned for the “Natural” standards that are being proposed or adopted ($2500 per product on one of them) it seems that the standard will be well beyond affordability for small and handmade product manufacturers who have pioneered the use of Organic products.

There will be a logo for use by those complying with the standard:

   NSF Made with Organic

One little tidbit from the Draft Standard:

7.1 The term "organic" shall only be used on labels and in labeling of raw or processed agricultural products, including ingredients, that have been produced and handled in accordance with the requirements of this Standard. The term "organic" shall not be used in a product name unless the product meets USDA-NOP criteria or criteria defined in this Standard.

Presumably this clause applies only to products claimed to meet the standard, but since this is now an ANSI standard should we worry that there might be an attempt to extend this to use by others such as essential oil vendors? 

Posted by Rob on February 19, 2009 in Regulatory Issues, Standards | Permalink | Comments (6) | TrackBack

January 26, 2009

Cropwatch Newsletter Jan 2009 Published

The most recent Cropwatch Newsletter Jan 2009 [pdf] has been sent to subscribers and posted on the Cropwatch website. There is also an html format post elsewhere on the web, and several of the articles in it were previously posted on this blog, so we won’t do more than summarize it.

The Newsletter starts out with an Editorial on the theme 2008: A Bad Year for Natural Aromatic Ingredients.  A Good Year for Industry Consultants and Ingredient Clerks, in which Tony discusses the REACH Process, Corporate Influence over IFRA and its affect on the use of Natural Products, and the effects of increasing market demand for natural ingredients on the sustainability of the natural environment.

The articles included in the Newsletter are:

1. The REACH Pre-registration Exercise – an Autopsy
2. Sandalwood – A Critical View of Developments
3. IFRA Gives Up Supporting Two More Natural Aromatics:
Opoponax & Styrax Next for the Chop
4. Frankincense – A Brief Catch-Up
5. The Art of Natural Perfumery: Under Threat from Natural &
Organic Cosmetic Certifying Organisations?
6. The Oakmoss & Treemoss Saga – Slight Return
7. GM Fragrance Anyone? – Hopefully No Takers
8. IFRA Workshop - Allergy Prevalence in Fragrance, November
4, 2008, Brussels, Belgium
9. More on Ylang-ylang oil

Articles 2, 3 and 4 are updated and slightly expanded from articles previously published on this blog. Click on the number for links to the posts here: 2 3 4 however you may want to read the PDF version to get the latest information.

Article 5 on the Art of Natural Perfumery is a detailed analysis and response to the various attempts by various organizations to develop Organic and Natural Standards to control the ingredients used. This topic has been previously discussed on this blog; you can find the articles filed under the category Standards. Tony takes several of the standards to task and closes his article with:

We could review proposals from other organisations, but we think you get the idea ….. both natural & organic cosmetics are a long way from living up to the promise of their descriptions. The lack of common sense is also worrying – for example, banning added synthetics such as UV filters (one thing that Cropwatch would allow) which as well as increasing the shelf-life of the product, arguably
help protect against the risk of solar/UV-induced skin cancer. This ban, taken with other considerations, means that evolving versions of natural & organic cosmetics may be in danger of becoming considerably less safe than conventional cosmetics.

Regarding natural fragrances, it can be guessed that many of us who have been involved in the teaching, promotion & development of the art of Natural Perfumery over the past several years may be getting a bit hot under the collar when whole classes of raw natural aromatic ingredients are suddenly declared “not natural” by the self-proclaimed officials of certifying organisations, who don’t appear have experience across all the areas they are proposing to regulate. The exclusion of concretes, absolutes & resinoids from an inventory of natural aromatics for fragrances intended for natural cosmetics may well pander to the more chemophobic amongst cosmetics customers. But the banning of petrochemical solvents cannot be justified on health grounds relating to supposedly harmful amounts of solvent residues that remain in these materials – since there is no health risk. We should also mention that there is a move to allow solvent extraction in the form of allowing CO2 extracts and bio-ethanol. The protagonists of these proposals do not make clear how they are going to determine whether the CO2 used in such processes is natural (i.e. produced by fermentation of natural materials etc.), or how they will propose to police the matter. Cropwatch’s guess is that (a) they haven’t thought about it and (b) they can’t guarantee it (thanks to Daniel Joulain for bringing this to our attention). The
proposed allowable use of bio-ethanol is welcome, but does not substitute for the elimination of other solvents.

We can clearly see that attempts by these certifying organisations to redefine natural cosmetics, and natural cosmetic/aromatic ingredients clearly bow to the business interests of the major international cosmetic companies and their customers, who are the potential cash-cows that these organisations are trying to milk. The multinational’s interests in the natural personal care sector has been plain enough for all to see – L’Oréal bought out The Body Shop, Estée Lauder did the same with Aveda & Clarins took over Kibio, just to mention three. That doesn’t mean to say that those of us working with natural products now have to dance to a tune played by the big corporates, or the organisations that suck up to them. We feel that many of the above-cited proposals & guidelines will be rejected by those purists who have been involved with natural perfumery to its
present point. You probably do not need Cropwatch to tell you that many experienced older perfumers have been found surplus to requirements lately by some of the Aroma Giants, probably because they are too expensive compared with younger perfumers. Many of these more experienced professionals are now working independently, making a living by creating natural perfumes. It is
unlikely, we feel, that this group will accept many of the definitions currently proposed by these Natural & Organic Cosmetic Certifying Organisations, and hopefully this group will become a growing influence in this area, for better values, independent of big industry’s requirements.

