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Background Memo on the Swan-labelling of textiles, skins and leather Background Memo to criteria document version 3.0 18 March 2004

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Background Memoon

the Swan-labelling oftextiles, skins and leather

Background Memoto criteria document version 3.0

18 March 2004

Introduction and background

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In 1989, the Nordic Council of Ministers adopted a measure to implement a voluntary, positive ecola-belling scheme in the Nordic countries. The Nordic Ecolabelling Board administers the scheme. The board among other things choose product groups and lay down the final criteria. Secretariats in the participating countries are responsible for implementing the scheme on national level.

The objective of ecolabelling is to provide information to consumers to enable them to select products the least harmful to the environment. Ecolabelling is intended to stimulate environmental concern in product development and a sustainable society.

In its work on ecolabelling Nordic Ecolabelling follows the ISO 14024 standard: "Environmental labels and declarations - Type 1 ecolabelling - Principles and Procedures". The product groups and environ-mental and performance requirements selected by Nordic Ecolabelling reflect the objectives, principles, practices and requirements of the standard. ISO 14024 includes the requirements that criteria should be objective, reasonable and verifiable, that interested parties should be given the opportunity to participate and that their comments are evaluated.

The criteria are based on evaluation of the environmental impacts during the products’ life cycle. The criteria set requirements towards a number of these factors. Upon approved application all products found to meet the criteria are awarded the ecolabel.

Due to new knowledge and production methods the criteria must be updated regularly. New revised criteria are presented at least 1 year prior to the expiry date. During the period of validity minor corrections may be adopted. This will normally not affect already approved licences.

A handling fee is paid upon submission of a complete application. The turnover value of the product determines the additional annual fee.Denmark:Ecolabelling DenmarkThe Danish Standards AssociationKollegievej 6DK-2920 CharlottenlundTel: +45 72 30 04 50Fax: +45 72 30 04 51Homepage: www.ecolabel.dk

Finland:SFS-MiljömärkningPb 116FIN-00241 HELSINKITel: +358 9 1499 331Fax: +358 9 1499 3320Homepage: www.sfs.fi

Iceland:Norræn Umhverfismerking á ÍslandiUmhverfisstofnunSudurlandsbraut 24IS-108 REYKJAVIKTel: +354 591 20 00Fax: +354 591 20 20Hjemmeside: www.svanurinn.is

Norway:Ecolabelling NorwayKr. Augusts gt. 5NO-0164 OSLOTel: +47 22 36 57 40Fax: +47 22 36 07 29Homepage: www.ecolabel.no

Sweden:SIS Ecolabelling SE-118 80 STOCKHOLMTel: +46 8 55 55 24 00Fax: +46 8 55 55 24 01Homepage: www.svanen.nu

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Swan-labelling of textiles, skins and leatherPage

1 Summary 1

2 Introduction 22.1 Delimitation and definition of the product group 2

2.2 The period of validity of the criteria document 3

3 Other ecolabelling schemes for textiles, skins and leather 33.1 National environmental schemes 3

4 The market 45 The environmental impact of the production of textiles, skins and leather 66 Background to the requirements and criteria 9

6.1 Information on production and products 9

6.2 The relationship between Nordic Ecolabelling and the EU Flower scheme 10

6.3 Vegetable fibres 11

6.4 Skins and leather 11

6.5 Performance requirements for leather 12

6.6 Energy and water consumption 13

6.7 Ethical production 13

6.8 The requirements of the authorities 15

6.9 Requirements as to eco and quality assurance 15

6.10 Marketing 16

7 Future criteria 168 References 16

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1 Summary This document outlines the background to the environmental requirements (criteria) governing the ecolabelling of textiles, skins and leather [1] with the Nordic ecolabel, the Swan. The document describes the reasons underlying Nordic Ecolabelling's cri-teria to applicants, consumers and interest groupings.

The document outlines the reasons for the revision of the product group and criteria against the background of the environmental objectives contained in Nordic Ecola-belling's environmental philosophy [2] and strategy [3]. In the case of the production of textiles, skins and leather, the goals are primarily to bring about reduction in:

the use of chemicals that are harmful to health and the environment energy and water consumption the release of organic materials in waste water working conditions that are harmful to health

Justification for the criteria is also provided by the potential for environmental gain offered by the Swan-labelling of textiles, skins and leather, and the ways in which the requirements can be controlled and documented.

The background memo also discusses the requirements as to eco and quality man-agement in the production of textiles, skins and leather and considers the require-ment in relation to the overall objectives of ecolabelling.

This background memo also looks at possible additional criteria for the Swan-la-belling of textiles, skins and leather.

The work on revising the criteria for the Swan-labelling of textiles, skins and leather commenced in December 2002 under Danish management.

