The Now Smell This blog had a discussion yesterday about the 43rd amendment to IFRA and I made a couple comments that I thought could use further explanation. The 43rd amendment keeps the usage rate for oakmoss at 0.1%, but any oakmoss used must have atranol and chloroatranol levels of less than 100 ppm. The only natural moss I know of that currently meets this standard is the new moss I purchased in early January from Biolandes. I had sampled it last fall and found it to be very nice, especially as compared to the synthetic alternatives, as I have mentioned on this blog a few times.
The synthetic options I have tried for oakmoss don’t really smell very close to real moss; Evernyl/Veramoss is a nice, sweet, earthy, slightly powdery smell, but it lacks many of the qualities of real moss (it has much softer character to me and misses the green and darker qualities real moss has). Givaudan Oakmoss substitute is not one I like, though maybe some other perfumers might like it. Orcinyl 3 is a synthetic that is supposed to work well together with Evernyl, but I have not tried that one yet. My search stopped with the Biolandes moss because it is a natural moss with the atranol/chloroatranol removed and it smells very much like regular natural moss. I had been skeptical that I’d like it since I’ve not liked other low-allergen versions of naturals I’ve tried (bergamot and lavender), but the moss is very nice and is so much better than the synthetic alternatives I’ve tried.
As a perfumer, I need to decide if I’m going to follow the IFRA guidelines (and there’s no choice about it if I want product liability insurance), and if I choose to follow the rules I need to find an alternative to the oakmoss I’ve been using. Since I like this new low atranol oakmoss and it should be safer from a sensitization standpoint, I bought a kilo and will be working it into my formulas. I took Jour Ensoleille off my list for now because it will be the first scent to be reformulated with the new moss; the oakmoss note is more important to that scent than to my others, so I’m starting there with the hardest one.
The reason I expressed some concern on NST about the 100 ppm ruling possibly being changed is because I’ve read a research paper that was part of the input that went into the 43rd amendment decision process, and that document suggested 2 ppm. Apparently they compromised on 100 ppm for the final ruling, but seeing that 2 ppm worried me. (That paper was called the SCCP, or Scientific Committee on Consumer Products, Opinion on Oak Moss/ Tree Moss, sensitization only April 15, 2008). The Biolandes moss shows no atranol or chloroatranol at all at a detection level of 50 ppm, but they need to measure it with a better detection level to document how low it really is.
So, from my viewpoint I think I’ve found a solution that will let me continue to create moss notes in fragrances. I think there is hope on this oakmoss issue because of the new low atranol moss, perhaps in combination with low levels of things like Evernyl. There are still many other restrictions being introduced on other ingredients in the 43rd amendment and I hope we can find solutions as we move forward, but I will be very sad if this is the end to many old classics. I’d love to see some exceptions granted for old classic formulas even though that’d be tough to decide where to draw the line. This is indeed a major blow to perfumery, but I think it would be unfortunate to just give up. There are still a lot of beautiful fragrances that can be made, and perhaps it’s not too late to find a way to save at least some of the old classics. The industry does listen to its customers even though the regulating boards don’t seem to be listening yet. I’m no expert on IFRA or these regulating organizations, so these are just my thoughts from dealing with the rules as they come along.
Edited to add:
Ayala just posted about the oakmoss issue today on her Smellyblog and is also using and liking this new low atranol moss, so I’m really glad to hear that! She also addresses the issues I was wondering about for why the big oakmoss panic for 2010?
And PerfumeShrine addresses the larger topic today concerning this latest panic about the 43rd amendment.