revision of eco-label criteria for laundry...

May 2003

European Eco-label

Revision of Eco-label criteria forlaundry detergents

Final report

Prepared byDHI Water & Environmentdk-TEKNIK ENERGY & ENVIRONMENT

European Eco-labelRevision of Eco-label criteria for laundrydetergents

Final report

Agern Allé 11DK-2970 Hørsholm, Denmark

Tel: +45 4516 9200Fax: +45 4516 9292e-mail: [email protected]: www.dhi.dk

Client Client’s representative

Project

European Eco-labelRevision of Eco-label criteria for laundry detergents

Project No.

51503

Date2003.05.14

Authors

Torben Madsen (DHI)Heidi Stranddorf (dk-TEKNIK) Approved by

01 Draft report

Revision Description By Checked Approved Date

Key words Classification

Open

Internal

Proprietary

Distribution No. of copies

DHI: TMA/ERA/Arkivdk-TEKNIK ENERGY & ENVIRONMENT

ERA/2003.05.14 i

CONTENTS

1 SUMMARY....................................................................................................................1

2 MARKET REVIEW ........................................................................................................22.1 Consumption of laundry detergents in Europe...............................................................22.2 Product group definition.................................................................................................3

3 MARKET OF ECO-LABELLED LAUNDRY DETERGENTS...........................................33.1 Product tests .................................................................................................................43.2 Future promoting of eco-labelled products.....................................................................53.3 Actions at several levels ................................................................................................6

4 CURRENT ECOLOGICAL CRITERIA AND SUGGESTED CHANGES .........................64.1 Summary of the current criteria .....................................................................................64.2 Revised criteria..............................................................................................................74.2.1 Total chemicals .............................................................................................................84.2.2 Insoluble inorganic ingredients ......................................................................................84.2.3 Toxicity to aquatic organisms ........................................................................................94.2.4 Phosphates .................................................................................................................104.2.5 Biodegradability of surfactants.....................................................................................124.2.6 Dangerous, hazardous or toxic substances or preparations ........................................15

5 OTHER CRITERIA ......................................................................................................185.1 Packaging requirements..............................................................................................195.2 Consumer information .................................................................................................20

6 PERFORMANCE TEST ..............................................................................................21

ANNEXES

Annex 1: QuestionnaireAnnex 2: Inherent environmental properties of laundry detergent formulationsAnnex 3: Anaerobic biodegradability of surfactantsAnnex 4: Revised ecological criteria for laundry detergentsAnnex 5: List of participants and minutes from meetings in ad hoc working groupAnnex 6: Statement from Regulatory Committee meeting on 4 December 2002Annex 7: Incoming and outgoing correspondence

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1 SUMMARY

The European Commission authorised the Danish competent body with their partners toupdate the eco-label criteria for laundry detergents. The former criteria are laid down inCommission Decision 1999/476/EC and according to this Decision, the period of valid-ity of the product group criteria shall be three years.

The revised ecological criteria extend the product group definition, which implies thatmanufacturers of laundry detergents for launderettes and common laundries can alsoapply for the eco-label. The new product group definition is:

�All laundry detergents, in powder, liquid or any other form; for the wash-ing of textiles, and which are intended to be used principally in householdmachines; but not excluding the use in launderettes and common laundries.�

The environmental matrix or scoring system in the current criteria is replaced by a sim-plified system consisting of six parameters and associated hurdles, i.e.:

• The amount of total chemicals shall not exceed 100 g/wash• The total amount of insoluble inorganic ingredients shall be less than 30 g/wash• The critical dilution volume toxicity (CDVtox) shall not exceed 4500 l/wash• The total amount of phosphates shall not exceed 25 g/wash• Each surfactants shall be readily biodegradable and anaerobically biodegradable• Dangerous, hazardous or toxic substances or preparations, defined by chemical

names or risk phrases, are either excluded or limited in amount in eco-labelled prod-ucts.

The revised criteria are anticipated:

• To reduce the environmental impact of laundry detergents• To increase transparency and, thereby, encourage manufacturers to apply for the

eco-label• To facilitate the communication of the criteria to manufacturers and consumers

The revised criteria will lead to a harmonisation between the criteria for laundry deter-gents and the current criteria for all-purpose cleaners and cleaners for sanitary facilities(of 27 June 2001) and the criteria for hand dishwashing detergents (of 19 July 2001).

The requirements to washing performance have been adjusted in order to adapt the per-formance criteria to a level that can be met by typical liquid laundry detergents on themarket. This implies that the required levels of washing performance have been reducedfor heavy-duty and light-duty liquid detergents.

Furthermore, the packaging requirements have been modified by inclusion of a new re-quirement to the weight of the primary packaging for tablets.

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2 MARKET REVIEW

As part of the work on revision of the criteria, a questionnaire was been sent to theEUEB and the Commission, national eco-label competent bodies, consumer and com-mercial organisations and other relevant parties. The questionnaire is included in thisreport as Annex 1.

Twenty answers were received, distributed as follows:

• Competent bodies: 6• Manufacturers: 8• Organisations: 5• Other stakeholders: 2

The inputs received on proposals for revision of the criteria as well as related to marketissues are integrated in this report.

2.1 Consumption of laundry detergents in Europe

AISE, the international detergent and maintenance products industry, has not publishedany new statistics on the use of laundry detergents since 1996 (see Table 2.1). Thesestatistics show the consumption of laundry detergents in Europe in 1994 and 1995. InTable 2.1, the statistics covering the Danish consumption of laundry detergents from1998 to 2000 [The Association of Danish Cosmetics, Toiletries and Detergent Industries(SPT), October 2001] are used for estimating the consumption in 1998 and 2000 inEurope. Table 2.2 describes coarse estimates of the annual consumption of major sur-factants in laundry detergents for Europe.

Table 2.1 Estimated annual consumption of laundry detergents (Consumer Products – Fabricwashing) for Europe

19953 1998 2000Laundry detergents tons/year tons/year tons/yearPowders 3,400,000 3,600,000 4,200,000Liquids 550,000 620,000 780,000Auxiliary products1 100,000 100,000 93,000Fabric rinse products 2 1,100,000 950,000 950,000

1 Includes a.o. soaking product, stain removers, precursors, water softeners2 Fabric rinse products – all forms. Also known as fabric conditioners and softeners3 AISE, 1996. 1994/1995 Statistical Tables. June 1996.

The estimate indicates that both the amounts of powders and liquids are increasing. Theauxiliary and fabric rinse products are slightly declining or are the same. Through thenineties the trends in Europe have generally been towards an increase of the use ofhighly concentrated solid products � powders or single-load tablets called compacts orsuper compacts [Morse, P.M. 1999. Chemical & Engineering News. February 1999].The annual consumption of powders increases slowly whereas the consumed amountsof liquids increase rapidly. In the U.S., the liquids have continued to gain market sharesfrom the powders through the nineties.

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Table 2.2 Estimated annual consumption of major surfactants in laundry detergents forEurope

Surfactant tons/year (in 2000)Linear alkylbenzene sulphonates (LAS) 270,000Secondary alkane sulphonates 45,000Alkyl sulphates and alkylether sulphates 260,000Soaps 65,000Anionics, subtotal 640,000Alcohol alkoxylates 295,000Fatty acid glucose amides 1,300Nonionics, subtotal 295,300Cationics 35,000Amphoterics 550Total 970,850

Sources:ECOSOL (1996). Surfactant consumption in household detergents.Umwelt Bundes Amt (2001). Confidential informationDanish Environmental Protection Agency (2001). Environmental Project No. 615.

2.2 Product group definition

The current criteria define �laundry detergents� as �all laundry detergents, in powder,liquid or any other form; for the washing of textiles, and which are intended to be usedprincipally in household washing machines�. This definition implies that the scope ofthe eco-label is household laundry detergents although laundry detergents used outsidethe households are not completely excluded. Laundry detergents used for the washing oftextiles in coin-operated and communal laundries have a composition similar to that ofhousehold laundry detergents, and the potential advantages of a specific inclusion ofthis type of detergents in the product group definition should be considered. The ad hocworking group decided to use a broader product group definition for the work of revi-sion of the laundry detergents eco-label criteria. This definition is:

�All laundry detergents, in powder, liquid or any other form; for the washing oftextiles, and which are intended to be used principally in household machines;but not excluding the use in launderettes and common laundries� (see revisedcriteria, Article 2).

3 MARKET OF ECO-LABELLED LAUNDRY DETERGENTS

At present, three flower licenses have been given in the laundry detergent productgroup:

• The manufacturer Linds Fabrikker A/S in Denmark obtained a license in February2001

• The Italian retailer chain Esselunga SpA obtained a license in February 2001• The Dutch manufacturer Dalli Benelux b.V. obtained a license in May 2001

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All three licenses are relatively new as they have been on the market for only two years.This �first wave� may motivate other manufacturers to apply for the eco-label as well.

The European market for household laundry detergents is dominated by the multina-tional groups like Procter & Gamble, Unilever, Reckitt & Colman etc. For the present,these groups have not yet shown their interest in applying for eco-labels in general.Sweden making an exception as the Swedish market for eco-labelled (the Nordic Swan)laundry detergents is developed to an extent where an eco-label is regarded a prerequi-site for selling the products.

Apart from the multinationals, the big private label manufacturers play a certain role onthe European market. Private labels are produced for the retailer chains under their owntrademarks. As a consequence, the purchasers of the major retailer chains have an ex-tended influence on the market. They determine the product range on the shelves in-cluding the balance between mainstream products and high quality niche products.

The total European market for laundry detergents is estimated at � 3-4 billions. Ac-cording to a manufacturer, the market has been saturated for the past 10-15 years, andlaundry detergents in general are sold at the same price level as 20 years ago. Today,about 80% of all laundry detergents are sold on offer as loss leaders in the supermar-kets, which is not favourable for promotion of the high quality niche products.

On their respective markets, the present flower-labelled products are profiled as highquality products in relation to washing performance as well as to the environment. TheFlower itself is not the main selling point � only in combination with a high perform-ance.

3.1 Product tests

The importance of combining high quality products in relation to washing performanceas well as to the environment is illustrated by the results of two product tests on laundrydetergents on the Danish market carried out by the Danish Consumer Information in1999 (laundry detergents, colour) and 2001 (laundry detergents, white wash) respec-tively. The tests focused on washing performance, environmental impact and price. Inboth tests, an eco-labelled product came out as the total winner leading to a lot of posi-tive publicity. It should be noted that as a consequence the 1999 winner experienced areal boost on the market for the entire Swan-labelled product line, not only for the spe-cific laundry detergent. In 2001, the winning product carried the Flower eco-label.There has been a positive publicity as well as presentation in a very popular consumerprogramme on Danish television. However, it is still too early to conclude on the finalreaction on the market.

According to the questionnaires, a more widespread use of product tests carried out byindependent organisations is overall assessed to have a potential for promoting eco-labelled products in other countries too, for example in the Netherlands, Belgium, Ire-land and Austria. Naturally, it will only be beneficial to the eco label if the eco-labelledproducts perform very well in the tests. The major benefit of the tests in relation to mar-ket aspects is the combination of environmental performance, washing performance andprice. The best products are not always the most expensive ones and products with alow environmental impact are not old-fashioned or ineffective. Both statements are key-

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arguments in any campaign for awareness raising. There is also one example where atest demonstrating good performance, potential low environmental impact and lowprices did not influence the market. This indicates that a good combination is only valu-able when it is used with caution.

3.2 Future promoting of eco-labelled products

As the number of Flower licences is very limited for the time being, the eco-labelledlaundry detergents are not yet visible on the market in general. Two strategy elementsseem possible and can be interlinked.

1. Extend the position of the high quality niche productsThe advantage for this strategy element is that it is already ongoing. The process of get-ting more eco-labelled private labels can be stimulated by a focused effort targeted atthe purchasers of the big retailer chains. Each year, the Private Label Manufacturers As-sociation (PMLA) holds a trade fair in the Netherlands, and this could be a very goodoccasion for a campaign for eco-labelled products.

If the market for these high quality niche products is extended, it may also support thefollowing strategy element.

2. Break through the wall for the mainstream productsThis strategy demands a much more extensive effort as there is a need to raise theawareness on eco-labelled products among the consumers, the retailers and the manu-facturers. Moreover, a real break-through calls for one or more of the multinationals toapply for the eco-label on their main products. But if this happens, it will probably havea snowball effect on the market.

For the past few years, AISE, the international detergent and maintenance products in-dustry, have spent millions of Euros on �wash-right� campaigns targeted on the con-sumers. In the campaigns mainly based on pan-European TV spots, the consumers aretaught to minimise the environmental impacts during use e.g. by choosing a lower tem-perature for doing the laundry. Except for recommendations related to packaging (savethe box and buy refills if possible), the campaign does not focus on the product features.AISE represents the national associations of 27 countries (mainly located in Europe)and includes approximately 800 members.

Owing to the AISE campaigns, many consumers throughout Europe have started to re-alise that laundry detergents do have an environmental impact. This is an important steptowards realising that there are good reasons for buying products with less environ-mental impact.

No matter what strategy be chosen, there is a need to promote the eco-labels in generalamong manufacturers, retailers, (public) purchasers and consumers, not only one of thegroups. This is suggested by almost all the respondents on the questionnaire and in linewith the new working plan of the European Flower1 establishing a permanent EUEBmarketing group.

1 May be obtained from any EUEB stakeholder or downloaded from

http://europa.eu.int/comm/environment/ecolabel/pdf/work_plan/24septemberversion.pdf

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3.3 Actions at several levels

From a European Union point of view, several instruments can be used.

First of all, at the political level, the Procurement Directive could be improved towardsgreen procurements as an important aspect in realising the Integrated Pollution Preven-tion strategy. Public purchasers throughout Europe represent a substantial market andmay serve as a 'locomotive' for the eco-label and/or the criteria set up for the productgroup. The easier it is to understand the criteria the greater the potentials for use.

Campaigns. General information campaigns on eco-labelled products based on TVspots, advertisements etc. directed primarily towards the consumers are important toraise the awareness and, on a long view, raise the demand for these products. The cam-paigns should not be let alone issues but integrated elements in a large effort. Agree-ments should be made with manufacturers to launch eco-labelled products and retailersshould be involved in shop-campaigns to influence the consumers� choice at the time ofbuying the products. In other words, a successful campaign has to be conducted and co-ordinated in several fields at the same time.

Special events. Promotion of eco-labelled products at mega events like the OlympicGames or World Championships is worth considering. With respect to laundry deter-gents, which are probably not the most appealing product group to young athletes, theseproducts could be promoted together with eco-labelled textiles like sportswear, hotellinen, footwear etc. Moreover, a personal sponsorship of one of the top-athletes mayalso bring about a lot of valuable publicity and serve as a model for the young genera-tion (e.g. the Brazilian soccer player G. Elber promoting the Transfair label).

4 CURRENT ECOLOGICAL CRITERIA AND SUGGESTEDCHANGES

4.1 Summary of the current criteria

The current ecological criteria consist of eight parameters, which are related to a func-tional unit expressed in grams per wash. For heavy-duty detergents, the functional unitis the dosage in grams of the product recommended by the manufacturer for 4.5 kg load(dry textiles) while, for low-duty detergents, it is the dosage recommended for 2.5 kgload (dry textiles) in the washing machine.

The following parameters are considered in the existing ecological criteria:

• Total chemicals (TC)• Critical dilution volume-toxicity (CDVtox)• Phosphates (as STPP)• Insoluble inorganics (II)• Soluble inorganics (SI)• Aerobically non biodegradables (aNBO)• Anaerobically non biodegradables (anNBO)• Biological oxygen demand (BOD)

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To each of the individual criteria above, an exclusion hurdle, scores from 1 to 4 pointsand a weighting factor are assigned. The exclusion hurdles specify limit values thatmust be complied with, whereas the score is related to a defined value in grams perwash. The score is multiplied with the weighting factor, which shows the relative im-portance of the criterion. This scoring or matrix system is relatively complex and makesit difficult to explain the positive value of eco-labelled products to the consumers. Theresponses to the questionnaire indicate that some manufacturers abandoned to apply forthe eco-label because the lack of transparency of the current matrix system makes itvery difficult to assess the �pass� or �fail� of individual products.

4.2 Revised criteria

The environmental matrix in the current criteria is replaced by a simplified system con-sisting of six parameters and associated hurdles.

The revised criteria are anticipated:

• To reduce the environmental impact of laundry detergents• To increase transparency and, thereby, encourage manufacturers to apply for the

eco-label• To facilitate the communication of the criteria to manufacturers and consumers

Furthermore, the revised criteria will lead to a harmonisation between the criteria forlaundry detergents and the current criteria for all-purpose cleaners and cleaners forsanitary facilities (of 27 June 2001) and the criteria for hand dishwashing detergents (of19 July 2001).

Confidential formulations of 41 laundry detergents (powders, tablets and liquids) werereceived from manufacturers, companies and authorities in Germany and Denmark uponrequest. The revised criteria were partly based on analyses of the composition of theseproducts (Annex 2), although it was realised that the analyses suffered from the lack ofavailable data on laundry detergents on the markets in southern Europe.

Functional unit and limit of documentationSome of the parameters below are related to a functional unit, which is the dosage ingrams per wash for 4.5 kg dry textiles for heavy-duty detergents and 2.5 kg dry textilesfor low-duty detergents (similar to the current criteria).

The concentration of ingredients in the product, which implies a requirement for docu-mentation of compliance with the ecological criteria, is generally defined at ≥0.1% byweight of the preparation. This concentration is defined at ≥0.01% by weight of thepreparation for the criterion on �dangerous, hazardous or toxic substances or prepara-tions�.

Recommendations for the next revisionThe discussions in the ad hoc working group resulted in recommendations of specificissues that should be considered in the next revision of the criteria (see in the follow-

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ing). At its meeting on December 4, 2002, the Regulatory Committee prepared a state-ment describing issues that should be considered in the next revision (Annex 6).

4.2.1 Total chemicalsThe ad hoc working group recommended that a limit for the amount of total chemicalsin the product should be a parameter in the revised criteria in order to encourage theproduction of compacts and, thereby, reduce impacts related to transport.

Current criterionThe current criterion implies that the weight of the total chemicals at the recommendeddosage of the product must not exceed 110 g/wash (exclusion hurdle). The points ob-tained in the environmental matrix are reduced to 50% of the maximum value for thisparameter at a total chemicals dosage of 80 g/wash.

New criterionThe initial proposal presented to the ad hoc working group was that the weight of thetotal chemicals at the recommended dosage should not exceed 90 g/wash. The workinggroup modified this limit to 100 g/wash because representatives from countries in thesouthern Europe argued that many laundry detergents at their respective markets wouldfail to pass a hurdle of 90 g/wash. It was accepted that there might be a difference be-tween laundry detergents in the northern and southern parts of Europe, although datadescribing the formulations of laundry detergents in, e.g. Mediterranean countries werenot available. An analysis of 41 laundry detergents marketed in Germany and Denmark(Annex 2) showed that the range for the weight of the total chemicals at the recom-mended dosage was 39 g/wash to 160 g/wash with an average value of 78 g/wash.

The total chemicals of five of the 41 products exceeded 100 g/wash, which is the newcriterion.The new criterion is described below:

�Total chemicals are the recommended dosage in g/wash minus the water content.

The amount of total chemicals shall not exceed 100 g/wash.

Assessment and verification. The exact formulation of the product shall be provided tothe Competent Body, together with the details of the calculations showing compliancewith this criterion.�

4.2.2 Insoluble inorganic ingredientsInsoluble inorganic ingredients in laundry detergents, mainly in the form of zeolites,contribute to the production of sewage sludge and, thereby, increase the need for an ap-propriate disposal. Regulation of insoluble inorganics is not considered very importantfor reducing the environmental impact of detergents, and, a parameter on insolubleinorganics was not included in the first proposal which was presented to the workinggroup. However, the discussions in the working group re-introduced a limit on insolubleinorganics; the exclusion hurdle in the current criteria was considered to be a sufficientlimit also in the revised criteria.

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Current criterionThe current criterion implies that the total amount of insoluble inorganics in the productmust not exceed 30 g/wash (exclusion hurdle). The points obtained in the environmentalmatrix are reduced to 50% of the maximum value for this parameter at 20 g of insolubleinorganics per wash.

New criterionThe analysis of 41 laundry detergents marketed in Germany and Denmark (Annex 2)showed that the amounts of insoluble inorganics varied between 0 g/wash and 33g/wash. The insoluble inorganic ingredients in one of the 41 products exceeded 30g/wash, which is the new criterion (similar to the current exclusion hurdle).

The new criterion is described below:

�The total amount of insoluble inorganic ingredients at the recommended dosage shallbe less than 30 g/wash.


4.2.3 Toxicity to aquatic organismsBy volume, surfactants constitute the type of ingredients most relevant for the discus-sion of possible adverse effects of laundry detergents in the aquatic environment. Theability of surfactants to dissolve or emulsify lipids and proteins implies that these ingre-dients will always have an inherent toxicity to living cells and, hence, to aquatic organ-isms. The efficiency of the treatment of waste water varies between the European coun-tries; more than 98% of the major surfactants are generally removed in well-functioningwastewater treatment plants, and the surfactants that are eventually released into thewater environment are normally degraded when molecular oxygen is present (aerobicconditions), but far less efficient wastewater treatment, or even direct discharge of wastewater to aquatic environments, exists in some countries. With the exception of highlypolluted recipients receiving untreated or poorly treated effluents the organisms in theenvironment are normally exposed to a relatively low, but more or less constant, con-centration of surfactants. The relevant parameter describing the potential adverse effectsof surfactants and other ingredients in laundry detergents is the long-term effects thatare included in the calculation of the critical dilution volume toxicity (CDVtox).