The following took part in the criteria development process:

The secretariat group:Leena Nyqvist-Kuusola, SFS-Miljömärkning, FinlandElisabeth Magnus, Stiftelsen Miljømerkning, NorwayAnders Moberg and Ulf Eriksson, SIS Miljömärkning AB, SwedenKristian Dammand Nielsen, Miljømærkesekretariatet, Denmark (Project Manager)

The comments and advice of selected experts, relevant businesses and other inter-ested parties were also sought during the development process. The criteria docu-ment and the background memo have been circulating for comments during a 60-day period in the autumn of 2003.

By imposing mandatory requirements as to environmental conditions, quality and eco-management, the criteria document for textiles, skins and leather provides man-ufacturers with scope for working systematically on bringing about environmental im-

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provements in the areas described in Chapters 4 and 5. All manufacturers of textiles, skins and leather that successfully fulfil the requirements provided for in the criteria document may apply for a licence to display the Swan label on their products.

2 Introduction

2.1 Delimitation and definition of the product group

The product definition in the previous criteria document for the Swan-labelling of tex-tiles provided scope for the ecolabelling of semi manufactures, woven/knitted materi-als and yarn.

As well as the above, products were also eligible for a Swan Label if they were made of various fibres, these being cotton, wool, flax, hemp, jute, regenerated cellulose fibre (for example viscose), polyester and polyamide (nylon).

When compared with the product group definition for the ecolabelling of textiles un-der the EU Flower scheme, the product group definition of textiles contained in the previous Swan label document was lacking in many ways.

The criteria document for textiles applicable under the EU ecolabelling scheme provides greater scope for ecolabelling textile raw materials and textile products. This was one of the consequences of the revision of the Flower scheme in 2001/2002.

The most obvious advantages of the Flower scheme are as follows:

Licences are not restricted to semi-manufactured and finished textile products - fibres may also be eligible for a licence.

Textile accessories may be eligible for a licence (for example handkerchiefs, bags and belts), provided that the product contains a minimum of 90% textile fibre.

There are demands to a range of fibres that may be used in ecolabelled tex-tile products. In addition to the fibres with demands under the Swan Label cri-teria, the Flower criteria also contains demands to acrylic, kapok, elastane, ramie, polypropylene, silk and all other textile fibres, provided that they are not inorganic fibres.

Greater flexibility is afforded where fibres are present in quantities of less than 5 percent by weight of the overall product. Up to three different fibre types may be exempt from compliance with the requirements if they each make up less than 5 percent by weight of the total product. Under the Swan Label scheme this is restricted to one type of fibre. This makes a great differ-ence in the case of, for example, underpants containing 4% elastane in the waistband and 3% polyamide used to strengthen the cotton threads.

It was clear that the benefits offered by the product group definition in the EU scheme should also be included in the Swan Label criteria document for textiles. The

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proposal is therefore that the product group definition contained in the Flower scheme should be incorporated without change in the Swan Label criteria.

In addition, the new criteria document for Swan-labelled textiles provides scope for the ecolabelling of products made of skins and leather. Accordingly the criteria docu-ment now entitled "the Swan-labelling of textiles, skins and leather". Skins and leather have been included in the product definition partly on the grounds of the en-vironmental problems associated with their production over a number of years [11, 12, 13, 14, 15], and partly in response to demands from consumers and manufactur-ers for the ecolabelling of such products to be possible.

2.2 The period of validity of the criteria document

The recommendation of the secretariat group is that the criteria document should re-main in force until 31 May 2007. The reason for this is that there will be a process of harmonisation with the Flower criteria for textiles, which also have a period of validity until 31 May 2007.

3 Other ecolabelling schemes for textiles, skins and leather

3.1 National environmental schemes

DenmarkDenmark has no competing ecolabelling schemes for textiles, skins and leather other than the Swan and the Flower schemes. A number of textiles on the market in Den-mark carry ecolabels from Sweden (Good Environmental Choice) [18] and the Neth-erlands (SKAL) [17]. However, these are confined to a limited number of collections available primarily in small specialist shops.

NorwayApart from the Swan Label and the Flower schemes, there are no ecolabelling schemes in Norway for textiles, skins and leather. Some products on the market carry ecolabels, for example from IVN in Germany [16]. Nine Norwegian manufactur-ers are licensed to use Øko-tex 100, which is not an ecolabel, but a label telling con-sumers something about the chemical substances that are not contained in the tex-tiles.

FinlandApart from the Swan Label and Flower schemes, there are no ecolabelling schemes in Finland for textiles, skins and leather. However, some textiles on sale in Finland carry ecolabels from Sweden (KRAV and Good Environmental choice) and the Neth-erlands (SKAL), although these are confined to a limited number of collections. Many Finnish manufacturers label their textiles with Øko-tex 100.