The Oakmoss/Treemoss article updates an article in this blog several months ago and announces that a detailed review of the lichens is planned for publication in Flavour and Fragrance Journal by mid-February 2009.

The GM Fragrance article discusses the progress? made in the floral products industry to increase the fragrance of flowers through GMO manipulation and the possibility that this will be a back door entry into the aromatics industry in spite of public opposition (especially in the EU) to Genetic Modification. The article contains several references and additional reading.

Brief comments on the IFRA workshop on Allergy Prevalence in Fragrance suggest a possible out for IFRA on the current over-regulation of the European cosmetics industry with a report that

sensitization to fragrance ingredients has decreased considerably over the years, and for some weak allergens, the rate of incidence is now so low that several thousands of subjects now need to be tested
to obtain one genuinely positive result.

The Ylang Ylang article is an update and correction to comments made in the previous Cropwatch Newsletter (Sept 2008) having to do with coniferyl benzoate in (or not in) ylang-ylang oil. Tony goes on to clarify the current status of the Ylang market.

All in all, a useful and interesting issue. Recommended reading for a variety of topics and interests.

Posted by Rob on January 26, 2009 in Ecological/Cultural Sustainability, Essential Oils/Plant Extractions, Oil Crops, Perfumery, Safety/Toxicity, Standards, Weblogs | Permalink | Comments (0) | TrackBack

August 28, 2008

Why American Readers should read the previous post!

I realize that the previous post is very long and may appear to apply only to Europe, but it is also important to Americans for several reasons:

  • American companies who have signed up for the safe cosmetics compact have agreed to follow the European regulations.
  • Tony suggests that oakmoss could be considered to not be a "natural" product per the standards that are under development in the US.
  • The proposals for the FDA to increase its regulation of cosmetics will probably, if adopted, bring increasing scrutiny to the use of these products in the US.

So read at least the Executive Summary, and if you can go further down and read the details.

Posted by Rob on August 28, 2008 in Essential Oils/Plant Extractions, Perfumery, Regulatory Issues, Standards | Permalink | Comments (1) | TrackBack

Sale / use of fragrant lichen commodities to become virtually illegal in Europe?

From the forthcoming Cropwatch Newsletter & by the Cropwatch Team (with considerable help from those who have to remain anonymous).

Aug 2008

Executive summary

SCCP Opinion SCCP/1131/07 ‘Opinion on Oakmoss/Treemoss’ adopted at the 15th Plenary Meeting on 15th April 2008 limits the potent sensitisers atranol & chloroatranol to 2ppm in oakmoss & treemoss (and cedarmoss) products. These SCCP proposal limits are currently unachievable by industry, reported elsewhere as being the result of a mistaken manufacturers claim. Further, they contrast with a forthcoming IFRA Purity Standard (shortly to be introduced under the 43rd IFRA Amendment) which proposes an achievable limit of 100ppm for atranol & chloroatranol respectively. The SCCP proposal drives a stake right through the heart of perfumery art, heritage & culture, since fragrant moss (lichen) extracts are the cornerstones of both the chypre & fougère accords, so important throughout the history of perfumery. It remains to be seen whether this SCCP Opinion will be transformed into an EC edict, and therefore whether fragrant moss products have any future in Europe. Once again, the SCCP, with its impractical Opinions, is in danger of putting European aroma companies at a disadvantage in the global marketplace, unless the Commissioner can be persuaded otherwise.

Some contentious regulatory issues, 2008

Many contentious regulatory issues concerning Health & Safety in the EU remain unresolved, causing reactions amongst professionals which range between skepticism to deep despair. Many European citizens reading this Newsletter will have been spending the past 2-3 months battling with EU’s REACH pre-registration obligations, in order that your aroma company remains in business after 1st Dec 2008. No doubt you will have been attempting to use the user un-friendly software for multiple ingredient registrations, which many have found does not work properly and is difficult or impossible for most companies to network. Meanwhile a proposed act of cultural vandalism against the high art, history & culture of fine fragrance, via some regulatory measures which will ban citrus oil usage in cosmetics, is still hanging over the trade in the form of the phototoxic furanocoumarin issue. We can only assume any potential developments on this issue are temporarily held in abeyance whilst Brussels staff holiday-away the summer months. Ironically, recent studies have identified a number of photo-carcinogenic risks associated with several relatively common (non-aromatic) cosmetic ingredients,; & it will be interesting to see if these findings are quietly ignored by the Commission in favour of continuing to pursue the existing vendetta against natural aromatic products. A similar situation of unfair ingredient hounding applies to the ubiquitous monoterpene constituent and major component of citrus oils, limonene, allegedly a danger to the environment, and therefore classified as an R50/53 material (& also as an R38 irritant & R43 sensitiser). Certain of the more technically adept amongst the regulatory clerks who have been working on limonene’s predicament have appealed to Cropwatch for help to overcome the enveloping regulatory madness surrounding this material, whereby a set of archaic chemical tests (which bear no relation to limonene’s eventual environmental fate) are used to determine its environmental risk classification. Limonene-containing citrus oils have traditionally been used in many types of perfumes (for example, air fresheners, wicks & gels) for their diffusion, lift & character, but perfumers find it difficult or impossible to use them at useful levels because of obligatory R50/53 labeling (who’s labeling incidentally depicts a dead tree, although we challenge anyone to identify any tree killed by limonene). The same situation arguably also extends to pine oils and many other naturals. There is also a knock-on effect with the various eco-labeling systems - which are supposed to represent a form of environmental performance labeling. - since to qualify, fragrances would have to be completely free of ingredients with a R50/53 or R51/53 ’s risk classification. This results in a situation where a good proportion of individual natural ingredients are unable to be used, so that many eco-labeled perfumes are in fact 100% synthetic – possibly the opposite to what customers would expect from this form of labeling..

