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EUROPEAN COMMISSION DIRECTORATE GENERAL JRC

JOINT RESEARCH CENTRE Institute for Prospective Technological Studies (Seville) Sustainable Production and Consumption Unit

2nd

Ad-Hoc Working Group (AHWG) meeting for the

revision of the EU Ecolabel criteria for

Detergent product groups

20-21 October 2015

JRC-IPTS Albert Borschette Conference Centre, Room 3D

Rue de Froissart, 36, 1040 Brussels, BELGIUM

Minutes of the meeting

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Participant List

Name Surname Organisation

1 ARREGUI Cristina IFRA (INTERNATIONAL FRAGRANCE ASSOCIATION)

2 AURANMAA Kirsi The Finnish Ecolabelling Competent Body

3 BASTIANSEN Henriette Colgate-Palmolive

4 BOUDARD Sebastien CHRISTEYNS

5 BOURBON Frederic Werner&Mertz GmbH

6 BOUVY Alain CEFIC / CESIO / ECOSOL

7 BOYANO Alicia Joint Research Centre- European Commission

8 BROUET Cindy AFNOR

9 BRUYNDONCKX Raf European Chemical Industry Council - Cefic aisbl

10 BUJON david NOVAMEX

11 CHIAPPORI Andrea Afidamp

12 COSTINITI Fabio Italmatch Chemicals

13 CUPIDON Blandine BEUC/EEB

14 DAVIDE Bovone Gualadispensing S.p.A.

15 DE RIDDER Kathelijne Belgian Competent body

16 DEN BAKKER Peter Burg Groep

17 DUTEIL Philippe GUALA DISPENSING

18 ESKELAND Marianne Ecolabelling Norway

19 FERRATININ Silvia DG ENV, European Commission

20 GARCÍA Teresa ATQ QUIMYSER S.L.

21 GAST Marcus Umweltbundesamt

22 HUGUET Nicolas ACTION PIN

23 JORDAN GELABERT CRISTINA ATQ QUIMYSER-S L.

24 JOTRAU MATHIEU NOVAMEX

25 KAPS Renata Joint Research Centre- European Commission

26 LANZONI Luca CIAS (Research Centre for pollution control in high sterile room)

27 LILL Andreas European Federation of Cleaning Industries

28 LINSTEN Magnus AkzoNobel

29 LUIJKX Gerard Unilever

30 MEDYNA Galyna Joint Research Centre- European Commission

31 MINESTRINI Stefania DG ENV, European Commission

32 NETO Belmira Joint Research Centre- European Commission

33 NORIN Helena EEB/BEUC

34 PALAIS Frederic Solvay

35 PORTUGAL Laura A.I.S.E.

36 SAHLBERG Ulla Ecolabelling Sweden

37 SCHIPPER Willem PAPA

38 SCHRÖDER Wolfgang Sasol Germany GmbH

39 SCHWARZ Katrin BASF SE

40 STARK Susanne Austrian Consumer Organisation

41 TEMMERMAN Robin Chrisal NV

42 TKACZYK Joanna Polish Centre for Testing and Cerification

43 TOMA Maria-Daniela Ministry of Environment

44 TSUCHIYA Rie Novozymes A/S

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Name Surname Organisation

45 VERRIENTI Stefania Afidamp

46 VITTADELLO andrea MERIEUX NUTRISCIENCES

47 VOSSEN Guy Chrisal

48 WAIDTLØW jakob Ecolabelling Denmark

49 WOLF Oliver Joint Research Centre- European Commission

50 WOLTMANN Lars SMK

51 WREESMANN Carel AkzoNobel

52 ZAGO Tommaso Chimica HTS

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Agenda

Day 1: Tuesday, 20th October 2015

SCHEDULE

1. Introduction 09:30 – 10:00

2. Detergent product groups scope and definitions 10:00 – 11:15

Coffee break 11:15 – 11:45

3. Measurement threshold / Reference dosage/ dosage requirements 11:45-13:00

Lunch break 13:00 – 14:00

4. Toxicity to aquatic organisms criteria 14:00-16:00

Coffee break 16:00 – 16:30

5. Biodegradability criteria 16:30– 18:00

Day 2: Wednesday, 21st October 2015

SCHEDULE

1.