SwedenIn Sweden there are two well-established environmental labelling schemes for tex-tiles in addition to the Swan Label and the EU Flower. These are KRAV and the

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Swedish Society for Nature Conservation's "Good Environmental Choice" label. The rules applicable in both of these schemes are comparable to those of the Swan La-bel, except for the fact that Good Environmental Choice does not impose require-ments relating to fibre production.

4 The market

Denmark:In 2000, the textile and clothing industry in Denmark employed 12,308 people (source: Branchefacts, www.textile.dk) in 320 enterprises. The turnover in Denmark in 2000 totalled 3.9 billion euros for production and 3.8 billion euros for the retail trade. Exports totalled 2.9 billion euros and imports totalled 3.6 billion euros. In re-cent years, exports and imports have increased by a few percent a year, and this de-velopment is expected to continue in 2003. On the other hand, the number of people employed by the industry is falling by a few percent each year.

The general tendency is for cheap labour in neighbouring Eastern countries (primar-ily Poland and Lithuania) to be preferred over and above expensive labour in Den-mark. This trend has also been registered in the other Nordic countries. It is the la-bour-intensive processes in particular, such as stitching, folding, packing and cutting that are being moved eastwards (source: Utviklingen i den dansk Tekstil- og Be-klædningsindustri 1987 - 1999", by Dansk Textil og Beklædning).

Between January and May 2002, Denmark exported textiles and clothing to a value of approx. 250 million euros to Germany, 190 million euros to Sweden, 140 million euros to Norway and 70 million euros to Finland. During the same period Denmark imported textiles and clothing to a value of approx. 180 million euros from Germany and 80 million euros from Sweden. Figures for the other Nordic countries are not available since trade in these products between these countries is limited. As these figures show, in terms of imports and exports of textiles and clothing, Germany is Denmark's most important trading partner.

Textiles and clothing make up Denmark's fourth largest export product. (Source: Branchefacts, www.textile.dk.). There has been a notable change in the export situ-ation since 1987, when 63% of Danish clothing exports were to Sweden and Norway and only 13% to Germany, which at that time was confined to West Germany.

Norway:In 2000, the Norwegian textile and clothing industry employed just over 8000 people (source: Tekstilpanelet i Norge). In that same year the turnover of the industry totalled approx. 1.4 billion euros. About 50% of the output of the industry is exported - primarily to neighbouring EU countries. The industry in Norway is characterized by the production of specialist goods and niche products, using high-tech equipment. Businesses are usually small and medium-sized, employing fewer than 50 people. In future the industry will focus on products that offer added value in the form of quality,

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production efficiency or ethics, such as environmental considerations. Much of the production of the industry is located in the Baltic States and Poland.

Finland:In 2001, the textile and clothing industry in Finland employed about 12,000 people (source: Branchefacts, http://www.finatex.fi/html_en/statistics.htm). In the same year, the industry comprised 220 businesses and turnover totalled 1.2 billion euros in the case of production and 2.1 billion euros in the case of retail sales. Exports totalled 0.6 billion euro and imports 1.5 billion euros. In recent years exports have remained steady and imports have increased slightly each year.

This trend is expected to continue in 2003. Finland’s biggest export markets are Sweden (14%), Russia (12%) and Latvia (16%). Finland’s main sources of imports of textiles and clothing are Latvia (8%), Germany (10%) and China (12%). The number of people employed by the industry is decreasing annually by a few per cent.

Sweden:In 2001, almost 14,000 people were employed by the textile and clothing industry in Sweden in 350 businesses (source: the textile and garment industry, Sweden). Sales in the same year totalled approx. 1 billion euros. Exports by the industry amounted to 1.5 billion euros and imports totalled 3.5 billion euros. The European Union is the biggest market for Swedish exports, although Swedish textiles also go to Asia and North America. In 2001, retail outlets in Sweden sold clothing and accessories to a value of approximately 6 billion euros.

Europe:In 2000, the European clothing and textile industry employed 2.1 million people (source: Branchefacts, www.textile.dk.). In the same year, the industry comprised 114,00 businesses and turnover totalled 198 billion euros in the case of production and 3.8 billion euros in the case of retail trade. Exports totalled 34.3 billion euros and imports 57.3 billion euros. Retail sales totalled 229 billion euros. Purchases of cloth-ing by Europeans fell by 1.7% in 2000.

5 The environmental impact of the production of textiles, skins and leather

On the basis of the work of the secretariat group and contacts with experts in the in-dustry and a study of the literature Nordic Ecolabelling is imposing requirements on the following areas:

The production of raw fibres and skins without the use of chemicals those are harmful to health and the environment.

Spinning, knitting and weaving without the use of non-readily degradable oils that break down slowly in the environment.

