Fragrance requirements in Nordic Ecolabelling criteria

1 Fragrance requirements in Nordic Ecolabelling criteria Written by: Karen Dahl Jensen, Criteria Manager for the chemical technical product groups Introduction In March, the Nordic Ecolabelling Board (NMN) raised questions about the general guidelines for setting requirements concerning fragrance in Nordic Ecolabelling criteria, since the board was being asked to approve criteria documents with two different requirements and background justifications regarding fragrance in two criteria documents (hand dishwashing detergents and disposables for food). NMN therefore asked the Criteria Manager for the chemical technical product group to draw up a discursive presentation of when and how to set requirements for fragrance, which each national board could then use as the basis for its own discussions before the matter was returned to NMN for consideration in late. The discursive presentation is structured as follows: Previous discussions on fragrance within Nordic Ecolabelling are examined The facts and problems associated with fragrance are introduced: When is a substance a fragrance, where is it used, the environmental and health effects of fragrance A brief summary of the requirements set by the authorities and the industry The development of requirements for fragrance in the chemical technical product group is outlined via the criteria for hand dishwashing detergents The document concludes by considering the principles that might dictate when Nordic Ecolabelling prohibits/permits fragrance and what requirements should be set regarding fragrance in the future. This section includes a proposal to tighten requirements concerning allergenic fragrances. Fragrance discussions within Nordic Ecolabelling over the years There are very few subjects that have been discussed as much as fragrance over the 23-year life of the Nordic Ecolabel. Here is a short summary of the highlights from the past 10 years: In 2001, NMN agreed that there should be a multidisciplinary project on fragrance to ensure better underlying data regarding fragrance in chemical technical products, based on their health and environmental effects. The project was approved at the secretariat leaders meeting (SLM) in November 2002, and involved a thorough RPS for setting fragrance requirements, plus guiding questions to encourage the right requirement level for fragrance in criteria development processes. As part of the consideration of the proposal for revised criteria for hand dishwashing detergents at the SLM in May 2005, a decision was taken on a matter of principle: Nordic Ecolabelling shall try to help ensure that

2 fewer people develop allergies. Requirements should therefore be set that limit quantities of allergens, instead of focusing on information on/declaration of allergenic fragrances (which is primarily of benefit to people who already have an allergic and know what they are allergic to). Fragrance was then discussed again in conjunction with the development of version 2 of the chemical technical guidelines (2009/2010 adopted at the SLM in May 2010). The desire to avoid involuntary exposure to fragrance was made explicit at this point. Facts about fragrance i What is fragrance Fragrance is generally defined as a mix of fragrant ingredients that can be experienced over a set period. Fragrance is created by chemical synthesis or physical processing of synthetic/artificial, fossil or natural raw materials. The originating materials include aromatic chemicals, essential oils, natural extracts, distillates, extractions and so on. There are more than 2,000 different fragrances. Around 80% of the synthetic fragrance ingredients derive from terpenes, toluene, benzene, cresol or phenol. Fragrance tends to be diluted with ethanol. Fragrances are organic substances that necessarily must be liquid in order to be experienced (sensed). The number of fragrant ingredients in a finished fragrance may range from just a few to several hundred. ii Fragrances can also be extracted from certain plant families. The majority of these plants are from tropical or subtropical regions. Fragrance exists in quite small quantities in the plants (not only in the flowers, but also in the leaves, stems, bark and roots) either as liquid oils or as complex sugar compounds (glycosides). The oils from plants normally contain many different ingredients. When is a substance a fragrance? There is no particularly precise definition of the word fragrance. Many fragrances also have other characteristics as well as their scent. Some also taste as well, and are therefore added to products as flavourings (for example peppermint oil). Other substances have moisturising/conditioning properties (such as rose oil). In 2002, the multidisciplinary document concluded that in practice it was perfectly possible to define fragrance within Nordic Ecolabelling, even though grey areas may arise. However, the criteria for cosmetics have shaken this assertion. Experience from dealing with cosmetics cases shows that it is not easy to define when something is a fragrance. Often the person dealing with the cosmetics case will have to make a decision on whether a substance is a fragrance or an additive with a different characteristic, which leads to inconsistencies in the requirements. It has been necessary to apply a general interpretation on this point: that we rely on, and base case decisions on, what the applicant gives as the function of the substance. For example, if the applicant states that a substance that has a scent and can function as a fragrance is added as a flavouring, it is the requirements regarding flavourings that are to be fulfilled.

