European Eco-label Revision of Eco-label criteria for Detergents for dishwashers

Transcription

1 European Eco-label Revision of Eco-label criteria for Detergents for dishwashers Final report Prepared by Erik Svanes Consulting 24 September 2002

2 CONTENTS 1. INTRODUCTION PRODUCT DEFINITION ECOLOGICAL CRITERIA SUMMARY OF CURRENT CRITERIA SUMMARY OF PROPOSED REVISED CRITERIA ENVIRONMENTAL MATRIX: TOTAL CHEMICALS CDV PHOSPHATES NON BIODEGRADABLE ORGANIC COMPOUNDS (AEROBIC) NON BIODEGRADABLE ORGANIC COMPOUNDS (ANAEROBIC) TOTAL SCORE EXCLUSION OF SURFACTANTS THAT ARE NOT BIODEGRADABLE LIMITATION OF COMPOUNDS CLASSIFIED AS R50/53 OR R51/ CHLORINE BLEACHES REQUIREMENTS ON FRAGRANCES PACKAGING OTHER ISSUES PERFORMANCE TEST OTHER CRITERIA CONSUMER INFORMATION INFORMATION APPEARING ON THE LABEL CONSEQUENCES OF THE PROPOSED CHANGES POTENTIAL ENVIRONMENTAL BENEFITS OF THE ECOLOGICAL CRITERIA... 14

3 1. Introduction The EU ecolabelling criteria for detergents for dishwashers were approved 28 May In June 2001 Ecolabelling Norway answered a call for tender for the revision project. The Commission appointed Ecolabelling Norway as Lead Country in November Ecolabelling Denmark was appointed as Lead Country in the revision of the criteria for Laundry Detergents. Ecolabelling Denmark and Ecolabelling Norway decided in September 2001 to co-operate closely during the revision process. The technical work regarding the revision was conducted by the consultant Erik Svanes for Ecolabelling Norway The process was divided in 2 phases. Phase 1 of the project was concluded in the 1 st ad Hoc Working Group meeting in Brussels on 6 December 2001 when the Working Group decided to approve the proposed full revision of the criteria document. 2 more ahwg meetings were held, in Copenhagen 5 March 2002 and in Brussels 31 May The ahwg has consisted of approximately 20 members. Member States (Competent Bodies), Consumers organisations (BEUC), environmental organisations (EEB), ingredients manufacturers, detergent manufacturers (UEAPME, EDMA and 1 licence holder) and the European Commission were represented in the Group. All interested parties have been included on the mailing list and accordingly have received the project documents and been invited to all the meetings. The main manufacturers organisation and its members did not participate in the work, nor did they give any information or official comments despite repeated requests from Ecolabelling Norway. 2. Market review Since AISE stopped publishing data for consumption of detergents for dishwashers it has been difficult to find data for the European market. Competent Bodies, producers and others have been asked and a few figures have been given. The following tables contain the last published AISE data and the new figures obtained. Table 1. Total quantities sold Quantity (ktons pr annum) Other years Austria 5, Belgium (inc. in NL) Germany 52 Denmark 3,3 Spain 16 23,5 22, Finland 3,8 France 62,1 Greece 2,7 Ireland 1,6 Italy 26,9 26, Netherlands 8,3 Portugal 15,8 4,4 Sweden 5,5 UK 29,8 Total 233,6 Page 1 (14)