Current criterionThe potential aquatic toxicity of the product is estimated by the critical dilution volumetoxicity (CDVtox) which includes:

• The predicted emission to the aquatic environment (expressed by the amounts usedand a loading factor), and

• The predicted long-term effects of the ingredients

The CDVtox is calculated for each ingredient (i) using the following equation:

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CDVtox (ingredient i) = weight/wash (i) · LF (i) · 1,000LTE (i)

where weight (i) is the weight of the ingredient per recommended dose, LF is the load-ing factor and LTE is the long-term toxicity effect concentration of the ingredient.

The values of the LF and LTE parameters shall be as given in the detergent ingredientdatabase list (DID list) in Annex 1A of the current criteria. If the ingredient in questionis not included in the DID list, the applicant shall estimate their values following theapproach described in Annex 1B of the criteria. The CDVtox is summed for each ingre-dient, making the CDVtox for the product:

CDVtox= Σ CDVtox(ingredient)

The current criterion implies that the CDVtox for the product must not exceed 10,000l/wash (exclusion hurdle). The points obtained in the environmental matrix are reducedto 50% of the maximum value for this parameter at a CDVtox corresponding to 5,500l/wash.

New criterionThe analysis of 41 laundry detergents marketed in Germany and Denmark (Annex 2)showed that the range for the CDVtox was 946 to 4,781 l/wash with an average value of2,440 l/wash. Some of the formulations did not state the possible content of perfume,but the above-mentioned CDVtox of 4,781 l/wash was not exceeded, when a value of500 was added to the CDVtox of the products for which no information on perfumecontent was available (CDVtox = 500 represents 0.1 g of perfume/wash). The CDVtox ofone of the 41 products exceeded 4,500 l/wash, which is the new criterion. This may beseen as a very �soft� regulation of the CDVtox considering the importance of this pa-rameter, which combines the amounts of chemicals released to the aquatic environmentand the long-term environmental effects. However, similar to the parameter on totalchemicals, it was recognised that laundry detergents in the southern European countriesmight have higher values of CDVtox than the German and Danish products that were in-cluded in the analysis.The new criterion is described below:

�The CDVtox of the recommended dosage shall not exceed 4,500 l/wash.


4.2.4 PhosphatesPhosphorus used in the form of e.g. sodium tripolyphosphate (STPP) in laundry deter-gents is one of several sources of nutrients that contribute to enhanced growth of algaein aquatic systems (eutrophication) if the sewage is not purified in wastewater treatmentplants with processes designed for the removal of phosphorus, or, for obvious reasons,if poor wastewater treatment or direct discharge is applied. It is estimated that STPP inhousehold detergents contributes to up to 50% of soluble phosphorus in municipalwaste water [WRc. 2002. Eutrophication of waters, role of phosphates, preventive

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measures]. The countries in Europe have developed different strategies aiming at a re-duction of the enrichment of the water environment with phosphates. One approach is tosubstitute phosphates in detergent products with other chelating agents. Another ap-proach is to establish efficient processes for elimination of phosphates at the wastewatertreatment plants. This situation explains why diverging opinions regarding the accept-ability of phosphates in laundry detergent are represented among the Member States.The majority of the representatives in the ad hoc working group accepted that a mini-mum of phosphates could be allowed in eco-labelled laundry detergents. The MemberStates may reflect on introducing national regulations on phosphates in the products ifnecessary to facilitate the eco-label policy process. This would also reflect the differentstrategies for the treatment of waste water in Europe in view of an enlarged EuropeanUnion.

Current criterionThe current criterion implies that the total amount of phosphate (as STPP) in the prod-uct must not exceed 30 g/wash (exclusion hurdle). The points obtained in the environ-mental matrix are reduced to 50% of the maximum value for this parameter at a phos-phate content of 15 g/wash.

New criterionThe initial proposal presented to the ad hoc working group was that the total amount ofphosphates at the recommended dosage should not exceed 20 g/wash. The workinggroup modified this limit to 25 g/wash being convinced that this amount was necessaryto achieve sufficient chelating capacity with the current technology. The analysis of 41laundry detergents marketed in Germany and Denmark (Annex 2) showed that theamounts of phosphate varied between 0 g/wash (phosphate-free detergents) and 30g/wash. The phosphate content of two of the 41 products exceeded 25 g/wash, which isthe new criterion.


�The total amount of phosphates (as sodium tripolyphosphate � STPP) in the productshall not exceed 25 g/wash.


Recommendation for the next revisionSome Member States expressed concern related to the use of phosphates in laundry de-tergents and argued in favour of a criterion prescribing that eco-labelled laundry deter-gents should be phosphate-free. This point of view was supported by the recommenda-tion in a study commissioned by the EC Environment Directorate [WRc. 2002.Eutrophication of waters, role of phosphates, preventive measures] saying that a generalban on the use of STTP as a builder for household detergents should be placed on allEU Member States. The report on phosphates was made available at a late state in therevision process, and it is therefore recommended that the possible inclusion of a strictercriterion on phosphates is considered in the next revision.

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4.2.5 Biodegradability of surfactantsThe future European legislation on detergents is expected to prescribe that the surfac-tants in detergent products shall be readily biodegradable (aerobically) and that excep-tions to this general requirement are only acceptable if certain other eco-toxicologicaltests have proven a low potential for adverse effects. The rapid aerobic biodegradabilityof surfactants in an eco-labelled laundry detergent should be beyond doubt. Therefore,the compliance with pass criteria in the tests for ready biodegradability should bedocumented (either via the data in the DID list or by test results for the specific ingredi-ent). The 10-day window criterion, which is normally a part of the pass/fail criteria inready biodegradability tests, shall not apply for surfactants in eco-labelled laundry de-tergents. This is due to the fact that the 10-day window was originally intended for puresubstances and not for technical surfactants composed of several homologues or iso-mers.

Rapid aerobic biodegradability will normally ensure that a substance is degraded rapidlyin most environments in which molecular oxygen is present. Requirements to the an-aerobic biodegradability aim at a documented potential for the degradation of the sub-stance in sludge, soil and sediments, where oxygen may be temporarily or permanentlyabsent. A recent report prepared by the Fraunhofer Institut states that �it may be risky toaccept the application of large amounts of surfactants to soil with the hope that the natu-ral biodegradation potential will serve the complete elimination� [Fraunhofer Institut.2002. Anaerobic biodegradation of detergent surfactants]. On the other hand, this reportalso states that �there is no indication for a requirement of obligatory anaerobic biode-gradability when it is ensured that a substance is readily and ultimately biodegradableunder aerobic conditions". A risk assessment of non-anaerobically degradable surfac-tants conducted during the present study indicates a risk of adverse effects in sludge-amended soil in the first period after application of the sludge and in aquatic sedimentsin contaminated areas and areas with poor wastewater treatment (Annex 3).

The revised criteria prescribe that surfactants shall be ultimately biodegradable underaerobic and anaerobic conditions. The rationale for the requirements to the biodegrad-ability of surfactants is built on the fact that most surfactants are harmful to aquatic or-ganisms and are used in high volumes. The consumption and the use pattern of surfac-tants imply that small amounts of these ingredients reach the environment. If asurfactant is not degraded under the different conditions in the environment, it may betoxic to aquatic and soil-living organisms.

Current criterionThe current criteria disfavour the use of non-anaerobically-degradable ingredients by anexclusion hurdle associated with the parameter anNBDO (15 g/wash). The points ob-tained in the environmental matrix are reduced to 50% of the maximum value for thisparameter, when the content of non-anaerobically degradable ingredients corresponds to7 g/wash. The current criteria imply that all ingredients in the product shall be evaluatedfor anaerobic biodegradability

New criterionThe analysis of 41 laundry detergents marketed in Germany and Denmark (Annex 2)showed that all of the surfactants used in the products are ultimately degradable underaerobic conditions and comply with the above-mentioned criteria for ready biodegrad-ability. The available data do not allow a detailed assessment of anaerobic biodegrad-

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ability of the surfactants, but it is possible to indicate general trends. About 27% of theproducts (11 of 41) entirely contain surfactants that are ultimately degradable under an-aerobic conditions as confirmed by the data in the DID-list. Another 27% of the prod-ucts (11 of 41) contain multibranched nonionic surfactants that are presently not in-cluded in the DID-list and data confirming the ultimate biodegradation of this type ofsurfactant are not available. The remaining laundry detergents (46%; 19 of 41) containanionic surfactants of the sulphonate-type that are not ultimately biodegradable underanaerobic conditions. Sulphonates may be replaced by e.g. alkyl sulfates (DID Nos. 5-7)that are ultimately degradable under anaerobic conditions. If multibranched nonionicsurfactants cannot be confirmed anaerobically degradable, a substitution with linear al-cohol ethoxylates (DID Nos. 16-20) will make the products comply with the criterionon anaerobic biodegradability of surfactants.


�(a) Ready biodegradability (aerobic)

Each surfactant used in the product shall be readily biodegradable.

Assessment and verification. The exact formulation of the product shall be provided tothe Competent Body. The DID list (see Annex IA) indicates whether a specific surfac-tant is aerobically biodegradable or not (i.e. those that have an entry of �Y� in the col-umn on aerobic biodegradability shall not be used). For surfactants which are not in-cluded in the DID list, the relevant information from literature or other sources, orappropriate test results, showing that they are aerobically biodegradable shall be pro-vided. The tests for ready biodegradability shall be as referred to in Council Directive67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administra-tive provisions relating to the classification, packaging and labelling of dangerous sub-stances, and its subsequent amendments, in particular the methods detailed in AnnexV.C4, or their equivalent OECD 301 A-F test methods, or their equivalent ISO tests.The 10 days window principle shall not apply. The pass levels shall be 70% for the testsreferred to in Annex V.C4-A and C4-B of Directive 67/548/EEC (and their equivalentOECD 301 A and E tests and ISO equivalents), and shall be 60% for tests C4-C, D, Eand F (and their equivalent OECD 301 B, C, D and F tests and ISO equivalents).

(b) Anaerobic biodegradability

Each surfactant used in the product shall be anaerobically biodegradable.

Assessment and verification. The exact formulation of the product shall be provided.The DID list (see Annex IA) indicates whether a specific surfactant is anaerobicallybiodegradable or not (i.e. those that have an entry of �Y� in the column on anaerobicbiodegradability shall not be used). For surfactants which are not included in the DIDlist, the relevant information from literature or other sources, or appropriate test results,showing that they are anaerobically biodegradable shall be provided. The reference testfor anaerobic degradability shall be ISO 11734, ECETOC No. 28 (June 1988) or anequivalent test method, with the requirement of 60% degradability under anaerobic con-ditions.�

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The new criterion is stricter than the current criteria in relation to surfactants, whereas itis less strict in the requirements to the applicant�s documentation for anaerobic biode-gradability of ingredients. The new criterion reduces the requirements for documenta-tion of anaerobic biodegradability by focussing on surfactants, whereas such documen-tation in principle shall be provided for all ingredients according to the current criteria.

The arguments for the new criterion are the following:

• A combined requirement that the surfactants shall be biodegradable under bothaerobic and anaerobic conditions implies that optimal biodegradation properties areintended for the more hazardous ingredients in eco-labelled laundry detergents (thiswill reduce the risk that surfactants used in eco-labelled products are regulated innational or European legislation, e.g. in the form of quality standards for contami-nants in sludge used in agriculture).

• Surfactants are potentially hazardous to the environment and are used in highamounts in laundry detergents; the requirement that surfactants in eco-labelledproducts shall be rapidly degradable under different environmental conditions iseasy to communicate and is also a new selling argument.

• The new criterion will harmonise the eco-labelling criteria for laundry detergentswith the current (and recently revised) criteria for all-purpose cleaners and cleanersfor sanitary facilities (of 27 June 2001) and for hand dishwashing detergents (of 19July 2001).

In the ad hoc working group, some of the participants representing the producers of rawmaterials pointed to the fact that soap is found in g/kg levels in predominantly anaerobicaquatic sediments, although soap is biodegradable under anaerobic conditions. Besidesthe high volumes used, the presence of soap in sediments is due to limitations in bio-availability and not to a lack of anaerobic degradation. Only chemicals that are bioavail-able (i.e., desorbed and dissolved) can exert a toxic effect on organisms living close toor in aquatic sediments. The requirement that surfactants in eco-labelled laundry deter-gents shall be anaerobically biodegradable ensures that the surfactants will probably de-grade in the sediment as soon as they become bioavailable.

Documentation of anaerobic degradabilityThe following approach may be used to provide the necessary documentation of an-aerobic degradability for the Competent Body:

Consult the DID-list. The DID-list contains 26 anaerobically degradable surfactants(including C12-18 alkylamidopropylbetaine, DID No. 34, which is anaerobically de-gradable). These 26 surfactants comprise anionic, nonionic and amphoteric surfactants,and it is foreseen that �new� anaerobically degradable surfactants (including the fourthmain type, cationics) will be included during the planned revision of the DID-list. How-ever, the current DID-list provides the necessary data to produce a detergent based onanaerobically degradable surfactants.

Apply reasonable extrapolation. Use test results obtained with one raw material toextrapolate the ultimate anaerobic degradability of structurally related surfactants (usethe surfactant types defined in the DID-list or apply a similar approach for ingredientsnot included in the list).

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Perform screening test for anaerobic degradability. If new testing is necessary, per-form a screening test by use of ISO 11734, ECETOC No. 28 (June 1988) or an equiva-lent method.

Perform low-dosage degradability test. If new testing is necessary, and in the case ofexperimental problems in the screening test (e.g. inhibition), repeat testing by using alow dosage of surfactant and monitor degradation by 14C measurements or chemicalanalyses.

4.2.6 Dangerous, hazardous or toxic substances or preparationsThe criteria for eco-labelling shall define a standard for health and environmental safetyon the basis of the knowledge available today. This objective is met by supplementingthe above-mentioned criteria with prescriptions of certain ingredients that shall not beincluded in eco-labelled laundry detergents. Furthermore, no ingredient shall be in-cluded in the product that is classified or may be classified by certain specified riskphrases.

Current criterionThe current criterion implies that a number of specified ingredients shall not be used orare limited in their concentration in eco-labelled laundry detergents.

The following ingredients shall not be used in the product:

Alkyl phenol ethoxylates (APEOs) and their derivativesEDTA (ethylenediamine tetraacetate)Musk xylene: 5-tert-butyl-2,4,6-trinitro-m-xyleneMusk ambrette: 4-tert-butyl-3-methoxy-2,6-dinitrotolueneMoskene: 1,1,3,3,5-pentamethyl-4,6-dinitroindanMusk tibetine: 1-tert-butyl-3,4,5-trimethyl-2,6-dinitrobenzeneMusk ketone: 4�-tert-butyl-2�,6�-dimethyl-3�,5�-dinitroacetaphenone

Ingredients fulfilling the criteria for classification as carcinogenic, harmful to reproduc-tion or mutagenic shall not be used in the product. The associated risk phrases are notspecified in the current criteria; the risk phrases covering the mentioned hazardousproperties include:

R40 (limited evidence of a carcinogenic effect)R45 (may cause cancer)R46 (may cause heritable genetic damage)R49 (may cause cancer by inhalation)R60 (may impair fertility)R61 (may cause harm to the unborn child)R62 (possible risk of impaired fertility)R63 (possible risk of harm to the unborn child)R64 (may cause harm to breastfed babies)

The following ingredient is limited in concentration:

Phosphonates shall not exceed 0.5 g/wash.

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Ingredients fulfilling the criteria for classification as �very toxic to aquatic organisms�(N; R50) shall not exceed 10 g/wash.

Ingredients fulfilling the criteria for classification as �very toxic to aquatic organisms�and �may cause long-term adverse effects in the aquatic environment� (N; R50-53) shallnot exceed 0.25 g/wash.

New criterionCompared to the current criterion the main changes in the new criterion are the follow-ing:

• Specific substances are added to the list of ingredients that shall not be included, i.e.certain quaternary ammonium salts (see below), HHCB (1,3,4,6,7,8-hexahydro-4,6,6,7,8,8,-hexamethylcyclopenta(g)-2-benzopyran), AHTN (6-acetyl-1,1,2,4,4,7-hexamethyltetralin) and NTA (nitrilotriacetate).

• The inherent properties related to health hazards are being more precisely addressedby their associated risk phrases. The risk phrases for health and environmental haz-ards leading to exclusion of ingredients are extended and include: R68 (possiblerisks of irreversible effects), N, R50-53 (very toxic to aquatic organisms, may causelong-term adverse effects in the aquatic environment), N, R51/53 (toxic to aquaticorganisms, may cause long-term adverse effects in the aquatic environment) andR59 (dangerous to the ozone layer).

• A strict limit of documentation is defined as an operational approach to meet theintention that the specified ingredients or substances shall not at all be included inthe products (with the exception of phosphonates; see below). The applicant shalldocument that every ingredient or substance present in the product at ≥0.01% (w/w)fulfils the criterion on �dangerous, hazardous or toxic substances or preparations�.

• The amount of phosphonates in the product shall not exceed 0.5 g/wash.

The available data for the 41 laundry detergents marketed in Germany and Denmark didnot indicate the use of any ingredient which will be excluded from eco-labelled products(see revised criterion below). The phosphonates in one of the 41 products exceeded thelimit of 0.5 g/wash (Annex 2).


�(a) The following ingredients shall not be included in the product, either as part of theformulation or as part of any preparation included in the formulation:

• Alkyl phenol ethoxylates (APEOs) and derivatives thereof• Nitromusks and polycyclic musks, including e.g.:

• Musk xylene: 5-tert-butyl-2,4,6-trinitro-m-xylene• Musk ambrette: 4-tert�butyl-3-methoxy-2,6-dinitrotoluene• Moskene: 1,1,3,3,5-pentamethyl-4,6-dinitroindan• Musk tibetine: 1-tert-butyl-3,4,5-trimethyl-2,6-dinitrobenzene• Musk ketone: 4�-tert-butyl-2�,6�-dimethyl-3�,5�-dinitroacetaphenone

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• HHCB: 1,3,4,6,7,8-hexahydro-4,6,6,7,8,8,-hexamethylcyclopenta(g)-2-benzopyran

• AHTN: 6-acetyl-1,1,2,4,4,7-hexamethyltetralin

• EDTA (ethylenediamine tetraacetate)• NTA (nitrilotriacetate)

Assessment and verification. The applicant shall provide a declaration that theabove-listed substances have not been included in the product.

(b) Quaternary ammonium salts that are not readily biodegradable shall not be used.

Assessment and verification. The applicant shall provide the exact formulationof the product, together with documentation showing the biodegradability of anyquaternary ammonium salts used, and a declaration of compliance with this re-quirement.

(c) The total amount of phosphonates that are not readily biodegradable (aerobically)shall not exceed 0.5 g/wash at the recommended dosage.

Assessment and verification. The applicant shall provide the exact formulationof the product, together with documentation showing the biodegradability of anyphosphonates used, and a declaration of compliance with this requirement.

(d) No ingredient shall be included in the product that is classified or may be classi-fied as:

• R40 (limited evidence of a carcinogenic effect)• R45 (may cause cancer)• R46 (may cause heritable genetic damage)• R49 (may cause cancer by inhalation)• N; R50-53 (very toxic to aquatic organisms, may cause long-term adverse ef-

fects in the aquatic environment)• N; R51-53 (toxic to aquatic organisms, may cause long-term adverse effects in

the aquatic environment)• R59 (dangerous to the ozone layer)• R60 (may impair fertility)• R61 (may cause harm to the unborn child)• R62 (possible risk of impaired fertility)• R63 (possible risk of harm to the unborn child)• R64 (may cause harm to breastfed babies)• R68 (possible risks of irreversible effects)

or any combination thereof, according to Directive 67/548/EEC and its subse-quent amendments, or according to Directive 1999/45/EC of the European Par-liament and of the Council of 31 May 1999 concerning the approximation of thelaws, regulations and administrative provisions of the Member States relating tothe classification, packaging and labelling of dangerous preparations, and its sub-sequent amendments.

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Each substance or ingredient of any preparation used in the formulation that ex-ceeds 0.01% of the final product shall also meet the above requirements.

No preservatives shall be used that are or may be classified as R50-53, whatevertheir amount.

Assessment and verification. The exact formulation of the product shall be pro-vided to the Competent Body. Copies of the Material Safety Data Sheets shall beprovided for all ingredients (whether substances or preparations). A declaration ofcompliance with this criterion shall be provided by the applicant.

(e) The product shall not be classified as R43 (may cause sensitization by skin con-tact) according to Directive 1999/45/EC of the European Parliament and of theCouncil of 31 May 1999 concerning the approximation of the laws, regulationsand administrative provisions of the Member States relating to the classification,packaging and labelling of dangerous preparations.

Assessment and verification. The exact formulation of the product shall be pro-vided to the Competent Body, together with copies of the Material Safety DataSheets of each ingredient which shall indicate the relevant classification or lackthereof of each ingredient, and also a declaration of compliance with this criterion.

(f) Any ingredients added to the product as a fragrance shall have been manufacturedand/or handled following the code of practice of the International Fragrance Asso-ciation.

Assessment and verification. A declaration of compliance shall be provided.�

The new criteria harmonise the requirements for laundry detergents with the similar re-quirements in the criteria for all-purpose cleaners and cleaners for sanitary facilities (of27 June 2001) and for hand dishwashing detergents (of 19 July 2001).

