Joint Research Centre the European Commission's

in-house science service

Amendment of

the EU Ecolabel

Criteria for the

Textile product

group

Summary of the

final proposal

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Preparation of the amendment and key issues 1. Overview of amendment development and consultation 2. Fibre content threshold and recycled fibres 3. Cotton fibre criterion 1a and 1b 4. Criterion 1c, 1 d, and Wool and other keratin fibres 5. Chemicals and process criteria 6. Corporate Social Responsibility criteria 7. Duration of amendment and validity period of Textiles

criteria

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1. Overview of the amendment and consultation

CB Forum session on

issues matrix

virtual CB Forum

consultation on draft v1 Member State provided with draft v3

Commission ISC on draft v2

2016

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2. Pre-amble to the textile fibre criteria Source: CB Forum, virtual CB Forum, Member State proposals in 04/16 consultation, Member State comments received Rationale: Highlight the exceptions for the whole product and individual fibres used. New exception clarifies recycled cotton exclusion from calculation of cotton requirement. Proposed amended text:

Any fibre, including the above listed ones, may be used without having to meet the textile fibre criteria if it contributes to less than 5% of the total weight of the product, or if it constitutes a padding or lining. With the exception of polyamide and polyester the textile fibre criteria do not have to be met in the following cases: o By the whole product if the fibres contain recycled content that in total amounts to at least 70 % by weight

of all the fibres in the product, o By individual fibres forming part of the ecolabelled product where the fibre type contains at least 70 % by

weight of recycled content. For the purposes of calculating the percentage of cotton in a product that shall be required to comply with criterion 1(a) or 1(b), the recycled cotton fibre content shall be deducted from the required minimum percentages except in the case of clothing for babies under 3 years old.

Textile fibre criteria

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3. Cotton fibre criterion 1a and 1b

Balance between organic cotton criterion 1a and IPM cotton criterion EUEB view: Overall consensus that organic cotton shall be promoted with the Ecolabel. Organic cotton is environmental preferential to IPM cotton. However, organic cotton is more expensive and its market availability is less than IPM cotton.

EUEB and CB forum: 1. Verification of GMO free cotton is an additional burden in criterion 1a and makes

IPM cotton more appealing to applicants 2. Ecolabel is a different label than organic labels therefore the relevance of the

organic standards’ principle of using GMO free cotton is relevant only when a claim of organic content is made (criterion 28)

MS have provided to the EC and EUEB alternative proposals and expressed their views on the amendmend proposal sent to MS before the meeting.

Textile fibre criteria

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Criterion 1 and 28. Cotton criterion and claims NEW: Improved overall 'rules' for the criterion: - Only in the case that an organic cotton claim is made under criterion 28, for

the production standard 1(a) all conventional cotton and IPM cotton that is blended with organic cotton shall come from non-genetically modified varieties;

- For the purposes of calculating the percentage of cotton in a product that shall be required to comply with criterion 1(b), any organic cotton fibre content shall be deducted from the required minimum percentage.

Ref: Page 4 of Criteria Decision on Textiles

Criterion 28: amend optional text regarding using cotton that is GMO free - Table 11 in Criterion 28. Information appearing on the Ecolabel,

Textile fibre criteria

Fibres used Production specification Text that may be displayed

Cotton fibres Organic content of more than 50 % Made with xx % organic cotton.

Only GMO-free cotton used

Organic content of more than 95 % Made with organic cotton.

Only GMO-free cotton used

IPM content of more than 70% Cotton grown with reduced pesticides

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1. Cotton and other natural cellulosic seed fibres Source: virtual CB Forum, EUEB, Member State proposals. Rationale: 1. Emphasise that 1(d) provides the option to verify the annual volume of cotton, 2. Introduce GM cotton verification that is more precise, deleting the previous general

reference to Directive 1830/2003, and adding reference to EU Reference Methods for GMO analysis and IPM schemes excluding GMO cotton as means of verification,

3. Edit the restricted pesticide list to align with the Footwear/Furniture criteria and reflect Oeko Tex 100 (2016),

4. Remove the restrictive reference to cotton bales in 1(b) and (d)

Textile fibre criteria

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1. Cotton and other natural cellulosic seed fibres Improved overall 'rules' for the criterion: - All organic and IPM cotton shall be fully traceable in accordance with criterion

1d, with verification accepted based on the annual volume of cotton purchased or the content of the final product;

Replacement text in 1(a) verification:

For conventional or IPM cotton that is blended with organic cotton, a qualitative screening test for common genetic modifications carried out according to EU Reference Methods for GMO analysis 1 and indicating a GMO free result shall be accepted as a proof of compliance. Tests shall be made on samples of raw cotton from each country of origin and before it passes through any wet treatment. Certification of IPM cotton by schemes that exclude genetically modified cotton shall be accepted as proof of compliance. Verification reference: 1. European Commission, European Union Reference Laboratory for GM Food and Feed - Qualitative GMO detection PCR methods, http://gmo-crl.jrc.ec.europa.eu/gmomethods/

