Vol 2   Issue 1    No 1

January 2006 

The Independent Watchdog

 for Endangered & Vulnerable

 Natural Aromatic Products used

in the Aroma (Perfumes,

Flavours, Aromatherapy, Cosmetics),

Herbal, Traditional Medicine & Phytochemical Industries.

Editorial Comment

Welcome to the second Cropwatch newsletter.   As we enter 2006 it is already evident that (a) small steps of progress towards many of our mutual goals has been made but that (b) the workload is increasing. The vendetta against Natural Products gathered pace in 2005 as (in-)‘expert’ committees worldwide responsible for safety matters demonstrate their inability to see ‘the big picture’ and become more susceptible to industrial lobbying and biased scientific data. The EU Commission itself has clearly shown that in the aromatic and natural product areas, their safety aims and the policies of major trans-international concerns are one and the same, with no opportunity for a non-industrial voice, or even the concerns of smaller industries, to be listened to. This situation is building up considerable anger and resentment as obedient professional trade committees are seen to be fawning & powerless in the face of these governmental policies which are so enmeshed in procedural obligations, that they fail to properly represent an opposing point of view to senseless draconian safety proposals that take ‘the precautionary principle’ to a ridiculous level. The question  now  is – whose side exactly are these committees on? Cropwatch takes a look at a wide range of issues in this second Newsletter, expressing the views of many informed people who would otherwise be cowed into silence.


Natural Aromatics & Baby Care Products – New Restrictions?

Khat Ban? What Hope for Ethnic Practices in the UK?

Natural Perfumery


Opinion: EFFA Shows Signs of Schizophrenia

  Cropwatch's Message Influences the EU

The EPA ‘s (non) Protections for Subjects in Human Research  

Tea Tree Update: EU Officials Use Circular Arguments.

Oranges and Pesticides.

Cropwatch Red Tape Award for 2005.

The Standardisation of Natural Ingredients: A Good Thing?

Natural Aromatics & Baby Care Products – New Restrictions?

The European Cosmetic Toiletry and Perfumery Association (COLIPA) are currently looking at the Opinion which lead to the press releases from the French Agency for the Medical Safety of Health Products (AFSSAPS) on 3rd December and 28th December 2004, concerning the withdrawal of cosmetic products containing essential oils which contain the susbstituents camphor, menthol & eucalyptol. You might remember that previously, following trans-international concern, Proctor & Gamble withdrew Vicks VapourBalm, a product designed to be rubbed into the chests of babies of age 3 months plus to relax them. The product was withdrawn because of the alleged neurological side effects of cosmetics containing camphor and eucalyptol (the latter coming from Eucalyptus oil). The side effects of concern were said to include the possibility of convulsions in infants. However Cropwatch believes the risk associated with these oils is negligible when used correctly, and anyway, the matter has previously been exposed in the essential oil-users world where for example, an alleged relationship between inhalation of the vapour of camphor and eucalyptol containing essential oils and epilepsy has been revealed as an ‘Urban Myth’ (see point 8 below). Nevertheless the Committee on Herbal Medicinal Products meeting in March 2005 had a preliminary discussion on herbal preparations for external use containing camphor, Eucalyptus oil, Mint oil or Peppermint Oil.  It seems that Hazard Communication Working Subgroup (HCWG) on Naturals is to list all essential oils containing these constituents, and to co-ordinate with COLIPA.

Literature on Seizures & Oral Toxicity Hazards from EO’s.

Since many “expert” safety committees seem over-rely on doubtful published papers from literature searches for their opinions, and often do not properly evaluate the scientific rigour of the work, it might be as well to take a whizz through some publications in this area. For the purposes of this short feature we are just going to concentrate on a few items mainly drawn from the alleged seizure and oral toxicity hazards for Eucalyptus and other oils.

1.      Whitman & Ghazzizadeh (1994) claimed that the oral toxicity of eucalyptus oil is due to the presence of hydrocyanic acid (prussic acid)!  This claim is quite unbelievable, since medicinal quality eucalyptus oils are prepared from the crude oil employing a second (rectification) stage involving distillation over 1-2% sodium hydroxide to destroy the unpleasant aldehydes, which would also destroy any hydrocyanic acid content. However this mistaken belief is further quoted by Darben et al. (1998) in a paper on topical eucalyptus oil  poisoning.

2.      Darben et al. (1998) report on a single case of the systemic toxicity of eucalyptus oil (botanical origin not stated - presumably from Eucalyptus globulus) in a six-year-old girl. In the discussion they report the dearth of data on eucalyptus systematic poisoning and that paediatric cases “often progress to unconsciousness and short-lived generalised convulsions that are less common in adult cases”. This latter comment seems to solely derive from a reference attributed to Gurr (1965). 

3.      Burkhard et al. (1999) summarised the literature on epileptogenic properties of plant-derived essential oils, and identified eleven oils which were “powerful convulsants”, the oils being eucalyptus, fennel, hyssop, pennyroyal, rosemary, sage, savin, tansy, thuja, turpentine and wormwood “due to their content of highly reactive monoterpene ketones such as camphor, pinocamphone, thujone, cineole, pulegone, sabinyl acetate and fenchone” (no prizes for spotting several scientific errors made by the authors in this brief quote). The authors further reported in detail on three cases (2 adults and a child) involving isolated tonico-clonic seizures involving essential oils, the two adult cases resulting from oral over-dosing with sage essential oil (botanical sources not indicated). The authors fail to point out that oral intake of neat essential oils is not recommended by professional bodies including CAM organisations. Millet et al. (1981) had previously looked at tonico-clonic seizures in humans in 8 cases where essences of sage, hyssop, thuja & cedar were involved, further revealing that in unanaesthetised rats, cortical events are only sub-clinical at 80mg/Kg for hyssop oil and 300mg/Kg for sage. Convulsions appeared at 130mg/Kg for hyssop and 500mg/Kg for sage oil. The toxicity of each oil was ascribed to the presence of ketones, but the authors did not mention the fact that these were relatively large doses of essential oil which in a parallel human context, would only be likely to be encountered in cases of accidental ingestion.  

4.      In spite of the title (see references!) Webb & Pitt (1993) investigated forty-two cases of eucalyptus oil poisoning in SE Queensland in children under fourteen, included four who had allegedly imbibed more than 30 ml eucalyptus oil. The authors reported that no child required life support, symptoms were treated asymptomatically (no reports of convulsions) and the authors concluded that eucalyptus oil may be a less toxic compound than had previously been believed.  

5.      Tibbals  (1995) undertook a retrospective analysis of 109 cases of eucalyptus oil poisoning in infants & young children (all patients recovered). Tibbals concluded that ingestion of eucalyptus oil manifested in significant morbidity in infants and children. The author also remarked that hazardous treatment and over treatment was common.

