# IFRA-49 regulations



## dibbles (Dec 7, 2021)

This thread really made me start thinking about what I will do in May when the new IFRA regulations for maximum usage rate go into effect. Of course some will remain safe at the current usage rate, but some will have a reduced usage rate which might not be to my liking and some will no longer be considered skin safe at all. 

First I want to say I don't sell, but if I did I would without question adhere to the IFRA guidelines for safe usage rate. Since Bramble Berry is a vendor that has been updating their fragrance oils with the new usage rates available, and Midnight Waters is a fragrance oil that will dramatically change, let's look at that one as an example. Currently Midnight Waters has a usage rate of 5%, which will change to .4% - a huge difference. I've used that FO at 5% with no problems to anyone that I am aware of. Do I continue to use it at that rate until it's gone? Knowing that the usage rate will change, can I really feel good about making and using/gifting any more soap with that FO, even though technically it is still considered to be skin safe right now. 

I have a LOT of fragrance oils. Going forward I will only purchase FOs that are approved at a 5% usage rate or higher under the new regulations. But that doesn't help with the dilemma of what to do with the ones that I already have that will no longer be usable (or are they). I, of course, don't really know how many will be completely unusable. 

I'm just curious if any of you have been thinking about this, and what your views are. I think I'm going to have to learn to make wax melts, which I fear will be another deep rabbit hole.


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## CreativeWeirdo (Dec 7, 2021)

I've been contemplating the exact same thing!  I have no idea!


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## TheGecko (Dec 8, 2021)

I think it’s a bunch of male bovine excrement.


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## Mobjack Bay (Dec 8, 2021)

Here’s what I’ve learned about the IFRA standards and other regulations.  

According to this technical *document*, when data are available, IFRA determines lowest maximum acceptable exposure level to a fragrance component based on systemic toxicity, dermal sensitization or other endpoints. The standards take into account how the products are being used, for example, lotion versus soap and expected frequency of use.

If a new usage rate is based on the presence of carcinogenic compounds in an FO, the guidelines will help to reduce risk of adverse effects by reducing the level of exposure over time.  I think that we all know that toxicity testing often uses dosages that are much higher than those we would experience in normal use, but also that the risk of developing cancer goes up with the level, duration and route of exposure to a carcinogen, mediated by genetic factors, age (which affects ability to repair cell damage), overall health, etc. 

I doubt that suppliers are going to tell us why the usage rate for a particular FO has been lowered. That leaves us with the data sheets, assuming they’re available.  For Midnight Waters, the data sheets on the BB website provide a list of allergens that are “most likely to cause skin sensitivity” as well as California Prop 65 carcinogen ingredients, specifically styrene and beta-myrcene that were previously banned as flavor components in food.  The US FDA explains *here* that some bans “are a matter of law.”  “… the FDA cannot find as safe; i.e., cannot approve, the use of any food additive that has been found to induce cancer in humans or animals at any dose.”   Some might view bans as over protective, while others see them as protective of cumulative effects over time. 

I guess I will be using part of the winter break to check my FO usage rates against the new standards.  I currently use some EOs that have very low usage rates, but only in blends that have reasonable usage rates as calculated by EOcalc.  Blending might be a way to extend the use of favorite FOs that have lowered usage rates, but there would be some work Involved to get it right.


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## dibbles (Dec 8, 2021)

Blending is how I plan to use some of the FOs, and it is TBD if I will reorder those. The usage rate for BB Vetyver, for example, will drop to 2%, but I love it and it is one that blends well.


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## TheGecko (Dec 8, 2021)

The IFRA is NOT "law"...nobody from the IFRA is going to arrest me or fine me if I use XYZ FO at 5% instead of new 2.6%.  It's a "club", and if you want to be a member of the "club", you have to follow the rules of the "club" (see ifra-code-of-practice).  

Now it's not to say that it's not a "club" without any clout, the IFRA is recognized by many government authorities. An example can be found when the European Commission in 2017 banned the use of three molecules in perfumery based on concerns by the IFRA that they could cause skins in 1% to 3% of the EU population. In other words, because of something could, not would for sure...affect a very small number of people, that use a product containing that particular molecule, no one can use it. And since 80-90% of the perfume industry are members of the IFRA...that means no one else in the world can either.

