Criteria for IMAGING EQUIPMENT - Europasusproc.jrc.ec.europa.eu/furniture/docs/Questionnaire...

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EU Ecolabel and GPP criteria for the product group “Wooden Furniture” – Preliminary recommendations Revision of European Ecolabel and Green Public Procurement Criteria for the product group Furniture QUESTIONNARIE TO ANALYSE THE EXISTING SCOPE AND CRITERIA FOR FURNITURE PRELIMINARY RECOMMENDATIONS Stakeholder Consultation Document April 2013

Transcript of Criteria for IMAGING EQUIPMENT - Europasusproc.jrc.ec.europa.eu/furniture/docs/Questionnaire...

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EU Ecolabel and GPP criteria for the product group “Wooden Furniture” – Preliminary recommendations

Revision of European Ecolabel and Green Public Procurement Criteria for the product group

Furniture

QUESTIONNARIE TO ANALYSE THE EXISTING SCOPE AND CRITERIA FOR FURNITURE

PRELIMINARY RECOMMENDATIONS

Stakeholder Consultation Document

April 2013

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INDEX

1. OBJECTIVE.................................................................................................................................................................................................................3

2. EU ECOLABEL AND GREEN PUBLIC PROCUREMENT (GPP).............................................................................................................................3

3. PRELIMINARY CONSIDERATION ON REVISION OF SCOPE AND CRITERIA.....................................................................................................4

4. QUESTIONNAIRE.......................................................................................................................................................................................................6

4.1 DEFINITION AND SCOPE..........................................................................................................................................................................................7

4.2 ISSUES REGARDING CURRENTLY VALID CRITERIA...........................................................................................................................................9

4.3 NEW/ADDITIONAL CRITERIA.................................................................................................................................................................................19

4.4 ADDITIONAL DISCUSSION POINTS.......................................................................................................................................................................24

5. SUMMARY................................................................................................................................................................................................................ 26

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1. OBJECTIVE

This document constitutes one of the initial stages of the revision of the EU Ecolabel and the Green Public Procurement criteria (GPP) for furniture. The revision process takes into account the possible expansion of the scope for this product group and consequently provides additional criteria to other types of furniture than the wooden one.

One of the goals of the revision is to obtain simplified criteria addressing the most important environmental impacts of the furniture from a life cycle perspective.

This document is intended to be circulated to stakeholders in order to raise awareness of this revision and to obtain feedback on existing criteria and proposed changes. Contact with relevant stakeholders, such as competent bodies, manufacturers and retailers is essential to evaluate the current Ecolabel and GPP criteria.

We ask you to read this document carefully and provide your feedback using the associated comment fields.

2. EU ECOLABEL AND GREEN PUBLIC PROCUREMENT (GPP)

The EU Ecolabel and Green Public Procurement (GPP) are instruments which have been introduced in the European Union to encourage and stimulate the production and consumption of more environmentally friendly products and services throughout their life cycle, in both – private and public – sectors. These schemes help purchasers and consumers to make more informed decisions through certification of the environmental credentials of a product or service.According to the information facilitated by the web of the European Commission 1, the EU Ecolabel is a voluntary label that helps you identify products and services that have a reduced environmental impact throughout their life cycle, from the extraction of raw material through to production, use and disposal. When developing the EU Ecolabel criteria for products, the focus shall be put on stages and aspects in which the product has the highest environmental impact, and this differs from product to product. The requirements shall be established at the level which can be met by around 10 to 20% of most environmentally friendly products available currently on the market.

Green Public Procurement (GPP)2 is a process where public authorities seek to procure goods, services and works with a reduced environmental impact throughout their life cycle when compared to goods, services and works with the same primary function that would otherwise be procured. GPP is a voluntary instrument, which can be used in the calls for tenders of the public authorities, to cover in the evaluation process also the environmental aspects of the offers.

1 For more details please see: http://ec.europa.eu/environment/ecolabel/. 2 For more details, please see: http://ec.europa.eu/environment/gpp/index_en.htm.

