AEAT in Confidence AEAT/ENV/R/1460 ANEC2003/ENV/011 The Suitability of Eco-label Criteria to Derive Environmental Baseline Requirements Applicable to all Products on the Market
A report produced for ANEC
Phil Dolley, Louise Oldman & Jim Poll
May 2003
AEAT in Confidence AEAT in Confidence AEAT/ENV/R/1460 ANEC2003/ENV/011 The Suitability of Eco-label Criteria to Derive Environmental Baseline Requirements Applicable to all Products on the Market
Acknowledgements
With special thanks to the following people who provided valuable input to this study:
Kristian Dammand Nielsen, Miljømærkesekretariatet/Ecolabelling Denmark Kerstin Sahlen, SIS Miljömärkning AB / SIS Ecolabelling Dr. Tony Sagar, British Textile Technology Group (BTTG) NORMAN FALLA, THE PAINT RESEARCH ASSOCIATION
May 2003
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Title The Suitability of Eco-label Criteria to Derive Environmental Baseline Requirements Applicable to all Products on the Market
Customer ANEC - Dr Franz Fiala (Project Supervisor)
Customer ANEC2002/R&T/ENV/001 reference
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Report number AEAT/ENV/R/1460
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Author Louise Oldman & Jim Poll
Reviewed by Louise Oldman Approved by Phil Dolley
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Executive Summary
Ecolabel schemes set product related performance criteria at a high level so that typically only a limited percentage of products on the market can comply. Nonetheless, the process of establishing an ecolabel requires a wealth of information to be considered such that the broader spectrum of product performance can be identified. Access to such information is key to devising refined performance requirements.
With this background in mind, the possibility exists for using ecolabels to help identify product minimum performance standards. If such standards can be identified and agreed, then the further possibility is that they can be used in the context of IPP to develop minimum product specific requirements.
This study assessed the use of ecolabel criteria for establishing such requirements.
There are 13 ecolabel schemes in Europe covering some 240 product groups. These include the following product areas:
· Electrical/electronic · Cleaning products · Paper products · Garden and household products · Textiles · Items used in offices · Services and tourism.
In this exploratory study devised to determine the suitability of using ecolabel criteria to determine minimum product requirements, it was necessary to select a much smaller but representative cross-section of products for assessment. Ultimately ANEC's objective was for five product groups to be studied. As a result it was necessary to filter product groups by:
· Preferentially opting for products covered by the EU ecolabel scheme the development of which involves a wide range of stakeholder consultation, which aims to incorporate specific requirements (environmental or political) from EU Member States. In other words, a degree of consensus exists across Europe. · Selecting products where criteria have also been set by national ecolabel schemes and for which there have been a number of applicants. Again, the reasoning being that for such products one can surmise a degree of stakeholder consensus regarding the environmental impacts. · Eliminating criteria in which production related requirements prevail. The issue here concerns potential trade barriers. · Requiring that the criteria for a product should contain a sufficient number of specific environmental criteria so that even after elimination of some of those (e.g. production related) sufficient criteria covering a range of different issues remain for a minimum baseline to be developed.
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As a result of applying these filters the following five product groups were selected and approved by the ANEC project supervisor:
· Dishwashers · Vacuum cleaners · Detergents for dishwashers · Paints and varnishes · Textiles.
A detailed review of EU ecolabel requirements and background data on the current environmental performance for each of the five product groups allowed outline minimum requirements to be identified for each.
This report presents the work as undertaken, detailing the method adopted and derivation of the baseline requirements.
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CONTENTS
1 INTRODUCTION 1 2 PHASE 1: IDENTIFICATION OF PRODUCT GROUPS 2 3 OPPORTUNITIES AND ISSUES WITH USING ECOLABEL CRITERIA TO DEVELOP STANDARDS 5 3.1 ELECTRICAL AND ELECTRONIC PRODUCTS ...... 5 3.2 CLEANING PRODUCTS ...... 7 3.3 PAPER PRODUCTS...... 8 3.4 PAINTS AND VARNISHES ...... 9 3.5 TEXTILES, MATTRESSES AND FOOTWEAR ...... 10 3.6 SOIL IMPROVERS ...... 10 4 IDENTIFICATION OF FIVE SELECTED PRODUCTS 11 5 PHASE 2: DEVELOPMENT OF ENVIRONMENTAL BASELINE REQUIREMENTS 13 5.1 DISHWASHERS ...... 13 5.1.1 LIFE CYCLE CONSIDERATIONS ...... 14 5.1.2 KEY ENVIRONMENTAL CHARACTERISTICS OF DISHWASHERS ...... 15 5.1.3 OTHE R ISSUES...... 18 5.1.4 OPPORTUNITIES FOR ESTABLISHING ENVIRONMENTAL STANDARDS FOR DI SHWASHERS.... 18 5.2 DETERGENTS FOR DISHWASHERS...... 20 5.2.1 LIFE CYCLE CONSIDERATIONS ...... 20 5.2.2 KEY ENVIRONMENTAL CHARACTERISTICS OF DETERGENTS FOR DISHWASHERS...... 21 5.3 VACUUM CLEANERS...... 26 5.3.1 LIFE CYCLE CONSIDERATIONS ...... 27 5.3.2 KEY ENVIRONMENTAL CHARACTERISTICS OF VACUUM CLEANERS...... 27 5.3.3 OPPORTUNITIES FOR ESTABLISHING ENVIRONMENTAL STANDARDS FOR VACUUM CLEANERS 30 5.4 INDOOR PAINTS & VARNISHES ...... 31 5.4.1 LIFE CYCLE CONSIDERATIONS ...... 32 5.4.2 KEY ENVIRONMENTAL CHARACTERISTICS OF INDOOR PAINTS & VARNISHES 34 5.4.3 OPPORTUNITIES FOR ESTABLISHING ENVIRONMENTAL STANDARDS FOR INDOOR PAINTS & VARNISHES...... 37 5.5 TEXTILES...... 39 5.5.1 LIFE CYCLE CONSIDERATIONS ...... 40 5.5.2 KEY ENVIRONMENTAL CHARACTERISTICS OF TEXTILE S ...... 42 5.5.3 DIVERSITY OF TEXTILES...... 47 6 CONCLUSIONS 50
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Appendices
APPENDIX 1 Chemicals with potential for negative effects on the environment (Textiles)
APPENDIX 2 Overview of European Ecolabel Schemes
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1 Introduction
The European Commission has instigated a discussion on Integrated Product Policy (IPP) aimed at the reduction of environmental burdens by taking into account all stages of the life cycle of a product. A green paper on IPP has been published in order to launch a public discussion. So far, there has been limited development of practical measures to implement the general principles. It would be helpful if clear-cut requirements could be embodied in European standards. As a consequence, the issues of establishing environmental baseline requirements need to be addressed.
Existing eco-label criteria may provide the foundation for addressing this issue. Research and data collected over the past ten years has enabled criteria (often with specific compliance values) to be set for a range of products, commending those with significantly reduced environmental impacts (those products normally fall in the top 5- 25% of their group). However, although eco-label criteria provide a method for identifying the products with reduced environmental impact, the overall impact of a product group can be reduced if those products with the greatest environmental impact are removed from the market. This means that a review of current eco-label criteria, and the opportunities and issues in using them is needed in order to identify how they may provide the foundations for establishing environmental standards. Consequently, ANEC have commissioned a study, to assess these issues.
The work consisted of two phases. The first phase identified five product groups for which ecolabel criteria could be used to derive general product requirements. Phase 2 then developed product environmental specifications for each of these products.
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2 PHASE 1: Identification of product groups
There are a large number of different 'eco-labelling' schemes in operation around the world, all with the purpose of guaranteeing to consumers that they are selecting products that are environmentally more sound than an equivalent product that does not have the label. Within Europe, there are 13 ecolabel schemes:
· The European Union scheme · 7 national schemes in current EU Member States · 5 national schemes in accession countries.
Some of these ecolabel schemes, such as the German Blue Angel, have been established for over 20 years, and have set criteria for about 100 products. Further schemes in Europe, include the Good Environmental Choice, and there are also schemes such as TCO, which set standards for products, which include environmental requirements.
These schemes set criteria for a range of products that can be grouped into the following broad classifications:
· Electrical/electronic · Cleaning products · Paper products · Garden and household products · Textiles · Items used in offices · Services and tourism.
A study being conducted by EU Ecolabel Co-operation and Co-ordination Management Group has identified over 240 different product groups under the National and European eco-labelling schemes. These products, together with the schemes that have set criteria for them, are tabulated in Appendix 2.
Although all of these products could be assessed, the limited time frame and resource for the study meant that it was necessary to filter the number of product groups that could be considered. The two filters used to initially assess the product groups consider the degree of consensus across Europe for specific product groups and their associated criteria as determined by their adoption and/take-up in ecolabel schemes. The filters are as follows;
· EU ecolabel scheme – the development of which involves a wide range of stakeholder consultation which aims to incorporate specific requirements (environmental or political) from EU Member States · Products where criteria have been set by a number of schemes and there have been a number of applicants.
The reasons why the EU eco-label scheme was selected as a filter were because:
· It is selective: it is awarded to products with lower environmental impacts. · It is transparent: the ecological criteria that products must meet are developed with the input of relevant stakeholders such as industry, commerce, environmental and consumer organisations and trade unions. Furthermore,
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consumers can be sure that a product/service that displays the Flower logo has been awarded it by an independent authority with no vested interest in the company. · It works with a multi-criteria approach: the whole life cycle of the product/service is assessed in order to study all its potential environmental impacts. · It has a European dimension: Eco-labelled products are typically marketed across the Member States, as well as Norway, Iceland and Liechtenstein. Some producers from accession countries have already been awarded the Flower logo.
The latter is particularly important since ANEC represents and defends consumer interests in the process of European standardisation and certification.
The first filter is the EU ecolabelling scheme. This currently covers 19 product groups, and the main product families were criteria have been set are:
Product family Number of product groups Electrical and electronic 7 Cleaning products 4 Paper products 2
The second filter is products where criteria have been set by more than one scheme and there are a number of applicants. Considering the other national schemes across Europe from the table contained in Appendix 1, the pool of products for which ecolabels exist is much expanded. Looking at the table, if one considers the number of schemes covering a given product group to be indicative of a product's appeal for ecolabelling, then one can identify additional products for consideration in this study.
Product group EU criteria Number of other schemes Textiles Yes 5 Paints and varnishes Yes 7 Soil Improvers Yes 3 Chain-saw lubricants No 5
A further filter, which was used, was the availability of the information on a product group. Although the required information is readily available from reports produced to accompany the development or revision of EU ecolabel criteria, it is unlikely that the information required is readily available for other product groups. The use of this filter meant that a number of potential product groups, such as rubbish bags, were not selected. Chain-saw lubricants were also not selected for this reason and also because it is a product which is only used by a very small proportion of European consumers.
A further product group that was considered, but has not been taken any further, was floor coverings. The issue here is that there are stark differences between the products favoured by different Member States. Broadly speaking, the market in the Southern States is predominantly for stone and tiles whilst in Northern States the market is predominantly for carpeting, wood and man-made coverings.
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Criterion
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The use of these filtering criteria has resulted in 20 products being identified for further consideration. These cover 6 product areas:
· Electrical and electronic products · Paper products · Cleaning products · Paints and varnishes · Textiles · Soil improvers.
Table 1 lists the types of ecolabel criteria that have been set in each of these product areas.
Table 1: List of types of criteria for EU ecolabel product groups
Product Group Electrical Paper Cleaning Paints and Textiles Soil and products products varnishes Improvers electronic products Energy in stand-by x Energy in use x Energy in manufacture x x Water in use x Emissions to water x x x Water in manufacture x Emissions to air X x x Residues in final x x product Noise X Flame retardants X x Hazardous substances X x x x x x Biodegradability x Critical dilution volume x VOCs x Other chemicals X x x x x x Materials x x x Health & safety X x x Takeback & recycling X x Design X Waste x x Packaging X x Lifetime X Performance X x x x x x User information X x x x Labelling of x ingredients Environmental X declaration
This table shows that there are 26 types of criteria. Only three types of criteria (hazardous substances, other chemicals, and performance) are set for all of these product areas. Although some of the other criteria are specific to certain product areas, the number ranges from six (soil improvers) to 17 for electrical and electronic products.
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3 Opportunities and issues with using ecolabel criteria to develop standards
This chapter of the report discusses the ecolabel criteria, which have been set for each of the product groups, identified in the previous chapter.
3.1 ELECTRICAL AND ELECTRONIC PRODUCTS
Life cycle considerations show that the major environmental impact for any electrical or electronic product is its energy consumption during use. Other criteria cover lifetime (in order to reduce the use of resources in manufacture) and performance, and water consumption criteria are set for appliances, which use water. However, as can be seen from Table 2, although 17 types of criteria are set for electrical and electronic products, only 3 criteria; flame retardants, lifetime and user information, are set for all 8 product groups.
Table 2: Criteria set for electrical and electronic products
Washing Fridges TV Dish Personal Portable Light Vacuum Machines and washers Computers Computers bulbs Cleaners freezers Energy in x x x stand-by Energy in use x X x x x x Water in use x x Emissions to x x water Emissions to x air Noise x X x x x Flame x X x x x x x x retardants Hazardous x x x substances Other X chemicals Health & x x safety Takeback & x X x x x x x recycling Design x x x x Packaging x Lifetime x X x x x x x x Performance x x x x User x X x x x x X x information Environmental x x x declaration
Although energy consumption is the key environmental impact, Table 2 shows that whilst electrical products set a criterion based on use (the energy label), electronic products set a criterion based on stand-by. The Energy Star program sets stand-by consumptions for
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AEAT in Confidence AEAT/ENV/R/1460 a range of electronic products, and there are also voluntary agreements1 to remove the least energy efficient white goods from the market. However, many voluntary agreements are business driven and do not set particularly ambitious targets. In addition, the energy label does not set a minimum requirement (i.e. maximum allowable energy consumption).
Some ecolabel schemes have set stand-by criteria for computers based on the Energy Star requirements, but the EU ecolabel criteria are based on a Intel and Microsoft standard which sets lower levels than that currently required by the Energy Star. Consequently, virtually all-new computers should be able to meet the EU ecolabel requirement.
Water consumption, and discharge of unused detergent are clearly important environmental issues for washing machines and dishwashers. However, more energy efficient products use less water, and the high level of cleaning performance required by consumers means that very little detergent is discharged unused.
Ecolabel criteria for hazardous substances, other chemicals, and health and safety requirements are set for some product groups. These cover:
· Use of mercury in fluorescent light bulbs · Use of mercury in liquid crystal displays (LCDs) used with computers · Use of chemicals in fridges and freezers which have either ozone depleting potential or a high global warming potential.
