The hazard communication of fragrance allergens must be improved

Abstract

Contact allergy is a global health problem that could be alleviated considerably if the general public could reduce contact to sensitizers. Efficient hazard communication would be a valuable instrument to achieve this. What do current regulations concerning fragrance sensitizers in cosmetic products in Europe contribute? For example, there are bans and restrictions according to the Cosmetic Regulation, there is the "26 allergens rule" that requires that the names of some allergenic fragrance ingredients are listed on the containers, there is labeling and classification of hazardous products according to Regulation 1272/2008, and there is the regulation concerning the registration, evaluation, authorization and restriction of chemicals (REACH). Do these regulations increase consumer protection by suitable hazard communication instruments? Four main problems were identified. First, according to the 26 allergens rule, consumers carry a very large part of the responsibility for risk reduction management. They need to be capable and motivated to recognize the names of strong allergens listed in the ingredient list and decide for themselves whether they want to run the risk or not, provided that they are aware of their responsibility. Second, cosmetic products do not need to be classified and labeled like other consumer goods, according to the European Commission Regulation 1272/2008, if they contain hazardous substances. Third, some pictograms for hazardous substances, for example, the exclamation mark for sensitizers, are not well understood by the majority of the general public. Fourth, very often, the design of cosmetic containers implies health and well being, even if the respective products contain sensitizers or other hazardous substances. Against this background, the following improvements are proposed: 1) the 26 allergens rule needs revision, 2) the exception for cosmetic products from labeling and classification should be abolished, 3) a new self-explanatory pictogram for skin sensitizers and skin irritants should become mandatory for consumer products containing allergens, and 4) packaging of products containing hazardous substances should not be allowed to be attractive and evoke feelings that the products were harmless. Labeling of consumer products can be a very efficient tool for risk communication, however, the addressees must be sufficiently trained to understand the system and know the consequences of their behavior. Transparent labeling will increase the credibility of manufacturers and can lead to a subsequent improved risk management with a benefit for all stakeholders.