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3. PRELIMINARY CONSIDERATION ON REVISION OF SCOPE AND CRITERIA

A preliminary check to analyze the scope and existing criteria for the product group of furniture has been carried out. In this step, a preliminary proposal for consideration to modify or/and add or remove criteria, and on the potential extension of the scope has been formulated. The extension of the criteria scope is proposed, among other, to include consumer health and safety aspect, as these are considered to have potential to stimulate the interest of many companies.

One of the key issues for discussion is the possibility to expand the product group scope from wooden furniture to other types of furniture. According to the European Furniture Manufacturers Federation, the main materials used in furniture production are: wood (-based materials), metal, plastics and textiles. Therefore, particular attention will be given to the environmental aspects of these materials (including also impacts of surface treatment and adhesives used).

In the Commission Statement from the Directorate General Environment accompanying the development of criteria for wooden furniture the following aspects were pointed out to be considered in this revision:

The availability of certified wood on the market will be checked and the percentage requested will be adjusted accordingly via a revision of the criteria.

The exclusion of all halogenated flame retardants.

The limit values of elements and substances allowed in recycled wood fibres for the production of wood-based material must be updated.

The allowance for dangerous substances classified as H420 (R59).

To include a global warming potential indicator (GWP).

To exclude manufactured nano-materials added to the product.

To increase the percentage of virgin wood and percentage of wood based materials coming from sustainably managed forest or recycled sources.

Market data and possibilities to substitute chemical preservation of outdoor products by other methods or with resistant and sustainable wood.

Use phase criteria on VOC and Formaldehyde emissions.

The exclusion of substances of very high concern, especially with regards to the substances referred to and defined in Article 59 (1) (also referred to as the “Candidate List”) of the Regulation Nº 1907/2006.

The definition of legal forestry especially with regard to the FLEGT.

The definition of Sustainable Forest Management (SFM).

The exclusion or inclusion of GMO wood and its relevance.

The relation between criteria for Green Public Procurement of wooden furniture/floor covering and criteria in the EU Ecolabel.

The necessity of labelling ingoing PVC material and possibility of sorting out and collecting wooden products with PVC content.

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Besides the recommendations given in the above-mentioned statement, a preliminary check to analyze the scope, criteria and the existing definition for wooden furniture has been carried out based on the following information and data regarding furniture sector collected so far:

- Legislation,

- European Standards,

- Other environmental labelling schemes,

- Analysis of market data,

- Review of available Life Cycle Assessment studies

Based on this preliminary analysis, some of the issues that are proposed for consideration and discussion with the stakeholders are listed below:

The possibility to extend the product group from wooden furniture to other types of furniture.

The possibility of harmonization with other eco-labels (Nordic Swan, Blue Angel, etc), in accordance with the recommendation of the EU Ecolabel Regulation 66/2010.

Setting specific requirements for materials other than wood such as plastics, metals and textiles.

Several criteria regarding substances could be potentially grouped under one horizontal criterion for excluded and restricted substances and mixtures.

Setting restrictions for surface treatment agents associated with certain negative health and environment impacts.

The possibility of tightening requirements relating to the use of halogenated organic flame retardants, biocides and heavy metals.

Introduction of specific requirements concerning ecodesign.

Promoting the use of recycled materials.

Requirements related to recycling of materials in the production processes and reduction in waste quantities during manufacturing.

Furthermore, it is proposed for consideration to reorganise the criteria in relation to the product life cycle, e.g. raw materials extraction, manufacturing and assembly, use phase and end-of-life.

The initial focus of this work is to review the existing EU Ecolabel scope and criteria for wooden furniture. The questionnaire is divided into the following parts (in each of them a brief introduction on the aspects proposed for consideration and subsequently questions to the stakeholders are included):

Section 4.1 Definition and scope

Section 4.2 Issues regarding currently valid criteria

Section 4.3 New criteria for consideration

Section 4.4 Additional discussion points

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4. QUESTIONNAIRE

First name: Surname:

Organisation: Job Title:

Email: Phone Number:

Organisation type:

Industry Government NGO

Environmental Agency

Other _______________________________________

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4.1 DEFINITION AND SCOPE

The following scope definition is preliminarily proposed for consideration for the EU Ecolabel on furniture:

The product group of 'furniture' shall comprise free-standing or built-in units of different types of furniture used for storing, hanging, lying, sitting, working, cooking and eating in domestic and non-domestic situations and in the context of indoor or outdoor use. Non-domestic situations include, for example, offices and schools as well as restaurants and hotels.