Recommendation for the next revisionSome of the chelating agents that are used to replace phosphates in laundry detergentsmay possibly cause adverse effects in the aquatic environment. NTA, EDTA and most(if not all) phosphonates are not readily degradable and, especially the first two are sus-pected to remobilize metals from aquatic sediments. Whereas NTA is evaluated as pos-sibly carcinogenic to humans [IARC Monographs, Vol. 48, World Health Organization,Lyon, France] and a need is identified for limiting the risks of EDTA [EU Risk Assess-ment, Edetic acid (EDTA)], the reasons for limiting phosphonates in eco-labelled deter-gents are less obvious. Phosphonates have been reported to be very toxic to algae, butthe observed inhibition of growth may be caused by chelation of essential nutrients inthe test medium. It is recommended that the environmental properties of chelatingagents (like e.g. phosphonates, polycarboxylates) is considered in the next revision ofthe criteria.

5 OTHER CRITERIA

Other criteria are criteria regarding packaging and information to consumers.

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5.1 Packaging requirements

Overall packaging has a minor environmental impact. In the ad hoc working groupmeeting a number of views regarding the importance of packaging were presented. Theviews were varying from participants arguing for not having a criterion, in fact propos-ing to delete it, to other participants arguing that since packaging in the case of deter-gents is the first visual sight of the detergents it is very important to use that signal.Further, it was argued that producers of non-eco-labelled products use the packaging tosignal environmental superiority. All in all, these arguments brought the conclusion thatis a good idea to maintain criteria for packaging.

Until now, the detergents awarded with the EU eco-label are powder-based. During therevision period, the development demonstrated that liquid detergents are also able tomeet the existing packaging criteria. A survey of common detergents marketed withinthe EU showed that tablets are packed in such a way that they could not meet the exist-ing criteria. In fact, the amount of packaging needed per functional unit is more thantwice as much compared to the consumption of packaging for liquids and powders. Adoubling of the packaging needed per functional unit leads to a doubling of packagingwaste per functional unit and subsequently increased energy consumption and relatedemissions. Increased consumption of packaging leads to the reverse effect than the aimof the �Packaging and packaging waste directive� (Directive 91/689/EC). Increasedemission has an undesirable effect. Arguments for and against a deviation of the exist-ing criteria have been presented. On one hand, it was argued that there is absolutely nopositive effect on the environment by using detergents in the form of tablets, while onthe other hand, it was argued that it would lead to more variations and possibly more of-fers for the consumers if also tablet-based detergents could be awarded the EU eco-label. The conclusion reached opened for a special criterion directed towards tablet-based detergents.

Current criteriaThe current criteria were modified by inclusion of a new requirement to the weight ofthe primary packaging for tablets.

New criterionThe new criterion is described below:

�(a) If refills are not provided the weight of the total primary packaging shall not ex-ceed 1.7 g per wash.

Excepted is laundry detergent sold in the form of tablets where the weight of thetotal primary packaging shall not exceed 3.7 g per wash.

(b) If refills are provided the weight of the total primary packaging shall not exceed 7g/wash and the manufacturer shall provide refills. The weight of refill packagingshall not exceed 1.7 g per wash.

(c) The cardboard packaging shall consist of ≥80% recycled material.

(d) Plastic primary packaging shall be labelled according to ISO 1043.�

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Assessment and verification. The applicant shall supply a sample of the packaging, to-gether with a declaration indicating compliance with each part of this criterion. A cal-culation of the weight of primary packaging and a declaration regarding the percentageof recycled material shall be provided to the Competent Body. Primary packaging is asdefined in the European Parliament and Council Directive 94/62/EC of 20 December1994 on packaging and packaging waste.

Recommendation for the next revisionWhen the criteria are revised next time it is recommended to evaluate the amount ofpackaging needed per functional unit.

5.2 Consumer information

Information on the packagingThe information that shall be provided on the packaging of eco-labelled laundry deter-gents addresses the same issues as required in the current criteria and only minor lin-guistic improvements have been introduced.

The revised criteria prescribe that the following text (or equivalent) shall appear on or inthe packaging:

�ENVIRONMENTALLY SOUND WASHING MEANS:

• Pre-sort laundry (e.g. by colour, degree of soiling, type of fibre)• Wash with full load• Avoid using too much detergent, follow dosage instructions• Choose low-temperature washing cycles

Using this eco-labelled product and following these instructions will contribute to thereduction of water pollution, waste production and energy consumption. For more in-formation visit the EU eco-label website: http://europa.eu.int/ecolabel.�

More information on the detergent shall be made available on request. For this purpose,a sentence should appear on the packaging saying that if the consumer wants to knowmore about the detergent, he or she should contact the consumer department of thecompany or the retailer.

Dosage instructionThe dosage instruction in the revised criteria is also very similar to the current criteria.A new sentence with relation to the changes on washing performance of heavy duty liq-uid detergents has been introduced:

If the number of CPU in the washing performance test is higher than 24 the followingtext (or equivalent) should be enclosed: �Difficult stains need special treatment beforewash�.

Dosage recommendations shall appear on the product packaging, together with a rec-ommendation to the consumer to contact his water supplier or local authority in order tofind out the degree of hardness of his tap water.

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The recommended dosage shall be specified for �normally� and �heavily� soiled textilesand the various water hardness ranges relevant for the countries concerned and referredas appropriate to the weight of textile. If dosage instructions are given by way of dosagedevice, the volume of the device (in ml) should also appear clearly on the packaging.

In order to encourage the consumer to avoid using too much detergent and to follow thedosage instruction, a dosage device (cup) showing a scale of at least 10 ml steps shall beavailable on request if it is not included in the packaging.

The washing efficiency shall be indicated and relate to �normally soiled� and the variouswater hardness ranges considered.

The dosage recommendations between water hardness range 1 (soft) � �normally soiled�and the highest water hardness range (3 or 4) � �heavily soiled� may not differ by morethan a factor of 2.

The reference dosage used for the washing performance test and for assessment of com-pliance with the ecological criteria shall be the same as the recommended dosage for�normally soiled� and the water range corresponding to 2.5 mmol CaCO3/l in the Mem-ber State in which the test has been performed.

If only water hardness lower than 2.5 mmol CaCO3/l are included in the recommenda-tions, the maximum dosage recommended for �normally soiled� shall be lower than thereference dosage mentioned in the previous paragraph.

Information and labelling of ingredientsThe following groups of ingredients shall be labelled independently from their masscontent:

• Enzymes: indication of the type of enzymes (e.g. protease, lipase)• Preservation agents: characterisation and labelling according to IUPAC nomencla-

ture• Disinfectants: characterisation and labelling according to IUPAC nomenclature.

If the product contains perfumes, it shall be indicated on the packaging.

Assessment and verification. A sample of the product packaging shall be provided tothe Competent Body, together with a declaration of compliance with each part of thiscriterion.

6 PERFORMANCE TEST

The working group considered if it was possible to reduce the costs of the performancetests, e.g. by reducing the number of required washing cycles. However, a high level ofperformance was regarded to be important in order to develop the market for eco-labelled laundry detergents. The discussions in the ad hoc working group lead to theconclusion that it was necessary to adjust the required performance for liquid laundrydetergents, because liquids are important as light duty detergents and many of theseproducts do not pass the current performance test.

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The changes of the performance test method are described below:

1. The required levels of performance, expressed as Cleaning Performance Units(CPU) are changed to 36 CPU for heavy-duty liquid detergents (current require-ment: 24 CPU) and 18 CPU for light-duty liquid detergents (current requirement: 12CPU; raised from 10 CPU as a consequence of new reference detergent). The re-quired level of performance for heavy-duty powder detergents is defined at 24 CPUsimilar to the current requirement.

2. The measurement of Ganz Whiteness is omitted together with the associatedpass/fail criteria, because this parameter is only a measure of the effect of opticalbrighteners.

3. New values are assigned for Basic Degree of Whiteness of light duty detergents.The new main criterion is: �Product � Reference >2.0. In any case equal to or betterthan the original unwashed fabric�. This is a stricter criterion than the current one.The purpose of the new criterion is to ensure that the fabric appears as white as pos-sible, or as equal to as possible, compared with the original unwashed fabric in orderto avoid yellow or grey coloration of the textiles.

The revised performance test protocol �Award of the community ecolabel of laundrydetergents, Performance test of household detergents� is available as a separate docu-ment.

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A N N E X 1

Questionnaire

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Revision of the criteria for laundry detergents under the EU eco-labelling scheme

In relation to the ongoing revision of the laundry detergents criteria under the EU eco-labelling schemewe kindly ask you to spend 10 minutes in sharing your experiences with us in fulfilling the relevant partsof this questionnaire. The questions relate to the existing criteria/documentation and market aspects withthe purpose of clarifying possible barriers for the applicants as well as proposals for improvements.

Questionnaire

i) Name of your organisation:ii) Contact person:iii) E-mail address:

Do you have any practical experiences with the criteria document?__ Yes – please specify:_______ No

Section A: The existing criteria and documentation

A.1: The environmental criteria for ingredientsA.1.1. It is the impression that the dosage value (in gram chemical ingredients per wash) recommendedby the manufacturers is much lower for most of the laundry detergents on the market than the limit of 110g/wash which is prescribed as the maximum acceptable dosage value in the criteria. Should the valuesdescribing the dosage of chemical ingredients in the calculation matrix be reduced as an adaptation tothe dosages recommended for the products on the market today?__ Yes - why: ______ No - why not: ____

A.1.2 The ecological criteria for all-purpose cleaners and cleaners for sanitary facilities (adopted onJune 27th 2001) and for hand washing detergents (adopted on July 19th 2001) prescribe that surfactantsshall be biodegradable under anaerobic conditions. Would an adjustment in the criteria for surfactants inlaundry detergents be appropriate? In case which kind of adjustment would be suitable:__ Each surfactant used in the product shall be biodegradable under anaerobic conditions__ Low values of non-biodegradable organics, NBDO (aerobically and anaerobically), should be given ahigher weight in the calculation matrix__ The existing criteria shall be maintained, because:_____

A.1.3 In the existing criteria, a small amount of phosphates is allowed. Should phosphates be unaccept-able in the revised criteria?__ Yes – why: ______ No – why not: ____

A.1.4 Other comments related to the criteria: ____

A.2: The performance testA.2.1. How do you find the requirements related to the performance test?__ Too comprehensive in the following areas: ______ Suitable__ Incomplete in the following areas: ____

A.2.2. Which of the following two statements do you mainly agree with?__ A high level of requirements in the performance test with the corresponding price level should bemaintained to assure a high quality standard for the eco-labelled laundry detergents

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__ The requirements and the corresponding price level in the performance test should be modified to mo-tivate more manufacturers to apply for the eco-label

A.2.3. Other comments related to the performance test: ____

A.3. User’s ManualA.3.1 Do you have any practical experience with the User’s Manual?__ Yes__ No

If Yes – Please note any comments or suggestions to improve the User’s Manual: ____

Section B: Market aspects

B.1: Promotion of eco-labelled productsB.1.1. Have any activities been carried through or are there any planned activities in your country topromote eco-labelled products?

__ Yes, particularly for laundry detergents. Please specify:� responsible organisation(s), e.g government, consumer organisation, retailer,…:� type of activities:� target groups, e.g. private consumers, retailers, public purchasers etc.:� main (expected) results, e.g. awareness, higher market share etc.:� other comments:

__ Yes, eco-labelled products in general. Please indicate the main activities and the (expected) results:

__ No

B.2: Product testsSome consumer organisations or other organisations conduct product tests comparing the performanceof a number of parallel products to support the consumers in making a conscious choice when buyingthat type of products.

B.2.1. Are there any laundry detergents launched as “green” products (with or without an official eco-label) on your national market?__ Yes__ No

B.2.2. Have any product tests including environmental performance on laundry detergents on yournational market been conducted by an independent organisation?

__ Yes (a copy of the test results will be welcomed)__ No

B.2.3. Have the test results encouraged the sale of environmentally friendly laundry detergents?__ Yes__ No

B.2.4. Do you think that product tests potentially could be an important market tool for promoting eco-labelled products? Under which conditions?

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B.3: Market of eco-labelled detergentsB.3.1. What are in your opinion the reason(s) why relatively few laundry detergents are eco-labelled onthe European market?__ Low awareness among the consumers__ A substantial difference in price level between eco-labelled and non-labelled laundry detergents__ Low awareness among the purchasers and retailers__ The purchasers and retailers in general do not require eco-labelled products__ Low awareness among the producers__ Other

Please specify your answer:

B.3.2. By what means do you think the market share of eco-labelled products could be expanded? Pleasetick off what you think are the 3 most powerful means on the following list:__ General information campaign on eco-labelled products based on TV-spots, advertisements etc. di-rected

primarily towards the consumers (awareness raising)__ Promotion of eco-labelled products at mega events like the Olympic Games or World Championships__ Promotion of specific eco-labelled product groups in supermarkets etc.__ Carrying through of product tests including environmental aspects and dissemination of the results__ An EU Commission stand promoting eco-labelled products on the yearly Private Label Manufacturers

Association’s fair for public and private purchasers__ Fairs and exhibitions in general__ Requirements for including environmental aspects in all public procurements in the EU countries__ Campaign directed towards the manufacturers whenever (new) criteria are adopted__ Discussion on meetings in business forums__ Other:

B.3.3. Who do you think are the main contributors to the promotion of eco-labelled products? What couldyour own role be?

Section C: Comments

Please note any other comments or proposals you find relevant to be considered in relation to the revi-sion of the criteria for laundry detergents:

Thank you for taking time to answer the questions. Please return the questionnaire to Birgitte Bo,dk-TEKNIK ENERGY & ENVIRONMENT, by e-mail ([email protected]) no later than Nov. 9th, 2001.

mailto:[email protected]

ERA/2003.05.14 27

A N N E X 2

Inherent environmental properties oflaundry detergents formulations

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Table A.2.1 Inherent environmental properties of laundry detergent formulations

Ecological criteria 2Product 1

TC II CDV Phosphates AnaerobicBiodeg

Dangeroussubstances

DK 1 (powder) 50-75 10-20 <1500 15-20 -* PassDK 2 (powder) 50-75 10-20 <1500 0 -* PassDK 3 (powder) 50-75 <10 <1500 0 -* PassDK 4 (powder) 50-75 10-20 <1500 15-20 -* PassDK 5 (powder) 50-75 <10 <2000 20-25 -* PassDK 6 (powder) 75-100 10-20 <1500 20-25 Pass PassDK 7 (powder) 75-100 10-20 <1500 20-25 Pass PassDK 8 (powder) 50-75 <10 <1500 15-20 -* PassDK 9 (powder) 50-75 0 <1500 10-15 Pass PassDK 10 (powder) 50-75 10-20 <1500 0 Pass PassDK 11 (powder) 75-100 0 <1500 10-15 Pass PassDK 12 (powder) 50-75 <10 <2000 <10 -* PassDK 13 (powder) 50-75 <10 <3000 <10 -* PassDK 14 (liquid) 25-50 0 <4500 <10 Pass PassDK 15 (powder) >100 0 >4500 20-25 -* PassDK 16 (powder) >100 0 <4500 >25 -* PassDK 17 (powder) 75-100 10-20 <3500 0 Fail PassDK 18 (powder) 50-75 20-30 <2500 0 Fail PassDK 19 (powder) 75-100 0 <2500 0 Fail PassDK 20 (powder) >100 20-30 <3000 0 Fail Fail*DK 21 (powder) >100 0 <4500 >25 -* PassDK 22 (powder) >100 20-30 <4500 0 -* PassDK 23 (powder) 75-100 20-30 <1000 0 Pass PassDK 24 (liquid) 25-50 0 <1500 <10 Pass PassDK 25 (liquid) 25-50 0 <3500 0 Pass PassD 1 (tablet) 50-75 10-20 <3000 0 Fail PassD 2 (tablet) 50-75 <10 <3000 0 Fail 0,3D 3 (tablet) 50-75 10-20 <3000 0 Fail Fail*D 4 (tablet) 50-75 20-30 <2500 0 Fail PassD 5 (tablet) 50-75 10-20 <4000 0 Fail PassD 6 (powder) 50-75 10-20 <3500 0 Fail PassD 7 (powder) 50-75 20-30 <2000 0 Fail PassD 8 (powder) 50-75 20-30 <3500 0 Fail PassD 9 (powder) 50-75 10-20 <2000 0 Pass PassD 10 (powder) 50-75 10-20 <2500 0 Fail PassD 11 (powder) 50-75 20-30 <3500 0 Fail PassD 12 (powder) 50-75 20-30 <2500 0 Fail PassD 13 (powder) 75-100 >30 <3500 0 Fail PassD 14 (powder) 75-100 20-30 <4000 0 Fail PassD 15 (powder) 50-75 20-30 <2500 0 Pass PassD 16 (powder) 75-100 10-20 <3500 0 Fail Pass

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Notes:1 Products: DK1-DK25, formulations received from Danish manufacturers; D1-D16, frame formulations

received from Umwelt Bundes Amt, Germany. Detailed product data are not disclosed, but such datawere used for calculations and assessments.

2 Explanation to ecological criteria:Criterion 1. TC, total chemicals (pass: ≤100 g/wash);Criterion 2. II, insoluble inorganic ingredients (pass: ≤30 g/wash);Criterion 3. CDV, critical dilution volume toxicity (pass: ≤4500 l/wash);Criterion 4. Phosphates (pass: ≤25 g/wash);

Criterion 5. Anaerobic biodegradability,Pass all surfactants in product confirmed biodegradable (in DID-list)Fail one/more surfactants confirmed non-biodegradable (in DID-list)-* no available data confirming anaerobic degradability of one/more surfactants

Criterion 6. Dangerous substances,* total amount of phosphonates exceeds 0.5 g/wash

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A N N E X 3

Anaerobic biodegradability of surfactants

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A N N E X 4

Revised ecological criteria for laundry detergents

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EN

COMMISSION DECISION

of

establishing revised ecological criteria for the award of the Community eco-label to laundry deter-gents and amending Decision 1999/476/EC

(Text with EEA relevance)

THE COMMISSION OF THE EUROPEAN COMMUNITIES,

Having regard to the Treaty establishing the European Community,

Having regard to Regulation (EC) No 1980/2000 of the European Parliament and of the Council of 17July 2000 on a revised Community eco-label award scheme1, and in particular the second subparagraph ofArticle 6(1) thereof,

Whereas:

(1) Under Regulation (EC) No 1980/2000 the Community eco-label may be awarded to a productpossessing characteristics which enable it to contribute significantly to improvements in relationto key environmental aspects.

(2) Regulation (EC) No 1980/2000 provides that specific eco-label criteria are to be established ac-cording to product groups.

(3) It also provides that the review of the eco-label criteria, as well as of the assessment and verifica-tion requirements related to the criteria, is to take place in due time before the end of the period ofvalidity of the criteria specified for each product group.

(4) It is appropriate to revise the ecological criteria that were established by Commission Decision1999/476/EC of 10 June 1999 establishing ecological criteria for the award of the Communityeco-label to laundry detergents2 in order to reflect the developments in the market. At the sametime, the period of validity of that Decision as extended by Decision 2002/172/EC3 and the defi-nition of the product group should be modified.

(5) A new Decision should be adopted establishing the specific ecological criteria for this productgroup, which will be valid for a period of 5 years.

1 OJ L 237, 21.9.2000, p. 1.2 OJ L 187, 20.7.1999, p. 523 OJ L 56, 27.2.2002, p. 32.

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(6) It is appropriate that, for a limited period of not more than eighteen months, both the new criteriaand the criteria established by Decision 1999/476/EC should be valid concurrently, in order toallow sufficient time for companies that have been awarded or that have applied for the award ofthe eco-label for their products prior to the date of application of this Decision to adapt thoseproducts to comply with the new criteria.

(7) The measures provided for in this Decision are based on the draft criteria developed by the Euro-pean Union Eco-Labelling Board established under Article 13 of Regulation (EC) No 1980/2000.

(8) The measures provided for in this Decision are in accordance with the opinion of the Committeeinstituted by Article 17 of Regulation (EC) No 1980/2000,

HAS ADOPTED THIS DECISION:

Article 1

In order to be awarded the Community eco-label under Regulation (EC) No 1980/2000, a laundry deter-gent must fall within the product group �laundry detergents� as defined in Article 2, and must complywith the ecological criteria set out in the Annex to this Decision.

Article 2

The product group �laundry detergents� shall comprise all laundry detergents, in powder, liquid or anyother form, for the washing of textiles, and which are intended to be used principally in household ma-chines, but not excluding the use in launderettes and common laundries

Article 3

For administrative purposes the product group code number assigned to this product group shall be �6�.

Article 4

Article 3 of Decision 1999/476/EC is replaced by the following:

“Article 3

The product group definition and the specific ecological criteria for the product group shall be valid until31 August 2004.�

Article 5

This Decision shall apply from 1 March 2003 until 29 February 2008.

Producers of products falling within the product group �laundry detergents� which have already beenawarded the eco-label before 1 March 2003 may continue to use that label until 31 August 2004.

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Producers of products falling within the product group �laundry detergents� which have already appliedfor the award of the eco-label before 1 March 2003 may be awarded the eco-label under the terms Deci-sion 1999/476/EC. In these cases the label may be used until 31 August 2004.

Article 6

This Decision is addressed to the Member States.

Done at Brussels,[]

For the CommissionMargot WALLSTRÖMMember of the Commission

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ANNEX

FRAMEWORK

The aims of the criteria

These criteria aim in particular at promoting:

� Savings of transport and energy by favouring compact laundry detergents

� Reduction of water pollution by reducing the volume of total chemicals used in the products andby limiting the use of potentially hazardous ingredients

� The minimisation of waste production by reducing the amount of primary packaging.

Additionally, the criteria enhance the consumers� environmental awareness. The criteria are set at levelsthat promote the labelling of laundry detergents that have a low environmental impact.

Assessment and verification requirements

The specific assessment and verification requirements are indicated within each criterion.

Where the applicant is required to provide declarations, documentation, analyses test reports, or otherevidence to show compliance with the criteria, it is understood that these may originate from the applicantand/or his supplier(s) and/or their supplier(s), et cetera, as appropriate.