4 Table 2 a. Distribution (%) of product categories (1994) Conventional powders Compact powders Liquids Tablets Sum Austria Belgium Germany Denmark Spain Finland France Greece Italy Netherlands Portugal Sweden UK Table 2 b. More recent data Conventional Compact Liquids Tablets powders powders Norway < Italy 65,6 0,1 10,4 23, From this data it is difficult to conclude any market trends, but based on consultations with producers the following trends have been mentioned. The sale of detergents for dishwashers is increasing. The market share of tablets is increasing. The change from conventional powders to compact powders has slowed down. The most important conclusions that can be drawn from this data is that it is important to ensure that a reasonable proportion of both tablets and compact powders can fulfil the requirements. Even though tablets often have lower scores on the environmental matrix they have the extra benefit of almost completely eliminating the possibility of overdosing. 3. Product definition A high proportion of the Detergents for Dishwashers sold in Europe is so-called I n I-products. These are products for Industrial and Institutional use. Consultations with several producers have confirmed the findings in the Swedish report that these products are very different in composition from the products for household use. They consist largely of alkali agents and complex binders and to a lesser extent chlorine bleaches, surfactants or phosphates. They have a very high ph and are designed for high temperature and short time wash cycles. The producers see the very high ph, leading most of them to be classified as corrosive, as the major obstacle for these products to fulfil the current criteria. Many of the products used by professionals are, however, very similar to the products used in households. Often the only difference is that the professional products are used in machines with a high temperature last rinse cycle (for hygiene purposes). It is important to make the product group definition as wide as possible in order to maximise the potential environmental benefit and to offer ecolabelled products to more user groups. Hence it has been proposed to include products intended partially or totally for use by professional users, but in machine with a similar size and function as those used domestically. Page 2 (14)

5 4. Detergents for low-temperature use The consumption of energy for the dishwasher has been shown to be the single largest environmental impacts in the lifetime of a dishwasher detergent. A large proportion of the dishwashers currently on the market has the possibility for a low-temperature program. It is very important that the use of lowtemperature programs is encouraged. In the current criteria this has been done by several requirements: a) The performance test is conducted at 55 C, hence the product must function satisfactory at this low temperature. b) The consumers are encouraged via the information text to use low-temperature programs. The manufacturers have asked that the criteria focus more on the energy than in the current criteria. Ecolabelling Norway has asked industry representatives what is being done by them to develop products that work at low temperatures. They reply that they are concerned that at lower temperatures the hygiene will not be good enough. If the water temperature is not high enough to kill microorganisms then the ingredients will have to do that job. The current and proposed criteria both have strict requirements making it impossible to introduce disinfecting compounds in ecolabelled products. When (if at all) the manufacturers of dishwashing detergents and dishwashing machines develop products that work at lower temperatures the current criteria should be revised in order to obtain as high an environmental benefit as possible. 5. Ecological criteria 5.1 Summary of current criteria The current ecological criteria contain an environmental matrix with 5 parameters and a total score parameter based on the 5 parameters: Parameter Score Excl. Hurdle Weight Factor Max. Possible Score Total chemicals Critical Dilution Volume, toxicity Phosphates (as STPP) Aerobically non- Biodegradable Organics Anaerobically non Biodegradable Organics TOTAL 62 Minimum score required 26 Furthermore a number of compounds were excluded or limited: Excluded: Alkylphenoletoxylates (APEOs), perfumes containing certain specified aromatic nitro compounds, EDTA and ingredients classified as carcinogenic, mutagenic or teratogenic. Limited: Phosphonates ( 0,2 g/wash) and total chlorine compounds ( 0,1 %). Page 3 (14)

6 5.2 Summary of proposed revised criteria The environmental matrix has been retained but some changes have been made. Parameter Score Excl. Hurdle Weight Factor Total chemicals Critical Dilution Volume, toxicity Phosphates (as STPP) 0 2,5 5 7, Aerobically non- Biodegradable Organics Anaerobically non- Biodegradable Organics TOTAL Minimum score required 30 The score formulas used for calculating the parameter scores have been changed for Phosphates only, but they now apply for the whole range of allowed parameter values whereas currently the lower range gives no more increase of points (e.g. if Total chemicals < 16,5 g/wash the score would still be only 12 which is the score for TC=16,5 g/wash) and for some parameters the high range gives 0 points (e.g. for 240 <CDV 250 l/wash the point score is 0). The list of compounds that are excluded or limited has been extended: Excluded: Alkylphenoletoxylates (APEOs), alkyl phenol derivatives (APD), perfumes containing nitro musks or heterocyclic musk compounds, EDTA and NTA. Limited: Non easily biodegradable phosphonates ( 0,2 g/wash) and compounds classified according to the following risk phrases ( 0,01 % of the total product): R40 (limited evidence of a carcinogenic effect), R45 (may cause cancer) R46 (may cause heritable genetic damage) R49 (may cause cancer by inhalation) R50+53 (very toxic to aquatic organisms and may cause long-term adverse effects in the aquatic environment), R51+53 (toxic to aquatic organisms and may cause long-term adverse effects in the aquatic environment), 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) R68 (possible risks of irreversible effects) Surfactants that are not easily (aerobically) biodegradable or not anaerobically degradable are also excluded. Page 4 (14)

