european legislation per - cinet legislati… · - guidance on bat for dry-cleaning is given in...

Professional Texti le Care

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Contents Page

1. How is the dry-cleaning regulated 4

1.1 European Legislation 41.2 Legislation system in Germany 51.3 Legislation system United Kingdom 61.4 Legislation system Italy 71.5 Legislation system Belgium 8

2. Does the regulation contain details on machines? 11

2.1 Specific Legislation regarding machinery 112.2 Specific machinery regulations in the UK 112.3 ECSA recommendations for cleaning machines 11

3. Perc restrictions in certain environments? 12

3.1 Environment restrictions of Perc in Europe 123.2 Perc Restrictions Germany 123.3 Perc restrictions UK 123.4 Perc restrictions Italy 133.5 Perc restrictions Belgium 133.6 Perc restrictions The Netherlands 14

4. Usage of Perc versus alternative solvents in europe 15

5. Is there any regulatory change expected soon? 15

6. Did Perc get any recent attention from media / NGO’s? 16

References (on request available at Cinet)

1. VOC Directive 1999/13/EC 2. E-DryClean information leaflet 3. E-DryClean: part of module 1 European Legislation 4. TKT Report: nr. 85120219 (2011) Toxilogical grounds for indoor air quality measurements, by ir. S. van der Burgh 5. Report 2011 ECSA: the European Chlorinated Solvent Association: Recommendations for Cleaning machines for the use of Chlorinated Solvents in dry-cleaning and surface-cleaning 6. Cinet: Benchmarkstudy, Professional Textile Cleaning (2012) 7. Cinet report PW/JS/991203116 (may 2012): Safe & Sustainable Processing in Professional Textile Cleaning (2012)

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1. How is the dry-cleaning regulated?

1.1. European Legislation

In Europe there is an overall tendency of following close the directives and developments in legislation within the European Community. Since more Eastern European countries became members of the European Community, it is expected that they also will follow these directives.

For Europe the VOC Directive 1999/13/EC is applicable (see reference 1). The most important element is the obligation to restrict the usage of Perc to less than 20 grams per kg. textile operated. Additionally important requirements are;

On a European scale detailed information and figures are available on the legislation of Perc related to environmental issues from studies Cinet carried out over the last years within the framework of international research projects and E-learning education and training materials like E-DryClean (see reference 2).

In Europe Germany has had a leading initiative as how to come to practical working methods to guarantee a safe and sustainable processing of Perc and other solvents. These were extensively discussed with all relevant government bodies, accepted and agreed upon over 20 years ago and still almost unchanged operational. Some ten years ago in other Northern European countries, the Scandinavian countries and The Netherlands, comparable agreements were discussed, agreed upon and laid down in legislation. General direction:

• Restrictemissionstolowerdimensions(forinstance:NL:<250µ-gram/m3 for neighbours inlivingareas,inworkingareas:<1050µ-gram/m3.• Installmechanicalventilationsystem.• Stimulatemachineimprovementstoover5th generation.• Preventsoilcontamination(leakagebasin).• RecyclingofPerc.• Educationofmanagementandstaff.

AREACHConsortiumhasregisteredamongstotherstheprofessionalusefofPerchloroethylene(perc)indrycleaning end of 2010. The use of perc in dry cleaning is under full regulatory compliance in Europe in the conditions set which will be secured under the perc evaluation in 2013 (regular process).The U.S. Environmental Protection Agency (EPA) and state regulations require safe handling and disposal of perc;formanyyears,ECSAhaspublishedanddistributedtodrycleanersabulletinentitled”TheSafeHandlingofPerchloroethyleneDryCleaningSolvent:BeyondRegulatoryCompliance.”EPAmandatethatpercdrycleanersshould not be co-located with residential buildings after 2020. This does not apply to stand-alone facilities. California is the only state that has phased out perc dry cleaning across-the-board (2023), althoug some cities have adopted perc bans.