Now I'm not a total rebel...I wear my seatbelt, I come to a complete stop at STOP signs...even in the middle of frickin' nowhere, but I'm not a sheep either. I honestly care about the products that I sell, I use good manufacturing processes, I have a couple of customers (old friends) that I made custom soaps for because they have skin sensitives, blah blah blah, but I've seen a crap load of waffling back and forth over the last 40+ on "this is bad", no "that is bad, this is now good" and yeah, I get it...the science can change as new technologies emerge and we have access to new information. But on the flip side...just because a large amount XYZ shot into a small rat causes cancer, doesn't mean that XYZ is going to cause cancer in humans. The human body is amazing and filters out and repairs itself on a daily bases.

As I said earlier...I think it's a bunch of male bovine excrement, but I will do the research.


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## Peachy Clean Soap (Dec 8, 2021)

Thx for the heads up' most important to follow the guidelines if @ all possible.  Great informative post.


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## dibbles (Dec 8, 2021)

@TheGecko I understand what you are saying and, since I don’t sell, I feel like using past experience and common sense for my own use will be fine. I will adhere to the new guidelines and will only buy fragrance oils with a safe usage rate in the % I like to use. I have decided I will not use fragrances (even now) that are changing to very low usage rates. I do wonder, for those that sell if this will affect insurance coverage if IFRA rates are exceeded. I don’t know as it’s not something I’ve ever looked into.


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## TheGecko (Dec 8, 2021)

dibbles said:


> I do wonder, for those that sell if this will affect insurance coverage if IFRA rates are exceeded. I don’t know as it’s not something I’ve ever looked into.



Why would it?  Again, the IFRA is NOT a governing body…they provide guidelines, but have no legal authority.


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## dibbles (Dec 9, 2021)

TheGecko said:


> Why would it?  Again, the IFRA is NOT a governing body…they provide guidelines, but have no legal authority.


I _know _IFRA is not a governing body. Just something that crossed my mind, but again, as I don't sell I don't have to worry about that.


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## Nona'sFarm (Dec 9, 2021)

Guess I'm glad I have very few fragrance oils, mostly use EOs at no more than the maximum rates.  I like the idea of blending for folks with excess FOs on hand.
I don't know the background for the changes. Just wondering out loud, if it was ok to use these fragrances before, why is it now considered dangerous? Did new research find problems we didn't know about before?  As someone who is allergic to a lot of things, I don't want to take a chance on harming myself or others.


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## paradisi (Dec 9, 2021)

For a view into how cynical IFRA are about fragrance, Procter & Gamble, who are major IFRA funders & manufacturers of synthetic aroma chemicals, have a big splash on their website about how supremely safe their own fragrances are, with a huge sad idiotic list of things they don't use in their fragrances, many of which have never been used in fragrance nor have any fragrance use, but have scary names or are otherwise "bad":

Fragrance Ingredients








						Fragrance Ingredients
					

Our goal is to publish fragrance ingredients for all our products in the US and Canada. Here you can find the fragrance ingredients list.




					us.pg.com
				




"Fragrance Ingredients
You will see that we do not use many common food allergens in our fragrances, including Animal Derived Materials, Egg Derivatives, Milk Derivatives, Gluten, Barley, Rye, Soy Derivatives, Fish or Shellfish" .. they also note they never use ox blood as a fragrance material.  Neither does anyone else, afaik.  But fear sells.

That level of fearmongering and anti-scientific nonsense from folks behind IFRA is alarming. That's who supposedly are telling us truthfully what is and isn't safe? Yikes.


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## SirSoapsAlot (Dec 9, 2021)

Nona'sFarm said:


> Guess I'm glad I have very few fragrance oils, mostly use EOs at no more than the maximum rates.  I like the idea of blending for folks with excess FOs on hand.
> I don't know the background for the changes. Just wondering out loud, if it was ok to use these fragrances before, why is it now considered dangerous? Did new research find problems we didn't know about before?  As someone who is allergic to a lot of things, I don't want to take a chance on harming myself or others.


They have been updating on EO's as well.