6.      Tibbals & James (1995) reviewed the uses of eucalyptus oil in OTC medicines as a congestant, airway dilator, expectorant, anti-tussive and a rubefacient, concluding that objective evidence for these actions was lacking. The authors recommended that the medical use of eucalyptus oil be abandoned, which would have the secondary effect of reducing the incidence of child poisoning. Cropwatch maintains that the review of the published evidence on eucalyptus oil was incomplete (only 28 papers referenced) and that beneficial effects can be demonstrated in a more thorough exercise.  Day et al. (1997) studied Eucalyptus oil poisoning in 109 cases involving children in Victoria, Australia over a 9-month period. A telephone survey showed eucalyptus oil was a leading agent associated with hospitalisation of the under 5’s, and 90 incidents (of the 109) involved vaporiser solutions. In these cases 74% gained access to the agent through a home vaporiser unit. The authors recommended a series of safety measures to reduce the incidence of these events. 

7.      Koren (1993) in a paper entitled "Medications which can kill a toddler with one tablet or teaspoonful." lists camphor, chloroquine, tricyclics, phenothiazines, quinine, methyl salicylate (= wintergreen oil) and theophylline as being potentially fatal to a 10 kg child who orally ingests one commercially available dose unit. Koren further reports that these substances were responsible for 42% of fatalities following acute ingestion in young children under 2 years in the US between 1983-1989. As a result of perceptions of the toxicity of camphor, as early as 1980 the FDA had limited camphor levels to 11% in consumer products such as topical lotions and moth repellents, whilst at the same time totally banning products labelled as camphorated oil, camphor oil, camphor liniment, and camphorated liniment. Camphor is readily absorbed through the skin and mucous membranes, and is present in many essential oils, such as rosemary, sage and lavandin oils. As little as 5ml camphorated oil (which was probably 20% camphor in cottonseed oil) taken orally has killed a small child (Smith & Margolis 1954). Cropwatch is not aware of any adverse effects from camphor, menthol or eucalyptol containing essential oils used in aromatherapy massage, where 10-20 ml max. of a diluted oil (say 2% in vegetable oil) might be applied during a normal whole body massage. 

8.      Robertson (1991) brought some editorial sanity to the subject of reports of toxins that are not really that toxic, at the end of an article on by Temple et al. (1991) on the management of citronella oil poisoning in a back issue of the journal Clinical Toxicity. He remarks that “those proverbial seizures (of which one hears much but sees remarkably little)… ought to be easily manageable should they ever occur.” Robertson further sides with the authors in agreeing that the possibility of poisoning with citronella oil is remote and text-book-recommended interventions may actually add risk to the situation, preferring dilution and symptomatic treatment if necessary instead. Similar remarks may well apply to accidents involving children swallowing small amounts of essential oils containing menthol and eucalyptol, where few seizures are ever actually recorded, but safety experts seemingly always refer to them. Symptomatic treatment may be the most appropriate response here also.   


The safe use of essential oils containing eucalyptol, menthol and camphor has been demonstrated by their continued popular use for more than a century and a half. Papers listing cases where unsupervised infants & children have accidentally imbibed small amounts of essential oils from aromatherapy nebulisers, or from retailed bottles of single essential oils not fitted with childproof closures, have been listed above. Few fatalities are recorded, and common sense counter-measures for prevention have been suggested by Day et al. (1997).  A very few instances where mature individuals have deliberately (but misguidedly) taken essential oils such as sage oil orally are also known, and more education to outline the risks of this practice are needed.

Looking ahead, presumably if opinions on ketone-containing essential oils in cosmetics are generated by COLIPA in line with AFFSTS thinking, and this is allowed to influence EU legislators, the prospect is that baby care products (at least) may not be allowed to contain a number of essential oils which contain menthol, camphor and eucalyptol over a limiting concentration threshold. Whether this prospect would be anything more than over-reaction is a subject for discussion, since few cosmetic preparations will contain amounts of these substances which would constitute a hazard via their bioavailability from cosmetics following topical application.  As an aside, you might remember that COLIPA put forward an Opinion in 2002 that tea tree oil should be limited to 1% concentration in cosmetics, and look how wrong that advice looks now…

So…stand by for some more unnecessary red tape from Brussels! 


Burkhardt P.R., Burkhardt K., Haenggeli C-A., Landis T. (1999) “Plant-Induced Seizures: the Reappearance of an Old Problem.” J. Neurol 246, 667-670


Darben T., Cominos B & Lee CT. (1998) “Topical Eucalyptus Poisoning” Australian Journal of Dermatology 59, 265-267.


Day L.M., Ozanne-Smith J., Parsons B.J. Dobbin M. & Tibbals J. (1997) “Eucalyptus Oil Poisoning among Young Children: Mechanisms of Access & the Potential for Prevention” Aust NZ J Public Health 21(3), 297-302.


Gurr E.W. (1965) “Eucalyptus oil poisoning treated by dialysis and maternal infusion” Australas. Ann. Med. 14, 238-249.


Millet Y., Jougleurd J., Steinmetz M.D., Tognetti P., Joanny P. & Arditti J.(1981) Clin Toxicology 18(12), 1485-98.


Koren G. (1993) "Medications which can kill a toddler with one tablet or teaspoonful." J Toxicol Clin Toxicol, 31(3), 407-13


Robertson W.O. “Editorial Comment” Clinical Toxicology 29(2), 263.


Smith A. & Margolis G. (1954) "Camphor Poisoning" American Journal of Pathology 30, 857-869.


Tibbals J. (1995) “Clinical effects & management of Eucalyptus oil ingestion in infants and young children” Med. J. Australia 163(4), 177-80.


Tibbals J. & James A. (1995) “Eucalyptus Oil – Medicinal Therapy or Folk Remedy?” Austr J Hosp Pharm 25(6), 516-519.


Temple W.A., Smith N.A. & Beasley M. (1991) “Management of Citronella Poisoning”  Clinical Toxicology 29(2), 257-262.

Webb N.J. & Pitt W.R. (1993) “Eucalyptus oil Poisoning in Childhood: 41 cases in SE Queensland” J. Paediart. Child Health 29(5), 368-71.


Whitman B.W. & Ghazizadeh H. (19940 “Eucalyptus Oil: Therapeutic & Toxic Aspects of Pharmacology in Humans & Animals” J. Paediatr. Child Health 30, 190-1.

 Additional Reading

Spoerke DG et al. (1989) “Eucalyptus Oil: Fourteen cases of Exposure” Vetinary & Human Toxicology 31(2), 166-168.


Steinmetz M.D., Vial M. & Millet Y. (1987) “Actions de l’huile essentielle de Romarin et de certains de ses constituents (Eucalyptol et Camphre) sur le Cortex Cerebral de Rat in  Vitrio” J. de Toxicologie Clinique et Experimentale 7(4), 259-271.