The product group shall include furniture based on wood and wood-based materials, metal, plastic, padding, textiles and other materials (e.g. bamboo or willow). Furniture can also contain other components made, for instance, of glass or stone.

The following condition shall be fulfilled:

(a) The product shall be made of at least X % w/w solid wood or wood-based materials (to be discussed, this could exclude some types of furniture based on other materials).

(b) The weight of any individual material, other than solid wood and wood-based materials, shall not exceed X % of the total weight of the product. The total combined weight of such materials shall not exceed X % of the total weight of the product (to be discussed, this could exclude some types of furniture).

Moreover, a change of the product group name from “wooden furniture” to “furniture” is proposed.

The scope of the product group in the context of indoor or outdoor use is limited to:- Domestic furniture including children's furniture, kitchens, bathrooms, bedrooms, dining-rooms and living-room furniture, mattress

supports excluding mattresses dealt within a separate product group under the EU Eco-label scheme for bed mattresses3,- Non-domestic furniture including products for offices and schools as well as restaurants and hotels.

The new product group definition could include:- Upholstered furniture,- Contract furniture where steel or other metals are used together with wood,- Kitchen and office furniture where plastic and metal materials are used.

3 Commission Decision of 9 July 2009 (2009/598/EC) establishing the ecological criteria for the award of the Community Ecolabel for bed mattresses, available online at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:203:0065:0080:EN:PDF.

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As a matter of consequence and considering the types of furniture with greater market shares (e.g. furniture for dining rooms, living rooms, bedrooms and kitchens, seats and office furniture), the proposed new product group scope definition would include most market segments of the furniture industry.

The product group would not include technical equipment and fittings. Specific types of products which primary function is not to be used as domestic or office furniture should be excluded from the scope (e.g. streetlights, bike-parks, playgrounds, building products – steps, walls, panels - , sanitary equipment and carpets).

Finally, according to the current definition of wooden furniture: “Glass, if easily replaceable in case of damage or breakage, may be excluded from the weight calculation as may technical equipment and fitting”. However, based on the preliminary analysis of LCA studies, glass should be not excluded "a priori" from the scope, due to relevant impacts associated with the use of this material like the use of natural resources and energy.

In the below section we would like to ask for your feedback regarding the above-given proposal. To make a cross in YES/NO double click the gray box and mark activate.

1. Do you agree with the proposed product group name?Yes No

If no, please explain why and/or propose modification.

2. Is the proposed definition appropriate and suitable for this product category

Yes No

If no, please explain why and/or propose modification

3. Are there any furniture types or materials which are excluded by this definition which, in your opinion, shall be included?

Yes No

If yes, please indicate.

4. Are there any furniture types or materials which shall be, in your opinion, explicitly excluded from the scope of the product group, but which are included by the proposed definition?

Yes No

If yes, please indicate.

5. Are differences in definition and scope necessary for the EU Ecolabel and GPP?

Yes No

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If yes, please indicate what aspects shall be covered.

6. Shall minimum share (% of weight) be set for solid wood and wooden based material as well as for any individual material other than them?

Yes No

If yes, please indicate proposed value(s) for wood (or each material) or value(s) ranges and explain rationale for your proposal.

7. Do you agree that glass components, as well as all other replaceable pieces, should be included in the scope and in the weight calculation?

Yes No

If no, please explain why and/or propose modification.

4.2 ISSUES REGARDING CURRENTLY VALID CRITERIA

EU ECOLABEL CRITERIA

The current EU Ecolabel criteria for wooden furniture aim in particular at promoting reduction of the impact of wooden furniture on the environment and on human health throughout its life cycle. More specifically, they focus on:

- the use of materials produced in a more sustainable way,

- reduction of use of hazardous substances and decreasing emissions of polluting substances,

- product durability.