7 5.3 Environmental matrix: The environmental matrix is a way of organising the most important parameters in such a way that the manufacturer has flexibility to choose which parameters she/he wants to work on in order to fulfil the requirements. The following advantages and disadvantages are noted: Advantages: - Flexibility for producers. If the product must be changed to fulfil the requirements the producer can choose to: - reduce dosage and/or - use less toxic, more degradable, less bioaccumulating surfactants or other ingredients and/or - reduce phosphate content and/or - reduce quantity of non biodegradable organics (perfume, polycarboxylates, PEGs) - The environmental matrix was developed in close contact with industry representatives. Disadvantages: - Very difficult to set weight factors and formulas. This is the same difficulty as in all Life Cycle Analyses (LCA). How can different environmental properties (F.ex. biodegradability, eutrophication and toxicity) be quantatively compared? - Complicated for producers (with a little help from a Competent Body this is easily overcome). - Difficult to understand for consumers (but one of the purposes of the label is to make it easy for the consumer. The consumer just has to see the Flower, not read on the label or in newspapers and make a judgement herself). Why keep the current set-up with few additions and making some requirements stricter? - Predictability for producers. Important not to change the criteria too much. Development time for new products is long. - Flexibility for producers. - Make it easier for producers to have few formulations instead of one EU flower product, one for Norway, one for Central Europe, one for Nordic Swan, etc. 5.4 Total chemicals This is the only parameter that addresses the environmental impact (use of resources, energy and emissions) of the production of the ingredient as well as the resource use they constitute. A large majority of concentrated powders and tablets has dosage 20 g/wash, but many have 18 g/wash. The main disadvantage of this parameter is that it does not distinguish between ingredients with low and high environmental impact. Hurdle: 22,5 g/wash. No change in the hurdle is proposed. The score formula (15-tc/1,5) has not been changed, but it is now linear across the whole range of dosage from 0 to 22,5 g/wash. Previously the formula was only applied in the area 16,5 to 21 g/wash. Reduction below 16,5 gave no further points and dosage from 21-22,5 g/wash gave 0 points. The motive behind the proposed change is to simplify the criteria and encourage any reduction in dosage, however small it may be. 5.5 CDV This is the most important parameter. The hurdle has been reduced from 250 to 200 but this has just a small impact. The only impact for non-phosphate products with low content of non-biodegradable organic compounds. The formula was proposed changed from 5-cdv/40 to 5-cdv/60 but after receiving more information about tablet formulas we have decided to keep the original formula. The score formula has been proposed to apply across the whole range of CDV values from 0 to 200 l/wash. Previously the formula only applied from 60 (less than 60 gave 4 points) to 240 l/wash (more than 240 gave 0 points). Values below 60 are not expected but why exclude the possibility? The motivation is again to simplify and encourage any reduction in dosage, however small. This parameter in practise excludes the use of chlorinated bleach compounds and perborates in ecolabelled products. Perfumes are heavily punished because of the low LTE and rather high LF. Products with more than 0,1 % perfume are not likely to fulfil the requirements. Most products contain Page 5 (14)

