– on IFRA rules and new EU regulations

My original plan for a blog post was a perfume review. My backlog is not getting smaller, and I have all sorts of fragrant epiphanies dying for a touch of superheated prose. But life, as John Lennon once famously said, is what happens when you’re busy making other plans.

Then two things prodded me with a lance and set off my inner Doña Quixota.

The first was a post on a Facebook perfume group concerning the possibilities opened up by new, non-allergenic fragrances and fragrance technologies. I’ll be getting back to that one later.

The second was a blog post by Kafkaesque concerning the new EU regulations on cosmetics and – a pivotal point – perfumes that may take effect by January of next year.

As of today, a petition to protest these proposed regulations and restrictions has gathered over 3400 signatures to protest the upcoming regulations and been given to the EU, along with an alternative to the proposed restrictions and bans.

So you don’t have to slog through a massive amount of turgid, brain-numbing prose, I should say that so far as perfume is concerned, the following three issues are first and foremost at stake:

–       A complete ban on oakmoss, tree moss and HICC, also known as Lyral, an aromachemical used to emulate lily-of-the-valley

–       Deliberating restrictions on citral (for all citrus-based perfumes and anything containing bergamot, which is at least 90% of everything, coumarin/tonka bean and eugenol, present in rose absolutes, concretes and essential oils

–       Deliberating labels on perfumes listing the substances they contain

The EU has also been considering severely limiting over 200 natural essences, oils and absolutes, all of which are (literally) essential to the production of perfumery as we know it today, whether mainstream, prestige, niche or indie perfumery.

Speaking of which…

They have also considered limitations on the sale and distribution of indie perfumes whose manufacture is based elsewhere – for instance, indie perfume houses based outside the EU. A requirement has been suggested that in order to distribute and sell indie perfumery, an EU-based business address will be required by law, which might be the death knell of those wonderful indie perfumes that aren’t IFRA-compliant (which is voluntary to a degree), meaning they contain ‘contraband’ substances, or lucky enough to have EU distributors or retailers.

This is the funeral bell of all perfumery. Or is it?

The Background

<sarcasm>We EU citizens should consider ourselves lucky to live under the aegis of a government so concerned with our personal health and welfare. </sarcasm>

Consider the indisputable fact that many of the potentially restricted raw materials have a proven cultural heritage that dates back at least 5000 years. Yet I don’t see any demonstrators or political activists waving placards near the famous frankincense trees of Dhofar or the fabled roses of Kazaniak in Bulgaria.

All of these proposed regulations and restrictions have been suggested solely for the benefit of potential allergenic effects, potential effects that down the road could mean litigation for perfumers and perfume houses.

Enter the tabloid headline: DIOR SELLS DEATH JUICE – CALLS IT “PERFUME”.

I’m certainly not arguing that perfume allergies don’t exist, nor do I want to disrespect the plight of those unfortunate people who suffer from them – sometimes excruciatingly so. I find it appalling that even unscented body products are often scented to mask the stench of the ingredients they contain.

But here’s the punch line: People who suffer from perfume allergies don’t buy or wear perfume.

The fragrant tachyderm in the room is what no one is saying. Not the EU and their hordes of political lobbyists representing the more sinister aspects of international politics, not the IFRA, certainly not the roaring, screaming silence of the perfume industry as a whole and with the exception of a few brave souls, not even the blogosphere, where most of us like to pretend that all is well, grand and divinely scented business as usual.

Because allergies and potential allergenic compounds are not the issue at all.

The Agenda

More fragrant food for thought – the IFRA, the industry regulator and watchdog that enforces (voluntary) regulations meant to ensure the safety of consumers, is not an independent entity – it is financed by Givaudan, Symrise and US-based International Flavors and Fragrances, in other words, the very perfumery companies it is supposed to regulate.

Let that sink in for a moment.

No matter what the label on the perfume bottle might lead you to believe, many times a perfume – whether mainstream, prestige or niche – originates with one of these companies. We perfumistas often kid ourselves that perfumes are discontinued due to IFRA regulations, but it is just as often due not to restrictions or the cost-effectiveness of materials, but to expiring patents of perfume formulae owned not by, say, a LVMH company (who own an appalling number of mainstream designer lines), but by – you guessed it – Givaudan, Symrise, Mane or IFF.

It’s interesting that LVMH or even Chanel have been so silent lately in this recent outrage, considering how much they protested when these proposed regulations and restrictions were made public. Then again, the perfume industry’s notorious conspiracy of silence is a public fact…

The plot thickens further.

Say the bill is passed in all its hideous, heritage-murdering glory. Will we all be doomed to a future of horrific sugar-sweet bubblegum fruitchoulis containing nary a single metaphorical rose petal?