In order to be awarded the EU Ecolabel for wooden furniture, a product must fall within the product group “wooden furniture” and must comply with the ecological criteria. The currently valid criteria are set for4:

1. Product description

2. Hazardous substances

4 Commission Decision of 30 November 2009 (2009/894/EC) on establishing the ecological criteria for the award of the Community eco-label for wooden furniture are, available online at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:320:0023:0032:EN:PDF.

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3. Wood and Wood-Based Material Requirements

4. Criteria for Surface Treatments

5. Criteria for the Assembly of Furniture

6: Criteria for the Final Product

The preliminarily issues identified for consideration in the revision of the currently valid criteria and questions to stakeholders are contained in below sections.

Criterion 1: Product description

In accordance with the current criterion formulation "A description of the product shall be provided (functional description, product name or reference code; if various types of the same product are available a description of the subtypes to which the application applies). Information shall be provided on the total weight of the product, the materials used in the product, including fixtures and fittings, and their respective weight".

Questions to stakeholders and issues for consideration regarding criterion 1

8. Do you consider the current criterion formulation appropriate?

Yes No

If no, please provide explain why and, if possible provide a proposal for modification.9. Do you consider the current formulation of assessment

and verification procedure (i.e. providing a description of the product including functional description, product name or reference code, the total weight of the product, the materials used in the product, including fixtures and fittings, and their respective weight) sufficient and appropriate?

Yes No

If no, please provide explain why and, if possible provide a proposal for modification.

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Criterion 2: Hazardous substances

In general, the environmental impacts of furniture are associated mostly with the production and treatment of raw materials used in the manufacturing, rather than with the assembling of the furniture itself. The main impact related to the use of hazardous substances is the eutrophication of surface and ground water caused by release during production, use or disposal of these substances.

Therefore, the focus in the revision will be given to the environmental aspects of the main raw materials that are being used in furniture and their finishing treatments. According to this, criteria should be defined to reduce the environmental impact in relation to the use of hazardous substances.

The following issues are proposed to be considered for the revision of the current criterion:

- Restrictions on substances and/or mixtures meeting the criteria for classification with certain hazard statements in accordance with CLP Regulation and restriction of substances from the candidate list of substances of very high concern (SVHC) (compliance with the new EU Ecolabel Regulation EC/66/2010 article 6(6)). Expanding the list of H-classes similarly to the recently developed or revised EU Ecolabel criteria for other product groups.

- Among the issues of concern related to plastic production are: the use of additives such as plasticisers or flame retardants with suspected environmental and health hazardous properties.

- Halogenated flame retardants such as short chain chloroparaffins (C10-C13) are listed on the candidate list of Substances of Very High Concern and hexabromocyclododecane (HBCDD) (and all major isomers) and tris(2-chloroethyl)phosphate (TCEP) are listed in Annex XIV of REACH regulation for authorisation.

- Some pigments such as Lead sulfochromate yellow (C.I. Pigment Yellow 34) and Lead chromate molybdate sulphate red (C.I. Pigment Red 104) are also included in the authorisation list.

- Phthalates are typically used as plasticisers in PVC. Phthalates classified as toxic for reproduction (Article 57 (c) of REACH) such as N-pentyl-isopentylphthalate, Diisopentylphthalate and Bis (2-methoxyethyl)phthalate are included in the candidate list of SVHC while dibutyl phthalate (DBP), bis (2-ethylhexyl)phthalate (DEHP), benzyl butyl phthalate (BBP) and Diisobutylphthalate (DIBP) are included in the Annex XIV under REACH Regulation.

- Evaluation of halogenated flame retardants used in this product group should be also conducted.

- In the case of surface coatings the key environmental and health impacts are associated with the use of surface treatment agents such as heavy

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metals, phthalates and halogenated organic flame retardants, some of which are classified with health and environmental hazard statements.

- Hazardous substances associated with the presence of solvents should be further investigated in order to consider new restrictions.

- Several criteria could be potentially merged within one criterion regarding excluded and limited substances and mixtures (e.g. the current criteria 2, 3c, 3d, 3e, 4a, 4b, 4c, 4d, 4e and 5a).