However, the ecolabel does set lower requirements than those set by either current or proposed2 legislation.
Noise is becoming more of an environmental issue; ecolabel criteria are usually set at a level, which 50% of equipment can meet because of the cost implications for reducing noise emissions.
Packaging represents a very small percentage of the total environmental impact for these products, and this is why no criterion is set apart from lamps.
Most other areas in which ecolabel criteria are set are now effectively covered by either current or proposed legislation. For example, Directives cover lifetime on guarantees. However, there are two additional areas where ecolabel requirements could be considered for setting standards:
· Marking of polymers above a certain weight with the polymer used in its construction in order to assist with recycling · Inclusion of risk (R) phrases for flame-retardants, as potential issues have been identified for alternatives to those listed in the Directive on restrictions on hazardous substances.
The wide range of criteria used for electrical and electronic products suggests that although they could be used to develop standards for the individual product groups, it would be more difficult to develop generic criteria, which covered all electrical and
1 For example – Voluntary Commitment on reducing energy consumption of domestic washing machines. CECED, April 1996 2 For example, the Restrictions on Hazardous Substances Directive sets a maximum level of 5 mg of mercury in a compact fluorescent lamp (CFL), but the ecolabel requirement is a maximum of 4 mg.
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AEAT in Confidence AEAT/ENV/R/1460 electronic products. However, generic criteria could be developed for sub-sets such as electronic products.
3.2 CLEANING PRODUCTS
The key ecolabel criteria for cleaning products are biodegradability, limitation of substances harmful to the aquatic environment, and fitness for use. Other criteria cover packaging, safety of the product, and instructions for correct environmental use. Table 3 shows that most of the types of criteria set for cleaning products, apply to all the product groups being considered.
Table 3: Criteria set for cleaning products
All Purpose Hand Detergents Laundry Nordic Good Cleaners Dishwashing for Detergents Swan Environmental Detergents Dishwashers Shampoo Choice Shampoo Emissions to x x x x x x water Residues in final x product Hazardous x x x x x x Substances Biodegradability x x x x x x Critical Dilution x x x x Volume VOCs x Other Chemicals x x x x x x Take Back & x Recycling Materials x x Health & Safety x Packaging x x x x x x Performance x x x x x x User information x x x x x x Labelling of x x x x x x ingredients
The criteria for laundry detergents have been set to encourage the use of compact powders. Consequently any standard based on these criteria is unlikely to be suitable for all types of laundry detergents.
Both aerobic and anaerobic biodegradability are important for these products, an area well covered by legislation. Critical dilution volume is a key issue for cleaning and detergent products, but no criterion is set in this area for shampoos.
Although all the products set a criterion on hazardous substances, and this can be based on R phrases, not all chemicals deemed to be hazardous (chlorine containing compounds such as bleaches) are covered by R phrases. Member States have different views about these compounds, and some would like to see them excluded. Consequently the agreed compromise is to use the R31 classification, which restricts the use of compounds that can emit toxic substances when mixed with other agents.
Criteria on other chemicals cover phosphates, phosphonates, dyes, fragrances and sensitising substances. Some Member States would prefer exclusions, rather than limits to be set.
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Performance of these products is a key issue for consumers, as they require assurance that the performance of an ecolabelled product has not been compromised in order to improve its environmental performance.
Criteria on packaging limit the amount of packaging material per unit volume of product, and set requirements for minimum recycled content.
The other criteria cover health and safety, user information, and labelling of ingredients. Clearly, what might be considered to be a health and safety issue for consumers in one Member State may not be an issue in other Member States. User information covers aspects such as how much detergent to use, which is typically done for all detergents.
3.3 PAPER PRODUCTS
The main ecolabel criteria for paper products are the use of recycled fibres or virgin fibres from sustainably managed forests, energy use during manufacture, and emissions to both air and water during manufacture. Table 4 shows that most of the criteria apply to all the products being considered, whilst the Blue Angel scheme does not cover energy use or emissions during manufacture.
Table 4: Criteria set for paper products
EU EU Blue Nordic Nordic Tissue Copying Angel Swan Swan Paper Paper Paper Printing Tissue Paper Paper Energy in x x x x manufacture Emissions to water x x x x Emissions to air x x x x Hazardous substances x x x x x Other chemicals x x x x x Materials x x x x x Health & safety x x x Waste x x x x Packaging x Performance x x x
A key issue for paper products is the source of the fibre. Consumers are well aware of the phrase “from sustainable forests”, and the sources of fibres are marked on many paper products, but there are different views on the definition of a sustainable forest.
The EU and Nordic schemes set criteria on manufacturing including, emissions to air and water as covered by legislation. Energy use considers both integrated and non- integrated mills.
The criteria on hazardous substances prohibit the use of chlorine gas, which is typically no longer used. They also limit the use of chemicals such as preservatives, which have been identified as problematic for the environment.
Packaging represents a very small percentage of the overall environmental impact of paper products.
Performance of any product is an important issue for consumers. Although performance criteria are set, there is no suitable test against which performance can be gauged.
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3.4 PAINTS AND VARNISHES
The main ecolabel criteria for paints and varnishes cover the levels of volatile organic compounds (VOCs), restrictions on the use of heavy metals and substances harmful for the environment and health, and performance of the product in terms of a minimum hiding power for paints and resistance to water for varnishes. Other criteria cover production, volatile aromatic hydrocarbons, and user instructions. Table 5 shows that most of these criteria have been applied by the 4 ecolabel schemes, which have set criteria for paints and varnishes. The Nordic Swan has not set criteria because the EU criteria cover all of their requirements.
Table 5: Criteria set for paints and varnishes
EU German Dutch Austrian Ecolabel Blue Angel Decorative Paints Paints Emissions to water x x Emissions to air x x (for paints) Residues in final product x x (for varnishes) Hazardous substances x x x x VOC’s x x x x Takeback & recycling x (of packaging) Waste x x (for paints) Performance x x x x Labelling of Ingredients x User information x x x x Environmental x x declaration
The two main concerns for consumers are emissions during use and performance (e.g. covering power). New paint formulations, which are claimed to be odour free, are available, and manufacturers can use standard tests to ensure that paints provide a satisfactory level of performance.
The ecolabel criteria limit the use of certain chemicals and heavy metals. A number of criteria cover manufacture, such as limiting sulphur dioxide emissions during the production of titanium dioxide, as controlled by legislation.
There have been over 25 applications for the EU scheme, and it is the second most popular product group (after textiles). Manufacturers have reported that the ecolabelled products are selling well.
All paint and varnish products contain information on use and the procedure for cleaning brushes.
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3.5 TEXTILES, MATTRESSES AND FOOTWEAR
The main ecolabel criteria for textiles, mattresses and footwear cover hazardous substances and performance. Other criteria exist specifically for these individual product groups and cover limiting water and air pollution during production as well as packaging. Table 6 shows these criteria.
Table 6: Criteria set for textiles, mattresses and footwear
EU Ecolabel EU Ecolabel EU Ecolabel Scheme for Scheme for Bed Scheme for Textiles Mattresses Footwear
Energy in manufacture x x Water in manufacture x x Residues in final product x Flame retardants x x Hazardous substances x x x VOC’c x x Other Chemicals x x x Materials x x Packaging x Performance x x x User information x
Textiles is the most popular EU product group with over 35 applications, but as the criteria cover a wide range of fabric types it would be very difficult to set general standards for all textiles. There would be fewer issues in developing standards for specific types of textiles such as cotton products.
The materials criterion for footwear prohibits the use of virgin PVC but allows the use of recycled PVC.
There are standard tests for assessing the performance of all 3 types of products.
3.6 SOIL IMPROVERS
The main ecolabel criteria for soil improvers cover the guaranteed minimum content of organic matters, minimisation of various nuisances such as odour and weeds as well as user instructions. Table 7 shows these criteria.
Table 7: Criteria set for soil improvers EU Ecolabel Scheme Residues in final product x Hazardous substances x Other Chemicals x Health & safety x Performance x User information x
The criteria cover the same areas as those covered by other standards on composts and soil improvers. There are 7 licences for the EU scheme, and 15 licences for the scheme in Poland.
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4 Identification of five selected products
As 20 potential products had been identified, two further filters were used in order to assist the identification of the five products for which environmental specifications were to be developed:
· The elimination of a criteria in which production related requirements (which would be viewed as trade barrier if they were contained in general product standards/regulations) prevail · The criteria for a product should contain a sufficient number of specific environmental criteria so that even after elimination of some of those (e.g. production related or otherwise unsuitable criteria) enough criteria covering a range of different issues remain for the preparation of a standard.
The use of these two additional filters meant that:
· Paper products could be eliminated because of the strong emphasis of production criteria (sustainable wood management, emissions from paper production) · Soil improvers are not suitable because only a few environmental criteria (mainly metals and some other chemicals) are covered. In addition, the criteria apply only to soil improvers produced from waste materials, and it is therefore difficult to use the criteria to produce guidelines for all soil improvers.
Consequently, after elimination of these two product groups from the list contained in table 1, the following groups remained:
· Electrical and electronic products · Cleaning products · Paints and varnishes · Textiles
Two electrical products were selected. The most suitable electrical products are:
· Dishwashers · Vacuum cleaners.
Dishwashers are a “traditional” eco-label product, which has a broad range of criteria, an existing database, and there is also an EU energy label (which does not establish maximum energy consumption requirements). By comparison, criteria have only recently been adopted for vacuum cleaners, and thus both baseline requirements and revisions of the eco-label criteria could be developed simultaneously.
Other products of this category seem to be less suited either because there are fewer criteria or the eco-labelling criteria are due for revision in due course. For instance, energy requirements for computers and personal computers can be fulfilled by most products on the market. Washing machines could be an alternative to dishwashers, but dishwashers appear to have more pronounced environmental performance differences.
The most suitable cleaning product is detergents for dishwashers, particularly as dishwashers have been selected as one of the two electrical products. There are no EU ecolabel criteria for shampoos, and thus it would be difficult to obtain the information
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AEAT in Confidence AEAT/ENV/R/1460 which would be required in order to set requirements. The criteria for laundry detergents are set to promote compact powders and may therefore not be suitable for all types of detergents.
For paints and varnishes, there are no criteria for specific products, and thus this group can be selected.
For textiles, the criteria are very comprehensive and contain fibre specific requirements as well as requirements which are non-specific for a certain fibre type. Even after elimination of production specific provisions a sufficient number of product related criteria remain and can be used to define general and fibre specific baseline criteria. The criteria for mattresses contain numerous references to the textiles criteria, and the criteria for footwear are too limited once production related requirements and the azo-dyes requirements (a European regulation on this subject was adopted in July 2002) are eliminated.
Hence, the following five products were selected for the second phase of the study:
· Dishwashers · Vacuum cleaners · Detergents for dishwashers · Paints and varnishes · Textiles
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5 PHASE 2: Development of Environmental Baseline Requirements
5.1 DISHWASHERS
In the EU ecolabel scheme the product group is defined as:
· "Electric mains-operated household dishwashers sold to the general public. Appliances that may also use other energy sources such as batteries or have no internal heat source are not covered".
It should be noted that industrial dishwashers, as are found in restaurants, hospitals etc, are different in terms of their energy consumption, the detergents they use and operation cycles etc, and thus the two types cannot be described by the same parameters.
Although sales of other large household appliances, such as washing machines and refrigerators, remain relatively constant (the market is now saturated) the annual sales of dishwashers have risen significantly since the early 1990s. The overall market saturation for dishwashers in the EU is 40%, and is expected to increase as many consumers are buying their first dishwasher rather than replacing their old one.
There are three generic types of dishwasher:
· Large – over 10 place settings (usually 12 place settings) · Medium – 6 to 9 place settings (usually 8 place settings) · Small – up to 5 place settings (usually 4 place settings).
About 90% of dishwashers sold in the EU have 12 place settings. Whilst small dishwashers are becoming more popular, they represent less than 2% of overall dishwasher sales.
Dishwashers can be sold as either free-standing units or as units for building into kitchen cabinets. Currently, sales of each type are about 50:50 in the EU.
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5.1.1 LIFE CYCLE CONSIDERATIONS A life-cycle analysis (LCA) of a dishwasher was conducted3 when the first EU ecolabel criteria for dishwashers were developed in 1992. This showed that the percentage contributions of the life-cycle stages to the total environmental impact of a 'typical' dishwasher were as follows:
Table 5.1a: Environmental Impact at various life-cycle stages
Production Distribution Use Disposal Total Energy 2% <1% 98% <1% 100% Critical air volume 2% <1% 97% <1% 100% Critical water volume 1% 1% 97% 1% 100% Solid waste 4% 2% 88% 6% 100% Water consumption 3% <1% 97% <1% 100% The table shows that the overall environmental impact of a dishwasher is dominated by the use phase, and that energy and water consumption during use are significant environmental factors. Consequently, the EU ecolabel criteria for dishwashers aim to promote:
· A reduction of environmental damage or risks related to the use of energy (global warming, acidification, depletion of non-renewable resources) by reducing energy consumption · A reduction of environmental damage related to the use of natural resources by reducing water consumption.
The revision of the EU ecolabel criteria in 1998 also introduced a key requirement for reducing water pollution by preventing unnecessary detergent consumption.
Developments in dishwasher technology have enabled manufacturers to reduce the environmental impacts4 of dishwashers over the last 40 years. For example, the table 5.1b (which is based on EU data) shows that energy consumption has reduced by over 60% during this period.
Table 5.1b: Reduction in Energy Consumption from 1965 to 2000
1965 1980 1990 2000 Energy (KWh/cycle) 3.1 2.6 1.5 1.1 Water (litres/cycle) 60 45 20 14 Noise (dB) 70 65 60 53
A recent report5 estimates a realistic consumption of 0.95 KWh/cycle for large dishwashers by 2010. The report also identifies an optimistic consumption of 0.78 KWh/cycle by 2010, but achievement of this optimistic level will depend on suitable developments in detergents that operate at lower wash temperatures.
Phase out of dishwashers with a low energy efficiency CECED has introduced a Voluntary Agreement6 on dishwashers, which covers the period January 2000 to December 2004. The market share for participants in the agreement represents more than 90% of dishwasher sales in the EU. The main part of the
3 Ecolabelling criteria for dishwashers. PA Consulting Group, May 1992 4 Data supplied to AEA Technology by VHK during the revision of the EU ecolabel criteria in 2001 5 Energy consumption of domestic appliances in European households. Report by CECED, 2002 6 Voluntary commitment on reducing energy consumption of household dishwashers. CECED, 19 November 1999
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AEAT in Confidence AEAT/ENV/R/1460 agreement is to remove less energy efficient dishwashers from the EU market. Participants will be required to:
· Stop producing or importing dishwashers which have an energy class E, F or G for large dishwashers, or energy class F and G for medium/small dishwashers by 31 December 2000 · Stop producing or importing dishwashers, which have an energy class of D for large dishwashers or E for medium/small dishwashers by 31 December 2003.