Excluded and limited substances and mixtures criteria:

- Specifically excluded substances and mixtures

- H-statements based restriction

- Specific limited in-going substances: Preservatives, Fragrances, etc.

- Other

09:30 – 11:30

Coffee break 11:30 – 12:00

2. Microorganisms

Sustainable sourcing of ingredients

12:00 – 13:30

Lunch break 13:30 – 14:30

3.

Fitness for use criteria

User instructions / Professional training

User information

14:30 – 16:00

Coffee break 16:00 – 16:30

4. Any other non-horizontal criteria and remaining issues 16:30-17:30

5. Summary and closure of the meeting 17:30 – 18:00

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Contents 1. Introduction – overview of the EU Ecolabel criteria revision process .................................................. 6

2. Definitions and scope ............................................................................................................................ 6

3. Measurement thresholds, reference dosages ....................................................................................... 8

4. Toxicity to aquatic organisms ................................................................................................................ 9

5. Biodegradability ................................................................................................................................... 10

6. Hazardous substances and mixtures ................................................................................................... 10

7. Packaging ............................................................................................................................................. 13

8. Fitness for use ...................................................................................................................................... 14

9. User instructions and information appearing on the EU Ecolabel ...................................................... 15

10. Other issues and criteria proposals/discussion ............................................................................... 15

11. Conclusions and next steps ............................................................................................................. 16

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The following minutes have been split by sessions and then by topics in order to facilitate

reading. Where an issue was raised multiple times during the two days, the discussions are

summarized in just one section. A final section that includes the general conclusions and the next

steps of the revision process has also been added.

Stakeholders can provide their written comments on the technical reports through the

BATIS system until the 13th

of November 2015. The publication of the third criteria draft is

expected to be presented in June 2016 and the revision process be finished in November 2016.

PDF versions of the presentations given during the two days can be found on BATIS and the

official website.

1. Introduction – overview of the EU Ecolabel criteria revision process

After an introductory round table and a brief introduction to the EU Ecolabel scheme, JRC-IPTS

presented the EU Ecolabel criterion revision process that is being followed for all the detergents

groups. Following the introduction by the chairman, the timing of the project and the coming

steps were revised. The feedback and comments on the TR2.0 can be submitted through BATIS

until 13th

November 2015. A short update of the progress is scheduled for the EUEB meeting in

November 2015 and subsequently a third criteria draft will be released, expected in May 2016.

2. Definitions and scope The presentations of the product names, definitions and scopes revised the changes proposed or

suggested during the previous meeting.

Stakeholders commented the need of creating a new category consisting of kitchen cleaners in the

hard surface cleaners product group. Further information regarding the formulation of the kitchen

cleaners was requested by IPTS to assess this proposal.

Regarding the scope of the product groups some aspects were commented:

- the sentence ''not including the use in …." for the LD does not add any value and is proposed to

be deleted. Stakeholders pointed out what is important defining the type of product is the kind of

machine.

- the list of materials ''…including cutlery, pots, pans and ovenware'' that can be washed with

HDD is also not needed and does not add any valued.

- the definition of ''routine cleaning'' does not need to say how often it happens. Additionally,

examples of cleaning under other regular intervals were done. These examples do not correspond

with the minimum proposed.

- the lack of reference to the cold wash in the case of LD was mentioned. It was stated that the

EU Ecolabel criteria for LD were designed for cold wash products and the only reference that

appears in the criteria is a recommendation of using the lowest possible temperature. The ability

for cold washing of the EU Ecolabel LD was proposed to be mentioned in the definition and

scope as well. The idea was welcome by the participants although a specific proposal would be

appreciated.

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- clarifications in the definition of industrial and institutional products considered as multi-

components should be introduced to make clear that they can get the label as a whole product.

Some stakeholders expressed their agreement of including multi-component products in the

industrial and institutional product group indicating that professionals know what they need and

what the IILD product should include in the formulation (eg softeners, if needed). However, they

also pointed out that this condition should not lead to the inclusion of softeners in the LD product

group.