Where possible, the testing should be performed by laboratories that meet the general requirements of ENISO 17025 or equivalent.

Where appropriate, test methods other than those indicated for each criterion may be used if the Compe-tent Body assessing the application accepts their equivalence.

The concentration of ingredients in the product, which implies a requirement for documentation of com-pliance with the ecological criteria, is generally defined at > 0.1 % by weight of the preparation. Thisconcentration is defined at > 0.01 % by weight of the preparation for the criterion on dangerous, hazard-ous or toxic substances or preparations.

Appendix IA. presents the detergent ingredient database (DID list) which contains the most widely usedingredients used in detergent formulations. It shall be used for deriving the data for the calculations ofCDVtox and for the assessment of the biodegradability of surfactants.

Where appropriate, the applicant may use subsequent revisions of the Detergent Ingredient Database asthey become available.

For ingredients which are not included in the DID list, the applicant shall, under his own responsibility,find the appropriate values for the relevant parameters by using the approach described in Appendix IB.

For ingredients, which are not listed in the DID-list, the applicant may use an approach to provide thenecessary documentation of anaerobic degradability described in Appendix IC

Where appropriate, Competent Bodies may require supporting documentation and may carry out inde-pendent verifications.

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The Competent Bodies are recommended to take into account the implementation of recognised environ-mental management schemes, such as EMAS or ISO14001, when assessing applications and monitoringcompliance with the criteria (note: it is not required to implement such management schemes.).

Functional unit and reference dosage

The functional unit is expressed in g/wash (grams per wash). For heavy-duty detergents this is related tothe dosage per 4.5 kg load (dry textiles) and for low-duty detergents to the dosage per 2.5 kg load (drytextiles) in the washing machine. The dosage recommended by the manufacturer to consumers for thewater hardness of 2.5 mmol CaCO3/l and �normally soiled� textiles is taken as the reference dosage forthe calculation of the ecological criteria, and the test of washing performance. If the water hardness of 2.5mmol CaCO3/l is not relevant in the Member States in which the detergent is marketed, the applicant shallspecify the dosage used as the reference.

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CRITERIA

1. Total chemicals

Total chemicals are the recommended dosage in g/wash minus the water content.

The amount of total chemicals shall not exceed 100 g/wash.

Assessment and verification: The exact formulation of the product shall be provided to the CompetentBody, together with the details of the calculations showing compliance with this criterion.

2. Insoluble inorganic ingredients

The total amount of insoluble inorganic ingredients at the recommended dosage shall be less than 30g/wash

Assessment and verification: The exact formulation of the product shall be provided to the CompetentBody, together with the details of the calculations showing compliance with this criterion

3. Toxicity to aquatic organisms

The critical dilution volume toxicity (CDVtox) is calculated for each ingredient (i) using the followingequation:

1000(i) LTE

(i) LF(i)weight i)t (ingredien CDVtox ⋅⋅=

where weight (i) is the weight of the ingredient per recommended dose, LF is the loading factor and LTEis the long-term toxicity effect concentration of the ingredient.

The values of the LF and LTE parameters shall be as given in the detergent ingredient database list (DIDlist) in Appendix 1A. If the ingredient in question is not included in the DID list, the applicant shall esti-mate their values following the approach described in Appendix 1B. The CDVtox is summed for each in-gredient, making the CDVtox for the product:

CDVtox= Σ CDVtox(ingredient)

The CDVtox of the recommended dosage shall not exceed 4500 l/wash.

Assessment and verification: The exact formulation of the product shall be provided to the CompetentBody, together with the details of the CDVtox calculations showing compliance with this criterion.

4. Phosphates

The total amount of phosphates (as sodium tripolyphosphate - STPP) at the recommended dosage shallnot exceed 25 g /wash.

Assessment and verification: The exact formulation of the product shall be provided to the CompetentBody, together with the details of the calculations showing compliance with this criterion.

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5. Biodegradability of surfactants

(a) Ready biodegradability (aerobic)

Each surfactant used in the product shall be readily biodegradable.

Assessment and verification: The exact formulation of the product shall be provided to the CompetentBody. The DID list (see Appendix IA) indicates whether a specific surfactant is aerobically biodegradableor not (i.e. those that have an entry of ‘Y’ in the column on aerobic non-biodegradability shall not beused). For surfactants which are not included in the DID list, the relevant information from literature orother sources, or appropriate test results, showing that they are aerobically biodegradable shall be pro-vided. The tests for ready biodegradability shall be as referred to in Council Directive 67/548/EEC of 27June 1967 on the approximation of laws, regulations and administrative provisions relating to the classi-fication, packaging and labelling of dangerous substances4, and its subsequent amendments, in particularthe methods detailed in Annex V.C4, or their equivalent OECD 301 A-F test methods, or their equivalentISO tests. The 10 days window principle shall not apply. The pass levels shall be 70% for the tests re-ferred to in Annex V.C4-A and C4-B of Directive 67/548/EEC (and their equivalent OECD 301 A and Etests and ISO equivalents), and shall be 60% for tests C4-C, D, E and F (and their equivalent OECD 301B, C, D and F tests and ISO equivalents).

(b) Anaerobic biodegradability

Each surfactant used in the product shall be anaerobically biodegradable.

Assessment and verification: The exact formulation of the product shall be provided. The DID list (seeAppendix IA) indicates whether a specific surfactant is anaerobically biodegradable or not (i.e. those thathave an entry of ‘Y’ in the column on anaerobic biodegradability shall not be used). For surfactantswhich are not included in the DID list, the relevant information from literature or other sources, or ap-propriate test results, showing that they are anaerobically biodegradable shall be provided. The refer-ence test for anaerobic degradability shall be ISO 11734, ECETOC No. 28 (June 1988) or an equivalenttest method, with the requirement of 60% ultimate degradability under anaerobic conditions. Test meth-ods simulating the conditions in a relevant anaerobic environment may also be used to document that60% ultimate degradability has been attained under anaerobic conditions (see Appendix IC).

6. Dangerous, hazardous or toxic substances or preparations

(a) The following ingredients shall not be included in the product, either as part of the formulationor as part of any preparation included in the formulation:

� alkyl phenol ethoxylates (APEOs) and derivatives thereof� nitromusks and polycyclic musks, including e.g.:

� musk xylene: 5-tert-butyl-2,4,6-trinitro-m-xylene� musk ambrette: 4-tert�butyl-3-methoxy-2,6-dinitrotoluene� moskene: 1,1,3,3,5-pentamethyl-4,6-dinitroindan� musk tibetine: 1-tert-butyl-3,4,5-trimethyl-2,6-dinitrobenzene� musk ketone: 4�-tert-butyl-2�,6�-dimethyl-3�,5�-dinitroacetaphenone� HHCB:1,3,4,6,7,8-hexahydro-4,6,6,7,8,8,-hexamethylcyclopenta(g)-2-benzopyran� AHTN: 6-acetyl-1,1,2,4,4,7-hexamethyltetralin

� EDTA (ethylenediamine tetraacetate)� NTA (nitrilotriacetate)

4 OJ L 196, 16.8.1967, p. 1.

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Assessment and verification: The applicant shall provide a declaration that the above-listed substanceshave not been included in the product.

(b) Quaternary ammonium salts that are not readily biodegradable shall not be used.

Assessment and verification: The applicant shall provide the exact formulation of the product, togetherwith documentation showing the biodegradability of any quaternary ammonium salts used, and a decla-ration of compliance with this requirement.

(c) The total amount of phosphonates that are not readily biodegradable (aerobically) shall not ex-ceed 0.5 g/wash at the recommended dosage.

Assessment and verification: The applicant shall provide the exact formulation of the product, togetherwith documentation showing the biodegradability of any phosphonates used, and a declaration of com-pliance with this requirement.

(d) No ingredient shall be included in the product that is classified or may be classified as:

� R40 (limited evidence of a carcinogenic effect),� R45 (may cause cancer),� R46 (may cause heritable genetic damage),� R49 (may cause cancer by inhalation),� R50-53 (very toxic to aquatic organisms, may cause long-term adverse effects in the

aquatic environment),� R51-53 (toxic to aquatic organisms, may cause long-term adverse effects in the aquatic

environment),� R59 (dangerous to the ozone layer),� R60 (may impair fertility),� R61 (may cause harm to the unborn child),� R62 (possible risk of impaired fertility),� R63 (possible risk of harm to the unborn child),� R64 (may cause harm to breastfed babies),� R68 (possible risks of irreversible effects),

or any combination thereof, according to Directive 67/548/EEC and its subsequent amendments, or ac-cording to Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 con-cerning the approximation of the laws, regulations and administrative provisions of the Member Statesrelating to the classification, packaging and labelling of dangerous preparations5, and its subsequentamendments.

Each substance or ingredient of any preparation used in the formulation that exceeds 0.01% of the finalproduct shall also meet the above requirements.

No preservatives shall be used that are or may be classified as R50-53, whatever their amount.

Assessment and verification: The exact formulation of the product shall be provided to the CompetentBody. Copies of the Material Safety Data Sheets shall be provided for all ingredients (whether substancesor preparations). A declaration of compliance with this criterion shall be provided by the applicant.

(e) The product shall not be classified as R43 (may cause sensitization by skin contact) according to Di-rective 1999/45/EC of the European Parliament and of the Council of 31 May 1999 concerning the ap-proximation of the laws, regulations and administrative provisions of the Member States relating to theclassification, packaging and labelling of dangerous preparations.

5 OJ L 200, 30.7.1999, p. 1.

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Assessment and verification: The exact formulation of the product shall be provided to the CompetentBody, together with copies of the Material Safety Data Sheets of each ingredient which shall indicate therelevant classification or lack thereof of each ingredient, and also a declaration of compliance with thiscriterion.

(f) Any ingredients added to the product as a fragrance shall have been manufactured and/or han-dled following the code of practice of the International Fragrance Association.

Assessment and verification: A declaration of compliance shall be provided.

7. Purity of enzymes

The enzyme production micro-organism shall be absent from the final enzyme preparation

Assessment and verification: A test report or certificate from the enzyme producer shall be provided tothe Competent Body.

8. Packaging requirements

(a) If refills are not provided, the weight of the total primary packaging shall not exceed 3.7 g perwash for tablets and 1.7 g per wash for all other products.

(b) If refills are provided the weight of total primary packaging shall not exceed 7 g per wash andthe manufacturer shall provide refills. The weight of refill packaging shall not exceed 1.7 g perwash.

(c) The cardboard packaging shall consist of ≥80% recycled material.

(d) Plastic primary packaging shall be labelled according to ISO 1043.

Assessment and verification: The applicant shall supply a sample of the packaging, together with a dec-laration indicating compliance with each part of this criterion. A calculation of the weight of primarypackaging and a declaration regarding the percentage of recycled material shall be provided to theCompetent Body. Primary packaging is as defined in the European Parliament and Council Directive94/62/EC of 20 December 1994 on packaging and packaging waste6.

9. Washing performance

The product shall be compared in its washing performance with reference detergents of the same typeaccording to the EU eco-detergents performance test �Award of the EU eco-label to laundry detergents:performance test of household detergents� (version 4 December 2002 and its subsequent amendments).

Assessment and verification: The applicant shall provide a test report indicating that the product fulfilsthe minimum requirements defined in this test.

6 OJ L 365, 31.12.1994, p. 10.

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10. Consumer information

(a) Information on the packaging

The following text (or equivalent) shall appear on or in all eco-labelled products within the productgroup:

�ENVIRONMENTALLY SOUND WASHING MEANS:

� Pre-sort laundry (e.g., by colour, degree of soiling, type of fibre)

� Wash with full load

� Avoid using too much detergent, follow dosage instructions

� Choose low-temperature washing cycles

Using this eco-labelled product and following these instructions will contribute to the reduction of waterpollution, waste production and energy consumption. For more information visit the EU eco-label web-site: http://europa.eu.int/ecolabel.�

More information on the detergent shall be made available on request. For this purpose, a sentence shallappear on the packaging saying that if the consumer wants to know more about the detergent, he or sheshould contact the consumer department of the company or the retailer.

(b) Dosage instructions

If the number of CPU in the washing performance test is higher than 24 the following text (or equivalent)shall be enclosed: �Difficult stains need special treatment before washing�.

Dosage recommendations shall appear on the product packaging, together with a recommendation to theconsumer to contact his water supplier or local authority in order to find out the degree of hardness of histap water.

The recommended dosages shall be specified for �normally� and �heavily� soiled textiles and the variouswater hardness ranges relevant for the countries concerned and referred as appropriate to the weight oftextile. If dosage instructions are given by way of dosage device, the volume of the device (in ml) shouldalso appear clearly on the packaging.

In order to encourage the consumer to avoid using too much detergent and to follow the dosage instruc-tion, a dosage device (cup) showing a scale of at least 10 ml steps shall be available on request if it is notincluded in the packaging.

The washing efficiency shall be indicated and relate to �normally soiled� and the various water hardnessranges considered.

The dosage recommendations between water hardness range 1 (soft) � �normally soiled� and the highestwater hardness range (3 or 4) � �heavily soiled� may not differ by more than a factor of 2.

The reference dosage used for the washing performance test and for assessment of compliance with theecological criteria on ingredients shall be the same as the recommended dosage for �normally soiled� andthe water hardness corresponding to 2.5 mmol CaCO3/l in the Member State in which the test has beenperformed.

http://europa.eu.int/ecolabel�

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If only water hardness lower than 2.5 mmol CaCO3/l are included in the recommendations, the maximumdosage recommended for �normally soiled� shall be lower than the reference dosage mentioned in theprevious paragraph.

(c) Information and labelling of ingredients

Commission recommendation 89/542/EEC of 13 September 1989 concerning the labelling of detergentsand cleaning agents7 shall be applied.

The following groups of ingredients shall be labelled independently from their mass content:

� Enzymes: indication of the type of enzymes (e.g. protease, lipase).

� Preservation agents: characterisation and labelling according to IUPAC nomenclature.

� Disinfectants: characterisation and labelling according to IUPAC nomenclature.

If the product contains perfumes, it shall be indicated on the packaging.

Assessment and verification: A sample of product packaging shall be provided to the Competent Body,together with a declaration of compliance with each part of this criterion.

11. Information appearing on the eco-label

Box 2 of the eco-label shall contain the following text:

* Helps reduce water pollution

* Helps reduce resource consumption

Assessment and verification: The applicant shall provide a sample of the product packages showing thelabel, together with a declaration of compliance with this criterion.

7 OJ L 291, 10.10.1989, p. 53

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AP P E N D I X I .A.DID-LIST

DETERGENTS INGREDIENTS DATABASE AND APPROACH TO BE FOLLOWED FOR INGREDIENTS NOT LISTED IN THE DATABASE

A. The data given below on the most commonly used detergent ingredients shall be used for the calculation of the ecological criteria.(Note: the parameters a NBO, SI, II, THOD as well as the CF-Factors for an NBO are not used within this product group)

Detergent Ingredients Database (DID-list; version 29.09.98)

DID Ingredients Toxicity Loading Anaerobic Non-Bio- Aerobic Non-Bio- Soluble Insoluble

No NOEC measured

LTE Factor (LF) degradable (an NBO) degradable (a NBO) Inorganics (SI) Inorganics ( II) THOD

Anionic surfactants 1 C 10-13 LAS (Na ø 11.5-11.8, C14<1 %) 0.3 0.3 0.05 Y, CF = 0.75 O O O 2.3

2 other LAS (C14 > 1 %) 0.12 0.12 0.05 Y, CF = 1.5 O O O 2.3

3 C 14/17 Alk. Sulfonate 0.27 0.27 0.03 Y, CF = 0.75 O O O 2.5

4 C 8/10 Alkylsulfate EC50= 2.9 0.15 0.02 O O O O 1.9

5 C 12-15 AS 0.1 0.1 0.02 O O O O 2.2

6 C 12-18 AS LC50 = 3 0.15 0.02 O O O O 2.3

7 C 16/18 FAS 0.55 0.55 0.02 O O O O 2.5

8 C 12-15 A 1-3 EO sulphate 0.15 0.15 0.03 O O O O 2.1

9 C 16/18 A 3-4 EO sulphate no valid data 0.1 0.03 O O O O 2.2

10 C 8 �Dialkylsulfosuccinate LC50 = 7.5 0.4 0.5 Y, CF = 1.5 O O O 2

11 C 12/14 sulpho-fat.-acid methylester EC50 = 5 0.25 0.05 Y, CF = 0.75 O O O 2.1

12 C 16/18 sulpho-fat.-acid methylester 0.15 0.15 0.05 Y, CF = 0.75 O O O 2.3

13 C 14/16 alpha olefine sulphonate LC50 = 2.5 0.13 0.05 Y, CF = 0.75 O O O 2.3

14 C 14-18 alpha olefine sulphonate LC50 = 1.4 0.07 0.05 Y, CF = 2.0 O O O 2.4

15 SOAPS (C12 - 22) EC0 = 1.6 1.6 0.05 O O O O 2.9

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No NOEC measured


Nonionic surfactants 16 C 9/11 A >3-6 EO lin. or mono br. EC50=3.3 0.7 0.03 O O O O 2.4

17 C 9/11 A > 6-9 EO lin. or mono br. EC50=5.4 1.1 0.03 O O O O 2.2

18 C 12-15 A 2-6 EO lin. or mono br. 0.18 0.18 0.03 O O O O 2.5

19 C 12-15 (Avg. C<14) A >6-9 EO lin. or mono br. 0.24 0.24 0.03 O O O O 2.3

20 C 12-15 (Avg. C>14) A >6-9 EO 0.17 0.17 0.03 O O O O 2.3

21 C 12-15 A >9-12 EO LC50 = 0.8 0.3 0.03 O O O O 2.2

22 C 12-15 A 20-30 EO EC50 = 13 0.65 0.05 O O O O 2

23 C 12-15 A > 30 EO LC50 = 130 6.5 0.75 O Y O O 0*

24 C 12/18 A 0-3 EO no data 0.01 0.03 O O O O 2.9

25 C 12-18 A 9 EO 0.2 0.2 0.03 O O O O 2.4

26 C 16/18 A 2-6 EO 0.03 0.03 0.03 O O O O 2.6

27 C 16/18 A > 9-12 EO LC50 = 0.5 0.05 0.03 O O O O 2.3

28 C 16/18 A 20-30 EO EC50 = 18 0.36 0.05 O O O O 2.1

29 C 16/18 A > 30 EO LC50 = 50 2.5 0.75 O Y O O 0*

30 C 12/14 Glucose Amide 4.3 4.3 0.03 O O O O 2.2

31 C 16/18 Glucose Amide 0.116 0.116 0.03 O O O O 2.5

32 C 12/14 Alkylpolyglucoside 1 1 0.03 O O O O 2.3

Amphoteric surfactants

33 C 12-15 Alkyl dimethylbetaine 0.03 0.03 0.05 Y, CF= 2.5 O O O 2.9

34 C12-18 Alkyl amidopropylbetaine 0.03 0.03 0.05 Y,CF = 2.5 O O O 2.8

Sud controllers

35 Silicone EC0 = 241 4.82 0.4 Y,CF = 0.75 Y O O 0.0

36 Paraffin no data 100 0.4 O Y O O 0*

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No NOEC measured


Fabric Softening

37 Glycerol LC50 > 5-10 gl 1000 0.13 O O O O 1.2

Builders

38 Phosphate as Sodium-tri-polyphosphate (STPP) 1000 0.6 O O Y O 0.0

39 Zeolite A 120 120 0.05 O O O Y 0.0

40 Citrate EC50 = 85 85 0.07 O O O O 0.6

41 Polycarboxylates and related derivates 124 124 0.4 Y, CF = 0.1 Y O O 0*

42 Clay 1000 0.05 O O O Y 0.0

43 Carbonate /bicarbonate LC50 = 250 250 0.8 O O Y O 0.0

44 Fatty acid (C >14) EC0=1.6 1.6 0.05 O O O O 2.9

45 Silicate / disilicate EC50 > 1000 1000 0.8 O O Y O 0.0

46 NTA 19 19 0.13 O O O O 0.6

47 Polyaspartic acid. Na salt 125 12.5 0.13 Y, CF=0.1 O O O 1.2

Bleaching

48 Perborate mono (as borate) 1 - 10 6 1 O O Y O 0.0

49 Perborate tetra (as borate) 1 - 10 6 1 O O Y O 0.0

50 Percarbonate (see carbonate) LC50 = 250 250 0.8 O O Y O 0.0

51 TAED EC0 = 500 EC0 = 500 0.13 O O O O 2.0

Solvents

52 C 1- C 4 alcohols LC50 = 8000 100 0.13 O O O O 2.3

53 Monoethanolamine 0.78 0.78 0.13 O O O O 2.4

54 Diethanolamine 0.78 0.78 0.13 O O O O 2.3

55 Triethanolamine 0.78 0.78 0.13 O O O O 2

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No NOEC measured


Miscellaneous

56 Polyvinylpyrrolidon (PVP / PVNO / PVPVI) EC50 > 100 100 0.75 Y, CF = 0.1 Y O O 0*

57 Phosphonates 7.4 7 0.4 Y, CF = 0.5 Y O O 0*

58 EDTA LOEC = 11 11 1 Y, CF = 0.1 Y O O 0*

59 CMC LC50 > 250 250 0.75 Y, CF = 0.1 Y O O 0*

60 Na Sulphate EC50 = 2460 1000 1 O O Y O 0.0

61 Mg Sulphate EC50 = 788 800 1 O O Y O 0.0

62 Na Chloride EC50 = 650 650 1 O O Y O 0.0

63 Urea LC50>10000 100 0.13 O O O O 2.1

64 Maleic acid LC50 = 106 2.1 0.13 O O O O 0.8

65 Malic acid LC50 = 106 2.1 0.13 O O O O 0.6

66 Ca formiate 100 0.13 O O O O 2.0

67 Silica 100 0.05 O O O Y 0.0

68 High MW polymers PEG > 4000 100 0.4 O Y O O 0*

69 Low MW polymers PEG < 4000 100 0.13 O O O O 1.1

70 Cumene Sulfonate LC50 = 66 6.6 0.13 Y, CF = 0.25 O O O 1.7

71 Xylene Sulfonate LC50 = 66 6.6 0.13 Y, CF = 0.25 O O O 1.6

72 Toluene Sulfonates LC50 = 66 6.6 0.13 Y, CF = 0.25 O O O 1.4

73 Na-/Mg-/KOH 100 1 O O Y O 0.0

74 Enzymes LC50 = 25 25 0.13 O O O O 2.0

75 Perfume formulation as used LC50 = 2-10 0.02 0.1 Y, CF = 3.0 Y O O 0*

76 Dyes LC50 = 10 0.1 0.4 Y, CF = 3.0 Y O O 0*

77 Starch no data 250 0.1 O O O O 0.97

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No NOEC measured


78 Zn Phthalocyanine Sulfonate 0.16 0.016 0.07** Y, CF=2.5 Y O O 0*

79 Anionic Polyester (Soil release polymer) EC50=310 310 0.4 Y,CF=0.1 Y O O 0*

80 Iminodisuccinate 23 2.3 0.13 Y,CF=0.25 O O O 1.1

Optical brighteners = FWA

81 FWA 1 1 LC0 = 10 1.0 0.4 Y, CF = 1.5 Y O O 0*

82 FWA 5 2 3.13 3.13 0.4 Y, CF = 0.5 Y O O 0*

Additional ingredients

83 Alkyl Aminoxides (C12-18) 0.08 0.08 0.05 Y,CF = 2.5 O O O 3.2

84 Glycereth (6-17EO) cocoate EC50=32 1.6 0.05 O O O O 2.1

85 Phosphate esters (C12-18) EC50=38 1.9 0.05 Y,CF = 0.25 O O O 2.3

1 FWA 1 = Disodium 4.4-bis (4-anilino-5-morpholino-1,3,5-triazin-2-yl)amino stilbene-2.2-disulfonate2 FWA 5 = Disodium 4.4-bis(2-sulfostryryl)biphenyl0* THOD for aerobically non degradable organic substances is set to zero.** rapid photodegradation

Notes:Y = yes, criterion applies NOEC = non observed effect concentrationO = no, criterion does not apply CF = correction factor for anaerobic non degradable organic substancesLTE = long term effect concentration THOD = Theoretical oxygen demand

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AP P E N D I X I .B

The following approach applies, as appropriate in the case of ingredients that are not listed on the DID-list

Aquatic toxicity

The lowest validated long-term effect (LTE) data on fish, daphnia magna or algae should be consideredfor the calculation of the critical dilution volume criterion (toxicity).