Participants will also be required to:
· Provide clear instructions to consumers on how to minimise the environmental impact of the use of the dishwasher · Improve the reproducibility of test methods and measurement standards (EN 50242) · Develop methods for further reducing the energy consumption of dishwashers through introducing enzyme detergent programmes and reducing the washing temperature for single temperature dishwashers from 65°C to 50/55 °C. However, the voluntary agreement does not cover cleaning performance, even though this is an important parameter for consumers. This is because industry considers that the driver for improved cleaning performance will result from competition between manufacturers.
The CECED agreement only covers those manufacturers who are party to the agreement. However, the proposed End Use Equipment (EuE) Directive will set requirements on energy efficiency which all manufacturers will have to meet, and may well set minimum levels which are higher than those set by the current voluntary agreement.
5.1.2 KEY ENVIRONMENTAL CHARACTERISTICS OF DISHWASHERS
5.1.2.1 ENERGY The following tables7 show the energy efficiency of dishwashers on sale in the year 2000.
Table 5.1c: Energy Efficiency of Dishwashers
Energy class Percent of dishwashers on sale A 31% B 24% C 28% D 12% E 5% F - G - Total 100%
7 All data presented in this section is based on information in the ELDA database of dishwashers on sale in Denmark in the year 2000. This information was used in the revision of the ecolabel criteria in 2001 because data from the energy label was not available, and because the data is considered to be representative of dishwashers on sale in all EU Member States.
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Table 5.1d: Energy Efficiency of Dishwashers
Energy Size of dishwasher consumption Small Medium Large A - 10% 38% B - 10% 23% C 33% 10% 28% D or lower 67% 70% 11% Total 100% 100% 100%
These tables show that there were no dishwashers with an F or G energy rating on the market in the year 2000, and that dishwashers with a D or E energy rating represented less than 20% of dishwashers on the market.
Although a significant percentage of large dishwashers can achieve an A rating, the majority of both small and medium dishwashers have an energy rating of D or lower. This is because the energy label formula for dishwashers makes it more difficult for small dishwashers to achieve an A energy rating. Consequently, manufacturers have tended to concentrate on reducing the energy consumption of large dishwashers, particularly as these represent about 90% of the overall market. These factors are recognised in the CECED agreement, which sets lower energy rating requirements for smaller dishwashers.
As a significant proportion of large dishwashers achieve an A energy rating, the ecolabel sets an energy efficiency level for large dishwashers which is 10% better than the A energy rating. This approach was adopted to provide an incentive to manufacturers to improve energy efficiency (and it also followed the similar approach adopted for washing machines). The ecolabel also set requirements of an A energy efficiency for medium dishwashers and A or B for small dishwashers.
As energy consumption during use is the major environmental impact for a dishwasher, this is clearly an area where a baseline requirement should be set. We recommend that minimum energy efficiencies are established as:
· Large dishwashers – between the current B and C levels set by the energy label · Small and medium dishwashers – between the current C and D levels set by the energy label.
The energy consumption of a dishwasher can be reduced if detergents that operate at 55 °C, rather than 65 °C are used. Consequently, a requirement that all dishwashers must be able to achieve a satisfactory level of cleaning performance when used with a detergent designed to operate at 55 °C could be considered.
5.1.2.2 WATER CONSUMPTION The following table8 presents information on water consumption (litres/cycle) for 12- place setting dishwashers with different energy efficiencies. It shows that there is a clear correlation between water consumption and energy use; i.e. A energy rated dishwashers use less water than those with a C energy rating. This is because if more water is used then more energy is required to heat it to a given temperature.
8 ELDA 2000
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Table 5.1e: Water Consumption
<15 15-17 >17 Total litres/cycle litres/cycle litres/cycle A 68% 32% - 100% B 14% 59% 27% 100% C - 71% 29% 100% D or worse - 7% 93% 100%
The current EU ecolabel criterion for dishwashers sets a maximum water consumption of 17 litres/cycle for a dishwasher with 12 place settings, and the table shows that all dishwashers with an A energy rating can meet this target. Consequently, large dishwashers should have a maximum water consumption of 17 litres/cycle.
5.1.2.3 CLEANING PERFORMANCE The following table9 shows that all dishwashers with an energy rating of C or better had a cleaning performance of either A or B, and so would meet the current EU ecolabel criterion on cleaning performance.
Table 5.1f: Cleaning Performance
Energy Cleaning performance efficiency A or B C or D Total A 100% - 100% B 100% - 100% C 100% - 100% D or worse 60% 40% 100%
Although dishwashers with an A energy rating can achieve an A rating for both cleaning and drying performance, the long cycle times may be unacceptable to some consumers. A further issue is that as dishwashers become more energy efficient, they may not be able to achieve an A rating for both cleaning and drying performance. Consequently, a minimum cleaning performance of B should be considered.
5.1.2.4 NOISE Noise is an issue, which has increased in importance on the environmental agenda over the past few years. Some Member States, such as Germany, have set requirements on noise for a number of products (lawn mowers and leaf blowers being examples). CECED have recently introduced a voluntary agreement10 for reporting noise levels.
The noise levels measured for built-in dishwashers are lower than those for freestanding dishwashers. This is because the Energy Label test method (EN 50246) requires built-in dishwashers to be tested inside a suitable cabinet thus mimicking in-service use.
The current ecolabel criteria set levels, which should not exceed 50 dB(A) for built-in dishwashers and 53 dB(A) for freestanding dishwashers. When set, these levels could be achieved by about 70% of dishwashers. However, data indicates that only about 10% of dishwashers had noise levels which were 2 dB(A) higher than these requirements; i.e. more than 52 dB(A) for built-in dishwashers and more than 55 dB(A) for freestanding dishwashers. Consequently, a maximum noise level equivalent to that set by the EU ecolabel could be considered.
9 ELDA 2000 10 Agreement on a common basis for noise declaration. CECED, 12 March 2002
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5.1.3 OTHER ISSUES The remaining ecolabel criteria for dishwashers cover take-back and recycling, lifetime, design and instructions provided to the user. Many of the requirements in the WEEE and ROHS Directives (such as those on flame retardants), which manufacturers will have to meet, are almost identical to the current take-back and recycling criterion.
However, an area not covered in the two directives, but included in the ecolabel, is the requirement that plastic parts which are heavier than 50 gram shall have a permanent marking identifying the material, in conformity with ISO 11469. This ecolabel requirement could be considered for inclusion in a baseline environmental standard, and could be extended to cover all electrical and electronic products.
Whether it is justified environmentally to extend a dishwasher's lifetime to, say, 15 years or more is unclear. The ecolabel assumes that the concept of lifetime extension is environmentally sound for such appliances. As such it requires spare parts to be available for an extended period thus ensuring that a dishwasher can be repaired and put back into service. Given that one would expect dishwasher environmental performance eg energy consumption, to improve over time, and that the key impact of a dishwasher is energy consumption, there is the possibility that product replacement with an up to date, energy efficient appliance is environmentally preferable. We are not aware of any research that explores this issue. Further work is necessary to explore the life cycle issues.
The criterion on user instructions provides instructions to the user in a number of areas. Some of these could be considered for inclusion in a baseline environmental standard, particularly those relating to use of detergents, which work at lower temperatures than 65 °C, using a full load, and installing the dishwasher in a way, which minimises noise. The most appropriate method for communicating these instructions to consumers could also be considered; for example, the use of clear simple language and pictures, together with a statement that using the dishwasher in accordance with the instructions provided will reduce operating costs whilst providing good cleaning results.
5.1.4 OPPORTUNITIES FOR ESTABLISHING ENVIRONMENTAL STANDARDS FOR DISHWASHERS A wide range of criteria are covered in the ecolabel for dishwashers, the following table outlines the main differences between the most environmentally acceptable dishwashers and the least environmentally acceptable dishwashers.
Table 5.1g: Differences between most and least environmentally acceptable environmental dishwashers
Most environmentally Least environmentally acceptable acceptable Energy consumption Low – Energy label rating High – Energy label of A or B rating of E, F or G Water consumption Low - < 15 litres per High - > 20 litres per cycle cycle Noise Less than 53 dBA for a More than 54 dBA for a free-standing dishwasher free-standing dishwasher
Cleaning performance is clearly an important issue for consumers, and the use of the correct quantity of a suitable detergent will enable a high level cleaning performance to be obtained whilst minimising the level of water pollution. Consequently, limits or requirements could be considered in the following areas outlined in table 5.1h:
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Table 5.1h: Possible areas for establishing baseline requirements
Requirement Justification Lower energy consumption · Reduction in global warming · Reduced resource use · Important issue for consumers Lower water consumption · Reduced resource use Noise · Some Member States have already set requirements on noise for certain products Acceptable cleaning performance · Important issue for consumers Clear instructions regarding dishwasher · Reduces energy consumption of temperature and correct amount of dishwasher detergent to use · Reduces water pollution
Consequently, the following approach, together with the ecolabel criteria that could be used in setting minimum standards are shown in table 5.1i:
Table 5.1i: Ecolabel criteria for setting minimum standards
Issue Approach or ecolabel criterion Energy consumption For large dishwashers, a minimum energy efficiency standard set between Energy Label B and C
For medium and small dishwashers, a minimum energy efficiency standard between Energy label C and D
All dishwashers able to operate at 55 °C Water consumption A maximum level of 17 litres/cycle for large appliances
More information is required for medium and small appliances to enable a standard to be proposed Cleaning performance All dishwashers achieve a minimum of a B rating for cleaning and drying performance Noise Maximum noise levels which are the same as the current EU ecolabel criteria Recycling All plastic parts heavier than 50 grams to have a permanent marking identifying the material in conformity with ISO 11 469 Provision of clear These should be presented in clear and simple instructions on minimising language making use of pictures where appropriate environmental impact and to aid communication. An industry wide standard minimising operating cost for this (and other product groups) would be a sensible way forward.
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5.2 DETERGENTS FOR DISHWASHERS
The first EU ecolabel for detergents for dishwashers was introduced in 1999. The definition of the product group was:
· “All detergents, which are intended to be used exclusively in automatic domestic dishwashers”.
However, as some detergents used in non-domestic locations are very similar to these products, the recent revision changed the definition in order to include them. The current ecolabel definition is:
“All detergents intended for use in automatic domestic dishwashers and all dishwashers operated by professional users that are similar to automatic domestic dishwashers in terms of machine size and usage”.
The main reason for adopting this definition was to enable ecolabelled products to be offered to a wider range of users and thus maximize the potential environmental benefits11.
Annual sales of household dishwashers have risen significantly since the early 1990s. The overall market saturation for dishwashers in the EU is 40%. As this is expected to increase, it will clearly increase the size of the market for dishwasher detergents.
There are four types of product:
· Conventional powders · Liquids · Compact powders · Tablets.
Although very little data on the sales of each type of product have been published since 1994, ecolabel consultation revealed that sales of tablets are increasing. The ecolabel criteria for dishwasher detergents encourage the development and use of compact powders or tablets because these use less resources during manufacture.
5.2.1 LIFE CYCLE CONSIDERATIONS The original ecolabel work conducted in 1997 used a 'streamlined LCA' approach. The most significant impact was considered to be the energy consumption of the dishwashing machine; this overshadows all other energy considerations during the remainder of the detergent's life cycle. Emissions to water are also significant. Consequently the criteria aim to promote:
· The reduction of energy use by promoting low temperature detergents. · The reduction of water pollution by reducing the quantity of detergent used and by limiting the quantity of harmful ingredients · The minimisation of waste production by reducing the amount of primary packaging and promoting its re-usability and/or recyclability
11 It should be noted that commercial dishwashers have different operation characteristics. Typically their operational cycle is shorter so to achieve good washing performance they operate at higher temperatures using a different detergent type.
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In order to achieve this, the types of criteria that have been set are as follows:
Table 5.2a: Typical Criterion Area Criterion Energy consumption in the Product to have a satisfactory cleaning dishwasher performance at 55 °C Quantity of detergent used Total amount of chemicals Water pollution Critical dilution volume Phosphates Non-biodegradable organics (aerobic) Non-biodegradable organics (anaerobic) Phosphonates Restrictions on other chemicals Packaging Maximum weight Minimum recycled content
As there is a wide range of chemical formulations for dishwasher detergents, a scoring matrix is used in order to assess if a detergent meets the requirements on water pollution. This also sets a maximum level for each type of chemical. Such an approach allows detergent manufacturers a degree of flexibility when formulating their products.
5.2.2 KEY ENVIRONMENTAL CHARACTERISTICS OF DETERGENTS FOR DISHWASHERS The Commission is currently considering new legislation (COM (2002) 485), which would set minimum requirements in a number of areas covered by the ecolabel including bio- degradability.
The current position with regards detergent legislation is in a state of flux, however it appears that MEPs are pressing for:
· An exclusion of carcinogenic, mutagenic and reprotoxic (CMR) substances · The Commission to clearly determine the case or otherwise for a phase out of phosphates
Consequently, we suggest that the development of minimum baseline requirements for phosphates, biodegradability and CMR substances is with held until the legislative position becomes clear.
5.2.2.1 OPERATING TEMPERATURE Energy consumption during use of the dishwasher is the largest environmental impact for a dishwasher. Although this has been considerably reduced since 1965, any significant further reduction will require developments in detergents that provide a satisfactory cleaning performance at lower temperatures. A large proportion of dishwashers currently on the market have a lower temperature (55 °C rather than 65 °C) setting. Consequently, the ecolabel sets a performance test, which has to be conducted at 55 °C and requires information on the use of a temperature of 55 °C to be provided on the packaging.
Although detergents, which work at 55 °C are on the market, there are concerns about hygiene at this lower temperature because the water temperature may not be high enough to kill all micro-organisms. This means that stringent chemicals may be required in order to achieve a high level of hygiene. Considering this, the ecolabel criteria were devised so that chlorine bleaches (e.g. sodium hypochlorite) cannot be used (they fail the toxicity dilution criterion). The criteria will allow the use of oxygen bleaches if percarbonate is used in preference to perborate.
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5.2.2.2 PERFORMANCE TEST The initial criteria introduced in 1999, required a satisfactory washing performance at the recommended dosage and at a temperature of 55 °C according to the standard test developed by IKW. During the revision of the criteria, there were concerns that although the IKW test provides a good measure of cleaning performance, some of the requirements for this test were difficult to achieve, particularly if efficient chlorine bleaches could not be included in an ecolabelled product. However, the new criteria still require the standards set by the IKW test to be met, and this can be tested by conducting the dishwasher energy label test (EN 50242) at 55 °C rather than 65 °C.
The ecolabelled dishwasher detergents have all passed the washing performance test.