Regarding the definitions the following points were flagged:

- a clarification on the types of products included in the heavy duty detergents and their possible

classifications was provided. In this sense, it was exampled that colour detergents can be

considered as a sub-class of the heavy duty detergents. Corrections related to this aspect were

required.

- regarding the requirement of providing SDS for all substances (ingoing substances), different

points of view regarding the feasibility and need of this statement were expressed. On one hand,

it was pointed out that this requirement will oblige manufacturers to get the SDS of all main

ingredients but also of all impurities and pollutants. This can be difficult to achieve, especially in

the case of certain particular ingoing substances (e.g. fragrances as a mixture). On the other hand,

it was flagged that it is impossible to verify if a mixture complies with the criteria if the

information of the substances that the mixture consists of is not provided. The deletion of point 3

was suggested based on the need of knowing all ingoing substances above 0.01% wt. Inclusion of

"impurities" and "by-products" in the definition of "ingoing substances" should be considered in

the light of verification.

Some drawbacks for the assessment and verification of this requirement were also commented

based on the experience of some competent bodies. It was highlighted that thanks to the

implementation of the CLP regulation and the control techniques that have been significantly

improved and implemented in the chemistry industry, there is an increasing amount of

information available on ingredients, which was unknown when the criteria were initially drafted.

In this sense, the stakeholders pointed out that nowadays it is possible to detect very small

quantities of for example impurities that were undetectable some years ago. This may lead to the

need of setting a different cut-off for specific substances or for impurities.

- stakeholders suggested the possibility of ruling out the use of microplastics regardless their

function. It was suggested to have a broader definition of microplastics that includes the fact that

they are dangerous for the environment regardless of the function. One stakeholder suggested

referring to all polymers in solid state.

Differences between microplastics and polymers in solid form were mentioned as well as

reference where further information can be found. All microplastics are solid polymers but not on

the other way round. It was also commented that microplastics and solid polymers have different

physical characteristics such as the solubility in water and that these differences can be included

into the definition. As an example, it was commented that there are ecolabelled detergents that

consist of solid polymers due to the good performance of these substances, but that they do not

contain microplastics.

- the deletion of limits for colouring agents and fragrances was required. It was pointed out that

both types of substances are added in very small quantities. Especially in the case of fragrances,

even if no limits are set, the use of these substances will be regulated by the CDV criterion. In the

case of IILD the use of fragrances is banned. Stakeholders required that the use of these

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substances should be allowed but that they should comply with the H-statements and all the other

criteria. Other stakeholders, however, required the ban of fragrances in all the product groups.

3. Measurement thresholds, reference dosages

The session kept on with the discussions on measurement thresholds and reference dosages.

Changes and modification were presented before opening the floor to the participants.

One of the points of discussion was the proposal of referring the reference dosage in mass. It was

commented that in the case of hard surface cleaners 1 liter of product is not 1 kg. Thus it would

be better to refer to a mass unit as most of the criteria deal with the content of the specific

substances.

Clarification regarding the reference dosage for laundry detergent was also requested. Some

stakeholders considered that keeping 1kg of laundry in the EU Ecolabel criteria and referring also

to 4.5kg of laundry, as requested by the detergent regulation is a complex way of reporting the

values. However, industry pointed out that the ratio between the specific values and the reference

wash load of detergent regulation is currently done in the industry on a usual basis.

Clarifications regarding the meaning of "normally soiled laundry" were also requested. It was

commented that likely the level of soiling referred has changed along the years. Industry

supported this idea, but pointed out that the meaning of this term is on the eyes of the consumers

and they proposed to leave the definition as it is right now. Moreover, it was highlighted that in

this way, the definition is in line with the detergent regulation.

IPTS asked participants about the changes proposed in the water hardness units (from German

units to mgCaCO3eq) and if the level of water hardness should be indicated in the definition. A

change in the water hardness of several European regions (e.g. Germany) during the last years

was commented in reference to the different reference dosage of the product groups regarding the

water hardness of the zone. However, it was stated that there are still European regions with hard

water.

