THE CONFERENCE PROCEEDINGS - IFEAT

wolf: “Ah we can’t do anything, we’re going to die, this is the end of the world, and it’s going to costus a fortune.” Well the industry has survived and it is still out there, maybe not everybody, but by andlarge the industry has survived. So theCommission looks at a piece of legislation, andsays the industry is going to cry wolf, we aregoing to pass it and they will adapt, they will findthe innovation and they will survive. TheCommission are not going to look at who isgoing to die to the left, who is going to die to theright, because by and large the big numbers workout for the Commission. Things move on andsafety is increased and everybody is happy. Theyget political kudos because consumers and NGOsare happy; the politicians are happy and so forth.This is what we call the default model of theindustry.Naturals are Particularly Vulnerable• The Commission’s default model:– Propose legislation– Industry protests– Enact legislation– Industry adjusts (via innovation)– Business as usual• SEA– Only addressed downstream– Positioned the fragrance industry as innovative• “Industry would be “different” if SCCS opinionenacted” – Top perfumers24Protecting the Naturals – Our Actions• Show that the fragrance industry value chain willbe harmed– EU competitiveness will suffer– European innovation and creativity will suffer• Engagement by the fragrances houses andperfumers• Missing a critical piece - where is commitmentof the naturals?– Showing that the naturals industry is committed viapolitically savvy programs– Science– Socio-economic assessment25We do not want this; we believe this is wrong,and that we definitely need to do somethingabout it. One of the issues we have today is thatwe need to show how the industry would beharmed if the naturals were to be heavilyregulated through DG Sanco’s risk managementmeasures. So what we are really missing now isto show the commitment that the naturalsindustry has towards the industry, per se, what isthe natural’s political platform to speak on, andwhat are the sciences of the naturals, and whatare the socio-economics of the naturals.The Allergens Work PlanBecause separately we also have - what we call -an allergens work plan. This is a commitmentfrom the industry to show that we are seriousabout the allergens. So as DG Sanco looks at itsmeasures, it will also look at the commitmentthat the industry is willing to make for the futureof safety assessment and understanding allergensin the world and in Europe in particular. So onthe one hand they know how big we are and howmuch value we bring, and they see that we havea commitment to do something about theallergens, but on the other hand we need to givethe Commission again the true impact of thenaturals on the business.Our Allergens Work Plan• We have developed detailed proposals fora multi-faceted program– What is an allergen?– Induction versus elicitation (98% versus 2%)– Risk-based approach – QRA– Requires investment of Euros 1.0 million over5-year period• Understands Commission’s political context26229