Meanwhile, we natural ingredient users have another piece of toxicological scare-mongering looming up at us, which is making some parts of the aroma producing industry very, very annoyed, whilst the professional perfumers amongst us wring our hands. This time the ‘anti-fragrance brigade’ is trying to completely strangle the use of fragrant lichen products in cosmetics, via a misconceived 2008 SCCP Opinion.

Oakmoss: importance in perfumery.

Oakmoss products have a solidly established place in perfumery, being the cornerstone of two renowned accords; the chypre and the fougère. In the classical chypre accord, oakmoss is blended with patchouli, labdanum and other woody animalic and ambery notes, and also often with bergamot. These combinations are the foundation of a family of several leading fine fragrances: Chypre (Coty 1917), Mitsouko (Guerlain 1919), Miss Dior (Christian Dior 1919), Ysatis (Givenchy 1984) & in the male category Aramis (Aramis 1965) & Macassar (Rochas 1980) to name but a few. In the fougère accord, striking examples of which include Fougère Royal (Houbigant 1882), Drakkar Noir (Guy Laroche 1982), and Jazz (Yves St. Laurent 1998), oakmoss is blended with coumarin, lavandaceous notes and often with salicylates. Oakmoss products also find uses in colognes, pine fragrances, Crepe de Chine, oriental and fantasy bases etc. etc. (Burfield 2000).

The importance of oakmoss in our perfumery heritage cannot be understated - indeed what are we left with if fragrant moss products are taken away (as nitro-musks and oakmoss have been, in Guerlain’s controversially reformulated Mitsouko fragrance, now a shadow of its former self). Well, we are left with a few synthetic oakmoss chemicals, such as Evernyl (methyl 2-4-dihydroxy-3-6-dimethylbenzoate) and formerly, the less popularly-utilised Orcinyl-3 (3-methoxy-5-methylphenol), which the hype from synthetic aroma chemical producers would try to persuade you ‘represent the essential character compound of oakmoss’. But, as any practicing perfumer will tell you, there is no way that any single oakmoss synthetic can offer the richness, full body and presence of authentic oakmoss commodities in use, nor approach their superior fixative properties, nor can they duplicate approach the way that oakmoss can radiate and resonate through the entire body of a fragrance. It should also be mentioned that a range of commercial oakmoss products exists, some offering a warm, leathery-mossy character, whilst others offer have woody, mossy - almost marine-like aspects. When materials like oakmoss extracts are restricted by the existing culture of toxicological imperialism on dubious safety grounds (and this applies also to other vital perfume ingredients such as coumarin and citrus oils - see elsewhere), the ‘art of the possible’ in perfumery’ dies back even further, with a result that fragrance companies, instead of vigorously opposing regulatory change, end-up producing cheap, conformist and essentially poor-quality perfumes with little consumer re-purchase potential, for a increasingly non-discerning market slot.

It is also important to remember, as Joulain (2002) pointed out, that many in the US did not distinguish botanically between the lichen sources of oakmoss (Evernia prunastri (L.) Arch), and the source for treemoss & cedarwood (Pseudevernia furfuracea (Fr.). This may account for the confusion on various perfume blog sites which have discussed the exact identity of the listed fragrant lichen ingredients employed in a number of classic fragrances, although, to be fair, it should also be remembered that previously oakmoss extracts have invariably been extended with synthetics, and mixed in with treemoss extracts either intentionally, or unintentionally when harvested together..

cedarmoss growing on Cedrus atlantica

Cedarmoss growing on Cedrus atlantica in High Atlas, Morocco.

Picture: T. Burfield

Oakmoss products have been identified amongst the most frequent fragrance contact sensitizers (Schnuch et al. 2007), although the exact chemical identity of the major allergens has been elusive. Gonçalo (1988) for example, considered that that the major sensitisers in oakmoss included atranorin, followed by usnic, evernic and fumarprotocetraric

atranorin structure evernic acid structure

atranol structure chloroatranol structure usnic acid structure

acids, but Bernard et al. (2003) note that sensitivity to oakmoss has been associated with components which hold the phenylbenzoate molecular fragment in common, including atranorin & evernic acid. In particular, Bernard et al. identified atranol & chloroatranol as strong elicitants in most patients sensitized to oakmoss, and that the oakmoss character compound methyl b-orcinol carboxylate (Evernyl) is also capable of eliciting a reaction in most patients.

How widespread is our exposure to atranorin and other lichen sensitizers? Atraric acid, produced by the hydrolysis of atranorin, has been found in low concentrations of the heartwood from oak species Quercus robur & Quercus petraea used for staves in the production of oak barrels used for storage of wine & sprits (Bourgeois et al. 1999). It is likely that colonizing species such as Parmelia olivetorum and/or P. perlata produce depsides in the wood leading to atranorin accumulation.

