Re: Don't know how I missed this story that includes EU/E.O. commentary

[Guest guest]

Anya,

You are human, and you too have to have a life... That's how you missed

it...

Sides, give yourself some credit woman you have a lot of irons in the fire.

(and remember to stop and smell the rose oil.)

[Guest guest]

http://www.nytimes.com/2007/11/20/business/worldbusiness/20cosmetics.html

> page two is where you'll find the comments on the threat to E.O.'s ...<

Sigh....

This is happening in herbal medicine, as well, and under the same

guise of " testing " . It's a tough issue, because I don't think anyone

can find fault with consumers wanting to be 100% sure of what is in a

blend, either medicine or perfume, but from the perspective of the

manufacturers, the new requirements are just impossible.

As the article notes that the new regulations would sweep aside

smaller companies, the FDA admits in its own documents regarding the

new herbal regulations:

" It is possible that a large number of these very small and small

establishments would be unable to absorb the compliance costs and will

close. "

As an herbal extract manufacturer, I am facing these regulatory

changes right now- and I am looking at how in the heck I can afford

the estimated $62,000 per year I will need to spend to comply. I could

rant about that forever, but what I would really like to point out

here relevant to perfumery is that the state of the IFRA/EU

regulations right now looks very much like the herbal regulations

several years ago.

Like the perfumery issue, the dietary supplement regulations started

in Europe, and seemed unlikely to be implemented in the US, with our

freer and more independent culture. Then, they did come here, but only

as regulations that had to be met to remain a member of the AHPA

(American Herbal Products Association). So what, everyone said, I just

won't join the AHPA.

Now, these regulations are law applied to everyone, and none of us

smaller companies are ready because we thought it couldn't happen. I

don't want to depress everyone, but I see so many parallels here in

the progress of the regulation. I know Anya and other folks here have

worked hard to make sure everyone knows how serious the IFRA

regulations are for all of us, but I just wanted to add my two cents

worth as someone looking down the wrong end of a similar regulatory

process that is further along.

Strength & Wisdom,

leavesofjoy

www.al-kemi.com