Reports are coming out that the EU has decided, at least for now, to continue to allow the low atranol version of oakmoss and tree moss while only banning moss that has not had the allergens atranol and chloroatranol reduced. Most perfumers (myself included) already switched to the low atranol version of oakmoss years ago when that standard was first set by IFRA, so there will be no change for us. IFRA not only requires the use of the low atranol type but also places a limit on the percentage of use of the low atranol type. Even at the IFRA level it is useful though, and I have the low atranol natural moss in many of my perfumes. I am glad to hear they are not banning it. Suppliers are actually getting better at removing atranol and chloroatranol to the point where it is difficult to detect any at all in the treated moss; I’m hoping as detection methods improve perhaps the low atranol moss will someday be deemed zero atranol moss and remain usable for the future.
The EU also decided not to implement the drastic restrictions on a number of ingredients, like citral and eugenol, that would have made it virtually impossible to use naturals anymore. They are going to conduct more research so this saga will continue, but at least the pace has slowed and better studies will be done.
Lyral (a synthetic lily of the valley ingredient sometimes referred to as HICC, short for hydroxyisohexyl 3-cyclohexene carboxaldehyde) will be banned. It was already heavily restricted and this move was expected, so I doubt anyone will be surprised. I do not use Lyral in any of my scents and never have used it, so this issue does not affect my formulations.
It sounds like the EU still wants to require labeling for over 80 allergens rather than the current 26, but they may allow the allergen listings to be made online rather than on the product boxes. There will still be a lot of work to comply with the EU rules, but this is overall very good news, at least for now. I think the great outpouring of concern over the proposed regulations helped persuade lawmakers to do further research before taking those drastic steps.
I’m not selling in the EU so these rules don’t technically apply to me at the moment, but I believe that the EU is setting precedents that may well migrate to the USA eventually. Also, the IFRA and EU ingredient regulations affect what is considered “currently accepted practices” for product liability insurance purposes, so the standards do have an effect on all perfumers whether directly or indirectly.
I will update if the news changes.