by Wayne Willis
Under FDA regulations, “cosmetic” products (including shampoos and conditioners) must have a list of ingredients. In most cases, each ingredient must be listed individually. However, under these same regulations, fragrance ingredients can be listed simply as “fragrance” and not listed individually.
The reason for this exception was twofold: 1) Fragrances are often composed of a large number of aromatic natural and synthetic compounds, suspended in a complex mixture, and 2) they are often considered trade secrets.
Because all the components of a fragrance are not disclosed, consumers cannot know what’s included. Most importantly, consumers want to know if there are any compounds included to which they are sensitive or allergic. (Fragrance ingredients are disproportionately implicated when consumers have skin sensitivities, irritations or allergic reactions. This should not be surprising because these molecules need to be “volatile” in order to move into the air and be detected by the nose.)
Many times, cosmetic makers will declare what is NOT in their fragrance (e.g., no parabens, no phthalates) or what IS in it (e.g., some “essential oil.”) But unless the cosmetic maker declares ALL the ingredients, consumers won’t know for sure.
Frankly, most consumers simply to do not trust cosmetic makers. Consumers assume toxic ingredients are hiding in the “fragrance” catch-all category. Therefore, some consumer advocates urge consumers to shy away from any product that “hides” its fragrances under the catch-all “fragrance” category on the label.
So What’s In Illumai’s “Fragrance?”
When we started work on illumai in 2012, we tested several commercially available fragrances but noticed that some people had scalp sensitivities or irritations from those components. Then we tested “unfragranced” versions of illumai. There were no reports of sensitivities! We were delighted that the main ingredients in illumai’s formulations caused NO problems. (In fact, illumai cured several scalp problems among the testers.)
That was great, but users weren’t fond of the way the unfragranced version of illumai smelled. So, we commissioned a specialized developer of custom fragrances to create a proprietary formula for us, following a “brand brief” that specified that “the illumai scent” should connote “clean, fresh”, that it be neither citrus-y or floral, that it be subtle and not overpowering, that it not linger long, and that it not trigger ANY sensitivity, irritation, allergic reaction or other inflammatory response.
After about a dozen attempts, they created what we have now … a fragrance known by the codename “Whitney.”
Some people love the fragrance, some do not, but the metric I love is that we’ve had ZERO complaints of scalp sensitivity, irritation, allergic reaction or itchiness since Whitney was introduced in 2014. In the cosmetics industry, that is almost unheard of. I deliberately sent a free set of illumai to every person who had ever reported an issue from the earlier versions of illumai and asked them to test the version with Whitney. 100% said “no problem”.
Dr. Zasloff (science) and me (law) went through the list of components used in Whitney and satisfied ourselves that there were no bad ingredients included. Unfortunately, the fragrance developer still owns the formula, and we are under a non-disclosure agreement not to disclose the ingredients. I can tell you, though, that well over half of the formula is composed of natural orange oils (from different species), and the bulk of the remainder is composed of other “essential oils,” both natural and man-made. Last, because we wanted a very light scent, the entire fragrance component is less than 0.5% of the total weight of the product.
Legally, we cannot disclose more. What we have disclosed should be reassuring. But for anyone committed to the proposition that “the word ‘fragrance’ on a label hides what’s in it, and therefore, we want to avoid it,” we really can’t do more.
Additional Background.
The International Fragrance Association only allow fragrances marked as “natural” to contain ingredients that are truly natural (as, existing in nature!) or isolated from botanicals by purely physical means like distillation. It’s a very strict definition.
For example, lavendar’s fragrance comes from a molecule called linalool. One can get it by distilling it from lavendar oil or by synthesizing it from petroleum. Both molecules are exactly identical, but only the former can be characterized as “natural.”
When we commissioned the work to create our fragrance (project name “Whitney”), our goals were:
- do not interfere with the microbiome!
- do not provide a substrate on which pathogens might take hold. (This would necessitate our using preservatives, which would damage the microbiome.)
- do not create any sensitivity, irritation or allergic reaction i users. (Our prior product used a lemon oil based fragrance that had some a few people report irritation. We used those people to test Whitney, and none of them had any sensitivity or irritation.)
- be stable (don’t react with packaging or other ingredients, survive freeze/thaw cycles, maintain aromatic potency, have a long shelf life)
- deliver on the brand brief we gave them (which said “not fruity, not floral, but connote ‘fresh’ and ‘clean’ and ‘light.’ Be subtle, not overpowering, yet mask some of the somewhat unpleasant odors of some of the ingredients.
As you might imagine, achieving all these goals with ONLY natural botanicals was difficult (maybe impossible), especially the part about avoiding the common fragrance families of “fruity” or “floral.” The fragrance house said they could deliver Whitney by using a blend of natural ingredients and some ingredients synthesized from petroleum. The exact list of ingredients is confidential property owned by the fragrance house (and we are under an NDA), but I can tell you that the largest ingredients, by volume, are natural and the synthetic ingredients exist only in low concentrations, many of them less than 1 part per 1000. I also hasten to add that “fragrance” as a whole is less than 1% of the products, sometimes much less.
The largest component of Whitney, by far, is Citrus sinensis oil, which comes from oranges. It’s natural. I can’t tell you the precise concentration without violating the NDA, but it’s the dominant ingredient and is many times more prevalent than the next most common ingredient. The other natural ingredients are:
- Citrus nobilis (Mandarin Orange)
- Citrus limon (Lemon)
- Armoise oil [distilled from dried Artemisia herba alba herb (white wormwood)]
- Citrus bergamia oil (bergamot oranges)
- Pogostemon cablin oil (plant source of patchouli!)
That said, we are not an “all natural” fragrance, just like we do not have an “all natural” or completely “organic” list of ingredients. We are a blend.
While “natural” is a convenient shorthand for safer, more healthful and therapeutic, these consumer perceptions are not necessarily accurate. Our focus is to deliver a hypoallergenic, stable, attractive scent that does no harm. I believe we’ve done it.