Well, you would have to stipulate what level would trigger a labeling requirement. You would also have to be prepared for the inevitable consequence – an apparently simple labeling requirement in Europe has caused what could reasonably be described as mass panic, as many manufacturers re-formulated, so they would not have to declare any of the “allergens” on their products. Sounds good, but some of the synthetic alternatives now used are equally allergenic, but are not restricted! And, the labeling requirement, as I mentioned before, has become a de-facto safety regulation.

Another approach would be to require all fragrance ingredients to be listed. It raises some new problems, but it could be done.

There is no evidence that I am aware of that synthetic fragrances are, as a group, more skin-reactive than essential oils, though there is much anecdotal evidence that synthetics are more likely to cause respiratory symptoms in sensitive individuals. At present, this issue is not being addressed by any regulatory agency, though it may be fair to say that those who are sensitive know to avoid highly fragranced products.

The issue is education. Ask 100 small, independent crafters making aromatherapy lotions what the specific maximum levels are for each of their ingredients…I guarantee you…few if any even know what you are talking about.

I personally don’t think we need a lot of new laws for cosmetics, but it sure would be nice if the FDA actually followed up on the laws that are already there.

Now a question, do you believe any of the 26 fragrance materials listed as an allergen in the European Union should be listed on product labels for consumer’s benefit? I ask, because I won’t buy ANY product that lists just “fragrance” on the label. If the product says fragrance, I assume it’s synthetic fragrance and I avoid them for both health and environmental reasons. If a product says something general like “scented with only essential oils”…I still won’t buy the product unless the EOs are specifically listed, because I am extremely allergic to lemongrass.

So I don’t have a problem with regulations that are “information” based. But listing a fragrance component on a label is different from making the use of that ingredient illegal, as the Colorado Bill would have done.