The above requirements are the basis for the CINET initiative to lay down a proven sustainable processing with Perc and other solvents in a project: ”Best reference sustainable processing in dry cleaning”. Operation under this guideline and according to E-DryClean instructions and working methods guarantee a safe and sustainable processing in dry-cleaning shops, as currently operational in many countries in Europe and beyond worldwide. The vast amount of data and experience that is available for Perc does not excist to that extent of the alternative solvents, who’s potential health and environmental effects are largely unknown yet.At Cinet you can request a part of E-DryClean module 1 on European legislation (see reference 3).

ArecentDutchstudyoftheesteemedTNOResearchInstituterevealedevenatwotimesbetterperformanceover domestic cleaning (see reference 4).

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1.2. Legislation system in Germany

In Germany all experts from research institutes, governmental bodies, suppliers and associations have agreed a sustainable processing with solvents still effective today. Most important elements are:

Inventory of all relevant legislation related to prevention of soil contamination and solvent emissions.

There are regulations in place regarding• Soilandwaterprotection• Airprotection• Wasteandwastewatertreatmentordisposal• Waterregimelaw(WHG)• Wastewaterresourceordinance(AbwHerkV)• item9c:dry-cleaningandlaundry• Soilprotectionlaw(BodSchuG)• Lawregardingdetergentsandcleaningagents• Ordinanceondegradabilityofsurface-activesubstances• Ordinanceonmaximumphosphatequantity

Special legislation with regard to the solvents in use:• 2ndBImSchVforPER• 31stBImSchVforHCS

Degree of implementation of the European directive 1999/13/EC: 100% as 31st BImSchV.

State of the art technology applied with the divers solvents to enable the implementation of the divers directives.

Kind of machinery applied: PER,HCS(veryfewsiliconeandCO2)

Consumption of solvent and emission to the air per kg of treated textile:About 1% emission (legal threshold = 2%)

Consumption of chemical auxiliaries: Prespotting/spotting agents: 0,3% of 60.000 tons/year = 210 tDetergents: 2,0% = 1.400 tSizing/repellentagents: 0,5%= 350tFilter powder: 0,2% = 140 t

Restrictions with regard to waste water: TheFederalWaterActregulatesthewastewaterdisposal.

Types waste/contact water treatment:• Collectioninbarrelstobepickedupbycertifiedrecyclers.• In-housewastewatertreatmentsystemmonitoredbyauthority.

Method treating residue:Still bottoms, lint and cartridge filters are collected in barrels and picked up by certified recyclers.

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Measures to prevent soil contamination by the solvent:• Safetypan.• Closedfillingsystemforsolvent(Perconly).• Closedcleanoutsystemofstill(Perconly).

Storage of solvents and auxiliaries in the companies:Storage barrels and containers are placed in a safety pan.

TheFederalWaterActregulatesthewastewaterdisposal.

Measures in building and installation technology in use to comply with the legislation:• Workplacedirective. - size, height, windows, rest rooms, escape route.• Fireprotectionregulation. - sprinklers, storage of dangerous material.• 2.BImSchVforPerc.• 31.BImSchVforHCS. - full implementation of European directive 1999/13/EG.

Other environmental and sustainable aspects, such as water and energy consumption:• None.

1.3. Legislation system United Kingdom

• VOCdirectiveeffectivestarting2008.• PollutionPreventionandControlAct1999. -ImplementedthroughthePollutionPreventionandControlRegulations2000. - Implementation takes into consideration the principle of BAT – Best Available Technique.• NationallegislationBAT(BestAvailableTechnique). - The BAT approach requires that the cost of applying techniques is not excessive in relation to the environmental protection they provide. It follows that the more environmental damage BAT can prevent, the more the local authority can justify requiring the operator to spend on it before the costs are considered excessive. - Guidance on BAT for dry-cleaning is given in Process Guidance Note 6/46(04) – Secretary of State‘s Guidance for Dry Cleaning. - This note also inclues mandatory requirements contained in the EU Solvents Emissions Directive(SED). -TheDirectiveisbeingimplementedintheUKthroughthePollutionPreventionandControlRegulations 2000. - Guidance on BAT for dry-cleaning is given in Process Guidance Note 6/46(04) – Secretary of State‘s Guidance for Dry Cleaning.• AimofEnvironmentalPermittingRegime. - Protect the environment and human health. - Deliver permitting and compliance affectively and efficiently in a way that provides increased clarity and minimises the burden on both the regulator and the operators of facilities. - Encourage regulators to promote best practice in the operation. -ContinuetofullyimplementEuropeanLegislation.• Dry-CleaningisregulatednationallybyLAPPC. -LAPPCjustregulatesairemissions.