Questions to stakeholders and issues for consideration regarding criterion 2

10. Which substances or functional groups of substances contained in furniture products and used in their manufacturing are of special concern? Could you indicate them?

Please indicate and, if possible, provide supplementary information.

11. Are you aware of substances which should be particularly investigated to see if they should be explicitly excluded?

Yes No

If yes, please provide supplementary information.

12. Do you agree to merge several criteria (e.g. criteria 2, 3c, 3d, 3e, 4a, 4b, 4c, 4d, 4e and 5a) within one criterion 2 regarding excluded and limited substances and mixtures?

Yes No

If no, please explain the approach you consider more appropriate.

13. Is the current verification procedure (i.e. submitting a declaration of compliance with this criterion, together with a list of ingredients and related documentation, such as Safety Data Sheets) sufficient and appropriate?

Yes No

If no, please explain why and, if possible, provide a proposal for modification.

14. Is administrative workload for the Competent Bodies and/or applicants considered reasonable?

Yes No

If no, please provide supplementary information.

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Criterion 3: Wood and Wood-Based Material Requirements

The key environmental aspects of solid wood are mainly related to the level of legal5 and sustainable character of the forest management it originates from. Among impacts related to uncontrolled wood are loss of biodiversity, erosion and soil degradation. In the development of the EU Ecolabel criteria for copying and graphic paper6 strict requirements regarding this issue is set. The respective criterion specifies that the fiber raw material in the paper may be recycled or virgin fiber. In the later case, 100% of virgin fibres must be sourced from sustainably managed forests which have been certified by independent third party schemes fulfilling the criteria listed in paragraph 15 of the Council Resolution of 15 December 1998 on a Forestry Strategy for the EU 7 or from recycled fibres. This indicates that the current level of at least 70% for solid wood and 40% for wood-based materials sourced from sustainably managed forests which have been certified by independent third party schemes should be revised.

On the other hand, in the GPP criteria, all wood and wood-based materials shall come from sourced managed timber such as FSC, PEFC or any other equivalent means of proof.

It should be taken also into account that if the scope of the EU Ecolabel is extended to other forestry and vegetal materials, such as willow or bamboo, criterion 3 should be considered if it applies also to these materials. For materials with no sustainable source certifications available, origin and traceability could be considered, as well as the possibilities to apply evidence of written procedures on sustainable management chain.

The main categories of wood-based products such as panels are fibreboard, particleboard and plywood are mainly produced with heat and pressure and the addition of an adhesive to glue fibres, particles or sheets of wood. The main environmental impacts are linked to the use of substances such as formaldehyde resins, melamine, polyurethane resins, etc. The development in other environmental schemes such as Nordic Swan for furniture and fitments has led to the implementation of strict criteria, e.g. regarding the content of free formaldehyde. This implicates that the current level of 0,3% (w/w) for products or preparations used in panels and 0,5% for binding agents, adhesives and glues for plywood or laminated wood panels should be analyzed and, if necessary, revised.

5 According to Regulation (EU) 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down the obligations of operators who place timber and timber products on the market. 6 Commission Decision of 7 June 2011 on establishing the ecological criteria for the award of the EU Ecolabel for copying and graphic paper (2011/332/EU), available online at:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:149:0012:0024:EN:PDF. 7 Available online at: http://ec.europa.eu/agriculture/fore/forestry_strategy_en.htm .

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16. What proportion of wood in wooden furniture, according to your knowledge, arises from third party certified sustainable forests?

Please provide supplementary information, if available.

17. Up to what extent is it considered feasible to increase the proportion of certified wood in wood furniture? Please provide your proposal and explanation.

18. Are other forest/biomass materials usually used in furniture sector? If, yes, which materials are used and in which applications?

Yes No...

If yes, please provide supplementary information.

19. It is feasible to set these criteria to other biomass materials such as bamboo, hemp or willow?

Yes No...

Please provide supplementary information, if available.20. Up to what extent is considered feasible to limit the

content of free formaldehyde from untreated raw wood-based materials?

Please provide supplementary information, if available.

21. What is your opinion regarding the restriction on the use of GMO wood in this product group? Please explain, if applicable.