3 Where is fragrance used? Fragrance is added to many different chemical technical products, such as cosmetics, washing powder and cleaning products. However, the use of fragrance spreads far beyond the chemical technical product group. We encounter fragrance in many more products than people might think: erasers, felt-tip pens, toys, plastics, kitchen towel, graphic paper and textiles are just some of the places where fragrances are added. There are also a whole host examples of fragrances being used in open spaces: air fresheners in toilets and cars, the aroma of freshly baked bread outside the bakers, fragrances in specific parts of department stores, that new car smell, etc. Most products contain fragrance in very small quantities see Table 1: Table 1: Correlation between product groups and fragrance content. Product group Shampoo 0.3-0.8% Fragrance content Dishwashing detergents 0.15-0.3% Universal cleaning products 0.01-0.5% Liquid laundry detergents 0.4-0.9% The data in Table 1 is from an analysis conducted by Nordic Ecolabelling in 2002. Our knowledge of products today suggests that the concentrations in Table 1 remain relevant, but that Nordic Ecolabelled products often contain lower concentrations than this. The use of fragrances varies in Europe. In the Nordic region it is much more common to use non-fragranced products, and fragranced products often contain less fragrance, than in southern Europe. However, within the Nordic region itself, the focus of fragrance in products varies. The debate on allergenic fragrances is highly active in Denmark, and on the Danish consumer market there is a clear link between products being promoted as good for the environment and health and also being fragrance free. A similar link and active debate about fragrances cannot be seen in countries such as Sweden and Finland, where the Nordic Ecolabel is considered more purely as an environmental label, with other labels dominating in the field of health. Known environmental and health problems associated with fragrances Environmental effects More and more fragrance producers have begun to present detailed environmental and health information about their fragrances, and these show that fragrance ingredients are not uncommonly classified as R50/53 (H400 and H410), R51/53 (H411) or R52/53 (H412), which means that they have a long-term effect on the environment. This closely reflects what we have learned from water treatment plants, which is that waste water tends to smell of cleaning products when it is released after treatment.

4 When it comes to chemical technical products that end up in an aquatic environment after use, Nordic Ecolabelling applies the Critical Dilution Volume calculation to determine that the poor environmental profile of fragrances has an impact on the environmental profile of the whole product. Even in small quantities, added fragrance contributes considerably to an increased CDV, and fragranced products thus need to work harder to achieve a good environmental profile for the other chemical additives in order to meet the CDV requirement. In the event that it is not possible to source information on a fragrance s environmental profile, the fragrance is judged to be a worst case example in Nordic Ecolabelling s case management. It is thus reasonable to conclude that several fragrance ingredients can have a significant environmental impact and, due in particular to their environmental toxicity, Nordic Ecolabelling is focused on limiting the use of fragrances. However, with the very small concentrations of added fragrance it is not always the case that fragrance weighs heavily on a product s total environmental impact, seen from a life cycle perspective. One example of this might be where quite a small amount of fragrance is added to the cardboard roll of toilet paper, in which case the production of the paper far outweighs the environmental impact caused by the fragrance in each roll of toilet paper. Health effects Fragrances can have various effects on health, of which the most serious classifications are carcinogenic and toxic to reproduction. Via its ban on CMR substances Nordic Ecolabelling has ensured that such fragrances are not included in Nordic Ecolabelled products. Allergies are considered to be the most common health effects from fragrances. Fragrance causes 30-45% of the allergic reactions from cosmetics in eczema patients and is the most common cause of contact allergies from cosmetics. Two out of three patients with fragrance contact allergies notice, before diagnosis, that they cannot tolerate fragranced products on their skin. In general, the number of people allergic to fragrances has risen in Europe. If you are already allergic to one or two fragrances, you will typically become allergic to more over time 1. Tests have shown that lowering the concentration of the allergens allows many sensitive individuals to tolerate exposure even for prolonged periods 1. Studies tend to be conducted on individual substances and do not examine what might happen with blends of fragrances, which is how they most commonly appear 1. 1 Jeanne Duus Johansen, 2002: Contact Dermatitis Environmental and Occupational Dermatitis. Contact Allergy to Fragrances: Clinical and Experimental Investigations of the Fragrance Mix and its Ingredients.

5 Fragrance requirements set by the authorities and the industry The Detergents Regulation The Detergents Regulation relates to all washing and cleaning products that are covered by the Cosmetics Directive 76/768/EEC. The Detergents Regulation sets out requirements on the declaration of ingredients in washing and cleaning products, and fragrances must always be declared, whatever the quantity, as parfum. In addition, the 26 fragrances that are on the list of potential allergens must be declared by name if concentrations are >0.01%. Otherwise, there are no requirements relating to fragrances in the Detergent Regulation. The list of 26 fragrances has been compiled on the basis of a previous SCCS opinion from 1999/2000, in which they concluded from studies that 24 known fragrances were so allergenic that they should be named on the products. Two other substances (plant extracts) were later added to the list, and it should be mentioned that it took several years (3-4 years) from SCCS making this recommendation before it was actually implemented in cosmetics and detergents legislation. Cosmetics Directive/Cosmetics Regulation The Cosmetics Regulation has entered into force and will take over from the Cosmetics Directive when the directive expires on 11 July 2013. The Cosmetics Directive gives a long list of substances that must not be included in cosmetic products or may only be included in limited quantities or for limited applications. The directive also gives a positive list, for particular groups of substances, of which substances are allowed. In addition to these lists (which can be found in the annexes to the directive), there is a general ban on substances that are classified in CMR categories 1 and 2 (H340, H350, H350i, H360F, H360D, H360FD, H360Fd, H360fD). (CMR cat 3 (H341, H351, H361f, H361d, H361fd) is also excluded in principle, but dispensation may be given for substances which have been subject to a risk assessment by SCCS.) The list of substances that must not be used includes substances such as hormones, metals, biocides, named CMR substances, certain natural oils and extracts, medical substances and colouring agents. Some fragrances are also stated by name, e.g. musk ambrette, musk and musk tibetene. The list currently contains 1,369 stated substances or groups of substances which are not permitted in cosmetic products. Fragrances are marked so that they can easily be identified in this list. The Toy Safety Directive The EU s Toy Safety Directive (2009/48/EC) contains a list of 55 fragrances that must not be used in toys sold in the EU (for list of the 55 fragrances, see annex 2). Of the 55 fragrances in the Toy Safety Directive, 39 are banned under IFRA s rules (see below) and 15 of these overlap with the list of the 26 fragrances stated in the Detergents Regulation, which otherwise contains 11 more substances than are stated in the Toy Safety Directive list. IFRA s rules IFRA (the International FRagrance Association) represents the perfume industry. They carry out safety assessments of fragrances and blends and have public standards/guidelines for the use of fragrances. IFRA s guidelines limit or prohibit the use of certain fragrances in various product types.