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Solvent consumption:• TheSED(SolventEmissionDirective)requiresthatdrycleaninginstallationsareoperatedinsuchamanner that no more than 20 grams of solvent per kilogram of product cleaned and dried shall be emitted as measured on an annual basis. • Monitoringthatisrequired: - Solvent input - Solvent losses - Mass of garments etc. cleaned

Storage of solvents:

Cleaning solvents not received in bulk shall be stored: - In the containers they were supplied in with the lid securely fastened at all times other than when in use; and -Withinspillagecollectors,ofsuitableimperviousandcorrosion-proofmaterialsandcapableofcontaining 100% of the largest container; and - Away from sources of heat and bright light; and -Withaccessrestrictedtoonlyappropriatelytrainedstaff;and - From a health and safety point of view; a well ventilated area should be used.

Filling of solvents into the machine: -Wherecleaningsolventsarenotreceivedinbulk,thelidsofthecontainersshallonlyberemovedwhenthe container is next to the cleaning machine ready for filling. - Cleaning solvents shall be obtained in containers of a size which allows the entire container to be emptied into the machine at each topping up. - Once emptied the lid of the container shall be replaced securely.

Solvent contaminated waste shall be stored: - In suitable sealed containers with the lid securely fasted at all times other than when in use; and - On a suitable impervious floor; and - Away from any drains which may become contaminated with residues as a result of spillage; and - Away from sources of heat and bright light; and -Withaccessrestrictedtoonlyappropriatelytrainedstaff;and - From a health and safety point of view: a well ventilated area should be used.

1.4. Legislation system Italy

Inventory of all relevant legislation with regard to the prevention of soil contamination and solvent emissions:

Therelevantlawisthe“D.lgs152/2006”:itisdividedin6parts:• PartIIIconcernssoilprotection;• PartVconcernsairprotection:herearereceiptedtheindicationsgivenintheVOCDirective.

New legislation to be expected in the near future: none.Special legislation with regard to the solvents in use: not present.

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Degree of implementation of the European directive 1999/13/EC: already receipted.State of the art technology applied with the diverse solvents to enable the implementation of the diverse directives.

Kind of machinery applied: Perc.

Consumption of solvent and emission to the air per kg of treated textile:

According to the law, consumption of solvent must be <20g/kg

Consumption of chemical auxiliaries: Info not available

Types of auxiliaries: A large variety of chemical auxiliaries is used: Deodorant essences, colour revitalizing, antistatic, softening, waterproofing, antifoaming, solvent stabilizing, pre-cleaners, strengthening, stain removing (pre-spotting), anti-bacterial

Restrictions with regard to waste water: Wastewaterisconsideredasdangerouschemicalwaste and must be properly treated

Types waste/contact water treatment: Wastewatermustbedeliveredtospecializedcompanies that can treat it

Method treating residue: Residuemustbedeliveredtospecializedcompaniesthat can treat it

Measures to prevent soil contamination by the solvent:

Safety tray under the machine, safety tray under the residues tanks and under the drums

Technical safety precautions: Safety tray under the drums;Concerning the solvent filling, in CE machines is possible to perform a filling procedure that reduce the risk of contact between operator and solvent;In some cases are used sealed systems provided by solventmanufacturers(forexampletheSAFE-TAINERsystem)

Measures to prevent solvent emissions to the working room:

Recentmachinesareequippedwith“dry-control”deviceand active carbon systems. The working room must be provided with adequate mechanical ventilation which takes solvent vapors away from the working room (10 air changes per hour)

1.5. Legislation system Belgium

Special legislation with regard to the solvents in use: • TiltelIIvanhetVlarem -Afdeling5.41.2.Inrichtingenvoorhetchemischreinigenvantextiel

Degree of implementation of the European directive 1999/13/EC: VLAREM:afterrevision.