Maybe not, since the rise of synthetic aromachemicals in the twentieth century have revolutionized perfumes and often, these materials are entire perfumes in and of themselves. If so many natural absolutes and oils are severely restricted, then they would be substituted with synthetic and/or nature-identical aromachemicals. Meanwhile, no one really knows the long-term effects of using these synthetics.

Synthetics provided by Givaudan, Symrise, IFF. Who naturally – such being the supply and demand of market economics – stand to make an absolute killing, and not just of a cultural heritage. In other words, it’s not about potential allergies or allergenic reactions to known perfume components at all. It’s about the money, sadly, just like so much else in the world.

Hi-Tech Magic

I’ve said it before, and I’ll say it again: there is no such thing as a natural perfume, unless you place a fragrant flower behind your ear and call it a day. I will also say that so far as I am personally concerned, I have no particular bias one way or the other. I have natural – which is to say, containing no synthetics – perfumes in my cabinet that rival any stellar perfumes I could mention in complexity and depth.

Likewise, I’m well aware that many, if not most of the other fragrant wonders in my red IKEA cabinet of doom are known as ‘mixed-media’ perfumes, because synthetic aromachemicals can provide lift, body and longevity to truly make a perfume bloom. I’ve even encountered all-synthetic perfumes that have been interesting adventures on their own.

What really fascinates me are the technologies of headspace and fractionation, since they open up entirely new vocabularies for perfumers to work with.

Natural materials have an astonishingly complex olfactory profile. For instance, roses contain upwards of 10,000 different fragrant components, all of which give rose perfumes their spicy, earthy, fruity, fiery and musky profiles. Fractionation allows extraction of singular aspects of natural materials. If eugenol – one of the hotly contested components – is the issue, you can simply ‘weed’ it out of the rose. This has been one of the suggested remedies for banning oakmoss – simply remove the allergenic component, and voilà! Mitsouko is restored to all its former glory. (We can dream!)

Headspace technology is another new thrill for perfumers, since it allows for chemical analysis of aromachemical profiles from plants and flowers that are usually reconstructed, since they can’t be extracted from the plant. Gardenia and lily of the valley are two examples of using headspace technology for perfumery. This means that perfumers will still have a vast range of new materials to combine to infinity in any number of ways for new, exciting perfumes.

Having said that, any perfumer – or perfume aficionado – will tell you in no uncertain terms: there is no synthetic substitute no matter how well-made for the complexity, the richness and the depth of natural essences and absolutes. For all of them provide a perfume with its soul, its terroir, that one core component that elevates a fragrant concoction from simply smelling good (or bad!) to transcendental in a way no synthetics can.

Murder They Wrote

The cultural history of humankind has been scented since the dawn of civilization. Whether for reasons of devotion or seduction, trade routes sprang up to supply the temples of Egypt, Mesopotamia, India and China and history was made, agriculture bloomed to provide raw materials, statues of gods and goddesses were adorned with garlands of fragrant flowers, and perfumes and incenses were used to impart divinity and power. Indeed, in some cultures it is required to meet the divine appropriately perfumed, whether with the sandalwood paste of Hindu temples of India, or the oud blends so beloved in the Middle East.

Today, we consider Paris the epicenter of the perfumery world, but in fact, the olfactory heritage of France did not originate there but in Italy, when Catherine de Medici set out for France and her future husband with a band of Florentine perfumers in tow.

The court of Louis XIV was known as the Perfumed Court, and in those days before indoor plumbing and regular baths, everything aristocratic and prestigious was scented and perfumed; clothes, gloves (to mask the stench of tanned leather), wigs, letter paper, wallpaper, surroundings.

The demand for perfumery with all its associations of luxury led to an industry that gave us the jasmines and roses of Grasse, the lavenders of Provence and the storied, world-renowned perfumeries of Paris. Colonization gave perfumers other and more exotic materials to work with, such as tolu and Peru balsam, ylang ylang and agarwood.

It gave us Paul Parquet of Houbigant, Aimé, Jacques and Jean Paul Guerlain, Ernest Daltroff of Caron, François Coty, Germaine Cellier (one of my own personal favorite renegade perfumers), Edmond Roudnitska, Ernest Beaux. It gave the world a quintessential pride in a shared scented history, and an even greater pride in the artisanal craft and alchemy of its perfumers. On perfume bottles the words ‘in honor of my art’ were engraved in invisible, fragrant ink in essence and absolute.

Along the way, we also had Paul Poiret, Chanel, Schiaparelli, Robert Piguet, Dior, Yves Saint Laurent, all fashion designers and visionaries who were quick to realize that even if a customer could never afford haute couture, he or she could afford that essential stamp of luxury, style and Parisian èlan by association; through a perfume.