8 much less perfume, typically in the area 0,01 0,02 % so very few products will be excluded because of perfume quantity. 5.6 Phosphates Phosphates are nutrients that can lead to eutrophication. Eutrophication is still a big problem in many European countries. It is seen as a big problem by many governments and reflected in special legislation in some countries. The main source of phosphorus is runoff from agriculture, but the use of phosphates in cleaning products is a major contributor (about 10 %) to the phosphate released to surface waters in the EU. Part of the phosphate is recovered in WWTPs, but in order to be of maximum use the sludge must be used for agricultural purposes. This is not the case in many countries. Moreover 35 % of the population of the former EU12 is not connected to a waste water system or there is inadequate treatment. In some countries in Northern Europe the use of non-phosphate products is high whereas in other countries phosphate-containing products predominate. Local environmental problems, national legislation and water hardness can partially explain this. The alternatives to phosphates (e.g. adipates and citrates) cause negative environmental impact, too. Phosphate-containing products (approximately %) dominate the European market. Exclusion of phosphates would lead to a very low percentage of the products currently on the market being able to fulfil the requirements. If the necessary changes of the products in order to fulfil the requirements are too large the likelihood that the producers will change their products in order to fulfil the requirements are low. For these reasons exclusion of phosphates is not recommended. However, it is important to give the producers an incentive to lower the quantity of phosphates. It has been proposed by Ecolabelling Norway to reduce the phosphate hurdle to 8 g/wash. Most compact powders and tablets currently on the market contain % phosphates. With a dosage of 20 g/wash this means 7-9 g/wash. However many products contains less than 8 g/wash and many of the products with a high phosphate content are conventional powders who do not qualify anyway because of the high dosage.the CEEP (Phosphate producer's organisation) and their customers have protested, arguing that 10 g/wash is necessary for an adequate wash result. They also point to the fact that STPP has not only a sequestering effect but also other effects such as cleaning effect. Data for water hardness in drinking water in many European countries has been collected. The results show that the water hardness vary a lot, not only from country to country, but also within countries. In Spain the average water hardness is such that 8 g/wash should be sufficient but there are many parts of the country with much higher water hardness. It has not been possible to estimate the percentage of Europeans with water hardness low enough for 8 g STPP pr wash to give a satisfactory result. Hence the current phosphate hurdle has been retained. Most dishwashing machines produced now and the last 10 years are equipped with softening devices. These devices should, if properly maintained, make hard water soft by removing most of the Calcium and Magnesium ions from the incoming water. The softening of water is one of the major functions of phosphates in detergents for dishwashers. If softening devices are in place and working properly there is no more need for phosphates in some regions of Europe than in others. For the other functions of phosphates there are well functioning alternatives. The question that must be answered is whether the alternatives to phosphates have less negative impact on the environment. These questions will be looked into during the coming revision of the criteria. A ban on phosphates will be one of the options considered. In order to give an incentive to further reduce phosphate content a change in the score formula has been introduced in order to reduce the points given to phosphate containing detergents. The score formula has been changed from 2*(4- p/3) to 2*(4- p/2,5). The consequence is that the phosphatecontaining products are "punished" slightly more (via the total score) than in the current situation. If a product contains 7,5 g/wash it will currently get 3 points, according to the proposal only 2 points. The change is motivated by the fact that the eutrophication problems is a big problem in many parts of Europe and the reuse of the phosphates (e.g. for agricultural purposes) is still not a reality in the large majority of Europe. 5.7 Non biodegradable organic compounds (aerobic) This parameter should be seen in connection with the exclusion of not biodegradable surfactants (aerobic and anaerobic) and compounds classified as R50/53 and R51/53. This requirement aim at Page 6 (14)

9 eliminating build-up of compounds in recipients even though some of the compounds does not seem to cause much environmental damage according to the present level of knowledge. No change in the hurdle or weight factor is proposed but some adjustments are made in the formulas. Score formulas: Aerobic degradability: Current formula: anbdo: Score = 4-anbdo/0,05 if anbdo < 0,15 g/wash. Score = 0 if anbdo is between 0,15 and 1 g/wash. Proposed formula: anbdo: Score = 4-anbdo/0,25 if anbdo < 1 g/wash. The new formula gives a larger point sum for most products and hence more motivation to reduce the quantity of such compounds. The score formula has been proposed to apply across the whole range of anbdo values from 0 to 1 g/wash. This means that every reduction of this parameter will earn the producer extra points. 5.8 Non biodegradable organic compounds (anaerobic) The purpose of the annbdo parameter is to avoid build-up of compounds that might cause problems some time in the future. No change in the hurdle or weight factor is proposed but some adjustments are made in the formulas. Hurdles: anbdo: 1 g/wash means 5 % at 20 g/wash total dosage. Anaerobic: 0,2 g/wash means 1 % at 20 g/wash total dosage. Compounds such as perfume and polymers such as PEGs and polycarboxylates are common constituents that are not biodegradable. annbdo: Score = 1,5*(4-annbdo/0,05) if annbdo < 0,15 g/wash. Score = 0 if anbdo is between 0,15 and 0,2 g/wash. Proposed formula: anbdo: Score = 1,5*(4-anbdo/0,05) if anbdo < 0,2 g/wash. Similarly the annbdo parameter score formula has been proposed to apply across the whole range of anbdo values from 0 to 0,2 g/wash. The motivation is simplification and to give the product extra points for every reduction of this parameter. 5.9 Total score In order to give the producers full flexibility this should be the parameter that is most strict, that separates the cream from the others. The hurdles of the individual parameters should only eliminate the worst proportion of the products. The total score hurdle was set to Exclusion of surfactants that are not biodegradable a) Aerobic biodegradability The future EU legislation on detergents is expected to prescribe that surfactants in detergents products for domestic use shall be readily biodegradable under aerobic conditions. Exceptions can be made in certain cases for certain categories of detergents but in these cases a number of other ecotoxicological tests must prove a low potential for adverse effects. The rapid aerobic biodegradability of surfactants in ecolabelled products should be beyond doubt. Hence a complete exclusion of not readily (aerobically) biodegradable surfactants is proposed. The previous limit of 1 g/wash anbdo allowed max 5 % such surfactants at 20 g/wash. Many companies have already substituted the non-easily biodegradable surfactants with degradable alternatives are already cutting out not readily biodegradable Surfactants manufacturers have in the past made great efforts to develop biodegradable surfactants. Page 7 (14)

