The reality is that the regulations squeezing the juice out of fragrances are complex, inconsistent, overlapping, hard to understand even for professionals and not black-and-white. They all stem from good intentions.
Most of the evil in this world is done by people with good intentions. T. S. Eliot
Are fragrance regulations evil? They certainly seem to be if you’re a perfumer, struggling to reformulate a classic scent to fit IFRA or a perfume fan whose favourite fragrance has been discontinued because it could not be changed without destroying it.
It’s very easy to cast IFRA in the role of the Bad Guy, but it really is not that simple. It’s complicated and nuanced. Understanding what is really going on with the EU fragrance regulations is tough.
I’ve written a long piece for Basenotes about the topic. It came out of sheer frustration – as some Basenoters of old will remember, I’ve had a long journey from a perfume enthusiast to perfumer, much of which has been documented here and in various blogs and articles over the years. In the sorts of jobs I do now, I have to understand what is really going on behind the scenes and therefore attend training courses and symposiums and whatnot.
I went to an IFRA day a while back now (must have been 2013!), hoping I’d come out of there a little wiser. Well, I suppose I did, but I also came out of there with pages and pages of notes and more questions than I went in with. It was obvious that many of the industry representatives in the room were frustrated about all the restrictions; didn’t feel that the EU’s actions – while well-meaning – were really protecting consumers as intended and just causing lots of extra pressure… and nobody seemed to be able to present a comprehensive overview of how all these parallel regulatory requirements fit together. So I decided to have a go at gaining a better understanding.
What became obvious was that there are no “good guys” and “bad guys” and that there were lots of inconsistencies, even loopholes, and the whole thing seemed in parts to be over-protective but in others, curiously obscure. I needed to learn more for my work anyway, so read through everything I could, asked subject matter experts to help spot errors in my facts (hence the fabulous Penny – who since has offered me a job; nothing to do with this piece, just the fact we’ve had a growing friendship and mutual respect over time and I happen to have skills which she can use).
I held back from finishing the article until I’d attended lots of extra training and spoken to many people who know more than I do.
And yet, any failings (such as the sad way in which this piece seems to have come across as scaremongering or propaganda to some of the Basenotes readers – or most confusingly, as a piece advocating the use of synthetics over naturals… that’s certainly not the message)… any failings are mine alone, and it’s been an interesting education to see just how tough it is to communicate complex topics like this from an informed position. The irony is that in order to understand something like this, one has to get knowledgeable enough that to many people one can appear like an industry shill. That I am not. My desire is to understand and I certainly don’t speak for the industry.
I hope this piece will generate healthy debate and discussion. I’m not the slightest bit offended by some of the more frustrated comments on the article; it is to be expected and I understand.
What I’d love to hear is your take on the final question I pose. “So now what?”
What do you all think would be a reasonable and realistic way to protect perfumes from over-regulation while protecting the consumers? Is it a totally naive idea to reason with the giant bureaucracy monster? Who do you think would be in the best position to protect the industry’s interests AND reassure consumers that their products are safe?