22. Is the current verification procedure (please see the attached criteria text) sufficient and appropriate?

Yes No

If no, please explain why and, if possible, provide a proposal for modification.

23. Is administrative workload for the Competent Bodies and/or applicants considered reasonable?

Yes No

If no, please provide supplementary information.

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Criterion 4: Criteria for surface treatments

One of the main environmental impacts related to the surface treatment are the VOC emissions as a result of the use of organic solvents. One of the more efficient measures to reduce this environmental impact should be limit the organic solvent content and reduce the VOC emissions from products, adhesives and surface treatments substances.

Phthalates shall comply with requirements and restrictions set out in section 2 regarding hazardous substances.

Questions to stakeholders and issues for consideration regarding criterion 4

23. Up to what extent do you consider feasible to decrease VOCs content in adhesives?

Please provide supplementary information.

24. Up to what extent do you consider feasible to limit the content of free formaldehyde?

Please provide supplementary information.

25. Do you have additional proposals regarding revision of this criterion (e.g. regarding biocides)?

If yes, please explain briefly.

26. Is the current verification procedure/test (i.e. appropriate declarations, Safety Data Sheet or equivalent documentation for each chemical product used in the assembly of furniture, test reports or a declaration from the supplier for the free formaldehyde content) sufficient and appropriate?

Yes No

If no, please explain why and, if possible provide a proposal for modification.

27. Is administrative workload for the Competent Bodies and/or applicants considered reasonable?

Yes No

If no, please provide supplementary information.

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Criterion 5: Criteria for the Assembly of Furniture

Main environmental impact associated with the use of adhesives in the furniture assembly is related to the use of organic solvents and the consequent emissions of VOCs. In other environmental schemes, such as Nordic Swan for furniture and fitments, a stricter criterion than the one included in the current EU Ecolabel criteria is set. This implicates that the current level of 5% (w/w) may be is not stringent enough and should be revised.

In the GPP criteria, the VOC content of adhesives shall not exceed 10% (w/w). It should be considered if it is needed to harmonize the respective requirement in Ecolabel and GPP (at least for the comprehensive criterion).

Hazardous substances associated with the presence of adhesives should be further investigated in order to see if additional restrictions are needed.

Questions to stakeholders and issues for consideration regarding criterion 5

28. Up to what extent do you consider feasible to decrease the content of VOCs in the adhesives used in the assembly of furniture?

Please provide supplementary information.

29. Is the current verification procedure (i.e. a declaration provided by the applicant indicating all adhesives used in the assembly of furniture) sufficient and appropriate?

Yes No

If no, please explain why and, if possible provide a proposal for modification.

30. Is administrative workload for the Competent Bodies and/or applicants considered reasonable?

Yes No

If no, please provide supplementary information.

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Criterion 6: Criteria for the Final Product

Lifespan and durability are the key factors which can contribute to minimizing the environmental impact of furniture. Design for durability and reparability shall be guaranteed for ecolabelled products in order to avoid early replacement of furniture.

Other aspects, besides guaranteeing spare parts for repair/replacement, could also be addressed, such as facilitating disassembly/assembly and easy replacement of components without special training/professional equipment.

At the end-of-life, reuse and remanufacturing should be promoted as preferable options.

Criterion 6(a) should cover ergonomic and fit for purpose aspects (not only durability and safety).

Questions to stakeholders and issues for consideration regarding criterion 6

31. Do you agree in setting additional requirements in criterion 6(a) regarding ergonomics and fitness for use? If yes, do you have any proposals which aspects shall be additionally covered and what verification and assessment procedure could be proposed?

Yes No

If yes, please provide your proposal and supplementary information.

32. It is feasible to fix a minimum durability guaranteed (years) after manufacturing?

Yes No

If yes, do you have any proposals how to formulate such a criterion? Could you describe it?

33. Which is the average lifespan of furniture? Please specify, is possible, for various kinds of furniture.

34. Is there any EN durability standard developed to assess durability?

Yes No

If yes, please provide supplementary information.

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35. Do you agree to set more restringing criteria for design for durability and remanufacturing?

