By Emil Panzaru, the Research Manager at the Consumer Choice Center.
New EU rules are coming after scented candles, perfumes, and wellness routines. The clean beauty cosmetics market has grown substantially as more European customers move from synthetic cosmetics to natural replacements. Put into numbers, the sector reached 2.29 billion euros in 2022 and is projected to surpass 3 billion in 2026. This growth is thanks to water or steam extracts called essential oils. Chances are your favorite sustainable make-up includes one of nine-hundred ninety-two such emulsions – some of which are household names like lavender, cinnamon, rose, and sage. If that were not enough, your preferred bio-degradable perfume most likely comes from one of the fragrances essential oils provide. Nevertheless, consumers should worry about the future of the industry. The European Chemicals Agency (ECHA) wants to move from a risk to a hazard-based assessment of essential oils, leaving the entire business in limbo.
For non-experts, ‘risk’ and ‘hazard’ may sound the same. They are, however, very different ways of thinking about regulation. Hazard assesses the characteristics of a substance alone to arrive at a recommendation; risk, too, looks at the nature of a compound before also considering probabilities and exposure levels. Less abstractly, it’s the difference between judging cars as dangerous per se versus looking at the chances of an accident to decide whether the situation threatens one’s safety.
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The consequences of each method are at odds, too. Where hazard will shy away from any material as long as there is even hypothetical proof that it is dangerous, risk assessment accepts that an item may pose a problem only after a certain concentration threshold has been exceeded. Using the same analogy again, it is akin to never hopping into a car out of fear of what could happen on the one hand and deciding to drive after establishing the safest route to go on the other.
The ECHA’s change of heart sees essential oils labeled as dangerous. So long as a single molecule (examined under the right laboratory conditions) becomes an issue, consumers will see a skull and crossbones on the beauty product’s packaging. Buyers then tend (research suggests) to avoid the items on sale.
Producers are consequently in a bind. They could look for alternatives to essential oils, yet most substitutes are already banned under EU regulation 2021/1902. So the option in many cases will be to pull out of the market altogether. As the dominoes fall, shampoos, shower gels, conditioners, foundation make-up, colognes, and deodorants are no longer available. Hazard-based thinking subsequently causes billions of euros in current and future revenue losses and leaves consumers with far fewer options.
The trouble does not end there, though. Several European countries are top producers of essential oils and will take the full brunt of the clean beauty market’s fall. Bulgaria is the world’s champion in rose oil extraction, responsible for distilling almost 2 tonnes of the material annually. Its 92 million euros worth of exports to France and Germany are now in danger. The loss would be another terrible blow to the EU’s poorest nation. France, the world’s third-largest producer of essential oils, sees 458 million euros wiped out thanks to the ECHA’s scheme. Italy is a crucial node in the global supply chain of one emulsion in particular – 95% of all bergamot oil is produced in the southern part of the country by a group of Calabrian families passing down techniques from generation to generation. Interrupting the trade will cost Italy upwards of 174 million euros and disrupt a way of life, all while throwing global trade into chaos.
Hazard cannot, therefore, wish trade-offs away, only worsen them. Giving up on a car will see you stranded when you need one the most; giving up on essential oils throws away valuable products and scuppers an entire business. Policymakers should encourage the ECHA to adopt a risk-based view, judging substances by safe use levels rather than all-or-nothing thinking. Now that is a wellness program all consumers can get behind.
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