It is also worth mentioning, as many of the more traveled amongst you will know, that according to some estimations, up to 1,000 tons/year of Parmelia nepalensis (Taylor) Hale ex Sipman is processed into lichen oil, absolute or extract in Western Nepal, and exported for global perfumery and incense use (although the lichens are also used in traditional systems of medicine). Other species such as Parmelia tinctorum Delise ex Nyl. & Usnea spp. may be co-gathered at the point of harvesting. Moxham (1986) notes the use of Parmelia nepalensis, P. nilgherrensis, Ramalina subcomplanata & Usnea lucea in India. Kumar & Muller (1999) have identified the depsides atranorin & diffractaic acid in Parmelia nepalensis & Parmelia tinctorum extracts. (N.B. note that Parmelia furfuracea is a synonym for Pseudervenia furfuracea).

A brief regulatory history of fragrant lichen products

1. An IFRA Standard was introduced for oakmoss extracts in April 1991; the updated IFRA Standard (2001) limits oakmoss extracts to 0.1.% concentration for finished cosmetic products either left on or washed off the skin, but if oakmoss products are also present in the preparation, the combination of both must not exceed 0.1%. As the presence of resin acids seem to be unavoidable in oakmoss products, IFRA `also imposes an interim limit of 0.1%`dehydroabietic acid for oakmoss extracts.

[The forthcoming 43rd IFRA Amendment (2008) will introduce a QRA-based system of concentration limits for oakmoss extracts across 33 different fragrance product categories. Purity criteria for oakmoss products are also introduced in the 43rd IFRA Amendment in the form of limitations on the concentrations of the strong sensitizers, atranol & chloroatranol to 100ppm each].

2. The existing IFRA Standard (1991, 2001) limits treemoss extracts to 0.1.% concentration for finished cosmetic products either left on or washed off the skin, but if oakmoss products are also present in the preparation, the combination of both must not exceed 0.1%. The IFRA Standard limits dehydroabietic acid (DHA) to 0.8% in treemoss extracts as a marker of 2% of total resin acids, determined by a routine analytical method using HPLC Reverse Phase -Spectrofluorimetry method apparently available from IFRA, according to their website.

[The forthcoming 43rd IFRA Amendment (2008) will introduce a QRA-based system of concentration limits for treemoss extracts across 33 different fragranced product categories].

3. Under the 5th EC Framework Program. the EC launched a Quality of Life Initiative & Management of Living Resources key action (1999) which included a study of “Fragrance chemical allergy: a major environmental and consumer health problem in Europe Contract No: QLK4-CT-1999-01558 (copy available from Cropwatch in case of difficulty locating it). This project led by J..P Leppoittevin employed a number of leading institutions & scientists in the field, including I.R. White (chairman of SCCP) & S.C. Rastogi (member of SCCP). This project completed in March 2003 at total cost of cost of 1, 927,280 Euros; the major part found by the EU. The project included the development and validation of a method for the identification of sensitisers in complex mixtures using the model of oak moss.

4 The SCC(NF)P at its 14th plenary meeting (24 October 2000) accepted an Opinion (SCCNFP/0421/00) concerning Oakmoss/Treemoss, that "… oakmoss/treemoss extracts, present in cosmetic products, have a well-recognised potential to cause allergic reactions in the consumer as fragrance ingredients…" The Opinion can be seen in full at http://ec.europa.eu/health/ph_risk/committees/sccp/docshtml/sccp_out124_en.htm

5. A scientific paper identifying atranol & chloroatranol as strong elicitants in most patients sensitized to oakmoss was released by Bernard et al. (2003). Methyl b-orcinol carboxylate (= Evernyl or methyl atrarate), a

methyl 2,4-dihydoxy-3,6-dimethylbenzoate image

principle odourant of oakmoss absolute, was also identified as an elicitant in most oakmoss sensitized patients. One of the paper’s authors (S.C. Rastogi) is an SCCP committee member.

6. A scientific paper by Bossi et al. (2003) describes the analysis of atranols in perfumes, employing LC-MS-MS with electrospray ionization (ESI) in negative mode One of the authors (S.C. Rastogi) is an SCCP committee member.

7. A scientific paper Rastogi et al. (2004) describing the analysis of 31 commercial perfume found that half the perfumes, & some eau de toilettes contained significant amounts of atranol & chloroatranol.. The author, S.C. Rastogi, is an SCCP committee member).

8. Filho et al (2004) comment that the present volume of lichen extraction is (ecologically) irreversible given the slow growth of lichen.

9. The SCCP at its 2nd plenary meeting (7 December 2004) accepted an Opinion (SCCP/0847/04) on atranol and chloroatranol present in natural extracts (e.g. oakmoss and treemoss extracts) with the conclusion: “…Chloroatranol was shown to cause elicitation of reactions by repeated open exposure at the ppm level (0.0005%) and at the ppb level on patch testing (50% elicit at 0.000015%.). As chloroatranol and atranol are such potent allergens (and chloroatranol particularly so), they should not be present in cosmetic products." Cropwatch comments: We understand that the robustness of certain parts of the scientific evidence in this Opinion is being queried...

S.C. Rastogi & I.R. White were listed as member & chairman respectively of the above SCCP committee.