The reference dosage of the products classified as hard surface cleaners was a point for

discussion. Some stakeholders appreciated to refer to RTU products and considered very sensible

to use the RTU basis when setting the reference dosages. They pointed out that in this way

undiluted products are favored. Additionally, it was suggested that maybe two bases can be

considered, RTU basis for most of the criteria and undiluted basis for CDV criterion.

Undiluted products are considered to be environmentally friendlier and therefore some

stakeholders suggested the possibility of not including RTU hard surface cleaners in the EU

Ecolabel. As an example, it was commented that the Austrian Ecolabel does not award RTU all-

purpose cleaners. However, other stakeholders highlighted the need of including RTU hard

surface cleaners in the scope of the EU Ecolabel because they are a huge market share in the

Mediterranean countries and this ban would create market restrictions.

It was requested that different reference dosages should also be included for hard surface cleaners

depending on the water hardness.

Finally, multi-component systems in automatic dosages were questioned. It was pointed out that

this type of products can only be used with automatic dosages and that is the provider of the

multi-component system who should take care of the automatic system too. This information

should be checked and the assessment and verification part of the criterion modified

appropriately.

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Comments on some of the values proposed for some specific products were arisen. Further

information was requested to assess a change in the proposed values.

4. Toxicity to aquatic organisms

The presentation of the first session of the afternoon dealt with the toxicity to aquatic organisms'

criterion. A common template and the particularities for each of the product groups were briefly

commented before opening the discussions.

Comments of the values proposed were done as follows;

- the new proposed value for undiluted hard surface cleaners was considered too high, while the

previous value was considered to be appropriate. The benefits of undiluted products from the

environmental point of view were pointed out as well as large use of these products in the

professional sector. On the other hand, some competent bodies suggested that they are not aware

of problems in the compliance of this criterion as long as the RTU basis is applied.

- the RTU limits are too restricted.

- CDV values for some products with and without fragrances were requested by the stakeholders.

This suggestion was based on the fact that there are products were the perfumes mask all other

ingredients and therefore to reach the proposed limits it is enough to decrease the amount of

fragrances added. This idea was considered to encourage the formulation of detergents without

perfumes.

Additionally, it was pointed out that is difficult to have information on fragrances as sometimes

they contain more than 200 compounds and for most of them the attributed value in the 2014 DID

list was modified. It was proposed to have a limit for perfumes (as a mixture of fragrances)

instead of a value for the whole detergent.

- CDV values for DD and LD were reduced around 20% but this reduction is considered to be too

high by some stakeholders.

- industrial and institutional products limits were considered too low. Request for stricter values

was made. Regarding this point, the lack of data to propose better values was highlighted. The

new values were calculated once the feedback from the competent bodies was analysed. There

were very few formulations and data and therefore the uncertainties of the proposed values are

still quite high. Participants were invited to send further information and calculations regarding

this fact.

- the difficulties of considering microorganisms in these calculations was pointed out (since they

are not included in the DID). It was also considered that detergents with microorganisms should

have lower CDV limits as microorganisms allow the reduction of the amount of chemicals in the

detergent formulation. Industry representatives responded that this may not be the case as the

addition of microorganisms does not necessarily aim to substitute chemical compounds. They

may be added to fulfil additional functions.

- stakeholders welcome the reduction of the CDV values for HDD and pointed out that likely

similar reduction should be done for other product groups.

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5. Biodegradability

The final scheduled session of the 1st day dealt with biodegradability. As the six EU Ecolabels

under consideration were revised two at a time in the past, the current criteria take three different

approaches regarding biodegradability criteria. In this revision, the most recent approach was

presented as a starting point for discussion. Industry input and feedback received along the

consultation regarding the criteria formulation was included. Subsequently, revised and newly

proposed threshold values (for HDD and APC) for non-degradable organic compound content

were shown.

Regarding the proposed harmonised criterion the following aspects were commented:

- some stakeholders supported the new proposal and found it a reasonable compromise while

others would still prefer to have a total ban on non-anaerobically degradable surfactants. No

additional evidence was however presented. Even though, it was mentioned that due to the

increasing application of sludge to agricultural land, farmers are concerned about higher loads of

surfactants in detergents. It was also indicated that, degradation data exist for 43 anaerobically

biodegradable compounds while 46 compounds have not yet being tested. This indicated a need

for more testing.