5.2.2.3 WATER POLLUTION The ecolabel criteria for water pollution are assessed by a scoring matrix, which sets both a maximum level for each chemical considered, and a score that increases as the amount of chemical reduces. In order to meet the ecolabel requirements, the chemicals used in the detergent cannot exceed any of the maximum levels, and the sum of the individual chemical scores must also be higher than a specified amount.
During the development of the revised criteria, information12 was obtained on a limited sample of 30 compact powder and tablet products used in both Northern and Southern Europe. This is shown in Table 1.
Table 5.2b: Chemical content of dishwasher detergents
Requirement Average Range Ecolabel Number of exclusion products hurdle tested which are below the exclusion level Total chemicals (g/wash) 20 18-25 22.5 29 Critical dilution volume (CDV) 337 42-829 200 12 (litres/wash) Phosphates (g/wash) 5 0-15.5 10 24 Non-biodegradable organics 0.32 0-1.1 1 29 (aerobic) (g/wash) Non-biodegradable organics 0.03 0-0.33 0.2 29 (anaerobic) (g/wash)
Twelve of these thirty products would meet the ecolabel requirements.
5.2.2.4 TOTAL CHEMICALS This is the only parameter that assesses the environmental impact of the production of the detergent. Most compact and tablet powders have a dosage of approximately 20 g/wash. Although the ecolabel hurdle of 22.5 g/wash means that only compact or tablet powders can meet the criteria, it does not cover possible overdosing when using compact powders (instructions with tablets specify the required number of tablets). Consequently, the production of dishwasher detergents in tablet form would both minimize resource use and prevent additional water pollution through over-dosing if
12 Revision of ecolabel criteria for detergents for dishwashers. Final report by Eric Svanes Consulting, 24 September 2002.
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AEAT in Confidence AEAT/ENV/R/1460 appropriate instructions are provided to users. This suggests that a maximum total chemical content of 22.5 gm/wash could be a suitable baseline requirement.
5.2.2.5 CRITICAL DILUTION VOLUME (CDV) This is a most important parameter for a detergent. The ecolabel exclusion hurdle was reduced from 250 to 200 during the revision in 2002.
The exclusion level is set at a level, which means that it cannot be met by detergents that contain chlorinated bleach compounds or perborates. This is because of concerns about the formation of AOX compounds. Although studies have shown that the proportion of AOX resulting from household detergents forms a very low proportion of the total AOX in European rivers, the use of the precautionary principal in setting ecolabel criteria means that materials which could produce AOX compounds have been excluded.
This is a difficult area in which to set an environmental requirement, particularly if chlorinated chemicals are deemed appropriate for achieving a satisfactory level of hygiene at lower operating temperatures (55 °C). As neither the main dishwasher detergent manufacturer’s association or its members, participated in the revision of the criteria, there is no readily available data on the use of chlorinated bleach compounds in market brands. Consequently, there is a need to obtain information from the major manufacturers on the issues regarding the use of chlorinated compounds at lower temperatures before proposing options and limits.
5.2.2.6 PHOSPHATES Phosphates from wastewater treatment plant (WWTP) effluent may contribute to eutrophication of surface waters. Phosphates in detergent represent around 15% of phosphorous released to such waters in the EU. Consequently some Member States have introduced legislation, which prohibits the use of phosphates in detergents whilst others require a high percentage of wastewater to receive tertiary treatment (which includes phosphate removal). As noted earlier, the Commission has been asked to consider the case of otherwise for a detergent phosphate phase-out.
The ecolabel accepts the reality that, at the time of developing the criteria, an out right exclusion would not be practical and sets an exclusion hurdle of 10 g/wash. Table 1 shows that most compact or tablet products meet this requirement. Recent trends have been to decrease the quantity of phosphates in detergents. Once the situation regarding a phosphates directive is clear, it would be appropriate to consider a minimum baseline requirement.
5.2.2.7 NON-BIODEGRADABLE ORGANIC COMPOUNDS (AEROBIC AND ANAEROBIC) Ecolabel criteria set limits for both of these parameters seeking to limit the impact of such compounds on the effluent from wastewater treatment plants (WWTP).
Table 5.2b shows that 29 of the compact powders and tablets for which data was obtained are below the ecolabel exclusion hurdle. These detergents would also meet the requirements set by the proposed new legislation on detergents.
5.2.2.8 SURFACTANT BIODEGRADABILITY Proposed EU legislation on detergents is expected to require that surfactants in domestic detergents shall be readily biodegradable under aerobic conditions. The current ecolabel criteria have been set at a level, which excludes all surfactants that are not readily aerobically biodegradable.
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There are conflicting views on the importance of anaerobic biodegradability for surfactants, and it is currently not an area that would be included in the proposed new EU legislation on detergents. However ecolabel criteria are set because potential problems with accumulation of non-biodegraded chemicals in sediments and sludges have been identified, and hence require surfactants to be anaerobically biodegradable.
Table 1 shows that 29 of the compact powders and tablets for which data was obtained are below the ecolabel exclusion hurdle. Consequently, this does not appear to be an issue for dishwasher detergent formulations but we suggest that the outcome of legislative actions is awaited before taking this aspect further.
5.2.2.9 RISK PHRASES The ecolabel criteria for dishwasher detergents aim to reduce the quantity of compounds that are CMR - that is carcinogenic, mutagenic or reprotoxic. Consequently there is an extensive list of R-phrases that exclude the use of CMR compounds.
MEPs have confirmed a request for CMR substances to be prohibited from detergents.
5.2.2.10 PHOSPHONATES AND OTHER CHEMICALS The ecolabel requires chemicals to be readily biodegradable. This is the reason for setting a limit on the level of phosphonates and for excluding a number of chemicals, such as alkylphenothoxylate (APEO). However, information obtained during the revision of the criteria indicated that readily biodegradable phosphonates are now being produced.
5.2.2.11 PACKAGING The ecolabel criterion set a maximum weight for the packaging and minimum recycled content for cardboard packaging. Any plastic packaging must indicate the polymer from which it was produced.
Packaging represents a small percentage of the overall environmental impact of this product. Typically cardboard packaging would contain some 60%+ recycled material. However, it may be more difficult for tablet products to meet the ecolabel requirements on weight of packaging, particularly if each tablet is individually wrapped.
5.2.2.12 INFORMATION ON THE PACKAGING The criterion on user instructions provides instructions to the user in a number of areas. A number of these could be considered for inclusion in a baseline environmental standard, particularly those relating to using a full load, using detergents, which work at lower temperatures than 65 °C, and use the correct dosage of detergent. The most appropriate method for communicating these instructions to consumers could also be considered; for example, the use of clear simple language and pictures, together with a statement that using the dishwasher in accordance with the instructions provided will reduce operating costs whilst providing good cleaning results.
5.2.2.13 OPPORTUNITIES FOR ESTABLISHING ENVIRONMENTAL STANDARDS FOR DISHWASHER DETERGENTS Although a wide range of criteria are covered in the ecolabel for dishwasher detergents, the table 5.2c outlines the main differences between the most and least acceptable environmental dishwasher detergents.
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Table 5.2c: Differences between most and least environmentally acceptable environmental dishwasher detergents
Most environmentally Least environmentally acceptable acceptable Form Concentrated Conventional powder or liquid Temperature and Gives satisfactory Only give satisfactory cleaning cleaning performance at cleaning performance at 55°C 65°C+
Chemicals All chemicals are readily Use of chemicals which biodegradable under have poor aerobic conditions biodegradability under aerobic conditions Critical dilution volume Low Very high
Given that the ecolabel criteria were established by considering data from a small sample size, it is not possible to suggest specific limits. However, some outline suggestions can be made.
Whilst the ecolabel criteria promote the use of both compact powders and tablets, the use of tablets reduces the possibility of over-dosing, and thus reduces potential pollution loading. Consequently, limits could be considered in the following areas highlighted in table 5.2d:
Table 5.2d: Possible areas for establishing baseline requirements
Requirement Justification Detergent produced in tablet form · Lower resource use · Reduces possibility of over- dosing, and thus reduces possibility of additional water pollution Detergent provides satisfactory · Energy consumption in use is cleaning performance at 55 °C and the major environmental impact passes the EN 50242 test used for the for a dishwasher dishwasher Energy Label. · Cleaning performance is an important issue for consumers All chemicals are readily biodegradable · Reduces water pollution under aerobic conditions · Reduces loading of sludges from WWTP Critical dilution volume as low as · Reduces water pollution possible, but detergent must have satisfactory cleaning performance and meet hygiene requirements Phosphates · Legislation in some Member States Clear instructions on packaging · Reduces energy consumption of regarding dishwasher temperature and dishwasher correct amount of detergent to use · Reduces water pollution
As many of these issues will be covered by proposed new legislation, initial actions should focus on the areas that are unlikely to be covered by this new legislation, i.e use of compact powders and tablets, achievement of a satisfactory cleaning performance at
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55°C, and instructions to users on both dishwasher temperature and the amount of detergent used. Consequently we suggest that the position with regards to pending detergent legislation is finalised before issues such as phosphates and CMR substances are tackled.
The ecolabel criteria that could be used in setting minimum standards against remaining issues are highlighted in table 5.2e:
Table 5.2e: Ecolabel criteria for setting minimum standards Issue Approach or ecolabel criterion Production in tablet form Total chemicals – maximum of 22.5 g/wash Satisfactory cleaning performance at 55 Satisfactory performance based on EN 50242 °C at 55 °C Product to have a low Critical Dilution Ecolabel CDV criterion volume A higher level than the ecolabel exclusion hurdle may be required in order to meet acceptable hygiene requirements. The point requires further clarification. Provision of clear instructions on These should be presented in clear and minimising environmental impact and simple language making use of pictures minimising operating cost where appropriate to aid communication. An industry wide standard for this (and other product groups) would be a sensible way forward.
5.3 VACUUM CLEANERS
The EU ecolabel definition for the product group “vacuum cleaners” is:
· “All self-contained vacuum cleaners, such as cylinder and upright vacuum cleaners, which are fit to aspirate dust on surfaces of at least 10 m2 per use. Cordless or battery operated vacuum cleaners, and central vacuum cleaning systems are excluded from the product group”.
Although the ecolabel concentrates on domestic products, this definition also covers some semi-professional systems. Commercial and institutional vacuum cleaners are not covered.
There are three main types of products on the market in Europe; cylinder vacuum cleaners, upright vacuum cleaners and handheld vacuum cleaners. The EU market is dominated by cylinder vacuum cleaners, although this is not the case for the UK where upright vacuum cleaners represent about 50% of the market.
The two most important areas for consumers are reported as being dust removal and dust emissions. Noise may also be an issue for a significant proportion of consumers. Energy consumption is likely to have lower importance.
Developments in vacuum cleaner technology have covered the following areas:
· Reducing size (more compact, less weight) · Increased suction · Lower dust emissions · Lower noise.
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There have also been some more innovative products, such as the DYSON cleaner (which has no bag but uses cyclones13) in the UK, and the POLTI cleaner (which has no bag but filters dust in a water container) in Italy. These cleaners may increase their market share because they have lower dust emissions.
5.3.1 LIFE CYCLE CONSIDERATIONS A simplified life-cycle assessment (LCA) was conducted14 for the ecolabel regarding energy and material use. This showed that the in-use phase represents about 90% of the energy consumed during the life-cycle of the vacuum cleaner; a similar finding to that for other electrical products. Consequently, the ecolabel aims to promote:
· The reduction of environmental damage or risks related to the use of energy (global warming, acidification, depletion of non-renewable resources) by reducing energy consumption · The reduction of environmental damage related to the use of natural resources by encouraging the durability, recyclability and maintainability of a vacuum cleaner · The reduction of environmental damage or risks related to the use of hazardous substances by reducing the use of such substances.
The criteria cover energy consumption, cleaning performance, durability, recycling, noise, dust emissions, ease of use, and user instructions.
5.3.2 KEY ENVIRONMENTAL CHARACTERISTICS OF VACUUM CLEANERS An energy label for vacuum cleaners is presently under consideration. Its development is dependent upon suitable test methods being devised and agreed. An issue requiring attention for example, is whether a vacuum cleaner test should be conducted with the dust collector empty, partially full or full (or all three).
The sensitivity here is that a single test could favour a certain product type - in essence a partially full or full container test will generally favour bagless vacuum cleaners whilst an empty container test generally favours vacuum cleaners with a dust-bag.
Development of an energy label is further complicated by the limited data availability on factors such as dust removal efficiency, energy consumption, dust emissions and noise levels.
Consequently the limited information available makes it difficult to comment on the spectrum of vacuum cleaner performance, and hence to suggest minimum performance standards for this study. In this respect we are grateful for the input provided by the ANEC project advisor who provided thoughts based on information available to ANEC.
13 This technology is being replicated by other manufacturers. 14 European ecolabel for vacuum cleaners: technical study on criteria definition and updating – final report. Report produced by J Chevalier for AFNOR, July 2002.
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5.3.2.1 ENERGY CONSUMPTION AND DUST REMOVAL EFFICIENCY A combined criterion specifies maximum power consumption for specified dust removal efficiency. Requirements, which are determined using EN 60312, are set for both a Wilton carpet and a hard floor surface and are detailed in table 5.3a:
Table 5.3a: Requirements for a Wilton carpet and a Hard floor surface
Wilton Carpet Hard floor Number of strokes 5 1 Dust removal efficiency >70% >98% Power consumption < 345 Wh < 69 Wh
Results of a limited test programme conducted on three vacuum cleaners during the ecolabel's development indicate that none of the machines tested could meet the finally approved ecolabel requirements. The reasoning behind this is presumed to be the result of the EU Ecolabelling Board (EUEB) pressing for higher standards for this product group.
As the ecolabel sets a very high standard, which anecdotal evidence suggests that few vacuum cleaners can achieve, the baseline minimum standard would need to be significantly lower. Suitable analysis of private data could be used to set requirements for both energy consumption and dust removal efficiency, but any comparison of the data would need to take account of possible differences in the testing procedures used.
5.3.2.2 DUST EMISSIONS This is an important issue for consumers due to concerns about asthma and allergies. Some manufacturers include as part of their product's marketing, details of the importance of dust pick-up and retention.
The ecolabel criterion is that the quantity of dust emitted ie that which is sucked up off a surface but passes through the vacuum cleaner to be emitted to air, shall be less than 0.01 mg/m3. The criterion also requires dust filters to be light coloured (so that the level of dust on them can be more easily seen) and either replaceable or washable.
The level of dust emissions set by the ecolabel is significantly lower than the level of 0.05 mg/m3 originally proposed. The level was altered to 0.01 mg/m3 on the basis that the ecolabel should set a more challenging target. Consequently, when considering a minimum performance standard for dust emissions, a level of 0.03 to 0.05 mg/m3 is appropriate.