In cases where data on homologues and/or QSARs (Quantitative Structure Activity Relationships) areused, a correction could be considered for the finally selected LTE data.

In the absence of LTE data the following procedure has to be applied in order to estimate the LTE data byusing the specified uncertainty factor (UF) on the data of the most sensitive species:

Non surfactants

DATA AVAILABLE UF TO BE USED

At least 2 acute LC50 on fish or daphnia or algae 100

1 NOEC on fish or daphnia or algae 10

2 NOEC on fish or daphnia or algae 5

3 NOEC on fish, daphnia or algae 1

Take lowest validated NOEC

Deviation from this rule may be admitted if evidence can be provided that lower factors or data can bescientifically justified. NOEC is the No Observed Effect Concentration (in a chronic toxicity test).

Surfactants

DATA AVAILABLE UF TO BE USED

At least 2 NOECs on fish or daphnia or algae 1 (lowest NOEC)

1 NOEC on fish or daphnia or algae 1 (NOEC-if species is most sensitive in acute toxic-ity)

10 (NOEC-if species is not the most sensitive inacute toxicity)

3 LC50 on fish or daphnia or algae 20 (lowest LC50)

At least 1 LC50 on fish, daphnia or algae 50 (lowest LC50)

or 20 in specific cases (see below)

In the last case referred to above, an uncertainty factor of 20 may be used instead of 50 only if 1-2L(E)C50 (LC 50 in case of fish toxicity, EC50 in case of daphnia or algal toxicity) data are available and ifit can be concluded from the information for other compounds that the most sensitive species have beentested. Such a rule can be applied only within a group of homologues. It should be emphasised that theLTEs (long-term effects) used must be consistent within a group of homologues with respect to the influ-ence of e.g. length of alkyl chain for LAS (linear alkylbenzene sulphonate) or number of EOs (ethoxygroups) for alcohol-ethoxylate if such QSARs can be established.

Any deviation from the above-described scheme has to be well reasoned for the specific chemical.

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Loading factors

Loading factors shall be established according to Commission Directive 93/67/EEC of 20 July 1993 lay-ing down the principles for assessment of risk to man and the environment of substances8 notified in ac-cordance with Council Directive 67/548/EEC and to Council Regulation (EEC) No 793/939

8 OJ No L 227, 8.9.1993, p.99 OJ No L 84, 5.4.1993, p.1

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Non-biodegradable organics (anaerobic): flow diagram to define correction factors (CF)10

LTE ≤ 0.1 mg/l log Pow ≤ 4 RB CF = 3

RB CF = 2.5

LTE < 1 mg/l log Pow ≤ 4 RB CF = 2

RB CF = 1.5

LTE ≤ 10 mg/l log Pow ≤ 4 RB CF = 0.75

RB CF = 0.5

LTE > 10 mg/l log Pow ≤ 4 RB CF = 0.25

CF = 0.1

RB: ready aerobic biodegradability

LTE: long-term effect

CF: correction factor

10 The correction factors are to be established on the basis of the ingredient properties and applied to the dosage

expressed in g/wash.

yes

no noyes

no

yes

yes

no noyes

yes

yes

no

yes

no

yes

yes

yes

yes

no

no no

yes

yes

yes

ERA/2003.05.14 73

AP P E N D I X I .C

Documentation of anaerobic biodegradability

The following approach may be used to provide the necessary documentation of anaerobic degradabilityin the case of ingredients that are not listed in the DID-list:

1) Apply reasonable extrapolation. Use test results obtained with one raw material to extrapolate the ulti-mate anaerobic degradability of structurally related surfactants. If anaerobic biodegradability has beenconfirmed for a surfactant (or a group of homologues) according to the DID-list, it can be assumed that asimilar type of surfactant is also anaerobically biodegradable (e.g., C12-15 A 1-3 EO sulphate [DID No.8] is anaerobically biodegradable, and a similar anaerobic biodegradability may also be assumed for C12-15 A 6 EO sulphate). If anaerobic biodegradability has been confirmed for a surfactant by use of an ap-propriate test method, it can be assumed that a similar type of surfactant is also anaerobically biodegrad-able (e.g., literature data confirming the anaerobic biodegradability of surfactants belonging to the groupalkyl ester ammonium salts may be used as documentation for a similar anaerobic biodegradability ofother quaternary ammonium salts containing ester-linkages in the alkyl chain(s)).

2) Perform screening test for anaerobic degradability. If new testing is necessary, perform a screening testby use of ISO 11734, ECETOC No. 28 (June 1988) or an equivalent method.

3) Perform low-dosage degradability test. If new testing is necessary, and in the case of experimentalproblems in the screening test (e.g. inhibition due to toxicity of test substance), repeat testing by using alow dosage of surfactant and monitor degradation by 14C measurements or chemical analyses. Testing atlow dosages may be performed by use of OECD 308 (August 2000) or an equivalent method.

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A N N E X 5

List of participants and minutes from meetingsin ad hoc working group

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Minutes of the 1st AD Hoc Working Group meeting regarding revision of the EU ecolabel criteriaof detergents held on 6th of December 2001

Place: European Commission, Avenue de Beaulieu 5, Room A, BrusselsParticipants (see the enclosed list, Annex 1)

The minutes is organised under the following headings:

1. Market review2. Ecological criteria3. Discussion4. Performance test5. Other criteria6. Decision on revision or abolition of the criteria7. Any other business

The chairman, Ms L. Frisenborg, welcomed the participants to the 1st AD Hoc Working Group meetingregarding revision of the EU ecolabel criteria of detergents. After a roll call of participants she gave thefloor to the consultants.

1. Market review and amendment of product group definition

The consultants gave a presentation of the results of the market survey and a possible lay-out of a newcriteria structure. This included an overview of the market (detergents and surfactants), input from themarket and criteria survey, and possible revision of the product group definition. In the end of the pres-entation and discussion a decision of whether the criteria should be revised or abolished should be taken(ed. This is also referred to later in this minutes).

Ms. Stranddorf, dk-TEKNIK ENERGY & ENVIRONMENT, presented an estimate of the annual consump-tion of laundry detergents and an estimate of the annual consumption of major surfactants in laundry de-tergents. These figures were based on data from ECOSOL (1996), Umwelt Bundes Amt (2001) and theDanish Environmental Protection Agency (2001). From these figures it can be seen that there has been aslight decrease in the volume powders. This decrease shall probably be explained in the increasing mar-ket of compact powders rather in reduced washing activities. On the basis of these figures the consultantsaid the consumption of detergents has been rather stable from 1995 to 2000. She also said that sincethe consumed amount of the surfactants is large and since surfactants are likely to end in the environ-ment after use, it is worthwhile working towards a reduction of the total volume and of potentially hazard-ous ingredients.

Only relatively few answers have been received to the market survey questionnaire which was forwardedto a number of stakeholders. However, this is a usual situation for rather open market survey of this kind.Luckily, there has been a broad feedback from competent bodies, companies, organisations and NGOs.The feedback includes responses from eight EU member states. The main conclusions from the marketsurvey were:

• Products are much more concentrated than earlier• The performance of the products is crucial, although a cheaper performance test will be welcomed• Simplification of the criteria will be welcomed, possibly combined with

• Harmonisation with the structure of other washing agents criteria• Different opinions regarding the use of phosphates are stated (and are apparently related to national

regulations within this area)• Demonstration of good score in public performance tests combined with low prices has a positive ef-

fect in marketing of labelled products• Few, but new, license holders, are on the market.

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The consultants introduced a possible revision of the product group definition (the letters in italics are thenew addition):

“All laundry detergents, in powder, liquid or any other form; for the washing of textiles, and which areintended to be used principally in household machines; but not excluding the use in launderettes andcommon laundries”

As a part of the market survey some possible approaches were suggested in order to promote the labeland the labelled products. Suggested promotion ideas were among others; combination of the launchingof eco-label products combined with good performance test results, general branding of labelled andquality products and special events like, e.g. athletes carrying eco-labelled clothes at international cham-pionships have been suggested as a way to communicate the existence of the eco-label.

(Ed.: Discussion regarding product group definition is presented later in the minutes.)

2. Ecological criteria

The consultants proposed a new structure of the criteria. The new set of criteria would lead to a simplifi-cation of the present criteria for laundry detergents. Furthermore, the set up of criteria would lead to har-monisation with the structure of ecological criteria for other detergent products (i.e., hand dishwashingdetergents, and all-purpose cleaners and cleaners for sanitary facilities). The proposed criteria are basedon five ecological parameters and associated hurdles, and, hence, the systems are more transparent andeasier to communicate compared to the present rather complex combination of hurdles and total points.The proposed ecological parameters and the associated hurdles were:

• Maximum allowed critical dilution volume toxicity (CDVtox) of 6,000 l/wash• Maximum allowed amount of phosphates of 20 g/wash• Maximum allowed amount of phosphonates of 1 g/wash• Each surfactant in the product shall be readily biodegradable and biodegradable under anaerobic

conditions• Exclusion of dangerous, hazardous or toxic substances or preparations

Regarding CDVtox, its general function is to reduce the impact on the environment taking into considera-tion that there will (always) be some impact of detergents. The CDVtox is included in the scoring system ofthe existing criteria with an exclusion hurdle of 10,000 l/wash. In the proposed simplified criteria theCDVtox partly covers the need of setting maximum limits for total chemicals, insoluble inorganics, solubleinorganics and BOD.

The maximum allowed amount of phosphates serves the function to reduce the eutrophication potential ofeco-labelled laundry detergents. Phosphates are included in the scoring system of the existing criteriawith an exclusion hurdle of 30 g/wash.

The maximum allowed amount of phosphonates aims at a reduction of the use of potentially hazardouscomplexing agents in eco-labelled laundry detergents. A similar limit for phosphonates is specified in theexisting criteria.

The requirements to the biodegradability of surfactants have the purpose of ensuring optimal biodegrada-tion properties of surfactants in aerobic and anaerobic environments. As a positive ‘side-effect’, the re-quirement of anaerobic biodegradability of surfactants is in agreement with the efforts in several countrieswhich aim at a reduction of organic contaminants in wastewater sludge used on agricultural land. Morestringent requirements are placed on surfactants as these ingredients are used in high volumes and areamong the more toxic ingredients in laundry detergents. The proposed requirements to the biodegrad-ability of surfactants are related to the requirements to the amounts of NBDO (aerobic) and NBDO (an-aerobic) in the existing criteria.

Exclusion of dangerous, hazardous or toxic substances or preparations. The requirements proposed inthis section aim at an exclusion of substances and properties of ingredients that pose a risk to man or the

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environment. Similar requirements are included in the existing criteria. The requirements in the currentproposal have been updated and follow the approach in the criteria for hand dishwashing detergents, andall-purpose cleaners and cleaners for sanitary facilities.

The consultants ended the presentation of the criteria by saying that additional parameters could beadded, if this is found to be necessary, although it was recommended to maintain the simplified approach.

3. Discussion

An industry representative mentioned a study which is presently being conducted in Germany. He sug-gested that the continuation of the revision of the eco-label criteria should await the results of this study.He also felt that it was important that the criteria were based on science, and that the criteria should notbe too stringent for certain substances, until a scientifically based knowledge is established within each ofthe area covered by the criteria. Mr. Madsen, DHI, responded that if surfactants are the substances beingaddressed, there is little doubt that a small amount of these chemicals will reach the environment. If asurfactant is not degraded under the different conditions in the environment, it may be toxic to aquaticorganisms. The stringent requirements to the biodegradability of surfactants in eco-labelled products arein agreement with a precautionary principle. This approach is considered to follow the philosophy of theeco-label.

Another industry representative said that many published data are not correct. In aquatic sediment, soapmay be found in g per kg levels, whereas substances like LAS are found in mg per kg levels. He alsomentioned that the focus regarding anaerobic biodegradability should be broader than just LAS.

A representative from a national eco-labelling body mentioned that in another product group, soil im-prover, dealt with under the EU eco-labelling scheme, sewage sludge is used as one of the ingredients.She also referred to a study regarding sewage sludge that should be considered in the revision of thecriteria. She expressed a general interest in addressing the presence of surfactants (and other chemicals)in sewage sludge, because the use of sludge as an agricultural fertilizer is becoming more popular inmany countries. She also said that the effects of the eco-label should not alone be evaluated by the num-ber of licenses. The label has an enormous positive impact, because the multinational companies adapttheir product composition in order to match the eco-label criteria, although they will not apply for the eco-label at present.

Mr. Madsen agreed with the representatives from industries that there has been a particular interest inLAS and consequences of the lack of degradability in anaerobic environments, whereas the same atten-tion has not been given to other surfactants with similar properties. He explained that LAS was deliber-ately not mentioned in the presentation and that the proposed criteria address the property ‘non-anaerobic-biodegradability’ of all surfactants. Mr. Madsen also agreed about the finding of soap in aquaticsediments despite that soaps degrade under anaerobic conditions. This example perfectly illustrates therelation between (anaerobic) biodegradability and toxicity. The presence of soap in sediments is due tolimitations in bioavailability and not to a lack of anaerobic degradation. The requirement that surfactants ineco-labelled detergents shall be anaerobically degradable ensures that the surfactants will degrade in thesediment as soon as they become dissolved and bioavailable, and this is the condition where surfactantsmay exert a toxic effect.

One industry representative said that he did agree on the focus on anaerobic biodegradability. He alsosaid that a shift from sulphonates to sulphates is very logical as an improvement of the environmentalproperties.

One representative from a competent body suggested that the requirements to maximum amounts ofphosphate and phosphonate should be described as two separate parameters (and not one as in the pre-sent proposal). This was accepted and phosphates and phosphonates will be so described in the revisedreport and in the proposal of new criteria.

An industry representative was concerned that the decisions are based on the uncertain existing data. Healso said that we want eco-label on the market and that the label is certainly not successful at present. He

ERA/2003.05.14 78

was worried about the relatively low number of producers of raw materials that were present at the meet-ing.

The representative of the Commission and the consultants said that they were of the opinion that all ma-jor actors in the area of detergents have been invited to the meeting. However, the participants at themeeting were encouraged to suggest additional representatives that should be invited to the next meet-ing.

Another participant asked if the consequences of the revision of the criteria are known. Mr. Madsen an-swered that a routine calculation of the proposed simplified criteria versus the existing criteria has beenconducted by use of hypothetical model formulations and real (confidential) formulations provided fromUBA in Germany. The calculations demonstrated that a single substitution of non-anaerobically-biodegradable surfactants (e.g. sulphates instead of sulphonates) would make many of the products onthe market able to pass the proposed simplified criteria.

The inclusion of a hurdle for total chemicals was proposed by a representative of one of the memberstates with the main argument that the eco-labelling should encourage the production of compacts (andhence save energy for transport). This proposal will be included in the revised report and will also be con-sidered for the proposal of new criteria.

A national competent body representative said that he thought it would be a mistake to leave the existingcombined point-hurdle model. He said the dosage would be important to have included in the criteria aswell. Against this was argued that a simplification of the criteria would make them more transparent andeasier to communicate, i.e. the proposed simplified criteria make it possible to say that eco-labelled laun-dry detergents are based on surfactants that degrade rapidly in the environment. Another representativeproposed with the argument of the precautionary principle a complete band on the use of perborate. Mr.Madsen explained that the perborate matter is partially dealt with in the critical dilution volume parameter.

Another industry representative said that laundry detergents are very refined systems. The total con-sumption volume is very high and therefore there are good reasons to stimulate the production of envi-ronmentally sound products. The requirements in the criteria are, however, very high, and, therefore, theydo not stimulate anything because they are considered unattainable by some industries.

An industry representative mentioned that 6 billion people will machine wash the next year. It is thereforeimportant to reduce the general level of impact to the environment. He argued that it could be reasonableto accept substances that are unwanted in the environment in order to reach other improvements. Hesaid that the supply of certain materials is not sufficient since raw material manufacturers have not initi-ated the production early enough. In practise, it means that it can be difficult to get the needed raw mate-rials in order to demonstrate compliance with specific eco-label criteria.

Then, a discussion regarding quaternary ammonium compounds ensued. It was argued that not all typesof quaternary ammonium compounds are resistant to degradation in tests for ready biodegradability. MrMadsen responded that it is correct that quaternary ammonium compounds like, e.g., the esterquats, arereadily degradable. In order to reflect this situation, the general exclusion of quaternary ammonium com-pounds in the proposed ecological criteria will either be withdrawn or modified.

An industry representative also suggested that the criteria should be LCA based. Ms. Frisenborg said thatthe criteria already are based on LCA consideration. A real LCA will, however, not be performed in con-nection to the revision of criteria.

Finally, the discussion addressed whether or not a simplified approach as proposed by the consultantswas acceptable and appropriate for the future revision process. Before a Tour de Table, Mr. Stimmeder,EU Commission, said that a broad consensus was needed in order to change the structure of the criteria.Most of the representatives, with the exception of Spain and Norway, expressed that they have not con-sidered the actual level of the proposed criteria, but that they were in favour of a simplification as sug-gested. Norway argued especially for the combined hurdle and point system because they felt it wouldlead to more continuous improvement, while Spain were more focussed on finding the right moment for a

ERA/2003.05.14 79

change. On this basis Ms. Frisenborg concluded that there were a majority for a simplification along thelines proposed by the consultants.

4. Performance test

The market survey demonstrated that the performance test is crucial. Since there are some practicalcomplications of the performance test of the existing eco-label criteria, it will be amended. However, oneof the primary criticisms to the performance test is the price. The level of costs will probably not bechanged considerably. A representative from EEB suggested either to pay less attention to the perform-ance test or to abandon it. He argued that the market itself would decide if the products performed satis-fyingly. A member state representative argued that this is not at all the way the market functions. A repre-sentative from industry suggested using a benchmark test plus a test of the colouring transfer. It is not areal performance test but almost as good and in all cases cheaper. A representative from a test organisa-tion had forwarded a lot of comments regarding performance test. These were not discussed at thismeeting, but performance test will be a matter for discussion at the next meeting in the EU ad hoc work-ing group of laundry detergents. The majority of the participants were in favour of a continuation of inclu-sion of a performance test.

5. Other criteria

The French representative suggested inclusion of waste in the criteria. A single industry representativesaid that he did agree on the focus on anaerobic degradability.

6. Decision of revision or abolition of criteria

Ms. Frisenborg concluded on the basis of the market survey and the potential impact to the environmentand after a Tour de Table that there was basis for a revision of the criteria. She also concluded that therewere a majority for a simplification of the criteria. Further, it was concluded that the proposed criteria wererelevant. However, the next meeting will lead to discussion regarding the actual level of the criteria and ithas to be considered if one more criteria should be included.

7. Any other business

Ms. Frisenborg concluded the meeting by thanking for fruitful discussions and valuable input. She in-formed that the EUEB will be informed about the Ad Hoc Working Groups decision regarding revision aswell as the simplification of the criteria. She mentioned that the next meeting will be held the 4th of Marchin Copenhagen.

