Petition to the EU regarding perfume regulation

Save Perfume’s Soul.” That is the plea behind a well-crafted, factually detailed, and heavily researched petition to the EU on the issue of perfume regulation. It has been put together by the people at, and I was rather hoping that a few of you may take a moment to sign it.

The petition begins with the following arguments:

The EU Commission should protect health, AND the cultural asset perfumery:

We, the undersigned consumers, hereby voice our objection to the amendment currently proposed, which would render colourless the range of European perfumery.

Accordingly, we strongly oppose any further ingredients restrictions.

Please be advised that we, the undersigned, support the contribution by the “Consumers’ initiative for the protection of perfumes as a cultural asset“.1 This contribution has been presented as part of the public consultation on fragrance allergens pursuant to Regulation EC No 1223/2009 on cosmetic products.2, 3

With our signatures, we request that the decision-makers obtain a comprehensive perspective beyond the scope of the narrow confines of the Scientific Committee on Consumer Safety (SCCS) opinion.4 This broad and complete perspective must include the following considerations and interests:

  • Consumer protection,
  • Cultural identity,
  • Economic considerations,
  • Consumer interests above and beyond mere health and safety.

I have to applaud the individuals behind this petition. They have clearly spent a massive amount of time doing their research, annotating the petition with links, and being very strategic about how they have presented things. I think my favorite part was when they used German governmental findings (from the German Federal Environment Agency [Bundesumweltamt]) against the EU bureaucrats in Brussels:

Research has demonstrated that it is impossible for an allergic event to be triggered through the use of perfume by a third party in proximity to a susceptible individual. The pertinent study, conducted by the German Federal Environment Agency [Bundesumweltamt], concluded that the mere act of inhaling potential contact allergens did not, in fact, result in the development of allergic symptoms by the test subjects.

From a legal perspective, I think it was also very astute of them to phrase one of the upcoming labeling proposals as the potential first step on the road to a de facto ban:

Three substances are currently scheduled to be prohibited under the proposed amendment (Lyral® and [Chloro-] Atranol, thereby oakmoss and treemoss). Further substances (including elementary substances such as Geraniol, Coumarin or Linalool) are to be labelled above the threshold of 0.001% in leave-on products. This miniscule allowance is tantamount to an outright ban in most cases, insofar as the concentration is so minute as to render the ingredient undetectable by the human nose in the finished product. A labelling requirement which demands that a trace amount of an ingredient be listed, is the first step toward a de facto ban, to the extent that the tiny concentration permitted is virtually undetectable. This would also affect about 90% of all essential oils because these substances are primary components. [Emphasis added by me.]

Legislators and judges are always very influenced by whether the indirect effect of something amounts to total exclusion, so I think they have been very strategic, indeed.

Signing the petition itself takes less than a minute, followed by another minute to check your Spam folder for email confirmation that you subsequently have to click on. That’s all it takes.

However, I wanted you to know that the Petition does require one to list one’s country of residency. I raise this only because I wonder if the EU would really care what someone outside its borders might think? Would they not be more convinced if the signatories all appeared to be EU citizens and, thus, from their voter base? Just to be clear, I’m not telling you to lie. Please follow the letter of the law. I’m merely raising the theoretical possibility that government legislators may care more if the signatories appeared to be their own constituents. Purely hypothetically, of course. I would never suggest that you … er… just casually … er… put down a different country than your own. Oh no, not at all.

At the end of the day, the bureaucrats in Brussels will do what they want to do, but a petition like this can’t hurt. So, please, if you can, sign it, spread the word, and pass it on.