5.3.2.3 NOISE Noise is an issue that has increased in importance on the environmental agenda over the past few years. It is worth noting that some Member States have set noise level requirements for products such as lawn mowers and leaf blowers.
Ecolabel consultation work suggests that vacuum cleaners typically have noise levels of between 76 and 79 dB(A), with some over 80 dB(A). The ecolabel sets a requirement that the noise level shall not exceed 76 dB(A).
Consequently, a level of between 77 and 78 dB(A) would appear reasonable.
5.3.2.4 DURABILITY The main requirement in the ecolabel criterion is that the motor shall have a lifetime of at least 550 hours. This is the lifetime, which the EUEB including consumer organisations considered to be acceptable.
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Motor lifetimes15 can range from 300 hours to 1,000 hours. Consequently a motor lifetime similar to that set by the ecolabel, i.e. a minimum of 500-550 hours is a useful baseline for a minimum standard.
5.3.2.5 EASE OF USE The ecolabel requires the vacuum cleaner to be easy to use (in terms of ergonomics), and sets a requirement that the cleaning nozzle can be easily moved over the surface, which is to be cleaned. This is defined in terms of suction head motion resistance.
Very little data exists regarding the derivation of this criterion. Consequently, in the absence of more detailed information we are not able to suggest a justified baseline requirement.
5.3.2.6 TAKE-BACK AND RECYCLING The requirements in the WEEE and ROHS Directives (such as those on flame retardants) are almost identical to the current take-back and recycling criterion.
However, one area which these Directives do not cover, but is included in the ecolabel criterion, is the requirement that plastic parts heavier than 50 grams shall have a permanent marking identifying the material, in conformity with ISO 11469. This ecolabel requirement could be considered for inclusion in a baseline environmental standard, and could be extended to cover all electrical and electronic products.
5.3.2.7 USER INSTRUCTIONS The criterion on user instructions provides instructions to the user in a number of areas.
Of these, we suggest the following could be considered for inclusion in a baseline environmental standard:
· Advice to users that energy consumption can be reduced if the dust container is emptied when full. · Advice to users that adhering to the provided maintenance procedures is important and will help effect good cleaning performance.
The most appropriate method for communicating these instructions should also be considered. We suggest the use of clear simple language accompanied by pictures, together with a statement that using the vacuum cleaner in accordance with the instructions provided will reduce operating costs whilst providing good cleaning results.
15 Low lifetime for products designed for Asian market. Miele claim that their products are designed for 1,000 hours of use
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5.3.3 OPPORTUNITIES FOR ESTABLISHING ENVIRONMENTAL STANDARDS FOR VACUUM CLEANERS Although a wide range of criteria is covered in the ecolabel, the table 5.3b outlines the main differences between the more and less environmentally acceptable vacuum cleaners.
Table 5.3b: Main differences between the more and less environmentally acceptable vacuum cleaners
More environmentally Less environmentally acceptable acceptable Energy consumption for a Meet requirements set by Significantly higher specified efficiency of the ecolabel consumption than those dust removal set by the ecolabel Dust emissions < 0.02 mg/m3 > 0.05 mg/m3 Noise < 77 dBA > 79 dBA Durability > 600 hours <400 hours
Consequently, options for minimum baseline standards are outlined in table 5.3c.
Table 5.3c: Main differences between the more and less environmentally acceptable vacuum cleaners
Requirement Justification Dust removal efficiency and energy · Cleaning performance is an consumption important issue for consumers · Energy consumption during use is the major environmental impact for a vacuum cleaner Dust emissions · Important issue for consumers due to concerns about asthma and allergies Noise · Some Member States have already set requirements on noise for certain products Durability · Reduces resource use in manufacture · Providing good in-service lifetimes Instructions · Assist consumer in reducing energy consumption · Assist consumers to achieve good performance by providing clear maintenance instructions
Consequently, the following approach, together with the ecolabel criteria that could be used in setting minimum standards are outlined in table 5.3d.
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Table 5.3d: Ecolabel criteria for setting minimum standards for vacuum cleaners Issue Approach or ecolabel criterion Energy consumption and dust removal Further data required to enable a minimum efficiency standard to be identified Dust emissions To be set between 0.03 and 0.05 mg/m3 Noise To be set between 77 to 78 dBA Durability Similar to ecolabel requirement - between 500 and 550 hours for motor lifetime Recycling All plastic parts heavier than 50 grams to have a permanent marking identifying the material in conformity with ISO 11469 Provision of clear instructions on These should be presented in clear and minimising environmental impact and simple language making use of pictures minimising operating cost where appropriate to aid communication. An industry wide standard for this (and other product groups) would be a sensible way forward. Information could be provided in leaflets with the product and/or appear as a sticker on the product itself.
5.4 INDOOR PAINTS & VARNISHES
The first EU ecolabel for indoor paints and varnishes was introduced in 1994. The criteria have since been revised 3 times and the current definition of this product group is:
· “Indoor decorative paints and varnishes, woodstains and related products, for use by do-it-yourself and professional users; and that are primarily developed for indoor use and marketed as such”.
This includes, inter alia, floor coatings and floor paints; products which are tinted by distributors at the request of amateur or professional decorators; decorative paints in liquid or paste formulas which may have been pre-conditioned, tinted or prepared by the manufacturer to meet consumers needs, including primers (and undercoats) of such product systems.
The current criteria cover materials classified according to their specular gloss (Class 1 and Class 2). There has been interest surrounding the development of criteria for outdoor paints and varnishes but at present, there are insufficient test methods and standards to do so. The possibility for extending the product group was discussed at the most recent ecolabel criteria review as part of consideration for an extension for the product group.
At present, products not covered by the current definition include: · Anti-corrosion coatings · Anti-fouling coatings · Wood preservation products · Coatings for particular industrial and professional uses including heavy-duty coatings and two-pack products · Specialty products, including specific stain blockers and high performance penetrating primers.
The European decorative coatings industry market is forecast to be 3 300 000 tonnes with an annual turnover of about 7 000 millions of euro, by the year 2004. Water-based products will overwhelmingly dominate the market, while low solid solvent based paints will be in decline.
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So far the industry has tackled the problem of reducing VOC content by researching the more efficient use of solvents. In the decorative paints market, industry water based paints have been very successful in being accepted as a cleaner alternative to solvent based paints. 70% of paints used in Europe are water based paints. But it depends on the country, for example 90% of paints in Denmark are water based paints and only 54% in France16.
5.4.1 LIFE CYCLE CONSIDERATIONS The following information has been provided via Ecolabel Study documents prepared by AFNOR and their contractors in France. Information on types of paint used to derive the original criteria is limited but available information summarizes that the work was conducted by considering available LCA studies and feedback from consultation.
The main environmental problems and their origin in the life cycle of the paints are presented in the table 5.4a17.
16 Draft Interim Report –November 2001 – BIO INTELLIGENCE SERVICE/ AFNOR 17 ECOLABELLING CRITERIA BASED ON THE LIFE CYCLE INVENTORY INVENTORY OF ELEVEN INDOORS DECORATIVE PAINTS written by the ECOBILAN COMPANY for the ministry of Environment in France in 1994
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Table 5.4a: Environmental problems and their origin
ENVIRONMENTAL Origin in the life cycle of the Contribution PROBLEMS paints Non renewable Mainly coming from production of 444 resources depletion the TiO2, the alkyd resins and the solvents Mainly due to petroleum consumption Global Warming Mainly coming from production of 444 energy for TiO2 process, the coke for lithopone process Mainly due to CO2 emissions Atmospheric Mainly coming from TiO2 process 444 Acidification Mainly due to SOx emissions Tropospheric Ozone Mainly coming from application of 4 Creation the paint Mainly due to VOC emissions Other Air Emissions MAINLY COMING FROM THE 4 PRODUCTION OF THE RESINS AND THEIR CONSTITUENTS MAINLY DUE TO THETIO2 PROCESS Water Consumption Mainly coming from theTiO2 process 4 Eutrophication Mainly coming from the production 4 of the resins and their constituents Mainly due to COD Other Discharges into Mainly coming from theTiO2 process, 444 water washing of the application tools (brushes…) Solid Waste Mainly coming from application of 4 the paint Mainly due to can and paint residues
444 = key criteria 4 = secondary criteria
Consequently, for PAINTS & VARNISHES, the ecolabel criteria aim to promote: – The efficient use of the product and the minimisation of waste, (IN USE & PRODUCTION) – Reducing the environmental and other risks (such as tropospheric ozone) by reducing – Solvent emissions, (PRODUCTION & IN USE) – Reducing the discharges of toxic or otherwise polluting substances into waters. (PRODUCTION, IN USE & DISPOSAL)
In order to achieve this, the types of criteria that have been set are highlighted in table 5.4b;
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Table 5.4b: Typical Criteria
Area Criterion Quantity of chemicals in Maximum white pigments in paints product Elimination of ingredients classified as very toxic, toxic, carcinogenic, mutagenic, toxic for reproduction
Emissions The emissions and wastes from TiO2 process The maximum VOC in P & V The maximum Volatile Aromatic Hydrocarbon content in P & V Fitness for Use Product to have a satisfactory properties in terms of functionality such as spreading rate, wet and dry scrub resistance, adhesion and abrasion
Consumer Information Recommendations concerning use of product as well as recommendations for cleaning tools and hence, avoiding unnecessary water pollution
The following three sections discuss criteria that may be suitable for consideration as baseline requirements. It must be noted that many of the criteria set out for P & V’s are production related. Therefore, where they occur, discussions on setting limits have been avoided for such criteria could be viewed as a trade barrier if they were contained in general product standards/regulations.
There are 8 criteria in total, with criteria;
1. 1-5 focusing on environmental criteria (such as emissions to air of certain chemicals during production) 2. 6 focusing on Fitness for Use criteria 3. And criteria 7-8 focusing on Consumer Information
5.4.2 KEY ENVIRONMENTAL CHARACTERISTICS OF INDOOR PAINTS & VARNISHES
5.4.2.1 WHITE PIGMENT CONTENT
This is an issue because of the environmental problems related to production (TiO2 process). These problems include global warming, atmospheric acidification, other air emissions and discharges to water. However, it must be considered that white pigment content is important for fitness for use; i.e. X litres of paint to cover Ym2 with a specific opacity. It would be appropriate to examine the possibilities of developing a baseline standard for this criterion. A limit similar to the ecolabel criteria limit 38g/m2) could be considered. There are no white pigments in varnishes.
5.4.2.2 TITANIUM DIOXIDE This criterion refers to emissions and discharges of wastes from the production of any titanium dioxide pigment used. Criteria referring to production related requirements should be avoided, since they may be viewed as barriers to trade. Furthermore, it should be noted that the latest revisions to the ecolabel criteria found that reducing the content further posed difficulties due to significant technical reasons and the German Blue Angel does not set a limit in their ecolabel criteria – the production has to be in conformity with Directive 92/112.
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5.4.2.3 VOLATILE ORGANIC COMPOUNDS (VOC’S) For paints & varnishes, these compounds are the main contributors to the tropospheric ozone formation. Information was gathered for some of the ecolabel criteria development reports in 1993 for 11 paints and varnishes. Former ecolabel criteria set 30g/L for wall paints although most ecolabelled Paints & Varnishes now achieve 25g/L. A level of 250 g/L is set for paints with a spreading rate of at least 15m2/L and all other products a level of 180g/L. Proposed maximum VOC content limit values for decorative paints and varnishes are contained in Annex II of the proposed DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL On the limitation of emissions of volatile organic compounds due to the use of organic solvents in decorative paints and varnishes and vehicle refinishing products and amending Directive 1999/13/EC18. These limit values are provided in the table 5.4d;
Table 5.4d: Proposed limits for VOC content limit values
Product Subcategory Type19 Phase I Phase I (g/l*) (from (g/l*) (from 1.1.2007) 1.1.2010) A Interior matt walls and WB 75 30 ceilings (Gloss < 25@60o) SB 400 30 B Interior glossy walls and WB 150 100 ceilings (gloss >25@60o) SB 400 100 C Exterior walls of mineral WB 75 40 substrate SB 450 430 D Interior/exterior trim and WB 150 130 cladding paints for wood SB 300 - and metal E Interior/exterior trim WB 150 100 varnishes and woodstains, SB 500 400 including opaque woodstains F Interior and exterior WB 150 130 minimal build woodstains SB 700 700 G Primers WB 50 30 SB 450 350 H Binding Primers WB 50 30 SB 750 750 I One-pack performance WB 140 140 coatings SB 600 500 J Two-pack reactive WB 140 140 performance coatings for SB 550 500 specific end use such as floors K Multi-coloured coatings WB 300 100 SB 500 100 L Decorative effect coatings WB 300 200 SB 500 200 *g/l ready to use
18 DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL On the limitation of emissions of volatile organic compounds due to the use of organic solvents in decorative paints and varnishes and vehicle refinishing products and amending Directive 1999/13/EC 19 WB = water based SB = solvent based
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In view of the forthcoming directive establishing VOC-limits for paints it does not seem beneficial to consider establishing baseline limits for this criteria.
5.4.2.4 VOLATILE AROMATIC HYDROCARBONS (VAH) The Blue Angel RAL-UZ 12a sets a requirement to be checked against R phrases. The criteria for Stichting Milieukeur set a level of < 0.5% (weight/weight) and for the ecolabel, a VAH content of 0.15% of the product in m/m is set for wall paints and for all other products at VAH content of 0.4% of the product (in m/m) is set. NF Environment set two levels depending on the class of paints (0.5% for class 1 and 2 but 1% for paints with a higher hiding power). Austrian legislation limits the content of VAH’s to 5% for most paints and varnishes. This level could be used to establish a baseline requirement.
5.4.2.5 HEAVY METALS Heavy Metals pose significant risk to the environment with proven risks associated with pollution to land, air and water. Baseline standards could be set in terms of ppm (parts per million) for heavy metal content by restricting the quantity of the following metals in paint; cadmium, lead, chromium VI, mercury and Arsenic. The German Paint Association (Verband der Lackindustrie e. V.) has issued guidelines20 for paints for buildings and wood paints which disallow the use of cadmium, lead, mercury and chromium VI. However, there are guideline limits in the ppm range where the presence of cadmium and lead may be unavoidable (Cd=100ppm, Lead=200ppm). Furthermore, the Council Directive 91/338/EEC21 of 18 June 1991 also states that cadmium and its compounds must not exceed 100ppm. However, the exception being that if the paint has a high zinc content, the residual concentration of cadmium must be as low as possible and at all events not exceed 0.1% by mass. Consequently, the aforementioned guidelines could be used for establishing baseline criteria, which set limits in the 100 ppm range.