Heidi K: Stranddorf

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List of participants, 1st ahWG meeting Laundry Detergents

Annica Hedin, SIS Ecolabelling, SwedenBill Duley, Rhodia and CEEF, UKBo Nyström, EEB, SwedenDaniela Calcinai, Ecosol, ItalyErik Svanes, Erik Svanes Consulting, working for Ecolabelling NorwayFabrizio Zago, VEAPNE, ItalyFrancesco Tarisciotti, ANPA, ItalyGerhard Stimmeder, EU CommissionGiorgio Cassani, Ecosol, ItalyHeidi K. Stranddorf, dk-TEKNIK ENERGY & ENVIRONMENT, DenmarkHelmut Berenbold, Clariant, GermanyIgnocio Lopez, Ecosol, SpainJesu Barrera, AENOR, SpainJohn Pickup, John Pickup Associates, UKJørgen Dahl Toldsted, Ecolabelling DenmarkKees van Ginkel, Akzo Nobel Funtional Chemicals, The NetherlandsKerstin Sahlen, SIS Ecolabelling, SwedenLisbeth Frisenborg, Ecolabelling DenmarkMarianne B. Eskeland, Ecolabelling NorwayMarleen Van den Brande, Ecolabelling BelgiumPer Baummann, EUROCOOP, SwedenPeter Malaise, EDMA, BelgiumRenate Paumann, Austrian Ministry for Agriculture & Environment, AustriaSøren Mørch Andersen, Danish EPA, DenmarkTorben Madsen, DHI – Water & Environment, DenmarkVeronique Garny, Eurochlor, Belgium

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Minutes of the 2nd Ad Hoc Working Group Meeting regarding revision of the EU ecolabel criteriafor detergents, held on March 4th, 2002

Place: Eigtveds Pakhus, CopenhagenParticipants (see Annex 1)

Mr. Søren M. Andersen, the Danish Environmental Protection Agency (the Danish EPA), welcomed theparticipants to the meeting and to Eigtveds Pakhus. Ms. Lisbeth Frisenborg, the Danish ecolabelling bodyand chairman of the meeting, thanked the Danish EPA for their hospitality and welcomed the participantsto the meeting and suggested the participants to present themselves. This was done accordingly.

In the minutes the input and discussions are referred under the relevant headings and sub-headingsrather than presented chronological.

1. Approval of the proposed agenda

The chairman introduced the proposed agenda which is presented below. She suggested that item 3 and4 should be a joint presentation and discussion. With this procedural proposal the agenda was approved.

1. Approval of the proposed agenda2. Approval of the minutes of the 1st Ad Hoc Working Group Meeting3. Review of the proposed criteria4. Discussion of the proposed criteria5. Status and information of the wash performance test6. Any other business, next meeting

Documents

Ms. Heidi K. Stranddorf asked about the documents that have been sent to the participants beforehand inorder to ensure that all participants had received the relevant documents. The documents received were:Proposed Agenda for the meeting, Criteria proposal, Phase 1 Report, comments from CEEP, commentsfrom ECOSOL, comments from AENOR, comments from UEAPME, comments from John Pickup, com-ments from Phil Dolley, ETSU for the UK Competent Body, material from the Danish Consumer Informa-tion, proposals from the Danish Consumer Information, comments from Simon Kvindal, NOPA, Thoughtson the test for EU-Ecolabelling of laundry detergents, comments from AENOR to the proposed criteriaset. Later at the meeting an amended document from ECOSOL was copied and distributed at the meet-ing.

2. Approval of the minutes of the 1st Ad Hoc Working Group Meeting

Mr. Jesús Barrera from AENOR, Spain, had forwarded comments to the minutes in advance. These werealso distributed at the meeting. The participants agreed on the content of the amendments from Mr. Bar-rera and they will be incorporated in the minutes from the first meeting. This will be done in a neutralizedmanner in order to keep the minutes in a uniform manner. Ms. Stranddorf and the chairman thanked Mr.Barrera for his amendments and with the incorporation of these the minutes were approved.

3. and 4. Review and discussion of the proposed criteria

Mr. Torben Madsen introduced the proposed criteria.

He told that in some areas the criteria are strengthened while in other areas they are less stringent com-pared to the former document.

ERA/2003.05.14 82

Limit for Total chemicals, 90 g/wash

During the discussions of limit for total chemicals a number of questions regarding formulation of the de-tergents were raised. These questions are referred in succeeding order in the minutes.

The criterion was introduced to the members of the Ad Hoc Working Group at the 1st Ad Hoc WorkingGroup meeting. One of the main arguments for the criterion is that it is environmentally advantageous initself to introduce volume as a criterion. If anything else is unchanged, reduced volume to fulfil the samefunctional unit will reduce the environmental impacts through transport. The Austrian competent bodysupported this argument. Another competent body, Ms. Kerstin Sahlén, argued that the limit should bestricter in order to reflect the situation in the Nordic countries as well as to compensate for the omission ofa criterion for BOD.

The argument for the environmental superiority of concentrated products to the environment was sup-ported by several member states as well as industries and was also supported by European Environ-mental Bureau. However, other member states argued that they would have preferred a less strict crite-rion regarding limit for total chemicals.

During the discussion a number of clarifying questions were raised:

EEB asked what the difference between the heavy duty and the light duty was with respect to ecotoxicity.They suggested that the definition is looked upon and preferably, including a possible differentiation.Furthermore, it was also asked how liquids should be treated with regard to the limit of possible 90g/wash.

At the end of the discussion the chairman concluded that since there were arguments with both cons andpros regarding the actual limit concerning the total chemicals and there were no arguments against, thecriterion remains. In addition to this, it will be stated more precisely how the limit shall be understood. Ms.Frisenborg and Mr. Madsen suggested that we accept the 90 g/wash and that we develop further withrespect to the liquids.

Critical dilution volume, CDV < 6000 l per wash

The consultant presented the proposed hurdle and the setting of it. Since we move from a matrix systemto a hurdle system it is necessary to fix a number that generally speaking must be set at a lower levelthan the highest in the matrix system. In this case the level is placed at 6000 l per wash since many of theformulas we know of will not meet difficulties in the proposed hurdle.

During the presentation of the criteria the existing point system was presented in order to give the partici-pants an idea of where the proposed hurdle is placed compared to these.

Some member state representatives proposed (Italy) the hurdle to be placed on the 7500 l instead of6000 l. The consultant answered to this that the hurdle could just as well has been set to 5500 l. In fact,that would have been justifiable with the knowledge that the consultant has at the moment. Several mem-ber state representatives asked about the basis of this calculation. The consultant answered that the hur-dle has been based on the 35 formulas that the consultant has. These formulas are based on productsprimarily on the German and the Danish markets. Mr. Madsen demonstrated that for the 35 formulas theproposed limit only in rare cases would be exceeded.

At the meeting there seemed to be a general recognition about the fact that the formulas used for prod-ucts on the markets in Southern Europe will find more difficulties in meeting this criterion than the formu-las used for products to the North European market. However, this perception was based pure on intuitionsince there have not been provided any facts about this. All participants in the working group were kindlyasked to provide formulas on existing products on the market in order to elaborate this criterion.

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Other member state representatives (Belgium, Austria, maybe Denmark) proposed a lower level for thiscriterion. This was followed from other members of the working group by suggesting the level to be be-tween 3500 – 5500 l rather than the proposed hurdle of 6000 l. Mr. Madsen said this was a real possibilitybut that it was also important not to make all criteria stricter at the same time. He recommended that for-mulas for products on the market are forwarded to the project team in order to get the best possible crite-ria.

A member state representative asked if the level of the limit of the 6000 l is based on both compact andnon-compact. The consultant replied that this was the case. Further, the representative said that it wasimportant that the Ad Hoc Working Group does its job as properly as possible. But it should also bear inmind that if the industry does not provide the EU eco-labelling scheme with formulas the group must relyon the formulas that the consultants have. The representative also said that there are large differencesamong consumers in Europe regarding compact/non-compact, liquids versus powders versus tablets andit is important that these differences are kept in mind during the development of the criteria. Another rep-resentative, Mr. Peter Malaise, supported this.

A representative, Mr. Henk Blonk, Dalli Benelux B.V., mentioned that the concept (and therefore also theformulas) differs a lot between liquids and powders. Liquids have a large content of surfactants and dueto this they will, relatively, have more difficulties in complying with the eco-label criteria.

Then, Mr. Madsen showed a slide with examples of a number of different products. The examples dem-onstrated that some products immediately will be able to fulfil the ecological criteria and when that is notthe case the reason is frequently that they are not fully anaerobically degradable. However, in mostcases, the surfactant can be substituted for an anaerobically degradable surfactant and thereafter theproduct will be able to comply with the criteria. To this, a number of the participants (Mr. Henk and Mr.Thornton) mentioned the importance to promote substitution towards less hazardous substances.

A representative, Mr. Christopher Thornton, CEEP, asked if it is possible to make an ingredient substitu-tion and thereby enable the critical dilution volume to decrease to such an extend that one product whichcould not comply with criteria immediately would be able to so after the substitution. Mr Madsen an-swered positively to this. He mentioned that alkyl sulphates (AS) are one of the anaerobically degradablealternatives and that this does not bring up the critical dilution volume. The same representative then re-plied that when it is possible to bring down the critical dilution level considerably without violating theperformance of the products, this approach should certainly be promoted.

Mr. Madsen demonstrated examples of formulas with and without perfume and with a substitution of LASwith AS. Many of the existing labelled products do not contain perfumes but the proposed limit is, how-ever, not very strict. In conjunction to this Mr. Madsen said that it is very difficult to calculate good exam-ples due to lack of information. There are many possible ingredients so it is not just one way straightfor-ward. It is important to have some space left in order to navigate. Mr. Madsen concluded that there issome space.

In order to ensure the limit to be set at the right place Ms. Frisenborg said that a number of calculationswould be made, demonstrating how a product will be able to fulfil the criteria and that 5500 l most likelywould not create problems. The problems will not occur until perfume is added to the products. To thisconclusive mark an industry representative, Mr. Henk, suggested the calculation to be based on a num-ber of different types of products. In addition to this, another industry representative, Mr. Thornton, sug-gested that the differences between products containing perfume and products without perfume shouldbe demonstrated. Another representative (Mr. Malaise) from the industry mentioned that oil based onvegetable oil in many situations could add the perfumed effect the consumers need.

In addition to the suggested calculation Mr. Madsen mentioned that the German formulas used in hispresentation were without phosphates, while the corresponding Danish formulas are 50-50 with respect tophosphates and non-phosphates. He added to this that it would be very important if the members of theAd Hoc Working Group could provide formulas from product places on the market in Southern Europe.

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An industry representative (Mr. Malaise) thought it to be a very valuable approach if sustainability wasincluded. There, he mentioned, it was pretty obvious that LAS would not stay on the market, which actu-ally would be another incentive to squeeze it out of the eco-labelled products.

Based on the discussion referred above where arguments supporting the proposed level as well as sug-gesting stricter as well as less strict criteria, Ms. Frisenborg concluded that the level of 6000 l will bemaintained. This conclusion maintains provided the information from the Ad Hoc Working Group mem-bers that will be envisioned till the next meeting supports the proposed hurdle makes a reasonablepass/fail level.

Phosphates ≤ 20 g/ wash

Mr. Madsen introduced to the proposed criteria. He said that the proposal is based on the basic principlethat a small tightening is wished in order to promote a positive development in the countries where phos-phates are used. The countries that have a ban on phosphates can continue in that direction.

Overall, there were very few comments to this approach. One member state representative (Ms. Sahlén)proposed to have more levels corresponding to the situation in the Nordic scheme. The consultants an-swered that it is a possibility, and that it is certainly functioning in the Nordic countries. However, on aEuropean scale this could be much more complicated, and therefore he found it very advantageous toavoid this situation.

An industry representative (Mr. Thornton) said that the limit was not very important since the focus shouldbe on whether the phosphate is available in organic or non-organic form. Another industry representative(Mr. Cassani) and a member state representative joined this statement.

Another industry representative, Mr. Henrik Møller Jørgensen, Linds Fabrikker, Denmark, expressed hisdoubts whether it would be possible to produce products with a good performance if the limit was actuallyset at 20 g/wash. The reason for this was the degree of the hardness of the water in some areas. Phos-phates that are a very good complex binder and normally have a positive effect on the washing perform-ance of laundry detergents can be substituted by zeolite. However, the environmental performance ofzeolite is not better for the environment than phosphates, and sometimes zeolite makes white spots onthe clothes.

With that in mind a member state representative, Ms. Renate Paumann, said that the proposed structurewas to prefer.

Based on the comments, Mr. Madsen proposed the limit to be 25 g/wash rather than 20 g/wash. Thiswould include the concerns of the industry and avoiding the substitution towards zeolite and at the sametime avoiding differentiation between different markets. Another industry representative, Mr. John Pickup,endorsed the proposal.

In order to clarify, a member state representative asked if the limit should be calculated on STPP. It wasthe case.

Ms. Frisenborg concluded that the limit would be proposed at 25 g/wash calculated as STPP. If a countrywants to ban phosphate they are of course still free to do so. To this conclusion one member state repre-sentative (Mr. Andersen) added that it was liveable but that a lower limit would be preferred and that theAd Hoc Working Group should bear in mind that the limit should be pushing towards an environmentallypreferred situation. To this an industry representative added that the limit of 25 g/wash still would bepushing the development in the right direction when 20 g/wash is a very difficult level.

Phosphonates ≤ 0.5 g / wash

The philosophy in setting the limit on this criterion has been to decrease a little on the one hand and onthe other not to tighten too much. The purpose of this approach is to ensure a positive development, e.g.

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degreasing the use of phosphonates while at the same time avoiding industry to find the criteria to be toodemanding. Still, like for phosphates, if individual countries want to ban the phosphonates they can do it.Phosphonates are moderately toxic and very poorly degradable. However, the phosphonates are notconsidered to be candidate to R50/53 but rather R 52/53. A member state representative (Mr. Barrera)expressed his satisfaction with the implementation of a criterion specifically on phosphonates.

A member state representative (Mr. Andersen) mentioned it as reasonable to use the principles of pre-caution with regard to substances as EDTA. He could not see any good reason to accept substances thathave those irreversible, negative impacts on the environment.

A representative from EEB (Mr. Bo Nyström) mentioned that this had to be considered very carefully.Phosphonates are used as stabilisers - to stabilise the enzymes. The enzymes are generally preferablebecause they make it possible to wash at lower temperatures.

Another expert (Mr. Erik Svanes) argued for a continuation of the criteria.

An industry representative (Mr. John Pickup) warned against the focus on the specific substances. In-stead the group should focus on the hereditary characteristics and a more generic approach would beconsidered as optimal. Therefore, he suggested that in the future a generic criterion could be introducedinstead when more knowledge is gained.

Another expert (Mr. Thornton) agreed on this. He suggested a criterion focusing on poor degradabilityand then excluding one criterion on phosphonates.

Mr Madsen agreed to this. However, at present he suggested that at this stage the Ad Hoc WorkingGroup should continue with a limit for phosphonates and that the argument shall be written into the back-ground document in order to ensure that the importance of the message should not be forgotten in a pos-sible future revision of the criteria. At that time there might also be more information available.

Mr. Malaise said that the real world is even more complicated and that he knew of products that are read-ily degradable and contain phosphonates. In other words, some of the phosphonates are LN.

Mr. Madsen said that this was new to him. If this was the case we should choose the same approach asfor quaternary ammonium compounds.

Ms. Frisenborg concluded that the phosphonates would be moved to the negative list but with the pro-posed limit. She also suggested that the considerations are mentioned in the background document inorder to ensure that it will be included in a possible future revision of the criteria.

Insoluble substances

During this point of the presentation, a member state representative (Mr. Barrera) requested that the pos-sible amount of insoluble substances was considered carefully in order to take it into the overall environ-mental importance of surfactants. He suggested that a maximum value of acceptable insoluble sub-stances should be included in the set of criteria. He argued that it was of importance for the sewagesludge and subsequently the amount of waste. He mentioned this to be an important matter in countrieslike Spain – maybe also others. Zeolite, insoluble inorganic, will increase the sludge.

To this discussion another industry representative (Mr. Malaise) added that the issue primarily hassomething to do with the quality of the sludge that will increase without the insoluble inorganic. A studyperformed for the wastewater facility in Cologne was mentioned. The same industry representative saidthat the development goes in the direction of insoluble inorganic. We should not tighten the criteria furtherbut stay with the existing proposal.

One industry representative (Mr. Thornton) mentioned that 95-99 % of the zeolite would end in thewastewater treatment, where it would constitute about 5 % of the total sewage sludge. This was signifi-

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cant in terms of sewage sludge production. In the very end the sewage sludge (after further treatment) isused as a fertilizer contributor in the agriculture.

The representative was asked to provide figures for this in order to demonstrate the importance of thewastewater treatment. Further, the consultants will calculate the amount of waste from i.e. zeolite in thesewage sludge.

Ms. Frisenborg concluded insoluble ingredient will be integrated as a criterion. The consultants will inves-tigate a little more regarding the amount of these substances found in the sludge and in finding the rele-vant limit.

Criterion regarding surfactants

Mr. Madsen introduced the criteria. He explained that the criteria for surfactant are divided in two:

� Ready biodegradability� Anaerobic biodegradability

Mr. Madsen said that in the criteria the surfactants shall be respectively readily biodegradable and in ad-dition to this also anaerobically degradable. The criteria of ready biodegradability are almost legislationwithin the EU and anaerobic degradability is already included in the Nordic eco-label, and in other of theFlower detergent criteria.

Another industry representative, Mr. Lionel Godefroy, Stepan Europe, wanted to wait for revision of theeco-label criteria until results of an ongoing study was ready.

A member state representative, Ms. Marianne Eskeland, Ecolabelling Norway, supported the proposedcriteria. Also other representatives (Kerstin Sahlen), and among others a representative from the industry(Peter Malaise) also pushed for the criteria.

A member state representative (Ms. Paumann) confirmed that there is a draft of a regulation regardinganaerobic biodegradability, but while it is not adopted, the draft regulation does not cover households.

Mr. Madsen said in his presentation that there are a lot of concerns regarding biodegradability. We arefocused on the inherent characters and are not specifically interested in specific substances like LAS. Anindustry representative (Mr. Malaise) said that many studies demonstrated that the concern on LAS andother is real and that it is important to continue in the direction that already has been laid out in the pro-posal for the criteria.

Another member state representative (Ms. Sahlén) supported the proposed criteria. She wanted to have itas general as possible and liked the chosen approach. Further, she said that the criteria proposal wouldbe seen as untrustworthy if it did not include criteria for anaerobic degradability.

An industry representative (Mr. Cassani) said that about 300,000 t LAS are used in the EU memberstates per year. Therefore, he suggested that there should not be a demand that in practise would ex-clude LAS from use in eco-labelled products. To that, Mr. Madsen added that it is actually possible toproduce detergents without LAS. Ms. Frisenborg replied that with a consumption of 300,000 t LAS it iseven more important to have a criterion excluding the use of non anaerobically biodegradable sub-stances. Yet another member state representative (Ms. Paumann) supported this. Furthermore, she em-phasized that it is not a mandatory regulation the group is developing but fulfilling a voluntary environ-mental scheme using the precautionary principle.

Mr. Malaise added to this that well-performing products that are not based on LAS already exist. Mr.Madsen said that many of the laundry detergents placed on the market in Denmark are without LAS. Therepresentative from the Danish Environmental Protection Agency followed up on this by addressing toconsumer test results demonstrating that the eco-labelled products based on other ingredients than LAS

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placed on the Danish market performed among the best. In fact, it seems that the presentation of theseresults had motivated other products, i.e. the P&G product like ARIEL to have a changed formulation.

Based on this discussion Ms. Frisenborg summed up asking Italy and Spain kindly to check up on theirmarkets and concluded that while some of the industry representatives, however not all, did not like theapproach it seemed that everybody else of the participants were supporting the approach. Therefore, sheconcluded that the consultants should continue with this approach.

Exclusion of hazardous substances

Mr. Madsen introduced that the exclusion list of hazardous substances is based on a combination ofspecified ingredients and specified inherent properties. Earlier at the meeting it was concluded to movethe handling of phosphonates hereto.

A representative (Mr. Pickup) mentioned the distributed documents. These would enable the Ad HocWorking Group to discuss further regarding specific substances at future meetings.

One of the participants (Mr. Svanes) stated that it is important that general statements excluding R50-51/53 ingredients essential for detergents should be considered very carefully. That could be for perfumeand colours as well as ingredients with other properties (e.g. biocides). He also pointed at the chosenphrasing; excluding hazardous substances if these are present to more than 0.1 % may be too strict. Tothis an EEB representative said that these phrases literally would exclude perfumes which would be finefor him.

Regarding fragrances Ms. Frisenborg said that she had interviewed some companies. The perfumemanufacturers say they get more and more data, and that sometime in the future it will be possible to getall relevant data. To this discussion a participant mentioned that we should be careful not to mix perfumewith natural fragrance. Yet another participant (Mr. Malaise) thought that we should not mix up the dis-cussion regarding perfume and the discussion regarding biocides. Further, he stated that as the criterionis now, it is not strict enough. Although he agreed with the overall principle of excluding certain sub-stances, he felt that we should go a bit more in depth with each of the properties of the substances.

To this discussion Mr. Madsen mentioned that it is possible to find both degradable biocides and coloursthat are not toxic. He stated that it is quite easy to manoeuvre around and pick up ingredients that areallowed within the proposed criteria. Mr. Madsen also mentioned that he was not sure if the 0.1 % re-quirement should be placed in a guideline document or in the criteria document. For him, the most im-portant point is that we choose an approach that is harmonized with other chosen approaches within theeco-labelling scheme.

