(CAS Number 80-54-6, Chemical name 2/(4-tert-Butylbenzyl) propionaldehyde).
More commonly known as “Lilial”.
The Industry Position:-
As you will be aware The 15th Adaptation to Technical Progress (ATP) to the EU Classification, Labelling and Packaging, Regulation (1272/2008) Regulation, was published on August 11th 2020 in the Official Journal. It lists the formal reclassification of Lilial.
Simply put, Lilial will be banned for use in cosmetic products (skin, soap, bath, hair etc). It should be noted that whilst the ban on Lilial does not apply to Non-Cosmetic products (candles, melts, diffusers, room sprays etc), it is the case that REACH regulations also impose restrictions onto products being placed into the market, implying that Lilial should not be placed on the market or used within Non-Cosmetic products when its concentration within that product is greater than, or equal to 0.30%.
The time frames / significant dates to be aware of are as follows:-
Date of publication into the Official Journal (CLP) (aka “this is what we’re thinking of doing”) – 11th August 2020
Entry into force (aka “this is definitely happening”) – 31st August 2020
Ban on “making available” (aka no cosmetic products containing Lilial will be made available to end customers) – 1st March 2022. It is considered that the restriction on Lilial within Non-Cosmetic products to levels of equal to, or less than 0.30% will be actioned by the same date.
The Fragrance House Position:-
The fragrance industry as a whole has become in polite terms “very used to” regular legislation changes being placed upon raw materials and these changes in turn impact upon their existing fragrance oil (F.O.) creations and future F.O. creations. Fragrance Houses will have been made aware of the changes anticipated for Lilial and will have started to take action well in advance of the various deadlines noted above and in fact will have been aware of the possible changes before they were made public*. (1) Firstly they will have put policies in place to cease the creation of new F.O.’s containing Lilial. (2) They will also have looked toward sourcing and approving replacement materials for Lilial with the same fragrance character, the same technical properties and the same commercial considerations where possible. (3) Having sourced and approved replacement raw material(s) they will have set to work to modify existing F.O.s and for the replacement material(s) to become standard within their palette of ingredients going forward for freshly created F.O.’s.
This is a huge task for Fragrance Houses as each of them will have many thousands of F.O.’s that they have created over many years. Lilial is a material that has been used for decades and will certainly have been a “go to” material for many perfumers. The pressure from customers will have been immense – we seriously are talking here about global brands and every brand/company downwards that will be expecting to receive replacement F.O.’s very quickly, that smell the same, have the same technical properties and that don’t cost a penny more!
(*) As an example, I was working for a particular fragrance house back in the Summer of 2019 (nearly a year before the date of publication into the Official Journal) and we were already sourcing replacement materials for Lilial and creating F.O’s with them.
Note:- The above opinions are my own, based on 3 decades within the fragrance industry, but also based on regular conversation with my industry network and fragrance house partners with regards to the Lilial “situation”.
The Fragrance Liaison Position:-
When we first planned Fragrance Liaison back in early 2020 there were a number of “must have” considerations. Amongst these considerations were to partner with reputable and creative fragrance houses and also that we could ask them to provide us with F.O.’s from the very beginning that did not contain Lilial.
As time has worn on and we have at last approached “squeaky-bum” time as far as Lilial is concerned it is obvious that more and more questions are being asked, which is entirely natural. We have been very lucky that in asking for Lilial free F.O.’s from the very outset of Fragrance Liaison that we haven’t been put into a position of asking for modifications because we’ve been future-proof from the outset, and I’m truly grateful to our fragrance house partners in this respect. That said, because we didn’t need to do anything about it I think we’ve been in the position of not having to talk about it.. which has been a mistake, and I think that we should have done more to reassure you that you didn’t need to worry about Fragrance Liaison F.O.’s are far as Lilial is concerned… and I’m sorry for that, we should have said more, and not assumed that everyone knew.
Being mindful of getting complacent I regrouped with our Fragrance House partners and asked them to carry out a deep dive into the formulations of the F.O.’s they provide us that in turn are available to you just to check on Lilial one last time. I asked this as its often the case that perfumers use “mini fragrances” within F.O.’s …these are sometimes called Internal Bases, sometimes called Accords too. Basically it’s a way for the perfumer to have a “go to” set of pre-combined raw materials that they know will work every time – pretty much the same as going to a jar of Garam Masala and using it as a start point to add other spices and herbs to.
Both houses checked and I can confirm that of our 120 plus F.O.’s currently within our range all but 4 are as previously mentioned completely free of Lilial as we had requested and have been from the very first day of Fragrance Liaison trading.
As a result of the deep dive carried out by our fragrance house partners, they have determined that only 4 of our current oils contain Lilial at very low levels – those 4 F.O.’s being Black Leather, Fantasia, The Man & 5 and that the Lilial contained within each has been identified as a part of the Internal Bases – the Garam Masala bit.
Going back to the original context of Lilial being banned for use within cosmetic products such as soaps, skin, bath etc BUT being allowed for use within non-cosmetic products such as candles, melts, diffusers etc I am pleased to be able to confirm that all 4 of those F.O.’s contain Lilial at such low levels that (for example) in a wax or melt dosed with 10% F.O., the Lilial content in each of the 4 would be between 0.01% and 0.10%, which is permissible given the allowable level of up to 0.30%.
This means that whilst Black Leather, Fantasia, The Man & 5 cannot be used within cosmetic products such as soaps and skin, they CAN be used safely within non-cosmetic products such as candles, melts, diffusers, room sprays etc.
So, in summary:-
The vast majority of our F.O. range have originally been created with the requested exclusion of Lilial in mind from the very outset of Fragrance Liaison. ..and I apologise, I should have reassured people regularly of that fact.
All additions to our range since our launch have been created with no Lilial contained within, at all.
All future additions to our range are and will be created with no Lilial contained within, at all.
As a result of the deep dive, it was revealed that 4 of our F.O.’s – Black Leather, Fantasia, The Man & 5 contain internal bases that contain Lilial at small levels. Lilial is contained within these for oils at levels which allow the oils to be used within non-cosmetic products such as candles, melts etc. These 4 oils cannot be used within cosmetic products such as soaps, skincare etc.
I can appreciate that customers may feel concerned at the prospect of using any or all of these 4 F.O.’s within their candles, melts, diffusers, room sprays etc. given the complexity of the situation. However, the legislation is clear.. F.O.’s containing Lilial can be used for non-cosmetic products as long as the end product contains Lilial at less than 0.30%, which it will assuming accepted normal F.O. dosages and IFRA guidelines are followed.
The product pages of the 4 oils noted above have all been updated to clarify where they may be used and where they may not.
I really hope the above is useful and clear (I know I can waffle, but this one is worth the waffle!). If you have any questions please do feel free to contact us through email here, or though your preferred social media route.
Take care, Steve