'The Commission needs to accompany SMEs to implement SSbD' - interview with Chaima Elyahmadi, IFRA, and Annika Batel, BASF

IFRA represents the fragrance value chain in the IRISS project. We got the chance to interview them to hear more about their work with SSbD and what IRISS can do to support the development and implementation of the concept.

Hi Chaima Elyahmadi from IFRA and Annika Batel from BASF, a member of IFRA. Tell us about IFRA.
Chaima Elyahmadi: - IFRA, The International Fragrance Association, founded in 1973, represents the interests of the fragrance industry worldwide. IFRA comprises seven multinational Regular Members and 24 national associations in four global regions representing hundreds of small and medium-sized fragrance ingredient manufacturers, as well as supporting members. Its mission is to promote the safe use of fragrance for everyone’s enjoyment. Fragrances are a key platform technology used by consumer goods companies – for fine fragrances, personal care products, household care and more.

Who is the driving force for the IFRA Standards?
Chaima: - The IFRA Standards are at the heart of the fragrance industry's product stewardship program, ensuring fragrance ingredient safety in consumer products. These Standards, which may prohibit, limit, or specify purity requirements for certain ingredients based on scientific research, are obligatory for all IFRA members. Together with the IFRA Code of Practice, the IFRA Standards play a crucial role in promoting the safe utilization of fragrance ingredients and bolstering advocacy initiatives.

Annika Batel: - The development of the IFRA Standards involves numerous stakeholders and typically relies on safety assessments conducted by the Research Institute for Fragrance Materials (RIFM), which are then validated by an independent Expert Panel for fragrance safety.

- There are regular reviews of the safety assessments that may lead to setting a new standard or adjusting an existing one. Standards are only set in case the safety assessments cannot conclude that the current exposure is safe. If there is a need to restrict the use, the safety assessments derive specific thresholds for the use of the substance in different applications, that are much more detailed than usual exposure scenarios within REACH registration for instance. This way, IFRA ensures that each of the fragrance ingredients that ends up in any consumer product are used in a safe manner.

What are the topics being discussed within the fragrance value chain at the moment?
Chaima: - The introduction of new hazard classes, such as Endocrine Disruptors, under the CLP is a big challenge for industry and guidance is being developed to have a common understanding by all parties. Establishing criteria rooted in robust scientific research is crucial, especially considering the potential repercussions of restricting or banning substances. This becomes even more critical when aligning with other significant EU goals, such as the phasing out of animal testing, given that the identification and characterization of endocrine disruptors may potentially require the use of millions of animals.

In addition, the detergents regulation is under revision and some provisions under discussion would impact fragrance ingredients, notably in relation to the provisions on biodegradability. The REACH regulation has been delayed to the beginning of next year and will have a significant impact on the fragrance industry.

Annika: - What we are observing is a general shift into a more hazard-based approach and less focus on risk. The concept of Generic approach to risk management (GRA) introduced by the EU Chemicals Strategy for Sustainability illustrates this shift. This concept aims to ban and/or restrict substances based solely on their hazard profile rather than on risk.

-Regarding sustainability, I believe that there is room for us to accelerate our progress. We are currently engaged in discussions regarding data availability and transparency, with a primary focus on CO2 calculations. These discussions involve determining the elements to be calculated, the methods to be used, to ensure consistency across dataset, methods and results. However, we’ve yet to delve into other important categories such as e.g. biodiversity and water use. It is essential for us to broaden our conversations to include validation, harmonization, the establishment of a common data pool, and common data analysis to provide a solid foundation for future sustainability assessment.

Do you feel that it’s moving too fast?
Annika: - I think it’s good that it’s pushing, but in the end, we will have a huge set of data and results that are not even comparable and without any meaningful insights. It will not help in making the right decisions.

Is using biobased resources also being discussed?
Annika: - Yes, it’s a huge discussion, where we are also trying to move away from fossil-based sources and going into renewable biobased sources.

Chaima: - The fragrance industry is advancing on the development of a range of bio-based fragrance ingredients, which not only enhance product performance but also contribute to reducing environmental impact and optimize raw materials use, in line with the objectives of the circular economy. By exploring novel ways to source raw materials and enhance the sustainability profile of its fragrance formulations, the sector has made significant strides in leveraging biotechnology and bio-manufacturing for sustainable fragrance production.

Going into SSbD, do you feel that the concept gives more clarification or confusion? Does it push in the right direction?
Annika: - I have the feeling that the concept is too complex at the moment. It helps once you are pushing yourself and going into it and especially going into details. I think the aim is very good, but we need to go step by step.

Chaima: - As we implement it, we are finding that exchanging data along the value chain is challenging. When exchanging data from suppliers to manufacturers and to the final producer, sometimes suppliers get asked about LCA data without even understanding what LCA entails. Additionally, some data is sometimes considered confidential, and NDAs needs to be signed before any exchange can occur.

Annika: - In general, I think it’s a necessary and crucial progression. While we’ve made significant progress regarding safety, especially for fragrances but not only, there is a pressing need for more sustainability data and more knowledge. The sustainability part is by far not as advanced as the safety part. We need a more common discussion about sustainability: defining our focus, determining analytical methods and establishing protocols for transferring chemical data along the value chain. This final step is paramount. As Chaima noted, accessing information, even in Europe, is very challenging. Transferring that information along the supply chains to analyze the whole life cycle is critical.

BASF is a large organization that has the resources to start the assessments. What about smaller companies?
Annika: - They can’t do it; they rely on us. Our efforts are focused on encouraging the larger members of IFRA to take action and give them resources, which can then be shared with the smaller companies. I really hope that we can have some sort of guidance in the future that says “this is the SSbD approach that works for us” and also train our smaller companies to the downstream users. When we meet up with the smaller companies, they often seek guidance on the regulatory implications too.

Chaima: - With the Green Deal and the Chemical Strategy for Sustainability, we have raised the bar too high, necessitating significant innovation and resources. We have observed that only larger industries have the capacity to meet these demands, but the Commission also needs to accompany the SMEs to implement SSbD.

What can IRISS do to drive this in the right direction?
Chaima: - The initial step is to establish a clear definition. Implementing it is premature at this stage. It’s also important to have a harmonization in the terminology used across all regulations. IRISS can communicate about SSbD as an ongoing initiative. The industry is willing to help, and the Commission needs to accompany the small companies and to give further guidance. It should also be receptive to industry feedback. The framework needs to be more compatible with the chemical sector.

Annika: - IRISS can play a significant role in providing clarity on what is feasible and what is not through the completion of all case studies. I believe IRISS could help by outlining potential SSbD approach(es), tailored for various industry sectors, and what would be implementable. Additionally, IRISS can either help simplify it, define it in a different way or give proposals on how to communicate it.