An industry representative said that in general terms R 50/51/53 is acceptable as criterion. A participant(Mr. Malaise) said that it was important that you could not dilute you out of the matter.

A participant (Mr. Svanes) asked clarifying if it is each of the ingredients or the sum of ingredients thatshall be below the proposed limit. Another represenative (John Pickup) pointed at substances that havedifferent effects depending on if they are diluted or not, for instance NaOH.

Ms. Frisenborg summed up. There have been no specific comments to the negative list. The text needsclarification in order to write precisely which amount that shall be calculated. Mr. Madsen answered thatthe consultants would investigate it more thoroughly.

An industry representative (Mr. Pickup) would investigate the negative list till next meeting.

Packaging

A participant mentioned that the packaging requirements because of the criterion about refill in praxis ex-clude tablets. Another participant (Mr. Jørgensen) said that in praxis the refill system is excluded for minor

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products since it is difficult to get more shelter space in the supermarkets. In praxis the criteria allowedonly cardboard boxes. If this was the case he suggested them to be based on recycled fibres.

An industry representative (Mr. Henk) said that in some areas tablets in praxis are overdosed becausethey are designed for hard water and often function in soft water, i.e. 75% of the Netherlands has softwater. If the information on the packaging is not provided with great care, consumers may overdose to alarge extent.

A member state representative (Belgien – Marleen Van den Brande) said that the argumentation regard-ing packaging should be the same for detergents as for e.g. light bulbs. The Commission (Ms. NicolaMarinucci) said that packaging might not be the most important environmental issue for detergents whileit might be more relevant for other product groups. The member state representative (Belgien) said thatpackaging is important because detergent is a short-lived consumer good. This is especially true since itis even more short-lived than light bulbs where packaging is considered to be important.

In addition to the proposal for cardboard-based packaging a member state representative (Mr. Andersen)proposed a criterion for polymer-based recycled packaging. He also mentioned that the packaging is veryimportant in terms of how the products, e.g. the laundry detergents, appear. He mentioned examples ofnon-labelled product packed in environmentally friendly packaging. By doing so the packaging signals areduced impact on the environment while this may only be the case for the packaging. The member staterepresentative felt it is important that such aspects are considered in conjunction with the revision of thecriterion of packaging in the criteria set.

The EEB wanted to delete the B-part of the criteria. The EEB representative added that the word “box or”should be deleted from the requirements. A representative (Mr. Malaise) said that this is just commonpractice regarding the cardboard. It is different from the situation with plastics, where you probably needan inner layer of virgin material. Besides, we can forget about the lightweight criteria if we shall ask forrecycled material.

Mr. Madsen proposed that we could get to a point where we could indicate a preferred option that wouldmake it possible for tablets.

A representative (Mr. Thornton) mentioned that, however, packaging might not be the most important is-sue for detergents with regard to the overall potential environmental impact it is one of the most visual.Therefore, the criterion for packaging and the way it presents itself should be considered very carefully.

Ms Frisenborg concluded that there would be maintained a criterion for packaging. Further it is lookedupon the formulation in the proposed criteria B) “box or” and its possible influence on C).

5. Status and information of the wash performance test

The performance test discussion was not prepared for the meeting. Therefore, Mr. Madsen suggestedthat a more in-depth discussion was taken at the next meeting.

Ms. Frisenborg said that we should consider the performance test discussion in conjunction with the EEBthought about washing at lower temperatures.

However, a number of points were raised. An industry representative (Mr. Jørgensen) said that it is a keycriterion that eco-labelled products are well performing. Some products have also difficulties in meetingthe performance test demands. Another participant (Mr. Svanes) said that this is not a quality label but aneco-label arguing that the performance test is not so important. To this an industry representative (Mr.Malaise) said that the test is ten years old and it consists of some formulas that are not really acceptable.He said that it is not necessary to be as good as the reference detergent. A third industry representative(Mr. Henk) thought that the test is good for powder products. However, this is not the case for liquidswhere it is more complicated. Liquids detergents are used to wash at low temperatures and there are noresidues. Yet another industry representative (Mr. Pickup) mentioned that performance is a competitionmatter.

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A representative from the Danish Consumer Test Institute, Ms. Guddie Poulsen, said that the referencedetergent has been changed a couple of years ago. To this Mr. Madsen said that we know that the refer-ence product is not on the market as a consumer product. At the 1st Ad Hoc Working Group meeting weagreed that we should not change the test fundamentally. To underline the correctness of this conclusionthere is only very little experience since there are only three licensed products. All participants that haveinput to this document are welcomed to forward these as soon as possible.

Then a discussion about what to do took place. Different suggestions on which existing detergent thatcould be used were proposed. Mr. Thornton proposed that we might be able to live with less successful-ness. Another representative (Mr. Henk) suggested that acute tests were performed. A third representa-tive (Mr. Malaise) commented that this also should be done for liquids. A fourth representative (Mr.Pickup) said that distinction between what consumers expect from a product and how it looks is made.The reference detergent in the wash performance test was questioned, because it does not reflect theproducts on the market. Mr. Madsen answered that one of the good things about the reference detergentis that it has been generally accepted (it would not be difficult to suggest another reference detergent, butit would probably not be easy to propose a new consensus formulation).

Ms. Frisenborg concluded that there would be collected as many input as possible regarding the test untilthe next meeting.

Test

In the end of the above-referred discussion a member state representative (Italy) asked if performancewas included in these considerations of reference detergent. He said that the performance test was veryimportant. The representative said that while he agreed on the proposed reduction in the number of crite-ria, he considered it being of outmost importance that the performance test should be revised.

Ms. Frisenborg concluded that the test as such hardly would be revised while the intentions are that thenecessary revision shall be made. However she concluded that it should be investigated if the test couldfunction at 40 ° C instead of 60 ° C as today, if the reference detergent also applies for a liquid. Finally,she promised that the test will be placed higher on the agenda at the next meeting.

6. Any other business, next meeting

The EEB representative (Mr. Nyström) would like to have a certificate regarding enzyme-based solutions.Further, he suggested a text on the eco-labelled packaging saying ”Drop dry when possible”.

Ms. Frisenborg then suggested the members of the group to send input for possible wording on the pack-aging for the coming eco-labelled products.

Environmental drivers

A discussion of which of the criteria that could be understood as environmental drivers followed. Mr. Mad-sen said in his presentation that he considered the critical dilution volume and the criterion on biodegrad-ability as the driver criteria. Some of the participants, e.g. John Pickup, supported this. Further, it wassuggested by some of these participants that the group should take the advice from the persons whohave investigated more about this, e.g. the consultant. The Commission said it was confusing to talkabout which criteria that are driving criteria and asked if the critical dilution volume still is the most domi-nant criteria. Further, the Commission expressed concerns regarding the basis of the criteria, emphasiz-ing that the EU label is supposed to reflect the situation in the whole EU.

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DID-list

An industry representative, Mr. Giorgio Cassani, Condea, Italy, asked about which numbers that havebeen used in the calculations. He asked if the numbers were from the DID list. He mentioned that ap-proximately 300,000 tons of LAS are used within EU. However, the LAS substitutes have 3 times higherimpact on the environment than LAS.

Mr. Madsen replied that this statement is based on the fact that LAS has a long-term effect of 0.3 ac-cording to the DID list while the corresponding LTE value for AS is 0.1. However, when the critical dilutionvolume is calculated, the LTE is combined with a loading factor (LF) which is reflecting the removal of thesubstance in a wastewater treatment plant. Here, LAS has a LF of 0.05, whereas the LF for AS is 0.02(i.e. a higher removal is estimated for AS). When combined in the calculation of the critical dilution vol-ume, the difference between LAS and AS is a factor of 1.2 which is hardly significant (and not 3 as statedby the industry representative). The potential higher toxicity of AS compared to LAS is counter-balancedby the faster degradation of AS, especially in environments where oxygen is limited. Mr. Madsen men-tioned that we have to base our calculations on the DID list values and that we do not claim that to bescientific. Mr. Madsen concluded to this debate that the eco-labelling criteria are not science it is science-based. He mentioned that there are a lot of uncertainties in those values, i.e. LF – loading factor - is notscientific. Ms Frisenborg then added that it is a scientific approach. Furthermore, she concluded that theAd Hoc Working Group could not go into details regarding the DID list and the values there. This has tobe done in another forum. As for the DID list, however, it would be advantageous if a participant havingvalues for the DID list provides these to the planned revision of it.

Formulations

Ms Frisenborg requested the representatives of especially Italy, Denmark and Holland to check if the al-ready existing labelled products would be able to meet the proposed revised criteria.

As an overall conclusion of the discussion, she said that all Ad Hoc Working Group members are kindlyasked to provide more formulas in order to do an extra check regarding the proposed criteria.At the end of the meeting a participant (Mr. Barrera) congratulated the group for being a real workinggroup.

Ms Frisenborg ended the meeting by summarising what has been concluded:

Regarding the total chemicals we stay at the 90 g/wash. In addition to this she underlined the importanceof the group members to provide the consultants with formulas. As for the Critical dilution volume thecontent is kept while the phrasing will be changed. In addition, she reminded the group members to pro-vide formulas to the consultants. If those formulas indicate it, the limit will be decreased from the propose6000 l to something lower. For phosphates the level of 25 g per wash is fixed. This value shall be calcu-lated based on STTP. The phosphonates are moved (with a limit value) to the section regarding thenegative list. The considerations shall be included in the background document in order to look more in-depth on it in the next revision. A new criterion regarding insoluble substances is added so far at the levelof 30 g per wash. Surfactant criteria regarding anaerobic and aerobic biogradability are unchanged. Thetext of hazardous substances shall be clarified a little bit more regarding the limits. This also applies forthe criteria regarding packaging. There will be worked more on the performance test.

Next meeting will be held on May 30th, 2002, in Brussels. It will be an all day meeting.

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Annex 1

List of participants at the 2nd Ad Hoc Working Group Meeting regarding revision of the EU ecola-bel criteria for detergents

Participants InstitutionTorben Madsen DHI Water and EnvironmentHeidi Stranddorf dk-TEKNIK ENERGY & ENVIRONMENTLisbeth Frisenborg Ecolabelling DenmarkSøren Mørch Andersen Danish EPALise Møller Danish EPAMarianne Eskeland Ecolabelling NorwayErik Svanes Erik Svanes ConsultingBo Nyström EEBNicola Marinucci EEBFarbizio Zago ItalyPer BaummannJohn PickupHenrik Møller Jørgensen Linds FabrikkerMarleen Van den Brande Belgian Federal Departm. of the Environ.Francesco Tarisciotti ANPAChristopher Thornton CEEPGuddie Poulsen Danish Consumer InformationKerstin Sahlén SIS EcolabellingHenk Blonk Dalli Benelux B.V.Giorgio Cassani CondeaJesús Barrera San Martín AENORLionel Godefroy STEPAN EUROPERenate Paumann BMU (Federal Environment Ministry, Germany)Peter Malaise Ecolever

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August 2002

Minutes of the 3rd Ad Hoc Working Group meeting regarding revision of the EU eco-label criteriaof detergents, held on May 30th, 2002

Place: European Commission, Avenue de Beaulieu 5, Room A, Brussels

The minutes are organized under the following headings:

Welcome1. Approval of proposed agenda2. Approval of the minutes of the 2nd Ad Hoc Working Group Meeting3. Status and information of the wash performance test4. Ecological criteria5. Any other business6. Conclusion, end of meeting

1. WelcomeMrs. Frisenborg welcomed the participants to the 3rd Ad Hoc Working Group meeting regarding revisionof the EU eco-label criteria of detergents.

2. Approval of the proposed agendaThe proposed agenda was adopted.

3. Approval of the minutes of 2nd Ad Hoc Working Group meetingThe minutes of the 2nd Ad Hoc Working Group meeting were adopted without amendments.

4. Status and information of the wash performance testMrs. Frisenborg introduced the subject. At the 2nd Ad Hoc Working Group meeting the Ad Hoc WorkingGroup felt that there was too little time to a satisfying deep discussion regarding the wash performancetest and the proposed amendments. Earlier it has been argued that the costs of a wash performance testare relatively high and there has been expressed a wish to reduce these costs. Experts on these mattershave looked through the document in order to identify potential cost reductions and ensure that the per-formance test is up-to-date. The item was therefore put at the agenda once again at this 3rd Ad HocWorking Group meeting. In order to facilitate the discussions the consultant (Mrs. Stranddorf) introducedthe major proposed changes. The major discussions, changes and conclusions are described below.

Colour maintenance determination cannot be performed as it is described and results from specific testsindicate that the variation in the colour maintenance test is larger than the variation of different dyestuffs.The industry is improving on colour maintenance but there is no standardized method. But it is still im-portant to ensure a certain quality of imported goods. Therefore it was proposed and subsequently con-cluded to keep colour maintenance as an integral part of the wash performance test but without having atest criterion. This will result in a minor cost reduction.

As for fabric damage, the loss of textile strength, the consultant had pointed to this as a possible area toreduce costs. The number of washing cycles was pointed at as a possible cost reduction. Specifically, itwas proposed to reduce the number of wash cycles from 25 to 15 cycles. A number of member state rep-resentatives and representatives from industries were in favour of maintaining the 25 cycles in order totest for secondary effects. The Ad Hoc Working Group concluded, based on especially comments fromMr. Sommer, that the requirement should be maintained unchanged since the potential cost reduction isrelatively low and the risk of quality reduction is relatively high.

Regarding liquids, it was proposed from an industry representative and a member state representative todevelop a new test for liquids, since these have a specific purpose for the light duty area and in relation to

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other detergents have a low degree of performance. It was concluded that this area should be workedmore upon in the next revision of the criteria. Ed: After the meeting results from a light duty product haveshown that it is possible to comply with the existing criteria set for light duty products.

In addition to the above mentioned there were a number of smaller changes like new washing machine,change in the number of cleaning performance units etc. These were not debated very much and there-fore not reported here.

5. Ecological criteria

Total chemicals: < 90 g/wash changed to < 100 g/washBased on the 2nd Ad Hoc Working Group meeting on a number of primarily Danish and German formulas,the consultant suggested 90 g/wash. Two member state representatives and two industry representativesargued that a limit of 100 g/wash would be preferable.

In the end Mrs. Frisenborg concluded 100 g/wash to be the new limit.

Insoluble inorganics: < 30 g/washBased on the 2nd Ad Hoc Working Group meeting on a number of primarily Danish and German formulas,the consultant suggested 30 g/wash. This was afterwards concluded.

Aquatic toxicity, CDV-tox: < 4500 l/washThe consultant demonstrated the results of a survey of the known formulas. This survey demonstrated4500 l per wash to be a manageable limit. A number of the participants argued for this solution. However,others argued that the picture would have been much different if the formulas had been from Italy andSpain. In the end it was concluded by Mrs. Frisenborg that it would be acceptable to stay at the proposed4500 l/wash. At the same time Mrs Frisenborg suggested that companies as well as member states wererequested to provide formulas in order to indicate if the proposed limit is not adaptable.

Phosphates < 25 g/washAt the 2nd Ad Hoc Working Group meeting it was proposed to set the limit to 20 g/wash. However, basedon the inputs given from the members of the group, the consultant proposed a limit of 25 g/wash. Therewere very few comments to this and it turned out that Mrs. Frisenborg in the end concluded 25 g/wash tobe the limit.

Anaerobic biodegradabilityMr. Madsen presented the proposed criterion regarding the anaerobic biodegradability of surfactants.This criterion represents an important modification in order to establish a new set of ecological criteriathat is simpler in use and in relation to the communication to consumers – a purpose that was generallyagreed upon at the 1st and 2nd meeting in the Ad Hoc Working Group. As it has been discussed at theprevious meetings, the proposed simplified criteria are based on the same main parameters as the exist-ing criteria. The parameter on anaerobic biodegradability has been modified from a general requirementstating that:

The total content of non-anaerobically degradable (anNBDO) ingredients shall be below a maximum limit(15 g/wash), and that a lower score is obtained by increasing amounts of anNBDO (existing criteria) to amore specific requirement focusing on surfactants:

Each surfactant used in the product shall be anaerobically biodegradable (proposed criteria).

The more stringent requirement to the biodegradability of surfactants is justified by the potentially hazard-ous environmental properties of surfactants and the high volumes used in laundry detergents. A similarcriterion on anaerobic biodegradability of surfactants has already been introduced in the European eco-labelling criteria for hand dishwashing agents and all-purpose cleaners and cleaners for sanitary facilitiesas well as in the criteria for the Nordic eco-label. Mrs. Frisenborg (the chair) mentioned that a requirementof ultimate anaerobic biodegradability of surfactants has been included in the Nordic eco-labelling criteriafor several years and that this has not precluded a growth in the number of licences.

ERA/2003.05.14 94

There were clarifying questions and some debate regarding the proposed criterion on anaerobic biode-gradability. Some industry representatives questioned the relevance of having a criterion on anaerobicbiodegradability at all. These industry representatives argued that the standardized testing methods areunreliable and that a decision should be postponed until the results of the study conducted by the Fraun-hofer Institute on anaerobic biodegradation of surfactants were available.

A representative from Spain expressed his concern stating if anaerobic biodegradability goes ahead, itseems that the LAS could be excluded of the EU Eco-labelling. In Spain every brand of laundry detergentcontains LAS, so the exclusion of LAS of the Eco-label means that Spain should be excluded of the Eco-label. Perhaps this will also be the case for other EU countries. Further, the Spanish representative saidthat the exclusion is wrong since there is nothing clear regarding this issue. First of all, it would be neces-sary to establish which analytical methodology to be used to apply the criterion. There is not any officialmethod approved to determine if a substance is whether or no anaerobically biodegradable as there is inthe aerobic case. So the applicability of this criterion would be submitted to a certain level of arbitrariness.Moreover, the number of situations that really are under anaerobic conditions is not significant for deter-gent ingredients (surfactants) after use, since these are mainly readily aerobic biodegradable. So the an-aerobic biodegradability has not to be considered as a criterion, at least not in this revision. Maybe itwould be prudent to wait for the next criteria revision when the issue is clearer. Then, it could be possibleto take into account the Precautionary Principle, to impose some limitations for these substances that arereadily aerobically biodegradable but are not clearly anaerobic.

All member state representatives, with the exception of Spain, were satisfied with the proposed simplifi-cation of the criteria including the requirement of anaerobic biodegradability of surfactants. One memberstate representative argued that ultimate aerobic degradability is a part of the coming Detergent directive– this makes the requirement of anaerobic biodegradability of surfactants a logic improvement of the crite-ria as eco-labelling should be ahead of the legislation. Other member state representatives said that thecontents of non-anaerobically biodegradable substances in sewage sludge limit the possibilities of usingsludge as a fertilizer on agricultural soil. Overall the member states felt that the precautionary principle isimportant and should be used here.

Representatives from industry, in particular raw material suppliers, agreed with the position of Spain bysaying that the relevance of a requirement of anaerobic biodegradability of surfactants has not been sci-entifically documented. Other industry representatives were satisfied with the proposed criteria and ar-gued that it is fully possible to prepare well-performing detergent formulations without non-anaerobicallybiodegradable surfactants.

During the discussion the consultants presented an approach for documentation and testing of anaerobicbiodegradability of surfactants:

1) Consult the DID-list (contains 25 anaerobically degradable surfactants, including DID no. 34, whichhas been confirmed to be degradable under anaerobic conditions).

2) If a surfactant is not in the DID-list, apply reasonable extrapolation by using data for structurally simi-lar surfactants in the DID-list.

3) If no documentation can be achieved from the DID list or literature, perform screening test for an-aerobic biodegradability: “Water quality – Evaluation of the “ultimate” anaerobic biodegradability oforganic compounds in digested sludge – Method by measurement of the biogas production” (ISO11734). A closely related guideline entitled “Ready anaerobic biodegradability – Gas production fromdiluted anaerobic sewage sludge” (OECD 311) will (expectedly) be approved in the near future.

4) If the above-mentioned screening is unsuitable for the surfactant in question, perform a biodegrada-tion test by using a low concentration of the test substance (e.g. OECD 308).

In relation to the position of Spain, Mr. Madsen pointed to the fact that approved and standardizedscreening methods to determine anaerobic biodegradability do exist (ISO 11734 and the related ECETOCNo. 28) – these methods have already been approved as the reference tests for the documentation ofanaerobic biodegradability in the European eco-label criteria for other product groups (i.e., hand dish-washing agents and all-purpose cleaners and cleaners for sanitary facilities). Furthermore, Mr. Madsensaid that the current DID-list provides a background for documentation, which makes it easy to select an-aerobically degradable surfactants.

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Monitoring data for the occurrence of surfactants in the environment are scarce and mostly cover studiesof LAS. Measurements of LAS in sewage sludges have shown that this surfactant accumulates insludges, especially if anaerobic treatment has been applied as the concentration of LAS in these casesmay reach g/kg-levels. Besides, sediments in freshwater and marine environments are predominantlyanaerobic and may serve as a sink for organic substances that are not ultimately degradable under an-aerobic conditions. Mr. Madsen presented monitoring data showing concentrations of LAS of between 0.1and 4.8 mg/kg in sediments in Denmark. Calculations of Risk Quotients (RQ = PEC/PNEC, where PEC isPredicted Environmental Concentration and PNEC is Predicted No Effect Concentration) showed that thevalues for RQ ranged from <0.1 to 59 and exceeded 1 in a number of cases (RQ >1 indicates the pres-ence of a risk; see the attached slides presented at the meeting). The risk quotients probably represent arange between a ”best” and a ”worse” case scenario. If RQ <1, it is assumed that there is no risk of eco-toxic effects in the ecosystem. The calculations indicate that the use of non-anaerobically degradablesurfactants may present a risk to organisms living in aquatic sediments. However, several uncertaintiesstill remain – (i) the concentrations of LAS in sediments were measured in Denmark where a high per-centage of the sewage is treated in a wastewater treatment plant (higher concentrations of surfactantsmay possibly occur in regions with a less efficient wastewater treatment), and (ii) for some surfactants thetoxicity data are relatively few (although not the case for LAS). Mr. Madsen concluded that the approachof the precautionary principle is justified in relation to the proposed criterion on anaerobic biodegradabil-ity.