10 Hence this requirement should be relatively easy to fulfil for most products on the market today. Anaerobic biodegradability The previous limit of 0,2 g/wash anaerobic not biodegradable organic compounds allowed max 1 % such surfactants at 20 g/wash. Most dishwasher detergents have > 1 % surfactants and it is normal to have only one surfactant. The proposed total exclusion of surfactants that are not degradable is thus a moderate restriction. The arguments for this requirement are as follows: i) Surfactants are the most toxic organic compounds used in detergents for dishwashers. ii) The presence of not biodegraded chemicals is one of the major obstacles against the usage of sewage sludge for agricultural purposes. iii) Not biodegraded chemicals can accumulate in sediments and create problems in the future. iv) The proposed requirement will harmonise the ecolabelling criteria for detergents for dishwashers with the criteria for hand-dishwashing agents and all purpose cleaners and cleaners for sanitary facilities. The surfactant producers has objected to the requirement because they claim that the surfactants that are used in detergents for dishwashers (almost entirely non-ionic surfactants) have a low affinity for sludge and sediments and hence will not wind up in anaerobic environments. Experts that Ecolabelling Norway has asked has argued that there is despite the low affinity a high risk that non-ionic surfactants will accumulate in sediments and sludges. The ahwg supported the requirement partly because the environmental properties of surfactants in ecolabelled products should be as good as possible. This requirement will not increase the documentation burden for surfactants used in > 0,2 g/wash (= 1 % if the dosage is 20 g/wash). Surfactants added in smaller quantities must now be documented. This can be done in the following ways. The verification of this requirement can be done in the following ways: By referring to the DID-list. Many of the surfactants used in detergents for dishwashers are listed as anaerobic degradable. By doing an analogy evaluation. If the surfactant is very similar to an anaerobically biodegradable surfactant the surfactant in question may be regarded as anaerobically biodegradable. By performing the ECETOC test. If there is suspicion that the test result is wrong because of other factors e.g. the surfactants toxicity then a low-concentration test with an isotope-labelled surfactant can be used Limitation of compounds classified as R50/53 or R51/53 It is important to reduce the quantity of compounds that are both toxic and have a high bioavailability, i.e. stay a long time in the recipient and or are potentially bioaccumulating. Compounds classified as R50/53 or R51/53 are example of such compounds. The aim is to totally exclude such compounds but a limit of 0 % would create to high a documentation burden that could be a barrier to ecolabelling applications and would have an insignificant environmental impact. Hence a documentation limit of 0,01 % has been set. This limit means that almost all ingredients will have to fulfil the requirement, but that most additives of the detergent ingredients do not have to be documented. Perfumes are often used in 0,02-0,05 %. A documentation limit of 0,01 % means that 1 or a few of the compounds of the perfume mixture will have to be documented, but not all compounds (a perfume mixture can consist of 30 compounds or more!). The last years more and more perfume compounds have been tested regarding aquatic toxicity, bioaccumulation and biodegradability. By setting the limit very low the perfume producers are encouraged to gather more data while at the same time the limit is high enough that the burden of documentation is not too high. Page 8 (14)