5.4.2.6 DANGEROUS SUBSTANCES Substances contained within paints that can be classified according to the Risk Phrases indicated in 8(b) of the ecolabel should not be used, but these are laid down in the Council Directive 67/548/EEC. Concerning glycol ethers, since 1994 the EU Marketing and Use Directive has forbidden the sales of products containing glycol ethers which are category 2 reproductive toxicants with the risk phrases R60 and R61. The aforementioned provisions may form a suitable basis for the establishment of baseline requirements. Exclusions of certain compounds may not be an option if it would fundamentally affect the quality of the paint. (Cobalt, an additive and accelerator for polyester resins and deemed a potentially dangerous substance, is a substitute to lead). Evidence from the latest revision of the ecolabel for P & V’s has identified that alternatives to cobalt are equally or more toxic than cobalt.
The British Coating Federation has investigated alternatives but found that the alternatives were unsatisfactory (inferior drying properties, toxic etc). The toxicology of cobalt dryers is currently under review in Germany.
Concerning formaldehyde, an eco-label criterion exists which states that the concentration of free formaldehyde must not exceed 10mg/kg. As previously mentioned, the German Paint Association has issued guidelines20, which provide limits for various substances contained in paints for buildings. These guidelines also include a general limit of 10mg/kg in line with the ecolabel criterion. In conclusion, the existence of such levels indicates that this value may be suitable for consideration as a baseline requirement.
20 VdL-RL 01/April 2000 – Bautenanstrichstoffe (German Paint Guidelines) 21 Council Directive 91/338/EEC of 18 June 1991 amending for the 10th time Directive 76/769/EEC on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations
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5.4.2.7 FITNESS FOR USE Despite having important environmental standards, the product should still be fit for use, have good hiding power, be washable etc. Different “fitness for use” criteria depend on the class of the paint. This can be measured by the hiding power (m2/L) of the paint for which there is a test method (i.e. Kubelka-Munk), the wet scrub resistances for which there is a test method (EN ISO 11998), resistance to water for which there is a test method (EN ISO 2812-1) and Adhesion for which there is a test method (EN 2409). Standards could be set based on these criteria.
5.4.2.8 USER INSTRUCTIONS Information on how to use paint in order to minimise the health effects to the user (such as working in well ventilated rooms, wear gloves etc) and in terms of using the paint efficiently and effectively is important. All requirements pertaining to consumer information with the exception of the eco-label related text seem to be relevant for all types of paints and could also be used in the context of baseline requirements; · Information which enables consumer to minimise environmental impacts and obtain acceptable performance at lowest overall operating cost (quantity required for a given area) · Information concerning safe product storage and disposal (including cleaning tools).
5.4.2.9 INFORMATION APPEARING ON THE ECOLABEL Not relevant for general standards as this criterion is specific to the ecolabel.
Given that the ecolabel criteria were established by considering data from a small sample size (11 paints), it is not possible to suggest specific limits. However, some outline suggestions can be made.
5.4.3 OPPORTUNITIES FOR ESTABLISHING ENVIRONMENTAL STANDARDS FOR INDOOR PAINTS & VARNISHES A wide range of criteria are covered in the ecolabel criteria for indoor paints and varnishes, table 5.4e outlines the main differences between the most acceptable environmental indoor paints and varnishes and the least environmentally acceptable indoor paints and varnishes.
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Table 5.4e: Differences between most and least environmentally acceptable environmental indoor paints and varnishes Requirement Most environmentally Least environmentally acceptable acceptable Production Limiting damage to the A number of environment through environmental impacts restricting levels of white including atmospheric pigment in paint (process acidification and global which most impacts on warming contributed to the environment) by the production process for white pigment content Emissions, Chemicals & Elimination and limitation Use of substances which Heavy Metals of substances that lead to are hazardous to aquatic water pollution. life as well as other environmental parameters Fitness for Use Products are fit for Poor performance that purpose in terms of their might for example, performance necessitate repeat applications Consumer Information Correct information given Little or no information on use, storage and regarding application disposal of paints to rates, cleaning brushes, avoid hazards to health health and safety and the aquatic considerations etc environment
Given that the ecolabel criteria were established by considering data from a small sample size (11 paints), it is not possible to suggest specific limits. However, some outline suggestions can be made in the areas outlined in table 5.4f:
Table 5.4f: Possible areas for establishing baseline requirements Requirement Justification White Pigment Content · Lower resource use · Reduces level of non-renewable resource depletion, global warming etc VOC’s · Reduces contribution to VAH’s Tropospheric Ozone Creation Heavy Metals · Reduces water pollution
Fitness for Use · Reduces need to buy more paint (if quality of paint poor, will need more paint and hence, resources) Consumer Information · Reduce water pollution from disposal
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The ecolabel criteria that could be used in setting minimum standards are:
Table 5.2g: Ecolabel criteria for setting minimum standards
Issue Ecolabel criterion White pigment content 38 g/m2
VAH content Limit of 5%
Heavy Metals - exclusions Limits in ppm-range
Dangerous substances - exclusions Based on Risk Phrases
Formaldehyde Limit of 10 mg/kg
Fitness for Use Requirements for hiding power, wet scrub resistances, resistance to water, adhesion Consumer Information e.g. on how to minimise environmental impacts upon disposal
5.5 TEXTILES
The first EU ecolabel for textiles was introduced in 1996, setting criteria for bed linen and T-shirts made of cotton or cotton/polyester. With subsequent revisions, the product group now comprises;
· Textile clothing and accessories: clothing such as handkerchiefs, scarves, bags, shopping bags, rucksacks, belts etc consisting of at least 90% by weight of textile fibres.
· Interior textiles: textile products for interior use consisting of at least 90% by weight of textile fibres. Wall and floor coverings are excluded.
· Fibres, yarn and fabric: intended for use in textile clothing and accessories or interior textiles.
The textile industry is one of the longest and most complicated industrial chains in the manufacturing industry. It is a fragmented and heterogeneous sector dominated by SMEs, with a demand mainly driven by three main end-uses: clothing, home furnishing and industrial use. Italy is the leading European producer, with Italy, Germany, the UK, France and Spain accounting for 80% of the Community Textile and Clothing Industry22.
The textile industry is composed of a wide number of sub-sectors, covering the entire production cycle from the production of raw materials (man-made fibres) to semi- processed (yarn, woven and knitted fabrics with their finishing processes) and final products (carpets, home textiles, clothing and industrial use textiles). The share of the European Union of the world production of fibres in 1999 is given in table 5.5a.
22 European Commission, 2001, based on data from EURATEX
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Table 5.5a: The share of the European Union of the world production of fibres in 1999
Fibres Production in EU in % Of world production 1000 tons Cotton 553 2.9 Wool 114 8.6 SyntheticsA 3,256 11.5 CellulosicsB 597 22.4 TOTAL 4,520 8.8 AExcluding polyethylene for Western Europe BExcluding Lyocell for Western Europe (for confidentiality reasons)
(Source Calculated from CIRFS, 2000)
5.5.1 LIFE CYCLE CONSIDERATIONS Although access to the original reports produced when the initial criteria were set has not been possible, access to discussion documents from the most recent revision has enabled a summary of the work that was conducted which considered available LCA studies and feedback from consultation.
Environmental impacts surrounding textiles are related to a number of stages in the textile life cycle including those relating to farming practices for cotton and wool etc. For example, the so-called “finishing processes” (i.e. pretreatment, dyeing, printing, finishing and coating, including washing and drying) and upstream processes such as, for example, synthetic fibre manufacturing, spinning, weaving, knitting, etc. The environmental impacts associated with the “finishing processes” depend upon the sequence of treatments the textile is subjected to and which themselves are very variable and dependent on the requirements of the final user.
It can perhaps be concluded that the environmental impacts surrounding textiles are concerned with the use of substances harmful for the environment, in particular the aquatic environment and human health. A number of chemicals that may be used in the textile process are used either for growing, processing and finishing with the potential for negative effects on the environment. Some of these are contained in Appendix 123.
Many of the chemicals mentioned in Appendix 1 not only have an impact on the environment through the release into air and water during the textile processes but on humans through contact with the skin by residual chemicals in the textiles. For example, chemicals are used in the “finishing” process. The term "finishing" covers all those treatments that serve to impart to the textile the desired end-use properties and can include properties relating to visual effect, handle and special characteristics such as waterproofing and non-flammability. In addition, there are specific finishing treatments for certain types of fibre (for example, easy-care finishes for cotton, antistatic treatment for synthetic fibres and mothproofing and anti-felt treatments for wool). Other finishes have more general application (e.g. softening). Bactericidal and fungicidal treatments are frequently applied and many textile products (clothing and underwear) are now being treated with anti-microbial agents. The products used are biocides, which have associated with them a number of perceived risks to the end user (for example, the risk of allergenic reactions).
23 Integrated Pollution Prevention & Control (IPPC), Reference Document on Best Available Techniques for the Textile Industry, November 2002
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Textiles are the most successful product group in the EU ecolabel scheme, currently with 40 license holders (2003). Since the criteria were developed, the most significant environmental impacts have been addressed, namely; · Substances with harmful effects on the aquatic environment and air have been limited during fibre production
· The risk of allergic reactions has been reduced
· Good Fitness For Use performance in terms of shrinkage, colour fastness etc
Consequently, the criteria aim to promote:
· limiting the toxic residues in fibres
· reducing air pollution during the fibre process
· reducing water pollution during fibre process
· limiting the use of substances harmful for the environment in particular the aquatic environment and health
In order to achieve this, the types of criteria that have been set are highlighted in table 5.5b:
Table 5.5b: Areas for which EU Ecolabel Criteria for Textiles have been established
Area Criterion Quantity of residual Total amount of chemicals such as pesticides as a chemicals in fibres result of textile fibre production Water pollution Restrictions on chemicals in waste water Restriction on COD and BOD limits Emissions Restrictions on chemicals to air
Skin Sensitisation Restrictions on chemicals used for dyeing and treating textile fibres
Fitness for Use Product to have a satisfactory lifetime in terms of colour fastness and dimensional changes
The following three sections discuss criteria that may be suitable for consideration as baseline requirements. It must be noted that many of the criteria set out for Textiles are production related. Therefore, where they occur, discussions on setting limits have been avoided for such criteria could be viewed as a trade barrier if they were contained in general product standards/regulations.
There are 40 criteria in total, with criteria;
1. 1-9 focusing on requirements for textile fibres (such as emissions to air of certain chemicals during production) 2. 10-33 focusing on processes and chemicals criteria 3. And criteria 34-40 focusing on Fitness for Use
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The latter criteria appear to offer potential for developing standards. Reasons for which are discussed in the following sections.
5.5.2 KEY ENVIRONMENTAL CHARACTERISTICS OF TEXTILE S
5.5.2.1 REQUIREMENTS ON TEXTILE FIBRES The requirements within this section focus on specific fibre types and refer more often than not to processes used to produce the fibres, whether it be use of pesticides to grow cotton or emissions of certain chemicals during the production of synthetic fibres such as polyamide. The criteria set within this section do not apply if the fibre contributes to less than 5% of the total weight of the product or if the fibres are of recycled origin, although 85% by weight of all fibres in the product must be in compliance with the corresponding fibre-specific criteria or of recycled origin. Compounds such as Acrylic have criteria, which set limits to certain chemicals on emissions to air. Since these emissions will relate to the production process, it is proposed that these types of criteria are not suitable for baseline standards. Whilst setting limits for certain chemicals emitted to air may be a reasonable requirement for EU countries, it may pose barriers to trade for those textile producers in developing countries. However, where appropriate, criteria contained within this section that would be suitable for developing product baseline standards are given in Table 5.5j. Such criteria include restrictions on Antimony (criterion 8). Antimony is typically used in textiles for two main reasons: · Use as a catalyst in polyester manufacturing · Use as a flame retardant synergist in textiles (combined with a halide)
Environmental health problems are not expected to occur from the use of polyester textiles but it has been established that antimony can be dissolved out of fabrics at relatively low temperatures with liquids including perspiration. However, it should be considered that alternatives have been previously limited because alternatives such as Germanium are very scarce and hence expensive. The 1999 EU ecolabel criteria set a limit of 300ppm for antimony levels whereas the most recent revision set a limit of 260ppm. Consequently, a limit on the level of antimony around 300ppm and the exclusion of lead-based pigments in Polypropylene are options for baseline requirements.
5.5.2.2 PROCESSES & CHEMICALS As mentioned previously, criteria 10 – 33 relate to processes and chemicals such as the auxiliaries and finishing agents for fibres and yarns. Many of the criteria relate to emissions to water or air; for example, (ref criteria 10) states that spinning solution additives shall be sufficiently biodegradable or eliminable in wastewater treatment plants. Much of the documentation for such criteria relies on the manufacturer providing safety data sheets, product information sheets or their own declarations. It would be prudent to consider treatment or chemical limits etc in the context of the availability of appropriate test methods. For many textile processes conducted outside the EU Member States, it would be difficult to verify declarations unless tested by a third party.
As stated in the Integrated Pollution Prevention & Control (IPPC), Reference Document on Best Available Techniques for the Textile Industry, November 200223, information about textile raw materials is the first step to tackle pollution carried over from upstream processes. Information from the supplier should include not only the technical characteristics of the textile substrate, but also the type and amount of preparation agents and sizing agents, residual monomers, metals, biocides (e.g. ectoparasiticides for wool) present on the fibre. Various techniques are available that can significantly reduce the environmental impact originating from upstream processes.
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Contained within this section, there are a number of criteria, which impose restrictions on chemicals as a result of their known adverse effects on the environment and health. These chemicals could be restricted or eliminated and include the following;
5.5.2.3 AUXILIARIES AND FINISHING AGENTS FOR FIBRES AND YARNS Both the EU ecolabel and the Nordic Swan label contain a criterion on the content of poly aromatic hydrocarbons (PAH) in mineral oil. Research suggests that the limits put forward are achievable and information from a manufacturer of knitting oils reports that the normal content of PAH in mineral oils is between 1 and 3% but closest to the 1% (Vickers 2000). Consequently, baseline standards could be established limiting the PAH content in the mineral oil proportion to 1% by weight.
5.5.2.4 FORMALDEHYDE Baseline standards could be set for formaldehyde, which is used in easy-care treatment. Easy-care finishing is mainly carried out on cellulosic fibres and their blends in order to increase the crease recovery and/or dimensional stability of the fabrics. Formaldehyde is thought to be carcinogenic and can also be released, for example, during textile cutting operations (hence, a risk to the workforce). The presence of free formaldehyde or partly hydrolysable formaldehyde on the finished fabric also represents a potential risk for the final consumer. Formaldehyde residues on the textiles can be minimized and table 5.5c sets out limits that have been adopted.