Processing, dying, printing and tanning with less use of chemicals that are harmful to health and the environment and with a significant reduction in the content of organic materials in waste water.

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Quality assurance. Securing healthy working conditions.

The following pages describe selected areas of focus in terms of their environmental relevance and the scope for bringing about environmental improvement. Chapter 6 describes how Nordic Ecolabelling can encourage environmental improvement in the area by including requirements in the criteria document for the Swan labelling of tex-tiles, skins and leather. R, P and C stand for ”Relevance”, ”Potential” and ”Control-lability”. The selected areas of focus are those that it has been decided should be in-cluded as ”Supplementary Requirements” to the Flower criteria. Environmental relev-ance and background information on the environmental requirements imposed in the Flower criteria of textiles can be found in background documents for the Flower scheme [6].

Vegetable fibresThe environmental impact of cotton production in particular represents the main en-vironmental impact associated with textile production.

Chemical pesticides are used on all conventional cotton fields. Approximately 25% of all pesticide use is in cotton production, which accounts for only 5% of the total cultiv-ated land of the world. Over 30 different pesticides are currently in use [4,19].

According to a study, the EPA (The Environmental Protection Agency in the United States) regards the 15 most widely used pesticides in cotton cultivation in the United States as potentially carcinogenic [20].

Organic agriculture replaces the use of insect poisons with other methods. One ap-proach is to hang up traps containing pheromone scents. Pheromones are hor-mones that are released by female insects to attract males for mating. The traps are coated with an adhesive substance in which the males are trapped and die. Pher-omones are also applied to the leaves of the cotton plant in order to confuse the fe-males, thereby preventing mating. It is important to prevent the insects from mating because most insect problems occur when the females lay their eggs in the cotton flower and the larvae subsequently eat the flowers.

A second means of avoiding harmful insects is to create favourable conditions for predatory insects to prey on the pests. In some areas the farmers even catch predat-ory insects in other locations and transport them back to their fields to allow them to prey on the pests. In conventional agriculture these predatory insects are killed by the pesticides, with which the vermin are targeted.

In addition, the cotton plants used in organic agriculture are far more resistant to pests since over the courses of their lives they have built up natural resources to counter attacks from the outside.

Conventional agriculture use herbicides against weeds. The alternative to weed killers is often to remove weeds manually during the early growth stages of the cot-ton. In addition, fungicides (against fungi) and nemacides (against worms) are often

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used. Worldwide, pesticides to a value of 30 billion dollars are purchased each year (UN, 1996).A study conducted in Sudan has shown that the cost of the crop sprays used in the cotton fields rose 195-fold during the period 1945/46 – 1985/86, whereas the yield rose by just 4% during the same period [4]. Accordingly, there would appear to be an obvious environmental relevance in looking at the production of cotton and it seems reasonable that the requirement should be that the use of pesticides should be de-creased.

Water consumption in the production of cotton is also very high: between 7 and 29,000 litres of water are used per kilogram of harvested cotton [5].

The production of other types of vegetable fibre (not including viscose) does not in-volve the use of the same quantities of chemical agents to fight harmful organisms or water consumption. Even so, chemical agents are used in the production of, for ex-ample, flax and hemp to fight insects and weeds. Artificial fertilizer is also widely used, even though in reality both flax and hemp require very little nutrient. Pesticides and artificial fertilizers both have major environmental effects in many places in the world. One means of reducing this environmental effect would be to require fibre to be produced without the use of chemical pesticides and artificial fertilizers.

Genetically Modified cotton plantsThe cultivation of genetically modified cotton is becoming ever more widespread. During the 1990s, a genetically modified Bt-cotton was developed in China with a view to increasing the efficiency of cotton production. This cotton contains a toxin from a bacterium (Bactillus thuringiensis) and is particularly successful in areas in which butterfly larvae are the dominant pests. Chinese Bt-cotton was commercial-ised in 1997. Today, there are 22 Bt-cotton types approved for use on the Chinese market, of which 5 are American. Over 30% of the cotton cultivated in 2001 was ge-netically modified. In South Africa, 70% of the cotton cultivated in 2001/2002 was ge-netically modified. Studies in China have revealed an increase in yield of 5-10% in 1999 and 2001 and there has been a reduction in the use of pesticides of 78,000 tons (1/4 of Chinese consumption) since the mid-1990s.

Question about the environmental (development of resistance and the spread of genes) and social effects of the increased use of genetically modified plants are in-creasingly being raised in China and other cotton-producing countries. It has also been claimed that the quality of cotton grown in the United States and Australia – those countries in which genetically modified cotton has been grown the longest - has fallen [21,22].

Skins and leather The environmental relevance of imposing requirements on the production of skins and leather lies both in agricultural production and in the preparation of the skins [9,10,11,12,13,14,15].

