Essential Oils and the Law

Essential Oils (1)


If any of you are like I was, you began your essential oil journey in an earnest attempt to find the best ways to care for yourself and your family. Maybe you didn’t. Maybe you just like the way they smell as air freshener, personal perfume, or additives to your cleaning supplies. No matter what you use essential oils for, it’s important to understand the laws surrounding them.

U.S. regulations regarding natural products are unclear, ambiguous, and often confusing. The European Union (EU) has more specific definitions but even so, still lacks total clarity. I’ll try my best to break this down and make it easier.

Let’s look at some legislative definitions.

“Natural”

This word is easy for us all to understand, right? This is the most challenging and complex of the definitions.

“Natural” by U.S. standards means that all of the materials used to create something are derived from nature (that “derived from” part is the loophole). This looser interpretation of natural means that so long as a product contains all natural ingredients, it can still be considered a natural product, i.e. essential oils, smoke based flavors, etc. EU standards have a more restrictive definition of the term “natural” and apply it to the manufacturing process, as well as the component ingredients. The chemicals used for extraction, as well as the exact temperature that can be used are highly regulated. Many things that are “natural” by U.S. standards would not be deemed so when applying the EU standard.

The U.S. has the Flavoring Extract Manufacturer Association (FEMA). The EU has a comparable group, the European Food Safety Authority (EFSA). They also have the European Flavors and Fragrances Association (EFFA). The EU has new regulations that further restrict ingredients by implementing a list of positive ingredients that are much easier to regulate.

“Organic”

The USDA “Organic” seal is protected by federal law (7 CFR Part 205.311). In order to use it companies must comply with a set of USDA standards and have official certification (USDA Organic Factsheet). Pay close attention to the labels. If a product says “organic” it means that 95% of the ingredients meet organic criteria. The only way that you know the product is totally organic is if it says “100% Organic”. Non-agricultural products are broken down into: soap (self-explanatory), cosmetic, or a drug (FD&C Act, sec. 201 (i).

“Cosmetic”

The Federal Food, Drug & Cosmetic Act (FD&C Act) defines cosmetics as “articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body…for cleansing, beautifying, promoting attractiveness, or altering the appearance.”

Cosmetics are things like: moisturizers, hair products, lipstick, deodorant, makeup remover, nail polish, etc. If your cosmetic products claim to cure you of something then it is also a drug (or known as a “cosmeceutical”).

“Drug”

This is where it gets scary, folks, pay attention. Drugs are classified by their intended use. The FDA classifies drugs as “articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease” and “articles (other than food) intended to affect the structure or any function of the body of man or other animals”. Why should you care? Well, your essential oil products (and some cosmetics!) may actually fall into this category.

Now, why do you care?

Whether you use, purchase, or sell essential oils, listen up. If you sell someone an essential oil and tell them that the oil, peppermint, for an example, will restore hair growth, lower a fever, treat indigestion, etc, you are breaking the law. Those are considered medical claims and it makes the product a drug. Unless you are a licensed physician, you are now practicing medicine without a license (hence the breaking the law part). Is it always fair? No. There are plenty of times we all eye-roll because we know peppermint tea helps an upset stomach. Is it necessary? Yes. I will give you a very real example. If you are offended, then you are exactly the person that needs to be reading this article.

Sellers/associates of both DoTerra and Young Living were caught making egregious and unqualified medical claims. These individual sellers were stating on social media, in sales “parties”, and on their personal blogs and websites that their products could cure all manner of diseases, to include Ebola. Yes, you read that correctly! These well-intended, but grossly unqualified people were making profits by telling the world they could cure a disease that is closely regulated and has not been tested against any of those products. The result was that both companies received warning letters from the FDA, advising them of the violations and directing them to remove all marketing materials related to the claims. If not, the FDA will initiate regulatory actions. You can read the DoTerra letter here and the Young Living letter here.

I use that situation as an example of why regulation is important. It is not to pick on either company. They happen to be the largest essential oil sellers in the U.S. so it’s natural that they would get caught for violations that I’m sure many smaller companies make, as well. I am a huge advocate of people choosing to buy their products wherever they want, based on educated choices.

To be clear, I am no fan of the FDA or the USDA and have a fair amount of distrust when it comes t the motives and honesty of both. Either way, essential oils are tricky but we are still ultimately responsible for compliance. If you don’t sell essential oils or essential oil products, knowing the regulations is still worthwhile. Pay attention to who you buy them yours from and what their qualifications are. If you are purchasing from someone that does not know the law, you may want to reconsider where you source your products.

How does the sense of smell work?

Welcome!  

Today we are going to learn how the sense of smell works.  If you are wondering why an aromatherapist would care, head over to my previous post for a quick primer. Don’t worry, I’ll wait.

Now, let’s get into some granularity and talk about how the sense of smell works.  This is one of those topics that really sets professionals apart and illustrates their training.

So how does the sense of smell work?

