BEUC study 'The EU Eco-label - less hazardous chemicals in...

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Europäischer Verbraucherverband Neytendasamtök Evrópu Euroopan Kuluttajaliitto Europese Consumentenorganisatie Európai Fogyasztók Szervezete Europejska Organizacja Konsumencka Organización Europea de Consumidores Evropska potrošniška organizacija Eυρωлαïkή Opyάνωση Kαταναλωτών Organização Europeia de Consumidores Den Europeiske Forbrukerorganisasjonen Den Europæiske Forbrugerorganisation Organizzazione Europea dei Consumatori Den Europeiska Konsumentorganisationen

BEUC/X/010/200411 March, 2004

Contact : Charlotte de Roo Email : [email protected]

Lang : EN

The European Consumers’ Organisation

The EU Eco-label -

less hazardous chemicals

in everyday consumer products

Marie-Pierre Locret, Eco-label Manager

Charlotte de Roo, Environment, Safety and Health Advisor

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The EU Eco-label –

less hazardous chemicals in everyday consumer products

Content Page

1. Introduction and objective 3

2. Methodology 4

3. Conclusion 6

Eco-label criteria provide help in consumer choice for less hazardous chemicals

4. Discussion 7

5. The study 9

Overview of eco-labelled product groups’ criteria on chemical content

vs existing legislation

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Introduction and objective of the study

This study on "the EU Eco-label - less hazardous chemicals in everyday consumer products" is one of the actions undertaken by BEUC in our participation in the 2004 Eco-label Consumer Campaign.

The objective of the study is to look at the restrictions on the chemical content in the complete group of EU eco-labelled products. The focus is on whether the EU eco-labels impose limits on the use of hazardous chemicals in consumer products that do not apply to similar products not carrying the eco-label.

The result of this study will be translated into an "easy to use" guide for consumers and distributed during the "European Flower Week" in October 2004. The intention is to provide consumers with clear information on the difference between chemicals in EU eco-labelled products and ordinary products.

The EU eco-label

The European Eco-label sets ecological criteria for a range of products and services. It has existed for more than 10 years and can be awarded to 21 product groups. The EU eco-label is the only label which covers products moving across borders in Europe. It is a voluntary scheme that provides guidance for consumers who want to make an informed choice in order to support sustainable consumption patterns.

Consumers are drowning in green claims made by producers of different articles on the European market. The result being that consumers do not know which labels to trust or they have given up trying to understand the difference between them. The EU eco-label could provide help to consumers, but it needs to develop not just in terms of the number of product groups but also in visibility. So far, the label has not been able to attract much consumer interest. This may be due to the lack of visibility, but also to the fact that not all eco-labelled products are marketed in all European countries. Another factor may be that the price of eco-labelled products is often significantly higher.

The European eco-label establishes criteria for product groups in a transparent way and is open to third parties such as consumer and environmental organisations. This is a huge difference compared to the self-declared green claims established by producers. The eco-label criteria take the life-cycle of a product (from cradle to grave) into account, unlike many industries’ green claims that often just focus on the waste phase.

“The Flower” logo present on eco-labelled products is the assurance of European green authenticity. It is only awarded after it is verified by an independent body that the applicant product /product group complies with established ecological criteria.

Marie-Pierre Locret, Eco-label Manager

Charlotte de Roo, Environment, Safety and Health Advisor

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METHODOLOGY

The study aims to compare the voluntary eco-label scheme and existing legislation in terms of the level of protection of health and the environment that they offer in relation to chemicals.

Each of the 20 eco-labelled product groups was analysed for criteria relating only to the chemical content of the product. These criteria were compared with existing EU legislation.

The total number of eco-labelled product groups studied is 20, as follows:

All purpose cleaners and cleaners for sanitary facilities - Bed mattresses - Copying and graphic paper - Detergents for dishwashers – Dishwashers – Footwear - Hand dishwashing detergents - Hard floor coverings - Indoor paints and varnishes - Laundry detergents - Light bulbs - Personal computers - Portable computers – Refrigerators - Soil improvers – Televisions - Textile products - Tissue paper - Vacuum cleaners - Washing machines

The following two groups were excluded from the study:

• Detergent Ingredient Database (DID-list)

This is a background document, not providing criteria in itself. The DID-list is to be viewed as an annex to the detergent eco-labelling criteria studied in the following product groups: “all purpose cleaners and cleaners for sanitary facilities” - “detergents for dishwashers” - “hand-dishwashing detergents” - “laundry detergents”.

• Tourist accommodation

The product group was not analyzed as it is a new initiative aimed at extending the eco-label to services and this study only focuses on products.

The eco-label criteria on chemicals in the different product groups were compared with EU legislation in force. This includes:

1) all EU background legislation to which a reference is made in existing eco-label criteria dealing with hazardous substances for example the detergent regulation. Limit values and prohibitions to the use of the individual chemicals are compared;

2) in the absence of a specific reference to background legislation in the eco-label criteria, research focused on existing legislation covering individual chemicals.

Background legislation on dangerous substances and preparations used to conduct the study:

- Directive 1967/548 and its numerous amendments dealing with the classification, packaging and labelling of dangerous substances.

The objective of classification is to identify all the toxicological, physico-chemical and ecotoxicological properties of substances, and toxicological and physico-chemical properties of preparations, which may constitute a risk during normal handling or use.

After identifying hazardous properties the substance or preparation must be labelled to indicate the hazard(s) in order to protect the user, the general public and the environment. The introduction of risk phrases, symbols and safety phrases aims at ensuring that the specific nature of the potential dangers identified in classification are expressed on the label.

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- Directive 1999/45 and its subsequent amendments dealing with the classification, packaging and labelling of dangerous preparations.

As with Directive 67/548 it provides a list of preparations recognized as being hazardous.

- Directive 76/769 and its subsequent amendments dealing with restrictions on the marketing and use of certain dangerous substances and preparations.

In order to facilitate the reading of this study’s results, an overview box has been inserted to each product group. It contains "smileys" indicating the level of accomplishment performed by the eco-label criteria with regard to various chemicals contained in respective products or product groups.

Meanings of 3 types of smileys:

- ☺ = the eco-label is ahead of legislation

- = the eco-label is in line with legislation

- = the eco-label is behind legislation

NB :

* the third smiley never had to be used !

* sometimes 1st and 2nd smileys had to be used together when eco-label criteria for a single product group were tackling various types of chemicals.

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CONCLUSION Eco-label criteria provide help in consumer choice

for less hazardous chemicals

The eco-label was originally conceived to reward products having a reduced environmental impact. Studying what the eco-label criteria say about the content of hazardous chemicals in the final products allows an additional important dimension to be included: health.

As explained in the methodology, this study envisages both health and environment impacts up to the stage of the final product. As some chemicals also are released during the products’ waste phase and circulate through water to our food chain, then it is especially encouraging to see that hazardous chemicals often are phased out from eco-labelled products.

This study clearly indicates that the eco-label could provide consumers in Europe with an informed choice when shopping. When buying EU eco-labelled products they can avoid certain hazardous chemicals, which are not regulated in other everyday products on the shelves. The information is trustworthy and controlled by independent bodies.

The eco-label has a holistic approach, following the product from the cradle to the grave. In the particular case of chemical content this has a significant advantage as chemicals travel in the environment and in humans. Eco-label criteria on chemicals can therefore bring more benefit than just satisfying the immediate concerns of final consumers e.g. acute health concerns. The eco-label is a clear and concise tool for consumers to move towards more sustainable patterns of consumption.

The result of the study is positive because most often the eco-label is ahead of legislation, either by fully banning chemicals that EU law only limits or the eco-label sets a much stricter limit than the law.

In their daily life consumers are exposed to chemicals which can be released from everyday consumer products. These substances can be hazardous as they can have a toxic, allergenic or bioaccumulative effect on our health. The study has shown that the eco-labelled product often prevents or limits the presence and use of such hazardous substances. Consumers can make an informed choice about the content of chemicals by choosing eco-labelled products.

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Discussion This study has been carried out because of consumer concern about hazardous chemicals in products. A non-exhaustive list of chemicals, which are a concern to consumers, could be:

- endocrine disrupting chemicals: often persistent and bioaccumulating. They may cause serious malfunctions in the organism and even cancer ;

- organic halogens tend to be persistent, to accumulate in the environment and to be toxic to humans and other organisms ;

- allergenic chemicals can cause asthma and allergies. Asthma and allergies are on the increase;

- heavy metals: widespread in food and household products, they can cause permanent changes to the nervous system and, in high doses, serious effects on physical or mental health ;

- brominated flame retardants: these fire restraining chemicals are persistent, toxic and bioaccumulating. Polybrominated diphenyl ethers (PBDEs) have shown to be harmful to animals in laboratory tests. Even if there is no evidence that they cause problems in humans it is clear that their levels in humans are rapidly building up.

This study demonstrates that chemicals of concern to consumers are not handled in EU legislation as thoroughly as the eco-label does. The fundamental difference we identified is that EU legislation today only regulates chemicals as single substances or as part of a preparation, without tackling the final stage of a consumer product or article. This creates a situation where, for example, cancerogenic, mutagenic and toxic to reproduction (CMR) substances are not prohibited in everyday consumer products.

The eco-label however makes that link to the final product. It follows a holistic approach when analyzing the impact of the product throughout its life-cycle up to the disposal of the final product.

Our study coincides with the proposal from the European Commission on REACH (Registration, Evaluation and Authorisation of Chemicals). The proposal is aimed at improving the protection of human health and the environment by ensuring proper regulation of the 100,000 unassessed chemicals on the European market.

The REACH proposal only applies to the stage of consumer articles in a very limited way. Only chemicals in articles which have dangerous1 properties and only if the chemicals are intended to be released from the article and the chemical contained in the article type is marketed in more than 1 ton per year per manufacturer should be registered. The quantity of the substance released must also have an adverse affect on human health or the environment. Moreover, REACH will become reality only 11 years after the entry into force of the new legislation. Consumers will be left empty-handed until maybe 2020 and by then, still be poorly informed.

The eco-label goes a step further by taking the final product into account. Thanks to the holistic approach followed in the establishment of criteria, the assessment of the product’s impact on the environment is conducted throughout the whole of its life-cycle.

1 According to Directive 67/548/EEC

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The eco-label can be considered as the only ‘legislation’ of this kind : it is innovative when indicating which chemicals that are recognised and classified as problematic can have an impact on the environment and/or human health, when expressed in a total dose to which human beings are exposed.

REACH could benefit substantially from the experience of the eco-label scheme. It is a very advanced scheme compared to existing legislation on chemicals and it has been demonstrated that producers can provide these products.

In the meantime we hope that consumers will benefit from the advice that products with the EU eco-label minimize the chemical exposure from consumer products and that industry and retailers will ensure EU eco-labelled products are on the market. If the eco-label were sufficiently present in all member states then consumers would be able to not only have good intentions but also adapt their actual behaviour to make a “green choice”.

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Overview of eco-labelled product groups’ criteria on chemical content vs existing legislation

Page

• All purpose cleaners and cleaners for sanitary facilities 10

• Bed mattresses 16

• Copying and graphic paper 21

• Detergents for dishwashers 25

• Dishwashers 29

• Footwear 31

• Hand dishwashing detergents 36

• Hard floor coverings 41

• Indoor paints and varnishes 44

• Laundry detergents 49

• Light bulbs 53

• Personal computers 56

• Portable computers 59

• Refrigerators 60

• Soil improvers 63

• Televisions 66

• Textile products 69

• Tissue paper 80

• Vacuum cleaners 83

• Washing machines 85

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ALL PURPOSE CLEANERS AND CLEANERS FOR SANITARY FACILITIES

- Eco-toxicity and biodegradability : ☺

- Phosphates: ☺

- Biodegradability of surfactants : ☺

- Hazardous substances or preparations : ☺

- Biocides:

- Volatile organic compounds (VOCs): ☺

- Fragrances: ☺

- Sensitising substances : ☺ A – Existing criteria (Commission Decision of 27 June 2001, with a period of validity until 26 June 2004)

FUNCTIONAL UNIT

For all purpose cleaners the functional unit (used in the criteria below) is the dosage in grams of the product recommended by the manufacturer for 1 litre of suds (washing water).

For cleaners for sanitary facilities, no functional unit is defined (the relevant criteria below being calculated in relation to 100 g of the product).

ECOLOGICAL CRITERIA

1. Eco-toxicity and biodegradability

For all-purpose cleaners, the critical dilution volume toxicity (CDVtox) for the product shall not exceed 400 l/functional unit.

For cleaners for sanitary facilities, the CDVtox for the product shall not exceed 4000 l/100 g product.

Phosphorus and phosphonates

- all purpose cleaners : total phosphorus content not > 0,2 g/ functional unit – total of phosphonates not > 0,02 g/functional unit

- cleaners for sanitary facilities: total phosphorus content not > 2g / 100g of product – total of phosphonates not > 0,2 g/100 g of product

Anaerobic biodegradability of surfactants

Each surfactant shall be biodegradable under anaerobic conditions.