Khat Ban? What Hope for Ethnic Practices in the UK?

The 24 hour availability of the dangerous drug (ethanol), the excessive use of which causes strife, misery, serious illness and death - has become a reality in some places in England. The sad departure of the much-loved & respected footballer George Best this month cannot better illustrate one person’s tortuous struggle with ethanol addiction. So, the UK Home Secretary Charles Clarke, has asked the Advisory Council on Drugs to investigate ….err… err.... no, not anything to do with alcohol dependence, but alleged problems with the minor use herbal drug khat!

Increased alcohol availability, of course, comes in the form of changes to the licensing laws from 23rd November 2005, which allows the opportunity for  extended opening hours in English public houses. Excessive drinking can cause liver damage, pancreatitis, nutrient deficiencies, brain damage and a host of other serious health problems. Such is the average European’s exposure to this particular drug, that our bodies have genetically evolved to reduce its effects, by producing the enzyme called alcohol dehydrogenase in the liver, but since only 50% of Asian peoples produce this enzyme, it makes alcohol consumption a potentially more unpleasant experience for some. The chewing of khat leaves from the shrub Catha edulis Forsk. is an alternative to alcohol for many Muslims, and is said to lead to feelings of euphoria, alertness and the improved ability to communicate (that’s more than I ever got from a couple of pints of Bass! – TB). The plant is cultivated in Ethiopia, Kenya, Djibouti and Yemen, and chewing the leaves is a common sociocultural phenomenon in East Africa countries, and in the Arab Peninsula, although its use is arguably most common in Yemen. Burns (1999) suggested that khat chewing (and the large amount of time taken for working individuals to procure it) is one reason why Yemen is one of the 20 poorest countries in the world. For UK consumption, fresh leaves are flown in and are easily obtainable from markets in the Midlands, and to our certain knowledge khat has been legally available here (and in Holland) for over 20 odd years, although it is illegal in France, Switzerland & Sweden as well as in Saudi Arabia (Dhaifalah & Santavy 2004). According to Travis, khat leaves are also apparently banned in USA, Canada and Norway (Travis 2005). However and apparently conversley, Dhaifalah & Santavy (2004) maintained that khat leaves are in fact legal in USA & Australia.

Khat leaves contain the alkaloids cathine (norpseudoepedrine) & cathinone (S-(-)-alpha-aminopropiaphenone), the latter behaving as a amphetamine-like sympathomimetric amine producing CNS stimulant effects as well as cardiovascular effects (increased blood pressure & heart rate)(Al-Motarreb et al. 2002). Both cathine and cathinone are classified as class C drugs; Hughes (1973) suggested that a portion of khat is equivalent to a 5mg dose of amphetamine. So - why has Mr. Clarke got it in for khat all of a sudden? According to Travis (2005), it seems that a study by NACRO, the crime reduction charity, found that 49% of Somalis wanted it made illegal. Conversely 35% indicated it helped retain their cultural identity (although Cropwatch predicts that this view although possibly involving Human Rights issues, won’t be listened to). Refreshingly, Dhaifalah & Santavy (2004) describe khat chewing within a socio-economic and political context, rather than a narrow purely toxicological perspective and lack of pluralism that we are used to seeing from Western toxicological ‘expert’ committees.

There are plenty of studies that indicate the negative health effects of excessive khat use (but probably not as many as those available on alcohol abuse). At the moment we won’t go into that here. But, considering that the UK Government has a vested interest in alcohol sales via the exorbitant taxation of alcoholic beverages, but makes nothing for its coffers from khat, Cropwatch predicts that khat will inevitably be banned. Watch this space…


Al-Motarreb A., Baker K. & Broadley K.J. (2002) “Khat: Pharmacological & Medical Aspects and its Social Use in Yemen” Phytother. Res. 16(5), 403-413.

Burns J.F. (1999) “Khat-Chewing Yemen Told to Break Ancient Habit.” New York Times 19-09-1999.

Dhaifalah I. & Santavy J. (2004) “Khat Habit & Its Health Effect. A Natural Amphetamine” Biomed. Papers 148(1), 11-15.

Hughes P. (1973) “Khat Chewing in Yemen” in International Council on Alcoholism and Addictions (ed.). Abstracts of the 4th International Institute on the Prevention and Treatment of Drug Dependence, Lausanne, Switzerland p32-46.    

Travis A. (2005) “Ban on Khat Possible after Poll of drug’s Somali Users.” Guardian Monday 28.11.05

Natural Perfumery

In the early days of aromatherapy, essential oil sales-people were quite sniffy about selling product into this market. As Aromatherapy steadily grew in popularity over the years, eventually to account for some 7-10% of the total volume of essential oil sales, needless to say the attitude of these sales-people  changed. Now the bubble for Aromatherapy has burst somewhat in the USA, and arguably, Natural Perfumery has taken its place. But, and this is a big but, the practicising new perfumers have bought what skills they learned from aromatherapeutic blending with them, lending an almost spiritual goal to their work. So, for some at least, its’ not the same game anymore. Old-school Corporate perfumers such as Luca Turin [as revealed by his blog (Turin 2005)] have, in Cropwatch’s opinion, shown a lack of awareness of this change and cling to their own highly judgemental criticisms of craft levels in this area as a way of maintaining their imagined high place in some grand pecking order. But times have changed. Natural Perfumery is about exploring the art of the possible and doesnt need such negativity - especially from someone so intimately connected with the marketing of 'safe' synthetic aroma chemicals. Instead of publically pouring cold water on their hopes and aspirations, Natural Perfumers need support, guidance, enthusiasm, suggestions & direction. 


The heyday of Natural Perfumery is seen by some in the earlier decades of the last century and older books by perfumers such as Felix Cola’s La Livre du Parfueur & The Science & Art of Perfumery by Edward Sagarin are much sought after. Trying to update Natural Perfumery a little in terms of the increased range that a multitude of natural ingredients might offer, Grimshaw (1989) sets out a discussion on why a perfumer might seek to broaden the area set out by purists (no chemically produced or chemically modified ingredients). In apparent agreement, Gupta (2002) mentions the use of modern extraction solvents consisting of synthetic fluorocarbons to produce Natural Ingredients. Obviously there is considerable room for discussion here about how ‘deep green’ methods of production need to be, in order to call something a Natural Perfumery raw material.


IFRA’s Info. Letter on Natural Perfumery.