6 SCCS opinion on fragrance allergens in cosmetic products, June In June, the EU s Scientific Committee on Consumer Safety (SCCS) issued an opinion on the risk of a long list of fragrances causing allergies. One focus was on investigating whether the 26 fragrances implemented in the Detergents Regulation are relevant, and whether any other fragrances also have known allergenic effects and therefore should be considered for ranking alongside the 26. The report indicates that setting requirements for the 26 fragrances remains highly relevant, since several scientific studies show that these have caused allergic reactions in people. At the same time, SCCS found that the list of fragrances which have several scientifically documented allergic effects is much longer than the 26. In fact, SCCS found that as many as 54 individual chemical fragrances and 28 natural extracts (82 substances in all) may be considered as scientifically documented allergens for people, on the same footing as the 26. (Note that the 26 fragrances are included in the 82 substances). In addition, SCCS reported that for a further 45 fragrances there was also evidence that these may cause allergic reactions (evidence via testing on animals or via combined evidence). SCCS recommends that all the fragrances for which they have evidence of possible allergens, both the 82 with recorded results on humans and the 45 for which other scientific results indicate allergenic properties, should be declared by name on the cosmetic product. This list thus totals 127 fragrances in all, of which 26 are already restricted in the Detergents Regulation and 20 have a hazard classification of R43 (H317). The full list of the fragrances that SCCS gives as potential allergens can be seen in appendix 1 to this document. SCCS refrains from recommending definite max limits for content of fragrances in cosmetic products, but states that the general limit of 100 ppm is tolerated by most consumers, and will guard against the development of new allergy sufferers among both generally tolerant and sensitive individuals. The recommendation is therefore for 100 ppm as a declaration level. Development of Nordic Ecolabelling requirements for fragrances in the chemical technical product group In order to gain an overview of how the Nordic Ecolabelling requirements for fragrances have developed in the chemical technical product group, the fragrance requirements are described below as they have appeared in the versions of the criteria for hand dishwashing detergents. Hand dishwashing detergents have been chosen because the product group contains both professional and consumer products within the same criteria and can be considered relatively representative of the way that Nordic Ecolabelling has approached fragrance requirements over the years. It should be noted that the details below only focus on requirements relating specifically to fragrances. As new versions have been developed, there has also been a tightening of requirements concerning CDV and substances classified as environmentally hazardous, which has proven to have an extremely limiting impact particularly on the amount of fragrance in products (see section Known environmental and health problems associated with fragrances. Environmental effects above).

7 Version 1 of the criteria for hand dishwashing detergents was adopted in 1996. The only specific fragrance requirement was for compliance with IFRA s rules. Version 2 of the criteria for hand dishwashing detergents was adopted in 2001. The perfume requirements were now expanded into the following: A ban on the use of fragrances in professional products Compliance with IFRA s rules 5 nitro musk compounds were banned on the grounds of being carcinogens In the case of 13 fragrances (which were later included in the list of 26 fragrances), there was a requirement that these should be declared on the label under the title fragrances There were no requirements about the content of allergenic substances or CMR classified substances. Version 3 of the criteria for hand dishwashing detergents was adopted in 2005. It included a ban on substances that were classified as CMR, and a max limit for allergenic substances (R42 (H334) and R43 (H317)) (max 0.1% in the product) was introduced, which consequently limited the use of fragrances. In addition, there were the following specific requirements concerning fragrances: A ban on the use of fragrances in professional products Compliance with IFRA s rules 7 nitro musk compounds were banned on the grounds of their carcinogenic effect The Detergents Regulation s list of 26 fragrances was incorporated in the following requirements: Either addition in a max concentration of 100 ppm per substance, or declared on the label in concentrations over 10 ppm. It was also explicitly stated in the criteria that the declaration option would be deleted in the next revision Version 4 of the criteria for hand dishwashing detergents was adopted in 2008. The perfume requirement was amended only on one point compared with version 3: The Detergents Regulation s list of 26 fragrances: addition in a max concentration of 100 ppm per substance. Version 5 of the criteria for hand dishwashing detergents was adopted in. In addition to the above requirement, it was specified that fragrances from plant extracts are included in the perfume requirement. Another addition is that constituent substances in a fragrance classified as allergenic (R42 (H334) and/or R43 (H317)) may be max 100 ppm in the finished product, which is a tightening by a factor of 10 compared with the previous version. The fragrance requirements were thus tightened in each revision, with various loopholes closed regarding the use of substances harmful to the environment and to health, and the requirements have largely been based on existing legislation and known rules/guidelines. It should be mentioned that, over several rounds, Nordic Ecolabelling has tried to implement a fragrance ban in several chemical technical product groups through its introduction in the consultation documents (the latest example is the criteria for cleaning products, which were sent out for consultation in summer

