revision of ecolabel criteria for laundry detergents

DraftMay 2002

European Eco-label

Revision of Eco-label criteria forLaundry Detergents

Background report

Prepared byDHI Water & Environmentdk-TEKNIK ENERGY & ENVIRONMENT

European Eco-labelRevision of Eco-label criteria for laundryDetergents

Background report

Agern Allé 11DK-2970 Hørsholm, Denmark

Tel: +45 4516 9200Fax: +45 4516 9292e-mail: [email protected]: www.dhi.dk

Client Client’s representative

Project

European Eco-labelRevision of Eco-label criteria for laundry detergents

Project No.

51503

Date2002.07.04

Authors

Torben Madsen (DHI)Heidi Stranddorf (dk-TEKNIK) Approved by

01 Draft report

Revision Description By Checked Approved Date

Key words Classification

Open

Internal

Proprietary

Distribution No. of copies

DHI: TMA/ECOTOX/Arkivdk-TEKNIK ENERGY & ENVIRONMENT

ECOTOX/2002.07.04 i

CONTENTS

1 INTRODUCTION...........................................................................................................1

2 MARKET REVIEW ........................................................................................................12.1 Consumption of laundry detergents in Europe...............................................................22.2 Product group definition.................................................................................................3

3 MARKET OF ECO-LABELLED LAUNDRY DETERGENTS...........................................33.1 Product tests .................................................................................................................43.2 Future promoting of eco-labelled products.....................................................................43.3 Actions at several levels ................................................................................................5

4 CURRENT ECOLOGICAL CRITERIA AND SUGGESTED CHANGES .........................64.1 Summary of the current criteria .....................................................................................64.2 Proposed revised criteria...............................................................................................64.2.1 Total chemicals .............................................................................................................74.2.2 Insoluble inorganic ingredients ......................................................................................84.2.3 Phosphates ...................................................................................................................84.2.4 Toxicity to aquatic organisms ........................................................................................94.2.5 Biodegradability of surfactants.....................................................................................104.2.6 Dangerous, hazardous or toxic substances or preparations ........................................13

5 PERFORMANCE TEST ..............................................................................................16

6 OTHER CRITERIA ......................................................................................................176.1 Criteria on product packaging......................................................................................176.2 Consumer information .................................................................................................18

APPENDIX

A Appendix A: QuestionnaireB Appendix B: Performance test protocol

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1 INTRODUCTION

The European Commission has authorised the Danish competent body with their part-ners to update the eco-label criteria for laundry detergents. The former criteria are laiddown in Commission Decision 1999/476/EC and according to this Decision, the periodof validity of the product group criteria shall be three years. Thus, the criteria for thelaundry detergents have to be revised before June 2002. This will, however, probably beby September 2002.

This is the background report based on the material sent prior to the first and second AdHoc Working Group meetings including a market survey, an evaluation and proposalsfor revised set of the ecological criteria and the criteria for packaging. Input given dur-ing the process (meetings and in written or oral form in between) are considered and in-cluded whenever possible. Thus, chapter 2 of this background report presents the mar-ket review, including a revised product group definition. Chapter 3 presents centralconsiderations regarding eco-labelled products and possibilities and threats of gettingmore so. A threat that can be overcome in future is the price of performance test of theproducts, while especially well performing (relatively cheap) products is generally seenas a possibility for increasing market share. Other possible future marketing steps ofeco-labelled products are also indicated. Chapter 4 describes the ecological criteria.That includes a presentation of the existing and the revised criteria structure. For each ofthe specific criteria some of the key considerations and discussions are presented fol-lowed by a presentation of the current criteria and a proposal for a new criterion. Fur-thermore, the chapter presents a procedure for documentation of anaerobic degradabilityof surfactants as this requirement is new for laundry detergents. Chapter 5 presents therequirements to the wash performance test. Chapter 6 presents criteria for packagingand the wording on the packaging when eco-labelled products are marketed. AppendixA is the questionnaire used from the marked survey. Appendix B is the performance testprotocol.

2 MARKET REVIEW

As part of the work on revision of the criteria, a questionnaire was been sent to theEUEB and the Commission, national eco-label competent bodies, consumer and com-mercial organisations and other relevant parties. The questionnaire is included in thisreport as Appendix A.

Twenty answers were received, distributed as follows:

• Competent bodies: 6• Manufacturers: 8• Organisations: 5• Other stakeholders: 2

The inputs received on proposals for revision of the criteria as well as related to marketissues are integrated in this report.

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2.1 Consumption of laundry detergents in Europe

AISE, the international detergent and maintenance products industry, has not publishedany new statistics on the use of laundry detergents since 1996 (see Table 2.1). Thesestatistics show the consumption of laundry detergents in Europe in 1994 and 1995. InTable 2.1, the statistics covering the Danish consumption of laundry detergents from1998 to 2000 [The Association of Danish Cosmetics, Toiletries and Detergent Industries(SPT), October 2001] are used for estimating the consumption in 1998 and 2000 inEurope. Table 2.2 describes coarse estimates of the annual consumption of major sur-factants in laundry detergents for Europe.

Table 2.1 Estimated annual consumption of laundry detergents (Consumer Products – Fabricwashing) for Europe

19953 1998 2000Laundry detergents tons/year tons/year tons/yearPowders 3,400,000 3,600,000 4,200,000Liquids 550,000 620,000 780,000Auxiliary products1 100,000 100,000 93,000Fabric rinse products 2 1,100,000 950,000 950,000

1 Includes a.o. soaking product, stain removers, precursors, water softeners2 Fabric rinse products – all forms. Also known as fabric conditioners and softeners3 AISE, 1996. 1994/1995 Statistical Tables. June 1996.

The estimate indicates that both the amounts of powders and liquids are increasing. Theauxiliary and fabric rinse products are slightly declining or are the same. Through thenineties the trends in Europe have generally been towards an increase of the use ofhighly concentrated solid products – powders or single-load tablets called compacts orsuper compacts [Morse, P.M. 1999. Chemical & Engineering News. February 1999].The annual consumption of powders increases slowly whereas the consumed amountsof liquids increase rapidly. In the U.S., the liquids have continued to gain market sharesfrom the powders through the nineties. In Europe, the liquid use had generally been flator slowly declining in most countries with use levels estimated at 12 to 15%.

