Why Fragrance Disclosure?
For 80 years, fragrance suppliers have enjoyed special protections that allow fragrance ingredients to be kept secret from consumers, researchers, and regulators. Fragrance suppliers are not required by law to provide full ingredient disclosure to manufacturers or regulators. As a result, consumers get incomplete information regarding the ingredients in their personal care products, manufacturers are unable to provide consumers with the full ingredient disclosure they are asking for, and regulators are unable to determine the full scope of ingredients on the market being used to formulate cosmetics. American fragrance houses – and their trade associations – are desperately trying to hold on to this special privilege, even as other industries and European fragrance suppliers have become more transparent about the ingredients in their products.
As a 2018 BCPP report reveals, any product containing “fragrance” – a word representing a secret mixture of up to hundreds of ingredients – may contain sensitizers, allergens, respiratory irritants, carcinogens, endocrine disruptors, neurotoxic chemicals, or environmental toxicants. Even products labeled as unscented may have fragrance added to mask the smell of other ingredients. Consumers looking for fragrance free products have limited options. Hair product choices, in particular, are especially problematic: more than 95 percent of shampoos, conditioners, and styling products contain fragrance. Without required fragrance ingredient disclosure, it is impossible for consumers to avoid problematic ingredients or for researchers and regulators to understand the full universe of ingredients being used to formulate cosmetic products.
Lack of full fragrance disclosure negatively impacts consumers, manufacturers and regulators. The Research Institute for Fragrance Materials (RIFM), responsible for the bulk of fragrance ingredient testing, does not make all of its safety data available to those outside of the fragrance industry and, as a result, there is very little safety information on many fragrance ingredients in the public domain. The complete list of fragrance ingredients with potential allergenic, carcinogenic, endocrine-disrupting, or neurotoxic properties may be much larger than current estimates.
In September 2018, U.S. Rep. Jan Schakowsky (Democrat-Illinois) introduced the Safe Cosmetics and Personal Care Products Act of 2018, the only federal cosmetic safety bill that calls for full fragrance ingredient disclosure to consumers, manufactures and the FDA. The bill also requires supply chain transparency and industry data sharing to address the lack of safety data available for fragrance ingredients. Full fragrance ingredient disclosure will allow consumers to make safer and more informed decisions, benefit manufacturers who want to practice a higher level of transparency and provide regulators with the information they need to more effectively regulate the safety of cosmetic products. Full ingredient disclosure is needed now.
 Scheman, A., Jacob, S., Katta, R., Nedorost, S., Warshaw, E., Zirwas, M. and Bhinder, M. (2011) Hair products: Trends and Alternatives: Data from the American Contact Alternatives Group. Journal of Clinical and Aesthetic Dermatology, 4(7), pp. 42- 46.