8, where we attempted a total ban on fragrances in professional products). Each time there has been a strong reaction from several parties, particularly licensees and the rest of the chemicals industry. The arguments are often that users want fragrances, they are used as an indicator of cleanliness and some brands are identified by consumers via their scent, making the scent a more important part of the brand than the Nordic Ecolabel. Listening to the consultation responses is a key part of Nordic Ecolabelling s criteria work and therefore the finished criteria do not always end up containing complete bans. Discussion: Nordic Ecolabelling s attitude to fragrances in the future The principles for Nordic Ecolabelling setting requirements regarding fragrances are stated in bold in the text below. The environmental toxicity of fragrances is handled on the same footing as other substances As described above, fragrances can have a poor environmental profile, being classed as having lasting effects on the environment. The Nordic Ecolabel handles fragrances on the same footing as other chemical substances when it comes to environmental requirements. This means that fragrances are not exempt from environmental requirements and are handled based on the fragrance s environmental profile in these requirements just as with other substances. In the event that it is not possible to source information on a perfume s environmental profile, the perfume is judged to be a worst case example. Since several fragrances have an environmental hazard classification, and in order to comply with the principal described in the next section, it does however happen that limit values for amount of environmentally harmful substances in Nordic Ecolabelled products are set so that it is possible to add small quantities of fragrance. Proportion of fragranced products on the market and fragrance in the product s RPS For each individual product group it is important to analyse the market within which we are setting requirements, in order to ensure as great a potential for environmental improvements as possible in that market. This is also the case for fragrances! It means in practice that if the market share of fragrancecontaining products in the product group is high, it is not necessarily possible/a good idea to introduce a ban on fragrances. Other conditions within the product group must also be taken into account, and in particular there should be an assessment of which areas have a high RPS for the product group in question. In a product group with a high proportion of fragrance-containing products on the market, a ban on fragrances would mean that a very high proportion of the products on the market would not be able to achieve the Nordic Ecolabel, on the basis of one requirement that is not necessarily the most important environmental parameter for the product group. The consequence might be that we miss the opportunity to improve the environmental profile in those areas with a high RPS for a large proportion of the market s products.

9 Cleaning products: In cleaning products, the most important point environmentally is to ensure correct dosing, effective products, optimal use of packaging and that the chemicals used in large quantities (such as tensides) have as low an effect on the aquatic environment as possible. With stringent requirements for this, Nordic Ecolabelling ensures that the product group focuses on benefiting the environment. On the other hand it is important to remember that Nordic Ecolabelling is multi-criteria based, and thus also makes sure that other parameters than those that crop up in life cycle analysis are taken into account, including the issue of health. The market for cleaning products, particularly the consumer market but also certain parts of the professional market, features fragrance-containing products. The proportion of products with fragrances far exceeds the proportion of products without, and this is attributed in particular to a consumer desire for such products to be scented. Consumers do not necessarily want to ignore environmental considerations simply because they want scented products. However, it is likely that the choice between scent and no scent carries greater weight than environmental considerations for many consumers, since the scent gives the user the desired instant feedback from the product, while environmental consideration is a more abstract effect of purchasing the product. It is therefore much more possible to influence the fragrance-buying section of the customer segment to choose something that is better for the environment if we give them a choice of fragrance-containing products. In product groups with a high proportion of fragrance-containing products on the market, where perfume is not the only/most important environmental parameter in the product, it is the task of Nordic Ecolabelling to ensure a focus on the most relevant environmental parameters and on ecolabelled products with the best environmental profile, which is not necessarily the same as a total ban on fragrances. But at the same time, Nordic Ecolabelling should also safeguard consumers and the environment by ensuring that only the fragrances that are least harmful to the environment and health are added to the product. In product groups with a low proportion of fragrance-containing products on the market, Nordic ecolabelling may introduce a total ban on fragrances, on the grounds of the environmental and health problems of fragrances, in the same way that other undesirable substances that are harmful to the environment and health are banned. This is not necessarily related to whether a ban on fragrances has a high RPS for the product. This is because the Nordic Ecolabelling has good potential to influence the market with strict environmental requirements, giving a high RPS in the product group, while also ensuring a focus on health via a fragrance ban. Examples: Disposable items: Fragrances have a relatively low RPS in disposable items, since environmentally it is much more important to look at recycling, production and waste processing for the core materials in the product, such as plastic and paper. At the same time, the proportion of and demand for fragrance-containing products is very small, although they do exist. In this case, there is no problem in Nordic Ecolabelling imposing a ban on fragrances, while at the same time being sure that the Nordic Ecolabel can benefit the environment in the product group via the other requirements (with high RPS) that are set. Here a ban on fragrances can, to a large extent, be seen as a signal requirement.

