product environmental footprint category rules...

1

Product Environmental Footprint

Category Rules (PEFCR)

Household Heavy Duty Liquid Laundry Detergents (HDLLD) for

machine wash

DRAFT Final , 1st version (post EFSC review and taking into account the comments of the companies involved in the

supporting studies) Confidential

(No external distribution without A.I.S.E. prior agreement)

3 June 2016

PEFCR pilots: Heavy Duty Liquid Laundry Detergents (HDLLD) for machine wash

3 June 2016 draft Final PEFCR –First version of 146

Table of contents I. Introduction ................................................................................................ 11

II. General information about the PEFCR ........................................................... 12

II.1. Technical Secretariat ........................................................................... 12

II.2. Consultation and stakeholders ............................................................... 13

II.3. Date of publication and expiration ......................................................... 14

II.4. Geographic region ............................................................................... 14

II.5. Language(s) of PEFCR .......................................................................... 14

III. Methodological inputs and compliance .......................................................... 15

IV. PEFCR review and background .................................................................... 16

IV.1. PEFCR review panel ............................................................................. 16

IV.2. Review requirements for the PEFCR document ......................................... 16

IV.3. Reasoning for development of PEFCR ..................................................... 16

IV.4. Conformance with the PEFCR Guidance .................................................. 18

V. PEFCR scope ................................................................................................ 19

V.1. Unit of Analysis ...................................................................................... 20

V.2. Representative product ........................................................................... 21

V.3. Product classification (NACE/CPA) ............................................................. 21

V.4. System boundaries – life cycle stages and processes ................................... 21

V.4.1. System diagram ............................................................................... 21

V.4.2. System boundaries – upstream processes/scenarios .............................. 25

V.4.3. System boundaries – downstream processes/scenarios .......................... 27

V.5. Selection of the EF impact categories indicators .......................................... 28

V.5.1. Identification of the most relevant impact categories indicators ............... 29

V.6. Additional environmental information ........................................................ 31

V.6.1. Other initiatives by the HDLLD sector .................................................. 31

V.6.2. Addressing Biodiversity ..................................................................... 32

V.7. Assumptions/limitations .......................................................................... 33

VI. Resource use and emission profile ............................................................... 34

VI.1. Screening step .................................................................................... 34

VI.1.1. Identification of the most relevant life cycle stages ............................ 34

VI.1.2. Identification of the most relevant processes ..................................... 35

VI.1.3. Identification of the hotspots .......................................................... 40

VI.2. Data quality requirements .................................................................... 43

VI.3. Requirements regarding foreground specific data collection ....................... 46

VI.4. Requirements regarding background generic data and data gaps ............... 49



VI.4.1. Electricity mix and Heat mix – country specific process ....................... 51

VI.5. Data gaps .......................................................................................... 52

VI.6. Use stage ........................................................................................... 52

VI.7. Logistics ............................................................................................ 54

VI.8. End-of-life stage ................................................................................. 54

VI.8.1. Wastewater treatment ................................................................... 55

VI.8.2. End of life scenario for packaging .................................................... 61

VI.9. Requirements for multifunctional products and multiproduct - processes allocation ....................................................................................................... 64

VI.9.1. Introduction ................................................................................. 64

VI.9.2. Application to this PEFCR ................................................................ 66

VII. Benchmark and classes of environmental performance ................................... 67

VIII. Interpretation ........................................................................................ 69

IX. Reporting, Disclosure and Communication .................................................... 70

X. Verification .................................................................................................. 76

XI. Reference literature ................................................................................... 78

XII. Supporting information for the PEFCR .......................................................... 81

XIII. Annex ................................................................................................... 82

XIII.1. Representative product (RP) .............................................................. 82

XIII.2. Supporting studies ........................................................................... 89

XIII.3. Benchmark and classes of environmental performance .......................... 90

XIII.4. Upstream scenarios (optional) ............................................................ 91

XIII.5. Downstream scenarios (optional) ........................................................ 91

XIII.6. Normalisation factors ........................................................................ 91

XIII.7. Weighting factors ............................................................................. 92

XIII.8. Foreground data to be collected (specific data) ..................................... 93

XIII.9. Generic and semi-specific data ........................................................... 94

XIII.9.1. Generic and semi-specific data or activity parameters......................... 94

XIII.9.2. Guidance in case of refillable packaging ............................................ 95

XIII.9.3. Data sources and process LCI to consider ......................................... 96

XIII.10. EoL formulas ................................................................................. 122

XIII.11. Background information on methodological choices taken during the development of the PEFCR .............................................................................. 123

XIII.11.1. Energy mix ............................................................................... 123

XIII.11.2. Background information on the emissions/losses of detergent manufacturing plant ................................................................................... 124

XIII.11.3. Wash Energy Consumption –Temperature Relationship.................... 126



XIII.12. Review of the existing studies and Analysis of Consistencies and differences between existing PCRS and the PEF Guide ........................................................ 130

XIII.12.1. Analysis and comparison of USEtox/ESC evaluation ........................ 135



Table of tables Table II-1: Aggregated market shares from companies of Household Liquid Laundry

detergents in the EU, represented in the A.I.S.E. PEF TS, as at July 2013 ............. 12

Table V-1: Bill of materials template ..................................................................... 26

Table V-2: List of EF impact categories and related assessment methods used ............ 28

Table V-3: First proposal of selection issued from the PEF screening report ................. 30

Table VI-1: Identification of the most relevant processes ......................................... 38

Table VI-2: Identification of the hotspots ............................................................... 41

Table VI-2: Criteria that shall be used to perform the DQA ....................................... 44

Table VI-3: Specific data (activity data) ................................................................. 46

Table VI-4: template for primary packaging data collection ...................................... 48

Table VI-5: Semi-specific data (activity data) ......................................................... 49

Table VI-6: Generic data ..................................................................................... 50

Table VI-7: Removal rate and the characterisation factor for each component of the average formulation (A.I.S.E. HDLLD reference product) .................................... 60

Table VI-8: parameters for the end-of-life formula .................................................. 62 Table VI-9: default recycling efficiency and recycling process .................................... 64

Table VII-1: PEF profile of the HDLLD RP, incl. range of indicator results ................... 67

Table IX-1: Overview of the environmental indicators for liquid laundry detergents retained for B2B and B2B testing .................................................................... 71

Table XIII-1: Bill of materials ............................................................................... 83

Table XIII-2: Packaging description ...................................................................... 84

Table XIII-3: HDLLD manufacture consumptions ..................................................... 85

Table XIII-4: Data used to model the product use stage .......................................... 87

Table XIII-5: parameters applied data sources for the end-of-life formula .................. 88

Table XIII-6: Supporting studies – products studied ................................................ 89

Table XIII-7: Supporting studies – main results for EU-28 scenario - 40°C ................. 90

Table XIII-6: Recommended Normalisation factors for EU 27 (2010) based on domestic inventory .................................................................................................... 92

Table XIII-7: Specific data ................................................................................... 93

Table XIII-8: Semi-Specific data ........................................................................... 94

Table XIII-9: Generic data ................................................................................... 95

Table XIII-10: Process LCI ................................................................................... 97 Table XIII-11: ERASM 2014 LCI ......................................................................... 100

Table XIII-12: Completeness, Precision/uncertainty, Methodological appropriateness and consistency score for each default dataset. .................................................... 103

Table XIII-13: Technology, Geographical and Time information on each default dataset (source: relative datasource e.g. ecoinvent) ................................................... 109

Table XIII-14: Share of household connected to WWT by country in EU28+EFTA (Source Eurostat) .................................................................................................. 122

Table XIII-15: electricity consumption mixes and industrial heat mixes (2012) .......... 123



Table XIII-16: Energy consumption at different temperatures per country and an average ............................................................................................................... 127

Table VI-4: ESC tool assessment for ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ .............................................................................................. 141



Table of figures Figure V-1: System boundary diagram for HDLLD ................................................... 22

Figure V-2: Organizational Boundaries .................................................................. 24

Figure VI-1 : Identification of the most relevant life cycle stages ............................... 35

Figure VI-2 : Life cycle stages modelling with processes and activity data ................... 36

Figure VI-3 : Studied system with most relevant processes (contributing for more than 80% on the indicators) and linked activity data under the System Boundaries ....... 39

Figure VI-4: Typical scheme of wastewater treatment plant ...................................... 56

Figure VI-5: ecoinvent modelling principles of WWTP ............................................... 56

Figure VI-6: modelling principles adapted for HDLLD released into a WWTP ................ 57

Figure VI-7: Multifunctional process with several input products and resources consumed, and various wastes and emissions generated (source: ILCD Handbook) ............... 65

Figure VI-7: Theoretical example of Box and whisker plot ........................................ 68

Figure XIII-1: Graphical comparison of the different wash temperature – energy relationships .............................................................................................. 129

Figure VI-22: USEtox scenarios for HDLLD using different CF data sets and HDLLD compositions ............................................................................................. 137



Abbreviations and Units Abbreviations: A.I.S.E International Association for Soaps, Detergents and Maintenance Products ADEME Agence de l'Environnement et de la Maîtrise de l'Energie ASP Advanced Sustainability Profile

B2B Business to Business B2C Business to Consumer CAS Chemical Abstracts Service CDV Critical Dilution Volume CECED European committee of domestic equipment manufacturers CF Characterisation Factor CFC Chlorofluorocarbon CH Switzerland CTU Comparative Toxic Unit DQA Data Quality Assessment DQR Data Quality Rate EC European Commission ECHA European Chemicals Agency EF Environmental Footprint EFTA European Free Trade Association ELCD European reference Life Cycle Database ERASM Environment & Health Risk ASsessment and Management EoL End-of-life EPD Environmental Product Declaration ESC Environmental Safety Check EU European Union FAO Food and Agriculture Organization of the United Nations EU COM European Commission

GLO Global (worldwide) market situation (ecoinvent abbreviation to define the geographic scope)

GWP Global Warming Potential HC50 Hazardous Concentration for 50% of the species HDLLD Heavy Duty Liquid Laundry Detergents HERA Human and Environmental Risk Assessment HDPE High Density Polyethylene IEA International Energy Agency IFRA International Fragrance Association ILCD International Reference Life Cycle Data System ISO International Organization for Standardization JRC Joint Research Centre LAS Linear alkylbenzene sulfonate LCA Life Cycle Assessment LCI Life Cycle Inventory LCIA Life Cycle Impact Assessment LDPE Low Density Polyethylene



NACE Nomenclature Générale des Activités Economiques dans les Communautés Européennes

NF Normalization Factor NMVOC Non-Methane Volatile Organic Compounds OECD Organisation for Economic Co-operation and Development OEFSR Organisation Environmental Footprint Sector Rules PCR Product Category Rules PEC Predicted Environmental Concentration PEF Product Environmental Footprint PEFCR Product Environmental Footprint Category Rules PESR Projected Environmental Safety Ratio PM 2.5 Fine particulate matter (diameter of 2.5 micrometres or less) PNEC Predicted No Effect Concentration QSAR Quantitative Structure–Activity Relationship REACH Registration, Evaluation, Authorisation and Restriction of Chemicals RER European market situation (ecoinvent abbreviation to define the geographic

scope) RIFM Research Institute for Fragrance Materials RP Representative Product SCP/SIP Action Plan on sustainable consumption an production (SCP) and sustainable

industrial policy (SIP) SETAC Society of Environmental Toxicology and Chemistry SLES Sodium lauryl ether sulfate SMGP Single market for green products SSD Species Sensitivity Distribution SOM Soil Organic Matter TS Technical Secretariat UNEP United Nations Environment Program US EPA United States Environmental Protection Agency WBCSD World Business Council for Sustainable Development WMO World Meteorological Organization WRI World Resources Insititue WTA withdrawal-to-availability WWTP Wastewater treatment plant

Units:

CTU Comparative Toxic Unit g Gram kg Kilogram km Kilometre kWh Kilowatt hour m² Square metre m³ Cubic metre MJ Mega Joule ml millilitre pkm Person kilometre t Tonne



tkm Tonne kilometre vkm Vehicle kilometre °C Temperature in Celsius



I. Introduction The ‘Product Environmental Footprint (PEF) Guide’ (Annex II to Recommendation 2013/179/EU)1 provides detailed and comprehensive technical guidance on how to conduct a PEF study. PEF studies may be used for a variety of purposes, including in-house management and participation in voluntary or mandatory programmes. This PEFCR shall be used in parallel with the PEF Guide. Where the requirements in this PEFCR are in line with but at the same time more specific than those of the PEF Guide, such specific requirements shall be fulfilled. The use of the present PEFCR is optional for PEF guide in-house applications, it is recommended for external applications without comparison/comparative assertions, while it is mandatory for external applications with comparisons/comparative assertions. In the latter two applications contexts, organizations are to fulfil the requirements of thisPEFCR document from section II to X. This draft PEFCR endeavours to be compliant with the ‘Guidance for the implementation of the EU PEF during the EF Pilot Phase (version no. 5.2)’ and its ‘Product Category Rule Template’ (Version 1.0, April 16, 2013).

1 PEF Guide, Annex to Commission 2013/179/EU on the use of common methods to measure and communicate the life cycle environmental performance of products and organizations (April 2013) and available at http://ec.europa.eu/environment/eussd/smgp/index.htm



II. General information about the PEFCR

II.1. Technical Secretariat

The Technical Secretariat (TS) consists of the members of the A.I.S.E. PEF pilot project that took place between October 2013 and July 2016:

- A.I.S.E. (International Association for Soaps, Detergents and Maintenance Products)

- AFISE (Association Française des Industries de la Détergence, de l’Entretien et des Produits d’Hygiène Industrielle)

- CESIO (European Committee of Organic Surfactants and their Intermediates) - DETIC (Association Belgo-Luxembourgeoise des producteurs et des

distributeurs de savons, cosmétiques, détergents, produits d’entretien, d’hygiène et de toilette, colles, produits et matériel connexes)

- Dalli Group - Ecover Co‐ordination Center NV - GS1 (Global Standards 1) - Henkel AG & Co. KGaA - McBride plc - Procter & Gamble Services Company NV - SGS - Solinnen - FOEN (Swiss Federal Office for the Environment) - TSC (The Sustainability Consortium) - TU Berlin (Chair of Sustainable Engineering) - Unilever - Vandeputte S.A./NV Savonnerie ‐ Zeepfabriek

A PEF Communications sub-group (‘PEF COMMs’), which reports into the A.I.S.E. PEF TS, has been established. This group, consisting of experts having different background including sustainability, communication, marketing, market and consumer research, is leading the communications work and adequate liaising with the different suppliers (designers, agencies, market research etc.) through the A.I.S.E. Secretariat (Valérie Séjourné/Sascha Nissen).

The seven companies represented in the A.I.S.E. PEF TS have a share of over 73% of the total EU liquid laundry market (see table) and it is estimated that there is in total more than 100 manufacturers are operating in this product sector. An important share of the market is also covered by retailers’ own brands (about 14% in the EU market in 2012).

Table II-1: Aggregated market shares from companies of Household Liquid Laundry detergents in the EU, represented in the A.I.S.E. PEF TS, as at July

2013

Companies 2012 Dalli*, Ecover, Henkel, McBride*, Procter & Gamble, Unilever, Vandeputte*

>73.3%*

Source: Euromonitor International



*Those 3 companies are particularly active in the manufacturing of products for private label retailers. Should the share of the total private label sales be added to the above percentage, it can be anticipated that the coverage of the Technical Secretariat members is even higher than 73.3%.

Trade representativeness of A.I.S.E. A.I.S.E., the international Association for Soaps, Detergents and Maintenance Products is the official representative body of this industry in Europe. Its membership includes 9 direct member companies and 29 national associations in Europe and beyond, covering about 900 companies ranging from small and medium-sized enterprises to large multinationals active both in the consumer goods market and the industrial & institutional (I&I) domains. It is estimated that A.I.S.E. together with its members represents more than 90% of the market of this industry.

II.2. Consultation and stakeholders

The procedure for the development of a PEFCR according to the “Guidance for the implementation of the EU PEF during the EF pilot phase” considers a number of steps that have been followed by this Technical Secretariat, namely:

- Definition of PEF product category and scope of the PEFCR - Definition of the product “model” based on representative product(s) - PEF Screening - Draft PEFCR - PEFCR supporting studies - Confirmation of the benchmark(s) and determination of performance classes - Final PEFCR

A first physical consultation with stakeholders took place in March 2014 where the definition of the PEF product category, the scope of PEFCR and the definition of the representative product were presented and commented.

The TS invited a wide range of stakeholders including SMEs, environmental organizations and consumer associations. In total, approximately60 representatives from 46 stakeholder organizations (18 companies multinational to SMEs, 14 sectorial or industry organizations, 14 experts and advisors (from governmental body, academia, LCA consultants, etc.) were invited and from those 29 organizations outside the Technical Secretariat attended the consultation meeting and provided comments. Companies that were represented at the 1st stakeholder consultation as external stakeholders in March 2014 add another 4% to the market that is covered by the TS members (manufacturers and retailers).

The document hereby constitutes the draft final PEFCR, which is the deliverable required by the EU COM after the completion of the PEF Screening step (including the critical review of the PEF screening report and model by the European Commission and a neutral Review Panel).

The first draft PEFCR was submitted to virtual consultation in April 2015 and the new version including the amendments made further to the stakeholder comments as well as those received from the EF Technical Advisory Board was validated by the Steering Committee in July 2015. The second draft was used by six companies to perform a PEF supporting study on one of their products sold in Europe. This first version of the draft



final PEFCR includes the amendments made in response to comments provided by the 6 companies who performed the PEF supporting studies.

A virtual public consultation on this draft final version of the PEFCR will be carried out between 3 June and 1 July 2016.

All documents related to the work performed by the Technical Secretariat as well as the stakeholder consultation (document submitted to consultation, minutes of physical consultation, stakeholders comments and answers from the Technical Secretariat) are available at:

https://webgate.ec.europa.eu/fpfis/wikis/display/EUENVFP/Stakeholder+workspace%3A+PE

FCR+pilot+Household+liquid+laundry+detergents.

II.3. Date of publication and expiration

Version number: draft final PEFCR version 1

Date of publication: xx xx 2016

Date of expiration: 4 years after the date of publication

II.4. Geographic region

This PEFCR is valid for any Heavy Duty Liquid Laundry Detergent (HDLLD) sold in the European Union of 28 + EFTA countries.

When the HDLLD under study is manufactured outside Europe, the company shall use only specific data (activity data as well as process datasets) for the manufacturing step and the upstream steps since default data proposed by the PEFCR are representative of sourcing and manufacturing in Europe.

II.5. Language(s) of PEFCR

This original version in English supersedes translated versions in case of conflicts.



III. Methodological inputs and compliance This first draft PEFCR has been prepared in conformance with:

the PEF Guide, Annex II to Commission 2013/179/EU on the use of common methods to measure and communicate the life cycle environmental performance of products and organizations (April 2013),

the Detergent Regulation (EC648/2004).

The Technical Secretariat identified a list of existing PCRs and other useful documents (LCAs, other methodologies, etc.) displayed in section XI.

The analysis of those documents was carried out in order to check the similarities and differences respect to the PEFCR Methodologies and recommendations. A.I.S.E. PEF TS presented the conclusions of the analysis to the EF Steering committee, who approved them on the 19th of May 2014 (see annex XIII.12).

The relevant methodological inputs from these existing PCRs were considered during the screening study and the preparation of this PEFCR.



IV. PEFCR review and background

IV.1. PEFCR review panel

The members of the PEFCR review panel are:

Prof. Roland Clift - chairman of the panel. He was a founding member of the UK Ecolabelling Board, a member of the “Groupe des Sages” set up in the 1990s to advise the European Commission on the application of LCA to product labelling. More recently, he was a member of the groups which initially drafted and subsequently revised PAS 2050. His self-assessed reviewer qualification score is 23 points.

Mrs Hélène Lelièvre - member of the panel. She has 16 years of experience in LCA and Sustainability consulting. She has been working as an independent LCA expert consultant in environment (Enviroconseil) for 8 years and in particular performed 5 complete LCA studies on laundry detergents. Her self-assessed reviewer qualification score is 15 points.

Mr Martin Windenberg – member of the panel. He works as a guest researcher at the Regional Centre of Expertise Vienna (RCE-Vienna) at the Institute for the Environment and Regional Development. He has been leading the Sustainability Project at GLOBAL 2000/Friends of the Earth Austria for more than 5 years, resulting in a holistic assessment method for sustainable agricultural production used in business co-operations. His self-assessed reviewer qualification score is 6 points.

IV.2. Review requirements for the PEFCR document

The critical review is essential for ensuring that the PEFCR:

- is consistent with the guidance provided in the PEF Guide and the PEFCR guidance (version 5.2);

- is written in a format that persons with a technical background but without pre-knowledge in environmental footprints can understand and use to conduct a PEF study;

- completes the PEF guide requirements with additional requirements specific to the particularities of HDLLD life cycle; e.g. unit of analysis, allocation and calculation rules are adequate with the HDLLD category;

- provides guidance to conduct a compliant PEF study and clearly specify the most relevant LCIA indicators and additional environmental information for the HDLLD product category to determine the environmental performance;

- enables comparisons and comparatives assertions in all cases when this is considered feasible, relevant and appropriate.

IV.3. Reasoning for development of PEFCR

The current PEFCR aims at providing means to evaluate the environmental impacts of HDLLD used in the EU plus EFTA, applying a harmonised approach for any HDLLD manufacturer, in order to have the possibility to compare results.



The reasoning for A.I.S.E. to develop a PEFCR builds on the key following points: A.I.S.E. has at the heart of its activities the “Agenda for Sustainable

Cleaning”: this agenda sets out how A.I.S.E. views its approach and contribution to sustainable development and defines the framework for all the work that A.I.S.E. does. It is regularly updated to reflect relevant developments. Whilst it is obvious that addressing the sustainable development issues is a key priority in Europe (cf. the Commission Communication on a Roadmap for moving to a low‐carbon economy in 20502, the Roadmap to a Resource Efficient Europe3, the Single Market for Green Products initiative4 , or the 7th Environment Action Plan5 etc.), A.I.S.E. sees itself having a key role in providing its contribution to those major environmental and societal challenges to be addressed by all relevant actors in society, including business. The series of proposals are designed to improve – among others – the environmental performance of products and encourage more sustainable consumption. The action plan also clearly recognises the value of the role played by self‐regulatory voluntary industry initiatives. A.I.S.E. – representing the soaps, detergents and maintenance products industry in Europe and beyond – has long been committed to protecting consumers and the environment and has a long and successful track record of acting voluntarily including broader sustainability issues, in constructive and continuous dialogue with stakeholders. The cleaning and maintenance products industry in Europe has collectively defined its vision as: "We benefit society by contributing to the sustainable improvement of the quality of life through hygiene and cleanliness, in a constructive, competitive and innovative way.”

Tangible initiatives that can truly contribute effectively to PEF and sustainable consumption overall: A.I.S.E. places high emphasis on the development and promotion of voluntary initiatives, particularly for the part they play in demonstrating the detergent industry’s responsible approach. The major voluntary initiatives particularly noteworthy in the context of PEF are:

o The “A.I.S.E. Charter for Sustainable Cleaning”6: The Charter was launched in all EU countries plus Switzerland, Norway and Iceland at the end of 2004, and was updated with a “product dimension” in 2010, via “Advanced Sustainability Profiles” (ASPs) for major product groups of the industry sector. Those ASPs are designed to determine a set of minimum yet ambitious sustainability criteria that a product must meet, in order to be considered as an example of a product with a good sustainability profile. The Charter covers all product categories of the detergent industry – from laundry to maintenance products whether in the household or the industrial and institutional sector. This voluntary initiative broke new ground by encouraging adoption of good sustainability management practice at all stages of the product life‐cycle at factory level throughout the EU, and by developing product category rules applicable for major household products. The process goes through an external independent verification, and gives annual details of EU‐wide progress against certain KPIs (Key Performance Indicators). As at April 2014, more than 200 companies (manufacturers and distributors) have joined the project, representing more than 90% of the total production output for Europe. The Charter is seen as a long term project which will continue to evolve over time, to steer better sustainability practices for the whole sector.

2 COM (2011) 112 3 COM (2011) 571 4 COM/2013/019 5 Decision 1386/2013/EU 6 http://www.sustainable-cleaning.com/en.companyarea_documentation.orb



o The French Grenelle and pilot case for laundry detergents on environmental information7: A.I.S.E.’s French association Afise, together with seven of its members, volunteered to participate to the French pilot work on environmental information. A life cycle study of the environmental impacts of four household laundry detergent product forms was developed, assessed against standards defined by the French environment ministry and its sectorial application for laundry detergents, jointly defined by AFNOR, ADEME and the environment ministry with the participation of the industry. Afise has now published the methodology and results of the study, highlighting also the A.I.S.E. Charter for Sustainable Cleaning and the value of its aquatic environmental impact tool (ESC) as a substitute for the proposed French (USEtox) tool which was not ready.

o Engaging with consumers towards sustainable consumption: A broad number of projects are led by A.I.S.E. to engage consumers in the safe and sustainable use of products. Besides common artwork material used on packs in Europe since 1997, and the multilingual Cleanright.eu website8 which provides consistent consumer communication across Europe, A.I.S.E. also runs consumer engagement campaigns. c

Attempts to harmonize PEFCR or align with existing PCRs are presented in Annex XIII.12.

IV.4. Conformance with the PEFCR Guidance

This final draft PEFCR has been prepared in conformance with the ‘Guidance for the implementation of the EU PEF during the Environmental Footprint (EF) pilot phase – version 5.2.

This final draft of the PEFCR will be submitted to the critical review. A summary of the assessment will be provided here.

7 http://www.afise.fr/Default.aspx?lid=1&rid=121&rvid=135 8 http://uk.cleanright.eu/



V. PEFCR scope This PEFCR provides rules for the product category “Heavy Duty Liquid Laundry Detergents (HDLLD) for Machine Wash,” including 100% Liquid tablets (unit-dose).

Other products such as “Light Duty Liquid Laundry Detergents”9, “Powder Laundry Detergents” and “Powder Tablets” are part of the same category; but they are not covered by the PEFCR, since the different product types vary in their functional units. The A.I.S.E. PEF TS believes that the greatest clarity and accuracy for PEF product evaluations occur by focusing on one precisely defined and viable product. Expanding the PEF pilot to other products types would complicate the practicalities of the scheme and may have an adverse impact on interpretation of the results.

The A.I.S.E. plans to evaluate these other detergent product formats in order to assess if and how to apply the HDLLD PEFCR also to these product formats. Ultimately, it will benefit the PEF scheme to set parameters at the highest feasible level of product classification, without sacrificing accuracy, verifiability and meaningfulness. A.I.S.E. recognizes the importance of being in a position to accurately evaluate the best level at which to set the category rules for the entire laundry detergent segment. Due to the similarity of data, in most cases A.I.S.E. anticipates being able to extrapolate from liquid detergent to other formats following expert assessment of the differences and with additional work to develop the missing data (e.g. characterisation factors).

Mid 2013 A.I.S.E. launched the ‘I prefer 30°’ consumer engagement campaign to promote the benefits of low temperature washing (www.iprefer30.eu). In this context, an in-depth analysis on best laundry practice was carried out with experts, resulting in a ‘laundry guidance’ to consumers. Following this ‘laundry guidance’, it is indicated that a set of laundry items may adequately be washed with a heavy duty liquid laundry detergent at 30 °C: ‐ All outer clothing items (jackets, sweaters, shirts, skirts, trousers, dresses, ...), ‐ T-shirts, ‐ Top underclothing, ‐ Socks (unless in cases of fungal infection), ‐ Table linen, ‐ Curtains, ‐ Beach towels. Items that should not be washed with liquid detergents, but with a powder detergent10 at high (60°) temperature include: ‐ Items of ill persons, clothing of their careers or items of vulnerable persons, ‐ Professional clothing that may be contaminated,

9 The intended application of heavy-duty and light-duty detergents is different because each detergent is used for different textiles and in different washing programs, and each has a different formulation. According to the Detergent Regulation (EC648/2004), a detergent shall be considered to be a heavy-duty detergent unless the claims of the manufacturer predominantly promotes fabric care. 10 A general purpose powder detergent is a powder detergent that can be used for any textile/colour and which contains oxygen-based bleaching agents (see ingredient list on the package).



‐ Kitchen/food preparation textiles, ‐ Items heavily soiled with faeces, vomit, blood,

For all other normal daily laundry items, the use of a general purpose powder detergent or a liquid laundry detergent but using higher temperatures is recommended: ‐ Normal laundry items with or without intimate body contact.

V.1. Unit of Analysis

According to the PEF guide, the unit of analysis defines the qualitative and quantitative aspects of the function(s) and/or service(s) being provided; the unit of analysis definition answers the questions “what?”, “how much?”, “how well?”, and “for how long?

The unit of analysis11 for the HDLLD Product Category shall be the following:

“wash 4.5 kg of dry fabric with the recommended dosage for a 4.5 kg load; normally soiled fabric; with a medium water hardness;

in a 6 kg capacity machine wash at 75% loading ”.12

The unit of analysis addresses the following questions posed by the PEF:

What?: washing dry fabric;

How much?: 4.5kg of dry fabric;

How well?: wash normally soiled fabric in water with medium hardness until clean (i.e., reaching a performance acceptable to consumers);

How long?: one washing machine cycle.

The reference flow shall be the recommended dosage of the product, plus packaging.

Note: the Life Cycle Inventory (LCI) may be calculated for “a wash” or for “a kg of dry fabric”, as long as the calculation refers to the standard wash defined in the Unit of Analysis.

The product shall be fit for purpose, and reach a performance acceptable to consumers, consistent with claims made and supplemented by independently verifiable performance data held by companies in support of their claims. 13

11 in conformance with the Detergent Regulation (EC648/2004) 12 The aspects “4.5 kg of dry fabric”, “normally soiled fabric” and “medium water hardness” used for the product function definition are based on the Detergent Regulation (EC648/2004). Please refer to the legislation text for the full definition. 13 In the context of the PEF pilot on liquid laundry detergents, the same approach on performance as used in the A.I.S.E. Charter for sustainable cleaning is being applied.