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Dangerous, hazardous or toxic substances or preparations

Ban of following ingredients:

- alkylphenolethoxylates (APEOs)

- nitromusks and polycyclic musks, including for example:

musk xylene: 5-tert-butyl-2,4,6-trinitro-m-xylene

musk ambrette: 4-tert-butyl-3-methoxy-2,6-dinitrotoluene

moskene: 1,1,3,3,5-pentamethyl-4,6-dinitroindan

musk tibetine: 1-tert-butyl-3,4,5-trimethyl-2,6-dinitrobenzene

musk ketone: 4'-tert-butyl-2',6'-dimethyl-3',5'-dinitroacetaphenone

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

AHTN: 6-Acetyl-1,1,2,4,4,7-hexamethyltetralin

- EDTA (ehtylene-diamine-tetra-acetate)

- NTA (nitrilo-tri-acetate)

- quarternary ammonium compounds

- glutaraldehyde

Ban of ingredients classified as:

R31 (contact with acid liberates toxic gas),

R40 (limited evidence of a carcinogenic effect),

R45 (may cause cancer),

R46 (may cause heritable genetic damage),

R49 (may cause cancer by inhalation),

R68 (possible risks of irreversible effects)

R50+53 (very toxic to aquatic organisms and may cause long term adverse effects in the aquatic environment),

R 51+53 (toxic to aquatic organisms and may cause long term adverse effects in the aquatic environment),

R59 (dangerous to the ozone layer),

R60 (may impair fertility),

R61 (may cause harm to the unborn child),

R62 (possible risk of impaired fertility),

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R63 (possible risk of harm to the unborn child),

R64 (may cause harm to breastfed babies),

Each ingredient of any preparation used, exceeding 0,1% by weight, should comply with this requirement.

Biocides that are used to preserve the product and that are classified as R50 + 53 or R51 + 53 are permitted, only if they are not potentially bio-accumulative.

Volatile organic compounds

The product shall not contain more than 10% (by weight) of volatile organic compounds with a boiling point lower than 150 C°.

Dyes or colouring agents

Any dyes or colouring agents used in the product must be permitted by Council Directive 76/768/EEC on cosmetic products and its subsequent amendments.

Fragrances

The product shall not contain perfumes containing nitro-musks or polycyclic musks.

If one or more of the following fragrances is contained, this shall be clearly indicated on the packaging:

amyl cinnamal – benzyl alcohol – cinnamyl alcohol – citral – eugenol – hydroxycitronellal – isoeugenol – amylcinnamyl alcohol – benzyl salicyclate – cinnamal – coumarin – geraniol – hydroxymethylpenthylcyclohexenecarboxaldehyde

Sensitising substances

The product shall not be classified as R42 (may cause sensitisation by inhalation) and/or R43 (may cause sensitisation by skin contact) according to Directive 1999/45/EC.

Biocides

(a) The product may only include biocides in order to preserve the product, and in the appropriate dosage for this purpose alone. This does not refer to surfactants which may also have biocidal properties.

(b) It is prohibited to claim or suggest on the packaging or by any other communication that the product has an antimicrobial action.

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ECO-TOXICITY AND BIODEGRADABILITY

• Existing legislation on detergents making no reference to eco-toxicity, the eco-label is ahead of legislation when setting up the critical dilution volume toxicity (CDVtox).

• Basis Directive 73/404/EEC of 22 November 1973 on detergents sets up an average level of biodegradability of detergents of 90% as well as the use of surfactants with an average level of biodegradability of not less than 90%.

→ In setting up parameters for the assessment of eco-toxicity and biodegradability of surfactants the eco-label is ahead of legislation.

PHOSPHATES

Existing legislation on detergents making no reference to phosphates, the latter are allowed without restrictions.

→ The eco-label is thus ahead of legislation by setting up limits for the content of phosphorus and phosphonates. When purchasing the eco-labelled product consumers will know that this award stands for a less harmful product.

BIODEGRADABILITY OF SURFACTANTS

Directive 73/404/EEC of 22 November 1973 on detergents sets up an average level of biodegradability of detergents of 90% as well as the use of surfactants with an average level of biodegradability of not less than 90%.

→ The eco-label is thus ahead of legislation when requesting surfactants to be readily and anaerobically biodegradable.

HAZARDOUS SUBSTANCES OR PREPARATIONS

- APEOs, EDTA and NTA are not covered by any legislation.

- Quaternary ammonium compounds are classified as being harmful in Directive 98/73/EC amending for the 24th time Directive 67/548 on the classification, packaging and labelling of dangerous substances.

- Glutaraldehyde is classified as being toxic in Directive 96/54/EC amending for the 22nd time Directive 67/548 on the classification, packaging and labelling of dangerous substances.

- Directive 2002/34/EC of 15 April 2002 adapting to technical progress Annexes II, III and VII to Council Directive 76/768/EEC relating to cosmetic products authorizes a maximum concentration of 1,0% of musk xylene in fine fragrance and of 0,03% in other cosmectic products and a maximum concentration of 1,4% of musk ketone in fine fragrance and of 0,042% in other cosmectic products.

Directives 67/548 and 96/54 are part of the information given to consumers. This does not mean that such substances are banned.

Background Directive on cosmetics naturally does not cover this product group but all purpose cleaners and cleaners for sanitary facilities do contain the same fragrances.

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Ingredients with risk phrases

Directive 67/548/EEC of 27 June 1967 relating to classification, packaging and labelling of dangerous preparations contains risk phrases to ensure that the specific nature of the potential dangers identified in the classification are expressed on the label.

However background legislation on detergents does not take the issue of hazardous substances and preparations into account.

→ The eco-label is thus clearly ahead of legislation when banning these substances as ingredients in all purpose cleaners and cleaners for sanitary facilities. It stands out by making a direct link with the product bought by final consumers.

BIOCIDES

Existing legislation on detergents does not deal with biocides.

Directive 1998/8/EC on the placing on the market of biocidal products defines biocidal products as active substances or preparations that exert a controlling effect on any harmful organism by chemical or biological means.

Cleaning products that may have biocidal effect are included.

Some surfactants have biocidal properties, which mean that they contribute to the preservation of the product.

→ The eco-label is in line with legislation when ensuring that the final product only contains substances which help in preserving it.

VOLATILE ORGANIC COMPOUNDS (VOCs)

- Directive 1999/13/EC of 11 March 1999 on the limitation of emissions due to the use of organic solvents in certain activities and installations, do mention surface cleaning but as an industrial activity;

- Directive 1994/63 concerns prevention of VOC emissions to the atmosphere during the storage of petrol at terminals and its subsequent distribution to petrol stations;

- Directive 2001/81 concerns national emission ceilings for certain atmospheric pollutants.

→ In the absence of any specific reference legislation covering this product group, the eco-label, with a limit of 10% of VOCs by weight of the product, is ahead of legislation. It thus allows to reduce the harmfulness to health of organic compounds, as well as a number of indirect effects in the atmosphere of organic solvents.

FRAGRANCES

Existing legislation on detergents does not deal with fragrances.

All fragrance chemicals listed here are most frequently reported as contact allergens.

→ The eco-label is thus ahead of legislation when banning fragrances in the final product. It enables choice for sensitive consumers.

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SENSITISING SUBSTANCES

Existing legislation on detergents does not deal with sensitising substances.

Directive 1999/45/EC on the classification, packaging and labelling of dangerous preparations foresees that a preparation containing at least one sensitising substance in a concentration equal to or greater than 0,1% must bear the inscription that it may produce an allergic reaction.

Preparations producing a sensitising effect have to carry risk phrases R42 (sensitising though inhalation) and R43 (sensitisation through skin contact)

→ The above-mentioned pieces of legislation only serve the purpose of informing consumers of the hazardous nature of these substances. By banning substances classified as R42 and/or R43, the eco-label is ahead of legislation and it guarantees that the final product will not have any harmful impact on its consumer.

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BED MATTRESSES

- Heavy metals : ☺

- Formaldehyde : ☺

- Volatile organic compounds (VOCs): ☺

- Chlorophenols : ☺

- Butadiene : ☺

- Nitrosamines : ☺

- Organic tin : ☺

- Blowing agents :

- Benzenes and chlorobenzenes : ☺

Existing criteria (Commission Decision of 3 September 2002, with a period of validity until 31 August 2007)

CRITERIA

1. Latex foam

Note: criteria applying to latex foam > 5 % of the total weight of the mattress.

(a) Extractable heavy metals : the concentrations of the following metals shall not exceed the following values:

antimony 0,5 ppm

arsenic 0,5 ppm

lead 0,5 ppm

cadmium 0,1 ppm

chromium (total) 1,0 ppm

cobalt 0,5 ppm

copper 2,0 ppm

nickel 1,0 ppm

mercury 0,02 ppm

(b) Formaldehyde: maximum concentration = 30 ppm

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(c) Volatile organic compounds (VOCs) : maximum concentration = 0,5 mg/m3

(d) Dyes, pigments, flame retardants: same criteria as for textile products

= impurities in dyes - impurities in pigments - chrome mordant dyeing – azodyes -

dyes that are carcinogenic, mutagenic or toxic to reproduction - potentially sensitising dyes - flame retardants

(e) Metal complex dyes: Metal complex dyes based on copper, lead, chromium or nickel are banned.

(f) Chlorophenols: No chlorophenol (salts and esters) shall be present in concentrations exceeding 0,1 ppm, except mono- and di-chlorinated phenols (salts and esters) which shall not exceed 1 ppm.

(g) Butadiene: maximum concentration = 1 ppm.

(h) Nitrosamines: maximum concentration = 0,001 mg/m3

2. Polyurethane (PUR) foam

Note: criteria applying to PUR foam > 5 % of the total weight of the mattress.

Extractable heavy metals – Formaldehyde - Volatile organic compounds (VOCs) - Dyes, pigments, flame retardants - Metal complex dyes = same as for latex foam.

(f) Organic tin: banned

(g) Blowing agents: CFCs, HCFCs, HFCs or methylene chloride banned.

The use of methylene chloride as an auxiliary blowing agent is nevertheless allowed in conjunction with the application of powdered flame retardants.

5. Wooden material

(a) Particle board: the formaldehyde measured in any particle board used shall not exceed 50 % of the threshold value that would allow it to be classified as class 1 quality according to EN 312-1.

(b) Fibreboard: formaldehyde – same as above

7. Glues

(a) Volatile organic compounds (VOCs): glues shall contain less than 10% by weight of VOCs. Not applying to glues used for occasional repairs.

(b) Benzenes, chlorobenzenes: banned

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Comment

HEAVY METALS

- Directive 1996/62 of 27 September 1996 on ambient air quality assessment and management identifies arsenic, lead, cadmium, nickel and mercury as air pollutants;

- Directive 1999/30 of 22 April 1999 on limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air sets up a limit of 0,5 ppm for lead;

- Directive 76/769/EEC on restrictions on the marketing and use of certain dangerous substances and preparations bans arsenic compounds, cadmium and mercury;

- Directive 94/27/EC (12th amendment of Directive 76/769) limits the use of nickel in certain objects coming into direct and prolonged contact with the skin which may cause sensitization of humans to nickel and may lead to allergic reactions.

→ There is no specific legislation covering bed mattresses.

This product does contain a number of substances which are considered as being harmful and some of them are even recognised as causing sensitization and allergy problems:

- no legislation covers antimony, chromium, cobalt, copper ;

- regarding lead the eco-label sets the same limit as Directive 1999/30. But as bed mattresses are not in the scope of that Directive the eco-label, by incorporating that limit in an everyday product, is making a step forward;

- regarding nickel, Directive 94/27 does not have bed mattresses in its scope but sensitization problems caused by nickel are envisaged. No limits are set up.

→ The eco-label brings a plus by setting limit values for these extractable heavy metals in foams. It offers a clear and easy-to-understand advantage to final consumers who will be assured of the protection of their health when opting for an eco-labelled bed mattress.

FORMALDEHYDE

This substance is classified as being toxic in the Annex I of Directive 67/548/EEC of 27 June 1967 on classification, packaging and labelling of dangerous substances. This is part of the information given to consumers. They should therefore expect to find this substance in the final product as it is not banned.

→ The eco-label is clearly ahead of legislation because it is setting up a maximum concentration for formaldehyde. It goes further in incorporating this hazardous substance until the final stage of the consumer article.

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VOLATILE ORGANIC COMPOUNDS

- Directive 1999/13/EC of 11 March 1999 deals with the limitation of emissions due to the use of organic solvents, but the scope is “certain activities and installations” i.e. it is mainly addressing industrial operators;

- Directive 1994/63 deals with the prevention of VOC emissions to the atmosphere but its scope is “during the storage of petrol at terminals and its subsequent distribution to petrol stations”;

- Directive 2001/81 deals with national emission ceilings for certain atmospheric pollutants.

→ In the absence of any specific reference legislation covering bed mattresses the eco-label is ahead of legislation. By setting up a maximum concentration of VOCs for latex foam and glues it allows for a reduction in the harmfulness to health of organic compounds as well as a number of indirect effects in the atmosphere of organic solvents.

CHLOROPHENOLS

Directive 1991/173/EEC of 21 March 1991 amending for the ninth time Directive 1976/769/EEC regarding restrictions on the marketing and use of certain dangerous substances and preparations, limits the concentration of pentachlorophenol (and its salts and esters) to 0,1% by mass.

→ As the equivalent to 0,1% by mass would be 1,000 ppm the eco-label by limiting that concentration to 0,1 ppm is much stricter than existing legislation on that substance.

BUTADIENE

• Directive 2002/3/EC of 12 February 2002 relating to ozone in the ambient air identifies butadiene as one of the volatile organic compounds recommended for measurement. But it does not set any limit.

• Directive 2001/59/EC of 6 August 2001 adapting to technical progress for the 28th time Council Directive 67/548/EEC on the classification, packaging and labelling of dangerous substances mentions butadiene. If the substance is not classified as a carcinogen when contained at less than 0,1% w/w, at least a safety phrase should apply. This only serves the purpose of informing consumers.