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## glendam (Dec 9, 2021)

When I buy a fragrance, I write down the IFRA % usage rate in a spreadsheet, along with other notes (vanillin, behavior...), and use that going forward.  I plan to follow that until I use up a fragrance and will not buy it again if it is no longer soap safe.  I do not make candles so I do not have much use for them outside of soap and lotions, but I suppose I can make wax melts or something like that.  Like you, I do not sell for the most part.  I wish there were clear instructions from the IFRA on what to do with existing fragrances, sort of a recall or specific instructions on what to do with items already in consumer hands.  But without that, and considering that soaps are a wash off product, I am not very concerned about it (for now).  The only thing I found was the below link, it is the SOP (standard operating instructions) for the new amendment, for the manufacturer's of the fragrances, and for they to notify their clients and work on making a new version of products affected (and it seems they are given 14 months to complete that).


			https://ifrafragrance.org/docs/default-source/ifra-code-of-practice-and-standards/ifra-standards---50th-amendment/ifra-50th-amendment-(att-02)-sop-for-implementing-amendments-to-ifra-cop-june-30-2021.pdf?sfvrsn=8c03de2_4
		

I started typing this when you first posted the thread and I see there are new messages posted now, so I will go read them now.


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## IrishLass (Dec 9, 2021)

I wrote the following in a post back in 2019 in regards to IFRA'a usage rates, and I have not changed my mind:

This is just me, but I personally don't give a whole lot of weight to IFRA's safe usage rates.....at least not since reading through my Essential Oil Safety book by Tisserand and Young. They have a few carefully chosen words to say about how IFRA is structured and how it goes about coming up with their 'safe' recommendations, some of which they strongly disagree with in their book and explain their reasons why. A tad bit too "sketchy" for me to want to give their (IFRA's) recommendations the full weight of salt that I used to. I understand that those in the EU have to abide by their recommendations, but I am very glad that the US has not adopted them as law here.

I stay within the vendor max use recommendations, most times needing to use only a fraction of the recommended maximum. For what it's worth, it's very rare that I ever go as high as 1 oz ppo. Between .3 oz ppo to .8 oz ppo is my usual range, depending on the FO. If any particular FO cannot 'make the cut' as they say, I mark it off my list of keeper FOs and don't ever buy it again.


IrishLass


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## cerelife (Dec 9, 2021)

When I first started soaping, it was pretty much just 0.5 to 1oz ppo for FO depending on the scent/your preference. Maybe I was just living under a rock, but IFRA standards weren't really a big deal in the soaping community until less than a decade ago. When vendors starting posting using rates, I adhered to them although soapers I know IRL (who sell) considered the guidelines rubbish. While I didn't disagree with the general consensus of "I've used this FO for years and it's never hurt anyone at my usage rate.", I chose to adhere to the IFRA guidelines and I will continue to do so with future purchases.
However - for the multitude of FO that I currently have in stock (some in multiple pounds) - I will continue to use these at the IFRA usage rate at the time of purchase.


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## TheGecko (Dec 10, 2021)

IrishLass said:


> I wrote the following in a post back in 2019 in regards to IFRA'a usage rates, and I have not changed my mind:
> 
> I understand that those in the EU have to abide by their recommendations, but I am very glad that the US has not adopted them as law here.



Actually, they don’t.  As I noted previously, the IFRA is a “club”…a guild or a forum if you will.  IF you want to be a member of the club (or guild or forum), you have to abide by its rules, but it’s not a governing body, it can’t make law, not even in the country that it is headquartered in.  But, as also noted, and exemplified here by those who say they will abide by their “guidelines”…they have some clout. Which led to the European Commission, who does have the authority to make law, banning the molecules based on what the IFRA “recommended”.  But as noted in the article @Mobjack Bay, governments can do their own testing and say “No, we disagree“ as the FDA did and life goes on.

Sort of.  There is a bit of a catch-22.

Let’s say that I am a company that sells fragrance oils and am headquartered in the US and the IRFA has just said that XYZ component cause butt pimples in lab rats.  The FDA (legal authority in the US) runs it’s own tests and says, “If you slathered your butt with a cream containing XYZ every night for 20 years it might cause butt pimples, but in soap, it won’t.”  But in the EU, the EC is worried about butt pimples so they ban the use of XYZ.  Here’s the catch-22…I can sell my FO as in in the US, but I can’t sell it in the EU.  And I can’t afford to have two different versions of the same FO just in case something happens and there is a mix up. So my choices are…quit selling the EU or reformulate.


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## cmzaha (Dec 10, 2021)

When I was selling I still did not worry about IFRA usage. I stuck with my usage rates and did not have any issues. Manufacturers of fragrances are Not required to have their fragrances tested with IFRA, it is a choice. When making lotions common sense and your nose will usually not let you over fragrance. With soap if you use too much fo it will leak out. Like IL for EO's I went by my Essential Oil Safety book by Tisserand and Young guidelines.


