Following the publication of an opinion (SCCS/1459/11) by the Scientific Committee on Consumer Safety in July 2012, the Commission recently put forward a set of measures intended to enhance consumer protection against any harm that might be caused by allergens in perfume. The ambitious measures include adopting a quantitative risk assessment (QRA) methodology for raw materials used in the manufacture of perfume. This would entail exposing consumers to different finished products, with use levels being fixed in such a way as to avoid the occurrence of allergies. A number of options have been proposed concerning the provision of information to consumers so as enable them to avoid allergens in perfumes. While the Commission’s proposals appear fair, achievable and proportionate (in terms of their public health benefits compared to their cost), careful consideration needs to be given to the operational and administrative burden that they would place on Europe’s perfume industry, which includes eight of the world’s top‐10 manufacturers of high‐quality perfumes and a large number of SMEs, particularly in the natural ingredients sector. Finding the necessary funding for the analysis methods and for procedures to notify partners along the value chain and consumers of the presence of allergens in perfumes will be a major effort for the perfume industry. A realistic time frame therefore needs to be set so that the industry can adjust to the new provisions.
— Is the two‐year time frame put forward by the Commission not inadequate, particularly in view of the large number of products involved and the complex properties of natural and fragrance‐producing substances?
— What legal framework will be put in place to ensure that the QRA methodology is implemented in a transparent and effective manner?
— How will the Commission ensure that the efforts European manufacturers are being asked to make are matched by similar efforts elsewhere in the world, so that our companies may enjoy a level playing field?
— Does the Commission intend to push for the introduction of internationally agreed protocols, methodologies and criteria, in order to promote a better understanding of allergens and ensure that the rules are applied in a uniform manner?