→ Both these Directives do not deal with bed mattresses. The eco-label is ahead of legislation in fixing a maximum concentration for butadiene in latex foam used for bed mattresses.

NITROSAMINES

Directive 93/11/EEC of 15 March 1993 concerning the release of the N-nitrosamines and N- nitrosatable substances from elastomer or rubber teats and soothers sets up a limit of 0,01 mg in total of N-nitrosamines released /kg.

→ The eco-label is ahead of legislation in fixing a stricter limit for nitrosamines in latex foam used for bed mattresses.

ORGANIC TIN

According to Commission Directive 2002/62/EC of 9 July 2002 adapting to technical progress for the ninth time Annex I to Council Directive 76/769/EEC regarding restrictions on the marketing and use of certain dangerous substances and preparations, organostannic

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compounds may not be placed on the market or used as substances and constituents of preparations which act as biocides to prevent the fouling by microorganisms, plants or animals.

→ The eco-label is ahead of legislation as bed mattresses are not in the above-mentioned Directive’s scope.

BLOWING AGENTS

Regulation 2037/2000 of 29 June 2000 on substances that deplete the ozone layer, foresees the phase-out of chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and of hydrofluorocarbons (HFCs) and specifically bans the use of HCFCs for the production of all types of foams from 1st January 2004.

→ The eco-label is in line with legislation when it bans CFCs, HCFCs and HFCs as blowing agents or auxiliary blowing agents in polyurethane foam.

BENZENES AND CHLOROBENZENES

• Directive 76/768/EEC relating to cosmetic products bans benzene.

This Directive has nothing to do with bed mattresses but it has the merit of recognizing this substance as being “problematic”.

• Directive 1996/62 of 27 September 1996 on ambient air quality assessment and management identifies benzene as an air pollutant, without fixing any limit.

→ In the absence of specific legislation on bed mattresses, the eco-label is ahead of legislation as it bans benzenes and chlorobenzenes in glues used in bed mattresses.

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COPYING AND GRAPHIC PAPER

- Hazardous chemical substances : ☺


4. Hazardous chemical substances

(a) Chlorine: Chlorine gas banned as a bleaching agent.

Does not apply to chlorine gas related to the production and use of chlorine dioxide.

(b) APEOs: Alkylphenol ethoxylates or other alkylphenol derivatives shall not be added to cleaning chemicals, de-inking chemicals, foam inhibitors, dispersants or coatings. Alkylphenol derivatives are defined as substances that upon degradation produce alkyl phenols.

(c) Residual monomers: maximum 100 ppm for the total quantity of residual monomers (except acrylamide) that are assigned or may be assigned any of the following risk phrases (or combinations thereof):

R45 (may cause cancer)

R46 (may cause heritable genetic damage)

R49 (may cause cancer by inhalation)

R50/53 (very toxic to aquatic organisms and may cause long-term adverse effects in the aquatic environment)

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

R52/53 (harmful to aquatic organisms and may cause long-term adverse effects in the aquatic environment)

R60 (may impair fertility)

R61 (may cause harm to the unborn child)

Acrylamide shall not be present in coatings, retention aids, strengtheners, water repellents or chemicals used in internal and external water treatment in concentrations higher than 1 000 ppm (calculated on the basis of their solid content).

The competent body may exempt the applicant from these requirements in relation to chemicals used in external water treatment.

(d) Surfactants in de-inking formulations for return fibres:

- if used in quantities of at least 100 g/ADT, each surfactant shall be readily biodegradable;

- if used in quantities of less than 100 g/ADT, each surfactant shall be either readily biodegradable or ultimately biodegradable.

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(e) Biocides: The active components in biocides or biostatic agents used to counter slime-forming organisms in circulation water systems containing fibres shall not be potentially bio-accumulative.

(f) Azo dyes: No azo dyes shall be used that may cleave to any of the following aromatic amines:

4-aminobiphenyl (92-67-1)

benzidine (92-87-5)

4-chloro-o-toluidine (95-69-2)

2-naphthylamine (91-59-8)

o-aminoazotoluene (97-56-3)

2-amino-4-nitrotoluene (99-55-8)

4-chloroaniline (106-47-8)

2,4-diaminoanisol (615-05-4)

4,4-diaminodiphenylmethane (101-77-9)

3,3-dichlorobenzidine (91-94-1)

3,3-dimethoxybenzidine (119-90-4)

3,3-dimethylbenzidine (119-93-7)

3,3-dimethyl-4,4-diaminodiphenylmethane (838-88-0)

p-cresidine (120-71-8)

4,4-methylene-bis-(2-chloroaniline) (101-14-4)

4,4-oxydianiline (101-80-4)

4,4-thiodianiline (139-65-1)

o-toluidine (95-53-4)

2,4-diaminotoluene (95-80-7)

2,4,5-trimethylaniline (137-17-7)

o-anisidine (90-04-0)

4-aminoazobenzene (60-09-3)

(g) Dye stuffs: No commercial dye formulation shall be used on either pulp or paper that is assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):

R50 (very toxic to aquatic organisms),

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R51 (toxic to aquatic organisms),

R52 (harmful to aquatic organisms),

R53 (may cause long-term adverse effects in the aquatic environment),

No commercial dye formulation shall be used on either pulp or paper that contains more than a total of 2 % by weight of substances that are assigned or may be assigned at the time of application any of the above risk phrases (or combinations thereof) according to Directive 67/548/EEC and its subsequent amendments.

This criterion does not apply to formulations where the classification is solely due to the presence of dyeing component(s) with a degree of fixation of at least 98 %. The degree of fixation is taken as the total dye retention on the fibres in the process.

(h) Metal complex dye stuffs or pigments: Dyes or pigments shall not be used that are based on lead, copper, chromium, nickel or aluminium.

Copper phthalocyanine dyes or pigments may, however, be used.

(i) Ionic impurities in dye stuffs: maximum levels :

Ag 100 ppm; As 50 ppm; Ba 100 ppm; Cd 20 ppm; Co 500 ppm; Cr 100 ppm; Cu 250 ppm; Fe 2 500 ppm; Hg 4 ppm; Mn 1 000 ppm; Ni 200 ppm; Pb 100 ppm; Se 20 ppm; Sb 50 ppm; Sn 250 ppm; Zn 1 500 ppm.

Comment

HAZARDOUS CHEMICAL SUBSTANCES

- Chlorine

Directive 1999/45/EC of 31 May 1999 relating to the classification, packaging and labelling of dangerous preparations prescribes a compulsory labelling when the content of active chlorine exceeds 1%. This is part of the information given to consumers.

→ When banning such a substance which may release dangerous gases the eco-label is thus clearly ahead of legislation.

- APEOs

Alkylphenol ethoxylates (APEOs) or other alkylphenol derivatives are not covered by legislation.

→ The eco-label is thus clearly ahead when banning these substances in the final product offered to consumers.

- Residual monomers

Directive 67/548 on the classification, packaging and labelling of dangerous substances classifies residual monomers as being hazardous.

→ The eco-label is ahead of legislation when setting up a strict limit for this substance in the production process. This represents a step forward compared to a simple classification.

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- Biocides

Directive 1998/8/EC concerning the placing on the market of biocidal products defines biocidal products as active substances or preparations that exert a controlling effect on any harmful organism by chemical or biological means.

Under the conditions of use, the biocidal product shall pose only a low risk to humans, animals and the environment (“The Member State shall not authorise a biocidal product if the risk assessment confirms that, in foreseeable application including a realistic worst possible scenario, the product presents an unacceptable risk to humans”).

→ In the absence of specific legislation on copying and graphic paper the eco-label is ahead of legislation by prescribing that the active components in biocides or biostatic agents should not be potentially bio-accumulative. Whilst Directive 1998/8 only deals with marketing of biocidal products, the eco-label has an indirect effect on human health which could benefit the consumer.

- Azo dyes

Directive 2002/61 amending for the 19th time Directive 76/769 regarding restrictions on the marketing and use of certain dangerous substances and preparations bans azodyes in footwear, leather and textile articles which, by reductive cleavage of one or more azo groups, may release a number of aromatic amines in detectable concentrations above 30 ppm in the finished articles.

→ The eco-label is thus ahead of legislation because :

- copying and graphic paper is not in the above-mentioned Directive’s scope

- by fully banning azo dyes in the final product the eco-label limits consumer exposure to hazardous chemicals.

- Dangerous substances in dye stuffs

Directive 1999/45/EC relating to classification, packaging and labelling of dangerous preparations sets up concentration limits to be used for the evaluation of both health and environmental hazards:

- environmental hazards: substances having adverse effects on the aquatic environment carry risk phrases R50 to R53. The concentration limit used to determine the classification of the preparation is ≥ 25%.

→ By fully banning the presence of dangerous substances in commercial dye formulation, the eco-label is stricter than legislation.

The classification of dangerous preparations means that they are recognized as having an adverse impact without banning them. It also does not include the stage of consumer articles made of those preparations.

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DETERGENTS FOR DISHWASHERS

- Toxicity to aquatic organisms : ☺

- Total chemicals : ☺

- Phosphates : ☺



- Fragrances : ☺

Existing criteria (Commission Decision of 1 January 2003, with a period of validity until 31 December 2007)

CRITERIA

1. Environmental scoring matrix

(a) Toxicity to aquatic organisms

The critical dilution volume toxicity (CDVtox) shall be ≤ 200 l/wash.

Score (CDVtox) – (5- (CDVtox)) x 8

(b) Total chemicals

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

Total chemicals shall be ≤ 22,5 g/wash.

Score (Total chemicals) = (15 – (Total chemicals/1,5)) × 3

(c) Phosphates (as STPP — sodium tripolyphosphate)

Phosphates are the quantity of phosphates in the formulation calculated as STPP.

Phosphates shall be ≤ 10 g/wash.

Score (Phosphates) = (4 – (Phosphates/2,5)) × 2

(d) Aerobically non-biodegradable organics (aNBDO)

Aerobically non-biodegradable organics is the weight per wash, in g/wash, of all organic ingredients which are aerobically non-biodegradable (see DID-list).

aNBDO shall be ≤ 1 g/wash

Score(aNBDO) = 4 – (aNBDO/0,25)

(e) Anaerobically non-biodegradable organics (anNBDO)

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Anaerobically non-biodegradable organics is the weight per wash, in g/wash, of all organic ingredients that are anaerobically non-biodegradable using respective correction factors (see DID-list).

anNBDO shall be ≤ 0,2 g/wash.

Score(anNBDO) = (4 – (anNBDO/0,05)) × 1,5

(f) Total score

The sum of Score (CDVtox) + Score (Total chemicals) + Score (Phosphates) + Score (aNBDO) + Score (anNBDO) shall be ≥ 30.

2. Biodegradability of surfactants

(a) Ready aerobic biodegradability

Each surfactant used in the product shall be readily biodegradable.

(b) Anaerobic biodegradability

Each surfactant used in the product shall be anaerobically biodegradable.

3. Dangerous, hazardous or toxic substances or preparations

(a) No ingredient shall be included in the product that, at the time of application, is or may be assigned any of the following risk phrases (or combinations thereof):

R40 (limited evidence of a carcinogenic effect)



R49 (may cause cancer by inhalation)

R50-53 (very toxic to aquatic organisms and may cause long-term adverse effects in the aquatic environment)

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



R62 (possible risk of impaired fertility)

R63 (possible risk of harm to the unborn child)

R64 (may cause harm to breastfed babies)


as laid down in Directive 67/548/EEC and its subsequent amendments, or in Directive 1999/45/EC relating to the classification, packaging and labelling of dangerous preparations.

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Each ingredient of any preparation used in the formulation that exceeds 0,01 % by weight of the final product shall also meet this requirement.

(b) No preservatives shall be used that are or may be classified as R50-53, as laid down in Council Directive 67/548/EEC and its subsequent amendments or Directive 1999/45/EC and its subsequent amendments, whatever their amount.

(c) APEOs, APDs, EDTA, NTA

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

— alkylphenolethoxylates (APEOs) or other alkyl phenol derivatives (APDs).

— EDTA (ethylene-diamine-tetra-acetate)

— NTA (nitrilotriacetate)

(d) Phosphonates

The quantity of phosphonates that are not readily biodegradable (aerobically) shall not exceed 0,2 g/wash.

4. Fragrances

(a) Nitromusks and polycyclic musks.

The following are banned





musk ketone: 4’-tert-butyl-2’,6’-dimethyl-3’,5’-dinitroacetaphenone

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

AHTN: 6-Acetyl-1,1,2,4,4,7-hexamethyltetralin

(b) Code of practice

Any ingredients added to the product as a fragrance shall have been manufactured and/or handled following the code of practice of the International Fragrance Association.

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Comment

TOXICITY TO AQUATIC ORGANISMS TOTAL CHEMICALS Directive 73/404/EEC of 22 November 1973 on detergents only deals with biodegradability and does not take into account the total amount of chemicals nor toxicity parameters.

→ The eco-label is thus ahead of legislation by setting up a limit for the critical dilution volume toxicity and for the total of allowed chemicals in dishwasher detergents.

PHOSPHATES








Directive 67/548/EEC of 27 June 1967 relating to classification, packaging and labelling of dangerous preparations contains risk phrases to ensure that the specific nature of the potential dangers identified in the classification are expressed on the label. This only serves the purpose of informing consumers.