Table 5.5c: Formaldehyde limits for different Textile Standards
Standard Limits 1999 European 75ppm 300ppm Ecolabel Criteria (Skin contact) (Other products) 2002 30ppm 300ppm European Ecolabel Criteria Oeko-Tex 103 75ppm - Direct skin contact Oeko-Tex 103 300ppm - Without skin contact Oeko-Tex 106 75ppm - Baby Clothing Oeko-Tex 109, 110 300ppm - – Textile furnishing fabrics and curtains
Toxproof – 75 ppm - Direct skin contact Toxproof – Without 300 ppm 300 ppm skin contact (Garments) (Household Furnishings) Toxproof – Baby 20ppm Clothing
From the limits in the table, a baseline standard for formaldehyde in clothing could be established at 75ppm and 300ppm for products with and without skin contact.
5.5.2.5 PESTICIDES Criteria exist in the European Ecolabel Scheme that concerns the use of pesticides, including the emissions from the scouring process. The most common pesticides are
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AEAT in Confidence AEAT/ENV/R/1460 organophosphorous (OP), synthetic pyrethroids (SP) and insect growth regulators (IGR) and organochlorine (OC) pesticides are still found on wool from certain grower countries. Chemicals used as pesticides such as organochlorines are hazardous due to their persistence and bioaccumulability. The Oeko –Tex standard, which guarantees that textiles do not contain hazardous substances in amounts that could impair human health within normal conditions of use, set limits for total residues of pesticides in textiles and are provided in table 5.5d below;
Table 5.5d: Pesticide limits for different Textile Standards
Standard Criteria Oeko-Tex 103 1ppm Direct skin contact Oeko-Tex 103 1ppm Without skin contact Oeko-Tex 106 0.5ppm Baby Clothing Oeko-Tex 109, 110 – Textile 1ppm furnishing fabrics and curtains Toxproof – List with Direct skin contact restrictions Toxproof – Without skin contact List with restrictions Toxproof – Baby Clothing List with restrictions
The EU Ecolabel set restrictions on pesticides under the “Textile Fibre Criteria” for cotton (including other natural cellulosic seed fibres) and wool. For cotton, the limit is 0.05ppm for the named compounds whilst for wool, several concentration limits are set depending on the compound in question. All are however, in the ppm-range. Since a number of standards set limits for total quantity of pesticides in the final textile, a baseline standard could be established with regards to pesticides. This could either be enforced at the textile fibre stage (as has been done for the ecolabel) or to establish a baseline for the total quantity of pesticides in the final fibre as has been done in the Oeko-Tex 100 standard. However, the latter may be preferable from a market surveillance perspective. The chemicals listed under criteria 2, 5a, 5b, 5c and 5d could be limited to levels in the low ppm range. Suitable tests are suggested under criteria 2 and 5 and include test methods for organophosphorous compounds.
5.5.2.6 FLAME RETARDANTS A baseline standard for Flame-retardants could also be set, with the requirement being that those substances with specific risk phrases (or combinations thereof) should not be used.
5.5.2.7 DYES Textile dyes can be classified according to their chemical composition (azo, sulphur etc) or according to their application class (acid, basic, direct, disperse and metal-complex etc). The environmental issues surrounding dyes relate to their toxicity and the following have been classified as toxic and allergenic by the Ecological and Toxicological Association of Dyes and Organic Pigments Manufacturers (ETAD)24.
24 ETAD, (2001). "Guidance for the User Industry on the Environmental Hazard Labelling of Dyestuffs", .
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Table 5.5e: Dyes classified as toxic according to ETAD
Type Name ACID Orange 156 ACID Orange 165 BASIC Blue 3, 7, 81 BASIC Red 12 BASIC Violet 16 BASIC Yellow 21 DIRECT Orange 62
Table 5.5f: Dyes classified as allergenic according to ETAD
Type Name ACID Violet 17 DISPERSE Red 1, 11, 17, 15 DISPERSE Blue 1, 3, 7, 26, 35, 102, 124 DISPERSE Orange 1, 3, 76 DISPERSE Yellow 1, 9, 39, 49, 54, 64
The European Ecolabel Scheme also excludes certain dyes that are potentially sensitising and which do not have a fastness to perspiration of at least 4 (as described in criteria 23). Baseline standards could be established, which exclude those dyes that have been classified as toxic and allergenic by ETAD and/or that do not have a fastness to perspiration of at least 4.
About 60% - 70% of the dyes used nowadays are azo dyes (77, Euratex, 2000). Under reductive conditions, these dyes may produce amines and some of them are carcinogenic. Azo-dyes that might cleave to form one of the amines listed both in Integrated Pollution Prevention & Control (IPPC), Reference Document on Best Available Techniques for the Textile Industry, November 200223, Annex 9 and criteria number 21 in the 2002 European Ecolabel Scheme are prohibited according to the 19th amendment of Directive 76/769/EWG on dangerous substances and therefore no baseline standards need to be developed for azo-dyes. Oeko-tex25 also prohibits certain azo dyes as does the German TUV Rheinland Sicherheit und Umweltschultz GmbH Tox proof standard26.
The present Ecolabel criterion also covers dyes which have a carcinogenic, mutagenic or reprotoxic effect as defined in Council Directive 67/548/EEC27. According to this directive, substances are categorized in three groups in accordance with the evidence for the actual effect (carcinogenic: Carc1, Carc2, Carc3, mutagenic: Mut1, Mut2, Mut3 or toxic to reproduction: Rep1, Rep2, Rep3). The ecolabel criteria set in 1999 cover both CMR categories 1 and 2 whilst the more recent ecolabel revision cover CMR category 3. However, category 3 carcinogenic substances are defined as follows;
Substances which cause concern for man owing to possible carcinogenic effects but in respect of which the available information is not adequate for making a satisfactory assessment. There is some evidence from appropriate animal studies but this is insufficient to place the substance in Category 2.
25 Oeko-Tex Standard 100, http://www.emcentre.com/textile/LT_ecolabelGerman.htm#okotx 26 German TUV Rheinland Sicherheit und Umweltschutz GmbH, Toxproof & Ecoproof, http://www.emcentre.com/textile/LT_ecolabelGerman.htm#tox 27 OJ No 196, 16.8.1967, p.1.
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The Nordic Swan exclude all chemical products that are subject to a health risk classification according to the Council Directive 67/548 EEC last amended by the Commission Directive 2000/33/EC2 which includes all products classified as CMR1, 2 and 3. However, when the 2002 criteria were being decided, ETAD were not in favour of excluding CMR category 3. Reasons included; · Arguments for CMR category 3 are alleged to be weak, · few dye stuffs would be excluded because of the extended criteria and; · the possibility of the existence of differences between the EU Classification rules and national rules, could lead potentially to a debate on trade restrictions.
The ecolabel criteria for textiles aim to reduce the quantity of compounds that are CMR. A baseline standard could be established by eliminating those dyes, which are assigned known to be carcinogenic to humans or have shown evidence of carcinogenity in experimental animals. This would mean excluding dyes belonging to categories 1 and 2.
5.5.2.8 HEAVY METALS Metals can be present in dyes for two reasons (either as impurities or in some dyes the metal is chelated with the dye molecule, forming an integral structural element). Restrictions on heavy metal concentrations in dyes and the final textile products are set both in the European Ecolabel Scheme as well as the Oeko-Tex 100 standard. For the latter, limits are set for the following metals both with and without skin contact in the final textile, chromium, Mercury, Nickel, Copper, Cobalt and Zinc.
Table 5.5g: Heavy metal limits for different Textile Standards
Metals/ Oeko-Tex Oeko- Oeko- Oeko-Tex Tox- Tox- Tox- Limit 103 Tex 103 Tex 106 109, 110 proof – proof – proof – Values Direct Without Baby – Textile Direct Without Baby Skin Skin Clothing furnishing Skin Skin Clothing Contact Contact fabrics Contact Contact and for curtains garmen ts Lead 1ppm 1 ppm 0.2 ppm 1 ppm 0.8ppm 0.8ppm 0.8ppm Cadmium 1 ppm 1 ppm 0.1 ppm 0.1 ppm 0.1 ppm 0.1 ppm 0.1 ppm Chromium 2 ppm (VI 2 ppm 1 ppm 2 ppm (VI 1 ppm 1 ppm 1 ppm prohibited (VI (VI prohibited) (VI (VI (VI ) prohibite prohibite prohibit prohibite prohibite d) d) ed) d) d) Mercury 0.02 ppm 0.02 0.02 0.02 ppm 0.02 0.02 0.02 ppm ppm ppm ppm ppm Nickel 4 ppm 4 ppm 1 ppm 4 ppm 1 ppm 1 ppm 1 ppm Cobalt 4 ppm 4 ppm 1ppm 4 ppm 1 ppm 1 ppm 1 ppm Copper 50 ppm 50 ppm 25 ppm 50 ppm 20 ppm 20 ppm 20 ppm Zinc 20 ppm 20 ppm 20 ppm
The European Ecolabel Scheme have also adopted criteria which limit the levels of ionic impurities in the dyes and pigments based on values recommended by ETAD. The values have been set to ensure that emission levels from a 2% dyeing and a total dilution of the dye of 1:2500, will meet the known wastewater requirements28. Establishing baseline standards for limiting the quantities of heavy metals in the final product could be considered. Standards in the ppm range could be established with the actual value depending on the metal. Limits upstream in the textile manufacturing process could also
28 BASF, (1994). "Products for Textile Finishing: Ecological Evaluation",
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AEAT in Confidence AEAT/ENV/R/1460 be considered where limits for heavy metal impurities in dyes and pigments could be set. However, such limits may be difficult to enforce.
5.5.2.9 FINISHES A similar approach as that taken for dyes could be adopted for finishes. Baseline standards could be established eliminating the use of those finishes belonging to CMR- chemicals categories 1 and 2 as defined by Directive 67/548/EEC.
5.5.2.10 FITNESS FOR USE The ability of a textile product to retain its colour, shape and size is fundamental to the lifetime of the product. It is likely that those products which undergo dimensional changes will not live up to consumer expectations and hence, will be discarded earlier and thus have a larger impact on the environment as they have to be replaced by new products.
It therefore, appears that establishing baseline standards for criteria 34 – 39 is appropriate and in addition, there are recognised standard test methods for setting and measuring limit values. Table 5.5j highlights possible options.
5.5.3 DIVERSITY OF TEXTILES Although the product group textiles is extremely popular, the only category fully enclosed in the existing EU ecolabel product group definition is the indoor clothing category. Outdoor clothing are likely to be subject to a number of functional finishes, such as waterproofing and UV stabilising finishes and therefore, be unable to meet the existing criteria requirements. Therefore, we suggest options for the current ecolabel product group definition, which predominantly focus on textile clothing and accessories and interior textiles.
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Table 5.5h: Differences between most and least environmentally acceptable environmental textiles
Requirement Most environmentally Least environmentally acceptable acceptable Production Environmental impacts Few restrictions on use of associated with production are chemicals used to produce or limited, including limits on grow textile fibres. hazardous chemicals such as pesticides and biocides classified as hazardous substances Processing Chemicals used for finishing Use of chemicals which have treatments etc are sufficiently poor biodegradability biodegradable or eliminable in wastewater treatment plants Chemicals Chemicals used on fabrics will Chemicals used in finishing and not cause sensitisation when in other treatments etc may direct contact with skin. cause skin irritation. Limited Chemicals used for dyeing restrictions on chemicals used which have associated R for dyeing which have phrases are limited. associated R phrases
Fitness for Use Clothes are durable and are Textiles of poor quality, colours colour fast and undergo limited liable to run and stain other dimensional changes parts of fabric. Dimensional changes (shrinkage) highly probable.
In summary, some outline suggestions can be made in the following areas:
Table 5.5i: Possible areas for establishing baseline requirements
Requirement Justification Production · Reduces chemicals released to the environment · Reduces water pollution · Reduces air pollution Processing · Reduces water pollution · Reduces the loading of hazardous chemicals in the environment Chemicals · Reduces water pollution · Reduces skin sensitisation · Reduces other hazards to health that may result from CMR substances Fitness for Use – limits set for · Reduces hazards to health and dimensional changes, colour fastness the environment etc · Lower resource use
The ecolabel criteria that could be used when considering limits and options are:
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Table 5.5j: Ecolabel criteria for setting minimum standards
Issue Ecolabel criterion Production & Processing See Below Chemicals in textiles Limits regarding the use of: · Antimony in Polyester ~300ppm · PAH content in mineral oils ~1% · Formaldehyde 75ppm in-contact, 300 ppm no skin contact · Dyes that are CMR categories 1 and 2 · Potentially sensitising dyes · Pesticides - low ppm range for total amount · Heavy Metals - low ppm range · Flame Retardants - based on Risk Phrases · Shrink Resistant Finishes that are CMR category 1 and 2 Durability Fitness for Use (Product retains its colour, shape and · Colour Fastness to washing, size, hence, longer lifetime. Short perspiration, wet rubbing, dry lifetime will mean that the product will rubbing and light be discarded earlier and thus have a · Dimensional Changes during larger impact on the environment as it washing and drying has to be replaced by a new product).
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6 Conclusions
This study has shown that it is possible to use ecolabel criteria to develop product related baseline requirements. It has devised an approach and then applied it to a diverse range of product groups.
To use the method, three key information types are required, broadly speaking those that relate to:
· Life cycle considerations - to identify environmental impacts · Product 'classification' - to identify the performance spectrum across a given product group · Sales data - to identify sales volumes by classification
This study found that for some products, in particular those covered by the Energy Label, the information available is good and provides a firm basis for developing reasoned proposals. Dishwashers are an example.
For other product groups (for example, paints) the information available, at least in the public domain, is sparse. Indeed access to appropriate data was the most challenging aspect of the study. As a result, whilst issues against which performance baselines could be developed were identified, the derivation of a limit or level was impractical in many cases using available data.
Consequently, the development of proposals for such products is a more involved process; for example, consideration will need to be given to limited and/or privately held datasets and information with associated issues this poses.
This should not be seen as a barrier however; the EU ecolabel faces similar circumstances and rises to the challenge by:
· Using what ever limited dataset(s) exist · Undertaking a limited round of testing to develop performance data · Relying on stakeholder consensus building to develop general agreement on key issues · Using a mixture of all the above
A similar, flexible approach would serve to devise minimum performance requirements in the absence of comprehensive data and should be explored further.
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Further Work
1. An approach has been developed in this study to identify minimum requirements relating to specific products. The next step is to consider how to introduce the study's output into the IPP debate. Presentation of the study to the EUEB and/or EU ecolabel Policy Management Group (which has a brief to develop links between the ecolabel and IPP) seems appropriate. Making such links would raise the profile of the issues addressed by this study. Further, doing so may result in joint actions being identified and taken forward.
2. Discussions with the Commission's officer responsible for IPP would also be appropriate - particularly since the IPP debate has, according to some reporters, stalled in certain areas. ANEC's work may provide new impetus.