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In farming, the main threat to the environment and human health lies in the use of pesticides. This can be avoided by imposing the requirement that the pesticides used must be amongst the least environmentally harmful. In addition, animal welfare may also be a relevant aspect to consider in agricultural production [15], where eco-nomic considerations often weigh heavier than the conditions under which the anim-als are kept. Simple requirements as to the conditions under which animals live can improve their welfare. During industrial preparation, the skins undergo cleaning, tan-ning, dying and printing. These processes often involve the use of chemical products and heavy metals that may be harmful to the environment and human beings. Im-posing requirements on the chemicals used and the quantities in which they are used can help to limit their harmful effect.

Energy and water consumptionA further very important environmental parameter in the production of textiles, skins and leather is energy and water consumption. During wet processing in particular, the consumption of energy and water used per kilogram of textiles produced is high. Moreover both water and energy are resources that should be saved. Depending on the type of product in question, up to 200 litres of water may be used in the produc-tion, dying and finishing of 1 kilogram of textile, [23]. In more and more places, en-ergy is produced with the aid of fossil fuels, giving rise to a noticeable increase in air pollution. Moreover, reductions in the availability of water have been registered with concern in many places (including in the Nordic countries).

By requiring the disclosure of water and energy consumption at the points at which most of these resources are consumed (in wet processing) it is hoped that the insight thereby gained will result in an interest in saving resources –not least for financial reasons. Numerous studies and reports (published by amongst others the Danish EPA) show that there will always be further scope for saving energy and water in tex-tile production – it is simply a question of utilizing new technology and knowledge.

Ethical textile productionRegrettably, in many places throughout the world, textiles, skins and leather are pro-duced under inhuman conditions. Nordic Ecolabelling's vision includes the goal of working towards a generally sustainable society. Ethical guidelines are also a pre-condition for a sustainable society. Many businesses have adopted rules on ethical production based on the norms produced by the UN agency the International Labour Organization (ILO) in Geneva. Even so, only a small proportion of the total world pro-duction of textiles, skins and leather works in accordance with rules of this nature.

6 Background to the requirements and criteria

In this revision process one of the key principles has been that there should be as little administration as possible involved in applying for and maintaining the Swan la-bel. For this reason, the requirements in the criteria document have been reduced to an absolute minimum and only the most important criteria with a high degree envir-onmental relevance (R), potential (P) and controllability (C) have been included. This

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ensures that it is possible in practical terms for applicants to gain a Swan label for their products while at the same time enabling Nordic Ecolabelling to be sure that when a business applies for a Swan label there will be a significant reduction in the overall negative impact of the production process on the environment.

6.1 Information on production and products

Nordic Ecolabelling needs to have a thorough knowledge of the processes involved in the production of Swan-labelled textiles, skins and leather, as well of the products themselves. Without this knowledge it will not be possible to assess, which criteria are relevant and which requirements should apply to the product. For this reason, Nordic Ecolabelling needs the following information:

information on trademark/trade name information on where the product is expected to be on sale information on the expected annual sales of the product (in terms of product

numbers and turnover (in each Nordic country) a description of the product and an overview of suppliers and the production

process as a whole a sample of a representative product

Nordic Ecolabelling will also be able to assist in providing information on and in mar-keting the Swan-labelled products, for which reason it is important for information to be provided on the trademark/trade name of the products and the places in which the products are expected to be on sale.

6.2 The relationship between Nordic Ecolabelling and the EU Flower scheme

The revision of the criteria document for Swan-labelling textiles has taken the form of a process of harmonisation with the Flower requirements for the ecolabelling of tex-tiles.

This process has involved harmonizing Swan requirements with those of the Flower scheme and adding certain supplementary requirements.

This means that all relevant requirements in the Flower criteria document for the tex-tile production in question must be met. For this reason, the Flower criteria document is attached as Appendix 2. The supplementary requirements must also be observed if they are relevant to the production processes in question.

A Flower licence will therefore be available to Swan licence-holders provided that they pay the application fee and comply with other overall requirements (e.g. logo, marketing, trade name). It should also be easier to secure a Swan licence for textiles if a Flower licence has already been granted. Although this requires further docu-mentation in order to fulfil the supplementary requirements in the Swan label criteria.

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An entirely new aspect of the Swan and Flower criteria for textiles is that Nordic Ecol-abelling has decided that skins and leather should now be included. The criteria con-cerning skins and leather are specified in the criteria document. There are no criteria made for the EU ecolabelling The Flower and this is why a direct reference to this ecolabel (as for textiles) is not possible.

