You’ve heard the saying, “What they don’t know won’t hurt them,” right? In the world of flavors and fragrances, that isn’t necessarily true.
In 2016, for instance, Mother Jones magazine detailed the breathing difficulties that one New York-based library scientist said she had every time she came in contact with scented laundry detergent, which triggers her asthma. It’s not unusual. A 2009 study in the Journal of Environmental Health revealed that about 30% of survey respondents reported that they thought scented products were irritating, and 19% said they have experienced adverse side effects from air fresheners.
This is not surprising since some people display sensitivity or allergies to some specific chemicals that can be present in fragrances. These chemicals could have been added intentionally or are simply impurities that are naturally occurring in biological extracts. This is akin to food allergies, and while laws in many countries require disclosure of food allergens (soy, peanuts, tree nuts, etc.), this is not the norm for fragrance ingredients.
Consumer advocacy groups have been clamoring for more ingredient transparency for years, and the voices are only getting louder. In response to public and nongovernmental organization (NGO) demands, the International Fragrance Association (IFRA), which develops standards for the industry, lists hundreds of substances used by their members on its transparency website.
“To support our drive for increased transparency,” the association explains, “IFRA has published an alphabetized list of fragrance ingredients used by IFRA-affiliated members around the world. This list represents the industry’s palette of materials from which fragrances are formulated. We believe releasing information on our materials will help us in our efforts to communicate about the industry’s extensive safety program more comprehensively.”
Similarly, the Flavor and Extract Manufacturers Association lists all the flavoring ingredients it considers generally recognized as safe, better known as GRAS, on its website.
Additionally, large retailers have jumped on the transparency bandwagon as well. Walmart, for one, recently joined the Chemical Footprint Project, which encourages companies to disclose the chemicals in their products. In a similar vein, last January, Target declared it would use its market influence to push for full ingredient disclosures throughout its entire “value chain” by 2020.
Companies in the consumer goods industries have taken notice as well.
The likes of Unilever, which makes products like Dove soap and Axe body spray; S.C. Johnson & Sons Inc., which makes products such as Glade air fresheners; and Procter & Gamble Co. (P&G), which makes products like Tide laundry detergent and Herbal Essences shampoos, have all said they plan to disclose full ingredient lists in many of their products in the coming years.
“Our goal is to give people information that is clear, reliable and accessible. This is another step in our sustainability journey toward enabling consumers to make informed choices,” explained Kathy Fish, P&G chief technology officer, in a news release explaining the recent move toward transparency. “We want people to feel great about putting our products in their shopping baskets. We’re providing more information about fragrance ingredients because we believe this will build even greater trust in the quality and safety of all of our products.”
More Info, More Confusion
Today’s transparency push, of course, poses an interesting challenge for companies: How do they balance giving the public what they want to know vs. how do they keep their competitors from knowing too much about their intellectual property? It’s a gray area for sure, but what makes matters even more vexing is the potential for scaring off customers who are not used to seeing the full laundry list of chemicals in their products.
“We joke sometimes that we’re selling labels right now; we’re not selling products anymore,” said Jennifer Howell, senior manager of regulatory affairs, at FONA International, a flavor company based in Geneva, Illinois.
And with those expanded labels comes new challenges and complications.
“For example, lemon oil contains limonene,” Howell said. “If we were to disclose limonene to the customer, they get concerned that there’s a chemical in their food, even though it’s naturally occurring in lemon oil.… We’re disclosing more, but we also have to do a lot more education on what we’re disclosing.” It’s kind of like getting a glass of dihydrogen oxide to quench your thirst (water, that is). It sounds nasty for people who lack the scientific knowledge.
Other than the nature of chemicals, Howell says more FONA customers have started pushing to get information about the source of ingredients in their products—whether it is natural or synthetic, is grown from organic-certified sources or originates from a genetically modified organism (GMO), or not. Having that information “at your fingertips instead of having to ask your vendor who asked their vendor who asked their vendor will greatly reduce the cycle time of checking compliance for certain things,” she said.
For tracking ingredients, software plays a key role, and one would benefit from more sophistication than Excel® spreadsheets.
To meet its customers’ demands, FONA, for one, has considered taking a page out of the Bitcoin playbook and turning to blockchains to track ingredients. A blockchain is basically a decentralized database that is continuously updated with digital records and is visible to anyone in that network, according to The Blockchain Review website. When a transaction takes place, the information is grouped together and cryptographically protected.
In the flavors arena, it could “basically create a chain of custody throughout the supply chain with relevant information that can’t be modified,” Howell said.