Each and every one of these companies and their countless imitators milked the fragrant heritage of Paris and Parisian chic, luxury and seduction for all it was worth, and ever since, the rest of the world has been buying right into it, even as we knew we’d never in a million years be as fabulous as Jerry Hall in an Opium perfume ad or Marilyn Monroe between her sheets dressed only in Chanel no. 5, we could at least feel that way for as long as a perfume breathed on our skins and defined us.

But some time in the mid-1990s, shark fins appeared over the fragrant horizon in the wake of ubiquitous calone and aquatic perfumes. Perfume aficionados, myself included, began to notice that our long-beloved liquid definitions were no longer quite what they were. Some were discontinued, some were reformulated, but one thing became increasingly clear – the world of perfume was changing, and not necessarily for the better. Multinational conglomerate companies such as LVMH ate up renowned brands such as Guerlain, Dior and Yves Saint Laurent, and then proceeded to brutally murder everything that made those perfumes special without even the common decency to give them a proper burial.

Yet even as the Naughties gave us the rise of the dreaded Angel clones, fruitchoulis and celebufumes, times were changing. With the advent of sites such as Makeupalley, fabulously scented nobodies ventured forth and began to review perfumes for a burgeoning audience eager to learn, and with perfume blogging – fortuitously timed with the rise of indie and niche perfumery in the public awareness – the fragrant landscape changed yet again, and the international perfume community wafted dangerously expensive temptations in its wake.

My own descent in the maelstrom can be pinpointed to the late summer of 2003 and a post on Makeupalley that told of the bottled emotions of a certain Serge Lutens. I let my curiosity literally kill me, lurking on perfume blogs I read religiously for over six years before I found out for myself just how true that evocative description was.

Within three years, we would have perfume blogs to edify and educate us – and meanwhile, niche and indie perfumery rustled in the underground and took off, starting the trends and creating the perfumes and the brands both my readers and myself love and adore to this day.

The blogosphere I became a minuscule but proud part of in 2010 celebrated not only those immortal classics of the twentieth century, but independent perfumery and perfumers. Andy Tauer, Vero Kern, Neela Vermeire, Ormonde Jayne, the meteoric rise of Amouage as a global brand, the blooming advent of breathtaking indie perfumers based in the US such as Aftelier, aroma M, DSH Perfumes, Neil Morris, Olympic Orchids, Envoyage, even Tommi Sooni in Australia, the perfumer as rock star…

As we say in my native Denmark… our enthusiasm would never, ever end.

And if not for the wretched EU, the lobbyists in Brussels or the heavily vested interests of the IFRA, we might have remained blithely, blissfully unaware of those shark fins on the horizon.

Truth and Consequences

As it was written, the truth of the EU proposal would basically mean the death of perfumery as we define it today. Perfumes would by necessity have to be reformulated to the point of redundancy, growers in Bulgaria, Egypt, Morocco, France, Italy and Tunisia would have to find other, more profitable crops, hundreds of thousands of people would have to locate other employment in an inhospitable economic climate, and every single brand you’ve ever heard of would have to close its doors – forever.

Yet strangely enough, very few brand owners and perfumers rose to the occasion and decried their impending doom and demise. One of the few who put his passions right up front was Frédéric Malle of Editions de Parfums, who came right out and said what very few dared, least of all global players such as LVMH and Chanel, both selling perfumes on a scale where you’d expect them to have a definite opinion and with the kind of industry clout to put some political muscle behind it.

There we were, even I, yesterday, wrestling with the research and my own definite emotional response to this potential horror, when Michel Roudnitska – son of Edmond and a fabled former perfumer himself – posted a link to an article in French about the coming regulations and some new considerations the EU is taking into account, in part because of the protests of perfume consumers and concerned EU citizens.

It seems that the EU will, among other things, revise its testing methodology to also include non-allergic people, to allow the use of certain aromachemicals and problematic natural materials if the allergenic compounds are removed before use, and at least listened to some of the arguments from both the industry, such as they were, and consumers themselves. Then again, it’s hard to argue with a 19 billion € industry…

As I type these words, I’m wearing a perfume, one of my recent fragrant obsessions I have yet to write about. It has haunted and taunted me in ways all the best perfumes always do, defying my attempts to decline it and pin down its inherent mysteries. It shouldn’t work, shouldn’t exist, and yet it does, and as it does, I am taken out of myself and away from my woes and cares in a manner only literature and music can compete with, and even so, this perfume needs no words to explicate it. It simply is – no more and no less.

As I wonder, as I think about its marvels and its majesty, I wonder if we, the passionate perfumistas, bloggers and perfume writers of the world, haven’t been living in a kind of fool’s paradise, breathing in the flowers and essences of this perfumed Eden, and forgetting about the crumbling ledge beneath our feet.

The results of the EU consultation will be made public in July.

Stay tuned.