11 The use of biocides in detergents for dishwashers is very rare, but they are sometimes used to preserve ingredients such as perfumes and their future use cannot be excluded. They are often present in very small quantities (e.g. the low ppm range) and will be present in < 0,01 %. Biocides are often very harmful to the environment. Hence a restriction of these compounds even below 0,01 % is proposed: No biocide that is classified as, or may be classified as R50/53 is allowed even in quantities < 0,01 % of the final product. Very few other compounds used in detergents for dishwashers are expected to be classified as R50/53 or R51/53. Colouring substances are sometimes classified according to these risk phrases but less harmful alternatives seems to be available. Essentially this requirement is designed to avoid future problems rather than reducing current use of environmentally hazardous compounds. The required documentation is proposed to be declarations from the suppliers of the ingredients used in the detergents. A simple verification possibility is to check the data supplied for the CDV and anbdo parameters Chlorine bleaches The effects of chlorine bleaches on the environment have been the subject of many studies. The most studied compound is sodium hypochlorite that is used for bleaching and disinfection in liquid household detergent products. This compound is also used for disinfecting drinking water and swimming pool water. The compound sodium dichloroisocyanurate is the most used chlorinated bleach in automatic dishwashing powders. This compound reacts to form sodium hypochlorite and cyanurate compounds. Sodium hypochlorite reacts with organic matter. The main environmental concern is the halogenated organic compounds formed. These compounds are often measured as absorbable organic halogens (AOX). About 1 % of the Sodium hypochlorite is converted to AOX compounds. A large proportion of the compounds formed in the initial reactions has been identified: Chloroform and other trihalomethanes; chloroamines; di- and trichloroacetic acids, chloral hydrate and dichloroacetonitrile. Some of these compounds evaporate rapidly while others are converted. It has been concluded that the compounds remaining in the water phase cannot be regarded as potentially bioaccumulating or not biodegradable and only moderately toxic. However a transformation of the AOX compounds takes place in the wastewater treatment plants (WWTP). Very few of the AOX compounds leaving WWTPs have been identified, but studies of the toxicity of these compounds in the relevant concentrations have shown no detrimental effects on the studied organisms. Additionally studies have revealed that the proportion of AOX from household detergents forms a very low proportion of the total AOX in rivers and other recipients in Europe. Thus we do not have any evidence for the claim that the formation of AOX compounds from chlorinated bleaches poses an important environmental problem. The chlorinated bleaches are highly toxic and as such products containing these compounds are excluded via the CDV parameter. But do we have enough evidence to support the specific exclusion of chlorinated compounds? For ecolabelling purposes it is common to apply the precautionary principle to exclude or limit compounds that have not been proven to have especially bad effects on the environment, but for which there is considerable concern that future research may reveal that they cause a large environmental impact. This is the case for not biodegradable organic compounds. It has not been proven that these compounds will cause a large environmental impact but as they are not biodegradable they might accumulate in recipients and cause problems that will only be known in the future. Hence the precautionary principle is appropiate in this case. Not all AOX compounds formed by chlorinated bleaches have been identified. Some of these unidentified compounds may be problematic for the environment. They may end up in sewer sludge, air or water recipients. Even though studies have shown that there are no effect s of AOX compounds in water leaving a WWTP in the realistic concentrations it must be remembered that it is the effect of all effluents together on the recipients that is important. The AOX compounds are not the only contaminants in the river. AOX compounds have not been reported found in sludge but if they are they will surely cause concern and may reduce the willingness to use these sludges for farming purposes. Page 9 (14)