Table 2.2 Estimated annual consumption of major surfactants in laundry detergents forEurope

Surfactant tons/year (in 2000)Linear alkylbenzene sulphonates (LAS) 270,000Secondary alkane sulphonates 45,000Alkyl sulphates and alkylether sulphates 260,000Soaps 65,000Anionics, subtotal 640,000Alcohol alkoxylates 295,000Fatty acid glucose amides 1,300Nonionics, subtotal 295,300Cationics 35,000Amphoterics 550Total 970,850

Sources:ECOSOL (1996). Surfactant consumption in household detergents.Umwelt Bundes Amt (2001). Confidential informationDanish Environmental Protection Agency (2001). Environmental Project No. 615.

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2.2 Product group definition

The current criteria define “laundry detergents” as “all laundry detergents, in powder,liquid or any other form; for the washing of textiles, and which are intended to be usedprincipally in household washing machines”. This definition implies that the scope ofthe eco-label is household laundry detergents although laundry detergents used outsidethe households are not completely excluded. Laundry detergents used for the washing oftextiles in coin-operated and communal laundries have a composition similar to that ofhousehold laundry detergents, and the potential advantages of a specific inclusion ofthis type of detergents in the product group definition should be considered. At the adhoc working group meeting it was decided to use a broader product group definition forthe work of revision of the laundry detergents eco-label criteria. This definition is:

“All laundry detergents, in powder, liquid or any other form; for the washing oftextiles, and which are intended to be used principally in household machines;but not excluding the use in launderettes and common laundries”.

3 MARKET OF ECO-LABELLED LAUNDRY DETERGENTS

At present, three flower licenses have been given in the laundry detergent productgroup:

• The manufacturer “Linds Fabrikker A/S” in Denmark got its license in February2001

• The Italian retailer chain “Esselunga SpA got a license in February 2001• The Dutch manufacturer “Dalli Benelux b.V.” got its license in May 2001

All three licenses are relatively new on the market as they have been given this year.This “first wave” may motivate other manufacturers to apply for the eco-label as well.

The European market for household laundry detergents is dominated by the multina-tional groups like Procter & Gamble, Unilever, Reckitt & Colman etc. For the present,these groups have not yet shown their interest in applying for eco-labels in general.Sweden making an exception as the Swedish market for eco-labelled (the Nordic Swan)laundry detergents is developed to an extent where an eco-label is regarded a prerequi-site for selling the products.

Apart from the multinationals, the big private label manufacturers play a certain role onthe European market. Private labels are produced for the retailer chains under their owntrademarks. As a consequence, the purchasers of the major retailer chains have an ex-tended influence on the market. They determine the product range on the shelves in-cluding the balance between mainstream products and high quality niche products.

The total European market for laundry detergents is estimated at € 3-4 billions. Ac-cording to a manufacturer, the market has been saturated for the past 10-15 years, andlaundry detergents in general are sold at the same price level as 20 years ago. Today,

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about 80% of all laundry detergents are sold on offer as loss leaders in the supermar-kets, which is not favourable for promotion of the high quality niche products.

On their respective markets, the present flower-labelled products are profiled as highquality products in relation to washing performance as well as to the environment. TheFlower itself is not the main selling point – only in combination with a high perform-ance.

3.1 Product tests

The importance of combining high quality products in relation to washing performanceas well as to the environment is illustrated by the results of two product tests on laundrydetergents on the Danish market carried out by the Danish Consumer Information in1999 (laundry detergents, colour) and 2001 (laundry detergents, white wash) respec-tively. The tests focused on washing performance, environmental impacts and price. Inboth tests, an eco-labelled product came out as the total winner leading to a lot of posi-tive publicity. It should be noted that as a consequence the 1999 winner experienced areal boost on the market for the entire Swan-labelled product line, not only for the spe-cific laundry detergent. In 2001, the winning product carried the Flower eco-label.There has been a positive publicity as well as presentation in a very popular consumerprogramme on Danish television. However, it is still too early to conclude on the finalreaction on the market.

According to the questionnaires, a more widespread use of product tests carried out byindependent organisations is overall assessed to have a potential for promoting eco-labelled products in other countries too, for example in the Netherlands, Belgium, Ire-land and Austria. Naturally, it will only be beneficial to the eco label if the eco-labelledproducts perform very well in the tests. The major benefit of the tests in relation to mar-ket aspects is the combination of environmental performance, washing performance andprice. The best products are not always the most expensive ones and products with alow environmental impact are not old-fashioned or ineffective. Both statements are key-arguments in any campaign for awareness raising. There is also one example where atest demonstrating good performance, potential low environmental and low prices didnot influence the market. This indicates that a good combination is only valuable whenit is used with caution.

3.2 Future promoting of eco-labelled products

As the number of Flower licences is very limited for the time being, the eco-labelledlaundry detergents are not yet visible on the market in general. Two strategy elementsseem possible and can be interlinked.

1. Extend the position of the high quality niche productsThe advantage for this strategy element is that it is already ongoing. The process of get-ting more eco-labelled private labels can be stimulated by a focused effort targeted atthe purchasers of the big retailer chains. Each year, the Private Label Manufacturers As-sociation (PMLA) holds a trade fair in the Netherlands, and this could be a very goodoccasion for a campaign for eco-labelled products.

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If the market for these high quality niche products is extended, it may also support thefollowing strategy element.

2. Break through the wall for the mainstream productsThis strategy demands a much more extensive effort as there is a need to raise theawareness on eco-labelled products among the consumers, the retailers and the manu-facturers. Moreover, a real break-through calls for one or more of the multinationals toapply for the eco-label on their main products. But if this happens, it will probably havea snowball effect on the market.

For the past few years, AISE, the international detergent and maintenance products in-dustry, have spent millions of euros on “wash-right” campaigns targeted on the con-sumers. In the campaigns mainly based on pan-European TV spots, the consumers aretaught to minimise the environmental impacts during use e.g. by choosing a lower tem-perature for doing the laundry. Except for recommendations related to packaging (savethe box and buy refills if possible), the campaign does not focus on the product features.AISE represents the national associations of 27 countries (mainly located in Europe)and includes approximately 800 members.

Owing to the AISE campaigns, many consumers throughout Europe have started to re-alise that laundry detergents do have an environmental impact. This is an important steptowards realising that there are good reasons for buying products with less environ-mental impacts.