V.2. Representative product

The representative product is a “model” of concentrated liquid detergent products dosed at 75ml/job sold in the EU market in 2014.. This virtual product is called ‘A.I.S.E. Heavy Duty Liquid Laundry Detergent Reference product’ or ‘A.I.S.E. HDLLD Reference Product’ or also ‘A.I.S.E. HDLLD RP’ throughout this PEFCR.

This ‘A.I.S.E. HDLLD Reference Product’ has been defined using data collected from the companies participating in the TS normalized to the market share of each company (see Annex XIII.1 for a detailed description of the definition process).

V.3. Product classification (NACE/CPA)

The classification of products by activity is NACE 20.41 – Manufacture of soap and detergents, cleaning and polishing preparations. More precisely the classification of the product category considered here is 20.41.32 – Detergent and washing preparations. For the purpose of this pilot, HDLLD are the only products considered in this category.

This classification is more precise than the minimum requirement of a two‐digit CPA code division in the PEFCR guidance, version 5.2 and the PEF Guide. This is because the “unit of analysis” is specific to the category retained (20.41.32) and would be different with other products integrated in NACE 20 (NACE code C20: Manufacture of chemicals and chemical products).

V.4. System boundaries – life cycle stages and processes

All attributable life-cycle stages listed below shall be considered:

- ingredients sourcing and manufacturing; - packaging raw material sourcing and manufacturing; - transport of ingredients and packaging materials to the detergent

manufacturing plant; - detergent manufacturing (HDLLD manufacture); - distribution to retail; - transport and distribution to consumer’s homes; - product use and; - the end-of-life, including wastewater treatment (end-of-life of the detergent)

and municipal solid waste treatment (end-of-life of packaging).

Detergent manufacture does not involve the production of any co-products or by-products.

V.4.1. System diagram

The Figure V-1 presents the system boundary diagram for HDLLD:



Figure V-1: System boundary diagram for HDLLD

5. HDLLD manufacture

6. Transport and distribution to retail

7. Transport and distribution to consumer homes

8. Product use

9. Waste water treatment 10. Solid waste treatment (packaging)

1. Chemical ingredients sourcing and manufacturing

2. Packaging raw materials sourcing and manufacturing

3. Transport to processing plant 4. Transport to processing plant

Upstre

amprocesses

Dowstre

amprocesses

The following diagram on organizational boundaries highlights the typical activities with different levels of influence of the detergent company itself and the availability to operational data14:

14 This diagram with the different levels of influence was built on the basis of the feedback of the detergents companies, members of the TS. Therefore the levels of influence of the detergent company performing a PEF study may differ slightly from this average situation.



- Black: life cycle stage under operational control of the detergent company (i.e. processes run by the company). A full access to company-specific data is expected.

- Medium grey: life cycle stage with processes run by other companies in direct contact with the detergent company (direct suppliers). A high probable access to company-specific data is expected.

- Light grey: life cycle stage with processes run by companies in indirect contact with the detergent company (no-direct suppliers). A medium to low probable access to company-specific data is expected.

- White: life cycle stage with processes run by companies/organization not in contact with the detergent company (e.g. detergent user, wastewater treatment plant). No access to company-specific data is expected.



Figure V-2: Organizational Boundaries



Excluded processes: The washing machine manufacturing15 and the fabrics to be washed, which are detergent independent processes, shall be excluded.

Moreover, the losses to the environment from detergent production are less than 0,4% of the losses during consumer use16. Therefore these shall not be considered in this LCA.

No other losses of detergent are expected such as during retail and storage and use by the consumer. 17

V.4.2. System boundaries – upstream processes/scenarios

The upstream processes are:

the ingredients sourcing and manufacturing; the packaging raw material sourcing and manufacturing; and, the transport of ingredients and packaging to the processing plant.

Ingredients The ingredients are the purchased raw materials which are combined during the HDLLD manufacturing process. The ingredients constitute the Bill of Materials (unreacted formulation).

Two Bills of Materials shall be considered:

The Bill of Ingredients ‘as bought from the suppliers’. This bill considers each ingredient and its quantity of solution as bought from the suppliers and necessary to produce the detergent under study.

The Bill of Ingredients ‘in 100% active content’. This bill considers each 100% active content chemical substances and its quantity necessary to produce the detergent. If an ingredient is bought as a solution, each solute and each solvent shall be considered separately.18

The bill of ingredients ‘as bought from the suppliers’ shall be considered only at the transport to detergent manufacturing step to collect the appropriate data related to the transport of each ingredient (ingredient mass and transport distance and mode) if the detergent company has access to company-specific data from its suppliers (see Figure V-2).

The bill of ingredients ‘in 100% active content’ shall be considered at the sourcing of ingredients step. Indeed, to ensure the consistency between the data collected and the datasets used in the calculation, each ingredient shall be declared as 100% active content and linked to appropriate dataset defined also for 100% active content.

15 However the most representative technology used in EU (front load washing machine) was considered at use phase to define the electricity and water consumption (see section VI.6) 16 The details of the calculation and source of documentation are available in annex XIII.11.2. 17 This differs from the default rate of loss of 5% for cleaning products stated by the issue paper Guidance and Requirements for handing the use phase v5.1. January 2016. 18 In case of several solutes, each solute shall be considered separately.



The bill of materials template in Table V-1 gives the list of possible ingredients families with for each family, its functional description, the different types of chemicals and some examples.

Table V-1: Bill of materials template

Ingredients families

Description of function

(source Cleanright website) Type

Example of Chemicals

Water Water

Builders Reduces the effect of water hardness by removing calcium and magnesium ions and increases the effectiveness of the detergent.

Citric acid, salts of citric acid and other salts

Sequestrants Prevents free metal ions from causing any adverse effects on product performance, appearance, or stability by reacting with them.

Phosphonates Sodium phosphonate

Dye Dye

Enzymes Enzymes are catalysts that increase the rate of chemical reactions, such as digestion and growth processes. In the detergent industry, commercial enzymes are used to help ensure a high degree of stain removal, whiteness, fabric and color care, and overall cleaning performance.

Mannanase, protease, amylase, pectinase, lipase, other enzymes.

Fragrances Offer an aesthetic experience for the packed detergent, during/after the washing and when wearing the washed fabrics.

Fragrances

Optical brighteners

Makes the fabrics look brighter and whiter

Surfactant system (anionic – non-ionic)

Used to change the surface tension of water to assist cleansing, wetting surfaces, foaming and emulsifying (the suspension of one liquid evenly within another).

Anionic surfactants

Sodium alkyl ether sulfates (SLES), alkylbenzene sulfonate (LAS)

Soap Oleochemicals fatty acid (cocoate, palm kernel, etc.)

Non-ionic surfactants

Ethoxylates oleochemicals + petrochemical) & other non-ionic surfactants

Alkalinity sources

Increases the alkalinity of the product to aid dissolution of dirt.

Sodium hydroxide, triethanolamine

Solvents Used to dissolve other ingredients Glycerine, glycols, other solvents

Other ingredients

Preservatives, polymers, salts, others

Hydro-soluble film for Unit-dose capsule

polymer film Polyvinyl alcohol (PVA) film

The ‘ingredient sourcing’ and ‘manufacturing’ step shall be considered for each ingredient individually. It shall include mining and extraction of resources, processing of chemicals and transportation between extraction and the chemical manufacturing site.



During the detergent manufacturing process, some raw materials/ingredients may react chemically, such as during the neutralisation of acid surfactant mixtures with alkaline materials. If this occurs then the Bill of Materials (‘unreacted formulation’, in 100% active content) may differ from the so-called ‘reacted formulation’ that refers to the composition of the marketed HDLLD product and which is used by the consumer and ultimately discharged to the sewerage system. The ‘reacted formulation’ shall be used for the evaluation of the impacts at the end of life stage. The chemical substances listed in ‘reacted formulation’ are also expressed as 100% active content.

Packaging The three levels of packaging shall be considered: primary, secondary and tertiary packaging.19

The packaging sourcing and manufacturing step shall be considered for each packaging material individually. Also it shall include mining and extraction of resources, processing of packaging and transportation between extraction and packaging manufacturing site.

V.4.3. System boundaries – downstream processes/scenarios

The downstream processes are:

distribution to retail and its storage; transport and distribution to consumer homes; product use; and, the end-of-life, including the wastewater treatment (end-of-life of the detergent

ingredients) and municipal solid waste treatment (end-of-life of packaging).

The transport and distribution to consumer homes scenario shall take into account the different possible consumer habits when shopping including: by car, by foot, bike or public transport, home delivery.

The use scenario shall take into account the amount of HDLLD, and the use of water and electricity, based on consumer habits data and washing machine performance. The manufacturing of the washing machine and the fabrics washed are not in the scope.

Finally the end-of life scenario shall take into account the solid waste treatment of the packaging and the material recycling process as well as the wastewater treatment of

19 Primary packaging (or consumer packaging) is the material that first contains, preserves and protects the product as well as informs the end user. It also includes dosing devices and it is the smallest unit of distribution. Secondary packaging is outside the primary packaging and is often used to group primary packs together to protect them during storage, transport and distribution. Tertiary packaging (or transport packaging) is outer packaging including pallet, stretch wrap, etc. used for warehouse storage, transport shipping. The default form is a palletized unit load.



HDLLD (based on its ‘reacted formulation’ which is different from the bill of material- see explanations in section V.4.2) and direct discharges when households are not connected to a wastewater treatment plant (see section VI.8.1).

V.5. Selection of the EF impact categories indicators

The Table V-2 provides the list of 15 Environmental Footprint (EF) impact categories related to the assessment methods that shall be used. For each impact category, the following information are provided:

EF impact categories, EF impact assessment model, EF impact category indicator, Source, Classification of the methods performed in the ILCD Handbook “Recommendations

for Life Cycle Impact Assessment in the European context”, JRC, 2011 The recommended characterisation models and associated characterisation factors are classified into three levels according to their quality:

Level I Recommended and satisfactory

Level II Recommended, but in need of some improvements

Level III Recommended, but to be applied with caution

Table V-2: List of EF impact categories and related assessment methods used

EF impact category EF impact category model EF Impact category indicator

Source Classification

Climate change Bern model – Global Warming potentials (GWP) over a 100

year time horizon kg CO2 eq

Intergovernmental Panel on Climate Change,

2007 I

Ozone depletion

EDIP model based on the ODPs of the World Meteorological

Organization (WMO) over an infinite time horizon

kg CFC-11 eq WMO, 1999 I

Human toxicity- carcinogenic effect

USETox model CTUh, c Rosenbaum et al., 2008 II/III

Human toxicity- non- carcinogenic effect

USETox model CTUh, n-c Rosenbaum et al., 2008 II/III

Ecotoxicity for aquatic fresh water20

USETox model CTUe Rosenbaum et al., 2008 II/III

Environmental Safety Check (ESC)21

PESR AISE 2006 Not applicable

20 An EUCOM expert workshop was organized on 15 January 2015 on the topic of ecotoxicity evaluation; it concluded that USEtox must still be used for the screening and supporting studies, but may not be used for benchmarking and communication purposes, until the outcome is more robust (Executive summary of ‘Current and future implementability of USEtox’ PEF meeting, 15 January 2015 (version 23 January 2015)). This conclusion is in line with the findings of the A.I.S.E. PEF TS (Ref. A.I.S.E. PEF Screening Report).



EF impact category EF impact category model EF Impact category indicator

Source Classification

Particulate matter / respiratory inorganics

RiskPoll model kg PM2.5 eq Humbert, 2009 I

Ionizing radiation Human Health effect model kBq U235 eq Dreicer et al., 1995 II

Photochemical ozone formation

LOTOS-EUROS model kg NMVOC eq Van Zelm et al., 2008 as

applied in ReCiPe II

Acidification Accumulated Exceedance model mol H+ eq Seppälä et al., 2006;

Posch et al., 2008 II

Eutrophication – terrestrial

Accumulated Exceedance model mol N eq Seppälä et al., 2006;

Posch et al., 2008 II

Freshwater eutrophication

EUTREND model kg P eq Struijs et al., 2008 II

Marine eutrophication EUTREND model kg N eq Struijs et al., 2008 II

Land use Soil Organic matter (SOM)

model kg C deficit

Milà I Canals et al., 2007

III

Resource depletion water

Swiss Ecoscarcity model m³ of water-eq Frischknecht et al., 2008 III

Resource depletion- mineral, fossil

CML 2002 model kg Sb eq. Van Oers et al., 2008 II

V.5.1. Identification of the most relevant impact categories indicators

Based on the PEF screening normalised results, the five most relevant impact categories would be:

Climate change/ Resource depletion mineral fossil/Human toxicity/ Ecotoxicity for fresh water/ Resource depletion water.

But, in line by European Commission’s guidance and stated in the PEFCR guidelines, the TS has made its selection starting from the normalised screening results and using additional technical criteria and expert judgement The approach is described in the screening report (chapter VII.1 Most relevant impact categories) and was submitted to critical review.

21 According to the conclusions as drawn during the expert workshop on 15 January 2015 (see footnote before), the A.I.S.E. PEF TS agreed to apply an alternative method with regard to ecotoxicity to aquatic freshwater organisms, i.e. the Environmental Safety Check (ESC); see the annex XIII.12.1 for further details and guidance. The tool and a manual are publically available via: http://www.sustainable-cleaning.com/content_attachments/documents/ESC_Calculation_Tool_Version_7_4_20160407.zip; http://www.sustainable-cleaning.com/content_attachments/documents/ESC_Summary_1Oct2010.pdf



Based on this approach, the indicators that are the most relevant for this product category22 are the following:

Table V-3: Proposal of selection issued from the PEF screening report

Relevant EF impact category regarding the HDLLD

Robustness (quality classification based on ILCD Handbook)

Potentially considered for B2B communication?

Potentially considered for B2C communication?

Ecotoxicity for aquatic fresh water

Level II/III To be confirmed (Methodological issues)23

To be confirmed(Methodological issues)

Resource depletion water Level III YES YES

Climate change Level I YES YES


Level II NO NO

Acidification Level II NO NO

Ionizing radiation is not retained for communication purposes since this indicator is mainly linked to the use phase and therefore does not enable the differentiation of liquid laundry detergents. Moreover, the impact assessment for ionizing is among those which are not sufficiently reliable as by the European Commission in its disclaimer on normalisation and weighting (please see PEF Screening Report, chapter V.3. Normalised results).

Acidification is not retained for communication purposes since this impact indicator is mainly linked to the impacts occurring in the consumer use phase and specifically energy, which is already covered by the climate change impact indicator which has been retained.

Also Resource depletion- mineral fossil is not retained for communication purposes since the impact category is mainly linked to the impacts occurring during the construction of the industrial sites and the road infrastructure, on which neither the detergent company neither the consumer have a significant direct influence, and on which there is no improvement potential for the companies (as far as the product is concerned) since the construction of their production site has occurred in the past.

However, according to the PEFCR Guidance document (page 31), all impact categories shall be included and evaluated in the supporting studies. Only in the final PEFCR, the number of impact categories to be addressed may be reduced.

22 The indicators selection is based on criteria such as normalisation results and correlation with other indicators but also consideration of methodological concerns (robustness, reliability of the impact category and feasibility of the calculation). Cf. Screening report and footnote 19 for more details. 23 See remark 20



V.6. Additional environmental information

V.6.1. Other initiatives by the HDLLD sector

The PEF Screening confirms the results of several LCAs on laundry detergents (see in annex ‘Review of the existing studies and Analysis of Consistencies and differences between existing PCRS and the PEF Guide’), identifying the use phase as one of the most critical life-cycle stages, with climate change as the most important environmental impact category. This is mainly due to the energy that is needed to heat the water of the washing machine. A.I.S.E. has focussed on the development and promotion of voluntary initiatives, with a view to steer best practices and drive sustainable progress the detergent industry. Its main scheme called the “A.I.S.E. Charter for Sustainable Cleaning”(24) was launched in all EU countries plus Switzerland, Norway and Iceland at the end of 2004, and was updated with a “product dimension” in 2010, via “Advanced Sustainability Profiles” (ASPs). In addition to the company manufacturing requirements included in the Charter, those ASPs are designed to determine a set of minimum yet ambitious sustainability criteria that a product must meet, thus driving good sustainability standards in a given products category. In order to fulfil the requirements of an ASP, a laundry product has to be able – beside others requirements such as optimal use of resources, environmental safety – to wash efficiently at ≤ 30° C and consumers have to be informed on this product attribute via a claim on the pack. This enables consumers to reduce the washing temperature when doing their laundry (the average washing temperature in Europe, is 41 °C25). Evidence has to be provided by manufacturers that the product has been performance tested and reaches a performance acceptable to consumers, consistent with the claim made. Building on this best practice, HDLLD manufacturers which apply this PEFCR should indicate the claimed wash temperature of the product, reaching a performance that is acceptable to consumers. Figure: Charter Product ‘ASP’ logo

In addition, A.I.S.E. developed common artwork material which has been used on packs of laundry and cleaning products in Europe since 1997 in order to engage consumers in the sustainable use of products. For laundry detergents, besides washing at low temperatures, further tips to reduce the environmental footprint when doing the laundry are included on “Cleanright panels”, such as the fill level of the washing machine, the adequate product dosing and saving of packaging: 24 http://www.sustainable-cleaning.com/en.companyarea_documentation.orb 25 A.I.S.E. consumer habit survey which was carried out in 2011



Figure: Cleanright Panel for laundry detergents

This on-pack communication complements the multilingual www.cleanright.eu website that provides consistent consumer communication across Europe. HDLLD manufacturers should apply those best use tips on the product or should refer to the www.cleanright.eu website. More recently, targeted campaigns such as, “I prefer 30° “ a multi-stakeholder campaign to promote the benefits of low temperature washing, can complement the list of activities done by the detergent industry to help lower the footprint (see www.iprefer30.eu). Activation of this campaign has been achievable through on pack activities, point of sales activities, advertising amplification, on line communication etc. HDLLD manufacturers may be asked to refer to this campaign as well.

V.6.2. Addressing Biodiversity

According to the Issue paper 'Addressing biodiversity in the Environmental Footprint pilots', final version 2.3, 20 May 2015, "each pilot shall make an assessment about the relevance to report biodiversity impacts caused by the sector and its supply chain on land based, fresh and marine water ecosystems". In the context of discussions on the issue paper, the Detergents PEF pilot pointed out that biodiversity is not adequately measured in LCA and the PEF. Existing methods and schemes that address the topic fit a broader approach based on life cycle thinking and management which go beyond the scope of the current PEF methodology. Key issues that require further consideration in the management of biodiversity across the life cycle include:

How to assess the impacts/benefits of certification in supply chains/secondary data (e.g. bio-based feedstocks or bio-based energy).

How to assess the equivalency of different certification schemes for the same crop.

How to assess the impact on biodiversity as opposed to the management of biodiversity.

It is not clear how existing certification schemes which in most cases deal with sustainability at large - incl. social aspects - can be integrated in the PEF method, which is by definition only covering environmental aspects. Hence, the members of the Detergent PEF Pilot TS concluded to not refer to or communicate on biodiversity aspects per se in the context of the PEF pilot.



V.7. Assumptions/limitations

This draft final PEFCR provides rules for the product category “Heavy Duty Liquid Laundry Detergents (HDLLD) for Machine Wash,” including 100% Liquid tablets (unit-dose).

Other products such as “Light Duty Liquid Laundry Detergents”, “Powder Laundry Detergents” and “Powder Tablets” are part of the same category; but they are not covered by the PEFCR, since the different product types vary in their functional units.

The A.I.S.E. plans to evaluate these other categories in due course in order to assess if and how to apply the HDLLD PEFCR also to these categories. Ultimately, it will benefit the PEF scheme to set parameters at the highest feasible level of product classification, without sacrificing accuracy, verifiability and meaningfulness. A.I.S.E. recognizes the importance of being in a position to accurately evaluate the best level at which to set the category rules for the entire laundry detergent segment.



VI. Resource use and emission profile

VI.1. Screening step

The PEF screening study was performed on the A.I.S.E. representative product (RP) with the objectives to pre-identify the most relevant life cycle stages and the most relevant processes in order to define the data quality needs under the system boundaries stated in this PEFCR. Following the European Commission and the PEF Guidance, the annex E “data requirements in PEFCRS’ has been tested on one supporting study. Taken into account company feedback on the supporting studies process and high efforts to collect the specific data, it has been decided to make the necessary amendments to be in line with its main requirements. Therefore this PEFCR requires that the detergent company shall collect all company-specific data that are accessible and that have significant influence on the final environmental result (specific data). As regards the data that have less impact on the final results (according to the screening study and confirmed by the supporting studies), this PEFCR let the company decide whether it is worth making the additional effort to collect them or it should be better to consider the default data. E.g. This is the case for the transport distance from the supplier site to the HDLLD manufacturing site (that can be easy or very difficult and time consuming to collect) as well as the water and energy consumption at the manufacturing site (where allocation rules may be too complicated to be applied in case of multi-products manufacturing site).

VI.1.1. Identification of the most relevant life cycle stages

Based on the screening study outcomes, more precisely the Table VI-1 – Relative Contribution of detergent to all impact categories of the screening report, the figure below shows the most relevant life cycle stages, which together contribute over 80% (before normalisation and weighting) to any baseline impact.



Figure VI-1 : Identification of the most relevant life cycle stages

5. HDLLD manufacture


7. Transport and distribution to consumer homes

8. Product use

9. Waste water treatment 10. Solid waste treatment (packaging)


2. Packaging raw materials sourcing and manufacturing

3. Transport to processing plant 4. Transport to processing plant

cumulatively contributingto 80% of any baselineimpact

VI.1.2. Identification of the most relevant processes

The Figure VI-1 presents the system with more details on the processes considered and the activity parameters.



Figure VI-2 : Life cycle stages modelling with processes and activity data



Distinction is made between activity data (or activity parameters) and Life Cycle inventory datasets (or LCI datasets). A Life Cycle Inventory (LCI) dataset is a document or file with life cycle information of a specified product or other reference (e.g., site, process), covering descriptive metadata and quantitative life cycle inventory26. A LCI could be a unit process dataset (UPR) or an aggregated dataset (also called system process (SP)). Activity data refer to information which is associated with input or output processes while modelling Life Cycle Inventories. In the PEF guidelines, it is also called “non-elementary flows”. Activity data27 is multiplied by an LCI to derive the environmental footprint associated with a process or an operation.

Considering the relative contribution of each process presented in the screening report, the Table VI-1 identifies the most relevant processes, which together represent >80% of any baseline impact.

26 European Commission – Joint Research Centre – Institute for Environment and Sustainability

2009 27 Based on GHG protocol scope 3 definition



Table VI-1: Identification of the most relevant processes

Life cycle step Dataset

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(3.0

)

Propylene glycol (solvent) 2% 3% 9% 0% 2% 2% 1% 2% 10% 1% 2% 1% 1% 1%

Soap (surfactant) 0% 1% 3% 0% 1% 0% 2% 1% 1% 1% 2% 2% 0% 4%

Sodium hydroxide (alkalinity sources) 0% 1% 3% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Fatty alcohol ethoxylate ( non-ionic surfactant)

3% 6% 2% 0% 2% 0% 2% 3% 1% 0% 7% 3% 3% -10%

Alcohol ether sulfate (anionic surfactant)

1% 2% 2% 0% 1% 1% 2% 1% 0% 0% 4% 2% 2% -7%

Glycerine (solvent) 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 1% 1% 0% 16%

Corrugated board base paper, Kraftliner0% 1% 1% 0% 1% 0% 1% 1% 1% 0% 1% 1% 0% 11%

polyethylene, HDPE, granulate, at plant 2% 0% 0% 0% 1% 0% 1% 3% 0% 0% 2% 1% 0% 0%

Diesel (transport to process plan) 0% 0% 0% 0% 1% 0% 0% 1% 2% 0% 1% 0% 0% 4%

Capital goods of transport by truck 0% 5% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

operation, transoceanic freight ship, OCE

1% 0% 1% 0% 9% 0% 7% 9% 2% 0% 6% 10% 0% 3%

5. HDLLD manufacture Chemical plant - infrastructures 1% 16% 9% 0% 1% 4% 1% 1% 1% 0% 2% 1% 1% 3%

Electricity, hard coal, at power plant 40% 2% 31% 0% 49% 26% 30% 39% 3% 9% 43% 41% 1% 17%

Electricity, natural gas, at power plant 21% 3% 2% 0% 6% 0% 8% 12% 44% 0% 3% 11% 0% 18%

Electricity, nuclear, at power plant 0% 19% 1% 0% 1% 0% 1% 1% 11% 2% 1% 1% 80% 1%

Electricity, oil, at power plant 3% 1% 1% 0% 7% 0% 3% 4% 5% 2% 6% 4% 0% 7%

Electricity, at wind power plant 0% 3% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 2%

tap water, at user, RER 3% 3% 8% 0% 3% 2% 2% 4% 3% 81% 3% 3% 3% 14%

Fragrances 0% 0% 0% 80% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

WWTP 12% 18% 15% 0% 5% 55% 24% 6% 4% 1% 6% 5% 2% 9%

Total (most relevant process) 90% 84% 91% 80% 89% 92% 87% 89% 88% 99% 90% 87% 94% 94%

2. Packaging raw material sourcing and manufacturing

3/4. Transport to processing plant

8. Product use

9. Waste Water Treatment



The Figure VI-3 highlights these most relevant processes as well as the activity data linked to these processes (data in red).

Figure VI-3 : Studied system with most relevant processes (contributing for more than 80% on the indicators) and linked activity data under the System

Boundaries



Based on the results highlighted above, the effort of data collection shall be focused on these most relevant processes and the related activity data.

In order to classify the activity data as well as the LCI datasets as specific, semi-specific or generic data, we consider the following rules:

Primary/site-specific data are data that shall be collected specifically by each company. Primary/site-specific data are significant regarding the most relevant impact categories and accessible for companies. Primary data are also data describing the reference flow (studied detergent and its packaging).

Semi-specific data are data for which default data values are proposed but companies should replace it by primary data if available. Semi-specific data can be significant regarding impact categories but are not easily accessible for companies. They can also have such little influence on all indicators that efforts for collecting them is of little interest. In this latter case, default values are based on a worst case scenario.

Secondary/generic data are data for which sources are defined together with default data and shall be used by companies.

Regarding the process LCI, the list of all process is displayed in annex XIII.9.3. Processes are classified as “relevant” processes or “less relevant” processes. For each process, a default LCI is proposed. Especially for “relevant” processes, if the company has access to LCI datasets that are more representative of the process used and with an equivalent or a better data quality assessment level (see chapter VI.2), the company shall use those.

VI.1.3. Identification of the hotspots

The Table VI-2 includes for each impact indicators the life cycle stage, the processes and the elementary flow cumulatively contributing at least 50% to the impact category before normalisation and weighting (from the most contributing in descending order).



Table VI-2: Identification of the hotspots

hotpost (option A)

Life cycle stage 8. Product use 67% 1. Chemical Ingredient sourcing and manufacturing 21% 1. Chemical Ingredient sourcing and manufacturing 23% 9. Wastewater treatment 100%

8. Product use 31% 8. Product use 45%

Process Electricity hardcoal, at power plant (8) 40% Chemical plant, infrastructure (5) 16% Chemical plant, infrastructure (5) 9% Fragances (9) 80%

Electricity natural gas, at power plant (8) 21% Electricity hardcoal, at power plant (8) 19% Electricity hardcoal, at power plant (8) 31%

Wastewater treatment plant (9) 18% Wastewater treatment plant (9) 15%

Elementary flow Carbon oxide, fossil 87% Nickel, 1,98 % in silicates, 1,04% in crude oil 28% Mercury

Uranium, in ground 20% Chromium VI

Tantalum, 81,9% in tantalite, 1,6E‐4 in crude oil, in ground 11%

hotpost (option A)

Life cycle stage 8. Product use 66% 9. Wastewater treatment 60% 8. Product use 44% 8. Product use 61%

9. Wastewater treatment 26%

Process Operation, transoceanic freight ship (3/4) 9% Wastewater treatment plant (9) 55% Electricity hardcoal, at power plant (8) 30%

Electricity hardcoal, at power

plant (8) 39%

Electricity hardcoal, at power plant (8) 49% Wastewater treatment plant (9) 24%

Electricity natural gas, at power

plant (8) 12%

Elementary flow Sulfur dioxide 60% Phosphate 98% Nitrogen oxides 50% Nitrogen oxides 74%

hotpost (option A)

Life cycle stage 8. Product use 65% 8. Product use 95% 8. Product use 57% 8. Product use 60%

Process Electricity natural gas, at power plant (8) 44% Tap water, at user (8) 81% Electricity hardcoal, at power plant (8) 43%

Electricity hardcoal, at power

plant (8) 41%

Electricity nuclear, at power plant (8) 11% Fatty alcohol ethoxylate (non ionic surfactant) (1) 7%

Electricity natural gas, at power

plant (8) 11%

Elementary flow

Methane, bromochlorodifluoro‐, halon

1211 48% Sulfur dioxide 53% Nitrogen oxides 92%

Methane, bromotrifluoro‐, halon 1301 19%

hotpost (option A)

Life cycle stage 8. Product use 84% 8. Product use 58%

Process Electricity nuclear, at power plant (8) 80% Glycerine (solvent) (1) 16%

Electricity hardcoal, at power plant (8) 17%

Electricity natural gas, at power plant (8) 18%

Elementary flow Carbon‐14 90% Transformation, to and from permanent crop

Transformation, to and from arable, non‐irrigated and

irrigated

Transformation, to mineral extraction site

Transformation, from unknown

Transformation, from pasture and meadow

Stratospheric ozone depletion Water scarcity Particulate matter/Respiratory inorganics Terrestrial eutrophication

Ionising radiation Land use

IPCC 2007 with C biogenic, GWP 100a CML 2002 van Oers, Abiotic resource depletion ‐ Reserve base USEtox w/o LT human toxicity USEtox w/o LT ecotoxicity

Accumulated Exceedance, Acidification Freshwater eutrophication Marine eutrophication photochemical oxidation formation



Regarding the capital goods (infrastructures), only chemical plant and capital goods for road transport are among the most relevant processes. Based on the fact that such processes have a limited or negligible contribution to the environmental indicators, it has been decided to exclude capital goods.