12 The main question is: are the environmental problems caused by chlorinated bleaches worse than those caused by the alternative compounds, especially perborates and percarbonates in the necessary functional quantities? Due to lack of data this question cannot be answered. However, chlorinated bleaches are highly toxic and should be classified as R50/53. As such they will be eliminated by the exclusion on compounds classified as R50/53 and R51/53. The CDV and Total Score of product s with chlorine bleach will be very high. The following calculations demonstrate this effect: Powders (20 g/wash is assumed): Sodium dichloroisocyanurate Typical concentration: 3 %. Lowest LC50: 0,22. Uncertainty factor = 100.Calculated NOEC using procedure in criteria: 0,0022. LF=0,01. CDV= 2727 If the concentration is only 0,1 %: CDV= 91.This leads to a decrease of the Total Score of: 12 Liquids (22 g/wash (excluding water) is assumed): Sodium Hypochlorite Typical concentration: 2,5 %. Lowest LC50: 0,14. Uncertainty factor =100. Calculated NOEC using procedure in criteria: 0,0014. LF=0,01. CDV=3925 If the concentration is only 0,1 %: CDV= 157. This leads to a decrease of the Total Score of: Requirements on fragrances When developing ecolabelling criteria for detergents the opinion that fragrances should be excluded is always raised. Fragrances are seen as not contributing to the function of the product and hence an unnecessary burden to the environment. They are also seen as potential health risks due to allergy problems. It has been decided not to ban fragrances because of concerns that unperfumed products might not be acceptable for a large proportion of consumers, even though nonperfumed products are sold in many countries. The current proposed criteria contains restrictions on perfumes both quantitatively, indirectly through CDV and Total Score, and qualitatively through the exclusion list of perfume compounds and the limit of compounds classified as R50/53 and R51/53. In the current criteria even very small quantities of perfume contribute a lot to the CDV and hence decreases the total score a lot. With a dosage of 20 g/wash, 0,1 % perfume gives a contribution of 100 in the CDV. This reduces the total score by 13,3 points! Many products have less perfume than this. Some products have as little as 0,01-0,02% perfume content. Hence the increase in total score is expected to have little effect on the perfume content of these products. The proposed extension of the exclusion list of perfume compounds has been proposed in order to harmonise the criteria with those of all purpose cleaners and sanitary cleaners and hand dishwashing detergents and to avoid possible future problems. We have no indications that these compounds are used in machine dishwashing agents. In fact many of these compounds have only been found in cosmetic products. The requirement that the fragrance use should abide with the recommendations laid down by IFRA is proposed in order to prevent health risks connected with the use of perfumed machine dishwashing detergents. It does not take into account environmental risks Packaging It is proposed to retain the requirements on packaging in the current criteria with the exception that the requirement that the packaging should be recyclable or reusable has been omitted. The reason is that Page 10 (14)

13 the requirement is too vague and hence very difficult to verify. If the requirement should be kept the terms recyclable and reusable would have to be defined. A study of the potential environmental benefit would also have been necessary. The limited scope of this revision has not allowed such a study. Packaging gives a relatively minor load compared to the load caused by the ingredients of the products and the use phase. Very little data on packaging has been made available to Ecolabelling Norway during this revision. Hence no changes in the other packaging criteria is proposed Other issues Limit on phosphonates The current criteria set a limit of 0,2 g phosphonates pr wash. The main reason for the limitation of the phosphonates is their low biodegradability. There now exists phosphonates that are readily biodegradable. In order to promote a further development towards biodegradable phosphonates it is proposed to only limit phosphonates that are not readily biodegradable. Exclusion of EDTA EDTA are excluded because they have low biodegradability (very little degradation takes place < 14 ºC) and have a potential for remobilizing heavy metals from river beds etc. Exclusion of NTA NTA has been proposed added to the exclusion list because of low biodegradability and because it is a suspected carcinogen. It has also been excluded in the other detergent criteria. Tools for correct dosage This problem obviously does not concern tablets except for their use in small dishwashing machines. However, powders and liquids can be overdosed and very often it is. The AISE "Wash right" campaign addressed the problem, but should more be done? It is a paradox that a product can be awarded an ecolabel with a total score (or another parameter) slightly above the set limit and the consumer may easily apply double dosage because of lack of appropriate tools? 6. Performance test Ecolabelling Norway has received very few comments on the performance test. Some have complained that the requirement on removal of tea stains is very difficult to achieve. Others are of the opinion that the test is too expensive. One producer feels that it is unfair that his product with a very low dosage is compared to a reference detergent of much higher dosage. Experts on dishwasher detergent performance tests warn that the tea spot should be kept in the test as it is one of the most difficult soils to remove and is hence a good measure for cleaning performance. However, as the highly efficient chlorine bleaches are prohibited it might be a good idea to look at the requirement on degree removal (grade). The test costs Euros for one product in European test laboratories. A cheaper test has been asked for, but no suggestions have been given. At the end of the revision work it has been proposed to accept a modified version of the test method EN , a test developed to test the function of dishwashing machines. The modifications are small; the most notable being that the test is conducted at 55 C instead of 65 C. 7. Other criteria 7.1 Consumer information The information on the packaging has been slightly modified. The following phrase has been removed: - use detergents that work at temperatures lower than 65 C was removed because all eco-labelled has been tested and proven to work at 55 C. Instead the proposal states: This ecolabelled product works well at low temperatures. Page 11 (14)

