laundry detergents and stain removers · laundry detergents and stain removers 4 . a) the...

About Nordic Swan Ecolabelled Laundry Detergents and Stain Removers

Draft for consultation 1 April 2019 – 14 April 2019 Proposal for requirements within the third sub process: Sustainable renewable raw materials and microplastics

Content Introduction to the public consultation process .................................................................. 3 What can carry the Nordic Swan Ecolabel ........................................................................ 4

1. Sustainable renewable raw materials ..................................................................... 4 O1 Sustainable raw materials .......................................................................... 4

O2 Certified raw materials from oil palms ........................................................ 5 2. Requirements for constituent substances .............................................................. 6

O3 Prohibited substances ................................................................................ 6

Appendix 2 Declaration from the producer of the laundry detergent or stain remover Appendix 3 Declaration from the manufacturer of the raw material / ingredient

006 Laundry Detergents and Stain Removers, 01 April 2019

Addresses

In 1989, the Nordic Council of Ministers decided to introduce a voluntary official ecolabel, the Nordic Swan Ecolabel. These organisations/companies operate the Nordic Ecolabelling system on behalf of their own country’s government. For more information, see the websites: Denmark Ecolabelling Denmark Fonden Dansk Standard Göteborg Plads 1, DK-2150 Nordhavn Fischersgade 56, DK-9670 Løgstør Tel: +45 72 300 450 [email protected] www.ecolabel.dk

Finland Ecolabelling Finland Urho Kekkosen katu 4-6 E FI-00100 Helsingfors Tel: +358 9 61 22 50 00 [email protected] www.ecolabel.fi

Iceland Ecolabelling Iceland Norræn Umhverfismerking á Íslandi Suδurlandsbraut 24 IS-108 Reykjavik Tel: +354 591 20 00 [email protected] www.svanurinn.is Norway Ecolabelling Norway Henrik Ibsens gate 20 NO-0255 Oslo Tel: +47 24 14 46 00 [email protected] www.svanemerket.no

Sweden Ecolabelling Sweden Box 38114 SE-100 64 Stockholm Tel: +46 8 55 55 24 00 [email protected] www.svanen.se

This document may only be copied in its

entirety and without any type of change.

It may be quoted from provided that Nordic Ecolabelling is stated

as the source.

http://www.svanurinn.is/

006_Delremiss_III_Rawmaterials_Microplastics 2019-03-29 3 (15)

Introduction to the public consultation process The consultation on reviewing the criteria for Laundry detergents and stain removers is divided into three sub processes, each dealing with a specific topic in three individual consultation periods.

The three individual topics are:

1. Packaging and recycling 2. Correct dosing, ecotoxicity and efficiency 3. Sustainable and renewable raw materials and microplastics (current

consultation)

After the three consultation periods, Nordic Ecolabelling drafts a proposal for criteria for Laundry detergents and stain removers, based on new information, for a final public consulting period.

This criteria document holds a proposal for requirements within the third sub process: Sustainable and renewable raw materials and microplastics.

Note that the numbering of the requirements is not final and will change in the final proposal.

Nordic Ecolabelling 006/Consultation part III 01 April 2019

Laundry Detergents and Stain Removers 3

What can carry the Nordic Swan Ecolabel? The product group Laundry detergents and stain removers encompasses laundry detergents and stain removers in powder, tablets, liquids, gel or any other form. The products shall be used for washing of textiles, and are intended to be used in household machines, but not excluding the use in launderettes and common laundries.

The product group does not comprise products that are exclusively used for handwashing or products that are dosed via carriers such as sheets, cloths or other materials. Nor does it comprise fabric softeners or multiple function detergents such as “2 in 1” products with both detergent and fabric softening effects/claims.

Products for professional laundries cannot be ecolabelled according to this criteria document. However, Nordic Ecolabelling has specific criteria for Laundry detergents for professional use.

1 Sustainable renewable raw materials The requirements below are very similar to those in Cleaning products and Hand dishwash detergents, generation 6, that were published in 2018.

Nordic Ecolabelling would like your opinion on whether it would be possible to go further than this. For example:

• Require RSPO segregated or identity preserved only, and not acceptingmass balance level

• Require RSPO NEXT

If this is not possible yet, we would like to have your estimate on when it might be possible.