VI.2. Data quality requirements

According to the PEF guide, data quality requirements shall be met by PEF studies intended for external communication.

For other PEF studies the specified data quality requirements should be met but are not mandatory.

A semi-quantitative assessment shall be performed with the following steps:

1. Rank the datasets for each EF impact category according to the impact contribution;

2. Identify the datasets contributing to at least 70% of the contributions to each EF impact category;

3. Assess the data quality of the datasets identified via semi-quantitative judgment based on six criteria:

Five relating to the data: i. Technological representativeness (TeR) ii. Geographical representativeness (GR) iii. Time-related representativeness (TiR) iv. Completeness (C) v. Parameter uncertainty (P)

One relating to the methodology i. Methodological Appropriateness and Consistency (M);

Five quality levels are defined for each criteria:

very good (1); good (2); fair (3); poor (4); very poor (5).

The overall data quality of a dataset is the average of the scores obtained for all six data quality criteria:

The overall data quality rating shall correspond to a data quality level defined as follows:

Overall data quality rating (DQR) Overall data quality level

≤ 1.6 Excellent quality

>1.6 to≤ 2.0 Very good quality

>2.0 to ≤ 3.0 Good quality

>3 to ≤ 4.0 Fair quality

>4 Poor quality



Three criteria are defined based on the context of the product studied:

Technological representativeness The degree to which the dataset reflects the true population of interest regarding technology;

Geographical representativeness The degree to which the dataset reflects the true population of interest regarding geography;

Time-related representativeness The degree to which the dataset reflects the specific conditions of the system being considered regarding the time/age of the data.

The three other criteria have predefined requirements:

Completeness Completeness has to be judged with respect to the coverage for each EF impact category and in comparison to a hypothetical ideal data quality. The criterion has to be assessed for the whole EF impact category at one time.

The five quality levels are displayed in Table VI-3.

Parameter uncertainty Parameter uncertainty has to be judged based on qualitative expert judgment or relative standard deviation (as a % if a Monte Carlo simulation is used). Parameter uncertainty is only related to the LCI (datasets), not the EF impact assessment.


Methodological Appropriateness and Consistency This parameter assesses whether the applied LCI methods and methodological choices are consistent with:

- the goal and scope of the dataset, especially its intended application to support decisions;

- the PEF methodology.


The Table VI-3 presents the criteria used to perform the DQA.

Table VI-3: Criteria that shall be used to perform the DQA

Criterion Quality

level Quality rating

Definition

Technological representativeness

1 Very good Specific technology

2 Good Average technology for the specific product as EU-specific consumption mix

3 Fair Average technology for the specific product as EU-specific production mix

4 Poor Average technology for a group of similar product as EU-specific consumption mix

5 Very poor Other process or unknown

Geographical representativeness - if scope country specific

1 Very good Country specific

2 Good Continent specific data

3 Fair One or several country(ies) in the specific continent



Criterion Quality

level Quality rating

Definition

4 Poor Another continent

5 Very poor Global or unknown

Geographical representativeness - if scope is larger than a country specific

1 Very good Geographical scope specific

2 Good Some countries in the geographical scope

3 Fair One country in the geographical scope

4 Poor Geographical scope with the same technological level

5 Very poor Geographical scope with lower/higher technological level or unknown

Time-related representativeness

1 Very good ≤ 5 year old data

2 Good 5-10 years old data

3 Fair 11-15 years old data

4 Poor 16-30 years old data

5 Very poor ≥ 30 years old data

Completeness

1 Very good ≥ 90% of a full LCI

2 Good 80%-90% of a full LCI

3 Fair 70-80% of a full LCI

4 Poor 50-70% of a full LCI

5 Very poor <50% of a full LCI

Parameter uncertainty

1 Very good Very low uncertainty (≤ 10%)

2 Good Low uncertainty (10% to 20%)

3 Fair Fair uncertainty (20% to 30%)

4 Poor High uncertainty (30% to 50%)

5 Very poor Very high uncertainty (> 50%)

Methodological appropriateness and consistency

1 Very good Full compliance with all requirements of the PEF guide

2 Good

Attributional process-based approach AND the following three method requirements of the PEF guide are met: Dealing with multi-functionality End-of-life modelling System boundary

3 Fair

Attributional process-based approach AND two of the following three method requirements of the PEF guide are met: Dealing with multi-functionality End-of-life modelling System boundary

4 Poor

Attributional process-based approach AND one of the following three method requirements of the PEF guide are met: Dealing with multi-functionality End –f-life modelling System boundary

5 Very poor

Attributional process-based approach BUT none of the following three method requirements of the PEF guide is met: Dealing with multi-functionality End-of-life modelling System boundary



According to the PEF guide, the requirements for technological, geographical and time-related representativeness shall be subject to review as part of the PEF study. Table XIII-14: Completeness, Precision/uncertainty, Methodological appropriateness and consistency score for each default dataset. Table XIII-14 and Table XIII-15 in the Appendix gather the information necessary to recalculate the DQR values for the secondary datasets.

VI.3. Requirements regarding foreground specific data collection

This section describes in detail the requirements regarding the collection of specific data (activity parameters and process LCI).

Primary/site-specific data shall be collected specifically by the companies.

Most of specific activity parameters are related to the description of the product (formulation and packaging). Other specific parameters are data related to the HDLLD manufacturing stage, the use stage and are known by the companies. Some parameters concerning the wastewater treatment shall be calculated for each chemical of the studied detergent following an evaluation method defined in this PEFCR.

Table VI-4: Specific data (activity data)

Unit process Activity Data Unit

Product description

Bill of material in 100% active content:

for each ingredient:

- Name,

- CAS number,

- Ingredients family,

- Volume in 100% active content.

Qualitative information

litre

Reacted formulation:

For each chemical : name, CAS number, chemical formula, volume


litre

Weight of product by sales product unit

g

Detergent density g/ml

Dosage/wash ml

Packaging description

Primary packaging

Type of raw packaging (raw materials)

Mass


g

HDLLD manufacturing process Geographical location On country scale

Use Consumer geographical location On country scale

Recommended dosage ml



Wastewater treatment Characterisation factors of ecotoxicity for each available ingredient28

Characterisation factor shall be calculated according to the generic method defined in this PEFCR – see section VI.8.1.1

Removal rates in wastewater treatment plant for each available ingredient

Removal rate shall be calculated according to the generic method defined in this PEFCR – see section VI.8.1.1

Share of households connected to a wastewater treatment system (average weighted by sales per country)

See Eurostat data in annex XIII.5. for share of household connected per country

This table is reminded in annex XIII.8.

The bill of materials/ingredients in 100% active content shall refer to the list/amount of purchased raw materials in 100% active content used to produce the HDLLD detergent. It shall be collected as follows:

- Using the BoM template displayed in Table V-1: Bill of materials template detailing all individual ingredients.

- Technological and geographical representativeness; all available information on technology used to produce any specific ingredient as well as its location of sourcing and manufacturing (country scale) should be gathered. Such information will help to find the higher quality score LCI for the ingredient manufacturing process.

In order to ensure confidentiality of the formulation, only the percentage of each ingredient family in 100% active content should be displayed within the PEF report.

The ‘reacted formulation’ differs slightly from the bill of ingredients and shall be used for the evaluation of the impact of the end of life process.

As for the packaging, the primary packaging refers to the packaging that contains the finished HDLLD. It shall be the packaging that is used to contain, preserve and protect the HDLLD and inform the consumer.

The data shall be collected as follow:

- Each major component shall be listed with the material description and the quantity for one dose (cf. template inTable VI-5). When several primary packaging formats are used, a PEF assessment shall be performed for each specific product/packaging. However if it can be proven, through sensitivity analysis, that this characteristic has marginal influence on the final result and that even using the worst case feature (in this case packaging) the results in terms of benchmarking and class of performance would remain the same, an average primary packaging may be considered based on the different set of primary packaging (material and weight per reference flow i.e. a HDLLD dose) and their market share in volume.

28 An EUCOM expert workshop, organized on 15 January 2015 on the topic of ecotoxicity evaluation, concluded that USEtox must still be used for the screening and supportive studies, but may not be used for benchmarking and communication purposes, until the outcome is more robust (Executive summary of ‘Current and future implementability of USEtox’ PEF meeting, 15 January 2015 (version 23 January 2015)). This conclusion is in line with the findings of the A.I.S.E. PEF TS (Ref. A.I.S.E. PEF Screening Report).



- Technological and geographical representativeness; information on technology used to produce any specific material as well as its location of sourcing and manufacturing (country scale) shall be gathered. Such information will help to find the higher quality score LCI for the material manufacturing process.

The following template should be used:

Table VI-5: template for primary packaging data collection Packaging components

Bill of Materials Quantity Unit

Bottle or box HDPE, etc. g/dose Cap (incl. dosing device + spout)

PP, etc. g/dose

Paper Labels Paper g/dose Doy-pack PP, etc. g/dose Recycled plastic content29

%

Net detergent mass per bottle or unit-dose

g

Note: the glue for labels may be neglected.

The other activity data that shall be collected specifically by companies concerns the country location that influence the modelling of relevant processes since this influences the energy mix for electricity consumption as well as the share of households connected to a WWT plant. In case of sales in several countries, the relative volume contribution for each country shall be provided and the appropriate percentage weighted average by product sales calculated for energy mixes and share of household connected to WWT plants per country.

Finally, parameters related to the wastewater treatment have a large influence on the environmental impacts. Therefore the characterization factor for ecotoxicity and removal rate shall be calculated for each chemical of the reacted formulation following methods described in section VI.8.1.1.

With regard to process LCI, the annex IXIII.9.3 provides all process LCI for modelling each step of the life cycle. Most relevant processes are highlighted in this annex as well as in Figure V-1. For many processes the modelling approach is described in the following sections (e.g. electricity mix, heat mix, wastewater treatment, etc.) and for all processes a default LCI is proposed.

The company may have access to more representative data30 depending of its level of influence on the ingredient sourcing and manufacturing, the transport of ingredients and packaging or the manufacturing process or the transport and distribution of the finished

29 To be provided for each plastic material. In case of recycled content in the primary packaging, the RUaEP shall use the Dealing with multi-functionality in Recycling situations formula of the PEF Guide (Annex 5) in order to allocate the impacts and benefits due to recycling equally between the producer using recycled material and the producer producing a recycled product. The modelling for plastic recycling process is detailed in section VI.8.2. 30 Representativeness is assessed according to the criteria as defined in the Data Quality assessment regarding technological, geographical and time-related representativeness (see chapter VI.2)



product (see Figure V-2: Organizational Boundaries). If the company has access to more representative process LCI, especially regarding most relevant processes, i.e.:

- Ingredient sourcing and manufacturing for anionic and non-ionic surfactants, solvents and alkalinity sources.

- Packaging raw material sourcing and manufacturing for cardboard and plastics used for first and second packaging,

these LCI should be used.

VI.4. Requirements regarding background generic data and data gaps

Activity parameters that have less influence on the results and/or are less accessible to the companies are classified as semi-specific data.

Semi-specific data should be replaced by specific data when available. Default data are based on applying scaling factors (+50%) on the values identified on the A.I.S.E. HDLLD reference product.

The Table VI-6 lists the semi-generic data:

Table VI-6: Semi-specific data (activity data)

Type or unit process

Activity Data Default data31

Primary packaging description

Refillable packaging32 No

Number of refill 0

Secondary packaging description

Type of secondary packaging Cardboard box

Weight of secondary packaging

& Number of sales product units per secondary packaging

900 g / cardboard box and 4 unit/box

(225 g/sales product unit)

Tertiary packaging description

Type of packaging type 1 (pallet) Wood pallet

Weight of pallet

& Number of sales product unit per pallet

28 kg / wood pallet and 120 unit/pallet

(0.24 kg/sales product unit)

Number of uses of the pallet 40

Type of packaging type 2 (intercalary) Cardboard intercalary

Weight of packaging

& number of packaging 2 per pallet

400 g / cardboard intercalary & 4 intercalary/pallet

(13.33 g/sales product unit)

Type of packaging type 3 LDPE plastic film

Weight of packaging 350 g LDPE plastic film/pallet

31 These data are based on data used for the screening study; in addition, an average increase factor as validated by the TS members was applied. 32 In case of refillable packaging, the company shall describe the whole refilling system in details and take into account the share of the whole system allocated to the quantity of detergent under study for the primary packaging material and quantity. Guidance are provided in annex XIII.9.2.





Raw material transportation

Transport distance and mode of transport 2250 km by truck (articulated truck with payload 24t);

12000 km by boat (container ship).

HDLLD manufacture

Energy consumption (electricity, heat from grid, others)33

Electricity 0.25 kWh / kg of detergent (leaving the factory)

No heat

Water use

(excluding water in the detergent product leaving the factory)

0.9 litres34 / kg of detergent (leaving the factory)

Distribution Transport distance and mode of transport 900 km by truck (articulated truck with payload 24t)

Direct water and air emissions and losses of packaging during the HDLLD manufacturing process shall be excluded.

Secondary/generic data are data for which sources are defined together with default data and shall be used by companies.

Table VI-7: Generic data

Type Activity data Default data

Retail storage35 Electricity consumption36 0,217 MJ/sale unit product

Transport to consumer home37

Allocation of transport to the HDLLD 5% by sale unit product

Transport scenario between sale place and consumer home38

80% by car

15% by public transport

5% by delivery van

Transport distance between sale place and consumer home39

Car : 4.8 km40

33 In case of use of several energy sources, the company shall ensure that the complete energy consumption is accounted for. Also, if deionisation of water takes place on the HDLLD site, the related energy consumption shall be deducted from the total amount of energy consumption onsite since the default dataset already considers the deionising of water. 34 These data do not take into account incorporation of water in the product. 35 The retail storage has to be modelled by using the default data as provided by the OEF retail. While waiting for the final version of the OEFSR retail pilot, the retail storage shall be modelled, based on the electricity consumption. 36 Source: The Sustainability Consortium, Laundry detergent PCLC, 2011. 37 The company may deviate from this generic distribution scenario only if the detergent is sold via a different distribution mode (e.g. e-commerce). In such cases the delivery scenario shall be described in detail and the activity data shall be justified. 38 This scenario, provided by the OEFSR retail TS, could change in the final PEFCR depending on the progress made by the OEFSR retail TS on the subject.



Public transport : 1 km

Van : 4.8 km

Packaging end-of-life

Packaging end-of-life scenario end-of-life scenario defined in section VI.8.2

Transport (waste collection) end-of-life scenario defined in section VI.8.2

The following sub-section describes the modelling approach of the electricity mix and the heat mix supply for each European country.

VI.4.1. Electricity mix and Heat mix – country specific process

VI.4.1.1. Electricity

At the date of finalising this final draft PEFCR, an issue paper on electricity is still under review. This paper will be applied as soon as its final version is published. In the meantime, the following approach shall be applied in addition to the requirements already stated in the chapter 5.4.8 of PEF Guide.

The electricity mix shall be based on the most updated data provided by the Internal Energy Agency (IEA) as follows.

For each country, IEA provides41 data on the quantity of electricity that is produced, exported and imported. Based on these three types of information, it is possible to determine the electricity consumption mix. Electricity consumed is determined based on the following formula:

elec produced + elec imported - elec exported.

The consumption mix is obtained from the combination of two production mixes: For the share that is imported (% imports), the mix to be assigned is

approximated by the continental production mix, assuming importations from the corresponding continental market, in average.

For the part of electricity that is consumed locally, i.e. that is not imported (1 - % imports), the mix is taken equal to the production mix of the considered country. The calculation is hence made according to the following formula:

39 The transport distance, provided by the OEFSR retail TS, could change in the final PEFCR depending on the progress made by the OEFSR retail TS on the subject. 40 Note that these values are already considering that several actions can be made when "driving around Saturday afternoon," such as passing by the hairdresser, picking up the kids at the soccer training, etc., and, therefore, the 4.8 km distance is the portion of the trip that is allocated to the task of shopping. 41 Data available on http://www.iea.org/statistics/statisticssearch/



Consumption mix = % imports * [continental mix] + (1 - % imports) * [country-specific production mix]

The attributional approach shall be used to model the electricity mixes. In this approach, the allocation between the consumers is uniform. In other words, in order to answer the demand of a consumer, all power and heat plants in the country contribute proportionally to their share in the national electricity generation on a yearly basis.

Electricity supply occurs at different voltage levels (110 V, 220 V...). Figures on total losses come from IEA data sources (2009 data) and figures on the electricity losses for each of the voltage levels are based on ecoinvent modelling42 (7% of the total losses occur on high voltage, 13% on medium voltage and 80% in low voltage levels).

Default LCI considered for electricity production from the different energy sources are indicated in annex XIII.9.3.

VI.4.1.2. Heat

The country heat mixes shall be considered based on most updated IEA data sources43.

The attributional approach shall be used to model the heat mixes. In this approach, the allocation between users is uniform. In other words, in order to answer the demand of a user, it is assumed that all power and heat plants in a country contribute proportionally to their share in the national electricity generation on a yearly basis.

Default LCI considered for heat production from the different energy sources are indicated in annex XIII.9.3.

VI.5. Data gaps

No data gaps have been identified.

VI.6. Use stage

The use stage begins when the consumer takes possession of the product and ends when the used product and its packaging are discarded for transport to recycling or to a waste treatment facility.

Therefore the use stage shall include:

- The transport and distribution to consumer home - The consumption pattern (dosage and consumer habits) - The resource use (electricity and water consumption)

42 Life Cycle Inventories of Energy Systems: Results for Current Systems in Switzerland and other UCTE Countries, ecoinvent report No. 5, December 2007. 43 Data available on http://www.iea.org/statistics/statisticssearch/



Transport and distribution to the consumer’s home The transport to the consumer’s home is highly variable and hence a generic scenario has been applied based on information provided by the OEFSR retail TS 44 :

80% by car: 4.8 km round trip per shopping trip; 15% by foot, bike and/or bus (all modelled, using public transport): 1 km per

shopping trip (round trip); 5% of the remaining consumers get their products delivered at home by van, with

4.8 km allocated per delivery (round trip; per household).

These values consider that several errands can be made when "driving around Saturday afternoon" such as passing by the hairdresser, picking up the children at the soccer training, etc., and, therefore, the 4.8 km distance is the portion of the trip that is allocated to the action of shopping.

An allocation is required at this step: the OEFSR retail TS considers an average basket of 20 items per shopping trip. Therefore, the allocation of consumer transportation shall be set at 5% for a HDLLD.

Product use The use scenario shall be based on the A.I.S.E. laundry energy model 2014 provided and the average washing habits.

The standard use scenario shall be based on the following data:

- Specific dosage recommended to the consumer (in ml) - Specific location of the consumer (country scale) - Wash temperature: the temperature shall be determined by the company in

accordance with the unit of analysis. - Water consumption: 50 Litre/wash

Wash electricity consumption based on the A.I.S.E. laundry Energy model 2014 presented below.

In addition, if the wash temperature is different from 40 °C, a scenario considering the European average washing temperature (40 °C) shall be evaluated.

A.I.S.E. Laundry energy model 2014 The A.I.S.E. Laundry Energy model 2014 is a generic model connecting wash temperature (in range of ~15-90 degrees C) with the total energy used in an automatic laundry wash ‘standard’ cycle:

Electricity consumption (kWh) = b[0] +b[1] & washing temperature (°C) where b[0] = -0,1342 b[1] = 0,0193 The A.I.S.E. laundry energy model 2014 was developed in the context of the A.I.S.E. Pilot Project and is detailed in annex XIII.11.3XIII.11.2.

44 Status: 22 September 2014



Based on variations in consumer habits and in washing machine technology, the following parameters at the use stage may vary and may entail a significant change on total results.

Product dosing Wash temperature Water used by the machine

Therefore any other scenario studied by the company shall be clearly distinguished from the standard scenario(s).

There is no minimum loss rate expected for detergent (neither loss in the dosing nor loss in the bottle) and therefore no loss rate is considered.

VI.7. Logistics

Semi-specific parameters (transport distance and mode of transport) are proposed to define scenario by default (see section VI.4).

As for the LCI, the process LCI for transport by truck and transoceanic freight are proposed in annex XIII.9.3.

Impact allocation A fraction of the impacts from transportation activities shall be allocated to the unit of analysis (to the considered product) based on the load-limiting factor. According to the PEF guide, for goods transport, the following modelling principles should be considered: time or distance AND mass or volume (or in specific cases: pieces/pallets) of the transported good.

- If the maximum authorised weight is reached before the vehicle has reached its maximum volume capacity: at 100 % of its volume (high density products), then allocation shall be based on the mass of transported products.

- If the vehicle is loaded at 100 % of the volume but it does not reach the authorised maximum weight (low density products), then allocation shall be based on the volume of the transported products.

For this product category, except for cases when it is clearly known that the product is volume limited, an allocation based on mass shall be made, for raw material transportation and distribution of the final product.

VI.8. End-of-life stage

The scenarios to be adopted for the end of life stage shall be representative of the current practices at European level as well as any European country level. Also, such scenarios must be comparable from one pilot to another one. Therefore it is expected that at some point of the PEF pilot process, the EoL scenarios will be defined at global level.

In the meantime, any study on HDLLD products should use the scenario as considered in the A.I.S.E. PEF screening study. Such scenario as well as the modelling is reminded below.



The study shall consider the end of life of the studied HDLLD (wastewater treatment) as well as the end-of-life of its packaging (end-of-life of packaging).

VI.8.1. Wastewater treatment

The PEFCR considers that 100% of the product is used. Therefore, the used product is discharged to the sewerage system, which is connected to a municipal wastewater treatment plant (WWTP).

Both the sewage and the wastewater treatment need to be modelled in detail, considering that not all the population is connected to a WWTP.

The following paragraph presents the modelling approach used in the PEF screening study, which is based on the ecoinvent “wastewater treatment module”45.

The ecoinvent modelling is based on a typical scheme for a WWTP in Switzerland. Three stages are considered for the WWTP:

Primary treatment (mechanical): Solids present in wastewater accumulate by gravity at the bottom of a tank after a few hours of ‘treatment’ and these solids are removed as “primary sludge”;

Secondary treatment (biological): Micro-organisms degrade pollutants in an aerated tank. The degradation processes are essentially the same as processes occurring in natural waters, but with higher degradation rates and without exposing the natural ecosphere to the untreated pollutants;

Tertiary treatment (physico-chemical): Precipitation agents such as iron chloride are added at this stage to precipitate pollutants in order to clarify the water (phosphates are targeted at this step).

The sludge collected across the three stages of wastewater treatment are further degraded by anaerobic digestion in a closed digestion tank over several days. Biogas rich in methane (CH4) can be recovered from this process and burned to produce energy.

The remaining sludge (digested sludge) is de-watered and sent to a municipal waste incineration plant.

Note: In Europe, according to the local situation, primary treatment and/or tertiary treatment are facultative. However the technology (for the three stages) described by ecoinvent in its module is the predominant one used in Europe. Additional sludge treatment may also be implemented, such as like thickening, dewatering, drying, and lime/alkaline stabilization.

45 “Calculation Tool for Municipal Waste water Treatment Plant WWTP” for ecoinvent v2.1 (2008)



Figure VI-4: Typical scheme of wastewater treatment plant

The main methodological choices of the ecoinvent modelling are: The sewage is defined by a chemical composition. To distribute the chemical

elements between the outputs of the WWTP (after primary, secondary, tertiary treatment), transfer coefficients (to water, to air and to sludge) are used. Then a second set of transfer coefficients is used for the anaerobic digestion stage;

Figure VI-5: ecoinvent modelling principles of WWTP

An average electricity consumption per m³ of wastewater treated is defined (0.28 kWh/m³ sewage);



Two types of capital goods (also named infrastructures) are considered: the wastewater treatment plant (wastewater treatment plant, class 3, CH) 46 and the sewer grid (sewer grid, class 3, CH47);

The transfer coefficients are the default values from ecoinvent. They include treatment in WWTP with activated sludge treatment.

Sludge: 100% sent to incineration (hypothesis).

Adaptation made for the HDLLD: Adaptation made for the HDLLD is the following:

The chemical composition of the average ‘reacted’ formulation: the composition is estimated by the chemical formula of each ingredient (based on molecular formula) and its share in the average ‘reacted’ formulation;

o The chemical elements considered are C, O, H, N P, Ca, Na; o The effluent concentration is determined with the amount of water needed

for the product use: water use of the washing machine for one cycle – 50 litres.

The elementary composition is added in the ecoinvent Excel tool named Calculation Tool for Municipal Wastewater Treatment Plant WWTP for ecoinvent v2.1 (2008)

The output LCI from this tool is used in the modelling The capital goods shall be excluded.

The evaluation of the ecotoxicity for aquatic freshwater shall be conducted with the ‘reacted formulation’. Both a removal rate and a characterisation factor shall be used for each ingredient (adapted for primary and secondary treatments). The Figure V-1shows the modelling principle and the section VI.8.1.1 describes the calculation method for the characterisation factors that shall be used, as well as the list of available removal rates and characterisation factors (calculated for the A.I.S.E. reference product).

Figure VI-6: modelling principles adapted for HDLLD released into a WWTP

*CF : Characterisation factor

46 Five capacity classes of WWTP are available in ecoinvent database V2.2. Class 3 corresponds to 24 900 per-capita equivalent, an average annual sewage volume of 5.0 million m3/yr and a lifetime of 30 years. Note that treatment in a class 5 demands more infrastructures per m³ of waste water than a class 1. 47 A Class 3 sewer grid corresponds to 24 900 per-capita equivalent, an average length of 109.4 km and a lifetime of 100 years including a renovation after 70 years.



Note: in Europe, 91.6%48 of households are connected to a wastewater treatment system: individual or collective. The same modelling for both systems is considered.

VI.8.1.1. Removal rates and Characterisation factors

Guidance to obtain WWTP removal numbers

The numbers (in % removal) shall be obtained by means of one of the following methods, in decreasing order of preference:

1. Obtain removal numbers from publications in the scientific literature based on monitoring data in real WWTPs. For a large number of detergent ingredients measured removal numbers can be found in the ingredient dossiers on www.heraproject.com. The monitoring data selected should be sufficiently robust and be broadly representative for the geographic region of interest and its wastewater technology.

2. Use the removal numbers for detergent ingredients represented in the EU DID list. These values can be seen as averages.

3. Use removal numbers from an OECD 303A laboratory test or similar. 4. Model the % removal with the SimpleTreat model based on the following input

parameters: logP (or Kd value), and degradation rate estimated based on the results of a ready biodegradability tests (OECD 301). See also REACH TDG Chapter R.16 for further guidance.

Guidance to the calculation of the characterisation factors This guidance shall be applied for any ingredient entering the BOM of the studied detergent.

The characterisation factors shall be calculated using the following tool and principles for data selection and data sources.

Tool: The USEtox XL calculation tool (version 1.01) available from the USEtox website (www.usetox.org) shall be used.

Data sources

In the context of the EU REACH regulation, industry has submitted in many cases consensus data which are made publically available via the ECHA dissemination website (echa.europa.eu). These data shall be used as preferred input data for all endpoints, in particular for physico-chemical endpoints. However, all input data for USEtox may not be available from the ECHA database. For example, degradation half-lives and/or HC50 will rarely be found in the ECHA database and these need to be derived from other sources;

If no ECHA data are available, HERA (www.heraproject.org) data (preferred) or company-specific data shall be used;

48 Source: Eurostat (2009-2010), average performance of 18 member countries of the European Union + EFTA (http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_ww_con&lang=en)



Measured data take precedence over QSAR estimations. Use of QSAR is a last option if other data are unavailable. When data are unavailable from the above sources, the USEtox or Cosmede database49 can be consulted.

Data selection principles

Only data with Klimisch scores K1 and K2 shall be used. A single value from a Key Study from the ECHA database is selected, unless there are specific arguments not to do so. Averaging of endpoint results across studies shall be avoided (with exception for the HC50 derivation);

Degradation half-lives are based on (measured) primary degradation rates because primary degradation correlates best with loss of toxicity. If not available, mineralization rates shall be used as a conservative estimate (NB: the USEtox guidance is not really specific on this point);

Photodegradation, if applicable to the chemical, shall be considered as a primary degradation mechanism for the aquatic compartment (NB: which is not the case in the standard USEtox approach);

HC50 are preferably derived from a chronic Species Sensitivity Distribution (SSD). If not available, it is based on acute EC50/2, according to the approach described in the USEtox guidance;

For surfactants, the effect of composition/chain length shall be carefully considered, in particular for deriving the physico-chemical and ecotoxicological datasets. In the case of a mixture of different chain length compounds, an average value shall be used as described in the publication by Vanhoof et al. (2011).

Evaluation for consistency50

Once the input data for the chemicals in the reference formulation are collected, a consistency and plausibility check shall be done across the chemicals in order to spot anomalies that may be due to differences in amount, type and/or quality of endpoint data available;

Corrections should be applied based on knowledge of the respective chemical categories and/or expert judgment (always requiring adequate documentation).

The Table VI-8 presents the removal rate and the characterisation factor for each component of the average formulation of the A.I.S.E. representative product (RP).

49 http://usetox.tools4env.com/ 50 Van Hoof, G., Schowanek, D., Franceschini, H. and Munoz, I. (2011). Ecotoxicity impact assessment of laundry products: a comparison of USEtox and critical dilution volume approaches. Int. J. LCA. 16, 808 -818.