APEOs, APDs, EDTA, NTA

Alkylphenolethoxylates (APEOs) and other alkyl phenol derivatives (APDs) – ethylene-diamine-tetra-acetate (EDTA) and nitrilotriacetate (NTA) are not covered by legislation.

→ The eco-label is thus clearly ahead when banning these substances as ingredients in the final product. Consumers buying dishwasher detergents carrying the eco-label will have a poduct containing less problematic chemicals.

FRAGRANCES


All fragrance chemicals listed here are most frequently reported as contact allergens.

→ The eco-label is thus ahead of legislation when banning fragrances in the final product. It enables choice for the sensitive consumer.

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DISHWASHERS

Flame retardants : ☺

A – Existing criteria (Commission Decision of 28 August 2001, with a period of validity until 27 August 2006)

5. Take-back and recycling (flame retardants)

(c) Plastic parts heavier than 25 grams shall not contain the following flame retardants:

Name CAS No

Decabromodiphenyl 13654-09-6

Monobromodiphenyl ether 101-55-3

Dibromodiphenyl ether 2050-47-7

Tribromodiphenyl ether 49690-94-0

Tetrabromodiphenyl ether 40088-47-9

Pentabromodiphenyl ether 32534-81-9

Hexabromodiphenyl ether 36483-60-0

Heptabromodiphenyl ether 68928-80-3

Octabromodiphenyl ether 32536-52-0

Nonabromodiphenyl ether 63936-56-1

Decabromodiphenyl ether 1163-19-5

Chloroparaffins with chain length 10-13 C atoms, 85535-84-8

chlorine content > 50 % by weight

(d) Plastic parts heavier than 25 grams shall not contain flame retardant substances or preparations containing substances that are or may be assigned any of the risk phrases R45 (may cause cancer), R46 (may cause heritable genetic damage), R50 (very toxic to aquatic organisms), R51 (toxic to aquatic organisms), R52 (harmful to aquatic organisms), R53 (may cause long-term adverse effects in the aquatic environment), R60 (may impair fertility) or R61 (may cause harm to the unborn child), or any combinations of risk phrases containing any of the above risk phrases, as defined in Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances and its subsequent amendments.

This requirement does not apply to flame retardants that on application change their chemical nature to no longer warrant classification under any of the R-phrases listed above, and where less than 0,1 % of the flame retardant in the treated part remains in the form as before application.

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(e) The manufacturer shall take into account disassembly when designing and shall provide a disassembly report confirming among others that:

— incompatible and hazardous materials are separable.

Comment

FLAME RETARDANTS

Directive 2002/95/EC of 27 January on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), entering into force on 1 July 2006, foresees that new electrical and electronic equipment put on the market should not contain ... polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE).

• Directive 1999/45/EC relating to classification, packaging and labelling of dangerous preparations sets up concentration limits to be used for the evaluation of both health and environmental hazards:

- health hazards:

• substances classified as carcinogenic and mutagenic respectively carry risk phrases R45 and R46. The concentration limit used to determine the classification of the preparation is ≥ 0.1% ;

• substances classified as toxic for reproduction carry risk phrases R60 and R61. The concentration limit used to determine the classification of the preparation is ≥ 0.1%.


→ The eco-label is ahead of legislation by banning in dishwashers all the brominated flame retardants mentioned in RoHS. The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

By fully banning the presence of dangerous substances in flame retardants contained in plastic parts of dishwashers, the eco-label is stricter than legislation. Directive 1999/45 only informs consumers of dangerous health and environmental effects.

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FOOTWEAR



- Pentachlorophenol (PCP) and tetrachlorophenol (TCP) : ☺

- Azo dyes :

- Volatile organic compounds (VOCs) :

- PVC : ☺

Existing criteria (Commission Decision of 1 April 2002, with a period of validity until 31 March 2006)

1. Residues in the final product (heavy metals – formaldehyde)

(a) The average concentration of residues of Chromium (VI) in the final product shall not exceed 10 ppm and the residues of Arsenic, Cadmium and Lead shall not be detected.

(b) The amount of free and partially hydrolysable formaldehyde of the textile components of the footwear shall not exceed 75 ppm maximum and of the leather components shall not exceed 150 ppm maximum.

2. Emissions from the production of material

(b) Tannery waste water after treatment shall contain less than 5 mg Chromium (III)/l.

3. Use of harmful substances (up until purchase) (PCP and TCP – azo dyes)

(a) Pentachlorophenol (PCP) and Tetrachlorophenol (TCP) and its salts and esters are banned

(b) No azo dyes shall be used that may cleave to any of the following aromatic amines:

4-aminodiphenyl (92-67-1)

benzidine (92-87-5)



o-amino-azotoluene (97-56-3)


p-chloroaniline (106-47-8)

2,4- diaminoanisol (615-05-4)

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4,4’-diaminodiphenylmethane (101-77-9)

3,3’-dichlorobenzidine (91-94-1)

3,3’-dimethoxybenzidine (119-90-4)

3,3’-dimethylbenzidine (119-93-7)

3,3’-dimethyl-4,4_-diaminodiphenylmethane (838-88-0)


4,4’-methylene-bis-(2-chloraniline) (101-14-4)

4,4’-oxydianiline (101-80-4)

4,4’-thiodianiline (139-65-1)






Textiles: limit 30 ppm.

Leather: limit 30 ppm.

(c) The following N-Nitrosamines shall not be detected in rubber.

N-nitrosodimethylamine (NDMA)

N-nitrosodiethylamine (NDEA)

N-nitrosodipropylamine (NDPA)

N-nitrosodibutylamine (NDBA)

N-nitrosopiperidine (NPIP)

N-nitrosopyrrolidine (NPYR)

N-nitrosomorpholine (NMOR)

N-nitroso N-methyl N-phenylamine (NMPhA)

N-nitroso N-ethyl N-phenylamine (NEPhA)

(d) C10-C13 chloralkanes shall not be used in leather, rubber or textile components.

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4. Use of volatile organic compounds (VOCs) during final assembly of shoes

The total use of VOCs during final footwear production, for the following categories, shall not exceed on average:

General sports, school footwear, occupational, men's town, cold weather footwear: 25 gram VOC/pair,

Casual, women's town: 25 gram VOC/pair,

Fashion, infants, indoor: 20 gram VOC/pair.

5. Use of PVC

The footwear shall not contain PVC. Recycled PVC may, however, be used in outsoles, where no use is made of DEHP (bis(2-ethylhexyl)phthalate), BBP (butylbenzylphthalate) or DBP (dibutylphthalate) in preparing the recycled PVC.

Comment

RESIDUES IN THE FINAL PRODUCT

Chromium (VI) – arsenic – cadmium - lead

- Directive 2003/53 of 18 June 2003 amending for the 26th time Directive 76/769/EEC regarding restrictions on the marketing and use of certain dangerous substances and preparations : cement and cement-containing preparations cannot be placed on the market if they contain, when hydrated, more than 0,0002 % soluble chromium VI of the total dry weight of the cement. This legislation does not cover footwear and only enters into force on 17 January 2005;

- Directive 1996/62 of 27 September 1996 on ambient air quality assessment and management identifies among others arsenic, cadmium and lead as air pollutants, without setting any limit;

- Directive 76/769/EEC on restrictions on the marketing and use of certain dangerous substances and preparations bans cadmium and its compounds in a number of finished manufactured products other than footwear, sometimes with a limit of 0,1% or 0,01%;

→ The eco-label, by totally banning residues of arsenic, cadmium and lead in footwear, is ahead of legislation. By introducing a limit concentration of chromium VI in the final product, it is also clearly ahead as new legislation tackling this substance for the first time is not in force yet.

Formaldehyde

This substance is classified as being toxic in the Annex I of Directive 67/548/EEC of 27 June 1967 on classification, packaging and labelling of dangerous substances. This is part of the information given to consumers and the substance can be found in shoes as it is not banned.

→ The eco-label is clearly ahead of legislation because it is setting up a maximum concentration for formaldehyde in such a current article as shoes. The eco-label allows to follow the whole route of such a substance up to the final stage of the article offered to consumers.

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HARMFUL SUBSTANCES

Pentachlorophenol (PCP) and Tetrachlorophenol (TCP)

- Directive 76/769/EEC on restrictions on the marketing and use of certain dangerous substances and preparations bans PCP (and its salts and ethers) in a concentration equal to or greater than 0.1% by mass in substances or preparations.

→ The eco-label is clearly ahead of legislation by fully banning the use of PCP in the manufacturing process of footwear. Upon purchase the final product carrying the eco-label can be guaranteed not to contain PCP at all.

- Directive 1998/73/EC amending for the 24th time Directive 1967/548 on the classification, packaging and labelling of dangerous substances lists tetrachlorophenol as being a toxic substance.

→ This is part of the information given to consumers. This does not mean that this substance is banned. The eco-label is thus clearly ahead of legislation when banning TCP in footwear.

When banning both these hazardous substances the eco-label plays its full role by going further than what has to be implemented.

Azo dyes


→ The eco-label is thus in line with legislation when banning azo dyes and when setting up a limit of 30 ppm for textiles and for leather.


Directive 1999/13/EC of 11 March 1999 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations allows a total emission limit value of solvents of 25 g/pair of shoes.

→ The eco-label is thus in line with legislation and even ahead of it when fixing a limit of 20g/pair for fashion, infants and indoor shoes.

PVC

In the absence of generic legislation on PVC, the only reference is Commission Decision 1999/815/EC adopting measures prohibiting the placing on the market of toys and childcare articles intended to be placed in the mouth by children under three years of age made of soft PVC containing one or more of the substances di-iso-nonyl phthalate (DINP), bis(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), di-iso-decyl phthalate (DIDP), di-n-octyl phthalate (DNOP), and butylbenzyl phthalate (BBP).

This Decision eliminates the deliberate use of the relevant phthalates as plastisizers in the products in question, while acknowledging the possibility of their presence at a trace level of up to 0,1 % by weight.

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→ The eco-label, in fully banning the use of DEHP, BBP and DBP in recycled PVC which may be contained in outsoles, is thus ahead of legislation.

Once again the eco-label plays its full role in going beyond a sheer implementation of existing legislation. By being stricter than legislation it helps consumers in making a difference in terms of impact on their environment and health.

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HAND-DISHWASHING DETERGENTS




- Biocides :

- Fragrances : ☺

- Sensitising substances : ☺

Existing criteria (Commission Decision of 19 July 2001, with a period of validity until 18 July 2004)

Toxicity to aquatic organisms

The critical dilution volume toxicity (CDVtox) of the recommended dose expressed for 1 l of dishwashing water shall not exceed 170 l.

Biodegradability of surfactants

(a) Ready biodegradability (aerobic)

Each surfactant shall be readily biodegradable


Each surfactant used in the product shall be biodegradable under anaerobic conditions.

Dangerous, hazardous or toxic substances or preparations

(a) banned ingredients:

— alkyl phenol ethoxylates (APEOs)

— quaternary ammonium compounds

— trichlorocarbon

— EDTA (ethylene-diamine-tetra-acetate)

— NTA (nitrilo-tri-acetate)

— polyglycol solvents: polyethylene glycols

— nitromusks and polycyclic musks, including for example:



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musk ketone 4_-tert-butyl-2_,6_-dimethyl-3_,5_-dinitroacetaphenone

HHCB(1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta(g)-2- benzopyran)

AHTN (6-Acetyl-1,1,2,4,4,7-hexamethyltetralin).

(b) No ingredient shall be included in the product that is classified as:

R40 (limited evidence of a carcinogenic effect)





R50+53 (very toxic to aquatic organisms and may cause long-term adverse effects in the aquatic environment),

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

R59 (dangerous to the ozone layer),





R64 (may cause harm to breastfed babies),

Each ingredient of any preparation used in the formulation that exceeds 0,1 % by weight of the preparation shall also meet the above requirement.

Biocides that are used to preserve the product (as allowed under the criterion on biocides below), and are classified as R50+53 or R51+53 are nevertheless permitted, but only if they are not potentially bio-accumulative. …

4. Fragrances

(a) The product shall not contain perfumes containing nitro-musks or polycyclic musks (as specified in the criterion above).

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(b) If the product contains one or more of the following fragrances, this shall be clearly indicated on the packaging, mentioning the name or names of the fragrances concerned:

amyl cinnamal – benzyl alcohol – cinnamyl alcohol – citral – eugenol – hydroxycitronellal – isoeugenol – amylcinnamyl alcohol – benzyl salicyclate – cinnamal – coumarin – geraniol – hydroxymethylpenthylcyclohexenecarboxaldehyde

5. Dyes or colouring agents

Any dyes or colouring agents used in the product must be permitted by Council Directive 76/768/EEC of 27 July 1976 on … cosmetic products …and by Directive 94/36/EEC of the European Parliament and of the Council of 30 June 1994 on colours for use in foodstuffs and its subsequent amendments.

6. Biocides

(a) The product may only include biocides in order to preserve the product, and in the appropriate dosage for this purpose alone. This does not refer to surfactants which may also have biocidal properties.

(b) It is prohibited to claim or suggest on the packaging or by any other communication that the hand dishwashing product has an antimicrobial action.

7. Sensitising substances

The product shall not be classified as R42 (may cause sensitisation by inhalation) and/or R43 (may cause sensitisation by skin contact) according to Directive 1999/45/EC on the classification, packaging and labelling of dangerous preparations.

8. Limitation of the total surfactants per wash

The weight of total surfactants in the recommended dose for 1 l of dishwashing water shall not exceed 0,4 g for dirty dishes.