Which brings us to the modern day. In spite of Turin’s reaction, the reality is that natural perfumes, or perfumes with a given naturals content percentage, are in fact now part of the typical modern Working Perfumers weekly workload. As if in acknowledgement of this, Vey has written a piece on Natural Perfumes (largely concerned with the status of ingredients) in the IFRA Information Letter No 737. As many people reading this feature will not ever get to see IFRA’s restricted communiqués, let me inform you that the piece includes the fact that co-distilled ingredients need to have the solvent levels disclosed (!) - Natural Perfumers being purists would not knowingly use molecular co-distilled ingredients. Cropwatch is pleased to agree with Vey on the adoption of the definitions and terms of naturals as set out in ISO 9235 to give a vocabulary of aromatic raw materials, and Cropwatch would abide by definitions of ‘Natural’ as devised by groups such as the Committee of Experts for Cosmetic Products 2000. We would however make two further points:


(1)   That if ethanol is used in a Natural Perfume, it must be organic and bittering-agent free - many devotees use various strengths of vodka, which may not be altogether satisfactory.

(2)   That nowadays a huge range of natural fragrance chemicals is available via fermentation – at a price! This greatly extends the range of the art of the possible in terms of the odour range in Natural Perfumery. Individual natural fragrance chemicals can give an intense singularity that is difficult or impossible to emulate with essential oils and absolutes alone.

However the situation may be even more complicated than this with regard to definitions of Natural Ingredients. The author (TB) disagreed with a certain salesperson presenting 'natural' aromatic raw materials at the recent British Society of Perfumers meeting, to the extent that certain of the materials presented were in fact natural, since they were produced using aromatic materials used as molecular distillation solvents, which extracted but also chemically reacted with natural substances in the material being extracted, making new aroma compounds. I consider that deliberately designed chemical reactions to change the nature of extractives does not give the product a natural status – and much of the audience seemed to agreed with me. OK its a bit of a side issue, but causes problems for those of us who have to ‘sign off’ natural formulations. 

Natural Perfumery does gives artisans a chance to re-discover ingredients that are rare or no longer used on economic grounds – like the art of making tinctures, or products from the manufacturing methods of enfleurage and maceration.

On the other hand, Corporate Perfumers are at a distinct disadvantage in Natural Perfumery from two important factors:


  1. The burdening legislation makes it very difficult to construct perfumes that adhere to IFRA limits and EU legislation, and who’s ingredients are not subject to limitation with respect to labelling for R43 (sensitisers), R38 (irritants), R50-53 (harmful to the environment) etc. For example how do you make an orange fragrance that doesn’t have to carry any warning labelling? It is quite likely that aspiring Natural Perfumers neither know or particularly care about these things – the chances of being detected and prosecuted are, they will argue, next to zero anyway! But Corporate Perfumers cannot take this risk with their company’s reputation.

  2. That whereas the Corporate Perfumer’s choice of ingredients is limited by stocking policy of the company and is limited to the number of ingredients held in stock, Natural Perfumers are free to choose from several thousand possible natural aromatic materials. The downside is that Natural Perfumes rely for their character much more on a very consistent odour quality for natural raw materials batch-to-batch. And this can be hard to attain with small suppliers, especially those that basically buy odd job lots of raw materials off the spot market.

EU legislation has made matters extremely hard for Natural Perfumery. Natural materials are more and more being unfairly discredited on safety grounds by "expert" committees who are acting as rubber stamps for political ends - to support the Chemicals Policy of the EU. Yet even in Conventional Perfumery, few fragrances that are any good are totally synthetic (“most synthetic perfumes today are crap…” (Turin 2005)) and essential oils figure from 1-25% of the composition according to fragrance type etc. - and probably will always be used at the 1-2% level at least. Essential oils, absolutes and other naturals finish off and give a body and roundness to perfumes which is impossible to achieve with synthetics alone.   


Grimshaw B. (1989) Natural & Nature-Identical Fragrances – A New Creative Challenge in Natural Ingredients in Cosmetics eds. M. Grievson, Janet Barber, Anthony Hunting pub. Micelle Press, Weymouth, UK 1989.

Gupta S. (2002) “Natural Fragrances in Soaps & Cosmetics” Happi May 2002 pp65-69.

Turin L. (2005) – see blog at - but hurry, parts of this section are threatened with deletion!

Opinion: EFFA Shows Signs of Schizophrenia

Apparently an EFFA statement by director Dan Dils about Cropwatch was circulated to members of EFFA’s constituent organisations following a private enquiry from the EU Director General about collaboration. Although neither of the above gentlemen had either the manners or courtesy to copy Cropwatch, in its reply Dils huffily distanced the organisation from Cropwatch’s opinions and stated that its member organizations were not working with Cropwatch. This is only partially true.

Private support, encouragement and congratulations for Cropwatch’s aims thus far have come not only from within Brussels, but also from both the grass roots and from some of those at the highest levels of several of the constituent organizations of EFFA (again, with some of whom we have had off-the-record meetings). Further, many members of these constituent organizations actively contribute facts and opinions for Cropwatch articles. How else would we know exactly what is going on? Think about it.


From our viewpoint not only have the EFFA high command lost touch with their membership, but they also seem to have lost the plot in other ways. EFFA’s undemocratic stance is illustrated not allowing free speech, so that constituent member organisations cannot make statements to anyone (including the media & Cropwatch!) – Cropwatch believes this might date back to an incident where individual constituent organisation members were making some statements to the media about the build up synthetic musk compounds in the environment and human body. But more seriously we believe its policy-making shows bias towards the interests of big industry. For example the EFFA Fragrance Expert Committee (8 members) has three members from the major perfume organization IFF and one from the equally major concern Firmenich. The other four members are from trade/research organizations – and we believe no impartial observers are present (of course). Out of its eight members – and we might be wrong – most of the Fragrance Expert Committee members cannot actually construct a perfume.

EFFA could play an important role in defending the interests of the aroma trade, instead of obediently handing over technical information to EU law-makers, so they can hit us over the head with baseball bats - disguised as EU Directives - time after time. But as several suppliers to the aroma trade  have pointed out to Cropwatch, the more red-tape that is generated by EU Directives, the more it favours the geared-up dinosaurs of the aroma trade (like Givaudin & Firmenich), and the more it marginalizes smaller companies with fewer available human resources. The result is that there are more and more amalgamations, and hardly any small and medium sized companies left. EFFA’s role in supporting damaging legislation could change from its present state of connivance to outright opposition – its up to you members!    


Cropwatch's Message Influences the EU


A  survey of journalists (Dollarhide, 1999) found that they relied more on not for profit Internet websites than business websites for credible information. This may explain why Cropwatch as a non-profits, non-commercial organisation, is building a reputation for providing credible information on it's Website, and through the forum of this newsletter. Our broad spectrum of supporters includes academics, industrial researchers, employees of private companies, members of NGO's, government employees and many others.
It seems that EU officials do not very often officially respond directly to our critiques of SCCP Opinions (see below "The EU Commission replies to Cropwatch".), and of course this will never be admitted at an official level

but “The non-paper for discussion: Action Plan 2006 (Unit ENTR F-3 Cosmetics team)” includes the “Inventory of Cosmetic Ingredients on the Agenda (second update of Section 1 and Section II of the Inventory as well as a Cosmetics and Consumers chapter)”. You will remember the drubbing that Cropwatch previously gave the Inventory – see


So it seems that whatever they might say, the powers that be are in fact taking Cropwatch’s advice to heart (Brussels officials have been frequent visitors to the Cropwatch website).