Table VI-8: Removal rate and the characterisation factor for each component of the average formulation (A.I.S.E. HDLLD reference product)

Name CAS number

Removal rate in WWTP

Source of

removal rate

CF A.I.S.E51

(%) (CTUe)

Builders / Salts of citric acid and other salts 68-04-2 93% [1] 1.8E+00

Sequestrants / HEDP, /tetra Na salt (Phosphonates)

3794-83-0 60% [1] 1.7E+02

Dye / pigment yellow 1 2512-29-0 60% [1] 1.1E+04

Enzyme / amylase 9000-92-4 87% [1] 1.3E+02

Fragrances / dihydromyrcenol 18479-58-8 / 2436-90-0

99.9% [5] 1.0E+05

Fragrances / phenetyl alcohol 60-12-8 90% [3] 1.3E+05

Fragrances / 4-tert-butylcyclohexyl acetate 32210-23-4 90% [3] 1.2E+05

Fragrances / hexylcinnamic aldehyde 101-86-0 99.8% [2] 3.4E+05

Fragrances / hexyl salicilate 6259-76-3 99.8% [2] 2.0E+06

Fragrances / beta-pinene 127-91-3 90% [3] 7.7E+05

Fragrances / Iso E Super 54464-57-2 92% [2] 2.1E+05

Fragrances / Methyl Ionone Isomers 1335-46-2 97% [2] 3.0E+05

Fragrances / Dipropyleneglycol 25265-71-8 87% [2] 4.9E+00

Optical brighteners / biphenyl disulfonate (FWA5)

27344-41-8 60%

[1] 9.9E-01

Optical brighteners / Sodium Polyaryl Sulfonate

16090-02-1 [1] 8.9E+03

Surfactant / sodium alkyl ether sulfates (SLES)

68891-38-3 98% [1] 1.4E+01

Surfactant / alkylbenzene sulfonate (LAS) 68411-30-3 95% [1] 3.1E+02

Surfactant / C12 Fatty Acid Na salt (soap) 629-25-4 95% [1] 2.7E+01

Surfactant / Alcohols, C12-15, ethoxylated, C12-15EO11, C12-15EO7, C12-15EO7, C12-15EO7, C9-11EO5

68131-39-5 95% [1] 1.9E+02

Alkalinity sources / Triethanolamine 102-71-6 96% [4] 1.1E+01

Solvents / Glycerol 56-81-5 87% [4]

1.4E+00

Solvents / Propylen glycol 57-55-6 5.0E-01

Preservatives / 1.2-Benzisothiazol-3-one

2634-33-5 50% [4] 6.2E+03

Polymers 9010-92-8 60% [4] 2.8E+02

Sources for removal rates: [1]: Comparative Life Cycle Assessment (LCA) of Ariel “Actif à froid” (2006), a laundry detergent that allows to wash at colder wash temperatures, with previous Ariel laundry detergents (1998, 2001), Procter&Gamble, April 2006.

[2]: Simonich, S.L., Federle, T.W., Eckhoff, W.S., Rottiers, A., Webb, S.,Sabaliunas, D., de Wolf, W., 2002. Removal of fragrance material during US and European wastewater treatment.

[3]: interim value (expert judgment based on ready biodegradation results and logP)

[4]: ESC tool

51 Used in the average formulation



[5]: Klaschka, U.,& Carsten, P., von der Ohe, Bschorer, A., Krezmer, S., Sengl, M., Letzel, M., 2012. Occurrences and potential risks of 16 fragrances in five German sewage treatment plants and their receiving waters

Alternative method: the Environmental Safety Check (ESC) According to the conclusions as drawn during the expert workshop on 15 January 2015 (that USEtox must still be used for the screening and supporting studies, but may not be used for benchmarking and communication purposes, until the outcome is more robust, footnote 18), the A.I.S.E. PEF TS agreed to apply an alternative method with regard to ecotoxicity to aquatic freshwater organisms, i.e. risk-based ‘Environmental Safety Check (ESC)’ method used in the A.I.S.E. Charter for Sustainable Cleaning. The ESC-check is implemented through a user-friendly spreadsheet tool which uses an internal database of key ingredient parameters including predicted no-effect concentration (PNEC) and removal rate. The ESC tool includes market volume information for product types and ingredients in order to run a risk-based calculation. Conservative projections include the assumption of a 100% market share for the studied product and a factor-based approach to provide a conservative estimate of background ingredient concentrations which might arise from other uses, both within the detergent sector as well as in other industries. The ESC tool performs calculations based on the core concept of risk assessment: it conservatively projects Predicted Environmental Concentrations (=PEC) for the environment and compares these to relevant Predicted No Effect Concentrations (=PNEC). The result is expressed as a Projected Environmental Safety Ratio (PEC/PNEC = PESR). In order to pass the ESC check, the Projected Environmental Safety Ratio (PESR) for each ingredient as formulated and dosed must be less than 1. This corresponds to the PEC/PNEC < 1 criterion which is the basis for concluding no significant risk of adverse effects in the REACH legislation. The tool itself and a user manual are publically available via:

http://www.sustainable-cleaning.com/en.companyarea_documentation.orb.

For further details and guidance, please see the annex.

VI.8.2. End of life scenario for packaging

The end-of-life of the packaging materials shall include the following processes:

Collection transport; End-of-life treatment (recycling, incineration or landfilling) according to the

average European municipal solid waste treatment.

The transport distances for selective collection and non-selective collection shall be based on the document named “PEF-OEF_EOLDefaultData_v1.2_uploaded.xlsx” and available on the wiki page of the EU Environmental Footprint Pilot Phase52.

52 https://webgate.ec.europa.eu/fpfis/wikis/display/EUENVFP/EoL+parameters



The EoL formula provided in Annex 5 to the PEF guidance document is applied as baseline approach:

The following parameters shall be applied:

Table VI-9: parameters for the end-of-life formula

Primary packaging Secondary packaging Tertiary packaging

R153 Specific parameter

Semi specific data

Default data : 0%

except for cardboard : 94%54

Semi specific data

Default data : 0%

except for cardboard : 94%

R255 Shall be based on the document “PEF‐OEF_EOLDefaultData_v1.2_uploaded.xlsx”

R3 Shall be based on the document “PEF‐OEF_EOLDefaultData_v1.2_uploaded.xlsx”

LHV (MJ/kg)

Shall be based on the document “PEF‐OEF_EOLDefaultData_v1.2_uploaded.xlsx”

XER,heat Shall be based on the document “PEF‐OEF_EOLDefaultData_v1.2_uploaded.xlsx”

XER,elec Shall be based on the document “PEF‐OEF_EOLDefaultData_v1.2_uploaded.xlsx”

Qs/Qp Shall be based on the following assumption :

1 for all types of packaging

Note: In the end-of-life formula, ED is specific emissions and resources consumed (per unit of analysis) arising from disposal of waste material at the EoL of the analysed product (e.g. landfilling, incineration, pyrolysis). It is assumed that ED (and ED*) is 100% landfilling (no incineration without energy recovery or pyrolysis is considered).

The modelling principles of incineration, landfill and recycling processes that shall be applied are the following:

Incineration modelling principle The incineration process is modelled with the ecoinvent process. The main principles of this module are:

Characterization of the flow according to 41 major chemical elements; Transfer coefficients for each chemical element to the various incinerator outputs

are used to model emissions to air, water and bottom ash based on waste composition;

53 To be adapted in case of recycled content in primary packaging 54 CEPI - key statistics report 2012 – Europe (data for case material) 55 It is assumed that all packaging waste from selective collection is sent to recycling



Energy consumption and reagents for gas treatment; The infrastructure (capital goods) shall be excluded.

Energy recovery of calorific value is added to the ecoinvent process.

The recovery of electricity and heat is modelled based on the following parameters:

LHV – Lower Heating Value of the waste The recovery efficiency of the incineration plant: electrical and thermal energy

recovery

For the recovery efficiency rates are56

10% for the electricity recovery (XER,elec) 20% for the heat recovery (XER,heat)

The electricity mix avoided is the one of the country of product use.

The heat mix avoided is the one of the country of product use.

The ecoinvent processes used are:

Disposal, polyethylene, 0.4% water, to municipal incineration, CH Disposal, packaging cardboard, 19.6% water, to municipal incineration, CH Disposal, polypropylene, 15.9% water, to municipal incineration, CH Disposal, wood untreated, 20% water, to municipal incineration, CH

Landfilling modelling principle The landfilling process is modelled with the ecoinvent process. The main principles of this module are:

Characterization of the flow according to 41 major chemical elements; Transfer coefficients for each chemical element to the various landfill outputs are

used to model emissions to air and water based on waste composition; Energy consumption and reagents for the leachate treatment;

No energy recovery from biogas production is considered.

The ecoinvent processes used are:

Disposal, packaging cardboard, 19.6% water, to sanitary landfill, CH Disposal, polyethylene, 0.4% water, to sanitary landfill, CH Disposal, polypropylene, 15.9% water, to sanitary landfill, CH Disposal, wood untreated, 20% water, to sanitary landfill, CH

56 Source: proposition made by Sebastien Humbert and Cécile Guignard to TAB Members. Version of January 8, 2015



Recycling modelling principle Recycling is modelled with the following parameters:

The recycling efficiency The energy and chemicals consumption during the recycling process The virgin material avoided (1 kg of recycled material displaces 1 kg of virgin

material)

Recycling efficiency rates are presented in the Table VI-10:

Table VI-10: default recycling efficiency and recycling process

Material Recycling efficiency

Recycling process

Plastics (HDPE and PP)

90% 950 kWh of electricity / t of input material

0.16 kg of alkylbenzene, linear, at plant, RER, ecoinvent, / t of input material

800 l of water / t of input material

Cardboard 97% corrugated board base paper, Wellenstof, FEFCO 2009 (ecoinvent LCI with activity data from FEFCO 2009)

Wood 92% particle board, indoor use, at plant, RER, ecoinvent (LCI without wood resource consumption)

(data source for plastics recycling process: RDC Environment based on visits of recycling facilities in Spain, Portugal and Netherlands in 2007-2008). If the company wants to use other data, it shall clearly justify that the data used are more representative than the above-listed default ones (based on technological, geographical and time-related criteria defined in chapter VI.2).

VI.9. Requirements for multifunctional products and multiproduct - processes allocation

There is no multifunctional product on the life cycle of a HDLLD product.

Process allocation shall be applied for transport of goods and solid waste treatment. Such allocations are described in detail in the dedicated chapter within the report (section VI.7 for transport and section VI.8 for solid waste treatment).

VI.9.1. Introduction

According to the PEF guidance document, if a process or facility provides more than one function, i.e., it delivers several goods and/or services ("co-products"), it is “multifunctional.” In these situations, all inputs and emissions linked to the process must be allocated among the product of interest and the other co-products in a principled manner.



Figure VI-7: Multifunctional process with several input products and resources consumed, and various wastes and emissions generated (source: ILCD

Handbook)

Systems involving multi-functionality of processes shall be modelled in accordance with the following decision hierarchy:

1. System Subdivision or system expansion

Wherever possible, system subdivision or system expansion should be used to avoid allocation. Subdivision refers to disaggregating multifunctional processes or facilities to isolate the input flows directly associated with each process or facility output. System expansion refers to expanding the system by including additional functions related to the co-products. It shall be investigated first whether the analysed process can be subdivided or expanded.

Extending the system boundaries by including processes that would be needed to make a similar output, for example if a usable quantity of steam, produced as a by-product, is used in such a way that it avoids production of steam by more conventional means, one may subtract the environmental burden of the avoided steam production. A frequent practical problem is that it is not always possible to discern how the steam would be produced alternatively.

2. Allocation based on a relevant underlying physical relationship

Allocation based on a relevant underlying physical relationship refers to partitioning the input and output flows of a multi-functional process or facility in accordance with a relevant, quantifiable physical relationship between the process inputs and co-product outputs.

3. Allocation Based on Some Other Relationship: Allocation based on some other relationship may be possible. For example, economic allocation refers to allocating inputs and outputs associated with multi-functional processes to the co-product outputs in proportion to their relative market values.



VI.9.2. Application to this PEFCR

HDLLD manufacture (step 5) - No specific allocation is required since the detergent manufacturing process

does not entail co-products or by-products. However, there are different production lines in the same plant. The data collection shall be performed using the following rules: o Provide data for the specific product studied; o Use mass allocation if data are only available at the plant level.

Transport (steps 3, 4, 6) - Mass allocation shall be applied57 for the distance covered for the HDLLD. Such

approach is commonly used and harmonised; - Mass allocation shall be applied58 in the case of several providers for the same

ingredient. Transport and distribution to consumer homes (step 7)

- An average basket and purchase scenario should be considered by default (harmonised approach defined by the OEFSR retail workgroup).

- In case of another distribution scenario is studied, allocation may be required if we are considering a multi-stop scenario, e.g., distance must be allocated to the group of items purchased in each shop and a basket purchased scenario (allocation between products in the basket);

Solid waste treatment (packaging) - An allocation is made between the supplier and the user of secondary material

to allocate the recycling benefits. According to the PEF guidance document, a 50-50 allocation is made. Note: the EoL formula provided in Annex V to the PEF guidance document shall be applied as a baseline approach.

57 Excerpt for cases where it is clearly known that the product is volume limited. 58 Excerpt for cases where it is clearly known that the product is volume limited.



VII. Benchmark and classes of environmental performance

The Table VII-1 gives the results of the representative product (RP) for the 15 impact categories. The RP is the one studied in the Screening analysis and described in appendix XIII.1. However the values below slightly differ from the screening study because of the amendments made on the assessment methodology as well as the use of updated background data (life cycle inventory).

Table VII-1: PEF profile of the HDLLD RP, incl. range of indicator results

EF impact category Unit Representative

product

Representative product without the Product use

phase

Climate change g CO2-eq 444.0 141.6


g Sb-eq 5.82E-03 4.46E-03

Human toxicity, carcinogenic effect

CTUh, c 2.51E-09 1.50E-09

Human toxicity, non carcinogenic effect

CTUh, n-c 2.32E-08 1.25E-08

Ecotoxicity for aquatic fresh water

CTUe 30.14 30.12

Acidification mol H+ eq 2.16E-03 7.69E-04

Freshwater eutrophication g P-eq 3.98E-02 2.78E-02

Marine eutrophication g N-eq 5.01E-01 2.81E-01

Photochemical ozone formation

g NMVOC-eq 1.16 4.84E-01

Ozone depletion g CFC-11-Eq 4.13E-05 2.33E-05

Resource depletion- water litres-eq 11.46 0.67

Particulate matter g PM2.5-eq 1.22E-01 5.37E-02

Terrestrial eutrophication mol N Eq 4.13E-03 1.66E-03

Ionising radiation Bq U235-Eq 86.6 16.9

Land use g C-Eq 851.1 537.0

The A.I.S.E. PEF TS had initiated work to try and define so called ‘environmental classes of performance‘. According to the PEFCR guidance, there should ideally be 5 classes of environmental accomplishment (from A to E, with A being the best performing class, C being the performance of the representative product, i.e. the average performance in the European market, and E the worst performing class), by taking into account the estimated spread (min-max range including uncertainty) and the statistic distribution of the product category for each impact category.

Based on an analysis of the in-market variation of the most important variables (including product dosage, type and use of ingredients and packaging materials, energy and water consumption at manufacturing site), the AISE PEF TS with the help of RDC/Solinnen estimated the in-market ranges for the most important impact categories



as identified during the PEF Screening, and different scenarios were assessed. One example of the outcome (specifically for the Climate Change impact indicator) of this analysis can be found in Figure VII-1.

Figure VII-1: Theoretical example of Box and whisker plot

In addition the 6 supporting studies helped to refine the min-max ranges. However it became clear that it would still be very difficult to have an accurate knowledge of the statistic distribution of real commercial products for each impact category.

Moreover, due to the limited robustness of methods which had to be used for the PEF calculation (classified as level II/III robustness; cf. Table V-2) and a high level of uncertainty, such a 5 class ranking was judged as not appropriate nor meaningful by the technical experts; it was agreed instead to base any quantitative product relevant communication on three classes, i.e. worse, equivalent to or better than the representative product (which was used for the PEF Screening study calculation), and to limit this to the Climate Change impact indicator.

The three classes defined for Climate change are as follows:

- Equivalent Class: RP value –20% < performance< RP value + 20% - Better Class : performance <RP value – 20% - Worse Class: performance> RP value + 20%.



VIII. Interpretation It is important to emphasize that the PEF laundry screening and supportive studies analysis have confirmed the relevance of previous and ongoing A.I.S.E. voluntary sustainability initiatives. Among other initiatives that have been launched by A.I.S.E. (see chapter IV.3 and V.6.1), the ‘I prefer 30’ initiative aims at promoting low temperature washing and encouraging the user to select the lowest relevant wash temperature according to his needs in terms of performance (depending on the type of clothes and stains). The screening study as well as the supporting studies have confirmed the relevance of such initiatives since the choice of the wash temperature and the resulting energy used to heat the wash water is the main driver of the overall life cycle results of a HDLLD. In line with the requirements of the issue paper ‘Guidance and Requirements for handling the use phase – V5.1 – January 2016’, the company shall report in its PEF study the following indicators with and without the use phase, because of the large share of the listed processes at the product use stage in the environmental results:

(electricity consumption): climate change, acidification, photochemical oxidation formation, stratospheric ozone depletion, particulate matters, ionizing radiation, marine eutrophication, land use;

(water consumption): resource depletion-water. Regarding the ecotoxicity evaluation, an EUCOM expert workshop was organized on 15 January 2015 on the topic of ecotoxicity evaluation; it concluded that USEtox must still be used for the screening and supportive studies, but may not be used for benchmarking and communication purposes, until the outcome is more robust (Executive summary of ‘Current and future implementability of USEtox’ PEF meeting, 15 January 2015 (version 23 January 2015)). This conclusion is in line with the findings of the A.I.S.E. PEF TS (Ref. A.I.S.E. PEF Screening Report). Based on the conclusions from this expert workshop, the A.I.S.E. PEF TS agreed to apply an alternative method with regard to ecotoxicity to aquatic freshwater organisms, i.e. risk-based ‘Environmental Safety Check (ESC)’ method used in the A.I.S.E. Charter for Sustainable Cleaning, and use the results (either pass or fail) for product relevant communication purposes.

The interpretation shall also be accompanied with a ‘limitations’ chapter. The latter shall remind that a PEF study considers an average European wash machine model (see annex) and that the results could be significantly different if other assumptions are used.

Comparison or comparative assertions As indicated in this PEFCR, the wash temperature shall be determined by the company in accordance to the unit of analysis (which refers to the amount of liquid detergent needed to provide a performance acceptable to consumers, consistent with claims made and supplemented by independently verifiable performance data held by companies in support of their claims).

In case of comparing the performance of similar products, the same wash temperature shall be considered (i.e. the European average washing temperature, which is 40°C). In addition, if the information on the packaging clearly states that an acceptable wash performance can be obtained at lower temperature, an additional statement can be made specific to the impact indicator results at this lower temperature. This is relevant since the selected washing temperature will determine the energy consumption at the use phase and will have a major influence on many impact indicators linked to the energy consumption (climate change, acidification, photochemical oxidation formation, stratospheric ozone depletion, particulate matters, ionizing radiation, marine eutrophication, land use).



IX. Reporting, Disclosure and Communication This section provides an overview of the current status (as per May 2016) of the communications phase as initiated and envisaged by the A.I.S.E. PEF pilot. As described above in the chapter ‘II.1. Technical Sectratiat’, an adhoc structure has been established to implement this PEF pilot project, including the A.I.S.E. PEF TS and the A.I.S.E. PEF TS Communications sub-group (‘PEF COMMS’). After introducing the topic by recalling elements provided by the Commission on the communication phase, the section explains the main steps that have been undertaken by the PEF COMMs team so far: these include:

- 1. Background to the communications phase - 2. Confirmation of “WHAT” is going to be tested and target audiences - 3. Insights from available research - 4. Insights from previous consumer engagement campaigns - 5. Developing designs for consumer testing - 6. B2C part: Consumer research as main focus for the PEF communications phase - 7. B2B part: Adhoc research/interviews with retailers - 8. Possible synergies - 9. Overall timing

1. Background to the communications phase Preliminary information from the Commission and its support team have been provided namely: The objective of each pilot will be to

• Design the communication vehicle (CV) • Confirm the Target audience and sample – who will be the respondents? • Implement to the target audience or a sample of the target audience • Assess the impact of the CV • Outcome measures – what do you expect to achieve with the

label/declaration? • Method – what methods could be used to assess/ test effectiveness? • Analysis – how will you decide whether the label/declaration achieves its

objectives

Then the A.I.S.E. PEF TS will need to evaluate: what is the impact of the CV? • What is the expected change? The research question. • How to assess change? • Sequential filters from awareness to behavioural change

– Awareness – seen or heard – Knowledge – understood the CV message – Attitude – change in attitude – intention to purchase – Behaviour – actual behaviour

2. Confirmation of “WHAT” is going to be tested and target audiences The PEF COMMs group has liaised closely with the PEF TS to confirm the environmental hotspots that were retained for the B2B and B2C test phase. The table below lists the main environmental indicators and messages (also referred to as ‘hotspots’) that will be used to develop the B2C and B2B test programmes (planned for Summer 2016).



Table IX-1: Overview of the environmental indicators for liquid laundry detergents retained for B2B and B2C testing Brand Differentiators Common indicators (qualitative)

Climate change Without the use phase (3 levels of benchmark: Better, Equivalent to or Worse than Reference product) 3 bands : => <113g CO2eq /wash => (RP benchmark): 113g -170g CO2eq/wash (=141.6 g +/- 20%) => >170g CO2eq /wash

With the use phase: “Wash at lowest relevant temp”

(cf. IP30 guidance) “Fill the machine”

Ecotoxicity for aquatic fresh water 2 levels : either “Basic” or “Advanced” vis à vis compliance with the ESC (Environmental Safety Check) tool

“Dose according to soil and water hardness/check dosing instructions”

Concentration level (“additional info” – not directly from PEF studies)

3 bands: <40ml 40-55ml >55ml

“Favour concentrated products”

Water depletion Not applicable “Use the highest relevant spin speed”

(to be tested with consumers) As demonstrated above (and highlighted in more details in section 10. below), a number of these indicators are linked to how the product is manufactured/designed by the producer (see column ‘BRAND DIFFERENTIATORS’). Other hotspots are related to how any liquid detergent product should be used by consumers to have a lower footprint. This justifies the introduction of the listed ‘QUALITATIVE’ indicators and communication messages, which are common to the entire product category without the need or benefit for brand differentiation. Widescale consumer adoption of these behaviours (e.g. ‘wash at low temperature’) can significantly reduce the impact in the consumer use phase which contributes significantly to the total lifecycle impacts (e.g. >70% for Climate Change). In summary, the analysis of PEF Screening Study, PEF Supporting Studies and PEF performance classes shows that a mix of differentiation and generic, non-differentiating messages can have a high combined potential to reduce the overall environmental footprint of the liquid detergents category. The A.I.S.E. PEF TS and COMMS group defined the high level objective for the PEF project as reducing the lifecycle product environmental footprint for liquid detergents. Given this, the planned B2B and B2C test phase will study the effectiveness of multiple communication options/vehicles for influencing consumer behaviour towards more sustainable detergent purchase and use habits. 3. Insights from available research A.I.S.E. has evaluated a range of available studies and surveys of particular relevance for environmental footprinting and consumer habits. These include:

- 3-yearly A.I.S.E. quantitative survey/research (2014, 2011, 2008 ; conducted by Insites; 23 EU Countries, online quanti questionnaire covering sustainability expectations: interest, habits (dosage, loading, temperature used etc.)- This habits research gives insights in similarities and variations of consumer habits across regions, notably when it comes to laundry washing temperature.



- Learnings from the French experimentation, specifically the A.I.S.E./AFISE experimentation on laundry detergents (2011/2012)- cf. French Ademe and Ministry websites.

- Learnings from educational and nudging campaigns to help change consumer behaviour to more sustainable habits (e.g. I prefer 30, Turn to 30)

4. Insights from previous consumer engagement campaigns Insights from a diverse range of consumer engagement initiatives is available. At industry (A.I.S.E.) level… Several A.I.S.E. initiatives to drive sustainable consumer laundry behaviour have been described in chapter ‘V.6. Additional environmental information’. These include:

- On pack information through the widespread deployment of the Washright/Cleanright panels (since 1997) on all packs on laundry detergents in Europe

- Adhoc campaigns to drive adequate dosage (cf compaction projects, washright campaigns in 1998-2002), or low temperature washing (eg multistakeholder campaign www.iprefer30.eu in 2014-2016

At brand level: A number of initiatives have been undertaken by individual brands from the detergent industry (and also from the appliance industry) on the topics of dosage, compaction, low temperature washing. Through other platforms: Examples: www.ceced.eu website, www.clevercare.com, www.forumwaschen.de, www.washing-excellence.org, national energy savings campaign by authorities; AIM “Nudging for Good” (AIM report released end 2015). 5. Developing designs for consumer testing The PEF COMMs group is presently (May 2016) working with a graphic design agency to convert the retained indicators and messages (cf. Table IX-1 in section2) into a consumer friendly communication toolkit, which will be used in the upcoming B2C and B2B test phase. Below are typical examples from the longer list of candidate logos and design elements (for further details of this research, see section 6. below).



a) On-pack summary logo - a visual hook on pack

- which confirms that the product has been subject to a PEF study and - which links to a website where the individual product profile for the identified and

relevant PEF hotspots can be found (re chapter XIII.2. Supporting studies).

DRAFT/ exploratory - this version and others to be subject to consumer testing b) Detailed on pack version (mainly visual design)

DRAFT/ exploratory - this version and others to be subject to consumer testing c) Detailed on pack version (inspired from energy label)

DRAFT/ exploratory - this version and others to be subject to consumer testing



d) On pack panel with most consumer-relevant info

DRAFT/ exploratory - this version and others to be subject to consumer testing 6. B2C part: Consumer research as main focus for the PEF communications phase The PEF TS and PEF COMMs group are planning to run market research (as opposed to “in market” testing), since this was judged to be the most effective way to achieve the PEF communications/testing objectives across a range of European countries. The A.I.S.E. experts are planning a first phase with QUALITATIVE market research (outlined below, timing June-July 2015), followed by QUANTITATIVE market research in a broader geographical scope (expected August-September 2016).

Aim of the research: - Identify consumers’ perceptions specific to liquid laundry detergent and their

environment footprint (‘impact’); explore what sustainability related information is consumer relevant.

- Check consumer reactions to the environmental hotspots from the PEF screening.

- Test the designs that communicate the hotspots in order to refine them for the quantitative phase)

- Get consumers suggestions on how to optimally convey the messages deriving from the hotspots.

- Seek to understand the differences between what consumers say (“intention”) and what they actually do (“reality”) when shopping and using the product

Proposed geographical scope, methodology:

Countries: A.I.S.E. will run the research in 3 countries for the initial qualitative phase (Germany, Poland, Sweden) and a larger geographical scope for the quantitative part.

Consumer profile: Male and female; age diversity: representative

In charge of buying and using the laundry detergent products and, and using at least liquid laundry detergent (can include capsules) as part of their laundry product portfolio. With regard to interest in sustainability/environment topics, the sample should be representative of the population.

Methodology: One-to-one interviews for the QUALI; Communities platforms or online research for the QUANTI (TBC) 7. B2B part: Adhoc research/interviews with retailers The PEF COMMs group is evaluating a number of options to develop a B2B test plan.

- Assess if specific communication messages/vehicles are needed for retailers (different from B2C)



- Assess whether to run B2B consultations as A.I.S.E. PEF pilot or whether grouping with other pilots (as discussed with the Commission) might be envisaged, with other similar products categories. Response due end June 2016 from Commission (and possibly Supporting team). This could possibly be done via a joint Pilots/B2B workshop in Summer/Sept 2016.

- Identify potential members of the B2B test groups.



X. Verification According to the PEF Guide, “any PEF study for internal communication claiming to be in line with the PEF guide and any PEF study for external communication (e.g. B2B or B2C) shall be critically reviewed in order to ensure:

- The methods used to carry out the PEF study are consistent with the PEF Guide;

- The methods used to carry out the PEF study are scientifically and technically valid;

- The data used are appropriate, reasonable and meet the defined data quality requirements;

- The interpretation of results reflects the limitations identified; - The study is transparent, accurate and consistent.

Unless otherwise specified in relevant policy instruments, any study intended for external communication59 shall be critically reviewed by at least one independent and qualified external reviewer (or review team). A PEF study to support a comparative assertion intended to be disclosed to the public shall be based on relevant PEFCRs, and critically reviewed by an independent panel of three qualified external reviewers. Any PEF study intended for internal communication claiming to be in line with the PEF Guide shall be critically reviewed by at least one independent and qualified external reviewer (or review team).”

The qualification requirements for the external and independent reviewer are presented in chapter 9.3 of the PEF Guide.

The following paragraphs, provided by the PEFCR guidance give some additional guidelines for the critical review.

Critical review report The independent reviewer(s) shall generate a unique report documenting the verification process, while adhering to the obligations covering rules for data confidentiality. This report shall be available to any person upon request.

The methods used to carry out the PEF study

The unit processes are defined as specified in this PEFCR;

In verifying the results from the impact assessment, the verifier shall check that the calculations are made in a correct way based on the resource use and emissions profile and recommended characterization, normalization and weighting factors.

The data source and calculation (transparency, traceability and consistency) Specific and semi-specific data traceability The reviewer shall verify the traceability and validity of the information/data coming from the organization and from suppliers (mainly logistics companies or packaging companies)

59 B2B/ without comparative assertion.



and other forms of secondary data used in the PEF calculations. This task might involve cross-check comparison of documents (e.g. invoices, bills of sale, etc.) both provided by the organization producing the PEF profile and the suppliers. Data quality requirement

The source of input and output data (that is, referenced literature, vendor-supplied databases, and LCI databases) used for a unit process/module of specified unit processes shall be at least of the quality requested in the reference PEFCR;

In case of existence of secondary data in the LCA results which have been already verified according to rules in the PEF Guide, these shall not be subject for further verification regarding the criteria methodological consistency, completeness and uncertainty. However the appropriateness of the use of these data for the specific product needs to be verified. This verifications needs to cover the aspects of time, geographical and technological representativeness of the secondary data for the use in the specific PEF profile.

