The Increasing Regulatory World for Candles Global Key Issues. World Candle Congress 2016

Transcription

1 The Increasing Regulatory World for Candles Global Key Issues World Candle Congress 2016

2 Knowing when to act, Keeping Candles Out of the Regulatory Spot Light! Confidential and proprietary business information of Givaudan 2

3 Trends The Candle Industry will be impacted by broader issues Respiratory Allergy Airborne Exposure NGO s & Retailers Connecting the Dots Consumer What s Inside? Confidential and proprietary business information of Givaudan 3

4 The Globalization Effect Indoor Air Quality REACH EU CARB Cosmetics Allergens German BfR Prop 65 Confidential and proprietary business information of Givaudan 4

5 3200 Fragrance Materials 1400 Customer Requirements 1000 REACH Registrations 62 Regulations 30,500 Compliance Checks / Day Confidential and proprietary business information of Givaudan 5

6 IFRA Strategy Advocacy Changing the Discussion to Fragrance as a Consumer Delight! Government Relations Brussels Washington IFRA Global and IFRA NA Board Leadership to drive the agenda California AB 708: Ingredient disclosure Seeking to find practical solutions to prevent 100% disclosure TSCA Lobbying for modernized chemical management regulations Achieved Senate & House Bills that benefit fragrance material innovation California CARB Prop 65 Confidential and proprietary business information of Givaudan 6

7 IFRA Enabling Product Stewardship Supporting Business Strategies EPA Safer Choice Program Worked cooperatively to find a path forward for approval of fragrances Allowance for allergen labeling versus banning UL Good Guide Program for Target Confidential and proprietary business information of Givaudan 7

8 2016 Risk Map

9 2016 Global Risks NOAM Ingredient Bans (eg. Prop 65) GHS Hazard Classification & Labelling Retailers Ingredient Disclosure - AB708 EAME Fragrance Allergens REACH Ingredient Registration Impacts SCCS Ingredient Opinions (BMHCA) Product Standards (BfR) Candles APAC Expansion of Chemical Control Law LATAM Lack of strong product regulations Reapplication of REACH Korea Me too approach to US/Canada Halal Certification Expansion Product Labeling

10 Prop 65 Natural Exemption Confidential and proprietary business information of Givaudan 10

11 Prop 65 Naturally Occurring Exemption California Code of Regulations language exempts exposure to listed chemicals that occur naturally in foods (Cal. Code Regs. title 27, 25501) Exemption is not limited to use in foods Pulegon was listed in April 2014 found in mint oils B-Mycene was listed in March Higher profile material from citrus oils Legal challenges under bounty hunter provision Lead occuring naturally in fruits & vegetables coming from soil Pulegon challenge relating to content in pennyroyal oil

12 Fragrance Allergens European Cosmetic Regulation

13 EU Allergens - Cosmetics Product Labeling 26 allergens Bans HICC (Lyral) 89 allergens Restrictions Atranol & Chloroatranol Oak moss & Tree moss quality impact CONFIDENTIAL INTERNAL GIVAUDAN COMMUNICATION Confidential and proprietary business information of Givaudan 13

14 70.00% SCCS Allergen Fragrance Materials (% occurrence in sold formula 2012) 60.00% 50.00% Occurrence > 5% of products 26 allergens New allergens 40.00% 30.00% 20.00% 10.00% 0.00% Total sold 2012 ~ 23,000 14

15 Initial Fragrance Allergen Timetable 15

16 Product Formula Consumer Right to Know

17 Transparency Beyond Fragrance Disclosure Consumer Right to Know Marketing Strategies Transparency Retailers NGO s Confidential and proprietary business information of Givaudan 17

18 Formula Transparency has Now Begun - >0.09% Confidential and proprietary business information of Givaudan 18

19 Transparency Retailers Walmart relies on the WERCs to help with their compliance Owned by Underwriters Laboratories At this time we do not upload fragrance ingredients into the WERCs Target relies on the PurView Platform Owned by Underwriters Laboratories Target is requiring fragrance disclosure into the PurView portal Information is being use to rate ingredients to force removal of Target chemicals of concern Confidential and proprietary business information of Givaudan 19

20 Raw Material Assessment Chemical Control Laws

21 BMHCA (Lilial) Used in More than 50% of All Fragrances Confidential and proprietary business information of Givaudan 21

22 SCCS Opinion September 2015 Lilial is not safe for use in cosmetics The main concerns cited are insufficient safety margins at current use levels and mutagenicity. Potential timings, subject to revision, applying to cosmetics fragrances i.e. fine fragrances and personal care End of Public consultation Nov 10th SCCS Final opinion Q EU regulation and implementation for new products End 2016 Regulation for existing products off shelf allowing 3 years to rework? (TBD) No Lilial containing products on shelf by End 2019? (TBD) To be negotiated with EU Commission (Lyral 3yrs) Confidential and proprietary business information of Givaudan 22

23 REACH in a nutshell Concerns manufactured substances, raw materials and intermediates manufactured or imported into EU Tonnage Band Deadline Data needs Approx. full cost* >1000tpa 2010 >500K million(s) tpa 2013 >250K 500K tpa May K 1-10tpa May K Affects uses in all product categories Impacts already being felt HMPCC Karanal Styrene *Costs may be shared if >1 registrant

24 Ingredient Issue Timing Lilial CMR classification REACH and CMR H Bourgeonal ECHA review 2017 Karanal CMR classification Ban in Europe (SVHC due to Environmenal profile) Listed now. Ban Vetiveryl acetate SCCS review Q for SCCS opinion Geraniol 4-Methoxy Benzaldehyde (Anisic aldehyde) Silvial Hydratopic aldehyde 4-Methyl anisole Methyl & Hexyl Salicyclate Rose Oxide Testing to defend no CMR classification CMR classification. Potential ECHA review Potential for CMR Classification CMR Classification and Testing ongoing Ongoing 2017

25 Managing Candles Understanding of the Big Picture Proactive Defense & Engagement/Advocacy Protecting Raw Materials Investing in Regulatory to Manage the Complexity Confidential and proprietary business information of Givaudan 25

26 Lets not be Like This! Confidential and proprietary business information of Givaudan 26

27 Thank you Contact Dr. Greg Adamson Senior Vice President Global Regulatory Affairs, Product Safety & Sustainability Givaudan Fragrances SA Ridgedale Ave. East Hanover New Jersey USA Confidential business and proprietary information of Givaudan, may not be copied or distributed to anyone without the express written permission of Givaudan