10 Risk groups and exposure In addition to the above assessment of the market and the RPS, which largely has a focus on the product s overall environmental profile, Nordic Ecolabelling should also take account of health in the Nordic Ecolabel criteria. When setting requirements for fragrances that have a poor health profile, there should therefore be a focus on risk groups and exposure to the fragrances. Due to the harmful effects that fragrances have on health, Nordic Ecolabelling should ensure that particularly vulnerable population groups, such as children, are protected from fragrances via a ban on fragrances in products for children. Nordic Ecolabelling should ensure that people are not exposed to fragrances involuntarily, which is particularly the case if you have no influence over the purchase of products, and so over whether the product contains fragrances. This is the situation, in many cases, for professional users, where others are responsible for purchasing. At the same time, Nordic Ecolabelling must also recognise that there are occasions where the user voluntarily buys/chooses a fragrance-containing product. This may include chemical technical consumer products such as hand dishwashing detergent, hand soap, shampoo, cleaning products and so on. In these cases, it is Nordic Ecolabelling s task to ensure that only the fragrances that are least harmful to the environment and health are added to the product. The market for fragrance-containing product is not the same in all Nordic countries Nordic Ecolabelling comprises five countries, and it is important that the requirements function in all the Nordic countries, which is why there is a need to recognise that the Nordic markets are not always the same. Demands from consumers, the focus of the media and politicians, the attitudes of producers and retailers are not always uniform, and fragrances are a case in point. It is important in the discussions on fragrances to consider the national situation, and work towards solutions that can function in all the Nordic countries, accepting that there will have to be compromises. It is however even more important that discussions on the criteria retain a focus on the Nordic Ecolabel encouraging as much environmental improvement as possible, since that is the primary objective of Nordic Ecolabelling. Fragrance requirements of the future within Nordic Ecolabelling Nordic Ecolabelling should not introduce a total ban on fragrances in all product areas. Instead, Nordic Ecolabelling should set fragrance requirements based on the principles marked in bold in the discussion section above. Nordic Ecolabelling already has a ban on fragrances in products for children, and practically all product groups where the market share of fragrance-containing products is low have a ban on fragrances. This policy will remain in place.

11 Nordic Ecolabelling also has a focus on limiting fragrances in products for professional users, and has come a long way with bans on fragrances in many professional products. However, for professional products too there are certain areas where market share and demand for fragrance-containing products is high, and here Nordic Ecolabelling will constantly examine the scope for benefiting the environment by introducing a requirement to ban or limit fragrances. Proposal for tougher requirements concerning allergenic fragrances: SCCS s report from June on allergenic fragrances in cosmetic products shows that the list of 26 fragrances cannot be seen as sufficient to cover fragrances with scientifically documented allergenic effects. Nordic Ecolabelling will push for the list of fragrances that are excluded/limited due to allergenic effects (currently a list of 26 substances) to be expanded to contain the 127 fragrances for which SCCS has found scientific documentation of allergenic effects (see list of substances in appendix 1). Nordic Ecolabelling will hereby take account of the latest scientific information and adopt the precautionary principle with regard to the negative health effects of fragrances. The fragrance producers industry body appears to have recognised SCCS s report (see IFRA press release, Brussels, 31 July ) and the industry body for chemicals producers has indicated to Nordic Ecolabelling that it expects the results of SCCS s report to lead to a change in the law on fragrances in the near future. At the current time it is extremely difficult to judge the consequence of a ban/limitation on the 127 allergenic fragrances for each product group, but it is clear that many well known fragrances are on the list, and therefore Nordic Ecolabelled fragrance-containing products will be affected. For this reason, implementation of the 127 allergenic fragrances should be carried out with due common sense. Criteria in which we implement a ban/limitation on the 127 fragrances should be sent out for consultation and be tested in the market before such changes are implemented in any criteria. This kind of change cannot be made without consultation. In addition, it should be possible to introduce the ban gradually, depending on the product group. Since Nordic Ecolabelling s criteria have different lifetimes and thus not all chemical technical criteria with fragrance requirements are due for revision now, implementation of this will take a few years (until around 2016). The goal is that in the future 127 fragrances, rather than 26 fragrances, will be limited/banned based on their allergenic effect. Inspiration for future fragrance discussions In future discussions on fragrance requirements, consideration might be given to whether the idea of safeguarding people against involuntary exposure to fragrances should be expanded, such that people are not exposed to fragrances in public spaces. Nordic Ecolabelling has already come a long way on this in the form of requirements for a high proportion of Nordic Ecolabelled cleaning products and other products in criteria for Nordic Ecolabelled services, where fragrance is either prohibited or severely restricted. This reduces the risk that, for example, hotel guests at a Nordic Ecolabelled hotel get a room that smells strongly of fragranced cleaning products.

