In February, EFA submitted its response to the European Commission’s Directorate General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW) public consultation on the labelling of fragrance allergen substances.
According to the Cosmetics Regulation 1223/2009, fragrance allergens should be labelled individually in cosmetic products such as soaps, perfumes and creams. This is to ensure clear information about the ingredients of the product to consumers with skin allergies, such as allergic contact dermatitis, thus preventing a potential allergic reaction.
62 fragrances to be found potentially allergenic
The initiative concerns the labelling of 62 fragrance substances often present in cosmetic products, which were found to be potentially allergenic. They are coming on top of the 26 that are already under this requirement.
In this respect, the Commission explores three distinct policy options for the information of consumers: (1) On-pack labelling, (2) E-labelling, and (3) no action at the EU level. The outcome of the consultation will inform the final decision by the Commission, to be adopted by the end of 2021.
The current response was the third occasion where EFA provided feedback on this topic. Previously, we had also been in contact with the European Commission in the context of two scoping interviews, conveying the message of skin allergy patients both at the EU and the national level.
Full on-package fragrance allergens list
While EFA supports e-labelling as complementary to the on-pack information, we think it should not a replacement. Only a full on-package fragrance allergens list can help consumers avoid harmful ingredients through timely and effective access to allergen information.
While digital solutions are welcome, exclusive e-labelling for fragrance allergens comes with certain drawbacks, including a pre-requirement for digital literacy, which ultimately shifts the responsibility to the consumer.
Moreover, e-labelling the 62 new allergens while leaving the current 26 on-pack fragments information untouched might potentially be misleading for consumers.
EFA emphasizes need for ability to avoid harmful substances
In its response EFA stresses that every patient should be able to avoid any substance harmful for their health. In this spirit, the option of ‘No action” would deprive the 30% of Europeans that live with allergies and airways diseases of their fundamental right to information.
EFA’s response to the European Commission public consultation on fragrance allergen labelling can be found here.