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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 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 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. “

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.

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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.

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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, . 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 26 sensitizers in the ingredient lists of their Canadian product lines – including , Canus Products and Gilchrist & Soames. The Body Shop stands out for its transparency in this regard: they list each sensitizer individually and also identify it as a fragrance ingredient.

Twenty‐one of the companies contacted responded to our question about phthalates in fragrance mixtures (including seven companies that provided this information about some, but not all, of the products in question). Many others provided stock statements urging customers not to be concerned about phthalates in cosmetics, but did not tell us whether the product(s) in question contained phthalates. Fifteen companies stated that at least some of their products were phthalate‐ free.

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Table 1 – Summary of Responses Provided Provided Does fragrance mixture complete list information contain phthalates? Response of fragrance about (Response may be product­specific) received ingredients sensitizers No Yes/Maybe No answer Alberto Culver    *      Avon     Bath & Body Works     Beauti Control     Bio Oil (Advanced Innovations)     The Body Shop (L’Oréal)     Burt's Bees     Canus Products     Colgate­Palmolive    *  Coty International     La Coupe (Centura Brands)     Fruits & Passion     Gilchrist & Soames     Guelph Soap Company     The Hain Celestial Group  † † † † † Henkel    ‡  Jamieson   §  § § Johnson & Johnson    * *  Joico     Kao Brands Canada    ‡ **  Kevin Murphy  †† ­ ­     Live Clean (Belvedere Int.)     Lornamead  ­ ­ Lush     Nature’s Gate  ­ ­ Néolia (Novartis)    

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Table 1 (cont.) Provided Provided Do fragrance mixtures contain complete list information phthalates? (Response may be Response of fragrance about specific to a certain product) received ingredients sensitizers No Yes/Maybe No answer

Nivea (Beiersdorf)     L'Oreal  ­ ­ Pears  ­ ­ Pierre Fabre     Proctor & Gamble    *  Purell (GOJO)     Pureology  †† ­ ­  Radox  ­ ­ REHA Enterprises  ­ ­     Sally Hershberger     Unilever    *  Woof Cosmetics        ‡ *  TALLY 34/42 0 7 15 6 21 * Most responses from these companies did not specify whether their fragrance mixtures contain phthalates; however, some consumers received a response indicating that the product in question did (or did not) contain phthalates. In the case of Johnson & Johnson, one consumer received a response indicating that baby products do not contain DEP and other products may contain DEP. † A confidentiality notice on responses received from the Hain Celestial Group prevents us from disclosing this information. ‡ Most responses from these companies did not provide information about contact sensitizers; however, one consumer received a response that contained this information. § Jamison indicated that more information would be forthcoming. ** For most of the products we asked about, Kao Brands did not specify whether its fragrance mixtures contain phthalates; however, the company did indicate that Root, SB, Biore, RR, FE Brilliant Brunette and newer NG fragrances, as well as John Freida Frizz‐Ease 100% Shine and Secret Weapon are phthalate free. †† Acknowledgement only; no response provided to our questions.

Phthalates are a large class of ingredients we’re often asked about, but not all phthalates are the same. The phthalate family is similar to mushrooms; just like mushrooms, some phthalates are safe and some types are unsafe. “ Proctor & Gamble ” Failing the Sniff Test www.davidsuzuki.org/publications 7

Several of the responses we received argue that phthalates and other fragrance chemicals are perfectly safe. We may agree to disagree on this issue, but consumers should at least have access to the information they need to make a choice about whether or not to use , creams and other body products that contain such ingredients.

One of the most surprising responses was repeated by Henkel, Proctor and Gamble and Unilever. These companies informed us that they would only discuss specific fragrance ingredients if contacted by a customer’s family doctor. It is important that physicians have access to this information to help patients with fragrance allergy symptoms, but Canadians shouldn’t need a doctor’s note to find out what chemicals are inside their personal care products!

We normally do not disclose this information, as it is proprietary. However, if this is a medical necessity we would be more than happy to speak with your Physician should they wish to contact us. “ Unilever

Conclusion ” At present, it is difficult if not impossible for Canadian consumers to access information about the chemicals used as fragrance in their cosmetics, some of which are associated with serious health and environmental problems. We received only one complete list of fragrance ingredients from the companies contacted. These results underscore the need to strengthen Canada’s Cosmetics Regulation. Specifically, the David Suzuki Foundation offers the following recommendations:

1. That manufacturers be required to disclose complete lists of fragrance ingredients. Ideally, specific fragrance chemicals should be included on product ingredient lists. At a minimum, complete fragrance ingredient lists should be made available online and upon request.

2. That manufacturers be required to identify contact sensitizers on the retail product label, starting with but not limited to the 26 ingredients already regulated by the European Union.