- other stakeholders spoke about the amounts of non-degraded surfactants which can reach the

environment. These quantities are estimated to be very small, and additionally it was commented

that generally speaking, the final stage of these compounds after waste water treatment plants

(WWTP) is either incineration or being applied on the agricultural land, where again aerobic

conditions will allow for degradation.

- a study conducted by the University of Cadiz on LAS degradation was discussed briefly.

This issue was agreed to be once again brought at the EU Ecolabelling Board meeting

In addition:

- stakeholders asked regarding the revised values and basis for their change, also to set new

threshold values for products currently not covered with the requirement regarding the content of

non-degradable organic compounds. JRC explained the revision of values and which data was

obtained from competent bodies and licence holders.

- it was asked to include a definition of "organic compound" at least in the User Manual.

6. Hazardous substances and mixtures

The first morning session of the 2nd

day of meetings was dedicated to criteria related to hazardous

substances. First, the structure of the criterion was explained. The criterion consists of three parts:

a) Specific exclusions and restrictions for ingoing substances

Two tables listing substances that are not allowed or excluded as ingoing substances in the

formulation of the detergents were presented. One table is proposed to be in the criteria awarding

five product groups (namely LD, IILD, DD, APC and HDD) while the second table is proposed

to award IIDD products. The differences and similarities among the tables were highlighted.

The second part of this section corresponds to the restrictions of P-content in all the product

groups and VOCs in the hard surface cleaners' product group.

Regarding this section the stakeholders pointed out that:

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- formaldehyde releasers – it was mentioned that formaldehyde is explicitly excluded, but not

formaldehyde releasers.

- formaldehyde is restricted as in-going substance, but its release is not regulated (formaldehyde

is formed during the manufacturing of the detergents and released during the storage). It was

commented that surfactants contain formaldehyde and therefore it will be impossible to formulate

a free-formaldehyde detergent. The limit of 0.01% weight of formaldehyde was considered as too

low and examples of ingoing substances that contain formaldehyde were given.

It was also commented that formaldehyde is a preservative and that excluding too many

preservatives in this criterion will leave the EU Ecolabel without much choice in terms of

preservation.

- the limits of VOC were considered to be too high (25%wt) for products as sold. However,

complexity of VOCs testing was also commented.

- the P-content in the product groups was also discussed. It was pointed out that the proposed

limits for LD are too low as they are approximately 4 times lower than those proposed in the

Detergents Regulation. Stakeholders also showed their disagreement with the P-content limits

and the differences for rinses and detergents and for hard surface cleaners between those products

intended for professional use and those intended for household use. They commented that there

are many products that have both uses.

-finally and concerning phosphates, the proposal of allowing phosphates in IIDD was welcome,

but it was asked why this exception was not proposed for IILD. Stakeholders expressed their

desire of having an assessment of the pros and cons of using phosphate-alternatives in I&I

products before taking a decision.

- improvements are needed in the assessment and verification of section a) as it is not clear if the

declaration of compliance should come from the manufacturers or from the suppliers of raw

materials. As an example, it was pointed out that the suppliers should indicate the amount of

VOCs in the raw materials so that manufacturers can calculate the percentage in the final product.

Additionally, it was pointed out that P-content should be expressed as ''total elemental

phosphorus''.

b) Exclusions and limitations based on classification with hazard classes

The section b) of this criterion corresponds to the Article 6.6 and Article 6.7 of the EU Ecolabel

Regulation. According to this regulation, the awarded EU Ecolabel products should not contain

ingoing substances meeting the criteria for classification as toxic, hazardous to the environment,

respiratory or skin sensitizers, carcinogenic, mutagenic or toxic for reproduction and any ingoing

substance classified with any of the listed H-phrases should not have a concentration higher than

0.01% wt. Several derogations to this last restriction were also presented.

c) Specific limitations by substance type/substance group (e.g. preservatives, fragrances).