Comment

TOXICITY TO AQUATIC ORGANISMS

Directive 73/404/EEC of 22 November 1973 on detergents only deals with biodegradability and does not take into account the total amount of chemicals, a recommended amount of insoluble inorganic ingredients nor toxicity parameters.

→ The eco-label is thus ahead of legislation by setting up the critical dilution volume toxicity for hand-dishwashing detergents.




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- Polyethylene glycols are quoted as standards under conditions for separation and evaluation of polymers in Directive 98/73/EC amending for the 24th time Council Directive 67/548/EEC on the classification, packaging and labelling of dangerous substances.



→ All this is part of the information given to consumers. This does not mean that such substances are banned.

The eco-label is thus clearly ahead of legislation when banning these substances as ingredients in hand-dishwashing detergents. It stands out by making a direct link with the product bought by final consumers.

BIOCIDES

Existing legislation on detergents does not deal with biocides.

Directive 1998/8/EC on the placing on the market of biocidal products defines biocidal products as active substances or preparations that exert a controlling effect on any harmful organism by chemical or biological means.

Cleaning products that may have biocidal effect are included.

Some surfactants have biocidal properties, which mean that they contribute to the preservation of the product.

→ The eco-label is in line with legislation when ensuring that the final product only contains substances which help in preserving it.

FRAGRANCES


All fragrance chemicals listed in the eco-label criteria are most frequently reported as contact allergens.

→ The eco-label is thus ahead of legislation when banning certain fragrances in the final product. It enables choice for the sensitive consumer.

SENSITISING SUBSTANCES

Existing legislation on detergents does not deal with sensitising substances.

Directive 1999/45/EC on the classification, packaging and labelling of dangerous preparations foresees that a preparation containing at least one sensitising substance in a concentration equal to or greater than 0,1% must bear the inscription that it may produce an allergic reaction.

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Preparations producing a sensitising effect have to carry risk phrases R42 (sensitising though inhalation) and R43 (sensitisation through skin contact)

→ The above-mentioned pieces of legislation only serve the purpose of informing consumers of the hazardous nature of these substances. By banning substances classified as R42 and/or R43, the eco-label is ahead of legislation. It enables a choice for sensitive consumers.

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HARD FLOOR COVERINGS

- Dangerous substances : ☺


- Asbestos : ☺

- Polyester resins : ☺

Existing criteria (Commission Decision of 25 March 2002, with a period of validity until 31 March 2006)

2. Raw materials selection (for all flooring products) (dangerous substances)

No substances or preparations that are assigned, or may be assigned at the time of application, any of the following risk phrases (or combinations thereof):

R45 (may cause cancer);

R46 (may cause heritable genetic damage);

R50 (very toxic to aquatic organisms);

R51 (toxic to aquatic organisms);

R52 (harmful to aquatic organisms);

R53 (may cause long-term adverse effects in the aquatic environment);

R60 (may impair fertility);

R61 (may cause harm to the unborn child);

as laid down in Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances, and its subsequent amendments,

may be added to the raw materials.

Where lead, cadmium and antimony (or any of their compounds) are used in the additives, their content shall not exceed the following specific limits:

Parameter Hurdle (% in weight of the glazes)

Lead 0,5

Cadmium 0,1

Antimony 0,25

No asbestos shall be present in the raw materials used for natural and processed products.

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The use of polyester resins in the production shall be limited by 10 % of the total weight of raw materials.

6. Use phase (heavy metals)

6.1. Release of dangerous substances (glazed tiles only)

In order to control the potential release of dangerous substances in the use phase and at the end of the glazed tile’s life, the products shall be verified according to the EN ISO 10545-15 test. The following limits shall not be exceeded:

Parameter Hurdle (mg/m2) Testing method

Pb 80 ISO 10545-15

Cd 7 ISO 10545-15

Comment

RAW MATERIALS

Dangerous substances

• Directive 67/548/EEC of 27 June 1967 relating to classification, packaging and labelling of dangerous preparations contains risk phrases to ensure that the specific nature of the potential dangers identified in the classification are expressed on the label.

→ The eco-label is thus clearly ahead when actually banning such substances, as the Directive 67/548 only informs consumers of all dangerous health and environmental effects.

Lead, cadmium and antimony

- Directive 76/769/EEC regarding restrictions on the marketing and use of certain dangerous substances and preparations bans cadmium used to stabilize floor coverings. The placing on the market of this finished product or components manufactured from polymers or PVC, stabilized by substances containing cadmium, is prohibited if their cadmium content exceeds 0,01 % by mass of the polymer.

- Directive 1996/62 of 27 September 1996 on ambient air quality assessment and management identifies lead, mercury and arsenic as air pollutants.

- Antimony is not covered by any legislation yet.

→ The eco-label is ahead of legislation when extending the scope of the limits established under Directive 76/769. The Eco-Label criteria apply to natural stone and ceramic floor coverings, whereas the 76/769 ban concerns only polymers (including their use as floor coverings).

It is ahead of legislation when setting up limits for lead and antimony.

The eco-label is once again going beyond legislation which only identifies some heavy metals as being problematic to final consumers.

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Asbestos

Directive 85/610 of 20 December 1985 amending for the 7th time Directive 76/769/EEC regarding restrictions on the marketing and use of certain dangerous substances and preparations bans all asbestos fibres in a number of products except floor coverings.

→ The eco-label is ahead of legislation when banning asbestos in hard floor coverings. Whilst background legislation did not include hard floor coverings in its scope the eco-label makes that link to the final article.

Polyester resins

In the absence of legislation covering polyester resins, the eco-label is ahead when introducing a limit for these substances at the raw material level.

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INDOOR PAINTS AND VARNISHES

- Titanium dioxide : ☺

- Volatile organic compounds (VOCs) : ☺

- Heavy metals : ☺ /

- Ingredients with risk phrases: ☺

- APEOs: ☺

- Glycol ethers : ☺

- Isothiazolinone compounds : ☺

- Formaldehydes: ☺


1. White pigments

(a) White pigment content : lower or equal to 38 g per m² of dry film, with 98 % opacity. This requirement does not apply to varnishes and woodstains.

(b) Titanium dioxide: The emissions and discharges of wastes from the production of any titanium dioxide pigment used shall not exceed the following:

— SOx emissions (expressed as SO2): 300 mg per m² of dry film (98 % opacity),

— sulphate wastes: 20 g per m² of dry film (98 % opacity),

— chloride wastes: 5, 9 and 18 g per m² of dry film (98 % opacity) respectively for natural retile, synthetic retile and slag ores.

2. Volatile organic compounds (VOCS)

The VOC content shall not exceed:

— wall paints (according to EN 13300): 30 g/l (minus water),

— other paints with a spreading rate of at least 15 m2/l at a hiding power of 98 % opacity: 250 g/l (minus water),

— all other products (including paints that are not wall paints and that have a spreading rate of less than 15 m2/l, varnishes, woodstains, floor coatings and floor paints, and related products): 180 g/l (minus water). In this context, a volatile organic compound is any organic compound with, at normal conditions for pressure, a boiling

point (or initial boiling point) lower than or equal to 250 °C.

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3. Volatile aromatic hydrocarbons (VHS)

The VA. content shall not exceed:

— wall paints (according to EN 13300): 0,15 % of the product (m/m),

— all other products (including all other paints, varnishes, woodstains, floor coatings and floor paints, and related products): 0,4 % of the product (m/m).In this context, a volatile aromatic hydrocarbon is any hydrocarbon with, at standard conditions for pressure, a boiling point lower or equal to 250 °C and having at least one aromatic

nucleus in its developed structural formula.

4. Heavy metals

Cadmium, lead, chromium VI, mercury, arsenic are banned.

It is accepted that ingredients may contain traces of these metals deriving from impurities in the raw materials.

5. Dangerous substances

(a) The product: The product shall not be classified as very toxic, toxic, dangerous to the environment, carcinogenic, toxic for reproduction or mutagenic in accordance with Directive 1999/45/EC.

(b) Ingredients (very toxic, toxic, carcinogenic, mutagenic, toxic for reproduction): No ingredient (substance or preparation) shall be used that is assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):

R23 (toxic by inhalation)

R24 (toxic in contact with skin)

R25 (toxic if swallowed)

R26 (very toxic by inhalation)

R27 (very toxic in contact with skin)

R28 (very toxic if swallowed)

R39 (danger of very serious irreversible effects)



R48 (danger of serious damage to health by prolonged exposure)



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as laid down in Council Directive 67/548/EEC of 27 June 1967 or in Directive 1999/45/EC. Active ingredients used as preservatives in the formula and that are assigned any of the risk phrases R23, R24, R25, R26, R27, R28, R39 or R48 (or combinations thereof) may nevertheless be used up to a limit of 0,1 % (m/m) of the total paint formulation.

(c) Ingredients (dangerous for the environment):

a maximum of 2,5% by mass of the product for ingredients (substance or preparation) that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):





and maximum 5% by mass of the product for the total sum of all ingredients, as laid down in Directive 67/548/EEC or Directive 1999/45/EC.

This requirement does not apply to ammonia, akyl ammonia or alkylamine.

This requirement does not affect the obligation to fulfil the requirement set out in criterion 5(a) above.

(d) Alkylphenolethoxylates (APEOs): banned

(e) Glycol ethers: Diethylene glycol methyl ether banned

(f) Isothiazolinone compounds: The content of isothiazolinone compounds in the product shall not exceed 500 ppm. The content of the mixture of 5-chloro-2-methyl-2H-isothiazol-3-one (EC No 247-500-7) and 2-methyl-2H-isothiazol-3-one (EC No 220-239-6) (3:1) shall not exceed 15 ppm.

(g) Formaldehydes: maximum 10 mg/kg of free formaldehyde

CCoommmmeenntt

TITANIUM DIOXIDE

Directive 67/548 on the classification, packaging and labelling of dangerous substances mentions titanium. Which means that this substance is recognized as being dangerous but not actually banned nor limited.

→ The eco-label, by fixing limits for emissions and discharges of wastes from the production of titanium dioxide pigment, is ahead of legislation. Directive 67/548 only serves the purpose of informing consumers on the hazardous nature of this substance.

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- Directive 1999/13/EC of 11 March 1999 deals with the limitation of emissions of VOCs due to the use of organic solvents, but the scope is “certain activities and installations” i.e. it is mainly addressing industrial operators;

- Directive 1994/63 deals with the prevention of VOC emissions to the atmosphere but scope is “during the storage of petrol at terminals and its subsequent distribution to petrol stations”;

- Directive 2001/81deals with national emission ceilings for certain atmospheric pollutants.

→ In the absence of prescriptions covering VOCs in paints and varnishes the eco-label is ahead of legislation. By setting up maximum concentrations of VOCs it allows to reduce the harmfulness to health of organic compounds as well as a number of indirect effects in the atmosphere or organic solvents.

HEAVY METALS

Cadmium, lead, Chromium VI, mercury and arsenic

- Directive 2003/53 of 18 June 2003 amending for the 26th time Directive 76/769/EEC regarding restrictions on the marketing and use of certain dangerous substances and preparations : cement and cement-containing preparations cannot be placed on the market if they contain, when hydrated, more than 0,0002 % soluble chromium VI of the total dry weight of the cement. This legislation does not cover paints and varnishes and only enters into force on 17 January 2005;

- according to Directive 76/769 relating to restrictions on the marketing and use of certain dangerous substances and preparations, cadmium may not be used in paints;

- Directive 1996/62 of 27 September 1996 on ambient air quality assessment and management identifies lead, mercury and arsenic as air pollutants;

- Directive 1999/45/EC of 31 May 1999 relating to the classification, packaging and labelling of dangerous preparations foresees compulsory labelling when the lead content in paints and varnishes exceeds 0,15%

→ The eco-label is in line with legislation when banning cadmium and clearly ahead of legislation when banning chromium VI, lead, mercury and arsenic. The eco-label once again is beyond background legislation in order to ensure a less hazardous article to final consumers.

DANGEROUS SUBSTANCES

- Ingredients with risk phrases


- health hazards:

• substances classified as toxic, very toxic, carcinogenic and mutagenic, toxic for reproduction respectively carry risk phrases R23 to R28, R39, R45 and R46, R48, R60 and R61. The concentration limit used to determine the classification of the preparation is ≥ 0.1% ;

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• environmental hazards: substances having adverse effects on the aquatic environment carry risk phrases R50 to R53. The concentration limit used to determine the classification of the preparation is ≥ 25%.

→ The eco-label is thus clearly ahead when actually banning such substances, even with respective tolerances of 0,1%, 2,5% or 5% as Directive 1999/45 only informs consumers of dangerous health and environmental effects.

- APEOs

Alkylphenolethoxylates (APEOs) are not covered by legislation.

→ The eco-label is thus clearly ahead when banning such substances in the final product offered to consumers.

- Glycol ethers

In the absence of any legislation covering this substance, the eco-label is ahead of legislation when banning diethylene glycol methyl ether.

- Isothiazolinone compounds

Directive 98/73 amending for the 24th time Directive 67/548 on the classification, packaging and labelling of dangerous substances mentions isothiazol. Which does not mean that this substance nor its compounds are actually banned.

→ The eco-label is thus clearly ahead when fixing a limit for the content of this substance and its compounds in the final article.

- Formaldehyde:

This substance is classified as being toxic in the Annex I of Directive 67/548/EEC of 27 June 1967 on classification, packaging and labelling of dangerous substances. This is part of the information given to consumers but does not mean that this substance is actually banned in the final product.