Yes No

If yes, please provide supplementary information.36. Should a criterion on information to consumer (6c)

include not only information on assembly, but also information on disassembly and substitution of components and repair?

Yes No

If yes, please provide supplementary information.

37. Is the current verification procedure/test sufficient and appropriate?

Yes No

If no, please explain why and, if possible provide a proposal for modification.

38. Is administrative workload for the Competent Bodies and/or applicants considered reasonable?

Yes No

If no, please provide supplementary information.

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4.3 NEW/ADDITIONAL CRITERIA

Criteria for other materials: plastic, metal, textiles, glass, stone and padding materials

If the scope of the product group is extended in order to allow for inclusion of types of furniture made of other than wood materials, such as metals, plastics, textiles, but also with glass and stone elements, it will be important to set criteria for different materials types. They should then focus on the materials most commonly used in furniture and on the most important environmental impacts associated with these materials.

The following issues could be taken into consideration in the revision of the current criteria:

- PLASTICS: Environmental impacts related to plastic are mainly due to higher energy consumption, the use of non-renewable resources and the inclusion of some additives such as stabilisers, plasticisers and flame retardants with hazardous properties. These issues should be kept in mind in setting requirements regarding plastic materials used in furniture.

In the currently valid GPP criteria, plastic parts ≥ 50g shall be marked for recycling according to ISO 11469 or equivalent and must not contain additions of other materials that may hinder their recycling. Is this also relevant for EU Ecolabel?

- METALS: The most relevant kinds of metals used for the production of furniture are aluminium and steel. The most significant impacts related to their production are linked to energy consumption and the emissions of heavy metals. Due to environmental impacts associated with higher energy consumption, some limits of recycled metal chould be considered. Increasing the share of recycled materials considerably reduces the energy needed to produce these types of materials.

- TEXTILES: Should the respective EU Ecolabel criteria for textiles be used for the particular requirements regarding textiles in furniture, if upholstered furniture is to be included in the scope?

- PADDING MATERIALS are mainly polyurethane foams (PUR-foams) and latex foams used in upholstered furniture as filling materials. Should the padding materials comply with the EU Ecolabel criteria for bed mattresses8 (requirements set for the latex and polyurethane foams)?

- GLASS: Although glass is not as problematic as other non-renewable materials, as raw materials for its production are abundant in nature, the 8 Commission decision of 3 September 2002 establishing revised ecological criteria for the award of the Community eco-label to bed mattresses, available online at:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:236:0010:0015:EN:PDF

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extraction of these raw materials contributes to consumption of natural resources, use and destruction of land, consumption of energy, etc. For this reason, it is important to assess the use of glass. One of the more efficient measures to reduce the environmental impact is the use of recycled glass. Furthermore, the glass used in furniture should be completely recyclable and replaceable. Some type of glass can contain heavy metals that should be avoided, therefore this issue should also be taken into consideration.

- MATERIALS LIKE WILLOW, BAMBOO: For other biomass materials) it should be considered if the same criteria as for wooden materials (see proposal on criterion 3) shall be established.

- OTHER MATERIALS: The current use of other materials (like stone) in furniture products and the environmental impacts associated with them should be further investigated in order to evaluate need for specific restrictions.

Questions to stakeholders

39. Up to what extent is feasible to mark for recycling the plastic materials used in furniture?

Yes No

Please provide supplementary information.

40. What are the main barriers to recycle metal and plastic materials from furniture?

Up to what extent is feasible to recycle metal and plastic materials used in furniture?

Please provide supplementary information.

41. Do you consider feasible and appropriate to set minimum share of renewable materials (wood, bio-plastics, etc.)?

To what extent are bioplastics used in furniture sector?

Yes No

Please provide supplementary information about plastics used, market share and how their sustainability could be assessed and verified.

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42. Is it feasible to set a minimum share of recycled glass for glass components?

Yes No

If yes propose a percentage. If no, please explain why you think so.

43. Should the EU Ecolabel criteria for textiles be used for the respective requirements regarding textiles in furniture?

Yes No

If no, please explain why and, if possible provide your proposal, if possible.

44. Should the padding materials comply with the EU Ecolabel criteria for bed mattresses9 (requirements set for the latex and polyurethane foams)?