The third section of the criteria focuses on specific groups of substances that are classified either

as SVHC or that fulfil a specific function e.g. fragrances, preservatives, colouring agents,

enzymes or microorganisms. The following points were discussed:

- derogations for the use of surfactants and substilin, classified as hazardous to aquatic

environment were proposed for some product groups and under certain conditions. Regarding this

point, stakeholders pointed out the importance of derogating H412, as the workforce surfactants

on the market are classified with this H-phrase and the difficulties of applying the proposed

restrictions (lower than 25% limits) to I&I products, especially IILD.

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- clarifications on the percentages of surfactants classified with H412 that are derogated and for

which product groups were sought. It was commented that the derogations are drafted in a

general way and that it would be better to tailor them in accordance with each product group. As

an example, it was commented that there is no need for derogating surfactants classified with

H412 up to a concentration of 25% for all the product groups since RTU hard surface cleaners

have lower concentrations. However, it was also commented that a stricter restriction could

prevent from innovation towards more concentrated products.

The discussions about the classification of the substances brought on the table the issue that many

concentrated products may be labelled according to the CLP regulation and that it will be very

difficult to communicate to the end-users that a EU Ecolabel product is at the same time holding a

CLP pictogram. It was mentioned that in Germany such a situation would be considered as a

misleading claim. DG Environment clarified that legal services of the EC were consulted and that

it is legally allowed to have an EU Ecolabel product classified. Clarifications were given at this

point about the meaning of the EU Ecolabel and the pictograms to be displayed on the products.

A link to the restrictions regarding the CDV values was made. It was commented that this

discussion on the surfactants derogation could be triggered by the high values of CDV proposed.

- regarding subtilisin it was agreed to extend the derogation to hand dishwashing and hard surface

cleaning products.

- other ingoing substances or mixtures affected by the classification of hazardous to the aquatic

environment are perfumes, paracetic acid and preservatives.

- perfumes were considered by some stakeholders as important mixtures used in the formulation

of the detergents and a reason for the consumers for choosing a specific product. They have the

important function of providing smell and masking bad odours of ingredients, for instance

surfactants. This can be achieved by adding very little quantities. Due to the updating of the

regulations fewer and fewer fragrances are not classified and concerns about if the classification

is applied to the perfume (understood as a mixture) or to the fragrance (understood as a

substance) were commented. A link to the updating needed in the DID entry for fragrances was

also pointed out as a possible solution.

It was indicated further that there are products on the market without fragrances. It would be

useful to know which the alternative fragrance-free products are across Europe and for which

product groups. Further consultation on this requirement is needed.

- preservatives are substances with specific functions needed in various product groups, and

therefore the same substance may be covered by two different pieces of legislation. Prior to the

meeting industry sent a position paper asking for exemption of preservatives from the criterion on

substances. DG Environment explained that this would be not in agreement with the requirements

of the EU Ecolabel Regulation. Industry was asked to provide product group specific information

on the need of derogation for preservatives. The participants and CBs will receive industry

position paper.

- regarding the restrictions on microorganism it was commented that:

- the proposal need to be added that "all intended added substances, being not…."

- free enzymes should be excluded as they are produced by microorganism. The exclusion of

microorganisms that are not used in the food industry is not needed because only the

microorganisms that can be in contact with food are listed in that list.

- the dosage should be lower because this would lead in a proper use of professional

detergents.

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- the fitness for use criterion of the detergents with microorganisms should also be modified as

in most cases the microorganism have an effect in longer term. It was also pointed out that

some detergents with microorganisms should be used for a very specific purpose and that it

would be very difficult to include all the intended uses in the criteria wording. It was also

questioned if the hard surface cleaners containing microorganisms and intended for especial

cleaning actions comply with the requirement of ''routine cleaning''. If not, they would not fall

under the proposed definition and not be covered by this EU Ecolabel.

- the values of CDV should be checked. On the one hand it was pointed out that the detergents

containing microorganisms have a lower amount of chemicals, even if it is not its main

purpose. This means that in general their CDV values will be lower. Additionally, it was

commented that even if microorganisms are considered as ingoing substances they do not have

a CDV value attributed. The reason for that is that the CDV values are a measure of the

biodegradability and the ecotoxicity and that the bacteria have no problems either with

biodegradability or with toxicity.