The interpretation of results and communication Depending on specific application and communication option, different typology of verification may be required.

To be completed based on application and communication option. Transparency, Accuracy and Consistency of the study All relevant information is documented for each unit process/information module/PEFCR module, i.e. being consistent and understandable to enable an independent evaluation of the relevance of the data in accordance to this PEFCR. In particular the verifier should check that any additional documentation of the LCA process data (sources, correspondence, traceable references to origin, and so forth) is provided, especially if this information influenced LCA process data selection;



XI. Reference literature 1. Documentation used to prepare the PEF screening.

EUROPEAN COMMISSION RECOMMENDATION of 9 April 2013 on the use of common methods to measure and communicate the life cycle environmental performance of products and organisations, ANNEX II, Product Environmental Footprint (PEF) guide. European Commission-Joint Research Centre- Institute for Environment and Sustainability (2011): International Reference Life Cycle Data System (ILCD) Handbook-Recommendation for Life Cycle Impact Assessment in the European context. First edition November 2011. EUR 24571 EN. Publications Office of the European Union, Luxemburg. European Commission-Joint Research Centre- Institute for Environment and Sustainability (2014): Normalisation method and data for Environmental Footprints. Deliverable 2 of the AA Environmental Footprint and Material Efficiency Support for Product Policy (No. 70307/2012/Env.C.1/635340) Comparative Life Cycle Assessment (LCA) of Ariel “Actif à froid” (2006), a laundry detergent that allows to wash at colder wash temperatures, with previous Ariel laundry detergents (1998, 2001), Procter&Gamble, April 2006. Franke et al, 1995. Oekobilanzierung - Sachbilanz fuer die Waschmittel-Konfektionierung. Tenside Surfactant and Detergent 32: 508-514 DEMAND-SIDE MANAGEMENT, End-use metering campaign in 400 households of the European Community, Assessment of the Potential Electricity Savings in combination with first principles of physics; Project EURECO - SAVE PROGRAMME, January 2002. Frischknecht et al 2013. Swiss Eco-factor 2013 according to the Ecological Scarcity Method. Life Cycle Assessment of Selected Fragrance Materials, Research Institute for Fragrance Materials, Inc., April 2013. Medium and Long-term Opportunities and Risks of the Biotechnological Production of Bulk Chemicals from Renewable Resources, the potential of White Biotechnology, The Brew project, September 2006. Normalisation method and data for Environmental Footprints, European commission (DG JRC), September 2014. Product Environmental Footprint Pilot Guidance, Guidance for the implementation of the EU Product Environmental Footprint (PEF) during the Environmental Footprint (EF) pilot phase, version 4.0, European commission. Simonich, S.L., Federle, T.W., Eckhoff, W.S., Rottiers, A., Webb, S.,Sabaliunas, D., de Wolf, W., 2002. Removal of fragrance material during US and European wastewater treatment.



Van Hoof, G., Schowanek, D., Franceschini, H. and Munoz, I. (2011). Ecotoxicity impact assessment of laundry products: a comparison of USEtox and critical dilution volume approaches. Int. J. LCA. 16, 808 -818. Van Hoof, G., Vieira, M., Gausman, M., Weisbrod, A. (2013). Indicator selection in life cycle assessment to enable decision making: issues and solutions. Int J Life Cycle Assess 18:1568–1580.

2. List of existing PCRS and other useful documents 2.1. LCA studies 2.1.1. Peer Reviewed

Van Hoof, G., Schowanek, D. and Feijtel, TCJ: Comparative Life-Cycle Assessment of Laundry Detergent Formulations in the UK. Part I: Environmental fingerprint of five detergent formulations in 2001, in Tenside Surf. Det. 40, 2003

Van Hoof, G., Schowanek, D. , Feijtel, TCJ, Boeije, G. and Masscheleyn, P. H.: Comparative Comparative Life-Cycle Assessment of Laundry Detergent Formulations in the UK. Part II: Time trend analysis and wash equivalent comparison (1988 – 2001), in Tenside Surf. Det. 40, 2003

2.1.2. P&G Public LCA studies (not published in scientific literature)

Procter & Gamble (P&G): Ariel Actif à Froid – summary www.scienceinthebox.com

(www.scienceinthebox.com/environmental-impact-of-ariel-actif-a-froid), 2006

P&G: Ariel Excel Gel – summary www.scienceinthebox.com

www.scienceinthebox.com/ariel-excel-gel-cool-clean-technology , 2008

2.1.3. Others

Henkel AG & CO., KGaA: Case Study Persil Megaperls - Case Study undertaken within the PCF Pilot Project Germany, 2009

Nielsen, A M, Li, H, Zhang, H: Compact detergents in China – A step towards more sustainable laundry - A Life Cycle Assessment of four typical Chinese detergents, in: Household and Personal Care Today, Vol. 8(5) September/October 2013

Sustainability Assessment Program, Water Research Centre, UNSW, Sydney: The Life Cycle Assessment of Clothes Washing Options for City West Water’s Residential Customers, 2010

The Sustainability Consortium (TSC): Product Category Life Cycle Assessment (PCLCA) – Laundry Detergent, 2011

2.2. PCR

A.I.S.E.: A.I.S.E. Charter for Sustainable Cleaning – ASPs for Liquid Laundry Detergents, 2011

A.I.S.E.: A.I.S.E. Charter for Sustainable Cleaning – ASPs for Liquid Laundry Detergents Substantiation dossier, 2011

AFISE – ADEME/AFNOR: BPX 30-323-2 French labelling PCR - Grenelle Project France –



“Référentiel Détergents”, 2012

International EPD® System: PCR for Detergents and Washing Preparations, 2011

2.3. EPD

KEITI: EL302. Powder Laundry Detergents, 2003

The Sustainability Consortium (TSC): Laundry Detergent Product Category – Sustainability Measurement and Reporting System, 2011

2.4. Potentially useful related methodology publications

Pant, R., Gert Van Hoof, Schowanek, D., Feijtel, T.C.J., de Koning, A., Hauschild, M., Pennington, D., Olsen, S. I. and Rosenbaum, R.: Comparison between 3 different LCIA methods for aquatic ecotoxicity and a product Environmental Risk Assessment - Insights from a detergent case study within OMNIITOX. Int. J. LCA, 9, 17A-18A, 295-306, 2004

de Koning, A., Schowanek, D., Dewaele, J., Weisbrod, A. and Guinee, J.: Uncertainties in a carbon footprint model for detergents; quantifying the confidence in a comparative result. Int. J. LCA 15; 79- 89, 2010

Van Hoof, G., Schowanek, D., Franchesini, H. and Munoz, I.: Ecotoxicity impact assessment of laundry products: a comparison of USEtox and critical dilution volume approaches. Int. J. LCA. 16, 808 -818, 2011

Subramanian, V., Ingwersen, W.,Hensler, C.,Collie, H. : Comparing product category rules from different programs: Learned outcomes towards global alignment, Int. J. LCA, Volume 17, Issue 7, August, Pages 892-903, 2012

2.5. Others

A.I.S.E.: The Case for the “A.I.S.E. low temperature washing” initiative – Substantiation dossier, October 2013

European Commission: EU Ecolabel for Laundry Detergents, 2011

Nordic Ecolabelling: Nordic Ecolabelling of Laundry detergents and stain removers, Version 7.5, 15 December 2011 - 31 December 2017, 2011

Good Environmental Choice Australia Ltd: Environmental Performance Standard - Cleaning Products. Australian Ecolabelling in accordance with ISO 14024 Standard No: CPv2.2-2012, Issued: 26 November 2013, 2013

Koehler, A. et al: Comparing Environmental Footprint of Consumer Products – the Relevance of Different Life Cycle Phases, LCA VIII, Seattle, October 1, 2008

Product Category Rule Guidance Development Initiative: Guidance for Product Category Rule Development Version 1.0, August 28, 2013

The Sustainability Consortium (TSC): Laundry Detergent Product Category Dossier, 2013



XII. Supporting information for the PEFCR Open stakeholder consultations https://webgate.ec.europa.eu/fpfis/wikis/display/EUENVFP/Stakeholder+workspace%3A+PEFCR+pilot+Household+liquid+laundry+detergents

PEFCR Review Report

Additional requirements in standards not covered in PEFCR

Cases of deviations from the default approach



XIII. Annex

XIII.1. Representative product (RP)

The representative product (RP) or ‘A.I.S.E. HDLLD Reference product’ or ‘A.I.S.E. HDLLD RP’ is a virtual product that is a “model” of HDLLD products with a recommended dosage of 75 ml sold in the EU market in 2014.

Representative product - Definition Process For confidential reasons, all data have been gathered from each manufacturing company of the A.I.S.E. PEF Technical Secretariat by an external consultant (Solinnen). Those companies, which represent the majority of the Market in the EU and EFTA, have provided product specification information (i.e. ingredients and packaging data) for a typical HDLLD product with a representative dosage of 75ml.60

The 75ml dose is the recommended dosage of representative products in conformance with the Detergent Regulation (EC648/2004) necessary to wash 4.5 kg of normally soiled dry fabric, using water with a medium hardness, in a 6 kg capacity washing machine, at 75% loading capacity.

In order to provide these data the following method was used by each company: Identification of 1 to 3 most sold products among the heavy-duty liquid laundry

detergents with a recommended dosage ranging from 60 to 75 ml; Calculation of an average bill of ingredients on the basis of the mass of every

ingredients and the 2013 market share (in Euros) of each product. The same calculation was made on packaging components (considering primary, secondary and tertiary packaging);

Submission to Solinnen. Solinnen used the same method to calculate the bill of ingredients of the ‘A.I.S.E. HDLLD Reference Product’ on the basis of the bill of ingredients provided by each company and 60 The choice of a 75 ml dosage is linked to A.I.S.E.’s Charter for Sustainable Cleaning and the product related advanced sustainability profiles (ASP) defined for HDLLD products and the current market situation of this product segment. The idea via the Charter ASPs is to improve the sustainability profile of the industry sector via different measures, one of those the concentration of products. Via an industry consultation which was carried out in 2008, it was confirmed that a maximum dosage of 75ml can deliver a performance equivalent to more diluted liquid laundry detergents, and that a dosage of 75 ml is achievable by all actors in the market, incl. SMESs, through conventional technology (i.e. technology that is already widely used and readily accessible to all companies). Compared to the market situation in Europe in 2009, when 42,9% of laundry detergents liquids fulfilled the 75 ml dosage per wash threshold (source: Nielsen), the market has indeed developed towards more concentrated products with a market share of concentrated liquid laundry detergents (defined as 75 ml and below) of 95% in 2013 and 97% in 2014 (source: Euromonitor International). Therefore the 75 ml dosage was chosen for the A.I.S.E. HDLLD RP in order to be representative of the market: ultra-concentrated HDLLD are below (30 - 50 ml) and diluted HDLLD are above this threshold.



its 2013 market share in the concentrated HDLLD market (source: Euromonitor International). The same method was used for the packaging components (for the three levels of packaging).

Companies provided this information confidentially; Solinnen used the information to generate Table XIII-1 and aggregate the chemical names of ingredients according to their function in the detergent, in order to respect the confidentiality of the information received from companies.

Bill of materials The Bill of Materials lists the purchased raw materials that are combined during the HDLLD manufacturing process. During this process, several raw materials react chemically, such as during the neutralisation of acid surfactant mixtures with alkaline materials. This results in a slightly different composition for the marketed HDLLD detergent, which is released into the sewerage system. The bill of materials refers to the list/amount of purchased raw materials used to produce the HDLLD detergent. The ‘reacted formulation’ refers to the composition of the marketed HDLLD product and is used in the evaluation of the ecotoxicological impact of the HDLLD.

Table XIII-1: Bill of materials

Ingredients families

description of function

(source cleanright website)

Type Chemicals CAS number Representative

product

(% by mass)

Water Water 7732-18-5 70,22%

Builders Reduces the effect of water hardness by removing calcium and magnesium ions and increases the effectiveness of the detergent.

citric acid 77-92-9 1.61%

salts of citric acid and other salts

68-04-2

6132-04-3 0.67%

Sequestrants Prevents free metal ions from causing any adverse effects on product performance, appearance, or stability by reacting with them.

phosphonates sodium phosphonate

22042-96-2

0.41%

Dye Dye 0.03%

Enzymes Enzymes are catalysts that increase the rate of chemical reactions, such as digestion and growth processes. In the detergent industry, commercial enzymes are used to help ensure a high degree of stain removal, whiteness, fabric and color care, and overall cleaning performance.

mannanase 37288-54-3

0.58%

protease 9014-01-01

amylase 9000-90-2

pectinase 9015-75-2

lipase 9001-62-1

Other enzymes

Fragrances Offer an aesthetic experience for the packed detergent, during/after the washing and when wearing the washed fabrics.

Fragrances

0.71%

Optical brighteners

Makes the fabrics look brighter and whiter

0.06%

Surfactant Used to change the surface anionic sodium alkyl 68891-38-3 3.55%



system (anionic – non-ionic)*

tension of water to assist cleansing, wetting surfaces, foaming and emulsifying (the suspension of one liquid evenly within another).

surfactants ether sulfates (SLES)

alkylbenzene sulfonate (LAS)

25155-30-0

26836-07-7

68910-32-7

6.83%

soap oleochemicals fatty acid (cocoate, palm kernel, etc.)

2.41%

non-ionic surfactants

ethoxylates oleochemicals + petrochemical)

& other non-ionic surfactants

5.91%

Alkalinity sources

Increases the alkalinity of the product to aid dissolution of dirt.

sodium hydroxide

1310-73-2

2.31% triethanolamine 102-71-6

141-43-5

Solvents Used to dissolve other ingredients

glycerine 56-81-5

2.85% glycols 57-55-6

2163-42-0

other solvents

Other ingredients

preservatives

1.85% polymers

salts

others

Total 100%

Packaging description The Table XIII-2 presents the primary, secondary and tertiary packaging for the representative product or ‘A.I.S.E. HDLLD RP.

Table XIII-2: Packaging description

Packaging components and materials Representative product Unit

Primary packaging

Bottle in HDPE 3.7 g/reference flow

Cap (including dosing device + spout) in PP 0.8 g/reference

flow

Paper labels 0.1 g/reference flow

Recycled plastic content 0% %

Net detergent mass per bottle 1850 g

Secondary packaging

Mass of cardboard box 600 g

Number of products per cardboard box 6 #

LDPE plastic film 40 g



Number of products by plastic film 6 #

Tertiary packaging

Mass of wood pallet 25 kg Number of sales product unit per wood pallet 192 #

Number of uses of the pallet 40 #

Mass of one cardboard separator 400 g

Number of cardboard separators per pallet 3 #

Mass of LDPE plastic film 235 g

The range of values for secondary packaging takes into account the mass variability of cardboard boxes and the variability in the number of products in one cardboard box.

The mass of one intercalary and the number of cardboard intercalary per pallet are based on assumptions, due to lack of data (companies have not provided this information). System boundary diagram The system diagram is similar to the Figure V-1: System boundary diagram for HDLLD

The following paragraphs presents the assumptions related to foreground processes.

HDLLD manufacture

At the HDLLD manufacture stage, the data taken into account are:

Energy consumption; Water consumption.

Table XIII-3: HDLLD manufacture consumptions

Representative product

Unit Source

Electricity consumption

0.16 kWh / kg of detergent produced

Franke et al, 1995. Oekobilanzierung – Sachbilanz für die Washmittel-Konfektionierung. Tenside surfactant and Detergent 32: 508-5

Heat consumption 0

MJ / kg of detergent produced

Water consumption 0.661

Litres / kg of detergent produced

Estimation based on KPI performance named “consumed water”62 as published in the A.I.S.E. activity and sustainability report 2013-2014

The electricity and water consumption rates are based on European averages.

61 These data do not take into account the incorporation of water in the product 62 Actually, the “consumed water” KPI corresponds to water use. The initial data in the A.I.S.E. activity and sustainability report for 2013 is 1.3 m³/t of production (covering A.I.S.E. complete product portfolio). Water consumption at HDLLD manufacture = 1.3 [l/kg] - average quantity of water in HDLLD [l/kg] = 1.3 -0.7022 ≈ 0.6 [l/kg]



NB: the default data to be used for a PEF study are listed in Table XIII-10 and Table XIII-11.

Raw material transportation to processing plant Average transportation distances are considered as follows63:

1500 km by truck (articulated truck with payload 24t); 8000 km by boat (container ship).

These transport distances are applied to each material included in the formulation and the packaging.

Assumptions related to transportation and distribution to retail and consumer homes The average distance between the HDLLD manufacture facility and the retail facility has been defined as 600 km64, covered by truck (articulated truck with max payload of 24t).

At retail store, the electricity use during storage is calculated based on the worst-case market-typical sold unit in a retail store with the following formula:

[(Total overhead electricity consumption (MJ/cm2-day) of non-refrigerated shelf area / Height of a shelf) * (Volume taken up by primary packaging + 20%) * Days displayed

before sold]

With data from the sustainability consortium, Laundry detergent PCLC, 2011 as follows:

- Total overhead electricity consumption of non-refrigerated shelf area= 5.59E-04 MJ/cm2-day65

- Height of a shelf: 205 cm - Volume taken up by primary packaging: 17 cm * 10 cm * 26 cm=4420 cm³ - Days displayed before sold: 15 days

Therefore electricity use during storage is 0.217 MJ/sold unit.

The transport to consumer home is based on information as provided by the OEFSR retail TS 66:

80% by car: 4.8 km round trip per shopping trip; 15% by foot, bike and/or bus (all modelled, using public transport): 1 km per

shopping trip (round trip);

63 AFISE – ADEME/AFNOR: BPX 30-323-2 French labelling PCR – Grenelle Project France – « Référentiel Détergents, 2012 » based on date from participating companies and on cross discussion (multi product category) leaded by ADEME. 64 AFISE – ADEME/AFNOR: BPX 30-323-2 French labelling PCR - Grenelle Project France –“Référentiel Détergents, 2012" based on data from participating companies and on cross discussion (multi product category) leaded by ADEME. 65 The retail storage has to be modelled by using the default data as provided by the OEF retail. While waiting for the final version of the OEFSR retail pilot, the retail storage shall be modelled, based on the electricity consumption. 66 Status: 22 September 2014



5% of the remaining consumers get their products delivered at home by van, with 4.8 km allocated per delivery (round trip; per household).

Note that these values consider that several errands can be made when "driving around Saturday afternoon" such as passing by the hairdresser, picking up the children at the soccer training, etc., and, therefore, the 4.8 km distance is the portion of the trip that is allocated to the action of shopping.

An allocation is required at this step: the OEFSR retail TS considers an average basket of 20 items per shopping trip. Therefore, the allocation of consumer transportation is set at 5% for a HDLLD.

Assumptions related to use scenario The use scenario considered is an average European scenario, based on average European washing machines and the average habits of consumers regarding their use of these washing machines.

The data used in this study are shown in the Table XIII-4:

Table XIII-4: Data used to model the product use stage

Representative product

Unit

Dosage 75 ml

Water-demand of washing machine67

50 Litres / washing

Washing temperature68 40 °C

Assumption related to End of Life It is considered that 100% of the HDLLD representative product is used. Therefore, the used product is sent to a municipal wastewater treatment plant (WWTP).

The end-of-life of the packaging materials includes the following processes:

Collection transport; End-of-life treatment (recycling, incineration or landfilling) according to the

average European municipal solid waste treatment.

The collection transport distance69 are:

54 km/t for the selective collection; 12.2 km/t for the non-selective collection.

67 “Stamminger study”, not published. This study is based on the test of 9 different washing machines with a loading capacity of 5 to 11 kg, all front-loaded with horizontal axis and produced by 6 different manufacturers. The calculation is made by the University of Bonn. 68 The 40 °C washing temperature was chosen, based on the outcomes of an A.I.S.E. consumer habit survey which was carried out in 2011, covering Europe. The average laundry washing temperature is 41 °C. Around 68% of European loads are washed at or above 40 °C (43 °C are done at 40 °C). 40 °C was retained in order to have a realistic scenario. 69 French data, “Analyse des distances parcourues par les bennes de collecte des ordures ménagères”, ADEME, 2007



The EoL formula provided in Annex V to the PEF guidance document is applied as baseline approach:

Parameters applied and data sources are presented in Table VI-9:

Table XIII-5: parameters applied data sources for the end-of-life formula

HDPE PP LDPE Cardboard

R1

0% 0% 0% 94%

Base scenario 0% (conservative assumption) + sensitivity

analysis from0 to 100%


analysis from0 to 100%


analysis from 0 to 100%

CEPI ‐ key statistics report 2012 ‐ Europe

data for case material

R270

35.30% 35.30% 0.00% 83.80%

Eurostat ‐ data 2012 ‐ Fraction of recycled packaging wastes at end‐of‐life : plastic

packaging (http://ec.europa.eu/eurostat/tgm/refreshTableAction.do?tab=table&plugin=1&pcode=t

en00063&language=fr)

Conservative assumption

Eurostat ‐ data 2012 ‐ Fraction of recycled packaging wastes at end‐of‐life : paper and

cardboard packaging (http://ec.europa.eu/eurostat/tgm/refreshTableAction.do?tab=table&plugin=1&pcod

e=ten00063&language=fr)

R3

27.17% 27.17% 42.00% 6.80%

Calculation based on Fraction of non‐recycled municipal solid wastes that are incinerated ‐ Eurostat 2012 data (http://ec.europa.eu/eurostat/tgm/refreshTableAction.do?tab=table&plugin=1&pcode=tsdpc240&language=en)

(1‐R2)*Fraction of non‐recycled municipal solid wastes that are incinerated

LHV (MJ/kg)

42.47 32.78 42.47 15.92

ecoinvent dataset for PE incineration

ecoinvent dataset for PP incineration

ecoinvent dataset for PE incineration

ecoinvent dataset for cardboard incineration

XER,heat 20%

Proposition made by Sebastien Humbert and Cécile Guignard to TAB Members. Version of January 8, 2015

XER,elec 10%

Proposition made by Sebastien Humbert and Cécile Guignard to TAB Members. Version of January 8, 2015

Qs/Qp 1 1 ‐ 1

Assumption ‐ Assumption

70 It is assumed that all packaging waste from selective collection is sent to recycling



Note: In the end-of-life formula, ED is specific emissions and resources consumed (per unit of analysis) arising from disposal of waste material at the EoL of the analysed product (e.g. landfilling, incineration, pyrolysis). It is assume that ED (ED *) is 100% landfilling (no incineration without energy recovery or pyrolysis is considered).

XIII.2. Supporting studies

The two following tables describe the real commercial products studied by 6 PEF TS member companies as well as the respective results for an agreed selection of impact indicators in one of the 3 studied scenarios, specifically the common scenario that allows a direct comparison of the 6 products under common production, sales country and use conditions. Additional details on each supporting study and results are included in the individual full company reports. These reports contain confidential information (e.g. Bill of materials, specific company information) and are shared only between each company and the RDC/Solinnen LCA consultant on a confidential basis. Disclosure to other parties is not allowed without prior and proper approval by each company. The actual characteristics for each of the 6 supporting study are described in Table XIII-6. Collectively, the 6 supporting studies represent the European market to the extent possible in terms of commercial aspects (country of sales), countries of production as well as product and packaging characteristics (product dosage, amount/type/sourcing of ingredients and packaging materials).

Table XIII-6: Supporting studies – products studied

Company 1 Company 2 Company 3 Company 4 Company 5 Company 6

Production country NL FR BE BE UK FR

Sales country DE, PO FR IT,FR, ES EU-28 FR, UK, IE, NL,PT

DE, BE, FR, UK, PO

Dosage(ml) 75 70 25 70 35 65

Ingredients

‐ Chemical dosage (active content, without water) g/job

22.68 10.25 13.76 21.8 22.9 23.6

‐ Nature Mainly petro-based

Average mix

Mainly agro-based

Mainly agro-based

Mainly petro-based

Mainly petro-based

Packaging

‐ Weight (g/job) (primary + secondary)

5-7 <5 <5 <5 5-7 >7

‐ Nature Mainly petro-based

Mainly petro-based

Average mix

Mainly petro-based

Mainly petro-based

Mainly petro-based

‐ Refillable No No No Yes No No

‐ Post‐consumer

recycled material in

primary packaging No No No >25% No No



Table XIII-7 gives an overview of the results for the 6 supporting studies, covering a selection of impact indicators in the ‘common scenario’. This allows a direct comparison of the 6 products under common production, sales and use conditions to quantify product-related differences between the 6 products. The PEF TS agreed to share the selected information to allow an analysis of the results in a common scenario that removes differences related to the production and use phase country and use conditions, such as those related to electricity grid and waste infrastructure (This analysis is currently ongoing in the AISE PEF TS and is not yet included in this PEF CR draft report). In total, each company performed an analysis for 3 mandatory scenarios:

1. Baseline (representative of countries of production and countries of sales, main washing temperature as claimed on the packaging),

2. Common EU28 (e.g. EU28 production, EU28 use; 40°C wash temperature),

3. Common EU28 (e.g. EU28 production, EU28 use; 30°C wash temperature),

4. Main production and sales country.

A 5th scenario was optional and allowed each company to select other relevant production, sales and use combinations. Results for the 4 (of 5) scenarios are reported by each company in their confidential full reports.

Table XIII-7: Supporting studies – main results for EU-28 scenario - 40°C

Results for EU-28 scenario (production/sales) – 40°C Company 1 Company 2 Company 3 Company 4 Company 5 Company 6

Climate

change

(gCO2eq./job)

Use phase included 426 402 390 422 447.8 458

Use phase excluded 124 100 88 119 145.4 156

Depletion of

Water

resources

(litres/job)

Use phase included 11.2 11.07 11.09 11.23 11.3 11.37

Use phase excluded 0.5 0.28 0.3 0.44 0.5 0.58

Depletion

fossil/mineral

resources

(g Sb eq/job)

Use phase included 6.4E-03 3.44 E-03

3.09E-03 4.18E-03 5.87E-03 4.1E-03

Use phase excluded 5.0E-03 2.08 E-03

1.72E-03 2.81E-0.3

4.50E-03 2.73E-03

Ecotoxicity

USETox method

(CTUe/job) 10.5 9.41 4.26 6.65 12.8 29.41

ESC pass (y/n) Yes Yes Yes Yes Yes Yes

XIII.3. Benchmark and classes of environmental performance

See chapter VII.



XIII.4. Upstream scenarios (optional)

XIII.5. Downstream scenarios (optional)

XIII.6. Normalisation factors

This chapter gives the mid-point normalisation factors (NFs) as provided in the “Normalisation method and data for Environmental Footprints - Benini L., Mancini L., Sala S.,Manfredi S., Schau E. M., Pant R. (2014) - European Commission, Joint Research Center, Institute for Environment and Sustainability, Publications Office of the European Union, Luxemburg, ISBN: 978-92-79-40847-2”.

However, specific attention should be given to the recent paper “Indicator selection in life cycle assessment to enable decision making: issues and solutions - Gert Van Hoof & Marisa Vieira & Maria Gausman & Annie Weisbrod - Int J Life Cycle Assess (2013) 18:1568-1580". Indeed, this study highlights that the normalization process requires the use of factors whose quality depends on data completeness of the reference set and impact assessment method completeness and uncertainty. This paper shows three different normalization approaches applied on a hand dish washing product case study (using the ReCiPe impact assessment method) that produce different results in the most relevant indicators selection. The three methods are mid-point normalization, end-point normalization and a 3-step approach based on end-point normalization and a selection process that breaks out the normalized end-point indicators into the most contributing mid-point indicators. The authors recommend this 3-step approach to reduce bias due to lack of data completeness (especially for some mid-point indicators that contribute less within a given end-point (or area of protection) such as toxicity).

At this stage, this approach cannot be implemented because end-point characterization factors are not available for the PEF impact assessment model retained. Nevertheless, this paper encourages considering the result of mid-point normalization with precaution, especially for the less robust mid-point indicators.



The Table XIII-8provides the recommended normalisation factors for the EU 27 related to domestic inventory in 2010. Per person Normalisation factors have been calculated using Eurostat data on EU 27 population in 2010 (Eurostat, 2013a).

Table XIII-8: Recommended Normalisation factors for EU 27 (2010) based on domestic inventory

EF impact category Unit DOMESTIC Normalisation Factor

per Person (domestic)

Overall

Robustness

Climate change kg CO2 eq. 4.60E+12 9.22E+03 Very high

Ozone depletion kg CFC-11 eq 1.08E+07 2.16E-02 Medium

Human toxicity-cancer effect CTUh 1.84E+04 3.69E-05 Low

Human toxicity- non-cancer effect CTUh 2.66E+05 5.33E-04 Low

Acidification mol H+ eq 2.36E+10 4.73E+01 High

Particulate matter kg PM2.5 eq 1.9E+09 3.8E+00 Very high

Ecotoxicity for aquatic fresh water CTUe 4.36E+12 8.74E+03 Low

Ionizing radiation kBq U235 eq 5.64E+11 1.13E+03 Medium

Photochemical ozone formation kg NMVOC eq 1.58E+10 3.17E+01 Medium

Terrestrial eutrophication mol N eq 8.76E+10 1.76E+02 Medium

Freshwater eutrophication kg P eq 7.41E+08 1.48E+00 Medium to low

Marine eutrophication kg N eq 8.44E+09 1.69E+01 Medium to low

Land use kg C deficit 3.74E+13 7.48E+04 Medium

Resource depletion water m³ water-eq 4.06E+10 8.14E+01 Medium to low

Resource depletion - mineral, fossil kg Sb eq 5.03E+07 1.01E-01 Medium

Source: Benini L., Mancini L., Sala S., Manfredi S., Schau E. M., Pant R. 2014 Normalisation method and data for Environmental Footprints. European Commission, Joint Research Center, Institute for Environment and Sustainability, Publications Office of the European Union, Luxemburg, ISBN: 978-92-79-40847-2

XIII.7. Weighting factors

No alternative weighting approach was tested as “additional” compared to the baseline approach (i.e. all impact categories shall receive the same weight in the baseline approach)



XIII.8. Foreground data to be collected (specific data)

Table XIII-9: Specific data

Unit process Activity Data Unit

Product description

Bill of material in 100% active content:

for each ingredient:

- Name,

- CAS number,

- Ingredients family,

- Volume in 100% active content.


litre

Reacted formulation:

For each chemical : name, CAS number, chemical formula, volume


litre

Weight of product by sales product unit

g

Detergent density g/ml

Dosage/washing ml

Packaging description

Primary packaging

Type of raw packaging (raw materials)

Mass


g

HDLLD manufacturing process Geographical location On country scale

Use Consumer geographical location On country scale

Recommended dosage ml

Wastewater treatment Characterisation factors of ecotoxicity for each available ingredient71

Characterisation factor shall be calculated according to the generic method defined in this PEFCR – see section VI.8.1.1

Removal rates in wastewater treatment plant for each available ingredient

Removal rate shall be calculated according to the generic method defined in this PEFCR – see section VI.8.1.1)

Share of households connected to a wastewater treatment system (average weighted by sales per country)

See Eurostat data in annex XIII.5. for share of household connected per country

71 An EUCOM expert workshop, organized on 15 January 2015 on the topic of ecotoxicity evaluation, concluded USEtox must still be used for the screening and supportive studies, but may not be used for benchmarking and communication purposes, until the outcome is more robust (Executive summary of ‘Current and future implementability of USEtox’ PEF meeting, 15 January 2015 (version 23 January 2015)). This conclusion is in line with the findings of the A.I.S.E. PEF TS (Ref. A.I.S.E. PEF Screening Report).