Take an orange as an example. Say the fruit was grown in Brazil, but the flavor of the orange is later used in a consumer product such as gum in the United States. With this type of technology, the whole chemical composition could be completely traceable from the picked citrus product to the gum sitting in a package on a store shelf. This is an interesting concept at this point, but it could be a potential game changer for chemical transparency in the future.
More Stringent Regulations in Europe
The International Chemical Secretariat, a nonprofit organization based in Sweden dedicated to working toward a toxic-free environment, has been keeping track of chemicals on its “SIN” list for over a decade. For example, under “Health & Environmental Concerns,” the site lists everything from carcinogens to mutagens that should be avoided in any consumer product.
Keeping up with what needs to be disclosed can be a taxing process, too. Companies must be prepared sometimes 2 years in advance to get ready for regulations coming down the pipeline for chemicals that will be added to growing banned or restricted substance lists of carcinogenic, mutagenic, and reprotoxic chemicals, better known as CMRs.
But with that added scrutiny, the onus on companies to comply continues to intensify.
Xavi Gonzalez is based in Barcelona, Spain. He is the product safety and regulations deputy manager at KAO Corporation, a 130-year-old consumer product company headquartered in Japan that creates fragrances for personal care products and the like.
As he and his colleague, Nuria Casellas, a product safety regulator at KAO, explained: While European Union [EU] Registration, Evaluation, Authorisation and Restriction of Chemicals rules have led to more knowledge about chemical substances, chemical disclosure requirements have increased because EU (and non-EU) regulations demand more detailed information. There has also been an increase in the number of restricted or forbidden substances in recent years, which obligates suppliers to disclose more and more substances of our products.
“In the fragrance business, there are very complex formulas, and nowadays there are very comprehensive regulations,” Gonzalez said. “There are also a lot of client restrictions in addition to the regulations. We need a very flexible and a very powerful system to make all the calculations. I mean not only to produce the SDS [safety data sheet] and labels, and all the compliance documents that we need, but also in terms of delivering documentation to our clients who also impose restrictions. Then, for us, it’s very important to have an automated system that creates for us all the necessary documentation and certifications of compliance based on our formulas.”
For KAO, disclosures to clients often center around hazardous substances according to SDS, forbidden and restricted substances, and different regulations. “Sometimes the client makes their own restrictions and they say, ‘I forbid this or would like to avoid this ingredient,’ so we have to put customer-specific demands in our rules” he said.
After all, the transparency movement is just beginning to gain steam, and more and more consumer product manufacturers have gotten the message as we’ve seen with the aforementioned Unilevers, S.C Johnsons, and P&Gs of the world. And we believe the chemical transparency movement is only getting started.
The Price of Lack of Transparency
A 2013 report from The Regeneration Roadmap found that about 9 out of 10 consumers globally (88%) said “ingredient transparency is ‘extremely important’ or ‘very important’ for companies to address as part of their products, services or operations.” Additionally, 82% of those surveyed said transparency was important for food and beverage purchases as well as beauty and personal care and household items.
That said, only 57% said they “check the list of ingredients before purchasing products.”
However, a 2016 report from Label Insight, “How Consumer Demand for Transparency Is Shaping the Food Industry,” found that 37% of consumers said they would “be willing to switch brands if another brand shared more detailed product information that they could understand.” Additionally, 75% said they “do not trust the accuracy of food labels.”
So as chemical transparency begins to pick up steam in the flavors and fragrances fields, it will be incumbent upon manufacturers to offer up as much information as possible to ensure their market share stays healthy and that consumers won’t exercise their right to try out products with more information listed on their packaging. It will be a delicate balance, for sure, as companies look to please consumers but ensure the competition doesn’t get too good of a look behind the curtain at their intellectual property.
“We are using ‘trade secret’ provisions allowed in the U.S. to hide the identity of ingredients and keep our recipes confidential,” FONA’s Howell said. “But flavors are under a lot of scrutiny right now exactly because of that, because flavors are seen as a mystery ingredient and that we’re keeping information from the consumers because we don’t want them to know there’s something harmful in there that we’re not telling them about.”
But while the consumer perception might be that companies aren’t doing enough disclosure, the evidence points to a more transparent future in fragrances and flavors. Let’s call it the Transparency Transformation.
|Francis Trudeau has worked for nearly 20 years in product compliance and chemical management. He has significant experience in solutions management and development, global regulations, and industry standards enforced worldwide. He has worked on a wide variety of projects that support Sphera’s integrated information management solutions and address legal compliance challenges and the implementation of regulations in databases and software applications. Trudeau is a recognized industry expert, serving both as a featured speaker at international conferences and leading multiorganization task forces in establishing industry best practices for regulatory compliance.|