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6.3 Vegetable fibres

The criteria document imposes requirements as to certified organic production of cotton or that cotton cultivation should be in a phase of transition to organic produc-tion. This requirement has been imposed because we know from research results during evaluation in this project that the potential availability and cost of organically produced cotton are acceptable and that cotton of this origin can be purchased by both large and small manufacturers of textiles. At the same time, the requirement re-lating to organic production of cotton will ensure that genetically modified cotton is not used.

Following further research, Nordic Ecolabelling has found that there is also a basis for imposing the same requirements on the production of other vegetable fibres (not including viscose). This is primarily because the cultivation of, for example, flax and hemp often involves pollution of the environment that could be reduced.

Although by no means large, the Nordic market for organically cultivated vegetable fibres for use in textile production does exist. Both flax and hemp are cultivated or-ganically in the Nordic countries and Northern German also has a high output of or-ganic flax. Nordic Ecolabelling is imposing requirements as to the organic cultivation of all vegetable fibres in the hope that it will thereby be possible to increase the mar-ket and demand for these fibres. It may be possible by these means to increase the organic cultivation for vegetable fibres to textile production.

6.1 Skins and leather

Nordic Ecolabelling has carefully considered how best to impose requirements as to the production of skins and leather in this document. Nordic Ecolabelling has re-ceived applications from numerous manufacturers of skins and leather for ecolabels to be granted on their products. This, however, has not been possible since there have been no applicable criteria. This is one argument in favour of introducing cri-teria for these products here. A second argument is the harmful environmental ef-fects that the production of skins and leather brings with it (see below).

The skins and leather products for which Swan label licences may be granted in fu-ture will be confined to products made of goat, sheep, cattle and pigs. The reason for this delimitation is that joint environmental criteria can be compiled for skins from the aforementioned animals since they are very similar and all are typically kept as do-mestic animals in agriculture. The situation as regards other animals – for example seal and mink – is often very different, for which reason it is difficult to draw up joint environmental criteria on the production of skins and leather from animals of these types.

Experience of the ecolabelling of shoes and furniture has shown that the main sources of environmental pollution are the wet processing of skins, in other words during the tanning and dying of the skins [12,15]. During dying, the pollution is

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caused by auxiliary chemicals and dyestuffs that may be harmful to health and the environment, whereas during tanning the greatest environmental problem is caused by the use of chromium. For these reasons, the criteria document imposes require-ments relating to the use of these substances.

These requirements specify that certain dyestuffs must not be used. Moreover, that dyestuffs and auxiliary chemicals must not contain certain substances. In addition, detergents, softeners and complexing agents must be readily degradable. The de-mands refers to the criteria document on textiles for the Flower, that contains de-mands to dyestuffs and auxiliary chemicals, that are well examined for environ-mental- and health damaging effects, and therefore also included here in the swan criteria document for textile, skin and leather. The content of chromium III in wastewater must be less than 1 mg per kg of leather treated. This threshold value has been determined after extensive research and discussions with experts during the development of the EU criteria for the ecolabelling of furniture – in this case leather furniture. Finally, a demand is that chromium VI must not be present in skins and leather products [12,13,14]. The criteria document does not contain any direct ban on the use of chromium in tanning since very few tanneries tan leather without the use of chromium.

Nordic Ecolabelling also wished to impose requirements on one further aspect of skins and leather, viz-agricultural production. Requirements have therefore been evaluated as to animal welfare, care for the environment, no use of harmful pesti-cides and no use of GMO (Genetically Modified Organisms). But the evaluation and many comments from the business have shown that it is not possible for the tanner to know what is happening in the agriculture where the domestic animals are bred. The skins are nearly always bought without knowledge of origin, which is lost in the processing line and the stock market. Therefore criteria concerning animal welfare are left out in this revision.

6.2 Performance requirements for leather

Requirements are imposed as to the quality of leather products since this parameter is not included in the Flower requirements, which apply only to textiles.

Relatively strict requirements have been imposed in order to ensure that the quality of Swan-labelled products is always acceptable.

The levels of the requirements and the test methods were found on the basis of the Flower criteria document for shoes [29] and textiles [24] and from a previous study conducted by Nordic Ecolabelling in connection with the development of the criteria for furniture [30]. Furthermore test institutions and experts have been contacted to secure that the right methods and threshold limits will be used.

6.3 Energy and water consumption

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Since it would be beneficial not only for the environment but also for the manufactur-ers themselves (for both financial and environmental reasons) for energy and water saving measures to be introduced, the criteria document contains the requirement that the manufacturer must disclose energy and water consumption during wet pro-cessing, and have a plan in place for reducing consumption per production unit. Nor-dic Ecolabelling is not specifying the amount of such reductions nor how they should be achieved in this version of the document – this is left up to the manufacturers themselves.