XIII.9. Generic and semi-specific data

XIII.9.1. Generic and semi-specific data or activity parameters

Table XIII-10: Semi-Specific data



Primary packaging description

Refillable packaging73 No

Number of refill 0

Secondary packaging description

Type of secondary packaging Cardboard box

Weight of secondary packaging

& Number of sales product units per secondary packaging

900 g / cardboard box and 4 unit/box

(225 g/sales product unit)

Tertiary packaging description

Type of packaging type 1 (pallet) Wood pallet

Weight of pallet

& Number of sales product unit per pallet

28 kg / wood pallet and 120 unit/pallet

(0.24 kg/sales product unit)

Number of uses of the pallet 40

Type of packaging type 2 (intercalary) Cardboard intercalary

Weight of packaging


400 g / cardboard intercalary & 4 intercalary/pallet


Type of packaging type 3 LDPE plastic film

Weight of packaging


350 g LDPE plastic film/pallet


Raw material transportation

Transport distance and mode of transport 2250 km by truck (articulated truck with payload 24t);

12000 km by boat (container ship).

HDLLD manufacture

Energy consumption (electricity, heat from grid, others)74

Electricity 0.25 kWh / kg of detergent (leaving the factory)

No heat

Water use

(excluding water in the detergent product leaving the factory)

0.9 litres75 / kg of detergent (leaving the factory)

72 These data are based on data used for the screening study; in addition, an average increase factor as validated by the TS members was applied. 73 In case of refillable packaging, the company shall describe the whole refilling system in details and take into account the share of the whole system allocated to the quantity of detergent under study for the primary packaging material and quantity. Guidance are provided in annex XIII.9.2. 74 In case of use of several energy sources, the company shall ensure that the complete energy consumption is accounted for. Also, if deionisation of water takes place on the HDLLD site, the related energy consumption shall be deducted from the total amount of energy consumption onsite since the default dataset already considers the deionising of water. 75 These data do not take into account incorporation of water in the product.





Distribution Transport distance and mode of transport 900 km by truck (articulated truck with payload 24t)

Table XIII-11: Generic data

Type Activity data Default data

Retail storage76 Electricity consumption77 0,217 MJ/sale unit product

Transport to consumer home78

Allocation of transport to the HDLLD 5% by sale unit product

Transport scenario between sale place and consumer home79

80% by car

15% by public transport

5% by delivery van

Transport distance between sale place and consumer home80

Car : 4.8 km81

Public transport : 1 km

Van : 4.8 km

Packaging end-of-life

Packaging end-of-life scenario end-of-life scenario defined in section VI.8.2

Transport (waste collection) end-of-life scenario defined in section VI.8.2

XIII.9.2. Guidance in case of refillable packaging

As regards refillable packaging, there are two refill options to be considered: the refill pouch, displayed at the same place as the solid plastic bottles and the refill station

The primary packaging documentation shall be adapted to the above mentioned options:

Refill pouch : (the rigid bottle/# of refill+pouch to completely refill the bottle)/nb of doses in the rigid bottle content

Refill station: (the rigid bottle/# of refill)/# of doses in the rigid bottle + refill station/# of doses that can be distributed before being changed.

76 The retail storage has to be modelled by using the default data as provided by the OEF retail. While waiting for the final version of the OEFSR retail pilot, the retail storage shall be approached modelled, based on the electricity consumption. 77 Source: The Sustainability Consortium, Laundry detergent PCLC, 2011. 78 The company may deviate from this generic distribution scenario only if the detergent is sold via a different distribution mode (e.ge-commerce). In such a case the delivery scenario shall be described in detail and the activity data justified. 79 This scenario, provided by the OEFSR retail TS, could change in the final PEFCR depending on the progress made by the OEFSR retail TS on the subject. 80 The transport distance, provided by the OEFSR retail TS, could change in the final PEFCR depending on the progress made by the OEFSR retail TS on the subject. 81 Note that these values are already considering that several actions can be made when "driving around Saturday afternoon," such as passing by the hairdresser, picking up the kids at the soccer training, etc., and, therefore, the 4.8 km distance is the portion of the trip that is allocated to the task of shopping.



The information on the # of refill needs to be justified by appropriate documentation (consumer practice, sales data).

As for the second and third packaging it follows the same rules to include the second and third packaging of the pouch or additional level of packaging in case of the refill station.

XIII.9.3. Data sources and process LCI to consider

The LCI publicly available for the HDLLD ingredients in non-commercial databases is limited. The LCI data sources used for the screening PEF study of HDLLD product are compliant with the data hierarchy and data quality criteria recommended in the PEF guidance.

At this stage of the final draft, 1st version of the PEFCR, the following data sources are recommended:

ERASM (surfactant ingredients): The “ERASM Surfactant Life Cycle & Ecofootprinting (SLE)” project was commissioned by the ERASM, a research partnership of the Detergents and Surfactants Industries, A.I.S.E., the international Association for Soaps, Detergents and Maintenance Products and CESIO, European Committee of Organic Surfactants and their Intermediates. The objective of this project is to update or establish the environmental profile of 15 surfactants and 17 precursors, taking into consideration actual surfactant production technology and consistent high quality background data. This LCI data is currently only available to member companies but it is planned to publish the data as an update of the data currently available in publically available databases such as ecoinvent.

IFRA (fragrance ingredients): LCI carried out on behalf of the Research Institute for Fragrance Materials (RIFM), and considers the potential life cycle environmental impacts of fragrance materials. The life cycle stages included in this study address the production of upstream materials and energy, product manufacturing, and compounding. The compounding process refers to the mixture of fragrance ingredients and is included, even though each fragrance material is considered separately; the LCI data can be made available by IFRA upon request.

Novozymes (enzymes): LCI profile of detergent enzymes. Data refer to average enzyme production at six factories located in China, USA, Brazil, Denmark and Finland. Enzymes are produced via microbial fermentation followed by recovery and granulation using large scale, modern and efficient production processes. The data represent the production in 2010;

Franklin data (citric acid): Citric acid production, data provided by Franklin Associates (Representative data of the years 1995-2000)

The most relevant and up-to-date LCI commercial databases (e.g. ecoinvent, ELCD) (for a range of organic and inorganic ingredients and any other processes non specific to ingredients);

Confidential inventory data is permissible but should comply with the PEF guidance and data quality criteria.

The Table XIII-12 provides all process LCI to be considered for the system modelling. For each process, a default LCI is proposed. “Relevant” processes are marked with a red star.

If the company has access to a LCI more representative of the process used and with an equivalent or better data quality assessment level (see below), the company shall use it.



For any chemical substances/ingredients, the company shall ensure that the LCI is defined for 100% of active substances. As for the default LCI, any adaptation or choice required from the available LCI to obtain the LCI related to 100% active content is indicated in the following table.

Table XIII-12: Process LCI

Life cycle stage Process (unit) Default LCI


Water (g) Water, deionised, at plant, CH, ecoinvent82

Builders (g)- citric acid Citric acid production, Franklin data 1995-2000

Builders (g) – salts of citric and other salts

0.744 g of citric acid (Citric acid production, Franklin data 1995-2000)

+ 0.465 g of NaOH (sodium hydroxide, 50% in H2O, production mix, at plant, RER, ecoinvent)

Sequestrants (g) Sodium phosphate, at plant, RER, ecoinvent

Dye (g) Chemical organic, at plant, GLO, ecoinvent

Enzymes (g) Liquid enzyme product used for laundry washing, Novozymes data 2010. (adapted to 100% active content of enzyme).

Fragrances (g) Mix of

- 1/4 Dihydromyrcenol, RER , IFRA

- 1/4 Alpha-Hexyl Cinnamaldehyde, RER, IFRA

- 1/4 Hexyl Salicylate, RER, IFRA

- 1/4 Beta-Pinene, RER, IFRA

Optical brighteners (g) ½ Fluorescent whitening agent distyrylbiphenyl type, at plant, RER ecoinvent

½ DAS-1, fluorescent whitening agent triazinylaminostilben type at plant, RER ecoinvent

Anionic surfactants – Sodium alkyl ether sulphates (SLES) (g) *

C12-14 Alcohol Ether Sulphates (oleo based) ERASM 2014- 100% active content

or

C12-13 Alcohol Ether Sulphates (petro based) ERASM 2014 – 100% active content

Anionic surfactants- alkylbenzene sulfonate (LAS) (g) *

C10-13 Linear alkylbenzene sulphonic acid (HLAS) (petro based) ERASM 2014 – 100% active content

or

C12-14 Sodium alkyl sulphate (oleo/petro based) ERASM 2014 – 100% active content

Soap: oleochemical fatty acids (g) soap, at plant, RER, ecoinvent

Non-ionic surfactants : ethoxylates (oleo) (g) *

Mix of:

- C12-14 Alcohol (oleo) ethoxylate, 3 moles EO, ERASM 2014


- C16-18 Alcohol (oleo) ethoxylate, >20 moles EO, ERASM 2014

Non-ionic surfactants : ethoxylates (petro) (g) *

Mix of:

- C12-15 Alcohol (petro) ethoxylate, 3 moles EO, ERASM 2014 – 100% active content

- C12-15 Alcohol (petro) ethoxylate, 7 moles EO, ERASM 2014 – 100% active content

82 Since the default LCI considered water already as deionised, the company shall ensure that energy for water deionising (if made on site) is not double counted.




Other surfactants See ERASM 2014 LCI list provided in Table XIII-13.

Alkalinity sources (g) sodium hydroxide, 50% in H2O, production mix, at plant, RER ecoinvent

or

triethanolamine, at plant, RER, ecoinvent

Solvent – glycerine (g) * Mix of:

- Glycerine, from vegetable oil, at esterification plant, FR, ecoinvent

- Glycerine, from rape oil, at esterification plant, RER, ecoinvent

- Glycerine, from palm oil, at esterification plant, MY, ecoinvent

- Glycerine, from soybean oil, at esterification plant, US, ecoinvent

- Glycerine, from soybean oil, at esterification plant, BR, ecoinvent

Solvent – others (g) Propylene glycol, liquid, at plant, RER, ecoinvent

Others-Preservative (g) Benzo[thia]diazole-compounds, at regional storehouse, RER, ecoinvent

Others- Polymers (g) Polycarboxylates, 40% active substance, at plant, RER, ecoinvent

Others-Salts (g) Mix of other ingredients to 100% Sodium chloride, powder, at plant, RER, ecoinvent

Others-others (g) Chemicals organic, at plant, GLO, ecoinvent

Soluble film for unit-dose capsule (m2)

(to be defined)

2.Packaging raw material sourcing and manufacturing

Label - Kraft paper (g) Kraft paper, bleached, at plant, RER, ecoinvent

HDPE for packaging (g) polyethylene, HDPE, granulate, at plant, RER 2005

+ injection moulding, RER, ecoinvent

PP for packaging (g) Polypropylene granulate (PP) production mix, at plant, RER, ecoinvent


LDPE plastic film (g) Polyethylene, LDPE, granulate, at plant, RER

+extrusion plastic film, RER, ecoinvent

Other plastic film manufacturing (extrusion process)

extrusion, plastic film, RER, ecoinvent

Corrugated board (g)

Cardboard intercalary (g)

- Corrugated board base paper,

Kraftliner, ecoinvent with FEFCO data


Testliner, FEFCO, ecoinvent with FEFCO data - Corrugated board base paper, Wellenstof, FEFCO, with FEFCO data83

Wood pallet (g) EUR-flat pallet, RER, ecoinvent

3. Transport of

83 These three LCI have to be used to adapt the recycled content in the cardboard according to rules defined in this PEFCR (They are combined to calculate the Ev and Er to applied the PEF end-of-life formula).




ingredient to processing plant

Transport by truck (vkm) Transport, lorry 16-32t, Euro5, RER, ecoinvent

Transport by boat (tkm) Transport, transoceanic freight ship/OCE, ecoinvent

4. Transport of Packaging to processing plant


Transport by boat (tkm) Transport, transoceanic freight ship/OCE, ecoinvent

5.HDLLD manufacturing

Electricity (kWh) * Electricity consumption (medium voltage) in manufacturing country - built according to section VI.4.1.1. and electricity production LCI (EU and European countries) ecoinvent

- Electricity, hard coal, at power plant,

- Electricity, natural gas, at power plant,

- Electricity, nuclear power, at power plant,

- Electricity, oil, at power plant,

- Electricity, at wind power plant,

- Electricity, hydropower, at power plant.

Heat (kWh) Heat consumption – built according to country mix (EIA data) and the following LCI :

- heat, light fuel oil, at boiler 100kW, non-modulating, CH, ecoinvent

- heat, at hard coal industrial furnace 1-10MW, RER, ecoinvent

- heat, natural gas, at industrial furnace low-NOx>100kW, ecoinvent



Electricity (kWh) * Electricity consumption (medium voltage) in retail country - built according to section VI.4.1.1 and electricity production LCI (EU and European countries) ecoinvent







7. Transport and distribution to consumer home

Transport by car (vkm) Operational, passenger, car, diesel, fleet average2010, RER, ecoinvent

Transport by public transport (pkm) Transport, regular bus, CH, ecoinvent

Transport by van delivery (vkm) Operation, van < 3,5t, RER, ecoinvent

8.Product use

Electricity (kWh) * Electricity at grid (low voltage)

in consumer country - built according to section VI.4.1.1 and electricity production LCI (EU and European countries) ecoinvent









Electricity, hydropower, at power plant.

Water (kg) * Tap water, at user, RER, ecoinvent

9.Wastewater treatment

Sewer and Wastewater treatment (m3) *

Modelling described in section VI.8

Wastewater treatment LCI created based on wastewater treatment ecoinvent and adapted to the specific composition of the reacted formulation.

-

10.Solid waste treatment

Cardboard end-of-life (kg) Cardboard end-of-life LCI (built according to section VI.8.2)

- disposal, packaging cardboard, 19.6% water, to municipal incineration, CH, ecoinvent

- disposal, packaging cardboard, 19.6% water, to sanitary landfill, CH [#2225],

- corrugated board base paper, Wellenstof, FEFCO 2009 Ecoinvent

PE end-of-life (kg) PE end-of-life LCI (built according to section VI.8.2)

- disposal, polyethylene, 0.4% water, to municipal incineration, CH, ecoinvent

- disposal, polyethylene, 0.4% water, to sanitary landfill, CH

- alkylbenzene, linear, at plant, RER, ecoinvent

PP end-of-life (kg) PP end-of-life LCI (built according to section VI.8.2)

- disposal, polypropylene, 15.9% water, to municipal incineration, CH , ecoinvent

- disposal, polypropylene, 15.9% water, to sanitary landfill, CH


Wood end-of-life (kg) Wood end-of-life LCI (built according to section VI.8.2)

- disposal, wood untreated, 20% water, to municipal incineration, CH

- disposal, wood untreated, 20% water, to sanitary landfill, CH

- particle board, indoor use, at plant, RER, ecoinvent

In addition the Table XIII-13 provides additional information regarding the LCI available in the ERASM 2014 database. The LCI related to 100% active content shall be considered.

Table XIII-13: ERASM 2014 LCI

Generic surfactant family

Sub-family Substance name (REACH)

CAS number

Declared unit – scope of the data collection

Anionic surfactant

Alkyl benzene sulphonate (LAS)

C10-C13 Linear alkylbenzene sulphonic acid (HLAS)

85536-14-7 HLAS, sulphonation of LAB, 1 tonne at plant

Alkyl benzene sulphonate (LAS)

C12-14 AS (oleo/petro)

85586-07-8 C12-14AS (oleo/petro), sulphonation of C12-14 fatty alcohol (oleo/petro), 1 tonne at plant

Sodium alkyl ether sulphate

C12-14E2S (oleo) 68891-38-3 C12-14 E2S, Ethoxylation and sulphation of fatty alcohol, 1 tonne at





CAS number


(SLES) – oleo based

plant

Sodium alkyl ether sulphate (SLES) – petro based

C12-13E2S (petro) 161074-79-9 C12-13 E2S, Ethoxylation and sulphation of fatty alcohol, 1 tonne at plant

Hydrotrope Sodium cumene sulphonate

28348-53-0 Sodium cumene sulphonate, sulphonation of cumene, 1 tonne at plant

Non-ionic surfactant

Ethoxylate –oleo based

C12-14 AE3 68439-50-9 C12-14 AE3 (C12-14 Alcohol (oleo) Ethoxylate with 3 moles EO per mole), , 1 tonne at plant

Ethoxylate oleo based

C12-14 AE7 68439-50-9 C12-14 AE7 (C12-14 Alcohol (oleo) Ethoxylate with 7 moles EO per mole), 1 tonne at plant

Ethoxylate oleo based

C16-18 AE >20 68439-49-6 C16-18 AE>20 (C16-18 Alcohol (oleo) Ethoxylate with >20 moles EO per mole), 1 tonne at plant

Ethoxylate -petro based

C12-15 AE3 157627-86-6 C12-15 AE3 (C12-15 Alcohol (petro) Ethoxylate with 3 moles EO per mole), 1 tonne at plant

Ethoxylate -petro based

C12-15 AE7 157627-86-6 C12-15 AE7 (C12-15 Alcohol (petro) Ethoxylate with 7 moles EO per mole), 1 tonne at plant

others Cocamide diethanolamine

68603-42-9 Cocamide diethanolamine, reaction of coconut oil with diethanolamine, 1 tonne at plant

others C12-14 Amine Oxide

(C12-C14 Amines, (even numbered) -alkyldimethyl, N-oxides)

308062-28-4 C12-14 (oleo) Amine oxide, oxidation of tertiary amine with hydrogen peroxide, 1 tonne at plant

Cationic surfactant

C16-18 TEA-Quat;

Fatty acids, C16-18 (even numbered) and C18 unsaturated., reaction products with triethanolamine, di-methyl sulphate-quaternized)

CAS-Nr. None; (previously 91995-81-2)

EG-Nr. 931-203-0 (new description)

C16-18 TEA-Quat (Triethanolamine Ester Quat (oleo)), reactions of fatty acid with Triethanolamine (TEA) and Dimethylsulphate (DMS), 1 tonne at plant

Amphoteric surfactant

C8-18 Alkyl amidopropyl betaine

(1-Propanaminium, 3-amino-n-(carboxymethyl)-n,n-dimethyl-, N-C8-18(even numbered) acyl derivs.), hydroxides, inner salts;

CAS-Nr. none; EG - 931-296-8 (new description)

C8-18 Alkyl amidopropyl betaine, reaction of alkyl chain source with DiMAPA (N,N-Dimethylaminopropyl acrylamide) and reaction with Chloroacetic acid and NaOH, 1 tonne at plant

Sodium Cocoamphoacetate (Reaction products of 1H-Imidazole-1-

68390-66-9 Amphoacetate, carboxymethylation of fatty imidazolines, 1 tonne at plant





CAS number


ethanol, 4,5-dihydro-, 2-(C7-C17

odd numbered, C17-unsatd. alkyl) derivates and sodium hydroxide and chloroacetic acid )



The Table XIII-14 and Table XIII-15 provide for each secondary dataset listed in Table XIII-12, the required information to perform the data quality assessment:

For criteria of completeness, uncertainty/precision, methodological appropriateness and consistency, the score of the LCI against each criteria.

For criteria of representativeness regarding technology, geographic and time, a summary of the available information regarding the LCI in order to assess its representativeness of the studied product. For additional information, the company shall refer to the documentation provided by the data source (ERASM, ecoinvent, Franklin, etc.).

Table XIII-14: Completeness, Precision/uncertainty, Methodological appropriateness and consistency score for each default dataset.

Process (unit) Default LCI DQA rate

Completeness Precision/

Uncertainty


Water (g) Water, deionised, at plant, CH, ecoinvent84 2 2 3

Builders (g) Citric acid production, Franklin data 1995-2000

4 4 3


2 2 3

Dye (g) Chemical organic, at plant, GLO, ecoinvent 2 2 3

Enzymes (g) Liquid enzyme product used for laundry washing, Novozymes data 2010

2 2 2






5 2 5

Optical brighteners (g)

½ Fluorescent whitening agent distyrylbiphenyl type, at plant, RER ecoinvent


2 2 3


C12-14 Alcohol Ether Sulphates (oleo based) ERASM 2014

or

C12-13 Alcohol Ether Sulphates (petro based) ERASM 2014

2

2

2

2

1

1

Anionic surfactants- alkylbenzene

C10-13 Linear alkylbenzene sulphonic acid 2 2 1

84 Since the default LCI considered water already as deionised, the company shall ensure that energy for water deionising (if made on site) is not double counted.





Uncertainty


sulfonate (LAS) (g) * (HLAS) (petro based) ERASM 2014

or

C12-14 Sodium alkyl sulphate (oleo/petro based) ERASM 2014

Soap: oleochemical fatty acids (g)

soap, at plant, RER, ecoinvent 2 2 3


Mix of:




2 2 1


Mix of:

- C12-15 Alcohol (petro) ethoxylate, 3 moles EO, ERASM 2014


2 2 1

Other surfactants See ERASM 2014 LCI list

Alkalinity sources (g)

sodium hydroxide, 50% in H2O, production mix, at plant, RER ecoinvent

2 2 3

Solvent – glycerine (g) *

Mix of:






2 2 3


2 2 3

Others-Preservative (g)

Benzo[thia]diazole-compounds, at regional storehouse, RER, ecoinvent

2 2 3

Others- Polymers (g)

Polycarboxylates, 40% active substance, at plant, RER, ecoinvent

2 2 3


2 2 3


2 2 3


(specific LCI to be defined)

Label - Kraft paper (g)

Kraft paper, bleached, at plant, RER, ecoinvent

2 2 3





Uncertainty


HDPE for packaging (g)

polyethylene, HDPE, granulate, at plant, RER 2005


2 2 3

PP for packaging (g) Polypropylene granulate (PP) production mix, at plant, RER, ecoinvent


2 2 3

LDPE plastic film (g) Polyethylene, LDPE, granulate, at plant, RER, ecoinvent

+ extrusion, plastic film, RER, ecoinvent

2 2 3


extrusion, plastic film, RER, ecoinvent 2 2 3






Testliner, FEFCO, ecoinvent with FEFCO data - Corrugated board base paper, Wellenstof, FEFCO, ecoinvent with FEFCO data85

2 2 3

Wood pallet (g) EUR-flat pallet, RER, ecoinvent 2 2 3

Transport by truck (vkm)

Transport, lorry 16-32t, Euro5, RER, ecoinvent

2 2 3

Transport by boat (tkm)

Transport, transoceanic freight ship/OCE, ecoinvent

2 2 3



2 2 3



2 2 3





2 2 3






Uncertainty





Heat (kWh) Heat consumption – built according to country mix (EIA data) and the following LCI :




2 2 3



2 2 3








2 2 3

Transport by car (vkm)

Operational, passenger, car, diesel, fleet average2010, RER, ecoinvent

2 2 3

Transport by public transport (pkm)

Transport, regular bus, CH, ecoinvent 2 2 3

Transport by van delivery (vkm)

Operation, van < 3,5t, RER, ecoinvent 2 2 3



- Electricity, hard coal, at power plant, UCTE

- Electricity, natural gas, at power plant, UCTE

- Electricity, nuclear power, at power

2 2 3





Uncertainty


plant, UCTE

- Electricity, oil, at power plant, UTCE

- Electricity, at wind power plant, RER

Electricity, hydropower, at power plant,FR

Water (kg) * Tap water, at user, RER, ecoinvent 2 2 3




-

2 4 3

Cardboard end-of-life (kg)

Cardboard end-of-life LCI (built according to section VI.8.2)



- corrugated board base paper, Wellenstof, FEFCO 2009 ecoinvent

2 2 3





2 2 3


- disposal, polypropylene, 15.9% water, to municipal incineration, CH , ecoinvent



2 2 3

Wood end-of-life (kg)

Wood end-of-life LCI (built according to section VI.8.2)


2 2 3





Uncertainty


- disposal, wood untreated, 20% water, to sanitary landfill, CH




Table XIII-15: Technology, Geographical and Time information on each default dataset (source: relative datasource e.g. ecoinvent)

Process (unit) Default LCI Information in order to perform the DQA86

Technology modelled Geographical coverage Date of the data used

Water (g) Water, deionised, at plant, CH, ecoinvent87

Process includes a strong cation exchanger a degasser and a strong anion exchanger. unit is operated with counterflow regeneration. Obtained water quality about 1 uS/cm for the conductivity and a silica content (as SiO2) of 5-25 ug/l. As water resource tap water from a public supply with a total hardness of 1.71 mol/m3 (range 0.7 - 3.2) was assumed. No lime decarbonation as pre treatment is used.

Data mainly from European producers but also from Literature and U.S. companies. Raw water data from Switzerland (drinking water of Zurich and Basel). For electricity demand Swiss supply mix used.

Time of literature publication. Measurements took place partly before this period.

Builders (g) Citric acid production, Franklin data 1995-2000

No information No information 1995-2000


average technology for the examined area / time

average data for UK consumption - here used as average values for the whole European area

1994 - 1994

date of published literature

Dye (g) Chemical organic, at plant, GLO, ecoinvent

Present technology for the production of the different included chemicals (for details, see datasets of the respective chemical substance)

General module, based on chemicals from Europe, Switzerland and Global level, used as a global average.

No info

Enzymes (g) Liquid enzyme product used for laundry washing, Novozymes

Enzymes are produced via microbial fermentation followed

Data refer to average enzyme production at six factories

Production in 2010

86 Information provided in this table is extracted from the report or info added to the dataset. For any additional information, please refer to the report of the datasource. 87 Since the default LCI considered water already as deionised, the company shall ensure that energy for water deionising (if made on site) is not double counted.





data 2010 by recovery and granulation using large scale, modern and efficient production processes.

located in China, USA, Brazil, Denmark and Finland.






Site specific data representative of current technology were collected and analyzed for production of each fragrance material. For upstream raw materials and energy production, average industry profiles from the GaBi 5 databases were utilized (Source IFRA report- april 2013).

Model developed utilizing European background data. (Source IFRA report- April 2013).

Annual fragrance production data were collected for the year 2010. Additional data necessary to model material production and energy use were obtained from the GaBi Databases 2011 and are representative of the years 2005 to present. (Source: IFRA report – April 2013)

Optical brighteners (g)

½ Fluorescent whitening agent distyrylbiphenyl type, at plant, RER ecoinvent


distyrylbiphenyl type

Typical production process for end of 90s

triazinylaminostilben type

Typical production process for end of 90s


data from European main producer, used as European average


data from European main producer, used as European average


1999 - 1999

year of reported data


1997 - 1997

year of reported data


C12-14 Alcohol Ether Sulphates (oleo based) ERASM 2014

or

C12-13 Alcohol Ether Sulphates (petro based) ERASM 2014

C12-14 AES:

reaction of the ethoxylate of C12-14 alcohol from oleo-chemical sources, with sulphur trioxide in a falling film reactor

C12-13 AES: Four steps are involved in the manufacture of AES: alcohol production, ethoxylation, sulphonation and neutralization

C12-14 AES:

Data set based on primary production data for C12-14 E2S (oleo) Sodium Salt production from five different suppliers (Germany, India, France and Italy) representing the imported and produced C12-14 E2S (oleo) Sodium Salt in Europe.

C12-13 AES: data set based on Primary production data from five different suppliers (DE, IT, IN, FR) representing the imported and produced

C12-14 AES: average production based on the year 2011

C12-13 AES: average production based on the year 2011





C12-14 AES in Europe.

Anionic surfactants- alkylbenzene sulfonate (LAS) (g) *

C10-13 Linear alkylbenzene sulphonic acid (HLAS) (petro based) ERASM 2014

or

C12-14 Sodium alkyl sulphate (oleo/petro based) ERASM 2014

C10-13-HLAS is produced by sulphonation of LAB (linear alkylbenzene).

The sulphonation of LAB is commonly accomplished with SO3 as sulphonation agent using two different types of reactors, cascade and falling film

C12-14-AS

C12-14 fatty alcohol (oleo) is esterified with sulphuric acid followed by immediate neutralization. Sulphation with sulphur trioxide diluted with inert gas. The reaction product leaving the reactor is degassed and neutralized as quickly as possible using sodium hydroxide.

C10-13-HLAS data set based on primary production data for HLAS production from five different suppliers in Europe representing HLAS production in Europe (DE, ES, FR, GB, IT).