Also included under the Action Plan is monitoring the Implementation of the Cosmetics Act (7th Amendment), sections of which are possibly the most controversial & scientifically unsound pieces of legislation ever generated by the EU. Here, the F-3 Cosmetics team will be checking on its implementation into the National laws of the member states. Or, if not implemented, presumably fines would follow. 


The EPA ‘s (non) Protections for Subjects in Human Research  

As the main environmental regulatory body in the United States, the Environmental Protection Agency (EPA) has the authority and responsibility to protect both human health and the natural environment

On August 2, 2005, Congress instructed the EPA to create a rule that permanently bans chemical testing on pregnant women and children, without exception.

What the EPA has come back with is a rule full of exceptions where the testing of chemicals and pesticides on human subjects include the most vulnerable ie  mentally handicapped or orphaned newborns.

The full document can be located at

This document is extremely long (as these things often are) but of particular concern are the following parts of the document:

70 FR 53865 26.408(a) "The IRB (Independent Review Board) shall determine that adequate provisions are made for soliciting the assent of the children, when in the judgment of the IRB the children are capable of providing assent...If the IRB determines that the capability of some or all of the children is so limited that they cannot reasonably be consulted, the assent of the children is not a necessary condition for proceeding with the research. Even where the IRB determines that the subjects are capable of assenting, the IRB may still waive the assent requirement..."

This clause is quite possibly illegal apart from downright immoral and completely takes away the basic human rights of a newborn handicapped or orphaned baby who under this ruling could be tested on without assent


70 FR 53865 26.408(c) "If the IRB determines that a research protocol is designed for conditions or for a subject population for which parental or guardian permission is not a reasonable requirement to protect the subjects (for example, neglected or abused children), it may waive the consent requirements..."

The logic of this rule is based upon the stance that If a child’s parent or guardian consents to testing then testing can go ahead but If a child’s parent or guardian are themselves unfit to consent ie. If they have abused or neglected the child, then consent from the parent or guardian could be waived, thus allowing further abuse and failure of duty of care towards the already abused &/or neglected child


70 FR 53864 26.401 (a)(2) "To What Do These Regulations Apply? It also includes research conducted or supported by EPA outside the United States, but in appropriate circumstances, the Administrator may, under § 26.101(e), waive the applicability of some or all of the requirements of these regulations for research..."

This rule explains that the Administrator of the EPA has the power to completely waive the requirements of the regulations on human testing, if the testing is done outside of the U.S. This clearly gives carte blanche to human testing in other countries where the regulations allow or are not adhered to.


70 FR 53857 "EPA proposes an extraordinary procedure applicable if scientifically sound but ethically deficient human research is found to be crucial to EPA’s fulfilling its mission to protect public health. This procedure would also apply if a scientifically sound study covered by proposed § 26.221 or § 26.421--i.e., an intentional dosing study involving pregnant women or children as subjects..."

Again, the EPA propose to allow themselves Unrestricted power to act at It’s own discretion where accepting or conducting  "ethically deficient" studies of chemical tests on humans.. They set no criteria whatsoever for making an exception in any case and so this rule ultimately would allow every study they wished to accept or propose.


“HHS has taken further steps to provide additional protections specific to pregnant women, fetuses, and newborns as subjects of research. In a regulation initially promulgated on August 8, 1975 (40

FR 33526) and revised several times since, codified as 45 CFR part 46, subpart B (45 CFR 46.201 through 46.207), HHS defines stringent constraints on research with these particularly vulnerable populations.

The HHS subpart B does not rule out research with these groups when it would involve direct benefit to them, but it requires an especially high standard of justification and imposes many procedural and other

constraints on research which would not confer a direct benefit on the subjects”.

What possible “direct benefit” could there ever be to test chemicals and pesticides on these children?!!


Animal Testing

There is some discussion within the EPA document about animal studies as used to assess risks from chemical and pesticide exposure.  They state that

 “….the relationship between environmental concentrations of a substance and potential human exposure is unclear, and can be understood only through research involving human subjects”.

Looking at the proposed EPA rules on chemical testing we can clearly see that so-called civilised society is no closer to achieving a humanitarian stance.  We have traditionally used animals to test chemicals based on a mentality of “ownership” of the said animals.  They are bred and sold as “laboratory animals” where the owner is the breeder and then the company who purchase the animal for their own use. The said animal has no ability to claim rights as a free individual. Human beings however in the main are not “owned” but there are some of us who also do not have the ability to verbalise or otherwise express our rights as a free indiviudlal – namely, orphaned or mentality handicapped babies and abused and neglected children.

In these cases, the state has a duty of care towards these people.  Congress specifically dictated to the EPA to create a rule that permanently bans chemical testing on pregnant women and children, without exception.

Outrage from several interest groups, most notably the Organic Consumers Association who seem to be hot on the EPA's case have now  received support from several employees within the EPA itself. Further, the American Federation of Government Employees, The union representing scientists at the EPA have issued a statement which states that it {the union} is "extremely concerned that the proposed rule has so many loopholes and exceptions to provide any sort of enforceable ethical standards for human studies."

The union also said that if the rule is put into effect as proposed, it could create "serious ethical and liability problems" for EPA employees.

Jeff Ruch, executive director of Public Employees for Environmental Responsibility, is quoted as saying: "The good news is that EPA, for the first time, is pledging to abide by the Nuremberg Code, adopted after World War II to prevent a repetition of the horrific Nazi human experiments. The bad news is that EPA’s proposal breaks this long-overdue pledge by offering a plan peppered with loopholes that encourage unethical conduct and omit key protections for infants, pregnant women and other vulnerable populations."

The EPA invited public comment up until  December 12, 2005.

How much attention will be paid to public comments by the EPA is open to question since the requesting of public response amounts to just one step in the procedure towards the eventual rubber-stamping and implementation but Cropwatch will keep an eager eye on any developments and will report in a future newsletter.



Tea Tree Update: EU Officials Use Circular Arguments.

On the pretext of improving ‘user safety’, the flawed SCCP Opinion on Tea Tree Oil (: unsafe & unstable in cosmetics) caused a global howl of outrage and has rallied many people into protest action, imparting as it did a strong sense of a simplistic conviction that you cannot trust Brussels any more with these issues. In particular the positive experience of tea tree oil users contrasted strongly with the perceived bias of the SCCP, over-influenced as they are by dermatologist’s opinions and (often questionable) findings from single/multi-case studies which do not clearly establish tea-tree oil as the primary sensitiser.