- corrosive criterion was commented. Stakeholders pointed out that there is no need for

differentiating between 1a, 1b or 1c as all of them fall under classification 1.

- finally, improvement in the assessment and verification of this section were commented as it is

not clear how the compliance with the criterion should be demonstrated. Doubts and

misunderstandings about how to proceed are common points for discussion in the CB forums. A

session on verification of applications and fine-tuning of the wording of A&V section was

proposed to be held in April CB Forum meeting.

7. Packaging

The second morning session of the 2nd

day covered the criterion on packaging. While for almost

all the product groups considered, packaging was not one of the main hotspots, they are products

that are bought quite frequently, packaging does have an impact on transport and consumer's

perception is also important in this point. A horizontal text was proposed for all product groups.

Clarifications in the criteria wording related to the inclusion of trigger in the pump's weight were

requested. It was questioned if the WUR values refer to cleaning solution or to the product as sold

and how to deal with concentrated products (e.g. concentrated window cleaners) were requested.

Stakeholders marked that requirements on recycled or reused material are missing. At the

moment, the requirement of using recycled or reused materials is indirectly addressed but maybe

a direct requirement for paper, carton and PET could be included. Restrictions on the use of

polymer chloride as packaging were also missed by some stakeholders.

Questions about how to proceed when the product is delivered in bulk were arisen. As an

example, it was commented that some IILD are delivered in bulk, without packaging and stored

in the laundries. In other occasions, the containers that are taken back are used. Considering both

facts, the removal of this criterion was proposed.

Finally, concerns about the requirements and calculations where the refill packaging is addressed

were expressed. The refill packaging was introduced as a compromise in the current EU Ecolabel

for APC but it was commented that the selling of the refill packaging depends on the retailers but

not on the producers. If there are no space on the retailers serves for the product and the refill, the

latest one is not offered.

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8. Fitness for use

The first part of the final session of the meeting covered the fitness of use criterion. Due to the

different applications of the product groups it was not possible to draft a common template for all

the product groups. Therefore, each criterion was presented separately.

The main changes introduced in the fitness for use criterion may be summarized as follows:

- reference product: standard detergent formulations are proposed for LD and DD, generic

formulations are proposed for HDD and toilet acid cleaners and a product on the market

intended for exactly the same use is proposed for the rest of the product groups

- test methods: I&I products are proposed to be tested by user tests and household products

by laboratory tests

- EU Ecolabel protocols and well-recognized standards or test methods are proposed to be

used whenever possible

- the number of repetitions has been harmonized to five

- updates on the standards and protocols, wording and other aspects have been proposed.

Stakeholders commented the low effectiveness of using standard detergents or generic

formulations proposed as reference products in the fitness for use criteria and therefore the

easiness to comply with the criterion in general. It was also commented the different level of

performance of the reference products recommended by the different competent bodies create

unbalanced situation across Europe. Stakeholders also suggested the possibility of setting as

reference product another EU Ecolabel product.

Different points of view regarding the number of repetitions were commented. On the one hand it

was considered that five repetitions are not enough to give a good statistical value (e.g. 40 or 50

repetitions are needed by some labs to test HDD) and on the other hand it was suggested that this

number of repetition is enough to test a product without excessive testing costs. 15 repetitions

were suggested as a compromise number. It was also commented that increasing the number of

testing will mean additional tests for the current licence-holders.

The modifications regarding the type of tests to be used (user tests or lab tests depending on the

intended use of the product) were also commented. It was requested to include the laboratory

tests for I&I products since it can be a useful way to test them.

Clarification regarding the "harmonized relevant standards" was requested and it was commented

that it is related to the compliance with ISO 17025 but that it was stated as an open formulation to

be valid along the validity of the Decision. It was also commented that maybe it could be a

possibility to ask for accreditation. However, others commented that there are not many

laboratories accredited for testing fitness for use of the detergents and cleaners (e.g. in some

Member States where there are no laboratories).

Finally a question regarding the lowering of the DD testing temperature was arisen, what happens

with the licence holders that tested their DD products at 55C?