No matter what strategy be chosen, there is a need to promote the eco-labels in generalamong manufacturers, retailers, (public) purchasers and consumers, not only one of thegroups. This is suggested by almost all the respondents on the questionnaire and in linewith the new working plan of the European Flower1 establishing a permanent EUEBmarketing group.

3.3 Actions at several levels

From a European Union point of view, several instruments can be used.

First of all, at the political level, the Procurement Directive could be improved towardsgreen procurements as an important aspect in realising the Integrated Pollution Preven-tion strategy. Public purchasers throughout Europe represent a substantial market andmay serve as a 'locomotive' for the eco-label and/or the criteria set up for the productgroup. The easier it is to understand the criteria the greater the potentials for use.

Campaigns. General information campaigns on eco-labelled products based on TVspots, advertisements etc. directed primarily towards the consumers are important toraise the awareness and, on a long view, raise the demand for these products. The cam-paigns should not be let alone issues but integrated elements in a large effort. Agree-ments should be made with manufacturers to launch eco-labelled products and retailersshould be involved in shop-campaigns to influence the consumers’ choice at the time ofbuying the products. In other words, a successful campaign has to be conducted and co-ordinated in several fields at the same time.

1 May be obtained from any EUEB stakeholder or downloaded from

http://europa.eu.int/comm/environment/ecolabel/pdf/work_plan/24septemberversion.pdf

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Special events. Promotion of eco-labelled products at mega events like the OlympicGames or World Championships is worth considering. With respect to laundry deter-gents, which are probably not the most appealing product group to young athletes, theseproducts could be promoted together with eco-labelled textiles like sportswear, hotellinen, footwear etc. Moreover, a personal sponsorship of one of the top-athletes mayalso bring about a lot of valuable publicity and serve as a model for the young genera-tion (eg the Brazilian soccer player G. Elber promoting the Transfair label).

4 CURRENT ECOLOGICAL CRITERIA AND SUGGESTEDCHANGES

4.1 Summary of the current criteria

The current ecological criteria consist of eight parameters, which are related to a func-tional unit expressed in grams per wash. For heavy-duty detergents, the functional unitis the dosage in grams of the product recommended by the manufacturer for 4.5 kg load(dry textiles) while, for low-duty detergents, it is the dosage recommended for 2.5 kgload (dry textiles) in the washing machine.

The following parameters are considered in the existing ecological criteria:

• Total chemicals (TC)• Critical dilution volume-toxicity (CDVtox)• Phosphates (as STPP)• Insoluble inorganics (II)• Soluble inorganics (SI)• Aerobically non biodegradables (aNBO)• Anaerobically non biodegradables (anNBO)• Biological oxygen demand (BOD)

To each of the individual criteria above, an exclusion hurdle, scores from 1 to 4 pointsand a weighting factor are assigned. The exclusion hurdles specify limit values thatmust be complied with, whereas the score is related to a defined value in grams perwash. The score is multiplied with the weighting factor, which shows the relative im-portance of the criterion. This scoring or matrix system is relatively complex and makesit difficult to explain the positive value of eco-labelled products to the consumers. Theresponses to the questionnaire indicate that some manufacturers abandoned to apply forthe eco-label because the lack of transparency of the current matrix system makes itvery difficult to assess the ‘pass’ or ‘fail’ of individual products.

4.2 Proposed revised criteria

It is proposed to replace the environmental matrix in the current criteria with a simpli-fied system consisting of six parameters and associated hurdles.

The suggested revised criteria are anticipated to:

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• reduce the environmental impact of laundry detergents• increase transparency and, thereby, encourage manufacturers to apply for the eco-

label• facilitate the communication of the criteria to manufacturers and consumers

Furthermore, the proposed criteria aim at a harmonisation with the recently agreed crite-ria for other types of detergent products, i.e. the current criteria for all-purpose cleanersand cleaners for sanitary facilities (of 27 June 2001) and the criteria for hand dishwash-ing detergents (of 19 July 2001).

Functional unit and limit of documentationSome of the parameters below are related to a functional unit, which is the dosage ingrams per wash for 4.5 kg dry textiles for heavy-duty detergents and 2.5 kg dry textilesfor low-duty detergents (similar to the current criteria).

The concentration of ingredients in the product, which implies a requirement for docu-mentation of compliance with the criteria, is generally defined at ≥0.1% by weight ofthe preparation (limit of documentation). The criterion on ‘dangerous, hazardous ortoxic substances or preparations’ is an exception, as the limit of documentation in thiscase is defined at ≥0.01% by weight of the preparation.

4.2.1 Total chemicalsThe ad hoc Working Group recommended that a limit for the amount of total chemicalsin the product should be a parameter in the revised criteria in order to encourage theproduction of compacts and, thereby, reduce impacts related to transport.

Current criterionThe current criterion implies that the weight of the total chemicals at the recommendeddosage of the product must not exceed 110 g/wash (exclusion hurdle). The points ob-tained in the environmental matrix are reduced to 50% of the maximum value for thisparameter at a total chemicals dosage of 80 g/wash.

Proposal for a new criterionAn analysis of 35 laundry detergents marketed in Germany and Denmark showed thatthe range for the weight of the total chemicals at the recommended dosage was 39g/wash to 156 g/wash with an average value of 72 g/wash. The total chemicals of threeof the 35 products exceeded 90 g/wash, which is proposed as the new criterion.

The revised criterion is proposed as follows:

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

The weight of the total chemicals at the recommended dosage must not exceed 90g/wash.

Assessment and verificationThe exact formulation of the product shall be provided to the Competent Body, togetherwith the details of the calculations showing compliance with this criterion.”

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4.2.2 Insoluble inorganic ingredientsInsoluble inorganic ingredients in laundry detergents, mainly in the form of zeolites,contribute to the production of sewage sludge and, thereby, increase the need for an ap-propriate disposal. Regulation of insoluble inorganics is not considered very importantfor reducing the environmental impact of detergents, and it is therefore proposed thecurrent exclusion hurdle is used in the revised criteria.

Current criterionThe current criterion implies that the total amount of insoluble inorganics in the productmust not exceed 30 g/wash (exclusion hurdle). The points obtained in the environmentalmatrix are reduced to 50% of the maximum value for this parameter at a phosphatecontent of 20 g/wash.