O1 Sustainable raw materials 1. The licence holder must document that they are working to increase their

purchasing of sustainable and renewable raw materials or that they requiretheir manufacturer to work on increasing their purchasing of sustainablerenewable raw materials for Nordic Swan Ecolabelled laundry detergentsand stain removers. This can for example be done by promoting certified rawmaterials, by avoiding problematic raw materials or by changing from fossilbased raw materials to sustainable raw materials. The targets must bequantitative and time-based, and they must be set by the company’smanagement.Renewable raw materials are defined as raw materials from biologicalmaterial which are continuously renewed in nature within a short time span,for example grain and wood (European standard EN16575:2014).

2. The following data is required for each organic raw material/ingredient in theNordic Swan Ecolabelled laundry detergent or stain remover:



a) The proportion of the raw material/constituent part of the rawmaterial/ingredient that comprises renewable raw material or originatesfrom renewable raw material, calculated on an annual basis.The calculation of the proportion of the renewable material can be doneusing the following formula:Used amount renewable material / (used amount renewable material +used amount non-renewable material) x 100%Amounts in kg, molar weight or carbon atoms can be used in thecalculation. Average carbon chain lengths can be used.

b) What does the renewable raw material consist of (e.g. palm oil, coconutoil, grape seed oil, beeswax)?

c) Does the renewable raw material have any sustainability certification?If yes, state which and at what level of traceability (No Traceability,Identity Preserved, Segregated, Mass Balance, Book & Claim)?

1. Policy or equivalent documentation of the licence holders work for renewableand sustainable materials in Nordic Swan Ecolabelled products, includingquantitative, time-based targets and set by management.

2. Appendix 3 from the raw material supplier.

Background O1 Sustainable raw materials Laundry detergents and stain removers use constituent substances from both renewable and non-renewable organic raw materials. In addition, there are minerals (inorganic raw materials) as parts of organic raw materials, and e.g. in pigments.

The renewable base materials used in laundry detergents and stain remowers are usually various oils and fats, which are subsequently turned into e.g. surfactants and emulsifiers.

Renewable raw materials are defined here as both vegetable raw materials and animal raw materials. This includes for example palm oil, coconut oil, rapeseed oil and beeswax.

In general, Nordic Ecolabelling is working to promote renewable raw materials over fossil raw materials

The requirement on sustainable raw material procurement is the same as in generation 6 cleaning products and hand dishwash detergents. The concrete, measurable and time-based targets concerning their purchasing of sustainable raw materials can be done, for example, by promoting certified raw materials, by avoiding problematic materials or by changing from fossil raw materials to sustainable renewable raw materials. The requirement is written so that the policy required is on the Nordic Swan Ecolabelled products and not on the entire company, since the Nordic Swan Ecolabel is a product label, i.e. not labelling entire companies. The Nordic Ecolabel may however acknowledge the policy on a company level.

The goal of the requirement is to give the laundry detergent and stain remover manufacturers more of a focus on the origin of the raw material and associated certification schemes and to sharpen their focus on renewable raw materials when they are selecting and purchasing raw materials in their everyday



operations. It is therefore expected that the proportion of renewable raw materials in Nordic Swan Ecolabelled laundry detergents and stain removers will continue to increase during the lifetime of the criteria. The knowledge that Nordic Ecolabelling acquires via this documentation will also make it possible to set specific requirements concerning the content of renewable raw materials in later revisions.

O2 Certified raw materials from oil palms Palm oil, palm kernel oil and palm oil/palm kernel oil derivatives must be certified according to RSPO. Mass Balance, Segregated or Identity Preserved are accepted as traceability systems. The requirement does not include raw materials < 1% in the final product.

Information from raw material producer, where palm oil, palm kernel oil or palmoil or palm kernel oil derivatives are included in the raw material, Appendix 3can be used.

A valid RSPO CoC certificate from raw material producer.

The manufacturer of the Nordic Swan Ecolabelled product must show by rawmaterial producer's invoices/delivery notes that the palm oil purchased is certifiedand information about traceability system (Mass Balance, Segregated or IdentityPreserved accepted).

