The fragrance industry stands at an important moment in the future of regulation, presenting opportunities to advance regulatory systems and pathways that accelerate the kind of innovation that improves human and environmental safety, while simultaneously encouraging investment and responsible business practices.
Why The World Needs Fragrance
Beyond all frontiers and cultures, fragrance enhances and uplifts lives. Fragrance is a critical input into essential products such as disinfectants, cleaners and personal hygiene products. Fragrance improves our lives with a multitude of important well-being benefits—it aids in relaxation and memory recall and increases confidence and comfort. Depriving consumers of these beneficial sensory experiences would be akin to mandating colorless galleries or flavorless restaurants.
Approaches to Regulation
Foundational to chemical regulation lie two fundamentally different approaches: hazard and risk.
All substances have inherent hazards. Hazard-based management takes a shotgun approach that attempts to eliminate all hazards, thereby eliminating all risks. While obviously true, this approach leads one to wonder: almost everything has a potential hazard, so what substances won’t be banned? While relying solely or too heavily on hazard may be easier and more efficient for a regulator, it dramatically stifles the industry’s ability to innovate and create safer, greener materials. To paraphrase Paracelsus—the dose makes the poison.
A risk-based approach, on the other hand, uses a more nuanced and comprehensive view. Risk management assesses the potential of a particular chemical to cause or even reduce harm to people and the planet. Considerations like sustainability can be incorporated into risk-based decision-making because use levels (and more broadly, exposure) are central to safety. A substance might have a higher inherent hazard when it contains less dilutant, but it may also contribute less to harmful greenhouse gas emissions. Then, based on thorough research, scientists provide parameters within which a chemical is safe to use.
Importance of a Risk-Based Approach When Evaluating Fragrance
A risk-based approach to chemical management encompasses the regulatory framework most likely to both encourage innovation and preserve the health of people and our planet.
The risk-based approach considers a chemical’s potential for harm in many dimensions. Think of it this way: riding a bicycle is inherently hazardous. However, it makes no sense to remove all bikes from all roads—this is what the hazard-based regulatory framework would require. The more sensible regulatory approach is to continually innovate safer infrastructure and safety equipment so that we can benefit from their utility and fitness while diminishing risk.
From a chemical management standpoint, the risk-based approach assesses human safety holistically. Toxicological considerations like skin sensitization, reproductive toxicity, carcinogenesis, phototoxicity, respiratory toxicity, and others are considered. Assessments also include environmental aspects, such as persistence and biodegradation, ecotoxicity, aquatic toxicity, and others.
After careful evaluation of a chemical’s safety profile, levels of safe use for each product category are assigned so that manufacturers of household goods, like cleaning supplies and cosmetics, can be confident that the products they put on shelves don’t pose a risk to people or the planet.
If this all sounds complex, that’s because it is. Fortunately, we already have a system in place to assess these dimensions for ingredients used in the fragrance industry. Research Institute for Fragrance Materials (RIFM) has been independently performing these assessments since its inception in 1966.
Using the best scientific methods and tools available, RIFM analyzes the safety and toxicity of hundreds of fragrance and flavor ingredients every year and then publishes each finding in freely available, peer-reviewed publications.
Sharing high-quality information for education and building trust with governments are central to our strategy of ensuring regulatory decision-makers are fully informed. We will continue to make available the industry’s top experts—including the RIFM and Fragrance Creators network of over 1,000 scientific and technical experts. Equally important from a perfumer’s perspective is reinforcing the message that the fragrance industry is unique. We work with ingredients at very low concentrations—amounts that are much lower than anything that could reasonably be considered a risk when used as intended.
During the 2021-2022 state legislative sessions, Fragrance Creators Association tracked over 50 bills in 13 states related to chemical regulation directly impacting the fragrance industry. In the first two months of 2023 alone, we have tracked 32 such bills in 15 states.
Fragrance is important to consumers, not just for purchasing decisions, but in their everyday lives. Fragrance enhances our lives. It can provide pleasant aromas or mask malodors. It can aid in relaxation and memory recall.
Representing the majority of the North American fragrance industry, Fragrance Creators advocates for policies that help its 60+ member companies to collectively ensure the responsible advancement of the industry. Fragrance Creators will continue to work with lawmakers and regulators as we advocate for sensible legislation that encourages innovation and is framed around the latest science.
To aid in communicating about this important work, the Fragrance Creators Association recently published a White Paper called The Importance of Comprehensive Assessments in Evaluating Fragrance Ingredients.
In this White Paper are several examples that can be discussed with lawmakers, a detailed history of RIFM and how it operates, the techniques used in chemical risk assessments, and many more key points that support our position.