New legislation to be expected in the near future:VLAREM:• ARAB:abolition• BBT:revisedin2009

State of the art technology applied with the diverse solvents to enable the implementation of the diverse directives.

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Kind of machinery applied:95%lastgenerationmachines:closedcircuit,chilling,doublewaterseparator,activecarbonfilter• PERC• Hydrocarbons• PropyleneGlycolether-based(Rynex,Impress)• Greenearth• LCO2• Wetcleaning(washing)

Consumption of solvent and emission to the air per kg of treated textile:

Flemish Environmental Permit Regulations:EmissionPERC:20g/kgcleanedtextile

Best available practices:EmissionHYDROCARBONS:5to10g/kgcleanedtextile

Consumption of solvent and emission to the air/ kg of treated textile:• Machinesmusthaveadeepcoolingsystemandanactivecarbonfilter• Anautomaticlockingsystemondoorandpinandlintfilters• PERconcentrationabovetextilesjusttakenfromthemachineshouldbelessthan240mg/m3, the dry cleaner must be able to prove this by a measurement report• Weeklyleakcontrolonthemachine• PipingforPERshouldbegastightandresistanttoPER

Types of auxiliaries:• water• detergents• soap• scrubbing• Trichloroethylene

Restrictions with regard to waste water:• Adoubleseparatorforcontactwaterisobligatory.• Nodirectconnectionbetweenasolventmachineandthesewagesystemisallowed.• Iftheflooroftheroomwheresolventmachinesareplaced,hasaconnection to the sewage system, this connection has to be hermetically closed during the dry cleaning process.

Types waste/contact water treatment:• Registeredenterprisesmusttreatandcollectresidueofdistillation.• Thestorageofmaximum200lofsolventcontainingsolidorliquidwasteisallowed.• Solventcontainingwastemustbestoredinairtight,solventresistantandinflammablecontainersinaleak collector with a volume at least equal to half the volume of the containers or, if that is more, the volume of the largest container.• Theleakcollectorshouldbeheatresistant,nonflammableandpersistenttothesolvent.

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Measures to prevent soil contamination by the solvent:• Everysolventmachineisplacedonaleakcollectorwithavolumeatleastequaltohalfthevolume of the solvent tanks in the machine or, if that is more, the volume of the largest solvent tank. • Theflooronwhichsolventmachinesareplacedhastobeliquidproofandliquidimpermeable (only for locations fully renovated after January 1st 2004).

Storage of solvents and auxiliaries in the companies:• Solvent,detergents,spottingagents,impregnationagentsandsoapsmustbestoredinorabove a leak collector with a volume at least equal to half the volume of the storage containers or if that is more the volume of the largest container.

Technical safety precautions:• Afillingindicatoronthedoor,solventtanksanddistillationunitisobligatory.• Adoubleoverboilingpreventiononthedistillationunitisobligatory.• Onlysolventfiltersthatcanberegeneratedareallowed.• Yearlycontrolandmaintenanceofthemachineisobligatory.• Thedrycleanermustbeabletoshowanofficialdocumentthathismachinecomplywiththe Vlarem-demands.

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2. Does the regulation contain details on machines?

2.1. Specific legislation regarding machinery

In general the focus of legislation is more and more on results and effects for instance emission levels, rather than on the tools and machinery. Nevertheless guidelines and specific requirements on tools (including administrative formats and documents) and machinery are applicable.• UK:Useofclosedcircuitmachines,fornewinstallationssecondarywatertreatmentandcarbon absorpsion, spillage tray with a volume greater than 110% of the volume of the largest single tank (see special UK legis).• Denmark:strictrequirementsonmechanicalventilationandmachinespecifications.• Sweden:useofseparateventilation.• Portugal:mechanicalventilation.• Serbia:mechanicalventilation.• Belgium:strictregulationsformachinery:closedsystem,leakcollector,doublewaterseparator.• Netherlands:leakbasin,mechanicalventilationandguidelinesonmachinespecifications.• Finland:closedsystemmachines,leakbasinandcarbonrecoverysystem.• Italy:Safetytrayunderthedrums,mechanicalventilation.