3. As mentioned in the conclusions, whilst ecolabel criteria provide a framework for identifying performance parameters, ecolabel information is not always helpful in terms of informing the derivation of minimum baseline requirements; information audit trails are often missing and data is often incomplete. This issue and its attendant implications require attention such that the method can be developed further to overcome the barrier.
4. Clearly the work reported here is limited to a few products. To prove that the method is applicable in general rather than in a few specific cases, it could be applied to a larger range of product groups. Doing so would reinforce ANEC's message regarding the latent value of existing ecolabel criteria.
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Appendix 1
Chemicals with · alkyl phenol ethoxylates (detergents, wetting potential for agents, levelling agents, etc.): their metabolites (octyl- negative and nonyl phenols) are highly toxic to aquatic life and effects on the are reported to disturb the reproduction of aquatic environment species by disrupting the endocrine system (octyl and nonylphenol are on the list of “Priority Substances” targeted for priority action under the Water Framework Directive 2000/60/EC, in particular nonylphenol is identified has “Priority Hazardous Substance”) · polybrominated diphenyl ethers and chlorinated paraffins (flame retardants), halogenated phenols and benzenes (reagents in the production of flame retardants): some members of these classes of substances (e.g. pentabromodiphenylether, C10-13 chloroparaffines) have already been identified as “Priority Hazardous Substances” for their toxicity, persistency and liability to bioaccumulate or they have been evaluated under the scope of Regulation (EEC) 793/93 on the evaluation and control of the risks of existing substances. For other members of these classes the debate about their potentially negative effects on the environment is still on-going. · chlorine and chlorine-releasing compounds such as sodium hypochlorite (bleaching agent) and sodium dichloroisocyanurate (wool anti-felting agent), which are capable of reacting with organic compounds to form absorbable organic halogens (AOX) · metal-containing compounds such as potassium dichromate · substances with carcinogenic potential, such as a number of aromatic amines, formed by cleavage of some azo dyes or vinylcyclohexene and 1,3-butadiene, which can be present in polymer dispersions due to an incomplete reaction during polymerisation · It is reported29 that more than 90 % of the organic chemicals and auxiliaries in pretreatment and dyeing operations does not stay on the fibre, whereas the reverse is true in the finishing treatment
29 EURATEX, E.-D. , (2000). "Textile Industry BREF document (Chapter 2-3-4-5-6)
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· nearly 90 % of the organic raw material load entering the textile process ends up in the · waste water, the remaining amount being released to air.
With regard to emissions to air, volatile organic compounds are released from particular activities such as: · printing processes, in cases when organic solvents are used (e.g. they are contained in · pigment printing pastes) · cleaning with organic solvents · heat treatments (e.g. thermofixation, drying, curing) when the textile materials contain · substances that evaporate or degrade thermally (for example, oils, plasticisers, finishing agents and residues from upstream processes).
Furthermore, energy (from fossil fuels) is required principally in raising the temperature of the baths (e.g. pretreatment, dyeing, etc.) and in drying and curing
operations. This leads to the emissions of CO2, SOx, NOx and particulates associated with the on-site burning
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Appendix 2
Overview of European Ecolabel Schemes
The following table highlights the European labelling schemes and their products (for which there were over 240). This table has been produced as part of the work for the Eco-label Co-operation and Co-ordination Management Group. However, it should be considered that this survey is a preliminary one owing to the fact that certain information on the number of licenses held by schemes such as the German Blue Angel is still being awaited. In addition, calculations are different between the schemes. In the Nordic scheme, one company can have several licenses within the same product group, while under the EU Eco-label Flower Scheme only the numbers of companies are counted. Nevertheless, measures have been taken to account for this.
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All ecolabelling schemes EU-Flower Nordic Sw Spain Catalonia France Germany Austria Netherland Good env choice TCO Croatia Hungary Slovakia Czech Rep Poland Sum No schemes Chemicaltech Laundry detergents 3 10 X 0 55 0 0 1 0 69 9 GardenH Paint & Varnishes 27 2 X X 3 1 10 0 43 8 HouseholdM Refrigerators 2 0 X 0 X 0 0 2 7 HouseholdM Washing Machines 0 2 X 0 0 X 0 2 7 GardenH Textiles 37 4 11 0 0 0 52 6 Paper Toilet paper and tissues made of recycled paper X 0 1 7 2 10 5 GardenH Saw-chain lubricants X 3 1 X 1 5 5 Office Photocopiers/copying machines 4 0 X 0 X 4 5 Chemicaltech Allpurpose/sanitary cleaners 0 10 0 88 98 4 Chemicaltech Dishw detergents 6 12 0 51 69 4 Chemicaltech Handdishwasher 1 9 0 27 37 4 Office Toner cartridges 12 X 0 1 13 4 Office Adhesives 4 1 3 2 10 4 Paper Envelopes 5 4 X y 9 4 Office Fax machine 5 0 X X 5 4 Paper Copying pap 2 X 3 0 5 4 Office Printers 2 0 X X 2 4 Energy-rel Light bulbs 1 0 0 0 1 4 HouseholdM Dishwashers 1 0 X 0 1 4 GardenH Soil Improver 7 0 15 22 3 Paper Tissue paper 8 10 0 18 3 GardenH Dustin/rubbish bags 8 6 X 14 3 GardenH Products and systems for water saving/WC systems 13 X 0 13 3 GardenH Paints, varnishes and wood selant laquers 2 2 7 11 3 Recycle-rel Recycled plastic products 4 X 0 4 3 Services Towel rolls for use in towel dispersers 3 X 1 4 3 GardenH Wooden furniture 2 X 1 3 3 Miscellanous Fire-extinguishers, fire-extinguishing media X 0 3 3 3 Energy-rel Solar panels/collectors 0 X 2 2 3 GardenH Plastic sewer pipes/drain shafts 0 X 2 2 3
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Energy-rel Oilburners/boiler combinations 1 X 0 1 3 GardenH Hydralic fluids, rapidly biodegradable X X 1 1 3 Paper Products made of recycled paper X 0 X 3 Services Electricity supplies/Green electricity 1 72 72 2 Tourism Camp sites 12 56 68 2 Chemicaltech Soap and shampoos 7 49 56 2 GardenH Cat litter 13 1 14 2 Paper Nappies and similar products 3 9 12 2 Tourism Tourist accom 0 12 12 2 GardenH Shoppin bag 9 1 10 2 Energy-rel Special gas boilers X 8 8 2 GardenH Furniture 8 ? 8 2 GardenH Products of wood/wooden materials, low formaldehyde X 8 8 2 Energy-rel Heating boilers for gasous fuels with atmospheric burner 0 7 7 2 Miscellanous Vehicle tyres 5 1 6 2 GardenH Footwear 4 1 5 2 Office Organizers 4 1 5 2 Paper Coffie filters 5 X 5 2 Chemicaltech Cleaning agents, liquid 0 4 4 2 GardenH Bed mattres 4 X 4 2 Office PersComputer 0 2 X 0 4 2 Energy-rel Solid biomass fuels (biquettes,pellets) 2 1 3 2 GardenH Reusable bottles for beverages and liquid foodstuffs X 3 3 2 Miscellanous Batteries, rechargable 3 X 3 2 Paper Office paper X 3 3 2 Paper Recycled writing, copying and computer paper 2 1 3 2 Energy-rel TV-s 0 2 2 2 GardenH Textile floor coverings 1 1 2 2 Miscellanous Ice combatting agents 2 0 2 2 Services Car wash installations 2 X 2 2 Energy-rel Heating boilers for gasous fuels with preassured burner 0 1 1 2 Energy-rel Oilburners 1 0 1 2 GardenH Lubricants and forming oils 1 X 1 2 GardenH Masonry units 1 X 1 2 GardenH Office furniture X 1 1 2 Miscellanous Foam for fire-fighting systems 1 0 1 2
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Paper Hand dryers (paper) X 1 1 2 Energy-rel Boiler and water heater 0 X 0 2 GardenH Electronic based control-system for sanitary facilities X 0 0 2 GardenH Water and energy saving sanitary fittings X 0 0 2 Miscellanous Brake and clutch lining, asbetos-free 0 X 0 2 Miscellanous Recapped tires X 0 0 2 Office Cassettes/cartridges, returnable and recyclable X 0 0 2 Paper Go-for-the environments tickets X 0 0 2 Recycle-rel Packaging, returnably;plast,paper glass,metal/env. friendly 0 X 0 2 Energy-rel Low-emission atomizing oil burners X 1 Energy-rel Solar-energy products and mechanical watches X 1 GardenH Microfibrous cleaning material X 1 Tourism Tourism 168 168 1 Paper Printed matter 160 160 1 Services Grocer's shop 127 127 1 Tourism Hotels 32 32 1 Chemicaltech Stain removers 24 24 1 Services Paper recov 24 24 1 Tourism Bungalow parks 16 16 1 Paper Paper products 11 11 1 Paper Printing paper 11 11 1 Services End of life cars 11 11 1 Services Public transport 11 11 1 GardenH Concrete pavement tiles 10 10 1 GardenH Fertilisers for garden and indoor use 9 9 1 Miscellanous Batteries, primary 8 8 1 Tourism Service stations 8 8 1 GardenH Building board:chip-, fibre- and gypsum board 7 7 1 GardenH Concrete paving bricks 6 6 1 GardenH Concrete plinths 6 6 1 Paper Writing papers 6 6 1 Tourism Group accomodation 5 5 1 Tourism Youth accom 5 5 1 Chemicaltech Floor care products 4 4 1 GardenH Closed toilete systems 4 4 1 GardenH Flooring coverings 4 4 1
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Chemicaltech Wooden materials for indoor building purposes 4 4 1 Paper Paper labels 4 4 1 Paper Recycled paper and cardboard products 4 X 4 1 Services Goods transport 4 4 1 Energy-rel Closed fireplaces for biofuel 3 3 1 Energy-rel Hot-water boilers and local solid-fuel units 3 3 1 Office Writing instruments 3 3 1 Paper Publishing paper 3 3 1 Chemicaltech Carshampoo 2 2 1 Energy-rel Gas-fueled light and dark infra-red radiators 2 2 1 Energy-rel Wood-burning central heatings 2 2 1 GardenH Baths and shower stalls of steel enamel 2 2 1 GardenH Composters 2 2 1 GardenH Lawnmowers 2 2 1 GardenH Peat free culture substrates and soil improvers 2 2 1 Paper Adhesive labels 2 2 1 Paper Low pollutant printed products 2 2 1 Paper Paper and cardboard products 2 2 1 Chemicaltech Carwax 1 1 1 Chemicaltech Surfactant-based washing cosmetics 1 1 1 GardenH Anti corrosion agents for direct coating 1 1 1 GardenH Bottom organic household waste bin 1 1 1 GardenH Compostable material products 1 1 1 GardenH Compostable paperbags for biogenic waste 1 1 1 GardenH Container for used oil 1 1 1 GardenH Emulsifiers and dispersers of oil spills in water 1 1 1 GardenH Fire lighting material 1 1 1 GardenH Growing media 1 1 1 GardenH Industrial cleaning and degreasing agents 1 1 1 GardenH Kitchens 1 1 1 GardenH Lino 1 1 1 GardenH Matches free from toxic substances 1 1 1 GardenH Mirrors for domestic use 1 1 1 GardenH Office chairs X 1 1 1 GardenH Playground equipment 1 1 1 GardenH Resilient floor coverings 1 1 1
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GardenH Safety shoes 1 1 1 GardenH Thermal insulation made from used paper 1 1 1 GardenH Windows 1 1 1 Miscellanous Carbon dioxid from fermentation waste 1 1 1 Miscellanous Compostable flower arrangements and wreaths 1 1 1 Miscellanous Cork products and processed cork products 1 1 1 Miscellanous Liquids for circulating systems, 1 1 1 Miscellanous Ring binders 1 1 1 Office Filing systems made of recycled paper 1 1 1 Paper Grease proof paper 1 1 1 Paper Paper products for packaging 1 1 1 Recycle-rel Regenerated base oils and products incorporating them 1 1 1 Recycle-rel Returnable Containers, plastic 1 1 1 Recycle-rel Scrap products;paper,glass,plastic,rubber,wood 1 1 1 Recycle-rel Wrapping material of biodegradable plastics 1 1 1 Tourism Rural accom 1 1 1 energy-rel Lightsources 0 0 1 Energy-rel Solid biofuel boiler 0 0 1 GardenH Concrete buildingbricks and buildingblocks 0 0 1 GardenH Hard Floor Coverings 0 0 1 GardenH Playground equipment made of wood 0 0 1 GardenH Subfloors 0 0 1 GardenH Synthetic material/rubber cleanser (for cars) 0 0 1 GardenH Wallcoverings 0 0 1 GardenH Windowcleansers (carwindows) 0 0 1 Miscellanous Funeral equipment 0 0 1 Miscellanous Gas for fire-fighting systems 0 0 1 Miscellanous Leather products 0 0 1 Miscellanous Marine engines 0 0 1 Miscellanous Rimcleanser 0 0 1 Miscellanous Traffic acoustic screens 0 0 1 Office Port comput 0 0 1 Office Reprocessing of colour media 0 0 1 Office Writing materials 0 0 1 Recycle-rel Wast collection; paper,glass,plastic,metal,rubber,oil 0 0 1 Services Care products for carwash installations 0 0 1
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Miscellanous Noise barriers of wood X 1 Miscellanous Recycling services for acidic-lead batteries X 1 Miscellanous Salt-free abrasives X 1 Miscellanous Text markers, low-waste X 1 Miscellanous Zinc-air batteries X 1 Office Computer products X 1 Office Reprocessing of ink media ? 1 Office Telephone switchboards, electronic X 1 Paper Kitchen rolls X ? 1 Paper Newsprint for journals X ? 1 Paper Printing paper for newspaper X ? 1 Recycle-rel Building material made from recycled gypsum X 1 Recycle-rel Building material made from waste paper X 1 Recycle-rel Building materials made from recycled glass X 1 Recycle-rel Noise-absorbing waste-glass containers for noise-sensitive areas X 1 Recycle-rel Recycled waste rubber products X 1 Recycle-rel Returnable transportation packagings X 1 Services Cleaning services for soil contaminated X 1 Services Complex cleaning service, environmental sound X 1 Services Env sound pipe cleaners X 1 Chemicaltech Nail varnishes 0 0 Energy-rel Halogenfree cooling and insulating liquids f electric equ 0 0 Miscellanous Mobylettes 0 0 GardenH Closets 0 Miscellanous Bicycle tyres 0 Office Reprocessed photoconductive drums for laser printers 0 Services Water cleaners 0 Miscellanous Chain forms y Miscellanous Different kind of foodstuffs y Paper Fine paper ? Paper Offset paper y Paper TCF bleached paper for ink-jet and high perf printers ?