12 However this is highly complex task that is not as easy to resolve as it might sound, since other aspects enter the picture when it comes to exposure to scents in open spaces. One example of the problems that arise is the fact that bouquets of flowers in hotel receptions give off natural floral scents that some people may be allergic to. Should flowers therefore no longer be allowed in reception? It is clearly a complicated matter that should be carefully thought through and worked on in order to create a sound foundation for requirements in the Nordic Ecolabelling criteria.

13 Appendix 1. Tables of fragrances as proven of or suspected to be allergenic to humans from SCCS opinion on fragrances allergenes in cosmetic products, June. Table 13-1: Established contact allergens in humans. For categorisation of importance (+ to ) see chapter 7.1. Allergens of special concern are substances where between 100 and 1,000 cases (+) and more than 1,000 () have been published. These are set in bold. Fragrance substances identified as allergens in the 1999 opinion of SCCNFP (1) are marked with an asterisk. ox. = oxidised; non-ox. = non-oxidised; r.t. = rarely tested (see chapter 7) Substance marked in gray are classified with hazardous R43 (H317) according to the SCCS report INCI name (or, if none exists, perfuming name according to CosIng) CAS number Human evidence: see text Individual chemicals ACETYLCEDRENE 32388-55-9 + AMYL CINNAMAL* 122-40-7 AMYL CINNAMYL ALCOHOL* 101-85-9 AMYL SALICYLATE 2050-08-0 + trans-anethole 4180-23-8 + (r.t.) ANISE ALCOHOL* 105-13-5 + BENZALDEHYDE 100-52-7 + BENZYL ALCOHOL* 100-51-6 BENZYL BENZOATE* 120-51-4 BENZYL CINNAMATE* 103-41-3 BENZYL SALICYLATE* 118-58-1 BUTYLPHENYL METHYLPROPIONAL 80-54-6 * CAMPHOR 76-22-2 / 464- + (r.t.) 49-3 beta-caryophyllene (ox.) 87-44-5 Non-ox.: +, ox.: + CARVONE 99-49-0 / 6485- + (r.t.) 40-1 / 2244-16- 8 CINNAMAL* 104-55-2 + CINNAMYL ALCOHOL* 104-54-1 + CITRAL* 5392-40-5 + CITRONELLOL* 106-22-9 / 1117-61-9 / 7540-51-4 COUMARIN* 91-64-5 + (DAMASCENONE ) ROSE KETONE-4 23696-85-7 + (r.t.)

14 alpha-damascone (TMCHB) 43052-87-5 / 23726-94-5 cis-beta-damascone 23726-92-3 + delta-damascone 57378-68-4 + DIMETHYLBENZYL CARBINYL ACETATE (DMBCA) 151-05-3 + EUGENOL* 97-53-0 + FARNESOL* 4602-84-0 - + GERANIOL* 106-24-1 + HEXADECANOLACTONE 109-29-5 + (r.t.) HEXAMETHYLINDANOPYRAN 1222-05-5 HEXYL CINNAMAL* 101-86-0 HYDROXYISOHEXYL 3-CYCLOHEXENE CARBOXALDEHYDE (HICC)* 31906-04-4 / 51414-25-6 HYDROXYCITRONELLAL* 107-75-5 + ISOEUGENOL* 97-54-1 + alpha-isomethyl IONONE* 127-51-5 (DL)-LIMONENE* 138-86-3 (non-ox.); + (ox.) LINALOOL* 78-70-6 (non-ox.) + (ox.) LINALYL ACETATE 115-95-7 + (non-ox.) (ox.) MENTHOL 1490-04-6 / 89-78-1 / 2216-51- 5 6-METHYL COUMARIN 92-48-8 METHYL 2-OCTYNOATE* 111-12-6 METHYL SALICYLATE 119-36-8 + 3-METHYL-5-(2,2,3-TRIMETHYL-3-67801-20-1 (r.t.) CYCLOPENTENYL)PENT-4-EN-2-OL alpha-pinene and beta-pinene 80-56-8 and 127-91-3, resp. PROPYLIDENE PHTHALIDE 17369-59-4 + (r.t.) SALICYLALDEHYDE 90-02-8 alpha-santalol and beta- 115-71-9 and SANTALOL 77-42-9, resp. SCLAREOL 515-03-7 + TERPINEOL (mixture of isomers) 8000-41-7 + alpha-terpineol 10482-56-1 / 98-55-5 Terpinolene 586-62-9 +

