The EU Commission published a new piece of legislation (Regulation EU No 2017/1410) that prohibits the use of Hydroxyisohexyl 3-Cyclohexene Carboxaldehyde (HICC, trade name: Lyral), 2,6-Dihydroxy-4-methyl benzaldehyde (Atranol) and 3-Chloro-2,6-Dihydroxy-4-methylbenzaldehyde (Chloroatranol). These three fragrance allergens caused the highest number of contact allergies cases in past years, which justifies a total ban according to the SCCS and the EU Member States.
HICC is a very important fragrance ingredient and the impact of its ban is expected to be very high. BIORIUS recommends that you contact your fragrance suppliers without delay in order to schedule the reformulation of your fragrances.
Atranol and Chloroatranol are not fragrance ingredients per se but they occur naturally in Oak Moss (Evernia prunastri) and Tree Moss extracts (Pseudevernia furfuracea / Usnea furfuracea).
However, the impact of these bans is much less important for two reasons:
- Oak Moss and Tree Moss are typically used in high-end fine fragrances.
- IFRA, the International Fragrance Association, enforced Standards that restricts the level of Atranol and Chloroatranol at maximum 100 ppm in Oak Moss and Tree Moss extracts. Considering the typical dilution of these ingredients, the concentration of Atranol / Chloroatranol does not exceed 0.5 ppm in a fine fragrance. The EU Commission confirmed that this trace level is tolerable, which means that an IFRA compliant fragrance should not get impacted by this piece of legislation.
This new amendment to the EU Cosmetics Regulation (EC No 1223/2009) will enter into force on August 23rd, 2017. Given the exceptional difficulty to replace HICC, long transition periods have been granted by the EU Commission:
- From August 23rd, 2019 (2 years from now) only cosmetic products which comply with this Regulation shall be placed on the Union market (namely, no further placing on the market of non-compliant products after this date).
- From August 23rd, 2021 (4 years from now) only cosmetic products which comply with this Regulation shall be made available on the Union market (namely, non-compliant products are withdrawn from the market by this date).