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## Nona'sFarm (Dec 11, 2021)

@IrishLass and @cmzaha ,

Is this the book you're referring to? Or is there one specifically for soaps and lotions?






						Essential Oil Safety: A Guide for Health Care Professionals: 8601300273297: Medicine & Health Science Books @ Amazon.com
					

Essential Oil Safety: A Guide for Health Care Professionals: 8601300273297: Medicine & Health Science Books @ Amazon.com



					smile.amazon.com


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## Saponificarian (Dec 11, 2021)

Considering where the funding from IFRA comes from, I think it’s all about business for them. This chemical is not profitable to produce anymore, let’s limit its usage and use something else…. Guess what, as rich as the funding companies are, they can afford to fund a research that support whatever agenda they are pushing.

Call me a cynic but I don’t trust that there is no profit behind everything IFRA does.


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## Mobjack Bay (Dec 11, 2021)

@Nona'sFarm yes, that’s the book.

While the IFRA guidelines may be overly stringent in some/many cases, they also help to raise awareness that there are chemicals in fragrance and essential oils that can increase the risk of skin sensitization, cancer or toxic effects under some condition(s). Common sense is not going to help us predict effects, like cancer, that take decades to develop.

So, what’s a soap maker to do?  The easiest answer is to stay within manufacturer/supplier guidelines, which in some cases may result in a very wide margin of safety.  Alternatively, we can try to learn more as a basis for informed decision-making.

Tisserand and Young’s book is a valuable resource to have on hand, particularly when using EOs. Just this morning I learned that beta-myrcene is common in nature, for example in lemongrass, rosemary, and pepper.  After presenting a review of scientific research (lab studies), they conclude the following: “the results of the [high dose, ingestion route] study have little relevance to human exposure“ and beta-myrcene can be “regarded as non-irritant, non-allergenic, non-toxic and antimutagenic.”  Good, I’m crossing it off my list of things to worry about.

I don’t own a similar reference book for the alphabet soup of chemicals, including those that are synthetic, in fragrance oils.  Is there such a book?  Without any additional information to inform my decision making, I‘m most comfortable with sticking with the usage guidelines provided by the suppliers.


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## IrishLass (Dec 11, 2021)

Nona'sFarm said:


> @IrishLass and @cmzaha ,
> 
> Is this the book you're referring to? Or is there one specifically for soaps and lotions?
> 
> ...




Yes, that's the one. 


IrishLass


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## cerelife (Dec 12, 2021)

Saponificarian said:


> Considering where the funding from IFRA comes from, I think it’s all about business for them. This chemical is not profitable to produce anymore, let’s limit its usage and use something else…. Guess what, as rich as the funding companies are, they can afford to fund a research that support whatever agenda they are pushing.
> 
> Call me a cynic but I don’t trust that there is no profit behind everything IFRA does.


My first thought with these new regulations was that this was just another attempt to cripple the handmade soap industry. 
While I understand and applaud continuing research to help keep us healthy, I find myself skeptical that the small amounts of FO that we use (particularly in a wash-off product like soap) would now be considered harmful. As @cmzaha said, we are limited in our media as to how much fragrance we can actually use and still have a viable product. 
After reading over these new regulations, it seems that the IFRA is basing these new usage rates on a combination of studies of dermal sensitivity and systemic toxicity with a new scale 'created by them' - did I read that correctly? 
How many times a day would you have to bathe to build up these effects? How much lotion would you have to apply? Are we even talking about reasonable human usage here? 
Even water can be toxic if ingested at unreasonable amounts.


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## Nona'sFarm (Dec 13, 2021)

@IrishLass and @Mobjack Bay , thanks so much for your response.
And for anyone interested, it is currently free to download on Kindle. Though I have to warn you that it is not configured well for online reading. So after perusing it, I will probably purchase a copy. 






						Essential Oil Safety: A Guide for Health Care Professionals: 8601300273297: Medicine & Health Science Books @ Amazon.com
					

Essential Oil Safety: A Guide for Health Care Professionals: 8601300273297: Medicine & Health Science Books @ Amazon.com



					smile.amazon.com


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## glendam (Dec 27, 2021)

I was looking at a cardamom fragrance at candle science and noticed this statement: which is similar to the IFRA linked information but seems more clear.


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