2.2. Specific machinery regulations in the UK

Machine technology:• Allmachinesinstalledafter19.5.2005shallhaveinterlockstopreventstart-upofthemachineuntil the loading door is closed and to prevent opening of the loading door until the machine cycle has finished and the cage has stopped rotating.• Allmachinesinstalledafter19.5.2009shallhaveinterlockstoautomaticallyshutdownthemachineunder any of the following conditions: cooling water shortage, failure of the cooling ability of the still condenser, failure of the cooling ability of the refrigeration system or failure in the machine heating system resulting in the inability to dry the load.• Allmachinesinstalledafter19.5.2009shallhaveinterlockstoautomaticallyshutdownthemachineifthe still, button trap or lint filter doors are not properly closed.• Thestillshallhaveathermostaticcontroldeviceorequivalentwithwhichtosetamaximumtemperature, in accordance with manufacturers’ recommendations for the solvent used.• Theheatswitchshallautomaticallyswitchoffattheendofthedistillationprocess.• Allmachinesinstalledafter19.5.2009shallhaveasecondarywaterseparatortominimizepotential solvent losses.

2.3. ECSA recommendations for cleaning machines

The European Chlorinated Solvent Association (ECSA) recommends for the use of Chlorinated Solvents in dry-cleaning to use 4th generation or higher machines. These machines are designed to fulfill the emission requirementsoftheEuropeanVOCDirective.Highergenerationsmachinesminimizeemissions,ensuresafehandling,transferandtake-backofthesolvent(seereference5).

New dry cleaning equipment is designed to minimize emissions. The newest of these machines clean over 600 pounds of clothes using one gallon of perc, a more efficient rate of ”solvent mileage” than alternative solvents. Many dry cleaners have installed vapor barriers to provide further safeguards.

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3. perc restrictions in certain environments?

3.1. Environment restrictions of Perc in Europe

On a European scale CINET study on the legislation of Perc from a revealed below data:

Perc- Concentration Inside neighbouring premises mg/m3

Perc- Concentration Outside neighbouring premises mg/m3

MAC8hrtwaMg/m3

Perc- Concentration Above textiles just removing from machine mg/m3

UK Not Applied Not Applied 340 Not Applied

Sweden Not Applied Not Applied 70 170

Denmark 0,1 0,01 7ppm Not Applied

Norway Not Applied Not Applied 6 Not Applied

Portugal Not Applied Not Applied Not Applied Not Applied

Greece 50 50 Not Applied 20-25

Serbia Not Applied Not Applied Not Applied Not Applied

Finland Not Applied Not Applied 8ppm 150ppm

Netherlands 0,25 0,25 138 340

Be. Flanders Not Applied Not Applied Unknown 240

Be. Brussels 50 10 Unknown Unknown

Be.Wallonia 50 Unknown Unknown 300

CzechRepublic 0,06 0,06 250 250

Romania Not Applied Not Applied 50 50

3.2. Perc Restrictions Germany

Measures to prevent solvent emissions to the working room: • Loadingdooropensonlyifconcentrationinbasket<2g/m3.• Airvolumeofworkroomhastobeexchanged5times/hour.• Exhaustductaboveroofridge.

Measures to prevent solvent emission to the neighbouring premises:• Ceilingandwallstobesealedwithaluminiumcoatedwallpaper.• Floortobepaintedwithspecialpaint.

3.3. Perc restrictions UK

• EnvironmentalPermittingRegimeisusedtoprotecttheenvironmentandhumanhealth.

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3.4. Perc restrictions Italy

Kind of machinery applied: Perc.

Measures to prevent solvent emission to the neighbouring premises:

Ventilation outlets must be suitably placed to avoid solvent fumes entering neighbouring premises.

Measures in building and installation technology in use to comply with the legislation:

In addition to the above mentioned machine features and ventilation features there are other measures intended for complying with Machinery Directive (mechanical hazards and all the other indicated hazards).