Yes No

If no, please explain why and, if possible provide your proposal, if possible.

Introduction of new requirements concerning energy consumption and/or Global Warming Potential indicator

CO₂ and other GHG emissions appears one of the key environmental issues for this product group

They are the result of energy consumption in several stages of the product's lifecycle, especially in the production of materials.

Lighting sources in furniture: In the furniture design light sources play recently more significant role (e.g. in kitchen or living room furniture). Beside user's behaviour, the energy efficiency of lighting is of relevance for the consumption of energy. Therefore, setting respective requirements could be potentially considered in the revised criteria.

Questions to stakeholders

9 Commission decision of 3 September 2002 establishing revised ecological criteria for the award of the Community eco-label to bed mattresses, available online at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:236:0010:0015:EN:PDF

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45. Are lighting sources in furniture sector relevant enough to set a requirement in this criterion set?

Yes No

If yes, please provide supplementary information.

46. What types of light sources (energy class, LEDs, reflector lamps, etc) are used in furniture products?

Please indicate the type of light source and the product type (application, e.g. kitchen furniture).

47. Are you aware if energy consumption has been extensively assessed for furniture production?

Is there any methodology used by furniture industry in order to determine energy consumption? Are there any thresholds /requirements recommended by industry?

Yes No

If yes, please provide supplementary information.

Introduction of specific requirements concerning Ecodesign

In general, it is estimated that over 80% of all product-related environmental impacts are determined during the design phase of a product10.

Questions to stakeholders

48. Is a criterion on “Ecodesign” such as "Design for disassembling" feasible? How could be such criterion shaped?

Yes NoIf yes, please explain your proposal.

10 http://ec.europa.eu/enterprise/ecodesign

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49. Can you provide information on Ecodesign measures currently applied in the sector? Which Ecodesign measures do you consider particularly relevant for these criteria revision process?

Yes NoIf yes, please provide supplementary information.

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4.4 ADDITIONAL DISCUSSION POINTS

Additional points for consideration in the criteria revision

The number of EU ecolabelled products for furniture is considerably lower than for many other product groups and for other environmental schemes (such as Blue Angel, Nordic Swan, etc). So, it is important that the reasons for this situation are well understood and the revised criteria take into account respective concerns. Therefore, additional feedback from stakeholders is welcome on issues not highlighted above with the objective to improve the existing criteria. Comments will be collated to provide further evidence during the revision process. A few general questions are given below. Please feel free to indicate any other issues of relevance.

Questions to stakeholders (mainly for manufacturers, industrial associations)

50. Is your organization interested in applying for EU Ecolabel?

Yes No

51. If your organization had previously applied for the EU Ecolabel?

Yes No

If yes, what was the motivation behind applying? If not, what are the reasons for not considering applying?

52. Can you provide any relevant Life Cycle Assessment or Environmental Product Declaration or any environmental related document?

Yes No

If yes, please provide supplementary information.

53. Do you have any input on the prices of green furniture products compared to conventional products in furniture sector, which could be used subsequently in the Life Cycle Costing analysis for GPP?

Yes No

If yes, please provide supplementary information.

54. Any other issues of relevance

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5. SUMMARY

As stated above, this stakeholders' consultation form one of the first steps of the process to revise the EU Ecolabel and GPP criteria for wooden furniture. The stakeholders' opinion is vital to know the main barriers that they find regarding the practicability of the current criteria and to ensure that the revised criteria will be more appealing to the industry (taking into account that so far there is only one licence-holders of the EU ecolabelled wooden furniture).

We would highly appreciate your feedback on the questions, proposals and other points given above with the aim to know your opinion and to take it into consideration prior to the AHWG meetings.

Information supplied will remain confidential and anonymous. The draft criteria will be discussed with stakeholders at the first AHWG meeting on furniture in October 2013.

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STAKEHOLDERS ARE KINDLY ASKED TO SEND THEIR FEEDBACK DIRECTLY TO THE PROJECT TEAM PER E-MAIL BY THE Friday, 17th MAY 2013 to ensure that all comments can be fully considered in this process: E-mail: [email protected]