10. SCCP Opinion SCCP1131/07 (15th April 2008) describes an achievable reduction of atranol & chloroatranol in oakmoss extracts to <2ppm according to an analysis method (which is not disclosed), by two different preparative methods (details of which are not disclosed either). S.C. Rastogi and I.R. White were listed as member & chairman respectively of the SCCP committee. .Cropwatch comments: Data from LLNA tests is set out in the Opinion which did not show that reduction of atranol & chloroatranol contents in treated (but un-analysed) lichen extracts (of unknown purity) affected the LLNA results. Not withstanding this setback which the SCCP puts down to interlaboratory variation (!), the Opinion calls for a 2ppm limit for atranol & chloratranol in fragrant lichen products which would represent a level 50 times lower than the proposed IFRA Standard in its forthcoming 43rd Amendment. Evidence showing that treemoss & cedarmoss extracts deserve to be treated in a similar manner to oakmoss extracts is lacking, and Joulain (2002) has previously argued that the principal sensitisation risks in treemoss absolute prepared as described in his presentation, may centre around 7-oxo-dehydroabietic acid (from oxidized pine resin), rather than the atranols. The SCCP’s acceptance of claims for achievable atranol & chloroatranol concentrations of <2ppm in treated lichen extracts, via unidentified process(es) from an unidentified source, is typical of the secrecy which pervades the working of Brussels’ committees, and we believe contravenes the existing EU guidelines for transparency. Further, contrary information on this matter has been widely circulated in the trade (e.g. in a perfumery professional members communiqué seen by Cropwatch), which alludes to a mistaken claim made by an unidentified company who directly or indirectly have submitted data to the SCCP. This data, we are lead to believe, initially indicated that the 2ppm limit for atranol & chloratranol was achievable. The company involved however, was reported to have later withdrawn the claim when it realised that this experimental research result was not reproducible in a commercial production scenario. Who knows where the truth in this matter lies, but because of the lack of Brussels transparency, Cropwatch can only assume that the SCCP had already seized upon the 2ppm level finding, and, over-hasty as ever, have wrongly adopted the 2ppm limiting level for each sensitizer in the SCCP/1131/07 ‘Opinion on Oakmoss/Treemoss adopted at the 15th Plenary Meeting on 15th April 2008). If Cropwatch has misunderstood any of the above facts, we can point to the fact that much of the aroma trade has as well. As it is, the situation appears to be a complete shambles.

The Commission is of course not obliged to act on an SCCP Opinion, but as close followers of Brussels affairs will know, finding reverse gear in these situations has proven to be an unlearnt skill, and although they make enough mistakes, we have yet to see the SCCP ‘experts’ actually own up to an error. As it is, the result may end up in the effective banning of fragrant moss usage in European cosmetics, unless industry lobbyists can persuade the Commissioner otherwise. .

Further background

Interestingly, the scientific literature is pretty scanty on the details of fragrant lichen processing & chemistry, and for this reason Cropwatch has started a fragrant lichen bibliography, in the Cropwatch Files section of its website at http://www.cropwatch.org/oakmossbib.htm. This file will be continually updated - contributions, suggestions, & corrections should be directed please to info@cropwatch.org

Oakmoss absolute (Mousse de chêne), concrete, resinoid etc. are derived from the lichen Evernia prunastri (L.) Arch. (Fam. Usneaceae) which grows mainly on the bark of oak trees, but also to some extent on spruces & pine trees. Nine thousand tons of oakmoss lichen is gathered annually in S. Europe, in France (formerly in the forests around Fontainebleau), as well from Calabria, Bohemia, Morocco, Algeria, and the area of former Yugoslavia & Bulgaria (Burfield 2000); however this figure may be overstated – Joulain (2002) mentions a figure of 3,000 tons, and Huneck (2001) reported that for the year 1997, 1900 tons of Pseudevernia furfuracea and 700 tons of Evernia prunastri were processed at Grasse...Some harvested E. prunastri lichen has been co-gathered with the lichen Pseudevernia furfuracea throughout Europe, but other accounts relate that Striata pulmonacea, Usnea ceratina, Ramalia farinacea, Ramalia fraxinae, Ramalia pollinaria and some Alectoria and Parmelia species are also mixed in from batch to batch (Burfield 2000). Chinese oakmoss, similar in quality to European oakmoss, is reportedly produced from Evernia mesomorpha, and is also commercially available.

Oakmoss preparation. Oakmoss lichen is not fragrant of itself, and it is only the solvent processing operation which generates the fragrant artifacts which give oakmoss its perfumery value. Ironically then, it cannot be classified as a ‘natural product’ according to the many bodies now attempting a definition of this term for the cosmetics trade, as recently reported on the Aromaconnection website.

Preparation of oakmoss concrete is via solvent hydrocarbon extraction (formerly benzene, but nowadays more often cyclohexane, or hexanes, although acetone and other solvents has been used). of the dried, or freshly wetted dried lichen. Resinoids have been obtained historically by hot solvent extraction, and fragrance synthetics have invariably been added in. Formerly, benzene extracted resinoids had found popular use in soap perfumery. Absolutes can be made directly from the concrete, or by refluxing benzene or hexane extracts with alcohol, and hot filtering out the insoluble material - removal of the alcohol give the absolute in 30-60% yield. Diluting the alcohol extract down to 80% and filtering may give a more soluble product with fewer residues, but further ethanol treatment may give a turbid extract, which when mixed with a saturated salt solution and solvent extracted (benzene was formerly used) further amounts of useful product can be obtained. The identity of the alcohol used will determine the odour - methanol gives sweeter smelling esters, and ethanol produces a sharper smelling product.