C12-14-AS data set based on primary production data for C12-14 AS production from three different suppliers (India, Indonesia and Italy) representing the imported and produced C12-14 AS in Europe

C10-13-HLAS : average production based on the year 2011

C12-14-AS average production based on the year 2011

Soap: oleochemical fatty acids (g)

soap, at plant, RER, ecoinvent Average technology for the production of soap out of a blend acids from palm and coconut oil, representing typical European production mix in the mids 90s. The ratio of short to long fatty acid chains is 20:80>, the moisture is 13%.

Data based on the European fatty alcohol sulfonate production.

1992-1995


Mix of:


- C12-14 Alcohol (oleo) ethoxylate, 7 moles EO,

C12-14 AE3:reaction of C12-14 fatty alcohols (oleo) with ethylene oxide

C12-14 AE7:reaction of C12-14 fatty alcohols (oleo) with ethylene oxide

C12-14 AE3: The data set is based on primary production data for C12–14 AE3 production from three different suppliers (Germany, and Sweden) representing the imported and produced

C12-14 AE3: average production based on the year 2011

C12-14 AE7: average production based on the year





ERASM 2014


C16-18 AE ≥ 20: reaction of alcohols with ethylene oxide

C12–14 AE3 in Europe.

C12-14 AE7: The data set is based on primary production data for C12–14 AE7 production from three different suppliers (Germany, and Sweden) representing the imported and produced C12–14 AE7 in Europe.

C16-18 AE ≥ 20: data set based on primary production data for C16-18 AE ≥ 20 production from four different suppliers, either Germany or Sweden, representing the imported and produced C16-18 AE ≥ 20 in Europe

2011

C16-18 AE ≥ 20: average production based on the year 2011


Mix of:



C12-C15 AE3/AE7: Alcohol ethoxylates are produced by the reaction of detergent range alcohols with ethylene oxide.

C12-C15 AE3: data set based on primary production data for C12–15 AE3 production from three different suppliers (Belgium, Netherlands and Italy) representing the imported and produced C12–15 AE3 in Europe

C12-C15 AE7: data set based on primary production data for C12–15 AE7 production from three different suppliers (Begium, Netherlands and Italy) representing the imported and produced C12–15 AE7 in Europe

C12-C15 AE3: average production based on the year 2011

C12-C15 AE7: average production based on the year 2011.

Other surfactants See ERASM 2014 LCI list

Alkalinity sources (g)

sodium hydroxide, 50% in H2O, production mix, at plant, RER

Average of the different technologies used for sodium

European average values No info





ecoinvent hydroxide production – thus no process-specific emissions are included into this dataset.

Solvent – glycerine (g) *

Mix of:






Glycerine from vegetable oil: typical vegetable oil esterification plant designed for vegetable oil methyl ester (VOME) production (for use in the vehicle fuels market) in the French market. Vegetable oil base-catalyzed transesterification.

Glycerine from palm oil: typical vegetable oil plant designed for the production of methyl ester (for use in the vehicle fuels market), global context. Base-catalyzed transesterification.

Glycerine from rape oil: cf. glycerine from palm oil.

Glycerine from soybean oi (UK and US): cf. glycerine from palm oil.

Glycerine from vegetable oil: data from different plants worldwide (incl. literature data).

Glycerine from palm oil: data from different plants worldwide (incl. literature data)

Glycerine from rape oil: cf. glycerine from palm oil.

Glycerine from soybean oi (UK and US): cf. glycerine from palm oil.

Glycerine from vegetable oil:

1996-2006 (data from 1996 to 2003, current technology for large scale biodiesel plants worldwide)

Glycerine from palm oil: 1996-2006 (data from 1996 to 2003, current technology in the EU)

Glycerine from rape oil: 1998-2006 (data from 1998 to 2005, current technology for large scale biodiesel plant worldwide)

Glycerine from soybean oil (UK): 1998-2006 (data from 1998 to 2003, current technology for large scale biodiesel plant worldwide)

Glycerine from soybean oil (UK): 1998-2006 (data from 1998 to 2005, current technology for large scale biodiesel plant worldwide)


Production from propylene oxide and water with a process yield of 95%. Inventory based on stoechiometric calculations. The emissions to air (0.2wt% of raw material input) and water were estimated using mass balance. Treatment of the wastewater in an internal wastewater treatment plant

Data used has no specific geographic origin (stoechiometry). Average European processes for raw material, transport requirements and electricity mix used.

2000 (date of published literature)





assumed (elimination efficiency of 90% for C).

Others-Preservative (g)

Benzo[thia]diazole-compounds, at regional storehouse, RER, ecoinvent

benzo(thia)diazole-compounds The inventory is modelled for Europe.

2000 - 2010

Time of publications

Others- Polymers (g) Polycarboxylates, 40% active substance, at plant, RER, ecoinvent

Co-polymerization process of maleic anhydride and acrylic acid

Data represent European dataset

1993-1998 data of used literature


Modern solution mining technology (thermos compressing technology)

Data from one European solution mining site –used to represent the European mix of 41% solution mining and 59% rock salt

2000-2000


Present technology for the production of the different included chemicals (unweighted average of the first 20 organic substance, being part of the top100 chemicals and included into the ecoinvent database)

General dataset based on chemicals from Europe, Switzerland and Global level, used as a global average.

No info.


(to be defined- specific dataset)

Label - Kraft paper (g)

Kraft paper, bleached, at plant, RER, ecoinvent

Technology of one producer at the beginning of the 90’s

Data from one Swiss producer, used as European average data

1993

HDPE for packaging (g)

polyethylene, HDPE, granulate, at plant, RER 2005


HDPE: Polymerization out of ethylene under normal pressure and temperature

Injection moulding: present technologies

HDPE: 24 European production sites

Injection moulding: information from different European and Swiss converting companies

HDPE: 1999-2001

Injection moulding: 1993-1997

PP for packaging (g) Polypropylene granulate (PP) production mix, at plant, RER,

PP: polymerization out of PP: 28 European production PP: 1999-2001





ecoinvent


propylene

Injection moulding: see above

sites



LDPE plastic film (g) Polyethylene, LDPE, granulate, at plant, RER, ecoinvent

+ extrusion, plastic film, RER, ecoinvent

LPDE: polymerization out of ethylene at high pressure and high temperature

Extrusion process: cf below

LPDE: 27 European production sites Extrusion process: cf below

LPDE: 1999-2001

Extrusion process: cf below


extrusion, plastic film, RER, ecoinvent

Present technologies Information from different European and Swiss converting companies

1993-1997






Testliner, FEFCO, ecoinvent with FEFCO data - Corrugated board base paper, Wellenstof, FEFCO, ecoinvent with FEFCO data88

Kraft: technology of one producer at the beginning of the 90’s.

Testliner: recycled content 100%

Wellenstof: recycled content 100%

Kraft: data from one Swiss producer used as European average data

Testliner: paper mills in Austria, Czech Republic, France, Germany, Italy, the Netherlands, Spain and Great Britain.

Wellenstof: cf. testliner

Kraft:1993

Testliner: 2008

Wellenstof: cf. testliner

Wood pallet (g) EUR-flat pallet, RER, ecoinvent Standard composition of materials – no construction process

Dataset that include only the materials- no geographic coverage.

2000-2002



Diesel engine Data refer to European Conditions

2005



Average data from steam turbine (5%) and diesel engine (95%) propulsion. The fuel used

Global scope 1980-2000






is heavy Fuel oil (HFO0 and is representative for slow speed engine types (speed: 14 knots per hour). The data represents solid bulk transport (about 40000dwt)



Cf. above Cf. above Cf. above





- Electricity, hard coal, at power plant, UCTE

- Electricity, natural gas, at power plant, UCTE

- Electricity, nuclear power, at power plant, UCTE

- Electricity, oil, at power plant, UTCE

- Electricity, at wind power plant, RER

- Electricity, hydropower, at power plant,FR

Elec, hard coal: average installed technology

Elec, natural gas: standard technology of installed power plant

Elec, nuclear: standard technology of installed power plant

Elec, oil: estimation of average technology

Elec, wind: average technology

Elec, hydro: the dataset just describes shares (shares of electricity produced by of run-of-river and reservoir hydropower plants)

Elec, hard coal: UCTE 2000

Elec, natural gas: based on literature and efficiency from IEA2001 including countries AT, BE, DE, ES, FR, IT, LU, GR, PT

Elec, nuclear: Swiss data of one specific PWR(pressurized water reactors) and one specific BWR (boiling water power) for requirements and all UCTE (BE, CH, DE, ES, FR,NL) nuclear power plants for emissions<

Elec, oil: estimation of the mix of producing countries

Elec, wind: European average data

Elec, hydro: France

Elec, hard coal: 2000

Elec, natural gas: 1990-2000

Elec, natural gas: 1995-1999

Elec, oil: 2000

Elec, wind: 2002

Elec, hydro: 2000

Heat (kWh) Heat consumption – built Heat, hard coal: average used Heat, hard coal: German Heat, hard coal: 1988-1992





according to country mix (EIA data) and the following LCI :




in early 90’s> Stoker boiler used as reference technology.

Heat, light fuel: non-modulating, non-condensing boiler sold in 2000, efficiency 94%.

Heat, natural gas: technology available in mid 1990s.

conditions

Heat, light fuel: assumption for operation in Switzerland

Heat, natural gas: extrapolation from Switzerland to Europe

Heat, light fuel: 2000

Heat, natural gas: 1990-2000
















Transport by car (vkm)

Operational, passenger, car, diesel, fleet average2010, RER, ecoinvent

Diesel engine including various emissions standards

Data refers to European conditions

2010

Transport by public transport (pkm)

Transport, regular bus, CH, ecoinvent

Diesel, various emission treatment standards

The data for vehicle operation and infrastructure reflect Swiss conditions> Data for vehicle manufacturing and maintenance represents generic European data> Data for the vehicle disposal reflect the Swiss situation<

2005

Transport by van delivery (vkm)

Operation, van < 3,5t, RER, ecoinvent

Diesel and petrol cars Data refers to European conditions

2005








Electricity, hydropower, at power plant.






Water (kg) * Tap water, at user, RER, ecoinvent

Example of water works in CH Infrastructure data for CH> Energy use in DE.

2000 (time of publication)




-

Cardboard end-of-life (kg)

Cardboard end-of-life LCI (built according to section VI.8.2)



- corrugated board base paper, Wellenstof, FEFCO 2009 ecoinvent

Municipal incineration: average Swiss MSWI plants in 2000 with electrostatic precipitator for fly ash (ESP), wet flue gas scrubber and 29,4% SNCR, 32,2% SCR-high dust, 24,6% SCR-low dust- DNox facilities and 13,8% without DeNox (by burnt waste, according to Swiss average. Share of waste incinerated in plants with magnetic scrap separation from slag: 50% Gross electric efficiency technology mix 12,997% and Gross thermal efficiency technology mix 25,57%.

Sanitary landfill: Swiss municipal sanitary landfill for biogenic or untreated municipal waste. Landfill gas and leachate collection system. Recultivation and monitoring for 150 years

Municipal incineration: specific to the technology mix encountered in Swiss in 2000. Well applicable to modern incineration practices in Europe.

Sanitary landfill: technology encountered in Switzerland in 2000. Landfill includes base seal, leachate system, treatment of leachate in municipal wastewater treatment plant

Municipal incineration: waste composition as given in literature reference, theoretical data or other source. Transfer coefficients for modern Swiss MSWI. Emission speciation based on early 90s data.

Sanitary landfill: no info.





after closure.





Municipal incineration: cf. above

Sanitary landfill: cf. above

Alkylbenzene: average technology, typical for European production conditions in the mids 90s.



Alkylbenzene: data based on the European LAB production



Alkylbenzene: 1995 (date of published literature)


- disposal, polypropylene, 15.9% water, to municipal incineration, CH, ecoinvent





Alkylbenzene: cf. above







Wood end-of-life (kg)

Wood end-of-life LCI (built according to section VI.8.2)


- disposal, wood untreated, 20% water,



Particle board: average German technology (1996)



Particle board: data for Germany used for central Europe



Particle board: 1996-2000





to sanitary landfill, CH




XIII.10. EoL formulas

Wastewater treatment The Table XIII-16presents the share of household connected to at least secondary wastewater treatment (source Eurostat – Energy, transport and environment indicators- Edition 2014 - Table 4.6.6, p234)

Table XIII-16: Share of household connected to WWT by country in EU28+EFTA (Source Eurostat)

Country More recent percentage on the period 2000-2010

Related year

BE-Belgium 72% 2009

BG- Bulgaria 53% 2011

CZ-Czech Republic 78% 2011

DK-Denmark 88% 2010

DE-Germany 81% 2010

EE-Estonia 81% 2011

IE-Ireland 62% 2011

EL - Greece 88% 2011

ES-Spain 93% 2010

FR- France 80% 2005

HR- Croatia 27% 2011

IT-Italy 94% 2005

CY-Cyprus 30% 2005

LV-Latvia 63% 2007

LT-Lithuania 65% 2011

LU-Luxembourg 91% 2011

HU- Hungary 71% 2011

MT- Malta 100% 2011

NL- Netherlands 99% 2010

AT-Austria 94% 2010

PL-Poland 65% 2011

PT-Portugal 55% 2009

RO- Romania 31% 2011

SI- Slovenia 56% 2011

SK-Slovakia no data

FI- Finland 83% 2011

SE-Sweden 87% 2010

UK-United Kingdom 100% 2010

IS-Iceland 2% 2005

LI-Lichtenstein No data

NO-Norway 62% 2011



CH-Switzerland 98% 2010

Based on the above data, the European +EFTA average weighted by population is 91.6%

of households connected to a wastewater treatment system: individual or collective

XIII.11. Background information on methodological choices taken during the development of the PEFCR

XIII.11.1. Energy mix

As indicated in the section VI.4.1, the most updated data from the IEA shall be used.

As a reminder, the energy mixes considered for the screening study as well as the supporting studies were those related to 2012 and provide by Eurostat in 2015:

Table XIII-17: electricity consumption mixes and industrial heat mixes (2012)

Electricity consumption mixes industrial heat mixes

Country El‐Coal El‐Oil

El‐Gas

combust El‐Nuclear

El‐

Hydroel El‐Wind heat‐Coal heat‐Gas heat‐Oil

Austria 0.212 0.009 0.118 0.077 0.474 0.110 0.077 0.801 0.122

Belgium 0.082 0.005 0.300 0.473 0.031 0.109 0.000 0.960 0.040

Bulgaria 0.470 0.005 0.058 0.328 0.089 0.050 0.442 0.470 0.088

Cyprus 0.000 0.946 0.000 0.000 0.000 0.054 0.020 0.956 0.024

Czech Republic 0.578 0.003 0.020 0.294 0.031 0.074 0.733 0.256 0.011

Denmark 0.222 0.009 0.089 0.105 0.271 0.304 0.478 0.486 0.036

Estonia 0.648 0.004 0.061 0.055 0.111 0.121 0.336 0.597 0.067

Finland 0.140 0.005 0.101 0.331 0.277 0.146 0.560 0.351 0.089

France 0.041 0.008 0.043 0.750 0.116 0.042 0.088 0.792 0.120

Germany 0.446 0.012 0.122 0.175 0.060 0.185 0.415 0.566 0.019

Greece 0.509 0.091 0.216 0.012 0.083 0.089 0.981 0.000 0.019

Hungary 0.192 0.008 0.205 0.451 0.086 0.058 0.149 0.846 0.005

Ireland 0.298 0.009 0.493 0.005 0.037 0.158 0.404 0.527 0.069

Italy 0.169 0.057 0.386 0.060 0.183 0.145 0.027 0.719 0.254

Latvia 0.167 0.012 0.241 0.154 0.328 0.098 0.015 0.965 0.020

Lithuania 0.184 0.028 0.314 0.170 0.175 0.129 0.006 0.858 0.136

Luxembourg 0.343 0.009 0.225 0.181 0.082 0.160 0.000 0.996 0.004

Malta 0.000 0.993 0.000 0.000 0.000 0.007 0.404 0.527 0.069



Electricity consumption mixes industrial heat mixes

Country El‐Coal El‐Oil

El‐Gas

combust El‐Nuclear

El‐

Hydroel El‐Wind heat‐Coal heat‐Gas heat‐Oil

Netherlands 0.294 0.011 0.449 0.075 0.056 0.115 0.049 0.901 0.050

Poland 0.811 0.012 0.042 0.016 0.024 0.095 0.896 0.074 0.030

Portugal 0.265 0.048 0.235 0.041 0.132 0.279 0.000 0.901 0.099

Romania 0.380 0.013 0.150 0.198 0.206 0.053 0.297 0.610 0.093

Slovakia 0.359 0.011 0.063 0.410 0.097 0.060 0.268 0.587 0.145

Slovenia 0.230 0.014 0.106 0.175 0.421 0.054 0.637 0.338 0.025

Spain 0.188 0.051 0.244 0.215 0.083 0.219 0.404 0.527 0.069

Sweden 0.012 0.004 0.008 0.361 0.510 0.105 0.491 0.311 0.198

United

Kingdom 0.392 0.009 0.278 0.205 0.024 0.092 0.181 0.788 0.031

USA 0.381 0.008 0.294 0.187 0.077 0.053 0.148 0.764 0.088

Europe 0.267 0.018 0.187 0.245 0.166 0.117 0.404 0.527 0.069

Iceland 0.000 0.000 0.000 0.000 0.703 0.297 0.404 0.527 0.069

Liechtenstein 0.267 0.018 0.187 0.245 0.166 0.117 0.404 0.527 0.069

Norway 0.004 0.000 0.019 0.010 0.949 0.018 0.064 0.153 0.783

Switzerland 0.108 0.006 0.058 0.341 0.424 0.063 0.000 0.892 0.108

(source IEA 2015 publication)

XIII.11.2. Background information on the emissions/losses of detergent manufacturing plant

This annex was developed in order to evaluate the maximum burden of emissions/losses at detergent manufacturing plant on the full environmental performance of a HDLLD product and justify the choice made to exclude them in the related PEFCR. The source of information considered is the “A.I.S.E. SPERC fact sheet - Industrial use in formulation of liquid cleaning and maintenance products”89. The Specific Environmental Release Categories (SPERCs) are sets of sector-specific environmental release values compiled by industry sector groups or trade associations to help registrants develop the exposure scenarios needed for their registration dossiers in the REACH context. The concept of SPERCs is in line with ECHA's Guidance on Information

89 Source : http://www.aise.eu/our-activities/product-safety-and-innovation/reach/environmental-exposure-assessment.aspx



Requirements/Chemical Safety Assessment. Additional information on the concepts and use of SPERCs are described in a guidance document issued by CEFIC (2012) (Cefic Guidance - Specific Environmental Release Categories (SPERCs) Chemical Safety Assessments, Supply Chain Communication and Downstream User Compliance)90.

Specifically for cleaning (and some cosmetic products like shampoos), a series of SPERCS were developed by a team of environmental and process experts of the detergents industry under the umbrella of AISE and CEFIC. The work was built on an existing study by Royal Haskoning et al. (2009), complemented with information from companies not involved with the Haskoning report. Since there was need to have reasonable estimates of process emissions for production plants of different sizes, for liquids as well as more gel – or creamlike products, as series of ‘subspercs’ were developed.

SPERC values correspond to levels of substances released into the environment during the whole formulation process (this includes storing, mixing, packaging of substances (as part of mixtures) and equipment cleaning, maintenance and associated laboratory activities). SPERCS include the usual onsite Risk management Measures (RMMs), but normally exclude the stage of the on-site or municipal wastewater treatment plant.

The SPERC values depends on several factors such as the viscosity of products (high or low) as well as the scale of the manufacturing site (small scale site for annual production <1000 tons of finished products, medium for annual production below 10000 tons and large scale for production> 10 000 tons).

Liquid detergents are high viscosity products and can be produced in formulation site of any scale.

According to the fact sheet, losses from the processes constitute losses of raw materials, which, at least for economic reasons, have to be avoided. Formulation of preparations requires optimized use of raw materials for inclusion into products.

Significant losses to the environment can be the result of cleaning of mixing vessels, tubing, production/packaging lines. High viscosity products adhere more strongly to the walls of mixing vessels, tubing, production/packaging lines. They are less efficiently transferred into the packaging. Hence, emissions caused by equipment cleaning are higher. These losses occur irrespectively of the physical-chemical properties of the detergent ingredient substances. The release to the wastewater is between 0,001 and 0,004 kg of product for 1 kg of finished product. Losses of raw materials via volatilization are negligible as compared to the previous losses.

There is no other significant chemical release, neither to air, nor to soil or waste (in these industries solid chemical waste (if any) is usually incinerated by professional waste handling companies).

Based on such information, we can conclude that even with the more conservative estimations less than 0.4% of the chemicals in the life cycle of detergents are associated with the manufacturing stage, which is negligible versus the 99.6% (or above) emitted to the environment ( at the end of life via wastewater treatment).

90 Source : http://www.cefic.org/Documents/IndustrySupport/REACH-Implementation/Guidance-and-Tools/SPERCs-Specific-Envirnonmental-Release-Classes.pdf



In that context, the releases at the manufacturing site over the life cycle of a HDLLD product can be neglected (as compared to the end of life phase) and therefore excluded for any PEF study related to these HDLLD products.

XIII.11.3. Wash Energy Consumption –Temperature Relationship

This annex was developed for A.I.S.E. by Diederik Schowanek and Itziar Urdiales (P&G), with input from Erika Martinez (Henkel) and Henry King (Unilever).

In the context of the A.I.S.E. Pilot Project on Product Environmental Footprint Category Rules (PEFCR) on Heavy Duty Laundry Liquid Detergents (HDLLD), A.I.S.E. was looking for a reference agreed model/equation that connects wash temperature (in range of ~15-90 degrees C) with the total energy used in an automatic laundry wash ‘standard’ cycle. For the PEFCR, and in line with the EU Detergents Directive, a standard wash is defined as a 4.5 kg medium soiled laundry and medium water hardness, used in a 6 kg washing machine. The machine is assumed to use 50 l water per wash.

The electricity consumption is described by the following general formula:

Electric consumption (kWh)= b[0]+ b[1]* washing temperature (°C)

From the literature and industry reports several options for this equation were identified. Finally, a model was selected that is described here as the A.I.S.E. Laundry Energy Model 2014. The other options are also described in this document.

1. A.I.S.E. Laundry Energy Model 2014

with :

b[0]= - 0.1342

b[1] = 0.0193

The equation is based on fundamental thermodynamic principles. In this assessment, the sum is made of the mechanical energy for a wash (drum rotation, spinning) plus the amount of energy consumed in the water heating cycle, as a function of temperature. The efficiency of the washing machine is neglected. Other parameters required for the calculation are:

‐ The amount of water assumed to be heated is 21 l/wash ‐ The average seasonal inlet water temperature91 for a series of countries

(average = 12.98 degrees C) ‐ Tthe specific heat capacity of water.

The motor baseline energy requirement (0.105 kWh) is derived from household monitoring data in the SAVE 2002 study (Commission of the European Communities

91 Average seasonal inlet temperature, measured in a P&G study (Mercury Panel, AIT 2006)



report,: Demand Side Management, End-use metering campaign in the Residential Sector, Final Report 2002 – Table 5.3). Table XIII-18 presents the energy consumption as a function of the according to the wash temperature for a volume of 21 litres92 of water (water heated from inlet temperature to the desired temperature).

Table XIII-18: Energy consumption at different temperatures per country and an average

kWh/wash Germany France UK Italy Spain Average

Aver inlet temperature 12.4 13.9 10.2 14.675 13.725 12.98

cold 0.1050 0.1050 0.1050 0.1050 0.1050 0.1050

30 0.4406 0.4030 0.4957 0.3836 0.4074 0.4261

40 0.6909 0.6534 0.7460 0.6340 0.6578 0.6764

60 1.0409 1.0081 1.0891 0.9912 1.0120 1.0283

90 1.6048 1.5738 1.6503 1.5577 1.5774 1.5928

A linear regression was taken on the data in the last column from Table 1, leads to the equation:

E= - 0.1342 + 0.0193T

Where E is the energy requirement in kWh and T the temperature in degrees C.

This equation can be corrected eventually over time if the mechanical energy per wash would decrease due to technical improvements, or if less than 21 l water would be heated per wash.

2. Alternative Approaches

a. Stamminger Model 2004

This is based on the following reference: Energy Efficiency Potential of Temperature and Load Reduction in Automatic Laundry Washing Processes; Rainer Stamminger – report prepared for A.I.S.E, 2013). The results of Stamminger report represent 23 EU countries and are calculated for a range of temperature between 30-90 °C.

92 Different from the 50 litres of water use of a washing machine. The 50 litres also takes into account the unheated water (i.e. rinse etc)



The total resource use for a washing machine R in a consumer environment is calculated in a simplified approach to be approximately given by:

WWW effRnR

where nw = number of wash cycles per household per year Rw = average resource consumption per washing machine (for energy: Rw = 0.0213x – 0.3019 with x as the average wash temperature for water: Rw = 50 litres) effw = efficiency correction factor depending on the age of the washing machine The energy consumption of a single wash cycle (Stamminger, 2005):

E = (0.0213T – 0.3019) * 1.05 kWh = -0.317 + 0.0224T where T is the average temperature and 1.05 kWh is the average energy consumption of the 60 °C wash program for washing machines offered on the European market in 2008. It should be noted that the Rw factor is based on measurements in the market with consumers. The Stamminger 2004 approach was not selected for the A.I.S.E PEFCR Report as the model does not provide validated data below 30 degrees C (most machines in 2004 did not provide this option). However, this is the range in which the future technological developments will take place.

b. Approach by Oeko Institut (2005)

This is based on the following Reference (suggested by CECED): Eco-Efficiency Analysis of Washing machines– Life Cycle Assessment and determination of optimal life span – Rüdenauer et Gensch, 2005. The energy and water demand figures are mainly based on Stamminger (2004a) and Miele (2005), considering data from NEI (2001), NEI (2004), StiWa (2004), Schlohmann et al. (2001). The data is partly measured, partly taken from published consumption figures and partly extrapolated. In this study the energy and water consumption represent an average machines with a medium price segment and average design in Germany in the year 2004. The specific energy (kwh/kg) and water (l/kg) consumption of large washing machines in 2004 is given per kg of load. The assumption is a load machine 5 kg and water consumption approx. 50 l (9.7 l per kg) and the amount of energy to heat the water is based on thermodynamic principles. The energy consumption is estimated for a range of temperatures between 30-90 °C and the data leads to the following equation:

E = -0.2774 + 0.021T where T is the temperature (°C) and E the energy consumption (Kwh)



If we considere 4.5 kg of laundry, the functional unit of the PEF or the total capacity machine of 6 kg, the linear regression will vary because the water consumption becomes 43.65 l and 58.2 l, respectively.

4.5 kg →E = –0.2492 + 0.0189T 6 kg → E = -0.3786 + 0.025T –

Comparison of Results Overall, the different studies and approaches lead to similar results (Figure XIII-1). In the most common wash temperature zone of 40 to 60 degrees C, the results are very close. It can be observed that the equations that have been initially derived for the range 30-90 degrees (i.e. Stamminger 2004 and Oko Institut 2005) cross the X-axis between 10 and 20 degrees. This would mean that the extrapolated wash energy requirement at the background tap water temperature is unrealistically low. For this reason, the approach followed in the A.I.S.E Laundry Energy Model 2014 was finally preferred for use in the PEF project, also given that low temperature washing will be more common in the future.

Figure XIII-1: Graphical comparison of the different wash temperature – energy relationships



XIII.12. Review of the existing studies and Analysis of Consistencies and differences between existing PCRS and the PEF Guide

This annex presents a review of the existing studies. Each idea or comment is followed by the title of those studies which illustrate that idea (titles are indicated in brackets). The list of the existing PCRs and studies is presented in chapter XI.

Differences with the PEFCR guidance are explicitly mentioned.

Description of the Product Category and Product definition The existing LCA studies consider a range of laundry detergents, including liquid and powder formats.

As far as liquid laundry detergents are concerned, distinction is made between heavy‐duty laundry detergents, colour‐safe laundry detergents and low‐duty laundry detergents. (EU Ecolabel for laundry detergents, Nordic Ecolabel).

All kind of formats are considered (concentrated, ultra‐concentrated, tab, unitdose, etc.).

In all the reviewed studies the following products are excluded: hand‐washing detergents, products dosed by carriers (sheet, clothes), 2 in 1 products and products for professional purposes. Pre‐treatment products are covered in some of the studies (EU Ecolabel for laundry detergents). In most of the cases, primary and secondary packaging is considered.

Reference to the PEF guide

Tertiary packaging will be considered in the PEFCR drafting.

The International EPD System PCR uses the United Nations classification (UN CPC) and covers the whole subclass 35322 – Detergents and washing preparations. The BPX 30‐323‐2 French Labelling PCR also covers all kind of formats (liquid, powdered, concentrated, unitdose) without any reference to a specific classification.

The A.I.S.E. Charter for Sustainable Cleaning ASP documentation for liquid laundry detergents includes unit‐dose whereas the Japanese PCR only focuses on powder laundry detergents.

Unit of analysis and reference flow definition

Several “units of analysis” (functional units) have been observed among the reviewed LCA studies:

one average home laundry wash in a specific country (Ariel study) one wash in an average Chinese washing machine (Compact detergents in

China study) a single laundry cycle (BPX 30‐323‐2 French labelling PCR)



one sold unit (International EPD system PCR Detergent and washing preparation)washing and drying on large load of laundry (TSC PCLCA, Australian City West study)

The performance of the laundry detergent is treated in different manners. For instance the EU Ecolabel for laundry detergents requires compliance with criteria of good performance at low temperature while the Nordic Ecolabel standard requires the evaluation of the performance through a specific calculation including the cleaning effect and secondary effects (e.g. greying encrustation, chemical wear).

PCRs are more enclined to define the Unit of analysis (functional unit) for an average performance defined at European level (648/2004/CE regulation for product labelling: e.g. “the standard washing machine loads are 4,5 kg dry fabric for heavy‐duty detergents and 2,5 kg dry fabric for low‐duty detergents”) (BPX 30‐323‐2 French labelling PCR and A.I.S.E. Charter).

