Failing the Sniff Test Chemicals in Fragranced Personal Care Products Remain a Mystery
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June 2011 Failing the Sniff Test Chemicals in fragranced personal care products remain a mystery Summary A loophole in Canada’s ingredient‐labelling requirements for cosmetics allows manufacturers to list fragrance ingredients generically as “parfum” rather than disclosing the specific chemicals used to produce or mask scents. Some 3,000 chemicals are used as fragrance ingredients in cosmetics, including substances associated with health and environmental hazards. The David Suzuki Foundation and supporters contacted 42 manufacturers of fragranced cosmetics to request information about unlisted fragrance ingredients in their products. We were not able to obtain a complete list of fragrance ingredients from any of the companies. Only seven of the companies provided information about common contact sensitizers,i which must be identified on the label of products sold in Europe. Only 21 companies responded to our question about phthalates in fragrance mixtures (15 stated that their products were phthalate‐free). These disappointing results underscore the need to strengthen the labelling provisions of Canada’s Cosmetics Regulation to require manufacturers to disclose complete lists of fragrance ingredients and identify sensitizers. However, we do not want to give everything away as our blends are so special to us, so when you read ‘perfume’ in our ingredients list this describes the mixture of several different fragrances which will remain a mystery. “ Lush Background ” Canada’s Cosmetics Regulation requires that ingredients in most personal care products be listed on the retail package in descending order of concentration by weight. Except for ingredients used in fragrance mixtures. A loophole in the labelling requirements allows manufacturers to list any ingredients added “to produce or to mask a particular odour” to be listed generically as “parfum”. i A contact sensitizer is a substance that can induce an allergic response following contact with the skin. Subsequent low dose exposures are more likely to cause a reaction. In some cases, exposure to a contact sensitizer can trigger sensitivities to other chemicals, as well. 2 The term parfum may be inserted either in order of concentration or at the very end of the ingredient list regardless of the actual concentration of fragrance ingredients in the product. Parfum is a very common “ingredient” in cosmetics – not only in perfumes, colognes and deodorants, but in nearly every type of personal care product. Even products marketed as “fragrance‐free” or “unscented” may in fact contain fragrance ingredients, in the form of masking agents that block the odour of other ingredients. Some companies use “fragrance‐free” to indicate that no fragrance chemicals have been added, but this informal industry standard is not enforceable. Health Canada guidelines treat the two terms (fragrancefree and unscented) as equivalent.1 Most consumer products contain fragrance, and it is an industry standard for any "Unscented" product to contain some fragrance. All "Unscented" products contain small amounts of fragrance (usually less than .1%). “ Alberto Culver There's no way for Canadian consumers to know exactly which chemicals are contained in a product ” that lists parfum (or fragrance) as an ingredient. European regulations are stronger. They require 26 contact sensitizers used as fragrance ingredients in cosmetics to be identified on the label. That's a start. As many as 3,000 chemicals are used in fragrance mixtures.2 A single product can include dozens or even hundreds. Many of these unlisted ingredients are irritants and can trigger allergies, 3 migraines4 and asthma symptoms.5 In laboratory experiments, individual fragrance ingredients have been associated with cancer6 and neurotoxicity7 among other adverse health effects. Synthetic musks used in fragrances are of particular concern from an ecological perspective. Environment Canada has categorized several synthetic musks as persistent, bioaccumulative and/or toxic, and others as priorities for assessment because of human health concerns. Measureable levels of synthetic musks are found in fish in the Great Lakes and the levels in sediment are increasing.8 Laboratory tests of human umbilical‐cord blood commissioned by the U.S. Environmental Working Group detected common synthetic musks (Galaxolide and/or Tonalide) in seven out of 10 newborns sampled.9 Fragrance or parfum? Parfum is the term stipulated in Canada’s Cosmetics Regulation to designate fragrance ingredients that are not identified individually in ingredient lists. Fragrance is the standard term used in the U.S. Often both terms will appear on ingredient lists – e.g., “fragrance/parfum” or “fragrance (parfum)”. Failing the Sniff Test www.davidsuzuki.org/publications 3 Consumers deserve to know about all ingredients contained in cosmetics – including fragrance chemicals. So the David Suzuki Foundation, with the help of concerned Canadians, set out to gather information from cosmetic companies about their fragrance formulations. Believe me when I say that I would like nothing better than to know precisely what ingredients are used to make our fragrance, but the fragrance houses’ right to earn a living has been weighed against our right to know…. “ Canus Products The David Suzuki Foundation’s Fragrance Challenge ” In the spring of 2010, the David Suzuki Foundation asked Canadians about ingredients in their personal care products in an online survey. “Parfum” was by far the most commonly reported ingredient, identified in more than half the products with ingredient lists entered in the survey. It was also the most commonly reported ingredient in each individual product category, except for makeup and oral care products.10 With the help of David Suzuki Foundation supporters, we contacted 42 manufacturers of fragranced cosmetics and asked them about the fragrance chemicals in specific products that list parfum or fragrance as an ingredient. We asked each company: 1. For a complete list of fragrance ingredients for each product 2. Whether their fragrance mixtures contain phthalates 3. Whether their fragrance mixtures contain any of the 26 sensitizers that must be indicated in the list of ingredients under the EU Cosmetics Directive Diethyl phthalate (pronounced tha‐late), or DEP, is widely used in cosmetic fragrances to make the scent linger. The European Commission on Endocrine Disruption has listed DEP as a Category 1 priority substance, based on evidence that it may interfere with hormone function.11 Phthalates have been linked to reduced sperm count in men and reproductive defects in the developing male fetus (when the mother is exposed during pregnancy), among other health effects.12 Phthalate metabolites are also associated with obesity and insulin resistance in men.13 As well, Health Canada notes evidence suggesting that exposure to phthalates may cause liver and kidney failure in young children when products containing phthalates are sucked or chewed for extended periods.14 Phthalates are listed as a Priority and Toxic Pollutant under the U.S. Clean Water Act, based on evidence that they can be toxic to wildlife and the environment.15 Health Canada recently announced regulations banning six phthalates in children’s toys, but the use of DEP in cosmetics is unrestricted. 4 The response: Failing the sniff test Table 1 presents a summary of responses from some of Canada’s major cosmetic companies. 34 out of the 42 companies we contacted responded to our inquiry. While a few provided relatively informative responses, many were clearly form letters that did not address our questions. A very common response was to refer us to the ingredient list on the package label and/or company website. Unfortunately, that doesn’t answer the question as only the generic term parfum appears on the ingredients list. Some companies asked us to call a hotline to discuss the questions, only to then tell us by telephone that they would not disclose information about fragrance ingredients. In some cases, several consumers contacted the same company (or subsidiaries of the same parent company) and received different responses. We were not able to obtain a complete list of fragrance ingredients from any of the companies we contacted. Several companies told us their fragrance mixtures were proprietary – that is, trade secrets. Some companies suggested they didn’t know exactly which chemicals are used in their fragrance mixtures, because they purchase them from third‐party suppliers. The fragrances we use are, in general, obtained from sources outside the company. Their precise formulations, which are often complex and may include several different ingredients, are considered confidential information, for competitive reasons within the consumer product industry. “ Colgate‐Palmolive Only seven companies consistently provided information about common sensitizers named in the European Union’s Cosmetics Directive (three more companies provided information ”about sensitizers to one inquiring consumer, but not to others). These 26 fragrance ingredients, which can cause an allergic reaction in some individuals, must be identified on the label of products sold in Europe. Yet, Canadian consumers rarely have access to this same information – even for products sold both here and in Europe. Some companies unhelpfully assured us that the products they sell in Europe comply with E.U. regulations, yet declined to provide the same information to Canadian consumers. Only a handful of companies told us they identify these