Background O2 Certified raw materials from oil palms In addition to the policy requirement on sustainable raw materials (O3), special attention is paid to palm oil which raises concerns on e.g. land use. Palm oil is difficult to avoid in laundry detergents and stain removers since many surfactants are palm oil and palm kernel oil derivatives. One way to reduce the negative effects of the increasing use of palm oil products (e.g. rain forest destruction and unsustainable farming) is to increase the proportion of certified sustainable crops.

Nordic Ecolabelling sets general requirements for raw material labels that are used in our criteria documents, and at the current time, RSPO1 do not fully meet them. Generally, the standard provides too poor protection for important biological areas since it is among other things permitted to establish plantations on peat bogs, which are important carbon sinks. However, in product groups where there is a lack of better alternatives and no steerability for Nordic Ecolabelling to avoid palm oil, Nordic Ecolabelling sets as stringent requirements as possible. This means requiring RSPO certified raw materials, with its associated traceability systems.

Other ecolabels such as the EU Ecolabel2, The Swedish Good Environmental Choice (Bra Miljöval)3 and Australia’s Good Environmental Choice4 also set

1 Roundtable on Sustainable Palm Oil (RSPO) https://rspo.org/ (5 March 2019) 2 Commission Decision (EU) 2017/1218 of 23 June 2017 establishing the EU Ecolabel criteria for laundry detergents https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017D1218&from=EN (7 Feb 2019) 3 Swedish Society for Nature Conservation - Good Environmental Choice Chemical products Criteria 2018:1 https://www.naturskyddsforeningen.se/sites/default/files/dokument-media/Criteria_Bra_Miljoval_Chemical_Products_2018-1_20181125_0.pdf (7 Feb 2019) 4 Good Environmental Choice Australia Standard, Cleaning Products, Standard No: CPv2.2ii-2012, Issued: 6 July 2017, http://www.geca.eco/standards/cleaning-products-standard-cpv2-2ii-2012/ (5 March 2019)

https://rspo.org/

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017D1218&from=EN

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017D1218&from=EN

https://www.naturskyddsforeningen.se/sites/default/files/dokument-media/Criteria_Bra_Miljoval_Chemical_Products_2018-1_20181125_0.pdf

https://www.naturskyddsforeningen.se/sites/default/files/dokument-media/Criteria_Bra_Miljoval_Chemical_Products_2018-1_20181125_0.pdf

http://www.geca.eco/standards/cleaning-products-standard-cpv2-2ii-2012/



requirements on the proportion of sustainable palm oil and palm kernel oil derivatives in Laundry detergents.

The cut off limit of 1% is set in order to reduce the burden of documentation and focus on the raw materials that are present at higher percentages (typically surfactants and solvents).

Requirement is the same as in generation 6 cleaning products and hand dishwash detergents, but the documentation of requirement has been made clearer.

Certification requirement is not set for other renewable raw materials since they are either less relevant in laundry detergents (soy5 or sugar6) or there are not yet sustainability standards (coconut).

2 Requirements for constituent substances Note that this is a draft and so far only microplastics have been added to this list. The final consultation in August will contain the complete list. All substances that are prohibited in the current Laundry Detergents and Stain removers criteria (version 7.10) can be expected to still be prohibited.

O3 Prohibited substances The following substances are excluded from use in the product: • Microplastics** Microplastics are defined according to ECHAs working definition as of 11January 2019: material consisting of solid polymer-containing particles, to whichadditives or other substances may have been added, and where ≥ 1% w/w ofparticles have (i) all dimensions 1nm ≤ x ≤ 5mm, or (ii), for fibres, a length of3nm ≤ x ≤ 15mm and length to diameter ratio of >3. Polymers that occur innature that have not been chemically modified (other than by hydrolysis) areexcluded, as are polymers that are (bio)degradable

A duly completed and signed declaration of compliance with the requirement,Appendix 2 or similar documentation for the product, Appendix 3 or similarsigned documentation for the raw materials.

Background to requirement O3 Prohibited substances Microplastics

ECHA's current working definition is used in the criteria.7 The Nordic Ecolabelling will continue to follow the work done in EU on microplastics and the microplastic definition and may come to update the definition in the criteria if a new definition is accepted in EU.