Oakmoss incolore and molecular distilled grades of oakmoss are also commercially available. Worryingly, Pybus & Sell (1999) state “with some particularly viscous concretes such as those from oakmoss or treemoss, it is more usual to dissolve the concrete in a high boiling solvent, such as bis-2-ethylhexyl phthalate, and then co-distil the product with the solvent.” Hopefully, with current public disquiet over the potential toxicity of phthalates, this practice has been discontinued.

Oakmoss chemistry. As a preface to this section, it may be pertinent to recall Joulain’s (2002) remarks to the effect that although the literature reveals qualitative information about oakmoss composition, there is little quantitative data. The fragrant compounds in oakmoss are generated by the degradative action of the solvents on the naturally occurring depsides in the moss (depsides are phenolics composed by two or three monocyclic units linked by an ester bond and derived from orsellinic acid), generating (volatile) odourous monoaryl substances. The character impact compounds of oakmoss are considered to include methyl b-orcinol carboxylate (methyl atrarate, Evernyl)) which imparts a powdery-mossy note, the monomethyl ether of b-orcellinic acid, methyl & ethyl everniate, and the phenolic compounds orcinol and b-orcinol. Boelens (1997) tabled the various yields from different solvent process (extraction and transesterification of the depsides) for both oakmoss and treemoss, reporting that the odour of oakmoss was preferred to treemoss by an odour panel of expert perfumers. Methyl b-orcinol carboxylate was the chief component of both oakmoss absolute and treemoss absolute products (47% and 57% respectively). The quantities of 3-chloro-2,6-dihydroxy-4-methylbenzoate (Cropwatch comments: this is possibly a misprint in the original article – surely it should have been 3-chloro-2,6-dihydroxy-4-methylbenzaldehyde, or chloroatranol - 10%), 2,6-dihydroxy-4-methlbenzaldehyde (- atranol - 5% and 6% respectively) and methyl 2,4-dihydroxybenzoate (0.5% and 0.7%) were similar. Oakmoss absolute was found to contain had twice as much cembrene (2%) as treemoss absolute. A full account of the work and composition of the benzene extract and benzene/methylanol transesterification products of oakmoss can be found in an earlier paper by Boelens (1993).

Treemoss (Mousse d’arbre) Treemoss derivatives (concretes, absolutes) are mainly prepared from the lichen species Pseudevernia furfuracea (L.) Zopf. with Usnea barbata, Parmelia sulcata and other species often co-gathered in. These tree lichens can both be found living on the barks of firs and pines in Southern and Central Europe including and France and Morocco, & Balkan countries, including former Yugoslavia. Preparation of fragrant treemoss products is carried out in a similar manner to the preparation of oakmoss products, although evidence that isopropanol may be included as a processing solvent is shown by the presence of isopropyl haematommate (which does not exist in lichens) in the analysis of the weakly acidic factions of treemoss absolute (Endo et al. 1999). It should be noted that Treemoss products are generally considered inferior to oakmoss products and command a lower purchasing price.

Tabacchi (1983) acknowledged that pine products are co-gathered with treemoss, and this has caused the sensitising properties of treemoss extracts to be mis-interpreted by toxicologists at that time. More specifically, Joulain (2002) describes work confirming previous observations by Tabacchi that biosynthesized diterpenoid acids from Pinus sylvestris hosts migrate into the oakmoss lichen and assist in their oxidation. The author cites a patented process for producing a treemoss absolute with a low resin acids content but still containing high levels of atranol (0.31%) and chloroatranol (0.15%), which produced no adverse effects at 3% in a suitable solvent in a HRIPT test carried out according to the Marzulli-Maibach protocol with 158 volunteers. Joulain suggested this supported the hypopthesis that 7-oxo-dehydroabietic acid is one of the main sensitizers in treemoss extracts, and that whereas 4-10% of atranorin & chloroatranorin may be present in many treemoss concretes, during the production of absolutes, alcoholysis of the depsides in hot ethanol reduces their content to a level such that they are undetectable by HPLC.

Cedarmoss qualities are derived from Pseudevernia furfuracea Ach. growing on the Atlas cedarwood tree Cedrus atlantica, found mainly in the Atlas Mountains of Morocco. Solvent extraction produces the resinoid (cyclohexane is used as solvent by some manufacturers), followed by distillation to produce an ‘absolute’ although other methods for obtaining the absolute are used. Often sweeter than corresponding oakmoss products, it is used in similar perfumery applications.

IFRA Standards for cedarmoss extracts apply exactly as for treemoss extracts, the logic being that they both originate from Pseudevernia furfuracea (Fr.). Because it may not be collected exclusively on cedar trees, cedarmoss invariably contains pine twigs and wood fragments which affect the properties & odour of the ingredient.


Bernard G., Giménez-Arnau E., Rastogi S.C., Heydorn S., Johansen J.D., Menné T., Goossens A., Andersen K., Lepoittevin J.P. (2003) "Contact allergy to oak moss: search for sensitizing molecules using combined bioassay-guided chemical fractionation, GC-MS, and structure-activity relationship analysis." Archives of dermatological research 295(6), 229-235

Boelens M. (1997): “Production, chemistry and sensory properties of natural isolates” in Flavours and Fragrances ed Kjarl A.D. Swift publ. Royal Society of Chemistry Publications 1997.