Remember that the chairman of the SCCP, Ian White, previously claimed that self-regulation had failed to protect consumer interest in the perfumery industry, especially with regard to fragrance sensitivity, and that a think-tank had been set up “consisting of a balanced representation of dermatologists, fragrance-compound manufacturers and users to address aspects of ‘problems’ and ‘needs’ " (White 1998). How a person with these decidedly non-neutral opinions about the fragrance industry should become chairman of the SCCP is a complete mystery to Cropwatch, and the measures put in the place of voluntary regulation since Ian white has been chairman of the SCCP have not actually decreased the incidence of fragrance sensitivity (which has arguably increased if anything). You will also note that the representation of end-users has never actually materialised, so that fragrance regulation has effectively become a narrow-spectrum stitch-up between dermatologists, expense-account executives of the major aroma industry players and those in professional organisations which are financially dependent on the same major players, together with an assortment of university professors.  This is why Cropwatch believes that the SCCP should be reformed with panelists from a wider and more directly experienced section of the European community. 

Cropwatch has been gathering adverse reaction data from tea tree oil end users especially from aromatherapists via its interactive on-line questionnaire at Aromatherapists in particular may employ multiple applications for clients during their working week and may have client records from which to abstract data (any data used is anonymous and does not break the rules of therapist-client confidentiality). We would especially like to warmly thank the UK’s International Federation of Aromatherapists who recently submitted 71 finished forms, some entries also attaching helpful copious extra notes. We understand that we have until June 2006 if we wish to submit adverse reaction data for consideration by the EU regulatory machine.

Cropwatch was intrigued by insider information (allegations which it had heard for some time from several sources) about deliberately oxidised tea tree oil being sold into the essential oils marketplace, the motivation apparently being that the belief that oxidised tea tree oil has a greater biocidal effect. Accordingly Cropwatch set up a wide appeal for information in 2005, and we now know the identity of the perpetrator(s) which we have been advised not to name for legal reasons. It is a pity that the tea tree oil trade is (despite outward appearances) so adversarial and competitive, since the ability to self-police on this matter might have prevented potential physical harm to tea tree oil end-users. Cropwatch is still trying to estimate the extent of this occurrence, and the text of the message is reproduced below to this end (since this Cropwatch Newsletter will enjoy a much larger circulation due to people signing up on the website).

“Cropwatch has received information from a usually reliable source that deliberately oxidised tea tree oil has been sold into the essential oils marketplace. Cropwatch is appealing to industry & the general public to see if anyone is able to corroborate this (presently unsubstantiated) allegation. We are prepared to respect confidences and protect sources if this proves necessary, but we do need any information that there is out there on this matter, please.

It is also understood by Cropwatch that the motivation for this deliberate oxidation was apparently a belief that oxidised tea tree oils appear to have enhanced anti-microbial properties. Whilst there is published evidence to suggest that might be so under certain conditions, there may also of course be a case to answer for a potential increase in adverse skin reactions.  As an aside, the process technology for deliberate oxidation of essential oils is certainly known, and for example, oxidised cedarwood oil Virginian, oxidised sandalwood oils and oxidised lemongrass extracts of the Guatemalan type have been previously available as articles of commerce.

Please contact in complete confidence if you have any information on this matter.

N.B. Some pointers for oxidised/deliberately oxidised essential oils:

Jean Valnet The practice of Aromatherapy, A classic compendium of plant medicines & their healing properties ed. by R.Tisserand. Ch. 3 ‘Nature's Antiseptics’ gives information on the use of peroxidised thyme oil at 1.5% - 5% concentration.


Also Gattefosse had some interesting things to say on the alleged anti-microbial activity of deliberately oxidised Eucalyptus essences and some of their components (such as pinenes, phellandrene and aromadendrene), although he wrongly attributed the active agent to ozone instead of generated free radical spp. (in Rene-Gattefosse: Gattefosse’s Aromatherapy (1937) ed. R. Tisserand 1992 pub CW Daniel pp41-2).


Markham J.L. (1999) in ‘Biological Activity of Tea tree Oil’ in Southwell I. & Lowe R. (eds) Tea Tree: The Genus Melaleuca pub. Harwood Acad. Publishers, quotes Williams & Lusunzi (1994) working with Melaleuca dissitiflora (to 16% p-cymene content) who had suggested that oils with high p-cymene contents (as would be the case in deliberately oxidised tea tree oil - TB) possessed greater anti-microbial activity than standard tea tree oil – but Mann & Markham (1997), deliberately added p-cymene to normal tea tree oil to 15% conc. found no significant increase in activity (Refs: Williams  L.R. & Lusunzi I. (1994) “Essential oil from Melaleuca dissitiflora: a potential source of high quality tea tree oil” Industrial Crops & Products 2,211-217; Mann & Markham (1997) University of Western Sydney, Hawkesbury. Unpublished results).


The EU Commission replies to Cropwatch.

Cropwatch’s hard work on five topics, all on the subject of questionable SCCP Opinions (Tea tree oil, Tagete oil, Opoponax oil, Peru qualities, the Cosmetic Ingredient Inventory) has drawn forth just 2 replies from EC officials (dated 14.10.05 and 28.10.05) informing us that the Enterprise Directorate-General will be in touch, and that SCCP Opinions are based on scientific information submitted for evaluation. As Cropwatch has long suspected that agents provocateur  from the pharmaceutical world submit biased and selective data to the SCCP to the disadvantage of the natural products industry with whom they are in part-competition, this could explain why their Opinions are so often non-credible.   


The reluctance of Brussels officials to interact with Cropwatch is to their disadvantage: Cropwatch’s influence is growing. 


The Cropwatch Essential Oil Users: Adverse Reactions
to Tea Tree Oil Survey.

Cropwatch still needs more essential Oil users
 to  fill out the form at  from the main page.

It is equally important that those  essential oil  users who have NOT seen any adverse reaction to tea tree oil to participate!

If you have "ever" used tea tree oil please take a few minutes to assist the cause.



     Oranges and Pesticides.

Cropwatch has believed for some time that the citrus industry has been nurturing some big secret or another with respect to information about pesticides in citrus products…. strange you might think, since EU legislation requires that companies make public any unpublished safety information they may hold in these areas.

Perhaps the UK Government Pesticides and Residues Committee has stumbled on something big therefore, when it found that every single orange tested was contaminated with pesticides contained in the peel, specifically every orange except one with Imazalil, a particularly nasty carcinogen. The UK banned pesticides Carbofuran and the more moderately hazardous Methidathion were also found, as well as Fenthion, all above the EC safety limits. Egyptian imported oranges were found to contain the gender-benders/ possible carcinogens Diazinon and Dimethoate. The Pesticides Action Committee said that no adverse health reactions were anticipated, as most of the poisons were concentrated in the peel, which is not eaten.  