5 The Round Table on Responsible Soy http://www.responsiblesoy.org/?lang=en (5 March 2019) 6 Bonsucro https://www.bonsucro.com/ (March 5 2019) 7 Annex XV restriction proposal for Intentionally added microplastics, Version number: 1, 11 January 2019, https://echa.europa.eu/documents/10162/82cc5875-93ae-d7a9-5747-44c698dc19b6

http://www.responsiblesoy.org/?lang=en

https://www.bonsucro.com/

https://echa.europa.eu/documents/10162/82cc5875-93ae-d7a9-5747-44c698dc19b6



According to DG Environment report8 190-200 tonnes/year of microplastics are thought to be used in soaps, detergents and maintenance products. Plastics used are for example polyester, polyurethane, and PMMA. Microplastics can according to the report be used as e.g. rheology modifiers and enzyme encapsulation (30- 5000µm). Anti-redeposition agents are often polymers and can therefore be microplastics.

When microplastics are rinsed down the drain, they often end up in the sludge, but they also pass through the treatment plants.9 If the particles then continue on to lakes and seas, they are taken up by mussels, fish and other animals, which may be harmful.10 Some microplastics are then gradually broken down to even smaller particles by sunlight. They can also absorb harmful substances. There is however a lack of knowledge of fate and effects of microplastics. Since they are non-degradable and potentially harmful precautionary principle is used and microplastics are excluded even though microplastics from laundry detergents are a small part of the microplastics problem. Laundry detergents are also covered by ECHAs proposal for restriction11.

Note that foils/films wrapping tablets and other such products releasing microplastics are not allowed in Nordic Swan Ecolabelled products.

This is a new requirement that was not included in the preceding generation.

8 European Commission (DG Environment), Intentionally added microplastics in products Final report, http://ec.europa.eu/environment/chemicals/reach/pdf/39168%20Intentionally%20added%20microplastics%20-%20Final%20report%2020171020.pdf, October 2017 9 Miljøstyrelsen, Environmental Project No. 1906 Microplastic in Danish wastewater Sources, occurrences and fate, 2017, http://www2.mst.dk/Udgiv/publications/2017/03/978-87-93529-44-1.pdf 10 Annex XV restriction proposal for Intentionally added microplastics, Version number: 1, 11 January 2019, https://echa.europa.eu/documents/10162/82cc5875-93ae-d7a9-5747-44c698dc19b6 11 Annex XV restriction proposal for Intentionally added microplastics, Version number: 1, 11 January 2019, https://echa.europa.eu/documents/10162/82cc5875-93ae-d7a9-5747-44c698dc19b6

http://ec.europa.eu/environment/chemicals/reach/pdf/39168%20Intentionally%20added%20microplastics%20-%20Final%20report%2020171020.pdf

http://ec.europa.eu/environment/chemicals/reach/pdf/39168%20Intentionally%20added%20microplastics%20-%20Final%20report%2020171020.pdf





Appendix 2 Declaration from the producer of the laundry detergent or stain remover

Note that this appendix is a draft and consists so far only the requirements on this and previous sub consultations.

To be used in conjunction with an application for a licence for the Nordic Swan Ecolabelling of laundry detergents and stain removers. To complete the following declaration, you will need declarations for all raw materials (Appendix 3 or equivalent declaration).

This declaration is based on the knowledge we have at the time of the application, based on tests and/or declarations from raw material manufacturers, with reservations for new advances and new knowledge. Should such new knowledge arise, the undersigned is obliged to submit an updated declaration to Nordic Ecolabelling.

Product name(s): _____________________________________________________________

Product type

___________________________________________________________________________

Ingoing substances and impurities are defined below, unless stated otherwise in the requirements

• Ingoing substances: all substances in the Nordic Swan Ecolabelledproduct, including additives (e.g. preservatives and stabilisers) in the rawmaterials. Substances known to be released from ingoing substances (e.g.formaldehyde, arylamine, in situ-generated preservatives) are alsoregarded as ingoing substances.