 In the interest of time I will simplify this quite a bit.  Molecules are inhaled through the nose (essential oils, perfumes, nasty odors, they are all molecules of something).  The information is carried via an odor molecule which is turned into an electrical signal in the sensory neurons.    Olfaction, the ability to smell, and translate odors to electrical signals, is pivotal to the animals’ ability to find food and locate mates.  

In humans, our olfactory systems are rather elementary compared to other animals but it is still important for gathering information.  Odors and pheromones are translated into those electrical signals, conveying messages to the brain that elicit some type of response.  Odors are detected in the nose in the nasal olfactory epithelium (OE).

Animals detect pheromones via the VNO, the vomeronasal organ.  Some scientists believe that the VNO is an inactive organ in humans and that humans simply do not communicate via chemosignals.   Others know that scientific evidence proves this very concept.  Numerous tests have shown that when exposed to the smell of mens’ sweat, women’s physiological responses demonstrated statistically significant changes, classifying the sweat, or components of it, as pheromones.

Okay so we smelled something, the molecule was absorbed by the mucous membranes in our noses and were translated into electrical signals that are sent to the brain.  Then what? The olfactory passageways sent information to the olfactory cortex, located at the base of the frontal lobe of the brain.  Yep, what you smell is translated into a signal that is sent right to your brain.  From there it can be routed all over your brain, into various areas with various functions. The key to remember is that the brain controls things such as emotions, pain, memories, and a lot of other things. This is why aromatherapy can have both physical and psychological impacts.  If you are really fascinated by the science, there are plenty of courses online.  For our purposes, you get the picture.

Given that an essential oil has the power to communicate messages to the brain and those messages may cause a physical, mental, or emotional response, can you see why it is so important for an aromatherapist to understand olfaction?

Interested in learning more? My next post will be all about pheromones.

 

References:

Sense of Smell Institute. (2009). Human Pheromones: What’s Purported, What’s Supported. [White paper].Retrieved from http://files.achs.edu/resource/aroma501/human_pheromones_final.pdf

 

What is aromatherapy?

aromatherapy (1)

What is aromatherapy? Did you know that this very question causes major debates? There are a whole bunch of words and terms tossed about: aromatology, aromachology, aromatherapy, holistic aromatherapy, psychoaromatherapy. Seriously, it’s still a little daunting for me and I’m a pro. So, what exactly is aromatherapy?

For most people who are new to aromatherapy, they conjure up images of candles or bath salts.  Maybe they picture a scene with a woman in a bathtub, surrounded by things that smell good.  Well, that might be part of it, but it definitely does not cover it.  

Aromatherapy has a vast number of definitions, even amongst some aromatherapists.  Some definitions, such as the one contained in The Concise Oxford Dictionary, which defines aromatherapy as “the use of aromatic plant extracts and essential oils in massage and other treatment”, seem to be overly restrictive and do not fully embody modern aromatherapy.  According to Jane Buckle, author of our Clinical Aromatherapy textbook, aromatherapy is a misnomer because it is not just about smells and massage.  

The Sense of Smell Institute (SSI) recognizes aromatherapy as “the therapeutic effects of aromas on physical conditions as well as psychological conditions”.  This definition is much more inclusive and allows us to break aromatherapy into several subdisciplines, as described by Başer.  Aromatherapy is the more generic and overarching term, which will include: aromatherapy, aromatology, and aromachology.

Aromatology, a subdiscipline of aromatherapy, is concerned with the internal usage of essential oils.  The method of internal consumption is not as important as the effects of the chemicals.  This is usually overseen by doctors or herbalists and is traditionally quite common throughout much of Europe.

Aromachology is closely aligned with psychology since it is concerned with the impact of smells on feelings.  It is also referred to as psychoaromatherapy and aims to study the impact of aromas on endorphins and the limbic system. (Buckle, 2003)  

The term “holistic aromatherapy” seems to refer to an approach that considers that patient as a whole and aims to treat them as such.  This is a practice undertaken by many nurses in the U.K. who have begun to embrace complementary modalities in their healthcare practices.  This term most closely describes what I, as a student, envision aromatherapy to be.

Now, you may still be wondering how aromatherapy works.  There are a couple of different ways that the essential oils cause therapeutic actions within the body.  Oils can be applied topically to the skin, with somewhere around 20-75% of the oil absorbed by the skin.  It varies greatly by atomic weight of the oil but it is pretty straightforward.  The oils either treat a topical issue or treat an internal issue once they have gotten into the bloodstream.  Oils are sometimes ingested. This is also a pretty simple concept. The final way that oils work their magic is through inhalation. This is pretty complex so if you want to learn more, check out How the Sense of Smell Works.

References:

Başer, K. H., & Buchbauer, G. (2010).Handbook of essential oils: science, technology, and applications. Boca Raton: CRC Press/Taylor & Francis.

Buckle, J. (2003). Clinical aromatherapy: essential oils in practice (2nd ed.). Philadelphia: Churchill Livingstone.