→ The eco-label is clearly ahead of legislation because it is setting up a maximum concentration for free formaldehyde.

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LAUNDRY DETERGENTS

- Total chemicals : ☺

- Insoluble inorganic ingredients: ☺


- Phosphates : ☺



Existing criteria (Commission Decision of 1 March 2003, with a period of validity until 29 February 2008)

1. Total chemicals

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

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

2. Insoluble inorganic ingredients

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

3. Toxicity to aquatic organisms

The critical dilution volume toxicity (CDVtox) of the recommended dosage shall not exceed 4 500 l/wash.

4. Phosphates

The total amount of phosphates (as sodium tripolyphosphate-STPP) at the recommended dosage shall not exceed 25 g/wash.

5. Biodegradability of surfactants

(a) Ready biodegradability (aerobic)

Each surfactant used in the product shall be readily biodegradable.


Each surfactant used in the product shall be anaerobically biodegradable.

6. Dangerous, hazardous or toxic substances or preparations

(a) Banned ingredients:

— alkyl phenol ethoxylates (APEOs) and derivatives thereof,

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— nitromusks and polycyclic musks, including for example:

— musk xylene: 5-tert-butyl-2,4,6-trinitro-m-xylene,

— musk ambrette: 4-tert–butyl-3-methoxy-2,6-dinitrotoluene,

— moskene: 1,1,3,3,5-pentamethyl-4,6-dinitroindan,

— musk tibetine: 1-tert-butyl-3,4,5-trimethyl-2,6-dinitrobenzene,

— musk ketone: 4'-tert-butyl-2',6'-dimethyl-3',5'-dinitroacetaphenone,

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

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

— EDTA (ethylenediamine tetraacetate),

— NTA (nitrilotriacetate).

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

(c) The total amount of phosphonates that are not readily biodegradable (aerobically) shall not exceed 0,5 g/wash at the recommended dosage.

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

— R40 (limited evidence of a carcinogenic effect),

— R45 (may cause cancer),

— R46 (may cause heritable genetic damage),

— R49 (may cause cancer by inhalation),

— R50-53 (very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment),

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

— R59 (dangerous to the ozone layer),

— R60 (may impair fertility),

— R61 (may cause harm to the unborn child),

— R62 (possible risk of impaired fertility),

— R63 (possible risk of harm to the unborn child),

— R64 (may cause harm to breastfed babies),

— R68 (possible risks of irreversible effects),

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or any combination thereof, according to Directive 67/548/EEC and its subsequent amendments, or according to Directive 1999/45/EC relating to the classification, packaging and labelling of dangerous preparations .

Each substance or ingredient of any preparation used in the formulation that exceeds 0,01 % of the final product shall also meet the above requirements.

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

(e) The product shall not be classified as R43 (may cause sensitisation by skin contact) according to Directive 1999/45/EC.

Comment

TOTAL CHEMICALS – INSOLUBLE ORGANIC INGREDIENTS – TOXICITY TO AQUATIC ORGANISMS

Directive 73/404/EEC of 22 November 1973 on detergents only deals with biodegradability and does not take into account the total amount of chemicals, a recommended amount of insoluble inorganic ingredients nor toxicity parameters.

→ The eco-label is thus ahead of legislation by setting up limits for these three parameters.

PHOSPHATES







- APEOs, EDTA and NTA are not covered by legislation.

- Directive 2002/34/EC of 15 April 2002 adapting to technical progress Annexes II, III and VII to Council Directive 76/768/EEC relating to cosmetic products authorizes a maximum concentration of 1,0% of musk xylene in fine fragrance and of 0,03% in other cosmectic products and a maximum concentration of 1,4% of musk ketone in fine fragrance and of 0,042% in other cosmetic products.


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The Directive on cosmetics naturally does not cover this product group but laundry detergents do contain the same fragrances.

Directive 67/548 only provides information to consumers on dangerous substances, without prohibiting them.



→ The eco-label is thus clearly ahead of legislation when banning these substances as part of the formulation or of any preparation used in the formulation of laundry detergents.

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LIGHT BULBS

- Mercury : ☺ /

- Flame retardants : ☺

Existing criteria (Commission decision of 9 September 2002, with a period of validity until 31 August 2005)

CRITERIA

Mercury content

Single-ended light bulbs shall meet the following requirements:

Single-ended with integral ballast (compact fluorescent

lamps)

Single-ended without integral ballast (pin based lamp)

Average mercury content maximum of 4.0 mg maximum of 4.0 mg

Double-ended light bulbs shall meet the following requirements:

Double-ended, normal life Double-ended, long life

Average mercury content maximum of 5.0 mg maximum of 8.0 mg

Flame retardants

Plastic parts heavier than 5 grams shall not contain the following flame retardants:

Name CAS no. Decabromodiphenyl 13654-09-6

monobromodiphenyl ether 101-55-3

dibromodiphenyl ether 2050-47-7

tribromodiphenyl ether 49690-94-0

tetrabromodiphenyl ether 40088-47-9

pentabromodiphenyl ether 32534-81-9

hexabromodiphenyl ether 36483-60-0

heptabromodiphenyl ether 68928-80-3

octabromodiphenyl ether 32536-52-0

nonabromodiphenyl ether 63936-56-1

decabromodiphenyl ether 1163-19-5

Chloroparaffins with chain length 10-13 C atoms, chlorine content > 50% by weight.

85535-84-8

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Plastic parts heavier than 5 grams shall not contain flame retardant substances or preparations containing substances that are assigned at the time of application any of the following risk phrases (or combinations thereof):



R50 (very toxic to aquatic organisms)

R51 (toxic to aquatic organisms)

R52 (harmful to aquatic organisms)

R53 (may cause long-term adverse effects in the aquatic environment)



as defined in Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances and its subsequent amendments.

7. Information appearing on the eco-label

If the light bulb does not contain mercury, Box 2 of the eco-label may state that the light bulb does not contain mercury.

Comment

MERCURY

Directive 2002/95/EC of 27 January 2002 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), entering into force on 1 July 2006, bans mercury in any new equipment put on the market. Exempted is mercury in compact fluorescent lamps not exceeding 5 mg per lamp.

• Until this implementation date:

→ the eco-label is ahead of legislation with its criterion on a maximum mercury content of 4.0 mg maximum in single-ended light bulbs.

• After implementation in 2006 :

→ the eco-label will be in line with existing legislation with its criterion on a maximum mercury content of 5.0 mg for double-ended, normal life light bulbs; but behind legislation with the criterion on a maximum mercury content of 8.0 mg for double-ended, long life light bulbs.

FLAME RETARDANTS

• Directive 2002/95/EC of 27 January on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), entering into force on 1 July 2006, foresees that new electrical and electronic equipment put on the market should not contain ... polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE).

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- health hazards:




→ The eco-label is ahead of legislation by banning in light bulbs all the brominated flame retardants mentioned in RoHS. The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

By fully banning the presence of dangerous substances in flame retardants contained in plastic parts of light bulbs, the eco-label is stricter than legislation. Directive 1999/45 only informs consumers of dangerous health and environmental effects.

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PERSONAL COMPUTERS

- Mercury : ☺


- Heavy metals in batteries : ☺

Existing criteria (Commission Decision of 22 August 2001, with a period of validity until 21 August 2004)

3. Mercury content of a liquid crystal display (LCD) monitor

The background lighting of the LCD monitor shall not contain more than 3 mg of mercury per lamp (on average)

6. Take back and recycling (flame retardants)

(c) incompatible and hazardous materials shall be separable;

(f) plastic parts shall:

— have no lead or cadmium intentionally added,

— be of one polymer or compatible polymers, except for the cover, which shall consist of no more than two types of polymers which are separable,

— contain no metal inlays that cannot be separated;

(g) plastic parts heavier than 25 grams shall:

— not contain the following flame retardants:

Name Cas No

Decabromodiphenyl 13654-09-6










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Chloroparaffins with chain length C atoms, chlorine content > 50 % by weight 85535-84-8,

— not contain flame retardant substances or preparations containing substances, that are assigned or may be assigned any of the risk phrases R45 (may cause cancer), R46 (may cause heritable genetic damage), R50 (very toxic to aquatic organisms), R51 (toxic to aquatic organisms), R52 (harmful to aquatic organisms), R53 (may cause long-term adverse effects in the aquatic environment), R60 (may impair fertility) or R61 (may cause harm to the unborn child), as defined in Council Directive 67/548/EEC (1) and its subsequent amendments.

(h) batteries shall not contain more than 0,0001 % of mercury, 0,001 % of cadmium or 0,01 % of lead by weight of the battery.

Comment

MERCURY

Mercury content of the monitor

Directive 2002/95/EC of 27 January 2002 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), entering into force on 1 July 2006, bans mercury in any new equipment put on the market. Exempted is mercury in compact fluorescent lamps not exceeding 5 mg per lamp.

→ The eco-label is ahead of legislation as it fixes a maximum mercury content of 3 mg per lamp. By already incorporating the terms of a new legislation before it enters into force the eco-label offers a premium to final consumers who will buy a product with reduced impact on environment and health.

FLAME RETARDANTS

• Directive 2002/95/EC of 27 January 2002 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), entering into force on 1 July 2006, foresees that new electrical and electronic equipment put on the market should not contain ... polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE).


- health hazards:




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→ The eco-label is ahead of legislation by banning in personal computers all the brominated flame retardants mentioned in RoHS. The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

By fully banning the presence of dangerous substances in flame retardants contained in plastic parts of personal computers, the eco-label is stricter than legislation. Directive 1999/45 only informs consumers of dangerous health and environmental effects.

HEAVY METALS IN BATTERIES

Directive 1991/157 of 18 March 1991 on batteries and accumulators containing certain dangerous substances prohibits the marketing of certain alkaline manganese batteries containing more than 0,025% of mercury by weight. But batteries attached to terminals are not in the scope.

It requires recovery and disposal of batteries containing more than 0,025 % cadmium by weight and more than 0,4 % lead by weight.

→ The eco-label is ahead of legislation when setting up a maximum content of 0,0001% of mercury, of 0,001% of cadmium and of 0,01% of lead by weight of the battery in computers.

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PORTABLE COMPUTERS

- Mercury : ☺


- Heavy metals in batteries : ☺


NB: same criteria as for personal computers, with same limit for mercury content of display, except that here, we talk of the background lighting of “the flat panel display” and not of “the LCD monitor”.

→ Same comments as for personal computers

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REFRIGERATORS

- Ozone depleting substances:


A – Existing criteria (Commission Decision of 16 December 1999, with a period of validity until 1 December 2003)

KEY CRITERIA

2. Reduction of ozone depletion potential (ODP) of refrigerants and foaming agents

The refrigerants in the refrigerating circuit and foaming agents used for the insulation of the appliance shall have an ozone depletion potential equal to zero.

3. Reduction of global warming potential (GWP) of refrigerants and foaming agents

The refrigerants in the refrigerating circuit and foaming agents used for the insulation of the appliance, shall have a global warming potential equal to, or lower than, 15 (rated as CO2 equivalents over a period of 100 years).

ADDITIONAL CRITERIA


The refrigerator shall meet the following criteria :

3) Plastic parts heavier than 25 grams shall not contain the following flame retardants :

Name CAS No

decabromodiphenyl 13654-09-6










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Chloroparaffins with chain length 10 to 13 C atoms, 85535-84-8

chlorine content > 50 % by weight

4) Plastic parts heavier than 25 grams shall not contain flame retardant substances or preparations containing substances that are or may be assigned any of the risk phrases R45 (may cause cancer), R46 (may cause heritable genetic damage), R50 (very toxic to aquatic organisms), R51 (toxic to aquatic organisms), R52 (harmful to aquatic organisms), R53 (may cause long-term adverse effects in the aquatic environment), R60 (may impair fertility) or R61 (may cause harm to the unborn child), or any combinations of risk phrases containing any of the above risk phrases, as defined in Council Directive 67/548/EEC, as last amended by Commission Directive 98/98/EEC.

This requirement does not apply to flame retardants that on application change their chemical nature to no longer warrant classification under any of the R-phrases listed above, and where less than 0,1 % of the flame retardant in the treated part remains in the form as before application.

Comment

OZONE DEPLETING SUBSTANCES

Regulation 2037/2000 of the European Parliament and of the Council of 29/6/2000 on substances that deplete the ozone layer rules that the use of hydrochlorofluorocarbons (HCFCs) is prohibited as refrigerants in equipments produced after 31/12/1995, namely for domestic refrigerators and freezers and for foams.

→ By prescribing that refrigerants used for insulation purposes shall have an ozone depletion potential equal to zero, the eco-label is in line with legislation.

FLAME RETARDANTS



- health hazards:




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→ The eco-label is ahead of legislation by banning in refrigerators all the brominated flame retardants mentioned in RoHS Directive. The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

By fully banning the presence of dangerous substances in flame retardants contained in plastic parts of refrigerators, the eco-label is stricter than legislation. Directive 1999/45 only informs consumers of dangerous health and environmental effects.

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SOIL IMPROVERS

- Organic ingredients : ☺


- Pesticides : ☺


1. Organic ingredients

b) Products shall not contain sewage sludge.

2. Limitation of hazardous substances (heavy metals)

(a) In the final product, the content of the following elements shall be lower than the values shown below, measured in terms of dry weight:

Element mg/kg (dry weight)

Zn 300

Cu 100

Ni 50

Cd 1

Pb 100

Hg 1

Cr 100

Mo (*) 2

Se (*) 1,5

As (*) 10

F (*) 200

(*) Data relating to the presence of these elements are needed only for products containing material from industrial processes.