6.4 Ethical production

Nordic Ecolabelling has considered whether it would be realistic to impose ethical re-quirements on the production of textiles, skins and leather. A reference to existing standards would be the most obvious approach and this was considered carefully.

The only internationally acknowledged standard in this area seems to be SA8000. SA8000 certification was drafted and is managed by ”Social Accountability Interna-tional” (SAI) in New York. The organization consists of representatives of various parties within international trade. SAI issues certifications to companies specializing in business audits allowing them in turn to grant SA8000-certification to businesses that fulfil the standard.

SA8000 is based exclusively on agreements concluded by the ”International Labour Organization” (ILO) in Geneva, and these standards are acknowledged internation-ally. Using SA8000, businesses and retail outlets are able to develop tangible initiat-ives designed to promote ethical trade.

Further information on SA8000 can be found at the website www.sa-intl.org. The site also contains a list of the 310 businesses in 38 countries (of which 29 are textile manufacturers) with SA8000 certification on 31 October 2003.

For companies to be able to get the swan label Nordic Ecolabelling does not con-sider it realistic to demand a license to SA8000. It is too extensive not only to de-mand one but two certifications. Nordic Ecolabelling considers that it cannot be de-manded that the company shall meet the criteria in SA8000, because it is not pos-sible to take care of an acceptable inspection. Instead it has been chosen to let the company itself describe the politics concerning the issues put forward in SA80000 and thereafter make the politic public. By doing this everybody can see the state-ment and have the possibility to control if the politics are met.

In summary form the requirements in SA 8000 are:

1. Child Labour: No workers under the age of 15; minimum lowered to 14 for countries operating under the ILO Convention 138 developing-country exception; remediation of any child found to be working.

2. Forced Labour: No forced labour, including prison or debt bondage la-bour; no lodging of deposits or identity papers by employers or outside re-cruiters.

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3. Health and Safety: Provide a safe and healthy work environment; take steps to prevent injuries; regular health and safety worker training; sys-tem to detect threats to health and safety; access to bathrooms and pot-able water.

4. Freedom of Association and Right to Collective Bargaining: Respect the right to form and join trade unions and bargain collectively; where law prohibits these freedoms, facilitate parallel means of association and bar-gaining.

5. Discrimination: No discrimination based on race, caste, origin, religion, disability, gender, sexual orientation, union or political affiliation, or age; no sexual harassment.

6. Discipline: No corporal punishment, mental or physical coercion or verbal abuse.

7. Working Hours: Comply with the applicable law but, in any event, no more than 48 hours per week with at least one day off for every seven day period; voluntary overtime paid at a premium rate and not to exceed 12 hours per week on a regular basis; overtime may be mandatory if part of a collective bargaining agreement.

8. Compensation: Wages paid for a standard work week must meet the legal and industry standards and be sufficient to meet the basic need of workers and their families; no disciplinary deductions.

SA8000 can be found in its entirety at:www.sa-intl.org/Document%20Center/2001StdEnglishFinal.doc

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The requirement as to the ethical production of textiles, skins and leather is followedby a documentation requirement in which applicants must make the plan for ethicalproduction public. The reason for this is that no documentation exists to prove that production is ethical short of forcing businesses to undergo certification to a stand-ard, for example SA8000. Nordic Ecolabelling is unwilling to do this. However, if doubts arise about whether a manufacturer of Swan labelled textiles, skins and leather is complying with the requirements (during an inspection visit or through in-formation provided by persons with knowledge of the business) the licence will be re-voked with immediate effect. It is a desire that the plan covers the entire production, including sub contractors. The objective is that manufacturers in the future use workable certifications with ethical criteria, for instance SA8000.

6.5 The requirements of the authorities

To be granted a Swan label, the applicant must comply with all national laws and regulations and all requirements imposed by the relevant authorities. In order to be granted a Swan label licence this requirement has been included to ensure that the business maintains the standard of production. Especially for Norway a reference is made to the Limiting Direction (“Begrensningsforskriften”). There are no documenta-tion requirements, but the licence may be revoked if a business fails to comply with this requirement.

6.6 Requirements as to eco and quality assurance

Since is it important for manufacturers to maintain control over their suppliers and the various processes involved in production, requirements are imposed as to control over production of Swan-labelled textiles, skins and leather. Misunderstandings may occur between the various processes involved, new employees may be recruited, changes may be introduced into the production process, requiring approval by Nor-dic Ecolabelling. In short, many events can occur for which it is necessary to be pre-pared before actual production of Swan-labelled products commences. Nordic Ecola-belling has therefore introduced requirements as to the following factors:

Compliance with the rules in the ecolabelling criteria must be secured. The quality of the ecolabelled products encompassed by the licence must be

maintained at a high level. The manufacturer must provide details of the way in which the internal quality

and eco assurance system is structured in order to ensure compliance with the ecolabelling criteria.