Textile fibre criteria

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1. Cotton and other natural cellulosic seed fibres Updating of the pesticide list: Alachlor, aldicarb, aldrin, campheclor (toxaphene), captafol, chlordane, 2,4,5-T, chlordimeform, chlorobenzilate, cypermethrin, DDT, dieldrin, dinoseb and its salts, endosulfan, endrin, glyphosulfate, heptachlor, hexachlorobenzene, hexachlorocyclohexane (total isomers), methamidophos, methyl-o-dematon, methylparathion, monocrotophos, neonicotinoids (clothianidine, imidacloprid, thiametoxam), parathion, phosphamidon, pentachlorophenol, thiofanex, triafanex, triazophos Key: o Oeko-Tex 100 (2016) o Pesticide already listed o Correction of 2014 Decision

Textile fibre criteria

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3. Wool and other keratin fibres Source: virtual CB Forum Rationale: Clarify and minimise the verification burden of the composite sampling instructions, with its intended focus on sales lots and processing lots. Proposed amended verification text: The test should be made on sales lots of raw wool, by country of origin (if mixed) and before any wet processing. A minimum of one composite sample of multiple farmer or sales lots from each country of origin shall be tested per processing lot. A composite sample should consist of either of the following: (i) Wool fibres from at least 10 randomly selected farmer sales lots within the sales processing lot, or (ii) One sample per farmer supplying the processing lot where there are less than 10 sales lots within the processing lot. Alternatively a test report may be submitted for all farmer or sales lots in a processing lot.

Textile fibre criteria

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3. Wool and other keratin fibres Proposed amended verification text, alternative proposal (UK): The test should be made on sales lots of raw wool, by country of origin (if mixed) and before any wet processing. A minimum of one composite sample of multiple farmer or sales lots from each country of origin shall be tested per processing lot. A composite sample should consist of either of the following: (i) Wool fibres from at least 10 randomly selected farmer sales lots (by country of

origin), where there are more than 10 sales lots for that country of origin within the sales processing lot, or

(ii) One sample per sales lot or farmer lot (whichever is less) supplying the

processing lot where there are less than 10 sales lots for that country of origin within the processing lot.

Alternatively a test report may be submitted for all farmer or sales lots in a processing lot.

Textile fibre criteria

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13(b) Substances of Very High Concern (SVHC’s) Source: DG ENV/JRC Rationale: Alignment with the REACH SVHC process, as referred to in the EU Ecolabel Regulation Article 6(7), and the 'standard' text now being used for all products. Without the 'and' verification is implied for a much broader and undefined range of potential Article 57 substances.

Proposed amended text: The final product including any component or accessory shall not, unless specifically derogated, contain substances that:

(i) Meet the criteria in Article 57 of Regulation (EC) No 1907/2006, and (ii) Have been identified according to the procedure described in Article 59(1) of Regulation (EC) No 1907/2006 which establishes the candidate list for substances of very high concern.

This applies to substances used to impart function to the final product and to substances that have been intentionally used in production formulas.

No derogation shall be given concerning substances of very high concern that are present in a textile article, or in any homogeneous part of a textile article, in concentrations higher than 0,10 % (weight by weight).

Chemicals and process criteria

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14. Substitution of hazardous substances and mixtures used in dyeing, printing and finishing Source: DG ENV/JRC, CB Forum Rationale: Addition of reference to mixtures, thereby reflecting the scope of Article 6(6) of the EU Ecolabel Regulation. The DSD Directive has now been withdrawn - it has also been deleted in new criteria sets. Additional reference to fibres applies to all forms of synthetic fibres.

Proposed amended text:

Substances and mixtures applied to fabrics and knitted panels during dyeing, printing and finishing processes which remain on the final product and, in accordance with Regulation (EC) No 1272/2008 of the European Parliament and of the Council meet the criteria for classification with the hazard classes or risk phrases listed in table 5 shall not be used unless they have been specifically derogated. These restrictions shall also apply to functional substances incorporated into synthetic fibres and man-made cellulose fibres during their manufacturing. This criterion applies to production chemicals in the form that they are applied to the product, either as substances or mixtures.

Chemicals and process criteria

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Table 6. derogation (iv) Water, dirt and stain repellents/Appendix 1, d(iii) Source: DG ENV/JRC, CB Forum Rationale: Ensures the derogation reflects the most common substitutes used in the market, as reviewed by the Danish EPA report ‘Alternatives to perfluoroalkyl and polyfluoro-alkyl substances (PFAS) in textiles'. The study found that many have been tested according to OECD 302b (inherent biodegradability) but very few for bioaccumulation.

Proposed amended text:

The repellent and its degradation products shall be either:

- readily and/or inherently biodegradable and or, - Non-bioaccumulative in the aquatic environment, including aquatic sediment.