(b) Products shall not contain bark which has been treated with pesticides.

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6. Health and safety

Products shall not exceed the maximum levels of primary pathogens as follows:

- salmonella: absent in 50g

- E. coli: < 1 000 MPN/g (MPN: most probable number).

CCoommmmeenntt

ORGANIC INGREDIENTS

Sewage sludge

There is no legislation covering soil improvers. By requesting that sewage sludge shall not be contained in organic ingredients, the eco-label makes a link to Directive 86/278 of 12 June 1986 on the protection of the environment, and in particular of the soil, when sewage sludge is used in agriculture. The “sludge Directive” refers to potential pollutants, limit of which serves as guidance for the eco-label criteria.

HEAVY METALS

- No legislation covers chromium or copper.

- Directive 1996/62 of 27 September 1996 on ambient air quality assessment and management identifies among other metals arsenic as an air pollutant. But no limits are set up;

- Directive 86/278 of 12 June 1986 on the protection of the environment, and in particular of the soil, when sewage sludge is used in agriculture, sets up limit values for concentrations of heavy metals in soil:

• cadmium : 1 to 3 mg/kg of dry matter

• copper : 50 to 140 mg/kg of dry matter

• nickel : 30 to 75 mg/kg of dry matter

• lead : 50 to 300 mg/kg of dry matter

• zinc : 150 to 300 mg/kg of dry matter

• mercury : 1 to 1.5 mg/kg of dry matter

→ The eco-label is ahead of legislation by setting limit values for these heavy metals in soil improvers rather than acceptable ranges as in Directive 86/278 (“the sludge Directive”).

But in optimal conditions, the “sludge Directive” can be stricter than the eco-label. This leads to the conclusion that the eco-label could certainly be improved.

The eco-label is still ahead when covering all chemicals that are of concern to consumers whilst the “sludge Directive” only covers some of them.

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Finally, the eco-label certainly goes further as it also contains a criterion (n° 6) dealing with health and safety. This allows the eco-label to play a more ambitious role than its original role which is to help in minimising the environmental impact of a consumer product.

PESTICIDES

Directive 2003/60/EC of 18 June 2003 deals with the fixing of maximum levels for certain pesticide residues in and on cereals, foodstuffs of animal origin and certain products of plant origin, including fruit and vegetables.

→ By fully banning pesticide treatment of bark which may be contained in soil improvers the eco-label goes beyond legislation which only fixes limits and does not include bark in its scope.

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TELEVISIONS




3. Take-back and recycling (heavy metals and flame retardants)

(b) incompatible and hazardous materials shall be separable;

(f) plastic parts shall:

— have no lead or cadmium intentionally added;

— be of one polymer or compatible polymers, except for the cover, which shall consist of no more than two types of polymers which are separable;

— contain no metal inlays that cannot be separated;

(g) plastic parts heavier than 25 grams shall:

— not contain the following flame retardants:

Name CAS No

decabromodiphenyl 13654-09-6



tribomodiphenyl ether 49690-94-0



hexybromodiphenyl ether 36483-60-0





chloroparaffins with chain length 10-13 C atoms,

chlorine content > 50 % by weight, 85535-84-8

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— not contain flame retardant substances or preparations containing substances, that are assigned or may be assigned, at the time of application, any of the risk phrases R45 (may cause cancer), R46 (may cause heritable genetic damage), R50 (very toxic to aquatic organisms), R51 (toxic to aquatic organisms), R52 (harmful to aquatic organisms), R53 (may cause long-term adverse effects in the aquatic environment), R60 (may impair fertility) or R61 (may cause harm to the unborn child), as defined in Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances and its subsequent amendments.

Comment

HEAVY METALS

Lead and cadmium

- Directive 1999/30/EC of 22 April 1999 on limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air sets up a limit of 0,5 ppm for lead.

→ The eco-label is thus ahead of legislation when fully banning lead in the final article.

- Directive 76/769/EEC on restrictions on the marketing and use of certain dangerous substances and preparations bans arsenic compounds, cadmium and mercury.

→ The eco-label is thus ahead of legislation when fully banning cadmium in the final article as Directive 76/769 only deals with substances and preparations.

- Directive 2002/95/EC of 27 January on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), entering into force on 1 July 2006, foresees that new electrical and electronic equipment put on the market should not contain lead, mercury, cadmium and hexavalent chromium.

→ The eco-label is thus ahead of legislation when fully banning these heavy metals in the final article.

Directive 1999/30 is not directly linked to televisions but it serves in indicating that lead is recognized as being a problematic heavy metal.

Directive 76/769 only deals with dangerous substances and preparations and not with the final product.

The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

FLAME RETARDANTS



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- health hazards:




→ The eco-label is ahead of legislation by banning in televisions all the brominated flame retardants mentioned in RoHS Directive. The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

By fully banning the presence of dangerous substances in flame retardants contained in plastic parts of televisions, the eco-label is stricter than legislation. Directive 1999/45 only informs consumers of dangerous health and environmental effects.

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TEXTILE PRODUCTS

- Auxiliaries and finishing agents : ☺

- Biocidal or biostatic products : ☺

- Auxiliary chemicals : ☺

- Detergents : ☺

- Bleaching agents : ☺

- Azo dyes : ☺

- CMR dyes : ☺

- Volatile organic compounds (VOCs) : ☺



Existing criteria (Commission Decision of 15 May 2002, with a period of validity until 31 May 2007)

PROCESSES AND CHEMICALS CRITERIA

10. Auxiliaries and finishing agents for fibres and yarns

(a) Size: At least 95 % (by dry weight) of the component substances of any sizing preparation applied to yarns shall be sufficiently biodegradable or eliminable in wastewater treatment plants, or else shall be recycled.

(b) Spinning solution additives, spinning additives and preparation agents for primary spinning (including carding oils, spin finishes and lubricants): At least 90 % (by dry weight) of the component substances shall be sufficiently biodegradable or eliminable in waste water treatment plants.

This requirement does not apply to preparation agents for secondary spinning (spinning lubricants, conditioning agents), coning oils, warping and twisting oils, waxes, knitting oils, silicone oils and inorganic substances.

(c) The content of polycyclic aromatic hydrocarbons (PAH) in the mineral oil proportion of a product shall be less than 1,0 % by weight.

11. Biocidal or biostatic products

(a) Chlorophenols (their salts and esters), PCB and organotin compounds shall not be used during transportation or storage of products and semi-manufactured products.

(b) Biocidal or biostatic products shall not be applied to products so as to be active during the use phase.

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12. Stripping or depigmentation

Heavy metal salts (except of iron) or formaldehyde shall not be used for stripping or depigmentation.

13. Weighting

Compounds of cerium shall not be used in the weighting of yarn or fabrics.

14. Auxiliary chemicals

Alkylphenolethoxylates (APEOs), linear alkylbenzene sulfonates (LAS), bis(hydrogenated tallow alkyl) dimethyl ammonium chloride (DTDMAC), distearyl dimethyl ammonium chloride (DSDMAC), di(hardened tallow) dimethyl ammonium chloride (DHTDMAC), ethylene diamine tetra acetate (EDTA), and diethylene triamine penta acetate (DTPA) shall not be used and shall not be part of any preparations or formulations used.

15. Detergents, fabric softeners and complexing agents

At each wet-processing site, at least 95 % by weight of the detergents, at least 95 % by weight of fabric softeners and at least 95 % by weight complexing agents used shall be sufficiently degradable or eliminable in wastewater treatment plants.

16. Bleaching agents

In general, AOX emissions in the bleaching effluent shall be less than 40 mg Cl/kg. In the following cases, the level shall be less than 100 mg Cl/kg:

— linen and other baste fibres,

— cotton, which has a degree of polymerisation below 1 800, and which is intended for white end products.

This requirement does not apply to the production of man-made cellulose fibres.

17. Impurities in dyes

Maximum levels of ionic impurities in the dyes: Ag 100 ppm; As 50 ppm; Ba 100 ppm; Cd 20 ppm; Co 500 ppm; Cr 100 ppm; Cu 250 ppm; Fe 2 500 ppm; Hg 4 ppm; Mn 1 000 ppm; Ni 200 ppm; Pb 100 ppm; Se 20 ppm; Sb 50 ppm; Sn 250 ppm; Zn 1 500 ppm.

18. Impurities in pigments

Maximum levels of ionic impurities for pigments: As 50 ppm; Ba 100 ppm, Cd 50 ppm; Cr 100 ppm; Hg 25 ppm; Pb 100 ppm; Se 100 ppm Sb 250 ppm; Zn 1 000 ppm.

19. Chrome mordant dyeing

Chrome mordant dyeing is not allowed.

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20. Metal complex dyes.

If metal complex dyes based on copper, chromium or nickel are used:

(a) In case of cellulose dyeing, where metal complex dyes are part of the dye recipe, less than 20 % of each of those metal complex dyes applied (input to the process) shall be discharged to waste water treatment (whether on-site or off-site).

In case of all other dyeing processes, where metal complex dyes are part of the dye recipe, less than 7 % of each of those metal complex dyes applied (input to the process) shall be discharged to waste water treatment (whether on-site or off-site).

(b) Maximum emissions to water after treatment: Cu 75 mg/kg (fibre, yarn or fabric); Cr 50 mg/kg; Ni 75 mg/kg.

21. Azo dyes

Azo dyes shall not be used that may cleave to any one of the following aromatic amines:

4-aminodiphenyl (92-67-1)

Benzidine (92-87-5)



o-amino-azotoluene (97-56-3)


p-chloroaniline (106-47-8)

2,4-diaminoanisol (615-05-4)

4,4'-diaminodiphenylmethane (101-77-9)

3,3'-dichlorobenzidine (91-94-1)

3,3'-dimethoxybenzidine (119-90-4)

3,3'-dimethylbenzidine (119-93-7)

3,3'-dimethyl-4,4'-diaminodiphenylmethane (838-88-0)


4,4'-methylene-bis-(2-chloraniline) (101-14-4)

4,4'-oxydianiline (101-80-4)

4,4'-thiodianiline (139-65-1)



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22. Dyes that are carcinogenic, mutagenic or toxic to reproduction

(a) The following dyes shall not be used:

C.I. Basic Red 9

C.I. Disperse Blue 1

C.I. Acid Red 26

C.I. Basic Violet 14

C.I. Disperse Orange 11

C. I. Direct Black 38

C. I. Direct Blue 6

C. I. Direct Red 28

C. I. Disperse Yellow 3

(b) No use is allowed of dye substances or of dye preparations containing more than 0,1 % by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):









R68 (possible risk of irreversible effects),

as laid down in Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances, and its subsequent amendments.

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23. Potentially sensitising dyes

The following dyes shall only be used if the fastness to perspiration (acid and alkaline) of the dyed fibres, yarn or fabric is at least 4:

C.I. Disperse Blue 3 C.I. 61 505







C.I. Disperse Orange 1 C.I. 11 080

C.I. Disperse Orange 3 C.I. 11 005



(previously designated Orange 37)

C.I. Disperse Red 1 C.I. 11 110



C.I. Disperse Yellow 1 C.I. 10 345

C.I. Disperse Yellow 9 C.I. 10 375

C.I. Disperse Yellow 39

C.I. Disperse Yellow 49

24. Halogenated carriers for polyester

Halogenated carriers shall not be used.

25. Printing

(a) Printing pastes used shall not contain more than 5 % volatile organic compounds

(b) Plastisol-based printing is not allowed.

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26. Formaldehyde

The amount of free and partly hydrolysable formaldehyde in the final fabric shall not exceed 30 ppm for products that come into direct contact with the skin, and 300 ppm for all other products.

27. Waste water discharges from wet-processing

(a) Waste water from wet-processing sites (except greasy wool scouring sites and flax retting sites) shall, when discharged to surface waters after treatment (whether on-site or off-site), have a COD content of less than 25 g/kg, expressed as an annual average.

(b) If the effluent is treated on site and discharged directly to surface waters, it shall also have a pH between 6 and 9 (unless the pH of the receiving water is outside this range) and a temperature of less than 40 °C (unless the temperature of the receiving water is above this value).

28. Flame retardants

No use is allowed of flame retardant substances or of flame retardant preparations containing more than 0,1 % by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):














as laid down in Directive 67/548/EEC and its subsequent amendments.

This requirement does not apply to flame retardants that on application change their chemical nature to no longer warrant classification under any of the R-phrases listed above, and where less than 0,1 % of the flame retardant on the treated yarn or fabric remains in the form as before application.

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29. Shrink resistant finishes

Halogenated shrink-resist substances or preparations shall only be applied to wool slivers.

30. Finishes

No use is allowed of finishing substances or of finishing preparations containing more than 0,1 % by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):















31. Fillings

(a) Filling materials consisting of textile fibres shall comply with the textile fibre criteria (Nos 1 — 9) where appropriate.

(b) Filling materials shall comply with criterion 11 on ‘Biocidal or biostatic products’ and the criterion 26 on ‘Formaldehyde’.

(c) Detergents and other chemicals used for the washing of fillings (down, feathers, natural or synthetic fibres) shall comply with criterion 14 on ‘Auxiliary chemicals’ and criterion 15 on ‘Detergents, fabric softeners and complexing agents’.