15 TETRAMETHYL ACETYLOCTAHYDRONAPHTHALENES TRIMETHYL-BENZENEPROPANOL (Majantol) 54464-57-2 / + 54464-59-4 / 68155-66-8 / 68155-67-9 103694-68-4 VANILLIN 121-33-5 Natural extracts CANANGA ODORATA and Ylangylang 83863-30-3; + oil 8006-81-3 CEDRUS ATLANTICA BARK OIL 92201-55-3; 8000-27-9 CINNAMOMUM CASSIA LEAF OIL 8007-80-5 (r.t.) CINNAMOMUM ZEYLANICUM BARK OIL 84649-98-9 CITRUS AURANTIUM AMARA 8016-38-4; FLOWER / PEEL OIL 72968-50-4 CITRUS BERGAMIA PEEL OIL 89957-91-5 + (r.t.) EXPRESSED CITRUS LIMONUM PEEL OIL EXPRESSED 84929-31-7 CITRUS SINENSIS (syn.: AURANTIUM DULCIS) PEEL OIL EXPRESSED CYMBOPOGON CITRATUS / SCHOENANTHUS OILS 97766-30-8; 8028-48-6 89998-14-1; 8007-02-1; 89998-16-3 EUCALYPTUS SPP. LEAF OIL 92502-70-0; 8000-48-4 EUGENIA CARYOPHYLLUS LEAF / FLOWER OIL 8000-34-8 + EVERNIA FURFURACEA 90028-67-4 + EXTRACT* EVERNIA PRUNASTRI EXTRACT* 90028-68-5 + JASMINUM GRANDIFLORUM / OFFICINALE 84776-64-7; 90045-94-6; 8022-96-6 + JUNIPERUS VIRGINIANA 8000-27-9; 85085-41-2 LAURUS NOBILIS 8002-41-3; 8007-48-5; 84603-73-6 LAVANDULA HYBRIDA 91722-69-9 + (r.t.) LAVANDULA OFFICINALIS 84776-65-8 MENTHA PIPERITA 8006-90-4; 84082-70-2 MENTHA SPICATA 84696-51-5 MYROXYLON PEREIRAE 8007-00-9; NARCISSUS SPP. diverse

16 PELARGONIUM GRAVEOLENS 90082-51-2; 8000-46-2 PINUS MUGO/PUMILA 90082-72-7 / 97676-05-6 POGOSTEMON CABLIN 8014-09-3; 84238-39-1 ROSE FLOWER OIL (ROSA SPP.) Diverse SANTALUM ALBUM 84787-70-2; + 8006-87-9 TURPENTINE (oil) 8006-64-2; 9005-90-7; 8052-14-0 VERBENA ABSOLUTE 8024-12-2 Table 13-2: Fragrance substances categorised as established contact allergens in animals. INCI name (or, if none exists, perfuming name according to CosIng) CAS number Individual chemicals Human evidence: see text Allyl phenoxyacetate 7493-74-5 none 3,1 p-tert. - 18127-01-0 none 4,3 Butyldihydrocinnamaldehyde CYCLAMEN ALDEHYDE 103-95-7 none 22 Dibenzyl ether 103-50-4 none 6,3 2,3-DIHYDRO-2,2,6-116-26-7 limited 7,5 TRIMETHYLBENZALDEHYDE trans-2-hexenal 6728-26-3 none 2,6 2-Hexylidene cyclopentanone 17373-89-6 none 2,4 HEXYL SALICYLATE 6259-76-3 negative 0,18 p-isobutyl-α-methyl 6658-48-6 none 9,5 hydrocinnamaldehdye Isocyclocitral 1335-66-6 none 7,3 α-methyl cinnamic aldehyde 101-39-3 none 4,5 METHYLENEDIOXYPHENYL 1205-17-0 none 16,4 METHYLPROPANAL METHYLUNDECANAL 110-41-8 none 10 2-Methoxy-4-methylphenol 93-51-6 none 5,8 4-Methoxy-α-methyl 5462-06-6 none 23,6 benzenpropanal METHYL OCTINE CARBONATE 111-80-8 limited 2,5 Perillaldehyde p-mentha-1,8-dien-7-2111-75-3 none 8,1 al PHENYLACETALDEHYDE 122-78-1 limited 3 Jasminum Sambac Flower CERA / Extract / Water Natural extracts 91770-14-8 none 35,4 EC 3 value (min; %)