Boelens M. (1993) “Formation of volatile componds from oakmoss” Perf & Flav 18(1) 27-30.

Bourgeois G., Suire C., Vivas N. & Vitry C. (1999) "Atraric acid, a marker for epiphytic lichens in the wood used in cooperage: Identification and quantification by GC/MS/(MS)." Analusis 27, 281-283.

Bossi R., Rastogi S.C., Guillaume B., Gimenez-Arnau E., Johansen J.D., Lepoittevin J.-P., Menne T. (2003) "A liquid chromatography-mass spectrometric method for the determination of oak moss allergens atranol and chloroatranol in perfumes." Journal of Separation Science 27(7-8), 537-540. .


Burfield T. (2000) Natural aromatic materials – origins & odours. Publ. AIA, Tampa 2000.

Endo H., Andatsu M. & Ishihara M. “Chemical components of treemoss absolute”, (1999).” 43rd TEAC Oita Japan.

Filho L.X., Pereira E.C., Vicente C., & Legaz M.-E. (2004) "Synthesis of methyl-3-orsellinate by organic synthesis or by altered biosynthetic pathways using lichen immobilisates." ARKIVOC 2004 (vi) 5-11.

Gonçalo S. (1988) “Contact sensitivity to oakmoss” Contact Dermatitis 19, 355-7.

Huneck S (2001).. Progr. Chem. Org. Nat. Prod. 81, 1.

Joulain D. & Guillamon N. (2002) "Pseudevernia furfuracea ("treemoss") resinoid in fragrance compounding: Analytical issues." Presented at 46th TEAC Symposium Tokushima, Japan (2002).

Joulain D. (2002) “Stable Isotopes for determining the origin of flavour & fragrance components: recent findings.” In: Advances in flavours & fragrances from the sensation to the synthesis.ed. Karl A.D. Swift publ. Royal Soc. Chem 2002. Section 5 is: “The case of a natural raw material for fragrances: lichen resinoids.”

Joulain D., Guillamon N., Casazza A. & Tabacchi R. (2005) “New insight in the knowledge of the qualitative and quantitative composition of oakmoss resinoids.” 36th International Symposium on Essential Oils, 4-7 September, Budapest, Hungary.

Kumar S.K.. & Muller K. (1999) “Lichen metabolites. 1. Inhibitory action against leukotriene B4 biosynthesis by a non-redox mechanism.” Journal of Natural Products 62(6), 817-820.

Moxham T.H. (1986) “The commercial exploitation of lichens for the perfume industry.” In Progress in Essential Oil Research Walter de Gruyter Berlin – NY (1986).

Pybus D. & Sell C. (1999) The chemistry of fragrances. Pub Royal Soc. Chemistry (GB) p37:

Rastogi S.C., Bossi R., Johansen J.D., Menné T., Bernard G., Giménez-Arnau E., Lepoittevin J.P.. (2004) "Content of oak moss allergens atranol and chloroatranol in perfumes and similar products." Contact Dermatitis 50(6):367-70

Schnuch A., Uter W., Geier J, Lessmann H. & Frosch PJ. (2007) "Sensitization to 26 fragrances to be labelled according to current European regulation. Results of the IVDK and review of the literature." Contact Dermatitis 57(1), 1-10.

Tabacchi J. (1983) “Contributions to the knowledge of chemical composition of tree moss Pseudoervinia furfuranaceae L. Zopf.” Proceedings of 9th International Congress of Essential Oils Singapore 65-68. (1983).

Posted by Tony Burfield on August 28, 2008 in Essential Oils/Plant Extractions, Perfumery, Regulatory Issues, Safety/Toxicity, Standards | Permalink | Comments (1) | TrackBack

July 15, 2008

The Natural discussion continues

The Society of Cosmetic Chemists has weighed in on the question of "natural" at its annual scientific seminar last month in Orlando, according to a recent Happi article entitled "It's Not Natural..." The article discusses both natural and organic definitions, most of which we have mentioned here in previous posts.

Speakers at the conference pointed out that there are six major organizations trying to define natural, which is not exactly true; five them are working on organic standards and only one (NPA) has even dealt with the term "natural" in their standard. The NIRC and the IANPP weren't even mentioned, but they aren't major organizations so I supposed they don't count.

Issues other than standards, but related to natural/organic manufacturing including green chemistry and sustainable packaging.  There was a review of regulatory issues, pointing out that there is no general consensus on the meaning of "natural" and that because the FDA has no definition, it may be up to the Feceral Trade Commission (FTC) might resolve the issue based on whether claims made are "clear and definitive".

What is clear at present is that the whole discussion of natural is not definitive, as pointed out at the seminar, and as pointed out on this blog.

Posted by Rob on July 15, 2008 in Regulatory Issues, Standards | Permalink | Comments (0) | TrackBack

July 11, 2008

FDA enters debate on Natural

We've blogged before on the meaning of "natural" when applied to skin and body products, discussing in particular the definitions put forth by the Natural Products Association (NPA) and the Natural Ingredients Resource Center (NIRC).  Now the FDA (Food and Drug Administration) has reversed itself in a ruling on high fructose corn syrup (HFCS) and ruled that it can be considered "natural" under certain manufacturing processes, according to an article in FoodNavigator-USA, a food industry publication. The ruling came in a letter from the FDA to the Corn Refiner's Association (CRA).