In the end of the meeting Mrs. Frisenborg (the chair) asked for a Tour de Table. This demonstrated thatthe majority of member state representatives and many of the industry representatives were in favour ofthe proposed criterion on anaerobic biodegradability and appreciated the presented test strategy as well.The conclusion from the meeting was to maintain the criterion as proposed.

Dangerous, hazardous and toxic ingredientsRegarding phosphonates, it was suggested and accordingly concluded only to exclude phosphonates thatare not readily biodegradable. Afterwards the same was suggested and concluded for ammonium salts.

In 6.c. it was clarified that the limit is 0.01 %, except for preservatives where an absolute zero limit wasagreed.

In order to demonstrate compliance with the criteria regarding “Dangerous, hazardous and toxic ingredi-ents”, the demand is settled to include the delivery of Material Safety Data Sheets of the ingredients inquestion and a statement of compliance.

PackagingBased on input from the 2nd Ad Hoc Working Group meeting, the criteria of packaging have been re-viewed. Ed: After the 3rd Ad Hoc Working Group meeting packaging compared to the criteria has beenchecked again. These reviews indicate that the level as such is satisfying. However, there was a generalagreement about the actual wording in the criteria. The consultants promised to create a revised wordingto the final set of criteria.

6. Any other businessA representative suggested that the criteria document in a future revision should be more focused re-garding reduced resource consumption. There was a general acceptance of this suggestion.

Regarding fragrance, it was concluded to include a wording from IFRA in the final criteria set.

Regarding allergy, it was suggested and concluded to include R 43 under “Dangerous, hazardous andtoxic ingredients”.

Regarding consumer information, the wording environmentally friendly was changed to environmentallysound.

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In the end Mrs Frisenborg summarized the conclusions. These are:

Minor changes in the wash performance test.Total chemical: < 100 g/wash.Insoluble inorganics: < 30 g/wash.Phosphates: < 25 g / wash.Criterion for anaerobic biodegradability and test strategy included.The meaning of the criteria regarding packaging should be kept, however the wording should be moreclear.A wording regarding fragrance will be included.Phosphonates: Only exclude not readily degradable.Ammonium salts: Only exclude not readily degradable.Clarification of the 0.01% limit in 6.c.Allergy: The product must not be classified with R 43.

Heidi K. Stranddorf

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Annex 1

List of participants, 3rd ahWG meeting Laundry Detergents

Anders Reckweg BASF, DenmarkBrigitte Kleeb Dalli Werke, GermanyCassani Giorgio SASOL, ItalyCharles Cox DEFRA, UKChris Thornton CEEP, EuropeErik Svanes Erik Svanes Consulting, NorwayFabrizio Zago UEAPNE, ItalyFrancesco Tarisciotti ANPA, ItalyFranco Campoli EU CommissionHeidi K. Stranddorf dk-TEKNIK ENERGY & ENVIRONMENT, DenmarkHenk Blonk Dalli Werke, the NetherlandsJean-Paul Andriessen Dalli Benelux, the NetherlandsJesu Barrera AENOR, SpainJohn Pickup John Pickup Associates, UKKerstin Sahlén SIS Ecolabelling, SwedenLeena Nyqvist-Kuusola SFS Ecolabelling, FinlandLisbeth Frisenborg Ecolabelling DenmarkMaaike Fleur Stichting Milieukeur, the NetherlandsMarianne B. Eskeland Ecolabelling NorwayMarleen van den Brande Ecolabelling BelgiumMichele Accardo EU CommissionPeter Malaise EDMA, BelgiumSimon Goss EU CommissionSøren Mørch Andersen Danish EPA, DenmarkTorben Madsen DHI, DenmarkUlrich Sommer BAM, Germany

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A N N E X 6

Statement from Regulatory Committee meetingon 4 December 2002

ERA/2003.05.14 99

EUROPEAN COMMISSIONDIRECTORATE-GENERALENVIRONMENTDirectorate D - Implementation and enforcementENV.D.3 - Industry and implementationHead of Unit

Brussels, 4 DecemberENV/D.3

Regulatory Committteeestablished under Regulation (EC) No 1980/2000

of the European Parliament and of the Council of 17 July 2000on a revised Community Eco-Label award scheme

STATEMENT

On the occasion of the next revision of the Commission Decision establishing the ecological criteria forthe award of the Community eco-label to laundry detergents, particular attention will be paid to the fol-lowing issues:• Further restricting the use of phosphates

• The size of the load for the reference dosage, and the performance test in general

• CDV tox, also to be revised with reference to the new DID list

• Anaerobic biodegradability of surfactants

• Optical brighteners

• Total chemicals

• Perfumes

• Disinfectants

• Safety messages, including keep out the reach of children and avoid getting in eyes

• Reusable and recycled packaging

• Impact on energy use

• The use of points-based versus pass�fail criteria

Herbert AICHINGER

European Commission B-1049 Brussels - Belgium - Office:Telephone: direct line (+32-2)299.12 00, switchboard 299.11.11. Fax: 295.56.84.

ERA/2003.05.14 100

A N N E X 7

Incoming and outgoing correspondence

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Date ofsending/receivingmail/letter

Incoming/Outgoing Title

1. 05.10.2001 O Anne Nielsen, Change of meeting date.rtf2. 16.10.2001 O Heidi K. Stranddorf, Mødeindkaldelse for den danske følgegruppe for

vaskemidler.doc3. 17.10.2001 O Heidi K Stranddorf, Laundry Detergent - 1st ahWG meeting.rtf4. 18.10.2001 I Gerhard Stimmeder, RE Revision of criteria for detergents.rtf5. 18.10.2001 I Who does what - EU Eco-label.doc6. 23.10.2001 I Nicola Marinucci, Mailing lists for eco-label working groups.doc7. 23.10.2001 O Kirsten Schmidt, Questionnaire Revision of the criteria.doc8. 29.10.2001 I Answer to Questionnaire laundry detergents from ECOSOL.doc9. 30.10.2001 I Answer to Questionnaire laundry detergents from Nordisk Parfumeri-

varefabrik DK.doc10. 31.10.2001 I Answer to Questionnaire laundry detergent from National Procurement

DK.doc11. 05.11.2001 I Answer to Questionnaire laundry detergents from Linds Fabrikker

DK.doc12. 07.11.2001 I Comments to Questionnaire laundry detergents from Belgian Federap

Dep. of the Environment B.doc13. 08.11.2001 I Answer to Questionnaire laundry detergents from Stichting Milieukeur

NL.doc14. 08.11.2001 O Heidi K. Stranddorf, Indkaldelse til møde mandag 26.11. for Den dan-

ske følgegruppe for vaskemidler, version 1.doc15. 08.11.2001 O Heidi K. Stranddorf, Indkaldelse til møde mandag 26.11. for Den dan-

ske følgegruppe for vaskemidler, version 2.doc16. 12.11.2001 I Answer to Questionnaire laundry detergents from Dalli Benelux

NL.doc17. 14.11.2001 I Gerhard Stimmeder, Mail RE Revision of the criteria for laundry deter-

gents under the EU ecolabelling scheme -AGENDA NEEDED (evenif draft agenda).doc

18. 14.11.2001 O Kirsten Schmidt, Reminder reg Questionnaire.doc19. 14.11.2001 I Answer to Questionnaire laundry detergents from Eco-label DK.doc20. 14.11.2001 I Answer to Questionnaire laundry detergents from VKI Austrian Con-

sumer Association A.doc21. 14.11.2001 I Comments to Questionnaire laundry detergents from VKI A.doc22. 15.11.2001 I Answer to Questionnaire laundry detergents from Henkel-Ecolab

Denmark DK.doc23. 15.11.2001 I Answer to Questionnaire laundry detergent from National Standard

Organisation Irl.doc24. 19.11.2001 I Answer to Questionnaire laundry detergents from the Danish con-

sumer Information Centre DK.doc25. 22.11.2001 O Heidi K. Stranddorf, Invitation for 1st ahWG meeting.doc26. 22.11.2001 O 1st ahWG meeting - Agenda.doc27. 22.11.2001 O DHI, dk-TEKNIK, 1st report Revison of Eco-label Criteria Laundry

Detergents.doc28. 22.11.2001 O Heidi K. Stranddorf, Møde i Den danske følgegruppe for vaske-

midler.doc29. 22.11.2001 O 1. Følgegruppemøde - Forslag til Dagsorden.doc30. 23.11.2001 I Answer to Questionnaire laundry detergents from Procter & Gam-

ble.doc31. 23.11.2001 I ÅF-report from Procter & Gamble.pdf32. 26.11.2001 I Answer to Questionnaire laundry detergents from Swedish Society for

Nature Conversation S.doc

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33. 26.11.2001 O Birgitte Bo, RE AHWG - Laundry Detergents.doc34. 27.11.2001 I Answer to Questionnaire laundry detergent from Dept. for the Envi-

ronment, Catalonia, Spain.doc35. 28.11.2001 O Birgitte Bo, Change of meeting date for the 3rd ahWG meeting for

Laundry Detergents.doc36. 29.11.2001 I Answer to Questionnaire laundry detergents from Esselunga S.P.A.

I.doc37. 30.11.2001 O Birgitte Bo, RE Change of meeting date for the 3rd ahWG meeting for

Laundry D etergents..doc38. 03.12.2001 I Answer to Questionnaire laundry detergent from AENOR S.doc39. 04.12.2001 I Arno Dermutz, Mail reg. revision of laundry detergents - meeting Dec

6 2001.doc40. 04.12.2001 O Heidi K. Stranddorf, Mail ifm. Referat af 1. Følgegruppemøde.doc41. 04.12.2001 O Heidi K. Stranddorf, Referat 1. Følgegruppemøde.doc42. 04.12.2001 O Torben Madsen, Ecolabel-model laundry detergents.doc43. 04.12.2001 O Mødekort til 2. Følgegruppemøde.xls44. 04.12.2001 I Answer to Questionnaire laundry detergent from Unilever.doc45. 17.12.2001 I EC Meeting Dates 2002.doc46. 20.12.2001 I Phil Dolley, Mail Re Laundry Detergent Ecolabel Revision - UK re-

sponse.doc47. 18.01.2002 I Søren Andersen, Mail reg. Ad Hoc Working Group meetings in Co-

penhagen.doc48. 18.01.2002 I Søren Andersen, Info reg. AHWG meetings in Copenhagen March

2002.doc49. 23.01.2002 I Dees Lijmbach: Paper letter from CEEP – Status of phosphates on

“DID List”50. 29.01.2002 O Heidi K. Stranddorf, Indkaldelse til det 2. møde i Miljøstyrelsens følge-

gruppe for revision af miljømærkekriterie for vaskemidler.doc51. 29.01.2002 O Forslag til dagsorden til 2. Følgegruppemøde.doc52. 29.01.2002 O Birgitte Bo, Vedr. Indkaldelse til det 2. møde i Miljøstyrelsens følge-

gruppe for revision af miljømærkekriterie for vaskemidler.doc53. 04.02.2002 O Heidi K. Stranddorf, Minutes of 1st Ad Hoc Working Group Meeting -

Laundry Detergents - 06.12.2001.doc54. 04.02.2002 O Heidi K. Stranddorf, Minutes 1st adhoc working group 061201.doc55. 04.02.2002 O Heidi K. Stranddorf, Annex 1 of the Minutes of 1st adhoc Working

Group Meeting.doc56. 05.02.2002 I Phil Dolley, Mail Re Minutes of 1st Ad Hoc Working Group Meeting -

Laundry Detergents.doc57. 06.02.2002 I Gerhard Stimmeder, Mail re Phosphates in LD and DDD.doc58. 08.02.2002 O Heidi K. Stranddorf, 2. møde i Den danske følgegruppe for vaske-

midler.doc59. 08.02.2002 O DHI, dk-TEKNIK, Phase 1 report til 2. Følgeruppemøde.doc60. 26.02.2002 O Heidi K. Stranddorf, 2nd ahWG meeting for Laundry Detergents March

4th in Copenhagen.doc61. 26.02.2002 O Heidi K. Stranddorf, Proposed agenda for 2nd ahWG meeting March

4th.doc62. 26.02.2002 O Laundry Detergents 250202 Draft.doc63. 26.02.2002 O DHI, dk-TEKNIK, Laundry Detergents Phase 1 Report.doc64. 26.02.2002 O 2nd ahWG Meeting Copenhagen, Eigthved_pakhus 02.bmp65. 26.02.2002 O Birgitte Bo, Mail to Nicola Marinucci reg. 2nd ahWG meeting Copen-

hagen.doc

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66. 27.02.2002 I Christopher Thornton, Mail Re Invitation to 2nd aHWG meeting forLaundry Detergents.doc

67. 27.02.2002 I Letter from CEEP re ahWG meetings 4-5 March.doc68. 27.02.2002 I CEEP DID list.pdf69. 27.02.2002 I CEEP heavy metals letter.pdf70. 28.02.2002 I Jesus Barrera, Mail reg Spanish comments to minutes of 1st Ad Hoc

Working Group Meeting - Laundry Detergents.doc71. 28.02.2002 I Minutes 1st ahWG meeting with Spanish comments AENOR.doc72. 01.03.2002 I Simon Kvindal, NOPAs forslag til EU vasketestforenkling.doc73. 01.03.2002 O Heidi K. Stranddorf, Answer RE Spanish comments to minutes of 1st

Ad Hoc Working Group Meeting - Laundry Detergents -06.12.2001.doc

74. 01.03.2002 O Mail to Ecolabel Anpa Italy.doc75. 01.03.2002 O Mail to Nicola Marinucci.doc76. 02.03.2002 I Jesus Barrera, Spanish comments AENOR to Minutes of 1st ahWG

meeting.txt77. 03.03.2002 I Arno Dermutz, Autrian comments reg. Ecolabel - rev. Laundry Deter-

gents.doc78. 04.03.2002 I Tzeitel Schuster, Ecosol comments on proposed criteria.doc79. 09.03.2002 I Christopher Thornton, Mail reg. Ecolabel Laundry Detergents - im-

pacts on sewage sludge production.doc80. 09.03.2002 I CEEP, Summarized report Phosfacts.PDF81. 09.03.2002 I CEEP, Extracts from OIE report 3 2002.doc82. 22.03.2002 I M.N.Postma, Stichting Milieukeur comments to phosphates.doc83. 01.05.2002 O Heidi K. Stranddorf, Indkaldelse til det 3. møde i Miljøstyrelsens følge-

gruppe for revision af miljømærkekriteriet for vaskemidler.doc84. 01.05.2002 O Birgitte Bo, Vedr. Indkaldelse til det 3. møde i Miljøstyrelsens følge-

gruppe for revision af miljømærkekriterie for vaskemidler.doc85. 01.05.2002 O Heidi K. Stranddorf, Mail reg. Minutes of 2nd Ad Hoc Working Group

Meeting - Laundry Detergents - 04.03.2002.doc86. 01.05.2002 O Heidi K. Stranddorf, Minutes of the second Ad Hoc Working Group

Meeting.doc87. 03.05.2002 I Christopher Thornton, Comments to Minutes of 2nd ahWG Meeting -

Laundry Detergents.doc88. 06.05.2002 O Presentation at 2. ahWG meeting Laundry Detergents.ppt89. 07.05.2002 O Heidi K. Stranddorf, Mail to Michele Accardo.doc90. 10.05.2002 I Jesus Barrera, Spanish comments AENOR to Minutes of 2nd ahWG

Meeting - Laundry Detergents.txt91. 10.05.2002 I Minutes 2nd ahWG meeting with Spanish comments AENOR.doc92. 10.05.2002 I Jesus Barrera, Letter with comments from AENOR.doc93. 22.05.2002 O Heidi K. Stranddorf, 3rd ahWG meeting for Laundry Detergents May

30th 2002 in Brussels.doc94. 22.05.2002 O 3 rd ahWG meeting - Agenda.doc95. 22.05.2002 O LAUNDRY criteria for 3rd ahWG meeting.doc96. 22.05.2002 O Laundry Detergent Background Report for 3rd ahWG meeting.doc97. 22.05.2002 O Appendix B Performance Test for 3rd ahWG meeting.doc98. 23.05.2002 O Heidi K. Stranddorf, Mail reg. Criteria document for the eco-label for

Laundry Detergents.doc99. 23.05.2002 O LAUNDRY criteria for 3rd ahWG meeting version 2.doc

100. 23.05.2002 O Appendix B Performance Test for 3rd ahWG meeting version 2.doc101. 23.05.2002 O Performance test - comments.doc102. 24.05.2002 I Christian Jassogne, Mail reg. Cesio and Ecosol Position Paper.txt

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103. 24.05.2002 I Cesio and Ecosol Position Paper.doc104. 29.05.2002 I Chantal De Cooman, Mail reg. APAG Position Paper.txt105. 29.05.2002 I APAG Position Paper reg. Quaternary ammonium compounds and

eco-labelling.doc106. 29.05.2002 I APAG Position Paper reg. Quaternary ammonium compounds and

eco-labelling 2.doc107. 29.05.2002 I Bo Nyström, Comments on draft criteria for laundry detergents.doc108. 05.06.2002 I Guido Lena, Mail reg. UEAPME's position paper on the 23rd May

2002 draft Eco-Label criteria for Laundry Detergents.txt109. 05.06.2002 I UEAPME's opinion on draft Commission Decision.doc110. 05.06.2002 I UEAPME, Indagine dosaggio di Zago.doc111. 05.06.2002 I UEAPME, Trends in the Italian market for Laundry Detergents.doc112. 05.06.2002 I UEAPME, Analisi comparata detersivi per capi delicati mercato

Italia.doc113. 10.06.2002 O Heidi K. Stranddorf, Mail reg. Draft criteria for laundry detergents.doc114. 10.06.2002 O Laundry detergent draft criteria fin 040602.doc115. 10.06.2002 I John Pickup, Revised criteria for ecolabelling of dishwashing deter-

gent and laundry detergent - QUATERNARY AMMONIUMCOMPOUNDS.txt

116. 11.06.2002 O Birgitte Bo, Answer to John Pickup - Quaternary Ammonium Com-pounds.txt

117. 12.06.2002 O Birgitte Bo, Answer to Giorgio Cassani incl files.txt118. 17.06.2002 I Göran Almström, Mail reg. Detergent eco-labels.txt119. 05.07.2002 O Birgitte Bo, Mail to Michele Accardo reg. Draft criteria for laundry de-

tergents 05072002.doc120. 08.07.2002 O Birgitte Bo, Mail to Michele Accardo reg. Draft criteria for laundry de-

tergents 08072002.doc121. 08.07.2002 O Laundry detergent draft criteria fin 05072002.doc122. 08.07.2002 I Michele Accardo, Answer to Birgitte Bo reg. Draft criteria for laundry

detergents.doc123. 10.07.2002 I Phil Dolley, Comments reg. Ecolabel for Laundry Detergents.txt124. 19.07.2002 I Marleen Van den Brande, Comments reg. Criteria for laundry deter-

gents.doc125. 06.09.2002 O Heidi K. Stranddorf, Mail reg. Minutes of 3rd Ad Hoc Working Group

Meeting - Laundry Detergents - 30.05.2002.doc126. 06.09.2002 O Presentation af 3. ahWG meeting Laundry Detergents.ppt127. 06.09.2002 O 3rd ahWG Meeting - Calculation of Risk Quotients.doc128. 06.09.2002 O Attached mail from Chantal De Cooman, APAG - Quaternary Ammo-

nium Compounds.txt129. 06.09.2002 O Document from Chantal De Cooman, APAG, reg. Quaternary ammo-

nium compounds and eco-labelling.doc130. 06.09.2002 O Document from Chantal De Cooman, APAG, reg. Quaternary ammo-

nium compounds and eco-labelling 2.doc131. 11.09.2002 I Phil Dolley, Mail reg. Preservative ecolabel crieria for detergents.txt132. 11.09.2002 I Clive Aveyard, Mail to Phil Dolley reg. Preservative ecolabel crieria for

detergents.doc133. 17.09.2002 I Guido Lena, Mail reg. UEAPME's reaction to 6th August draft Eco-

Label criteria on Laundry Detergents.doc134. 17.09.2002 I UEAPME's opinion on 6 August 2002 draft Commission Decision

Laundry Detergents.doc135. 25.10.2002 O Mail reg. a revised position paper from CESIO.txt136. 25.10.2002 O A revised position paper from CESIO.doc

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137. 11.11.2002 O Heidi K. Stranddorf, Mail reg. Changes in proposed criteria for laundrydetergents.doc; performance test and packaging criteria.doc

138. 21.11.2002 O Heidi K. Stranddorf, Mail to Michele Accardo reg. Draft Criteria.doc139. 21.11.2002 O Draft Criteria 20 November (laundry detergents) 2.doc140. 21.11.2002 I Michele Accardo, RE Draft criteria for Laundry Detergents.doc141. 21.11.2002 I Draft Criteria 3 December (laundry detergents).doc142. 21.11.2002 O Lisbeth Frisenborg, Answer to Michele Accardo.doc143. 28.11.2002 I Thomas Krejberg, Mail reg. Changes in proposed criteria for laundry

detergents; performance test and packaging criteria144. 28.11.2002 I Thomas Krejberg, Calculations, Packaging - Tablets.xls145. 29.11.2002 I UEAPME's reaction to the last draft of eco-label criteria on laundry

detergents.doc