Chemicals and process criteria

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14. Substitution of hazardous substances and mixtures used in dyeing, printing and finishing Source: Conclusion of CB Forum Rationale: Clarification that these types of auxilliaries, as well as other potential auxilliaries are covered. Flexibility to accept calculations as verification has also been introduced. Proposed amended verification text:

(v) Auxilliaries , comprising including: Carriers, Levelling agents, Dispersing agents, Surfactants, Thickeners, Binders,

If the production formulas include auxilliaries that carry the hazard classifications specified in derogation (v) verification shall be required based on laboratory testing of a final or intermediate product, or alternatively a calculation of the carry-over of classified auxilliaries from production processes onto the final product.

Chemicals and process criteria

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16(b) Emissions to air from printing and finishing processes

Source: Conclusion of CB Forum Rationale: Introduce flexibility to accept VOC calculations, with reference to EU BAT (see the Textile BREF p-262) Proposed amended verification text:

The applicant shall demonstrate compliance according to EN 12619 or other equivalent standards. Calculation of the emissions of organic compounds based on the method described in the most current European Commission Reference document for best available techniques for the Textiles Industry (2003) shall also be accepted.

Chemicals and process criteria

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Colour fastness criteria 20 and 21

Source: Virtual CB Forum Rationale: Feedback indicated that the original criterion was not feasible for fashion denim. Cross-checking by JRC indicated that the proposal from Norway should be adopted, but that dark denim shades and new dyeing systems can meet the existing criterion. Proposed amended text:

Criterion 20. Colour fastness to wet rubbing The colour fastness to wet rubbing shall be at least level 2-3. A level of 2 is allowed for dark coloured denim and a level of 1 for all other denim colour shades. Criterion 21. Colour fastness to dry rubbing The colour fastness to dry rubbing shall be at least level 4. A level of 3-4 is allowed for dark coloured denim and a level of 2-3 for all other denim colour shades.

Fitness for use criteria

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26. Fundamental principles and rights at work Source: DG ENV/JRC Rationale: Alignment with computer and footwear labour criteria. This provision allows for greater flexibility and, potentially, reduced costs in providing verification. Proposed new text:

In countries where ILO Labour Inspection Convention, 1947 (No 81) has been ratified and ILO supervision indicates that the national labour inspection system is effective and the scope of the inspection system covers the areas listed above 2, verification by labour inspector(s) appointed by a public authority shall be accepted. Footnote reference: 2. See ILO NORMLEX (http://www.ilo.org/dyn/normlex/en) and supporting guidance in the User Manual

Corporate Social Responsibility criteria

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Appendix 1. RSL restrictions e(i)/g(iii) Source: DG ENV Rationale: Alignment with functioning of biocide regulatory framework in the EU. Proposed new text:

e(i) Biocide finishes used to impart biocidal properties to the final products.

Biocides Biocidal products (within the meaning of Article 3(1)(a) of Regulation (EU) No 528/2012 of the European Parliament and of the Council) shall not be incorporated into fibres, fabrics or the final product in order to impart biocidal properties. g(iii) Biocides used to protect textiles during transportation and storage. Only biocidal products that contain active substances that are authorised approved under Regulation (EC) No 528/2012 of the European Parliament and of the Council are permitted for use. Applicant should consult the most current authorisation list: https://echa.europa.eu/web/guest/information-on-chemicals/biocidal-active-substances

Restricted Substance List

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Appendix 1. f. Detergents, surfactants, softeners and complexing agents

Source: Conclusion of CB Forum Rationale: 1. Detergents re-introduced in order to clarify the scope of the restriction. Weight

calculation to be made at each production site. 2. Correction - the ISO standard refers to ultimate biodegradability. Reference to

detergents introduced, as per CB Forum discussions and to align with f(ii). 3. Reference introduced to classification as hazardous to the aquatic environment,

aligning with the Detergents revision.

Restricted Substance List

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Appendix 1. f. Detergents, surfactants, softeners and complexing agents

Proposed new text:

(ii) All detergents, surfactants, fabric softeners and complexing agents At least 95 % by total weight of all fabric softeners, complexing agents, detergents and surfactants used at each wet processing site shall be: (iii) Non-ionic and cationic detergents and surfactants Non-ionic and cationic detergents and surfactants used at each wet processing site that are classified as hazardous to the aquatic environment according to Regulation (EC) No 1272/2008 of the European Parliament and of the Council shall be ultimately biodegradable under anaerobic conditions.

Restricted Substance List

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7. Duration of amendment and validity of criteria Expected time plan of Amendment on Textiles:

1. November 2016, Regulatory Committee decision 2. Adoption of the amendment Decision ap. June 2017 3. Current validity of criteria June 2018.

The amendment Decision will be valid for only 1 year. Are the criteria environmentally ambitious to extend their validity period?

• Indication by recent independent study commissioned by Germany comparing different Ecolabels on Textiles shows that the EU Ecolabel criteria meet the highest environmental standards in the market. Ref: https://www.siegelklarheit.de/vergleichen/textilien/

Criteria revision process needs 2,5 years time. Constraints on available EC/MS resources

Duration of Amendment and validity of criteria

New point: Proposal to add in the amendment a prolongation of the Criteria of Textiles until 2020. The amendment Decision will then have additional 2 years time.

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