• Impurities: residuals, pollutants, contaminants etc. from production, incl.production of raw materials that remain in the raw material/ingredientand/or in the in the Nordic Swan Ecolabelled product in concentrationsless than ≤100,0 ppm (≤0,01000 weight percent, ≤100,0 mg/kg) in theNordic Swan Ecolabelled product.

• Impurities in the raw materials exceeding concentrations ≥10000 ppm(≥1,0000 weight percent, ≥10000 mg/kg) are always regarded as ingoingsubstances, regardless of the concentration in the Nordic SwanEcolabelled product.

Examples of impurities are residues of the following: residues or reagents incl. residues of monomers, catalysts, by-products, scavengers, and detergents for production equipment and carry-over from other or previous production lines.



Does the product contain microplastics*? * Micrplastics are defined according to ECHAs working definition as of 11 January 2019:material consisting of solid polymer-containing particles, to which additives or othersubstances may have been added, and where ≥ 1% w/w of particles have (i) alldimensions 1nm ≤ x ≤ 5mm, or (ii), for fibres, a length of 3nm ≤ x ≤ 15mm and length todiameter ratio of >3. Polymers that occur in nature that have not been chemically modified(other than by hydrolysis) are excluded, as are polymers that are (bio)degradable

Yes No

Does the product contain substances classified as environmentally hazardous with H410, H411 and H412, incl self-classifications in the ECHA database?

Yes No

If yes, state the amount (% by weight) per classification:

___________________________________________________________________

If the answer to any of the above questions is Yes, state the CAS no. (where possible), chemical name and level (in ppm, % by weight or mg/kg). Also state whether the substance is contained in the form of an impurity or an added substance.

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

In the event of any change to the composition of the product, a new declaration of fulfilment of the requirements is to be submitted to Nordic Ecolabelling.

Place and date Company name/stamp

Responsible person: Signature of responsible person

Telephone Email



Appendix 3 Declaration from the manufacturer of the raw material / ingredient

Note that this appendix is a draft and consists so far only the requirements on this and previous sub consultations

To be used in conjunction with an application for a licence for the Nordic Ecolabelling of cleaning products.

This declaration is based on the knowledge we have at the time of the application, based on tests and/or declarations from raw material manufacturers, with reservations for new advances and new knowledge. Should such new knowledge arise, the undersigned is obliged to submit an updated declaration to Nordic Ecolabelling.

Name of the raw material/ingredient:

______________________________________________________________________

Function of the raw material/ingredient:

______________________________________________________________________

Please note that the information in this declaration is internally shared with certification personnel in Nordic Ecolabelling to be used in evaluation of applications of chemical technical products.

Ingoing substances and impurities are defined below, unless stated otherwise in the requirements

• Ingoing substances: all substances in the Nordic Swan Ecolabelledproduct, including additives (e.g. preservatives and stabilisers) in the rawmaterials. Substances known to be released from ingoing substances (e.g.formaldehyde, arylamine, in situ-generated preservatives) are alsoregarded as ingoing substances.

• Impurities: residuals, pollutants, contaminants etc. from production, incl.production of raw materials that remain in the raw material/ingredientand/or in the in the Nordic Swan Ecolabelled product in concentrations<100,0 ppm (<0,01000 weight percent, <100,0 mg/kg) in the Nordic SwanEcolabelled product.

• Impurities in the raw materials exceeding concentrations of ≥ 10000 ppm(≥ 1,0000 weight percent, ≥ 10000 mg/kg) are always regarded as ingoingsubstances, regardless of the concentration in the Nordic SwanEcolabelled product.

Examples of impurities are residues of the following: residues or reagents incl. residues of monomers, catalysts, by-products, scavengers, and detergents for production equipment and carry-over from other or previous production lines.

Note that if the raw material contains impurities listed in this appendix, write the amount at the end of the appendix. The manufacturer of the Nordic Swan



Ecolabelled product is responsible for calculating compliance with the requirements of the criteria.

Part 1 – General requirements (applies to all raw materials)

Does the raw material contain microplastics*? * Micrplastics are defined according to ECHAs working definition as of 11 January 2019:material consisting of solid polymer-containing particles, to which additives or othersubstances may have been added, and where ≥ 1% w/w of particles have (i) alldimensions 1nm ≤ x ≤ 5mm, or (ii), for fibres, a length of 3nm ≤ x ≤ 15mm and length todiameter ratio of >3. Polymers that occur in nature that have not been chemically modified(other than by hydrolysis) are excluded, as are polymers that are (bio)degradable

Yes No

Does the raw material/ingredient contain substances classified as environmentally hazardous with H410, H411 and H412, incl self-classification in the ECHA database?