Proposal for a new criterionThe analysis of 35 laundry detergents marketed in Germany and Denmark showed thatthe amounts of insoluble inorganics varied between 0 g/wash and 33 g/wash. The in-soluble inorganic ingredients in one of the 35 products exceeded 30 g/wash, which isproposed as the new criterion.


“The total amount of insoluble inorganic ingredients in the product shall not exceed 30g/wash.


4.2.3 PhosphatesPhosphorus used in the form of e.g. sodium tripolyphosphate (STPP) in laundry deter-gents is one of several sources of nutrients that contribute to enhanced growth of algaein aquatic systems (eutrophication) if the sewage is not purified in wastewater treatmentplants with processes designed for the removal of phosphorus. The countries in Europehave developed different strategies aiming at a reduction of the enrichment of the waterenvironment with phosphates. One approach is to substitute phosphates in detergentproducts with other chelating agents. Another approach is to establish efficient proc-esses for elimination of phosphates at the wastewater treatment plants. This situationperfectly explains why diverging opinions regarding the acceptability of phosphates inlaundry detergent were represented in the responses to the questionnaire. It is proposedthat a minimum of phosphates should be allowed in eco-labelled laundry detergents, andthat the member countries may reflect on introducing national regulations on phosphatesin the products if necessary to facilitate the eco-label policy process. This would also re-flect the different strategies for the treatment of waste water in Europe in view of anenlarged European Union.

Current criterionThe current criterion implies that the total amount of phosphate (as STPP) in the prod-uct must not exceed 30 g/wash (exclusion hurdle). The points obtained in the environ-

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mental matrix are reduced to 50% of the maximum value for this parameter at a phos-phate content of 15 g/wash.

Proposal for a new criterionThe analysis of 35 laundry detergents marketed in Germany and Denmark showed thatthe amounts of phosphate at varied between 0 g/wash (phosphate-free detergents) and30 g/wash. The phosphate content of one of the 35 products exceeded 25 g/wash, whichis proposed as the new criterion.


“The total amount of phosphates in the product shall not exceed 25 g (as STPP)/wash.


4.2.4 Toxicity to aquatic organismsBy volume, surfactants constitute the type of ingredients most relevant for the discus-sion of possible adverse effects of laundry detergents in the aquatic environment. Theability of surfactants to dissolve or emulsify lipids and proteins implies that these ingre-dients will always have an inherent toxicity to living cells and, hence, to aquatic organ-isms. However, the waste water in the European countries is normally treated in waste-water treatments plants in which more than 98% of the major surfactants are usuallyremoved. Therefore, the relevant parameter describing the potential adverse effects ofsurfactants and other ingredients in laundry detergents is the long-term effects that areincluded in the calculation of the critical dilution volume toxicity (CDVtox).

Current criterionThe potential aquatic toxicity of the product is estimated by the critical dilution volumetoxicity (CDVtox) which includes:

• the predicted emission to the aquatic environment (expressed by the amounts usedand a loading factor), and

• the predicted long-term effects of the ingredients

The CDVtox is calculated for each ingredient (i) using the following equation:

CDVtox (ingredient i) = weight/wash (i) · LF (i) · 1,000LTE (i)

where weight (i) is the weight of the ingredient per recommended dose, LF is the load-ing factor and LTE is the long-term toxicity effect concentration of the ingredient.

The values of the LF and LTE parameters shall be as given in the detergent ingredientdatabase list (DID list) in Appendix 1A of the current criteria. If the ingredient in ques-tion is not included in the DID list, the applicant shall estimate their values followingthe approach described in Appendix 1B of the criteria. The CDVtox is summed for eachingredient, making the CDVtox for the product:

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CDVtox= Σ CDVtox(ingredient)

The current criterion implies that the CDVtox for the product must not exceed 10,000l/wash (exclusion hurdle). The points obtained in the environmental matrix are reducedto 50% of the maximum value for this parameter at a CDVtox corresponding to 5,500l/wash.

Proposal for a new criterionThe analysis of 35 laundry detergents marketed in Germany and Denmark showed thatthe range for the CDVtox was 946 to 4,781 l/wash with an average value of 2,324 l/wash.Some of the formulations did not state the possible content of perfume, but the above-mentioned CDVtox of 4,781 l/wash was not exceeded, when a value of 500 was added tothe CDVtox of the products for which no information on perfume content was available(CDVtox = 500 represents 0.1 g of perfume/wash). The CDVtox of one of the 35 productsexceeded 4,500 l/wash, which is proposed as the new criterion.

The revised criterion is proposed as follows:“The CDVtox of the recommended dosage shall not exceed 4,500 l/wash.


4.2.5 Biodegradability of surfactantsThe future European legislation on detergents is expected to prescribe that the surfac-tants in detergent products shall be readily biodegradable (aerobically) and that excep-tions to this general requirement are only acceptable if certain other eco-toxicologicaltests have proven a low potential for adverse effects. The rapid aerobic biodegradabilityof surfactants in an eco-labelled laundry detergent should be beyond doubt. Therefore,the compliance with pass criteria in the tests for ready biodegradability should bedocumented (either via the data in the DID list or by test results for the specific ingredi-ent). The 10-day window criterion, which is normally a part of the pass/fail criteria inready biodegradability tests, shall not apply for surfactants in eco-labelled laundry de-tergents. This is due to the fact that the 10-day window was originally intended for puresubstances and not for technical surfactants composed of several homologues or iso-mers.

Rapid aerobic biodegradability will normally ensure that a substance is degraded rapidlyin most environments in which molecular oxygen is present. Requirements to the an-aerobic biodegradability aim at a documented potential for the degradation of the sub-stance in sludge, soil and sediments, where oxygen may be temporarily or permanentlyabsent.

The proposed revised criteria prescribe that surfactants shall be ultimately biodegrad-able under aerobic and anaerobic conditions. The rationale for the proposed require-ments to the biodegradability of surfactants is built on the fact that most surfactants areharmful to aquatic organisms and are used in high volumes. The consumption and theuse pattern of surfactants imply that small amounts of these ingredients reach the envi-

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ronment. If a surfactant is not degraded under the different conditions in the environ-ment, it may be toxic to aquatic and soil-living organisms.