Recentmachinesareequippedwith“dry-control” device and active carbon systems The working room must be provided with adequate mechanical ventilation which takes solvent vapors away from the working room (10 air changes per hour).

3.5. Perc Restrictions Belgium

Measures to prevent solvent emissions to the working room: • Onlysolventfiltersthatcanberegeneratedareallowed.• Yearlycontrolandmaintenanceofthemachineisobligatory.• Thedrycleanermustbeabletoshowanofficialdocumentthathismachinecomplywiththe Vlarem-demands.

Measures to prevent solvent emission to the neighbouring premises:• ventilationtoexterior.• ventilationviaactivecarbonfilter.


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3.6. Perc restrictions The Netherlands

Since 2006 all companies that are using Perc have to prove by governmentally approved measurement techniques that they comply with the immission concentration restriction in closed part of sensitive neighbouring premisesof0,25mg/Nm3 as a weekly average. For neighbouring gardens, balconies, terraces etc the same maximumconcentrationofPER(0,25mg/Nm3) stands, however as yearly average. This value is increased dependingontheusageofneighbouringareasaccordingtoexposure.Reference4providesadetaileddescription of the exposure limits in these cases.

Emission concentrations neighbours dry cleaningshops the Netherlands:

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4. usage of perc versus alternative solvents in Europe

As far as the used dry-cleaning processes are concerned, CINET National Association members presented below figures as expert estimates for each country.

Country 2007 2010Perc Hydro Wet Others Perc Hydro Wet Others

Belgium 73 16 10 1 60 20 17 3Denmark 64 25 10 1 40 30 25 5Finland 80 6 14 0 80 6 14 0Germany - - - - - - - -Greece - - - - - - - -Netherlands 57 26 17 0 50 20 30 0Norway 80 18 2 0 60 38 2 0Sweden 79 5 15 1 78 5 15 2Romania 90 0 10 0 - - - -UK 80 5 0 15 70 5 0 25Italy 98 2 0 0 97 3 0 0CzechRepublic 98 2 0 0 - - - -

CertificationPerc is still by far the most important solvent in use. And will stay very important in the near future. In mature markets we can see, though slowly, a tendency towards other processes. In view of depreciation of machinery(>10-15years)thistakestime.Therefore in a growing number of countries there is more interest on safe and sustainable processing, which requires in many cases limited adjustments in working procedures, leakage basins, ventilation systems and measures for ceilings and walls, machine upgrade, inspections and administrative tools.These practices are laid down in the E-DryClean E-learning educational training materials, available in seven languages all over Europe. After completion of this study a National Certificate is granted according to international standards and agreements.

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5. is there any regulatory change expected soon?

The focus of governments on the environmental impact of the application of Perc in dry-cleaning in Europe has not resulted in major changes in regulations over the last years as shown also in this documents. In some countriesmorestringentregulationsandsectoragreementshavebeenadopted25/15yearsago(Germany,Scandinavian countries, The Netherlands, etc). All parties have accepted the practical situation and the focus is on the control of the implementation of these requirements and measures. There have been no reports of new discussions to extra / new more severe regulations. In Belgium currently an evaluation is ongoing.

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6. Did perc get any recent attention from media / ngo’s?

There are no reports of attention of media / NGO’s except for France. In other countries the overall situation is that drycleaners and associations demonstrate more awareness and attention for sustainable processing and invest step by step in more advanced machinery and appropriate working procedures and cleaning processes.

Demonstrating sustainable processing and adopting Certification (Germany and The Netherlands) have proven to be excellent measures to convince the general public opinion and governments.

The results of recent benchmark studies, like that of the Dutch TNO, claiming that on an average professional textile cleaning is up to three times better for the environment as domestic cleaning are supporting these views (see reference 6).

AbovethattheCINETinitiativetocompilea“BestReferenceStandardonSafe&Sustainableprocessesofprofessional Textile Cleaning” for dry-cleaners supported by experts world wide is expected to provide a better understanding of the durability of the sector for now and in the future (see reference 7).

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european legislation per - cinet legislati… · - guidance on bat for dry-cleaning is given in...

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