As for the definition of the reference flow, the dosage is mainly based on recommended information provided on packaging by the manufacturer.

Bills of materials The bill of materials is included in some of the LCA studies (comparative LCA of laundry detergents formulation in the UK part 1 and 2, P&G). In case of non‐accessible site information, bibliographical data are used. Each ingredient is clearly identified and no grouping of substances is made (ex: surfactants, enzymes, inorganic compounds, etc.).

The Nordic Ecolabel assesses the traceability of vegetable raw material and resource depletion.

PCRs can include specific requirements with regard to the bill of materials/formulation, such as:

specific environmental and safety criteria (A.I.S.E. Charter: all ingredients must pass successfully an ‘Environmental Safety Check’),

a high level of quality and representativeness (the BPX 30‐323‐2 French labelling PCR requires that ingredients and primary material being collected directly from and all formulation sites, in order to consider the electrical mix from each formulation site),

specific cut off and inclusion of all hazardous substances (e.g. The International EPD system PCR: cut‐off of 99% of those substances at manufacturing processes as well as in the upstream process).


Cut off is not foreseen in the PEF guide. Whereas it is foreseen that weighting of products will be based on market volume

(in tonnes) in order to calculate averages, according to the PEF guide the weighting is based on sales market shares.

The other elements are consistent with the PEF guide.

Define life cycle stages All studies and PCRs consider a Cradle to Grave approach or scope, since previous experience in LCA on detergents have shown that the use phase is the most relevant with regard to environmental impacts. As for the end of life phase, packaging disposal



has been excluded in some studies, whereas wastewater treatment has always been considered.

System boundary and flow diagram The most common steps considered are:

ingredients manufacturing, packaging, formulation, use, end of life and disposal of packaging.

Description of technologies used in each relevant life cycle stage. Analysis based on market share

Technologies are rarely described (consideration of evolution of technologies in P&G studies, short description on TSC PCLCA) since detergent production technologies seem to be common to all manufacturers.

At the ingredients’ manufacturing step, a mass allocation is being recommended when data can be provided by specific production sites (BPX 30‐323‐2 French labelling). However, in most of the studies, bibliographic data sources are considered since data collection would be too complex. In cases where the application of several technologies is possible for the downstream processes, PCRs require that the chosen scenarios reflect the situation occurring under realistic scenarios (The International EPD system PCR).


This is consistent with PEF guide.

At the detergent manufacturing (or preparation) stage, no allocation is required since the manufacturing of laundry detergents does not generate any co‐product or by‐product. At this specific step within the life cycle, cut off criteria in volume is allowed in most of the studies, except on hazardous and registered substances.


Cut off is not included in the PEF guide.

Uncertainties Uncertainty is considered at two levels: the composition of the ingredients (with different

values linked to different manufacturers) and the laundry detergent dosage (variability due to the users).

Assumptions on transport Some transport steps such as the transport of ingredients/packaging to the detergent production site and the shopping tour are excluded in most studies (only considered in TSC PCLCA).


All transport is included in the PEF guide.



Different levels of assumptions can be made according to the transport, their contribution to the whole life cycle impacts and the availability of data: The International EPD system PCR for instance requires primary data (distance, transport mean and vehicle load) for upstream transport from chemical suppliers to the formulation site, but considers a fixed distance of 100 km by lorry fleet average (20‐28 t) for the transport of the packaged product to consumers. On the contrary, the BPX 30‐323‐2 requires the same nature of data for all logistics steps (transport mean and average distance) but asks for more representative data for upstream stem (from formulation to sales location) when available.


This is consistent with the PEF guide.

Assumptions on distribution For distribution, the studies include either one distribution route (P&G studies), or a selection of routes representing the actual situation (TSC PCLLCA) or a distance by default.

Assumption on storage Storage is rarely considered due to its insignificance within the whole life cycle (included only in TSC PCLCA). Assumption related to the use scenario Among the reviewed studies, the considered use scenario is either based on average use (e.g. a typical wash load of 4,5 kg of normal soiled textile, washed in water in medium water hardness (18‐28 CacO3/l)) (A.I.S.E. Charter, P&G studies, BPX 30‐323‐2 French Labelling PCR) or a range of different use scenarios is been taken into account (Henkel study).


This is consistent with the PEF guide.

Regarding the washing machine, only non‐European studies consider several kinds of washing machines, which differ in energy and water consumption (e.g. front‐loading vs toploading, v‐axis and h‐axis). (TSC PCLCA, Korean Ecolabel, Australian City West study).

As for the energy mix consumed by the laundry machine, the use of the OECD electricity mix is sometimes recommended (International EPD system PCR).

Reference to the PEFCR

The European average will be recommended when drafting the PEFCR, based on the reference product.

Some studies also consider statistics on individual habits (e.g. evolution of per capital use; habits of the 5 biggest European countries – P&G studies).

Assumption related to End of Life (EoL) Among the reviewed studies, two main approaches are considered for the end of life of laundry detergents and more specific for wastewater treatment:



an average scenario with a municipal wastewater treatment and the use of generic data (P&G studies, TSC PCLCA, BPX 30‐323‐2 French labelling PCR);

specific scenarios with a specific focus on toxicity to aquatic organisms and biodegradability of ingredients (A.I.S.E. Charter 2010 ASP through Environmental Safety Check (ESC) criteria), and forbidden substances, plus the calculation of a critical dilution volume (EU Ecolabel for laundry detergents, Korean Ecolabel, Chinese study).

The disposal of packaging is sometimes included (excluded in P&G studies) and if so, the benefit of energy recovery in case of incineration is considered (Henkel study).

Moreover some PCRs give specific calculation rules for the recycling and recovery impact and benefits (French BPX 30‐323‐2).


The recommendations provided in the PEF guide regarding EoL differ from the French PCR.

Other standards consider eco‐design of packaging (weight and recyclability criteria) (EU Ecolabel for laundry detergents, A.I.S.E. Charter 2010 ASP).



XIII.12.1. Analysis and comparison of USEtox/ESC evaluation

(This analysis was done in the context of the PEF Screening and was included in the PEF Screening Report as endorsed by the EF Steering Committee in July 2015).

As required by the PEF methodology, the A.I.S.E. PEF TS has applied USEtox to evaluate the ecotoxicological profile of the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’. It appeared that USEtox results for the HDLLD are highly influenced by data availability, data quality and data selection principles. The A.I.S.E. PEF TS believes that the USEtox tool in its present form and with the currently available CF datasets, is not fit for use to make scientifically accurate, validated and environmentally meaningful differentiation between detergent products. An alternative methodology, the A.I.S.E. risk-based ‘Environmental Safety Check’ (ESC) method has been proposed and tested. The ESC model is operational and ready for use to evaluate the environmental (aquatic) risk of detergent products but it is not suitable in its present form for the purpose of product ranking or comparison.

This assessment has shown substantial differences between the USEtox and the ESC evaluations. The ESC analysis indicates that the ‘2013 HDLLD reference product’ is environmentally safe. In light of the above findings and due to the critical importance of ecotoxicity as one of the key environmental impact for detergents, the detergent industry is keen to progress this topic further with a view to find, in a constructive, scientific and transparent way with all concerned stakeholders the relevant method that will diminish/prevent impacts on the environment whether through USEtox, ESC or alternative models.

In the meantime, the PEF TS will continue to assess these methods in the context of the PEF pilot.

1. Background & Basic Principles of detergent ecotoxicological impact evaluation

Since cleaning products are released to the aquatic environment after their use in consumer homes, it is important to ensure that their use is environmentally safe. While efforts to improve their sustainability and environmental safety have made great strides, additional work continues, such as through environmental risk assessment of detergent ingredients in formal frameworks such as REACH, as well as through voluntary initiatives such as HERA93 , A.I.S.E. Charter for Sustainable Cleaning, other tools used for ecolabels, and manufacturers’ internal safety assurance procedures.

In the context of programmes to improve the overall sustainability for detergents and cleaning products, stakeholders demand environmental safety assurance and progress at product level. Several of the available product-level approaches (e.g. USEtox, CDV - Critical Dilution Volume) deal with aquatic environmental safety mainly in terms of hazard. The scientific position of A.I.S.E. regarding safety reassurance is to do so via risk-based approaches because ecotoxicological effects are generally threshold-dependent and risk assessments will take into account the actual product quantities used in the European market. A detergent ingredient will have no adverse environmental

93 Human and Environmental Risk Assessment on ingredients of household cleaning products



effect when real-world exposure levels are below the concentrations at which adverse effects can start to occur. This position is supported by the majority of A.I.S.E. members but may not reflect all industry members’ views.

For this purpose, A.I.S.E. has developed a risk-based approach through the A.I.S.E. Charter ‘Environmental Safety Check’ (ESC), to assess formulated detergent and cleaning products. This tool is consistent with the scientific risk assessment principles underlying REACH.

Implementation of a simple risk-based screening ESC check to provide reassurance on aquatic environmental safety for specific product formulations has been shown feasible. The ESC tool is currently in use to qualify brands for the Advanced Sustainability Profile criteria (ASP) of the A.I.S.E. Charter for Sustainable Cleaning. The ASP criteria and the use of the ESC tool for HDLLD products is described in the study “Advanced Sustainability Profiles for Household Liquid Laundry Detergents, 10 February 2011”94.

The ESC-tool and relevant information is publicly available (A.I.S.E. Charter website: www.sustainable-cleaning.com). A.I.S.E. is currently preparing a scientific publication with a detailed description of the ESC methodology.

2. Analysis of USEtox findings for ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’

The USEtox findings for the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ are reported above. That evaluation used the USEtox ecotoxicity for aquatic fresh water CFs for several of the HDLLD ingredients as they have been updated recently by A.I.S.E. and PEF TS company experts. They have calculated a series of new USEtox CFs for ingredients for which no CFs were available and they have also recalculated/revalidated all CFs for HDLLD ingredients for which CFs have been reported before. Since only a limited number of HDLLD ingredients needed to be calculated for the A.I.S.E. PEF pilot project, it was possible to do this with a high level of accuracy based on consistent principles, and aiming for the most reliable and industry-agreed input data. Additional evaluations were made with the CF factors in the Cosmede database, generally considered to be one of the most updated USEtox database for detergents and cosmetics.

The CF values show the substantial differences between the CFs in the Cosmede database and those provided by A.I.S.E. These are the result of differences in data quality and in the applied data selection procedures.

Initial trials with the A.I.S.E. CF data set showed that fragrances had the highest contribution to the CTUe scores. For this reason, 3 relatively similar HDLLD compositions were tested in which the fragrance level and composition was varied. A ‘fragrance prototype’ was defined, containing 8 common fragrance ingredients and dipropylene glycol as solvent. The composition of the fragrance prototype was varied. A first variation ‘fragrance prototype’ contained a 4x reduced active level for each of the 8 fragrance

94 www.sustainable-cleaning.com/content_attachments/documents/ASPsLLDCharterupdate2010products10February2011.pdf



ingredients (4x lower active level; higher solvent level). In a third variant, the ratio and levels of 4 individual fragrance ingredients were changed.

These fragrance prototypes have been operationally defined and should not be considered as market-representative. They were developed for the purpose of testing various scenarios with the overall objective to better understand what ingredient-related factors drive the USEtox CTUe scores. The results are reported in Figure XIII-2.

Figure XIII-2: USEtox scenarios for HDLLD using different CF data sets and HDLLD compositions

The first evaluation using the HDLLD composition with the standard fragrance prototype and the A.I.S.E. CF data set (‘HDLLD with Prototype Fragrance; A.I.S.E CF data set’) had a total CTUe score of 28.8, with a contribution of around 92% from the fragrance prototype ingredients and about 8% from all other HDLLD ingredients.

The same product was tested with the Cosmede CF data set (‘HDLLD with Prototype Fragrance; COSMEDE CF‘) and this showed a very different result: The total CTUe score was reduced considerably (15.2 CTUe). The fragrance prototype ingredients contributed around 6% to this total CTUe score, while the other ingredients contributed around 94%. When the USEtox method was applied with the Cosmede database, the preservative had a relatively high contribution to the USEtox score (approx. 21%).

The 3rd evaluation using the HDLLD composition with the reduced level of fragrance actives (‘HDLLD with Prototype Fragrance (reduced actives); A.I.S.E CF’) showed a significantly lower total CTUe score with a 74% contribution from the fragrance prototype ingredients.

The 4th evaluation using the HDLLD composition with the changed levels of individual fragrance actives (‘HDLLD with Prototype Fragrance (Varied Actives); A.I.S.E CF data set’) showed the highest total CTUe score (28.6 CTUe), with a 94% contribution from the fragrance prototype ingredients.



The observed data sensitivity of the USEtox assessment is in line with the findings described in the literature95. The authors reported a different contribution of fragrances as the result of differences in fragrance composition and selection procedures for the determination of USEtox CFs for fragrance ingredients. This confirms the sensitivity of the method to such choices and specifically to data availability, data quality and data selection principles.

An additional observation about the USEtox approach is that the characterization factors for chemicals have a very wide range, typically 2-3 orders of magnitude in difference. This can skew the obtained results when these CF are used for comparative evaluations. The relevance of the differences both for comparisons of chemicals as well as for product comparisons need to be better understood. While the data-related safety factors in risk assessments can span 2-3 orders of magnitudes, these uncertainties are fully taken into account in the calculated risk quotients. This is a substantial difference with USEtox evaluations where the uncertainty of 2-3 orders of magnitude is not reflected in the CTUe scores.

The outcome of USEtox assessments is very sensitive to a number of factors including the quality of the life cycle inventories (i.e. the named chemical emissions and their quantities) and the calculated characterisation factors for the specific chemicals. Understanding the drivers of the differences and uncertainties around the characterisation factors is very important since the current use of USEtox would indicate that fragrances are the single most important ingredient class which defines the ecotoxicity profile of the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’. It is generally accepted that other ingredients such as surfactants, solvents, builders, sequestrants and other ingredients also contribute to the environmental loading and impact of detergents. The A.I.S.E. PEF TS feels that the assessment of the ecotoxicity impact of detergents should not be limited or simplified to an assessment of single ingredient classes and will investigate this in detail.

Overall, this analysis shows that the USEtox method is highly sensitive to the selected database and the quality of the data from which the CFs are derived. Further work is planned by A.I.S.E. to understand how the database and calculation models can be improved to address this.

3. ESC Check - Methodology, Assumptions, Tool

The ESC-check is implemented through a user-friendly spreadsheet tool which uses an internal database of key ingredient parameters including predicted no-effect concentration (PNEC) and removal rate. The ESC tool includes market volume information for product types and ingredients in order to run a risk-based calculation. Conservative projections include the assumption of a 100% market share for the studied product and a factor-based approach to provide a conservative estimate of background ingredient concentrations which might arise from other uses, both within the detergent sector as well as in other industries. The ESC tool performs calculations based on the core concept of risk assessment: it conservatively projects Predicted Environmental Concentrations (=PEC) for the environment and compares these to relevant Predicted No Effect Concentrations (=PNEC). The result is expressed as a Projected Environmental 95 Vanhoof et al, Ecotoxicity impact assessment of laundry products: a comparison of USEtox and critical dilution volume approaches. Int. J. Life Cycle Assessment, 2011)



Safety Ratio (PEC/PNEC = PESR). In order to pass the ESC check, the Projected Environmental Safety Ratio (PESR) for each ingredient as formulated and dosed must be less than 1. This corresponds to the PEC/PNEC < 1 criterion which is the basis for concluding no significant risk of adverse effects in the REACH legislation.

Practically, the ESC Tool directly assigns a clear result “HERA OK” for ingredients for which detailed and peer reviewed96 published scientific risk assessments are available from the A.I.S.E./CEFIC Human and Environmental Risk Assessment programme (HERA, www.heraproject.com) and whose margin of safety is considered satisfactory on the basis of the conducted risk assessments. In the ESC assessment, these ‘HERA OK’ ingredients are considered to be environmentally safe on the basis of their margins of safety as reported in the HERA risk reports for each substance.

A range of non-hazardous substances are considered ‘exempt’ from the ESC check in line with REACH articles 2(a) and 2(b). These substances are considered to cause minimum risk because of their intrinsic properties and especially their use in detergents clearly poses no risk to the aquatic environment when disposed via sewage treatment.

Fragrances have a complex composition and common business practice is to treat the composition confidentially. The ESC assessment will require an assessment at the level of individual ingredients, which cannot be done for the complex and confidential fragrance mixtures. To address this, the ESC tool exempts fragrances as long as these are covered by the IFRA Code of Practice and standards. For commercial fragrance mixtures which are not covered by the IFRA Code of Practice and standards (www.ifraorg.org/en-us/code-of-practice), the ESC tool must be applied to perform calculations of the Projected Environmental Safety Ratio (PEC/PNEC=PESR) for each fragrance ingredient, similar to what is described below.

IFRA (International Fragrance Association) and RIFM (the industry’s scientific centre - Research Institute for Fragrance Materials) have implemented a worldwide IFRA Code of Practice and safety standards with the final objective of protecting the consumer and the environment. The IFRA Code of Practice is a comprehensive document that supports the IFRA commitment to provide products that are safe for use by the consumer and to the environment. Perfumes are created by a variety of specialist companies, often referred to as Fragrance Houses. Within the Fragrance Houses, experts in toxicology, ecotoxicology and risk assessment evaluate new and existing raw materials for safety and help to develop fragrances which can be used safely in a variety of consumer products by their business customers. The formulators’ experts use state-of-the-art approaches in risk assessment and risk characterization to ensure that the raw materials and perfumes meet safety standards and regulatory compliance. IFRA endeavors to ensure that usage standards are put into practice according to the available scientific recommendations and requires members to abide by the Code of Practice. IFRA Standards form the basis for the globally accepted and recognized risk management system for the safe use of fragrance ingredients. Manufacturers of detergent and cleaning products ensure that their fragrances will meet the Code requirements.

For all other ingredients, the tool performs calculations based on the core concept of aquatic risk assessment: it conservatively projects Predicted Environmental Concentrations (PEC) that could arise in the aquatic environment and compares these to relevant Predicted No Effect Concentrations (PNEC). The result is expressed as a

96 conducted according to standards similar to those set out in the EU Technical Guidance Document / REACH



Projected Environmental Safety Ratio (PEC/PNEC=PESR). In the concept of this risk-based safety evaluation, a PESR<1 is seen as demonstrating that the substance as used in the product is safe for the environment. Because the PESR calculation projects quite conservative tonnage estimations as the basis for the PEC, the PESR estimation is conservative. Therefore, a PESR>1 does not necessarily mean there is a risk for the environment, since more refined risk assessment based on better data could show no risk for an ingredient. On the other hand, a PESR<1 provides reassurance that the product is having an enhanced safety profile. Thus, ESC results is reflecting safety of ingredient in real world conditions, while hazard-based schemes such as USEtox do not have this direct link.

At present, the ESC database covers the vast majority of detergent and cleaning product ingredients. Data are included for around 270 ingredients, covering more than 600 CAS numbers. For the majority of these ingredients, the PESR calculation needs to be performed (175 entries); 12 entries are ‘exempt’; 29 entries are ‘HERA OK’ and 1 entry was EU RA assessed. The ESC database is updated on a regular basis by A.I.S.E.

4. Analysis of ESC findings for A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation

The ESC tool, developed by A.I.S.E., has been applied to the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ with the objective to evaluate its environmental safety and to explore if and how the ESC tool can be used in the context of the A.I.S.E. PEF for HDLLD. The ingredients of the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ were checked with the ESC Tool.

The ESC results for the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ are reported in Figure VI 23. For ease of reference, PESR values on the ESC Check Sheet are colour-coded:

Ingredients coloured Green have a PESR below 0.5–‘Clear’ result; Ingredients coloured Amber have a PESR between 0.5 and 1 – ‘Clear’ result; Ingredients coloured Red have a PESR >1.



Table XIII-19: ESC tool assessment for ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’

This analysis shows that the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ successfully passes the ESC-check and can thus be considered to be environmentally safe, according to ESC assessment. In the context of the A.I.S.E. Charter ASP product scheme for heavy duty liquid detergents, this formulation would meet the ingredient/formulation requirements.

Nine (9) ingredients of the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ have been assessed by the HERA risk assessment procedures and are considered to be environmentally safe on the basis of their margins of safety. These 9 ingredients constitute a relatively high proportion of the total number (n=18) of ingredients of the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ and it should be pointed out that the use of the ESC-tool for commercial, market-representative formulations is expected to include a higher number of non-HERA listed ingredients than was the case for the HDLLD reference formulation.

As mentioned above, fragrances as well as a range of non-hazardous substances are exempted (a total number of 4 ingredients). Three (3) ‘non-hazardous substances‘ (e.g. Na/Mg/K-Hydroxide, glycerol , Ca/Na-Chloride) are ‘exempt’ from the ESC check in line with REACH articles 2(a) and 2(b), since they are considered to cause minimum risk because of their intrinsic properties and



especially their use in detergents clearly poses no risk to the aquatic environment when disposed via sewage treatment. Fragrances are covered by the IFRA risk assessment procedures and the IFRA Code of Practice.

The PESR has been calculated for five (5) remaining ingredients. PESR values proved to be below 1, which fulfils the ESC compliance requirements and confirms the safe use of these ingredients. The ESC-tool is conservative so PESR values below 1 are a clear indication that the ingredient is environmentally safe. As an example, the preservative in the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ was assessed in the ESC check and it was confirmed to have a PESR < 1.

For perspective, once the ESC-assessment of each ingredient in a formulation is passed, it can be concluded that the ingredients and the formulation are environmentally safe (aquatic compartment). It is worth noting though that within the A.I.S.E. Charter for Sustainable Cleaning, there are also additional requirements against which a product/package has to be assessed before it can be concluded that the product meets the ASP requirements for heavy duty liquid detergents.

5. Discussion of ESC and USEtox findings

The ESC and USEtox methods have been developed for different purposes and gave very different results when applied to the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’.

- The USEtox method highlighted mainly fragrances as the single most important ingredients class in terms of contribution to the ecotoxicity for aquatic fresh water impact category, even when different sets of characterization factors were used. The primary intended application of USEtox is for hotspot analysis (i.e. identifying potentially significant contributions across the life cycle) and not product ranking. Once hotspots are identified, it is recommended that the user/researcher undertake further research to understand whether the potential impact is relevant/realistic or not. It can therefore be argued that the application of risk assessment procedures, taking into account the total usage of ingredients (as opposed to a single dose/wash equivalent), actually address the areas of potential concern identified by USEtox and assure that the potential impact on the environment is not realized in practice.

- The ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’ successfully passed the ESC-check and can be considered to be environmentally safe, according to the ESC assessment. In the context of the A.I.S.E. Charter ASP product scheme for heavy duty liquid detergents, this formulation would meet the ingredient/formulation requirements. The ESC-check had confirmed that the preservative is environmentally safe. This shows how the 2 methods come to different conclusions for the preservative. No comparison with fragrances can be made since these are covered by the IFRA risk assessment and management procedures.

A.I.S.E./AFISE (French Detergent association) actively participated to the 2010-2011 French ‘Affichage Environnemental’ pilot with laundry detergents. The USEtox method was assessed and this evaluation showed similar limitations related to data availability/quality for determining validated USEtox characterization factors. Based on



this, the French Environmental Footprint category rules for detergents adopted the use of the already operational A.I.S.E. ESC method, while further model and database development efforts for USEtox were ongoing. The rationale was as follows (Ref: BP X30-323-2 - Principes generaux pour ’affichage environnemental des produits de consommation: Methodologie d'evaluation des impacts environnementaux des lessives. ADEME, December 2012)97.

”Ecotoxicité aquatique : Ce critère, lié à la formulation de la lessive, représente le comportement de substances polluantes sur les écosystèmes aquatiques, une fois qu’ils se retrouvent dans l’environnement, après traitement en station d’épuration. Cet indicateur a été retenu car la formulation de la lessive présente un impact important sur l’écotoxicité, qui est différenciant (c’est-à-dire que l’on pourra comparer plusieurs produits entre eux sur ce critère) selon la nature des ingrédients utilisés. Le calcul de l’écotoxicité aquatique repose sur la méthode USEtox. Dans l’attente des facteurs de caractérisation pertinents pour rendre la méthodologie USEtox opérationnelle dans le secteur de la lessive, il est important que les professionnels aient la même approche. Ils peuvent pour cela dans un premier temps s’appuyer sur les bonnes pratiques de la profession définies dans la Charte pour le Nettoyage Durable de l’A.I.S.E. ».

While the USEtox characterisation factors databases have been improved since that period, the analysis by the A.I.S.E. PEF TS shows that this has not yet been addressed satisfactorily.

6. Extrapolation – what do the ESC and USEtox results mean for the real world?

As reported in the publication by Hauschild et al (Hauschild, Jolliet, & Huijbregts, 2011), USEtox is a tool commonly used in LCA community for the purpose of broad screening and hotspot analysis (i.e. identifying potentially significant contributions across the life cycle) and not product ranking. When the USEtox tool is used within its field of intended use, it can provide general, LCA-based guidance to product designers, indicating potential areas for improvement or areas that require a further refinement of understanding.

The USEtox result has a limited relation with actual impacts in the real world and the result is essentially an aggregated predictive hazard score modified by fate and exposure modelling. The USEtox methodology shares the same philosophical basis of the LCA approach, in that it is applied to the assessment of the functional unit which in this case is the emissions associated with the production and use of one dose of HDLLD for one wash event. Consequently, it is subject to a number of limitations associated with the LCA method in general namely that it assumes there is no spatial or temporal difference in the release of the emissions. For some impacts categories, this assumption can be considered acceptable, such as global warming potential where it can be argued that there is a continuum of impact driven a change in the concentration of greenhouse gases over time or in applications such as hotspot analysis. However, in the case of ecotoxicity for aquatic fresh water and ecosystem impacts where threshold levels exist for chemical classes with different modes of action, the assumptions and environmental relevance of the USEtox approach have yet to be scientifically proven.

A.I.S.E. is keen to thus progress this topic in a constructive, scientific and transparent way with all concerned stakeholders, leading to the provision of a relevant method. It is

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believed by the majority of industry players that this one should be based on risk assessment. Once the ecotoxicity assessment in a lifecycle assessment study has indicated the potential impact on freshwater ecotoxicity, an assessment of the actual environmental impact cannot be obtained with USEtox. The assessment of the actual impact on freshwater ecotoxicity will require the use of an appropriate and scientific method. When multiple tools are available, it is important to use each tool for the purpose and application domain for which it was developed and validated.

The ESC assessment covers only the aquatic compartment (generally considered as the most important for detergents) but does not cover other environmental compartments. ESC results are predictive of the realistic environmental, aquatic risk of detergent products, and will be rather on the conservative side. While both risk- based and hazard-based approaches can be and are used for example in the early phases of product development (Sustainable product design by company R&D organisations), companies and authorities will use validated risk-based assessments methods to evaluate the real environmental impacts of marketed products and their ingredients.

7. Implications for consumer communication and product design/innovation

The reported analysis indicates that selected classes of ingredients contribute significantly to the HDLLD USEtox score but also that their relative contributions vary significantly depending on the chosen characterization factors. The drivers and environmental relevance of the USEtox CTUe scores are not clearly understood and need to be further investigated.

The high variability of the USEtox ecotoxicity results observed for detergents with small compositional differences could lead to confusion in terms of the upcoming PEF communication testing with consumers as the USEtox scores would be highly influenced by relatively small differences in levels for a small set of ingredients.

It is equally important to take into account the consequences on the product innovation strategies when the USEtox method in its present form would become deployed on a broad scale for systematic assessments of the ecotoxicity impact of current and innovative detergent ingredients. At present, state of the art risk assessment/management procedures are used when companies develop and commercialize innovative chemicals. These approaches are environmentally validated, consistent with official risk assessment methods, and they support the sustainable innovation process by driving environmentally meaningful improvements. The A.I.S.E. ESC-evaluation is compliant with these risk-based methods.

Even when a standardized database with updated USEtox characterisation factors for ecotoxicity for aquatic fresh water would be available (which is highly recommended), the application of USEtox in its present form can be expected to lead to significantly different product design choices. Given the identified uncertainties, the variable CTUe scores depending on CF choices and the unclear link of CTUe scores with the real world situation, careful consideration is needed before the USEtox tool is applied broadly for ranking or comparisons of chemicals or products.

8. Concluding remarks

A.I.S.E. is committed to ensuring the safety of the detergent ingredients and products and agrees with the relevance of assessing the environmental impact of detergents as a



key component for any environmental product scheme, such as the EU PEF and the A.I.S.E. Charter for sustainable cleaning (ASP product scheme).

For this reason, A.I.S.E. has used both the ESC and USEtox methods to assess how they evaluate the ecotoxicological profile of the ‘A.I.S.E. Heavy Duty Liquid Laundry Reference Formulation’. This assessment has shown substantial differences between the USEtox and the risk-based ESC evaluations.

The interpretation of the USEtox scores is not straightforward. Analysis of the USEtox results shows that it is highly influenced by data availability, data quality and data selection principles. The USEtox tool (in its present form and with the currently available CF datasets) does not seem fit for use to make scientifically accurate, validated and environmentally meaningful differentiation between products. The USEtox assessment may be valid for LCA-based approaches such as hotspot analysis, but in present form it is not judged to be appropriate to accurately and reliably rank or compare the ecotoxicity profile of detergent ingredients.

The ESC model is ready for use (operational in the A.I.S.E. Charter for Sustainable Cleaning). Analysis of ESC results indicates that the ‘2013 HDLLD reference product’ is environmentally safe and that its use will not lead to adverse effects for aquatic organisms. According to the ESC model, further reductions in exposure concentration or hazard profile of the studied HDLLD ingredients will not lead to actual environmental improvements under actual “realistic” conditions. While the ESC-tool (similar to other risk-based models) can be used to evaluate the actual risk of detergent products, A.I.S.E. realizes that it is not suitable for the purpose of product ranking or comparison.