Current criterionThe current criteria disfavour the use of ‘non-anaerobically-degradable ingredients’ byan exclusion hurdle associated with the parameter anNBDO (15 g/wash). The pointsobtained in the environmental matrix are reduced to 50% of the maximum value for thisparameter, when the content of ‘non-anaerobically degradable ingredients’ correspondsto 7 g/wash. The current criteria imply that all ingredients in the product shall be evalu-ated for anaerobic biodegradability

Proposal for a new criterionThe analysis of 35 laundry detergents marketed in Germany and Denmark showed thatall of the surfactants used in the products are ultimately degradable under aerobic con-ditions and comply with the above-mentioned criteria for ready biodegradability. Theavailable data do not allow a detailed assessment of anaerobic biodegradability of thesurfactants, but it is possible to indicate general trends. About one third of the productscontains surfactants that are considered ultimately degradable under anaerobic condi-tions (11 of the 35 products). A lack of ultimate anaerobic degradability is suspected fortwo types of raw materials that are used in some of the 35 products. The first type isanionic surfactants of the sulphonate-type (used in 14 of the 35 products) that are notultimately biodegradable under anaerobic conditions. Besides, a low ultimate anaerobicbiodegradability is also anticipated for multibranched nonionic surfactants (used in 10of the 35 products). Substitution of sulphonates (e.g. with alkyl sulfates, DID Nos. 5-7)and multibranched nonionic surfactants (e.g. with linear alcohol ethoxylates, DID Nos.16-20) will make these products pass the criterion on biodegradability of surfactants.


“(a) Ready biodegradability (aerobic)

Each surfactant used in the product shall be readily biodegradable.

Assessment and verification

The exact formulation of the product shall be provided to the Competent Body. The DIDlist (see Appendix IA) indicates whether a specific surfactant is aerobically biodegrad-able or not (i.e. those that have an entry of ‘Y’ in the column on aerobic biodegradabil-ity shall not be used). For surfactants which are not included in the DID list, the rele-vant information from literature or other sources, or appropriate test results, showingthat they are aerobically biodegradable shall be provided. The tests for ready biode-gradability shall be as referred to in Council Directive 67/548/EEC of 27 June 1967 onthe approximation of laws, regulations and administrative provisions relating to theclassification, packaging and labelling of dangerous substances, and its subsequentamendments, in particular the methods detailed in Annex V.C4, or their equivalentOECD 301 A-F test methods, or their equivalent ISO tests. The 10 days window princi-ple shall not apply. The pass levels shall be 70% for the tests referred to in Annex V.C4-A and C4-B of Directive 67/548/EEC (and their equivalent OECD 301 A and E testsand ISO equivalents), and shall be 60% for tests C4-C, D, E and F (and their equivalentOECD 301 B, C, D and F tests and ISO equivalents).

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(b) Anaerobic biodegradability

Each surfactant used in the product shall be anaerobically biodegradable.


The exact formulation of the product shall be provided. The DID list (see Appendix IA)indicates whether a specific surfactant is anaerobically biodegradable or not (i.e. thosethat have an entry of ‘Y’ in the column on anaerobic biodegradability shall not beused). For surfactants which are not included in the DID list, the relevant informationfrom literature or other sources, or appropriate test results, showing that they are an-aerobically biodegradable shall be provided. The reference test for anaerobic degrad-ability shall be ISO 11734, ECETOC No. 28 (June 1988) or an equivalent test method,with the requirement of 60% degradability under anaerobic conditions.”

The proposed new criterion is more strict than the current criteria in relation to surfac-tants, and it is less strict in the requirements to the applicant’s documentation for an-aerobic biodegradability of ingredients. The proposed new criterion reduces the re-quirements for documentation of anaerobic biodegradability by focussing onsurfactants, whereas such documentation in principle shall be provided for all ingredi-ents according to the current criteria.

The arguments for the proposed new criterion are the following:• A combined requirement that the surfactants shall be biodegradable under both

aerobic and anaerobic conditions implies that optimal biodegradation properties areintended for the more hazardous ingredients in eco-labelled laundry detergents (thiswill reduce the risk that surfactants used in eco-labelled products are regulated innational or European legislation, e.g. in the form of quality standards for contami-nants in sludge used in agriculture).

• The requirement that surfactants in eco-labelled products shall be rapidly degradableunder different environmental conditions is easy to communicate and is also a newselling argument.

• The proposed new criterion will harmonise the eco-labelling criteria for laundry de-tergents with the current (and recently revised) criteria for all-purpose cleaners andcleaners for sanitary facilities (of 27 June 2001) and for hand dishwashing deter-gents (of 19 July 2001).

At the first ad hoc Working Group meeting (6 December, 2001, Brussels), some of theparticipants representing the producers of raw materials pointed to the fact that soap isfound in g/kg levels in predominantly anaerobic aquatic sediments, although soap isbiodegradable under anaerobic conditions. Besides the high volumes used, the presenceof soap in sediments is due to limitations in bioavailability and not to a lack of anaero-bic degradation. Only chemicals that are bioavailable (i.e., desorbed and dissolved) canexert a toxic effect on organisms living close to or in aquatic sediments. The require-ment that surfactants in eco-labelled laundry detergents shall be anaerobically biode-gradable ensures that the surfactants will probably degrade in the sediment as soon asthey become bioavailable.

Documentation of anaerobic degradability

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The following approach may be used to provide the necessary documentation of an-aerobic degradability for the Competent Body:

Consult the DID-list. The DID-list contains 26 anaerobically degradable surfactants(including C12-18 alkylamidopropylbetaine, DID No. 34, which is anaerobically de-gradable). These 26 surfactants comprise anionic, nonionic and amphoteric surfactants,and it is foreseen that ‘new’ anaerobically degradable surfactants (including the fourthmain type, cationics) will be included during the planned revision of the DID-list. How-ever, the current DID-list provides the necessary data to produce a detergent based onanaerobically degradable surfactants.

Apply reasonable extrapolation. Use test results obtained with one raw material toextrapolate the ultimate anaerobic degradability of structurally related surfactants (usethe surfactant types defined in the DID-list or apply a similar approach for ingredientsnot included in the list).

Perform screening test for anaerobic degradability. If new testing is necessary, per-form a screening test by use of ISO 11734, ECETOC No. 28 (June 1988) or an equiva-lent method.