17 Table 13-3: Fragrance substances categorised as likely contact allergens by combination of evidence. INCI name (or, if none exists, perfuming name according to CosIng) CAS number Human evidence: see text EC 3 value (min; %) SAR AMBRETTOLIDE 7779-50-2 limited none + CARVACROL 499-75-2 limited none + Citrus paradisi 8016-20-4 none R43 n.a. CUMINALDEHYDE 122-03-2 limited none + CYCLOPENTADECANONE 502-72-7 limited none + trans-trans-delta-damascone 71048-82-3 limited none + 2,4-dimethyl-3-cyclohexen-1-68039-49-6 none R43 + carboxaldehyde DIMETHYLTETRAHYDRO 68737-61-1 limited none + BENZALDEHYDE ETHYL VANILLIN 121-32-4 limited none + HELIOTROPINE 120-57-0 limited none + ISOAMYL SALICYLATE 87-20-7 limited none ISOLONGIFOLENEKETONE 33407-62-4 limited none + Longifolene 475-20-7 none R43 + Mentha arvensis 68917-18-0 none R43 n.a. METHOXYCITRONELLAL 3613-30-7 limited none + METHYL CINNAMATE 103-26-4 limited none METHYLIONANTHEME 55599-63-8 limited none + 5-METHYL-alpha-IONONE 79-69-6 limited none + MYRCENE 123-35-3 limited none MYRTENOL 515-00-4 limited none + NEROL 106-25-2 limited none Nerolidol (isomer not specified) 7212-44-4 limited none NOPYL ACETATE 128-51-8 limited none + PHYTOL 150-86-7 limited none + RHODINOL 6812-78-8 limited none + trans-rose KETONE-5 39872-57-6 limited none Substances/natural mixtures were classified as R43, according to the submission by IFRA. The evidence on which this classification was based was not available to the SCCS, so the validity of classification cannot be assessed. Nevertheless, the four substances/substance mixtures should be treated as likely contact allergens. n.a.: not applicable (natural mixture)

18 Appendix 2: Fragrances from Toys directiv, 2009/48/EC Name on fragrances Cas-No. Alanroot (Inula helenium) 97676-35-2 Allylisothiocyanat 57-06-7 Benzylcyanid 140-29-4 4-tert-Butylphenol 98-54-4 Chenopodiumolie 8006-99-3 Cyclamenalkohol 4756-19-8 Diethylmaleat 141-05-9 Dihydrocoumarin 119-84-6 2,4-Dihydroxy-3-methylbenzaldehyd 6248-20-0 3,7-Dimethyl-2-octen-1-ol(6,7-Dihydrogeraniol) 40607-48-5 4,6-Dimethyl-8-tert-butyl-coumarin 117874-34-9 Dimethylcitraconat 617-54-9 7,11-Dimethyl-4,6,10-dodecatrien-2-on 26651-96-7 6,10-Dimethyl-3,5,9-undecatrien-2-on 141-10-6 Diphenylamin 122-39-4 Ethylacrylat 140-88-5 Fig leaf, fresh and preparations (Ficus carica) 68916-52-9 Trans-2-Heptenal 18829-55-5 Trans-2-Hexenaldiethylacetal 67746-30-9 Trans-2-Hexenaldimethylacetal 18318-83-7 Hydroabietylalcohol 13393-93-6 4-Ethoxyphenol 622-62-8

19 6-Isopropyl-2-decahydronaphtalenol 34131-99-2 7-Methoxycoumarin 531-59-9 4-Methoxyphenol 150-76-5 4-(p-Methoxyphenyl)-3-buten-2-on 943-88-4 1-(p-Methoxyphenyl)-1-penten-3-on 104-27-8 Methyl trans-2-bytenoat 623-43-8 6-Methylcoumarin 92-48-8 7-Methylcoumarin 2445-83-2 5-Methyl-2,3-hexanedion 13706-86-0 Costusrodolie (Saussurea lappa Clarke) 8023-88-9 7-Ethoxy-4-methylcoumarin 87-05-8 Hexahydrocoumarin 700-82-3 Perubalsam, raw (Exudat af Myroxylon pereirae (Royale) Klotzsch) 8007-00-9 2-Pentyliden-cyclohexanon 25677-40-1 3,6,10-Trimethyl-3,5,9-undecatrien-2-on 1117-41-5 Verbenaolie (Lippia citriodora Kunth) 8024-12-2 Musk ambrette (4-tert-Butyl-3-methoxy-2,6-dinitrotoluene) 83-66-9 4-Phenolbut-3-en-2-on 122-57-6 Amyl Cinnamal 122-40-7 Amylcinnamyl Alcohol 101-85-9 Benzyl Alcohol 100-51-6 Benzyl Salicylate 118-58-1 Cinnamyl Alcohol 104-54-1 Cinnamal 104-55-2 Citral 5392-40-5 Coumarin 91-64-5

20 Eugenol 97-53-0 Geraniol 106-24-1 Hydroxycitronellal 107-75-5 Hydroxyisohexyl 3-cyclo-hexencarboxaldehyde (Lyral) 31906-04-4 /51414-25-6 Isoeugenol 97-54-1 Evernia prunastri extract (Oak moss) 90028-68-5 Evernia furfuracea extract (Tree moss) 90028-67-4 i The content of this section is based on general knowledge of fragrances, as already described in Nordic Ecolabelling s multidisciplinary project on fragrances vers 1.0, 12. November 2002, and its supplements. ii Jeanne Duus Johansen, 2002: Contact Dermatitis Environmental and Occupational Dermatitis. Contact Allergy to Fragrances: Clinical and Experimental Investigations of the Fragrance Mix and its Ingredients