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9. User instructions and information appearing on the EU

Ecolabel

The last block of criteria consists of the User information and the Information appearing on the

EU Ecolabel. Few changes are proposed on those two criteria that concerns the inclusion of a

mandatory statement informing about the damage to the environment of every cleaning process

and a new wording for the statements appearing, on voluntary basis, close to the EU Ecolabel

logo.

The main feedback from the stakeholders was related to the scarce room available on the product

labels to communicate the information and the additional requirements they have to comply with

(e.g. inclusion of pictograms in accordance with CLP regulation).

Additionally, the importance of the dosage instructions in comparison to the other points

proposed in the User information criterion and the need for better wording to make the

requirements clearer (e.g. regarding the provision of a dosage system it was proposed to remove

the words "if possible" and replace them by "mandatory" in LD criteria) was pointed out.

Other comments added regarding the EU Ecolabel logo were the difficulties for printing the

required colours and the disagreements with the new statements (mainly with the statements:

amount of hazardous substances in restricted). No better proposals were suggested.

10. Other issues and criteria proposals/discussion

The following diverse issues were raised during the two days of meetings:

Sustainable sourcing

Stakeholders pointed out that bio-surfactants shall not be produced from palm oil. The rainforest

has been cut down in massive amounts and they are concerned of that. Better criteria for

surfactants based on palm oil were required. It was commented that these discussions have been

held for quite a long time already and that no agreement was reached.

It was stated that bio-surfactants production is not the main reason for the rainforest felling, but

that they are produced from by-products of the food industry. Derivatives from the palm-oil

controlled by mass balances should be integrated and criteria should not just be based on the book

and claim system any longer.

It was pointed out that due to the lack of experience with this criterion, the lack of information

about the differences in cost of both accountability systems and other difficulties for assessing the

best wording and thresholds in the criterion, it could be better to postpone the inclusion of this

criterion until the next revision when tools to address this problem are excepted to be in place.

Nanomaterials

The exclusion of nanomaterials was brought on the table. It was stated that they go thought out

the WWTP and end up exposing to the consumers. Based on the precautionary principle, it is

better to exclude them. However, there is an internal Commission position how the nanomaterials

can be addressed and only specific exclusions based on hazard this particular nanomaterial poses

can be considered.

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Extension of the validity of the EU Ecolabel and transition periods

It was questioned if the current validity period of four years for detergents corresponds with the

current market development and it was proposed an extension of this period up to six years.

Supporting this idea it was highlighted that the revision process of the EU Ecolabel lasts for two

years and that some applicants to get thought the whole application process can last for 1 year.

Stakeholders did not show a preference and considered that the decision is in the hands of the

European Commission. 5 years could be a reasonable period and a compromise between the

needed financial and bureaucratic efforts done by the SMEs and other applicants and the benefits

of awarding the labels for the member states.

Several ideas to speed up the application process were launched at this point. Among them are:

making the dossier easier, submitting the dossier directly on the website or providing competent

bodies with the needed tools to speed up the applications.

The current revision is being carried out for six product groups simultaneously, this means that

the transition periods would, in theory, start at the same time and last approximately for the same

period of time. The foreseen workload for the competent bodies to reassess the validity of the EU

Ecolabel of the current license-holders will thus be significantly high. At this point, it was

required a good dialogue between the parties to smooth the process.

The harmonization efforts done in this revision were appreciated, and it was suggested if only one

decision could be released. This would make easier any amendment or corrigendum to be done in

the future.

11. Conclusions and next steps

The fruitful discussions with the stakeholders held on 20th

and 21st October in Brussels provided

the EU Ecolabel revision process with meaningful insights and views and pointed out the aspects

where further research is still needed. Besides, there is a series of aspects that should be consulted

at EUEB level due to their political nature (e.g. inclusion of fabric softeners, microorganisms,

biocides).

Feedback from the stakeholders is expected to be collected by 13th

November through BATIS.

This information will be checked and assessed to constitute, together with the decisions taken in

the next EUEB meeting in November 2015, the basis for the changes of the criteria proposal.