Perform low-dosage degradability test. If new testing is necessary, and in the case ofexperimental problems in the screening test (e.g. inhibition), repeat testing by using alow dosage of surfactant and monitor degradation by 14C measurements or chemicalanalyses.

4.2.6 Dangerous, hazardous or toxic substances or preparationsThe criteria for eco-labelling shall define a standard for health and environmental safetyon the basis of the knowledge available today. This objective is met by supplementingthe above-mentioned criteria with prescriptions of certain ingredients that shall not beincluded in eco-labelled laundry detergents. Furthermore, no ingredient shall be in-cluded in the product that is classified or may be classified by certain specified riskphrases.

Current criterionThe current criterion implies that a number of specified ingredients shall not be used orare limited in their concentration in eco-labelled laundry detergents.

The following ingredients shall not be used in the product:Alkyl phenol ethoxylates (APEOs) and their derivativesEDTA (ethylenediamine tetraacetate)Musk xylene: 5-tert-butyl-2,4,6-trinitro-m-xyleneMusk ambrette: 4-tert-butyl-3-methoxy-2,6-dinitrotolueneMoskene: 1,1,3,3,5-pentamethyl-4,6-dinitroindanMusk tibetine: 1-tert-butyl-3,4,5-trimethyl-2,6-dinitrobenzeneMusk ketone: 4’-tert-butyl-2’,6’-dimethyl-3’,5’-dinitroacetaphenone

Ingredients fulfilling the criteria for classification as carcinogenic, harmful to reproduc-tion or mutagenic shall not be used in the product. The associated risk phrases are not

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specified in the current criteria; the risk phrases covering the mentioned hazardousproperties include:R40 (limited evidence of a carcinogenic effect)R45 (may cause cancer)R46 (may cause heritable genetic damage)R49 (may cause cancer by inhalation)R60 (may impair fertility)R61 (may cause harm to the unborn child)R62 (possible risk of impaired fertility)R63 (possible risk of harm to the unborn child)R64 (may cause harm to breastfed babies)

The following ingredient is limited in concentration:Phosphonates shall not exceed 0.5 g/wash.

Ingredients fulfilling the criteria for classification as ‘very toxic to aquatic organisms’(N; R50) shall not exceed 10 g/wash.

Ingredients fulfilling the criteria for classification as ‘very toxic to aquatic organisms’and ‘may cause long-term adverse effects in the aquatic environment’ (N; R50-53) shallnot exceed 0.25 g/wash.

Proposal for a new criterionThe main changes in the proposed new criterion are the following:

• Specific substances are added to the list of ingredients that shall not be included, i.e.certain quaternary ammonium salts (see below), HHCB (1,3,4,6,7,8-hexahydro-4,6,6,7,8,8,-hexamethylcyclopenta(g)-2-benzopyran), AHTN (6-acetyl-1,1,2,4,4,7-hexamethyltetralin) and NTA (nitrilotriacetate).

• The inherent properties related to health hazards are being more precisely addressedby their associated risk phrases. The risk phrases for health and environmental haz-ards leading to exclusion of ingredients are extended and include: R68 (possiblerisks of irreversible effects), N, R50-53 (very toxic to aquatic organisms, may causelong-term adverse effects in the aquatic environment), N, R51/53 (toxic to aquaticorganisms, may cause long-term adverse effects in the aquatic environment) andR59 (dangerous to the ozone layer).

• A strict limit of documentation is defined as an operational approach to meet theintention that the specified ingredients or substances shall not at all be included inthe products (with the exception of phosphonates; see below). The applicant shalldocument that every ingredient or substance present in the product at ≥0.01% (w/w)fulfils the criterion on ‘dangerous, hazardous or toxic substances or preparations’.

• The amount of phosphonates in the product shall not exceed 0.5 g/wash.

The available data for the 35 laundry detergents marketed in Germany and Denmark didnot indicate the use of any ingredient which is proposed to be excluded from eco-labelled products (see proposed revised criterion below). The phosphonates in one ofthe 35 products exceeded the proposed limit of 0.5 g/wash (0.52 g/wash was the highestphosphonate level found).


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

• alkyl phenol ethoxylates (APEOs) and derivatives thereof• alkyltrimethyl-, dialkyldimethyl-, and alkyldimethylbenzyl ammonium salts• nitromusks and polycyclic musks, including e.g.:

• musk xylene: 5-tert-butyl-2,4,6-trinitro-m-xylene• musk ambrette: 4-tert–butyl-3-methoxy-2,6-dinitrotoluene• moskene: 1,1,3,3,5-pentamethyl-4,6-dinitroindan• musk tibetine: 1-tert-butyl-3,4,5-trimethyl-2,6-dinitrobenzene• musk ketone: 4’-tert-butyl-2’,6’-dimethyl-3’,5’-dinitroacetaphenone• HHCB: 1,3,4,6,7,8-hexahydro-4,6,6,7,8,8,-hexamethylcyclopenta(g)-2-

benzopyran• AHTN: 6-acetyl-1,1,2,4,4,7-hexamethyltetralin

• EDTA (ethylenediamine tetraacetate)• NTA (nitrilotriacetate)

The total amount of phosphonates in the product shall not exceed 0.5 g/wash.

No ingredient shall be included in the product that is classified or may be classified as:• R40 (limited evidence of a carcinogenic effect)• R45 (may cause cancer)• R46 (may cause heritable genetic damage)• R49 (may cause cancer by inhalation)• R68 (possible risks of irreversible effects)• N; R50-53 (very toxic to aquatic organisms, may cause long-term adverse ef-

fects in the aquatic environment)• N; R51-53 (toxic to aquatic organisms, may cause long-term adverse effects in

the aquatic environment)• R59 (dangerous to the ozone layer)• R60 (may impair fertility)• R61 (may cause harm to the unborn child)• R62 (possible risk of impaired fertility)• R63 (possible risk of harm to the unborn child)• R64 (may cause harm to breastfed babies)

or any combination thereof, according to Directive 67/548/EEC and its subsequentamendments, or according to Directive 1999/45/EC of the European Parliament and ofthe Council of 31 May 1999 concerning the approximation of the laws, regulations andadministrative provisions of the Member States relating to the classification, packagingand labelling of dangerous preparations, and its subsequent amendments.