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32. Coatings, laminates and membranes

(a) Products made of polyurethane shall comply with criterion 3(a) regarding organic tin and criterion 3(b) regarding the emission to air of aromatic diisocyanates.

(b) Products made of polyester shall comply with criterion 8(a) regarding the amount of antimony and criterion 8(b) regarding the emission of VOCs during polymerisation.

(c) Coatings, laminates and membranes shall not be produced using plasticisers or solvents, which are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):















Comment

AUXILIARIES AND FINISHING AGENTS FOR FIBRES AND YARNS

Polycyclic aromatic hydrocarbons (PAH) are not regulated by any legislation.

Directive 1999/45/EC relating to classification, packaging and labelling of dangerous preparations makes it compulsory to warn on the label that a preparation contains a substance not yet tested completely if this substance is present in a concentration ≥ 1%.

→ The eco-label is ahead of legislation when setting up a limit for this class of substances in a final consumer article whilst Directive 1999/45 only deals with dangerous preparations.

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BIOCIDAL OR BIOSTATIC PRODUCTS

Directive 1998/8/EC concerning the placing on the market of biocidal products defines biocidal products as active substances or preparations that exert a controlling effect on any harmful organism by chemical or biological means.

Its scope contains products used for the preservation of fibrous or polymerised materials, such as textile products by the control of microbiological deterioration.

Under the conditions of use, the biocidal product shall pose only a low risk to humans, animals and the environment (“The Member State shall not authorise a biocidal product if the risk assessment confirms that, in foreseeable application including a realistic worst possible scenario, the product presents an unacceptable risk to humans”).

→ In the absence of specific legislation on textile products the eco-label is ahead of legislation by prescribing that biocidal products should not be active during the use phase of textiles as a final product. It thus helps in protecting human health at the level of the consumer article whilst Directive 1998/8 only deals with marketing of biocidal products.

AUXILIARY CHEMICALS

Alkylphenolethoxylates (APEOs) – ethylene-diamine-tetra-acetate (EDTA) and nitrilotriacetate (NTA), etc… are not covered by legislation.

→ The eco-label is thus clearly ahead when banning these substances in the final product offered to consumers.

DETERGENTS

Basis Directive 73/404/EEC of 22 November 1973 on detergents sets up an average level of biodegradability of detergents of 90%.

→ By requiring at least 95% by weight of detergents to be sufficiently degradable, the eco-label is ahead of legislation.

BLEACHING AGENTS

The PARCOM 97/1 Recommendation, one of OSPAR measures for the protection of marine environment of North-East Atlantic, gives some reference values for effluent discharges from wet processes in textile processing industries. Regarding AOX, the discharge reference value is set at 100 mg Cl/kg for companies doing either pre-treatment or dyeing, and at 150 mg Cl/kg for companies doing both.

→ Even if PARCOM 97/1 is only a recommendation, the eco-label is ahead when requiring AOX emissions in the bleaching effluent to be less than 40 mg Cl/kg in some cases and less than 100 mg Cl/kg in other cases.

AZO DYES


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→ The eco-label is thus ahead of legislation when fully banning azo dyes in textile products. When going further than the limit set up in background legislation covering textile articles the eco-label offers an advantage to final consumers in terms of protection of their health.

DYES THAT ARE CARCINOGENIC, MUTAGENIC OR TOXIC TO REPRODUCTION

Directive 67/548/EEC of 27 June 1967 on the classification, packaging and labelling of dangerous substances contains a number of risk phrases to ensure that the specific nature of the potential dangers identified in classification are expressed on the label.

→ By fixing a strict limit in the use of dyes that are assigned CMR risk phrases the eco-label is stricter than legislation which only informs consumers of dangerous health and environmental effects.

Risk phrases only tell consumers how to handle dangerous substances put on the market. They do not go as far as considering the final article purchased by final consumers.

VOLATILE ORGANIC COMPOUNDS

- Directive 1999/13/EC of 11 March 1999 deals with the limitation of emissions due to the use of organic solvents, but the scope is “certain activities and installations” i.e. only addressing industrial operators;

- Directive 1994/63 deals with the prevention of VOC emissions to the atmosphere but its scope is “during the storage of petrol at terminals and its subsequent distribution to petrol stations”;

- Directive 2001/81 deals with national emission ceilings for certain atmospheric pollutants.

→ These directives do not deal with textiles. By setting up a maximum concentration of VOCs in printing pastes the eco-label is ahead of legislation. It thus allows to reduce the harmfulness to health of organic compounds as well as a number of indirect effects in the atmosphere or organic solvents.

FORMALDEHYDE

This substance is classified as being toxic in the Annex I of Directive 67/548/EEC of 27 June 1967 on classification, packaging and labelling of dangerous substances. This is part of the information given to consumers. This does not mean that this substance is banned in the final product.

→ The eco-label is clearly ahead of legislation when setting up a maximum amount of formaldehyde in the final fabric for textile products that come into direct contact with the skin. It thus allows to follow the route of such a hazardous substance until the purchase of the final article.

FLAME RETARDANTS


- health hazards:

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→ By fully banning the presence of dangerous substances in flame retardants contained in textile products, the eco-label is stricter than legislation which only informs consumers of dangerous health and environmental effects.

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TISSUE PAPER

- Chlorine gas : ☺

- APEOs : ☺

- Chloro-organic substances : ☺


- Glyoxal : ☺

- Dyes and inks : ☺

Existing criteria (Commission Decision of 4 May 2001, with a period of validity until 3 May 2006)

ECOLOGICAL CRITERIA

4. Hazardous chemical substances

Bleaching: Chlorine gas shall not be used as a bleaching agent. This requirement does not apply to chlorine gas related to the production and use of chlorine dioxide. (Note: while this requirement also applies to the bleaching of recycled fibres, it is accepted that the fibres in their previous lifecycle may have been bleached with chlorine gas.)

De-inking: Alkylphenolethoxylates (APEOs) or other derivates from alkylphenol shall not be added in de-inking chemicals. Derivates from alkylphenol are defined as substances that are degraded to alkylphenols.

Wet strength aids: Wet strength aids must not contain more than 1,0 chloro-organic substances, related to the dry content, that are assigned or may be assigned any of the risk phrases R45 (may cause cancer), R46 (may cause heritable genetic damage), R5O/53 (very toxic to aquatic organisms, may cause long-term adverse effects in the

aquatic environment), R60 (may impair fertility) or R61 (may cause harm to the unborn child) as defined in the Council Directive 67/548/EEC, as last amended by Commission Directive 2000/33/EC. Examples of such chloro-organic substances are epichlorohydrin (ECH). 1,3-dichloro-2-propanol (DCP) and 3monochloro-1,2-propanediol (MCPD).

6. Product safety

Products made from recycled fibres or mixtures of recycled and virgin fibres shall fulfil requirements on hygiene as follows:

The tissue paper shall not contain more than:

Formaldehyde: 1 mg/dm2 according to test method EPA 8315A

Glyoxal: 1,5 mg/dm2 according to test method EPA 8315A

PCB: 2 mg/kg according to test method EPA 8270

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All tissue products shall fulfil the following requirements:

Slimicides and antimicrobic substances: No growth retardance of micro-organisms according to test method EN 1104.

Dyes and optical brighteners: No bleeding according to test method EN 646/648 (level 4 is required).

Dyes and inks: Dyes and inks used in the production of tissue paper shall not contain

azo-substances that may cleave to any of the amines listed in the technical appendix, table 3.

Comment

HAZARDOUS CHEMICAL SUBSTANCES

Bleaching agents - Chlorine gas

There is no legislation setting up a ban or a limit to the use of chlorine gas.

Directive 1999/45/EC on classification, packaging and labelling of dangerous substances makes it compulsory to label preparations containing more than 1% of active chlorine.

→ The eco-label is ahead of legislation when fully banning chlorine gas as a bleaching agent in tissue paper.

De-inking chemicals - APEOs

Alkylphenolethoxylates (APEOs) are not covered by legislation.

→ The eco-label is thus clearly ahead when banning such substances in the final article offered to consumers. The eco-labelled article will be differentiated as being less hazardous than a standard one.

Wet strength aids - Chloro-organic substances

These substances are classified as being dangerous by Directive 67/548 on the classification, packaging and labelling of dangerous substances. Risk phrases only serve the purpose of providing consumers with information on such substances, telling them how to handle these substances. This does not mean that they are actually banned but only listed and recognized as being dangerous.

→ The eco-label is thus clearly ahead when fixing a strict limit to such substances in the final product offered to consumers.

PRODUCT SAFETY

Formaldehyde

This substance is classified as being toxic in the Annex I of Directive 67/548/EEC of 27 June 1967 on classification, packaging and labelling of dangerous substances.

This is part of the information given to consumers. They should therefore expect to find this substance in the final product as it is not banned.

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→ The eco-label is clearly ahead of legislation because it is setting up a maximum concentration for formaldehyde in the final product. This goes much further than a simple classification of dangerous substances.

Glyoxal

In the absence of legislation covering that substance, the eco-label is ahead by introducing a limit for glyoxal in the final article.

Dyes and inks

Directive 2002/61 amending for the 19th time Directive 76/769 regarding restrictions on the marketing and use of certain dangerous substances and preparations bans azodyes in footwear, leather and textile articles which, by reductive cleavage of one or more azo groups, may release a number of aromatic amines in detectable concentrations above 30 ppm in the finished articles. Sanitary items are also covered.

→ The eco-label is stricter than legislation when going further than the above-mentioned limit and when fully banning azo dyes from tissue paper, defined as “sheets or rolls of tissue paper fit for use for personal hygiene”.

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VACUUM CLEANERS




3. Recyclability, take-back and recycling (heavy metals and flame retardants)

(d) The vacuum cleaner (including the power nozzle and the hose) shall not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) and/or polybrominated biphenyl ethers (PBDEs), except as allowed in the Annex to Directive 2002/95/EC of the European Parliament and of the Council of 27 January

2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS) and its subsequent amendments.

(f) Plastic parts heavier than 25 grams shall not contain chloroparaffins with chain length 10-13 C atoms, chlorine content > 50 % by weight (CAS 85535-84-8).

(g) Plastic parts heavier than 25 grams shall not contain flame retardant substances or preparations containing substances, that are assigned or may be assigned at the time of application any of the risk phrases R45 (may cause cancer), R46 (may cause heritable genetic damage), R50 (very toxic to aquatic organisms), R51 (toxic to aquatic organisms), R52 (harmful to aquatic organisms), R53 (may cause long-term adverse effects in the aquatic environment), R60 (may impair fertility) or R61 (may cause harm to the unborn child), as defined in Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws, regulations and administrative provisions

relating to the classification, packaging and labelling of dangerous substances (1) and its subsequent amendments.

Comment

HEAVY METALS

Lead, mercury, cadmium, hexavalent chromium

- Directive 1999/30/EC of 22 April 1999 on limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air sets up a limit of 0,5 ppm for lead.

- Directive 76/769/EEC on restrictions on the marketing and use of certain dangerous substances and preparations bans arsenic compounds, cadmium and mercury.

- Directive 2002/95/EC of 27 January on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), entering into force on 1 July 2006, foresees that new electrical and electronic equipment put on the market should not contain lead, mercury, cadmium and hexavalent chromium.

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→ The eco-label is thus ahead of legislation when fully banning these heavy metals in the final article.

Directive 1999/30 is not directly linked to vacuum cleaners but it serves in indicating that lead is recognized as being a problematic heavy metal.

Directive 76/769 only deals with dangerous substances and preparations and not with the final product.

The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

FLAME RETARDANTS



- health hazards:




→ The eco-label is ahead of legislation by banning in vacuum cleaners all the brominated flame retardants mentioned in RoHS. The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

By fully banning the presence of dangerous substances in flame retardants contained in plastic parts of vacuum cleaners, the eco-label is stricter than legislation. Directive 1999/45 only informs consumers of dangerous health and environmental effects.

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WASHING MACHINES


Existing criteria (Commission Decision of 17 December 1999, with a period of validity until 30 November 2005)


(c) Plastic parts heavier than 25 grams shall not contain the following flame retardants:

Name CAS No

decabromdiphenyl 13654-09-6











Chloroparaffins with chain length 10 to 13 C atoms,

chlorine content > 50 % by weight 85535-84-8

(d) Plastic parts heavier than 25 grams shall not contain flame retardant substances or preparations containing substances that are or may be assigned any of the risk phrases R45 (may cause cancer), R46 (may cause heritable genetic damage), R50 (very toxic to aquatic organisms), R51 (toxic to aquatic organisms), R52 (harmful to aquatic organisms), R53 (may cause long-term adverse effects in the aquatic environment), R60 (may impair fertility) or R61 (may cause harm to the unborn child), or any combinations of risk phrases containing any of the above risk phrases, as defined in

Council Directive 67/548/EEC (1) as last amended by Commission Directive 98/98/EEC (2).

This requirement does not apply to flame retardants that on application change their chemical nature to no longer warrant classification under any of the R-phrases listed above, and where less than 0.1 % of the flame retardant in the treated part remains in the form as before application.

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CCoommmmeenntt

FLAME RETARDANTS



- health hazards:




→ The eco-label is ahead of legislation by banning in washing machines all the brominated flame retardants mentioned in RoHS. The RoHS Directive will apply the same provision to all electrical and electronic equipment, but only from July 2006 onwards.

By fully banning the presence of dangerous substances in flame retardants contained in plastic parts of washing machines, the eco-label is stricter than legislation. Directive 1999/45 only informs consumers of dangerous health and environmental effects.

END

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