3. That products marketed as “unscented” or “fragrance‐free” be truly free of fragrance chemicals.

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Go fragrance­free!

1. When it comes to personal care products and cosmetics, opt for those that do not list "parfum" or "fragrance" as an ingredient. Now that you're scrutinizing the ingredient list, check out our Shopper's Guide to a Dirty Dozen Ingredients to Avoid in Cosmetics. The Environmental Working Group's Skin Deep Database is another useful resource.

2. Sign our petition calling on cosmetic manufacturers to disclose fragrance ingredients at: http://action.davidsuzuki.org/fragrance‐petition.

3. Be aware of the wide range of fragranced household products, beyond cosmetics. Look for unfragranced alternatives – or make your own. David Suzuki's Queen of Green has simple recipes for do‐it‐yourself green cleaning. Forgo air fresheners — they only mask odour problems and worsen air quality. Instead, open a window or turn on a fan.

4. Find out if your (or your child's) school, workplace, place of worship, gym, local theatre and other public places you frequent have adopted fragrance‐free policies. If so, what's being done to promote awareness? If not, resources on how to create and implement scent‐free policies are available from the Canadian Lung Association at Developing a Scent‐Free Policy for the Workplace.

5. Call on Canada’s health minister to strengthen the Cosmetics Regulation to require companies to disclose fragrance chemicals. Take action at: http://action.davidsuzuki.org/parfum.

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Notes

1 Health Canada, Cosmetic Advertising, Labelling and Ingredients, http://www.hc‐sc.gc.ca/cps‐ spc/cosmet‐person/cons/advertising‐publicite‐eng.php (accessed June 1, 2011). 2 Fragranced Products Information Network, “Self‐Regulation,” Fragrance Materials and Composition, http://www.fpinva.org/text/1a5d908‐96.html. 3 Thyssen, JP et al., “Contact sensitization to fragrances in the general population: a Koch's approach may reveal the burden of disease,” British Journal of Dermatology 460, no. 4 (April 2009): 729‐35. 4 Kelman, L., “The triggers or precipitants of the acute migraine attack,” Cephalalgia 27, no. 5 (May 2007): 394‐402. 5 Millqvist E. and O. Löwhagen, “Placebo‐controlled challenges with perfume in patients with asthma‐like symptoms,” Allergy 51, no. 6 (June 1996): 434‐9. 6 NTP toxicology and carcinogensis studies of 2,4­hexadienal (89% trans,trans isomer, CAS No. 142­83­ 6; 11% cis,trans isomer) (Gavage Studies); NTP toxicology and carcinogenesis studies of methyleugenol (CAS NO. 93­15­2) in F344/N rats and B6C3F1 mice (Gavage Studies), National Toxicology Program Technical Report Series (U.S. National Toxicology Program, July 2000). 7 Anderson RC and Anderson JH, “Acute toxic effects of fragrance products,” Archives of Environmental Health 53, no. 2 (April 1998): 138‐46. 8 The Challenge of Substances of Emerging Concern in the Great Lakes Basin: A Review of Chemicals Policies and Programs in Canada and the United States (Toronto and Lowell, MA: Canadian Environmental Law Association and Lowell Center for Sustainable Production, 2009), http://www.cela.ca/sites/cela.ca/files/667IJC.pdf. 9 Pollution in People: Cord Blood Contaminants in Minority Newborns (Washingtron, DC: Environmental Working Group, 2009), http://www.ewg.org/files/2009‐Minority‐Cord‐Blood‐ Report.pdf. 10 What’s Inside? A survey of toxic ingredients in our cosmetics, David Suzuki Foundation, October 2010. www.davidsuzuki.org/publications 11 Study on Gathering Information on 435 Substances with Insufficient Data, Final Report to European Commission, DG Environment (Delft, Netherlands: RPS BKH Consulting Engineers, 2002), http://ec.europa.eu/environment/endocrine/documents/bkh_report.pdf 12 Griffin, S, CancerSmart 3.0: The Consumer Guide (Vancouver: Labour Environmental Alliance Society, 2007). 13 Stahlhut, RW et al., “Concentrations of urinary phthalate metabolites are associated with increased waste circumference and insulin resistance in adult U.S. males,” Environmental Health Perspectives 115, no. 6 (June 2007). 14 Health Canada, “Government of Canada Acts to Help Ensure Soft Vinyl Toys, Child‐Care Articles and Other Consumer Products Are Safer (News Release),”June 2009, http://www.hc‐sc.gc.ca/ahc‐ asc/media/nr‐cp/_2009/2009_96bk1‐eng.php 15 U.S. Environmental Protection Agency, “Toxic and Priority Pollutants,” http://water.epa.gov/scitech/methods/cwa/pollutants‐background.cfm