Documentation

The applicant shall document that every ingredient or substance present at ≥0.01% byweight of the preparation fulfils the criterion on ‘dangerous, hazardous or toxic sub-stances or preparations’. Each ingredient of any preparation used in the formulation pre-sent at ≥0.01% by weight of the preparation shall also meet the above requirement.

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No ingredient serving the function as preservative shall be included in the product, noteven below 0.01% by weight of the preparation, when the ingredient is classified ormay be classified with N; R50-53.


The exact formulation of the product shall be provided to the Competent Body, togetherwith copies of the material safety data sheets of each ingredient which shall indicate theclassification or lack thereof of each ingredient, as well as a declaration that none ofthe above substances have been included in the product.

Similarly the suppliers of any preparation used in the formulation shall provide a decla-ration that their preparation complies with the above requirements.”

The above proposal harmonises the requirements for laundry detergents with the similarrequirements in the criteria for all-purpose cleaners and cleaners for sanitary facilities(of 27 June 2001) and for hand dishwashing detergents (of 19 July 2001). Following thediscussion at the first ad hoc Working Group meeting (6 December, 2001, Brussels), itwas decided to mention specific types of non-readily degradable quaternary ammoniumcompounds that shall not be included in eco-labelled laundry detergents. This impliesthat readily degradable quaternary ammonium compounds, including e.g. many alkylester ammonium salts, can be used in the products.

Possible future revisionsSome of the chelating agents that are used to replace phosphates in laundry detergentsmay possibly cause adverse effects in the aquatic environment. EDTA, NTA and phos-phonates are not readily degradable and, especially the first two are suspected toremobilize metals from aquatic sediments. Furthermore, the International Agency forResearch on Cancer has evaluated NTA as possibly carcinogenic to humans [IARCMonographs, Vol. 48, World Health Organization, Lyon, France]. Phosphonates havebeen reported to ve very toxic to algae, but the observed inhibition of growth may becaused by chelation of essential nutrients in the test medium. It is recommended that athe environmental properties of chelating agents is considered in the future revision ofthe criteria by using a comparative and risk based approach.

5 PERFORMANCE TEST

From the questionnaires, the general impression is that it is important to maintain a highlevel of requirements in the performance test to assure a high quality standard for theeco-labelled laundry detergents. At the first and second ad hoc working group meetingsthe need of good performance and testing thereof was discussed. It was argued that itmight be unnecessary to use many resources on that aspect since products that do notperform well eventually will loose on the market. However, the general impression be-ing that good performance is essential was maintained.

The performance test will be discussed at the 3rd ad hoc Working Group meeting onMay 30th, 2002. Enclosed in this background report is Appendix B: Performance test

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protocol, “Award of the community ecolabel of laundry detergents, Performance test ofhousehold detergents”.

6 OTHER CRITERIA

Other criteria are criteria regarding packaging and information to consumers.

6.1 Criteria on product packaging

Overall packaging has a minor potential environmental impact. At the second ad hocworking group meeting a number of views regarding the importance of packaging werepresented. The views were varying from participants arguing for not having a criterion,in fact proposing to delete it, to other participants arguing that since packaging in thecase of detergents is the first visual sight of the detergents it is very important to use thatsignal. Further, it was argued that producers of non-eco-labelled products uses the pack-aging to signal environmental superiority.

All in all, these arguments brought the conclusion that is a very good idea, indeed, tomaintain criteria for packaging. The market survey indicated that the packaging criteriain the existing set of criteria are relatively strict, especially for the refill system. How-ever, the ecological criteria bring the volume of the detergent to fulfil a functional unitto the same level as today or a lower level and thereby a slight easing of the criteria ofthe criteria or packaging.

In addition to the existing criteria it is reasonable to add a phrase reflection the adopteddirective of packaging and packaging waste.

Current criteriaOnly primary packaging is considered. The packaging of the detergent shall consist oflightweight packaging or a container (cardboard/plastic box or plastic bottle)

If the detergent is provided in a container (box or bottle), the manufacturer shall providerefills.

The weight of the lightweight packaging or the refill packaging shall not exceed 1,7g/wash.

The weight of the container shall not exceed 7 g/wash.

The cardboard packaging shall be 80 % recycled packaging and the plastic packagingshall be labelled according to ISO 1043.

Proposal for a new criterionIn addition to the above mentioned test (under current criteria) it is suggested to includea criteria shall of course also reflects the EU directive of 94/62EC of December 1994

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6.2 Consumer information

Information on packaging

The following information shall appear on or in the packaging:

“ENVIRONMENTALLY FRIENDLY WASHING MEANS:

Step 1: Pre-sort laundry (e.g. by colour, degree of soiling, type of fibre)

Step 2: Wash with full load

Step 3: Avoid using too much detergent, follow dosage instructions

Step 4: Choose low-temperature washing cycles.

More information on the detergent shall be made available on request. For this purpose,a sentence should appear on the packaging saying that if the consumer wants to knowmore about the detergent, he should call (or write to) the consumer department of thecompany or the retailer.

In order to encourage the consumer to avoid using too much detergent and to followdosage instruction, a dosage device (cup) showing a scale of at least 10 ml steps shall beavailable on request if it is not included in then packaging.

The following information shall appear on the packaging:

This product has been awarded the EU eco-label because it contributes to thereduction of water pollution. Waste production and energy consumption. Formore information about the EU eco-label, visit the internet website.Http://europa.eu.int/ecolabel.

Dosage instruction

Dosage recommendations shall appear on the product packaging, together with a rec-ommendation to the consumer to contact his water supplier or local authority in order tofind out the degree of hardness of his tap water.

The recommended dosage must be specified for “normally” and “heavily” soiled tex-tiles and the various water hardness ranges relevant for the countries concerned and re-ferred as appropiate to the weight of textile. I dosage instructions are given by way ofdosage device, the volume of the device (in ml) should also appear clearly on the pack-aging.

The washing efficiency shall be indicated and relate, “normally soiled” and highest wa-ter hardness range (3 or 4) – “heavily soiled” may not differ by more than a factor of 2.

http://europa.eu.int/ecolabel

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The reference dosage used for the washing performance test and the calculation of eco-logical criteria shall be the same as the recommended dosage for “normally soiled” andthe water range corresponding to 2,5 mmol CaCO3/l in the Member State in which thetest has been performed.