Yes No

If yes, state the amount (% by weight) per classification:

______________________________________________________________________________________________

If the answer to any of the above questions is Yes, state the CAS no. (where possible), chemical name and level (in ppm, % by weight or mg/kg). Also state whether the substance is contained in the form of an impurity or an added substance.

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

Are renewable raw materials used in the raw material/ingredient?

Yes No



Part 2 - Only to be used if a raw material/ingredient contains renewable raw materials

List the renewable raw materials used (e.g. palm oil, coconut oil, rapeseed oil, beeswax) and the amount in % on a yearly basis:

PLEASE ONLY ONE RENEWABLE RAW MATERIAL PER LINE

Origin of renewable raw material in the raw material/ingredient (e.g. palm oil, coconut oil, rapeseed oil, beeswax, etc)

Amount of the renewable raw material (weight percent) in the raw material/ingredient on a yearly basis The calculation of the proportion of the renewable material can be done using the following formula: Used amount renewable material / (used amount renewable material + used amount non-renewable material) x 100% Amounts in kg, molar weight or carbon atoms can be used in the calculation. Average carbon chain lengths can be used. State how the calculation has been done.

Renewable raw material 1 Renewable raw material 2 Renewable raw material 3 Renewable raw material 4 Renewable raw material 5 Total amount (weight percent) of renewable raw materials in the raw material / ingredient:

For each renewable raw material in the raw material / ingredient, the following data is to be completed.

Renewable raw material 1 (e.g. palm oil or coconut oil or rapeseed oil or beeswax):

__________________________________________________________________________________________ Name of the supplier if stated: __________________________________________________________________

Is the renewable raw material sustainability certified? Yes No If yes, please state the raw material sustainability certification system: __________________________________________________________________________________ If a raw material sustainability certification system is used, state the level of traceability (shown in a Chain of Custody certificate where applicable) No traceability Identity preserved Segregated

Mass balance Book & Claim



Renewable raw material 2 (e.g. palm oil or coconut oil or rapeseed oil or beeswax): __________________________________________________________________________________________

Name of the supplier if stated: __________________________________________________________________ Is the renewable raw material sustainability certified? Yes No If yes, please state the raw material sustainability certification system: __________________________________________________________________________________ If a raw material sustainability certification system is used, state the level of traceability (shown in a Chain of Custody certificate where applicable)

No traceability Identity preserved Segregated Mass balance Book & Claim

Renewable raw material 3 (e.g. palm oil or coconut oil or rapeseed oil or beeswax): __________________________________________________________________________________________ Name of the supplier if stated: __________________________________________________________________

Is the renewable raw material sustainability certified? Yes No If yes, please state the raw material sustainability certification system: __________________________________________________________________________________ If a raw material sustainability certification system is used, state the level of traceability (shown in a Chain of Custody certificate where applicable) No traceability Identity preserved Segregated Mass balance

Book & Claim


Name of the supplier if stated: __________________________________________________________________ Is the renewable raw material sustainability certified? Yes No If yes, please state the raw material sustainability certification system: __________________________________________________________________________________ If a raw material sustainability certification system is used, state the level of traceability (shown in a Chain of Custody certificate where applicable) No traceability

Identity preserved Segregated Mass balance Book & Claim




Name of the supplier if stated: __________________________________________________________________ Is the renewable raw material sustainability certified? Yes No If yes, please state the raw material sustainability certification system: __________________________________________________________________________________ If a raw material sustainability certification system is used, state the level of traceability (shown in a Chain of Custody certificate where applicable) No traceability Identity preserved

Segregated Mass balance Book & Claim

In the event of any change to the composition of the product, a new declaration of fulfilment of the requirements is to be submitted to Nordic Swan Ecolabelling.

Place and date

Raw material producer Company name/stamp

Responsible person Signature of responsible person electronic signature is accepted

Telephone Email

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