[Adapted from Lean G. (2005)  “Oranges are not the safest fruit – they all exceed pesticide limits”.  Independent on Sunday 19 Dec 2005 p29].


Cropwatch points out that orange oil is mechanically pressed from the peel. The implications for the citrus essential oil industry are not clear.


Cropwatch Red Tape Award for 2005.

Customers for individual aromatic raw materials (including essential oils) often demand that their suppliers fill in the most detailed product questionnaires. If a supplier has, say, 200 products and 200 customers, you can imagine that many technical people in the aroma business are now just glorified form-fillers. Cropwatch also suspects that many of these labours of love languish in customer filing cabinets untouched for 12 months until being replaced annually.


The most complicated customer questionnaire yet seen by Cropwatch in 2005 originates from Cadima-Pathé, Paris and spans some eighteen pages. It might be instructive here to actually list the requests for detailed information to be declared in the appropriate categories:


1. Product

2. Vendor: business name, address etc.

3. Characterisation: single substance/natural/product & natural/NI/synthetic ratio etc.

4. Technical information (flashpoint, vapour pressure etc.)

5. Status Information (for USA, Europe, Canada, Japan, Australia, Philippines, Korea and China)

6. Additives:


Preservatives according to Annex VI of EU Cosmetics Directive 76/768/EEC as amended


UV-stabilisers according to Annex VI of EU Cosmetics Directive 76/768/EEC as amended)

Colours (according to Annex IV of EU Cosmetics Directive 76/768/EEC as amended & others)

Annex II or Annex III compounds of EU Directive 76/768/EEC as amended, with allergens listed as separate declaration in Attachment III (determination level 10ppm).

7. Solvents (determination level 10ppm);


8. Formaldehyde/Formaldehyde Releasers.

9. Animal Derived Materials (bovine/ovine/caprine or civets). [- No mention of whales -  Cadima-Pathé sells ambergris!]

10. Nut and Seed Products

11. Musks (nitro-musks, polycyclic musks, macrocyclic musks, Cashmeran)

12. CMR materials

13. VOC Ingredients (including Swiss legislation VOCV, dd. 12.11.1997/9.2.1999 & whether material meets definition of fragrance under California Clean Air Act)

14. Genetically Modified Organisms statements.

15. Impurities/Residues

16. Contaminants e.g. phthalates from filling lines, storage etc.

17. IFRA Compliance (including use limitations to IFRA standard)

18. Safety Evaluation (“if no information given, a (sic) unlimited use is confirmed by supplier”)

19. Hazard Classifications:

Dangerous under 67/548/EWG RESP. TO 1999/45/EC

Dangerous ingredients

Total fractional value for each risk according to 1999/45/EEC and its adaptation

20. Toxicological & Ecotoxicological Test Data

21. Additional Information:

Carcinogen according to NTP, IARC, Calif. Prop 65;

Contained Ingredients under SARA Title III,

Substances contained under CERCLA 

Substances contained under DEA

Hazardous Air Pollutants

NJ Right to Know Hazardous Substances List.


In Attachment I the questionnaire also asks to list all IFRA restricted ingredients (nearly 70 listed); to declare quenchers (Cropwatch thought that nobody believed in the quenching phenomenon anymore!); and ingredients without specification.


In Attachment II other substances prohibited/restricted by major customers are listed (approx 120 substances – Cropwatch didn’t count this accurately as staff became temporarily dizzy with rage. This is because the 3 pages of Appendix II reflect the fact that customer legal advisers now run the aroma business, and its becoming impossible to craft perfumes anymore with these ridiculous prohibitions/restrictions).


In Attachment III – ingredients considered as fragrance allergens – is the famously contentious  SCCP 26 allergen list.


Finally the supplier is invited to make various undertakings about the information given by signing the questionnaire!




- but Cropwatch considers even more red tape could be generated by asking for the following documents to be provided also:


Product Specification


Kosher Certification

Halal Certification

Certificate of Naturalness including component isotopic ratio analysis etc.

GMO Certificates (EU Legislation wrt traceability and labelling of GMO’s and traceability of food products from GMO’s according to 1829/2003/EC & 1830/2003/EC)

Whether any Animal Testing performed after 11 Sept 2004 (according to the 7th Amendment of the European Cosmetic Directive 76/768/EC) or prior to 11 Sept 2004 but after 1976.

Heavy metals declaration

Pesticide analysis data

Dioxin and PCB analysis


The Standardisation of Natural Ingredients: A Good Thing?


The year 2005 has been a difficult year for some natural ingredients – low yield harvests affecting availability of Chinese Litsea cubeba oil, Indian mint oil and Egyptian tagete oil (Anon 2005). Cropwatch has also noted climate problems has affected US grapefruit oils and Chinese ginger oil, although the latter, together with black pepper oil, has also felt pressure from ethnic and trans-international demand for raw materials as ingredients useful in combating SARS and bird ‘flu. Chinese star anise fruits have been used as a source of shikimic acid to manufacture Tamiflu a drug alleged to reduce the severity of influenza (Laurance 2005), resulting in Chinese Star aniseed oil being more difficult to obtain and liable to adulteration with synthetic anethole. Geranium oil Bourbon and vetiver oil Bourbon have been virtually unobtainable this year, and correspondents in Indonesia have written into Cropwatch giving details of widespread adulteration of Patchouli oil with Palm oil by larger oil exporting concerns.  East African and Australian sandalwood oil fractions continue to turn up in Sandalwood oil E.I., which anyway is almost unobtainable in any sort of quantity.  And this is just some of what has been going on…


In times of severe shortage, quality of natural products might be expected to vary ‘more than somewhat’ as Damon Runyan might put it, which roughly translates here as being ‘in excess of natural variation’. Yet customer rejections from QC number-crunchers have been uncompromising. Cropwatch has been discussing the reasons why this might be, with some more experienced industry colleagues.


Firstly, in this information age, customers do not actually seem to know what is going on in their own profession. Perhaps the trade shortages hadn’t yet come up as a topic on “Richard and Judy”, or been featured on the back of K…..’s Cornflake packets?


Secondly, the trend towards the increased use of synthetics (as the vendetta against naturals restricted on dubious safety grounds takes hold) may be raising a generation of technical staff who are expecting “same as last delivery” time after time. This does not happen with naturals. Suppliers have ironically pointed out to Cropwatch that if they routinely adulterated oils with synthetics, the resulting more uniformly-odoured essential oils would be almost certainly be passed by customers with histories of unrealistic expectations in this area. 


Thirdly perfumery and flavour training courses may not be teaching young analysts, perfumers and flavourists that if you compare a freshly distilled essential oil with a standard that has been in the ‘fridge for 6 months to a year, its going to smell different, and the colour might have changed also. What is required is to compensate for these facts and still make an informed opinion on acceptability – this comes with experience. Cropwatch intends to write to colleges which offer aroma training to remind them to emphasise this in taught courses.