If only water hardness lower than 2,5 mmol CaCO3/l are included in the recommenda-tions, the maximum dosage recommended for “normally soiled” shall be lower than thereference dosage mentioned in the previous paragraph.

Information on allergy riskIf a product contains potentially allergenic ingredients, this should generally be markedon the packaging of any laundry detergent. The way of handling this in the eco-labelcriteria should be considered by the group. In very general terms, one could reflect ontaking a similar approach to that on all-purpose cleaners and cleaners for sanitary facili-ties.

ECOTOX/2002.07.04 20

A P P E N D I X A

Questionnaire

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Revision of the criteria for laundry detergents under the EU eco-labelling scheme

In relation to the ongoing revision of the laundry detergents criteria under the EU eco-labelling schemewe kindly ask you to spend 10 minutes in sharing your experiences with us in fulfilling the relevant partsof this questionnaire. The questions relate to the existing criteria/documentation and market aspects withthe purpose of clarifying possible barriers for the applicants as well as proposals for improvements.

Questionnaire

i) Name of your organisation:ii) Contact person:iii) E-mail address:

Do you have any practical experiences with the criteria document?__ Yes – please specify:_______ No

Section A: The existing criteria and documentation

A.1: The environmental criteria for ingredientsA.1.1. It is the impression that the dosage value (in gram chemical ingredients per wash) recommendedby the manufacturers is much lower for most of the laundry detergents on the market than the limit of 110g/wash which is prescribed as the maximum acceptable dosage value in the criteria. Should the valuesdescribing the dosage of chemical ingredients in the calculation matrix be reduced as an adaptation tothe dosages recommended for the products on the market today?__ Yes - why: ______ No - why not: ____

A.1.2 The ecological criteria for all-purpose cleaners and cleaners for sanitary facilities (adopted onJune 27th 2001) and for hand washing detergents (adopted on July 19th 2001) prescribe that surfactantsshall be biodegradable under anaerobic conditions. Would an adjustment in the criteria for surfactants inlaundry detergents be appropriate? In case which kind of adjustment would be suitable:__ Each surfactant used in the product shall be biodegradable under anaerobic conditions__ Low values of non-biodegradable organics, NBDO (aerobically and anaerobically), should be given ahigher weight in the calculation matrix__ The existing criteria shall be maintained, because:_____

A.1.3 In the existing criteria, a small amount of phosphates is allowed. Should phosphates be unaccept-able in the revised criteria?__ Yes – why: ______ No – why not: ____

A.1.4 Other comments related to the criteria: ____

A.2: The performance testA.2.1. How do you find the requirements related to the performance test?__ Too comprehensive in the following areas: ______ Suitable__ Incomplete in the following areas: ____

A.2.2. Which of the following two statements do you mainly agree with?__ A high level of requirements in the performance test with the corresponding price level should bemaintained to assure a high quality standard for the eco-labelled laundry detergents

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__ The requirements and the corresponding price level in the performance test should be modified to mo-tivate more manufacturers to apply for the eco-label

A.2.3. Other comments related to the performance test: ____

A.3. User’s ManualA.3.1 Do you have any practical experience with the User’s Manual?__ Yes__ No

If Yes – Please note any comments or suggestions to improve the User’s Manual: ____

Section B: Market aspects

B.1: Promotion of eco-labelled productsB.1.1. Have any activities been carried through or are there any planned activities in your country topromote eco-labelled products?

__ Yes, particularly for laundry detergents. Please specify:� responsible organisation(s), e.g government, consumer organisation, retailer,…:� type of activities:� target groups, e.g. private consumers, retailers, public purchasers etc.:� main (expected) results, e.g. awareness, higher market share etc.:� other comments:

__ Yes, eco-labelled products in general. Please indicate the main activities and the (expected) results:

__ No

B.2: Product testsSome consumer organisations or other organisations conduct product tests comparing the performanceof a number of parallel products to support the consumers in making a conscious choice when buyingthat type of products.

B.2.1. Are there any laundry detergents launched as “green” products (with or without an official eco-label) on your national market?__ Yes__ No

B.2.2. Have any product tests including environmental performance on laundry detergents on yournational market been conducted by an independent organisation?

__ Yes (a copy of the test results will be welcomed)__ No

B.2.3. Have the test results encouraged the sale of environmentally friendly laundry detergents?__ Yes__ No

B.2.4. Do you think that product tests potentially could be an important market tool for promoting eco-labelled products? Under which conditions?

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B.3: Market of eco-labelled detergentsB.3.1. What are in your opinion the reason(s) why relatively few laundry detergents are eco-labelled onthe European market?__ Low awareness among the consumers__ A substantial difference in price level between eco-labelled and non-labelled laundry detergents__ Low awareness among the purchasers and retailers__ The purchasers and retailers in general do not require eco-labelled products__ Low awareness among the producers__ Other

Please specify your answer:

B.3.2. By what means do you think the market share of eco-labelled products could be expanded? Pleasetick off what you think are the 3 most powerful means on the following list:__ General information campaign on eco-labelled products based on TV-spots, advertisements etc. di-rected

primarily towards the consumers (awareness raising)__ Promotion of eco-labelled products at mega events like the Olympic Games or World Championships__ Promotion of specific eco-labelled product groups in supermarkets etc.__ Carrying through of product tests including environmental aspects and dissemination of the results__ An EU Commission stand promoting eco-labelled products on the yearly Private Label Manufacturers

Association’s fair for public and private purchasers__ Fairs and exhibitions in general__ Requirements for including environmental aspects in all public procurements in the EU countries__ Campaign directed towards the manufacturers whenever (new) criteria are adopted__ Discussion on meetings in business forums__ Other:

B.3.3. Who do you think are the main contributors to the promotion of eco-labelled products? What couldyour own role be?

Section C: Comments

Please note any other comments or proposals you find relevant to be considered in relation to the revi-sion of the criteria for laundry detergents:

Thank you for taking time to answer the questions. Please return the questionnaire to Birgitte Bo,dk-TEKNIK ENERGY & ENVIRONMENT, by e-mail ([email protected]) no later than Nov. 9th, 2001.

mailto:[email protected]

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A P P E N D I X B

Performance test protocol

See separate file.

revision of ecolabel criteria for laundry detergents

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