It appears that the ruling is based on technicality having to do with the production process for HFCS. Even though the process uses a synthetic fixing agent, it supposedly doesn't come into contact with the HFCS, so that it is acceptable as "natural".  As the article points out, however, the Sugar industry as well as other consumer groups argue that HFCS isn't natural because

its chemical bonds are broken and rearranged in the manufacturing process.

What this really points out is that there isn't yet a good standard definition for what is "Natural".  According to the FDA letter, it makes decisions on a case-by-case basis.

A search of the FDA website reveals this interesting statement:

The term "natural" has not been defined in FDA's law (the Federal Food, Drug, and Cosmetic Act) or in FDA's regulations.

A review of the Google Results for "FDA natural" reveals a number of recent "natural" issues with the FDA, including in addition to HFCS the issues of Stevia, various "natural" cures for cancer and other diseases, some paranoia about health freedom, and the discussion of whether they will define "natural." This blog post from April 2008 is a good discussion of some of the issues, although it is now outdated by the new FDA ruling.

According to SourceWatch, a website that tracks "the names behind the news" the CRA has spent $20-30 million on a public relations and advertising campaign in support of HFCS.

The FDA now seems to have thrown in its lot with the CRA.  I'm sure we haven't heard the last of it.

Posted by Rob on July 11, 2008 in Regulatory Issues, Standards | Permalink | Comments (0) | TrackBack

June 29, 2008

Pine Oil Tick and Mosquito Repellent

In one of those strange serendipitous moments that can happen with Google Alerts, I visited an article entitled "Tick and Mosquito Repellent Can Be Made Commercially from Pine Oil" which describes "a naturally-occurring compound prepared from pine oil" that deters mosquito biting and repels ticks.

After I read the press release, which contains the curious statement

Some segments of the public perceive efficient synthetic active ingredients as somehow more dangerous than botanical compounds, giving additional importance to the discovery of plant-based isolongifolenone.

my interest was piqued , so I read the patent which has been issued covering the preparation of the compound and "its use in repelling arthropods". Would this product meet the requirements of the NPA Natural Products standard? Would it meet the requirements of the NIRC definition of "Natural"? It's been over 40 years since I had my last chemistry course, but I think I can figure this out.

Reading through the patent, some interesting facts are revealed. Deet has long been considered the standard for mosquito repellency,

However, Deet is a plasticizer and clinical literature reports the association of Deet with neurotoxicity in humans (Robbins, P. J., and M. G. Cherniack. J. Toxicol. Environ. Health, 18: 503-525 (1986)). Thus, there is a great need for effective alternatives to Deet.

Essentially the process of producing takes isolongifolene, which is a naturally occurring component of Pinus longifolia, and converts it to isolongifolenone, which is also naturally occurring in smaller quantities. This is done via oxidation with tert-butyl hydroperoxide in the presence of a catalyst chromium hexacarbonyl. The process has a high yield but may not meet the natural standard because benzene is used to recover the catalyst (which itself is a considered toxic).

According to Wikipedia

In common with many of the other homoleptic metal carbonyls (e.g. nickel carbonyl and iron carbonyl), chromium hexacarbonyl is toxic and thought to be carcinogenic.

Tert-butyl hydroperoxide doesn't have its own entry in Wikipedia, but a search of the ToxSeek database reveals 143 entries.  Without detailed analysis, one can only conclude that it is a toxic hazard.

The NPA Natural Standard

To see what this means, let's look at the definition of natural in the NPA Standard:

Ingredients that come or are made from a renewable resource found in nature (Flora, Fauna, Mineral), with absolutely no petroleum compounds.

OK, that may work, except for the Tert-butyl hydroperoxide, benzene and the chromium hexacarbonyl.  A check of the NPA Standard's list of prohibited ingredients doesn't have any of those on it, except for the prohibition on petroleum.  We can only conclude from this standard that the isolongifolenone would only be natural if all the traces of either the catalyst or the chemical used to remove it are completely removed.

A look at the processes allowed or disallowed in the NPA Standard reveals that this process is not on either list.  Not surprising, considering that it wasn't known when the standard was written.

NIRC Definition of Natural

The NIRC definition of Natural requires a natural material to be "present in or produced by nature, produced using minimal physical processing, and directly extracted using simple methods, simple chemical reactions or resulting from naturally occurring biological processes."  Based on this part of the definition, our product would seem to pass.  However, the NIRC definition goes on to require that "Natural Ingredients are . . . not produced synthetically, free of all petrochemicals, not extracted or processed using petrochemicals, [and] not extracted or processed using anything other than natural ingredients as solvents."

So it looks like it won't meet this requirement either, even worse than the NPA definition, because of the petrochemical ban and the non-natural catalyst and solvent situation. Even if you could get all traces of the chemicals removed from the isolongifolenone, the processing is not natural.


Based on this analysis, the repellent isolongifolenone cannot be considered a "natural" product under the definitions of either the NPA or the NIRC.

Related Information

While researching this subject, I came across a 2005 Indian study on the effectiveness of Pine Oil as an insect repellent. The pine oils used in the study was analyzed, but didn't reveal the presence of either of the two compounds involved in the patent (they were probably included in the 13% unidentified ingredients. The paper states that pine oil is used traditionally as a repellent in India.

Posted by Rob on June 29, 2008 in Essential Oils/Plant Extractions, Research, Safety/Toxicity, Standards | Permalink | Comments (0) | TrackBack