Fourthly, the trend towards the standardisation of products is becoming obsessive, and meaningless test result numbers are substituting for an innate ability to make commercial judgements. Why buy an essential oil not intended for pharmaceutical use which conforms to Eu. Pharm. V as a buying criteria for example? Does it guarantee a better oil? Of course not. Milchard et al. (2005) have provided the basic fingerprints of a number of essential oils – but, for example does adherence to the GC traces provided necessarily establish whether a given Indonesian patchouli oil is good, bad or indifferent, or even if it contains palm oil? Err….well, no, although, on a good day, the total area of the GC trace (not mentioned) might indicate something is amiss - i.e the oil might contain “invisibles”. Patchouli oils are, anyway, generally sold on odour profile and solubility in a given strength of aqueous ethanol, a 5-minute test which would probably quite quickly reveal adulteration with palm oil. 


As an end-piece, Cropwatch has learned of an instance of small 10Kg batch of genuine Sandalwood oil East Indian being offered but rejected by a certain perfumer because “it smelt woody and was not the same as last’ (‘last’, it eventually turned out, was an unholy mixture of sandalwood East African Sandalwood and Cedarwood oil fractions). Just what is happening to our profession when perfumers cannot even remember what real Sandalwood oil is supposed to smell like?   



Anon (2005) – The Essential Oils Market Parfums Cosmétiques Actualités  No 185 Oct/Nov 2005 p82.

Laurance J. (2005) The Independent Sat 15th Oct 2005 p1-2.

Milchard M.J., Clery R., DaCosta N., Esdale R., Flowedew M., Gates L., Moss N., Moyler D.A., Sherlock A., Starr B., Wootten J., Wilson J.J., RSC London Perf & Flav. 29 (Aug 2004) 28-36. 



Correction / Apology

In the previous Cropwatch newsletter  (Vol 1, Issue 1, No 1)

we referred to Unifec Internat Pty Ltd  instead of UNIFECT INTERNATIONAL PTY LTD

(forgetting the "t")

for which we aplogise.



'Coming in Cropwatch 3:


Coumarin: the real story

Indoor air quality; the new Bete Noir for Perfumery, Incense and Perfumed Candles

Furanocoumarins in Essential Oils - the wrong data




























All Text, Articles © Cropwatch or authors name/s where stated.
 Please do not reproduce without quoting the source. The information supplied on this newsletter is believed to be accurate, but views, comments, criticisms, corrections or additional material can be forwarded to for consideration /correction.
 © 2006 Cropwatch  All Rights Reserved.




Cropwatch Updates


  KAVA-KAVA Ban: Deafening Silence from the UK’s MHRA.

Cropwatch has been following the UK review process for Kava-kava following the publication of the prohibition order MLX319, and has published a review of the situation at You may remember that one study estimated that 250 million daily doses of kava administered 1988 to 1998 resulted in 0.008 adverse reaction reports per million doses (compared with 2.12 for diazepam), demonstrating kava’s good safety profile. This Cropwatch topic has drawn of lot of interest from Internet visitors, by the way.




If you like to also enquire about the position of kava-kava, the MHRA can be contacted at the following address:

Medicines and Healthcare Products Regulatory Agency,

Market Towers,

1, Nine Elms Lane,

London SW8 5NQ.


Please let Cropwatch know if you receive an informative answer. Or any answer at all, really.

So Then: Who’s Afraid of Citronella Oil?  Update!

Continuing the bizarre story of Canada’s Pest Management Regulatory Agency efforts to phase out the use of Citronella oil in insect repellents, we can report that the Regulatory Officer for the Canadian PMRA has accepted evidence from Cropwatch, and forwarded this evidence to PMRA staff on 08th Nov 2005. The evidence forwarded was on Citronella oil and methyl eugenol toxicology only since interpreting the material on the PMRA website gave the impression that this was of primary concern, and the wording of PMRA communications in November 2005 led Cropwatch to believe that this was the only evidence sought. Further, Cropwatch put his belief in writing to the Regulatory Officer at the same time it forwarded evidence on Citronella oil and methyl eugenol – and it wasn’t corrected or challenged.

You may remember that Cropwatch maintained there was no case to answer in respect of a carcinogenic risk from the topical application of citronella oil used as normally employed as an insect repellent. The reasoning included the fact that low or negligible concentration levels of methyl eugenol occur in citronella oils, especially Java citronella oil, and the bioavailability of any methyl eugenol from topical application of citronella has not been demonstrated. Further, the concentration of methyl eugenol in the liver needed to constitute a carcinogenic risk is not realisable via topical application of citronella oil. Cropwatch was not invited to comment on PMRA’s dubious reasonings in other areas of alleged citronella oil toxicity – such as statements above the human metabolic fate of citronellol, a major component of Citronella oil (which it would have relished!). It is not currently known whether the PMRA have decided to drop this line of reasoning. 

Subsequent to this, however, in a further PMRA communication with a UK biocides manufacturer in Dec 2005 (which Cropwatch has been party to), it now appears that the PMRA position is that there are issues and data-gaps with Citronella oil toxicity itself – presumably in regard to reproductive toxicology, which Cropwatch was perfectly willing to give an Opinion on!  Cropwatch staffs feel very frustrated at once again being outmanoeuvered/disadvantaged by clever political moves, which have nothing to do whatever with the scientific aspects of the case.

The PMRA’s general handling of pesticide safety issues and its support of industry cartels that produce dangerous pesticidal chemicals has been the subject of severe criticism elsewhere – see for example ‘Pesticides – a Grave Oversight’ at

More worrying still is Cropwatch is well aware that UK Government officials were considering mirroring certain regulatory decisions in the light of this specific piece of PMRA policy  - a clear sign that we need more independently thinking, scientifically aware Civil Servants in Government.

Cropwatch is now awaiting the outcome of PMRA’s deliberations.

China Consumes Threatened Species Update. 

Following the harrowing reports of diminishing tigers and increasing trade in their parts outlined in the last newsletter, Cropwatch can now bring you news of some important positive developments in terms of protecting the tiger from trafficking of tiger skins and bones.

A new enthusiastic wildlife law enforcement network  has been launched In Thailand widely speculated to become the biggest operation of It's kind having the means to co-ordinate intelligence sharing and combined police operations.

The ASEAN Wildlife Enforcement Network (ASEAN-WEN) will start off with the 10 ASEAN nations and they hope to add China and India to  the network as soon as possible. 

Infamous wildlife trader Tashi Tsering also known as Tsewang who is responsible for several illicit
shipments of tiger parts seized in
Nepal and India and who has evaded capture for years has finally been tracked down himself.

Working on leads from conservation activists, police in Nepal have finally bagged their "most wanted"  See

India are still talking at government level and a bill is now before parliament to create a National Tiger Conservation Authority with statutory status.  (See