The manufacturer must ensure that a contact person coordinates internal control procedures.

6.7 Marketing

The manufacturer must describe the way in which marketing will be conducted and an undertaking must be given, in Appendix 1, that the manufacturer is familiar with the marketing rules applied by Nordic Ecolabelling. This requirement has been im-

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posed in order to ensure that misunderstandings do not occur on the part of custom-ers and users of ecolabelled textiles, skins and leather. Marketing material must be clear about what products are ecolabelled and why.

7 Future criteria In future criteria Nordic Ecolabelling will consider the possibility of full harmonisation with the EU ecolabel, the Flower. Harmonisation will depend on various factors, in-cluding the provisions of the Flower criteria for textiles applicable at the time. This means that Nordic Ecolabelling will take part in the development of the criteria for the Flower scheme and thereby work towards 100% harmonisation, at the same time as which the organization will continuously evaluate how the Swan label too might in-crease its ties to the Flower scheme. Animal welfare and ethical production will be subjects to consider in future revisions.

Ecolabelling is an ongoing process, for which reason it is by no means impossible that other proposals will be forthcoming for inclusion in future criteria.

8 References

[1] The ecolabelling of textiles, Nordic Ecolabelling, Criteria document ver-sion 3.0

[2] Nordic Ecolabelling: Environmental philosophy, 2000. [3] Strategy document for Nordic Ecolabelling 1999 – 2001, version 3[4] Nielsen, K.D. 1998, Ecodocument, textiles, for Green Info, the Sustainable

Solution Design Association. [5] Danish EPA 1997. Environmental Assessment of Textiles, Environmental

project no. 369.[6] Background document for the development of criteria for the Flower la-

belling of textiles (available only in hard copy, from the Nordic secretariats).Danish EPA 2002. Revision of Commission Decision 1999/178/EC estab-lishing the ecological criteria for the award of the Community eco-label to textile products, Working report.

[7] Social Accountability 8000, 2001:www.sa-intl.org/Document%20Center/2001StdEnglishFinal.doc

[8] Council Regulation (EC) No 1804/1999 of 19 July 1999. “Supplementing regulation EEC No 2092/91 on organic production of agricultural products and indications referring thereto on agricultural products and foodstuffs to include livestock production”.

[9] Action Plan II. Organic farming in development. The Council on Organic Foodstuffs, The Advisory Research Committee of the Ministry of Food, Agri-culture and Fisheries, January 1999.

[10] KRAV, ”Good Animal Husbandry", www.krav.se.[11] KRAV, ”Hides, leather and skin", www.krav.se.[12] CEA & TNO, Rotterdam 1994. An ecolabel for footwear. Background Re-

port.

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[13] The Danish EPA 2002. Investigation into the content of Cr (VI) and Cr (III) in leather goods on the Danish market.

[14] The Chemical Inspectorate, Sweden 2001. Chemicals in shoes - a prelimin-ary study.

[15] Lloranc et al. 2002. Use of Life Cycle Assessment in the Procedure for the Establishment of Environmental Criteria in the Catalan Eco-label of Leather. Int. J. LCA 7 (1) pp. 39-46.

[16] IVN, Germany. http://www.naturtextil.com/indexblau.ssi[17] SKAL, the Netherlands. http://www.skal.com[18] Good Environmental Choice, Sweden. http://www.snf.se/bmv/index.cfm[19] Pesticide Action Network (PAN). http://www.pan-uk.org/pestnews/pn28/

pn28p23.htm[20] The Organic Trade Association (OTA). http://www.ota.com/organic/environ-

ment/cotton_environment.html[21] Genialt 4/2002, Norwegian journal[22] BioTIK - biotechnology and ethics - a multi-ministerial project in Denmark.

www.Biotik.dk.[23] EPA, Best Management Practices for Pollution Prevention in the Textile In-

dustry, 1996 & pers. komm.[24] Commission decision 2002/371/EC1 of 15 May 2002 concerning the ecola-

belling criteria for the awarding of the European Union's ecolabel for textile products and changes to decision 1999/178/EC.

[25] Expert Meeting on Sustainable Public Procurement, Copenhagen, Den-mark, 2-3 December 2002.

[26] KESKO’s Control system for ethical quality.[27] H&M Code of Conduct[28] Lindex Code of Conduct for suppliers [29] Commission decision 2002/231/EC of 18 March 2002 establishing revised

ecological criteria for the award of the Community ecolabel to footwear and amending decision 1999/179/EC.

[30] ”The ecolabelling of furniture and fitments, 11 September 1998. Pro-posal 1.0 for requirements as to leather in the criteria document”, and the associated background document.

1 EFTL133, 18.05.2002, p. 29.