14 7.2 Information appearing on the label Together with the label 2 phrases is psoposed to be displayed: 1. Helps reduce water pollution 2. Helps reduce packaging This text indicates for the consumer the primary environmental benefits of the ecolabelling for the consumers. Other effects include: Reduction of resource use and transport work (and hence reduced fuel use and air pollution) through reduction of Total Chemicals. Reduction of energy use during the use phase through the performance test which ensures that the product works well at 55 C and through the consumer advice given on the packaging. Reduction of the quantity of sludge waste by reducing detergent residues in the sludge and hence making it easier to use waste water treatment sludge for agricultural purposes. Reduction of build-up of poorly biodegradable chemicals in water recipients and sediments and hence a minimisation of the potential for problems in the future. Reduction of the eutrophication problem through limitation of phosphate discharge. 8. Consequences of the proposed changes 30 product formulations from both North and South Europe have been examined. The consequences of the proposed changes are: Requirement Average Range Number of products that fulfil CDV Total chemicals Phosphates ,5 21 (24 if hurdle = 10) anbdo 0,32 0-1,1 29 annbdo 0,03 0-0,33 29 Total score 28,9 3, All requirements % of the products fulfil the criteria. Based on an assumption that these products are representative for compact powders and tablets in Europe and that compact powders and tablets make up 60 % of the market, a total market share of 24 % is estimated. Conventional powders do not fulfil the criteria. The so-called 3-in-1 tablets are also excluded because of the high content of surfactants. Liquids commonly have a high dosage (35-40 ml), but the dry content is not known. It is assumed that liquids cannot fulfil the criteria because of high surfactant content and high dosage. Compact powders and tablets with perborates or chlorine bleaches must change to less toxic alternatives like percarbonates (+ TAED) in order to fulfil the requirements. Page 12 (14)

15 Table 4. Typical tablet products that fulfils the criteria Component Quantity with phosphate Quantity without phosphate Non-ionic surfactant (LTE=0,2, 2,5 % 2,5 % LF=0,03) Polycarboxylates 4 % 4 % Na-carbonate 3 % 3 % STPP 40 % 0 % Na-sulphate 12 % 12 % Na-percarbonate 10 % 10 % TAED 5 % 5 % Na-disilicate 20 % 20 % Enzymes 3 % 3 % Perfume 0,02 % 0,02 % Na-citrate 0 % 40 % Dosage 20 g/wash 20 g/wash Calculations Total chemicals 20/5 20/5 CDV (value/points) 120/24 122/24 Phosphate 8/0 0/8 ANBDO 0,8/0,8 0,8/0,8 AnNBDO 0,9/3,2 0,9/3,2 Total points Table 4. Typical compact powder product that fulfils the criteria Component Quantity Non-ionic surfactant 1,5 carbonate /bicarbonate 20 Citrate 35 Enzymes 3 Polymers 4 Percarbonate 17,00 perfume formulation as used 0,02 Phosphonates 0,80 Silicate 15 Silicone 0,15 TAED 2,50 Dosage 20 g/wash Calculations Total chemicals 20/5 CDV (value/points) 115/25 Phosphate 0/8 ANBDO 0,8/0,8 AnNBDO 0,09/3,2 Total points 42 Page 13 (14)

16 9. Potential environmental benefits of the ecological criteria Ecolabelling criteria can give an environmental benefit in many ways: 1. Product formulations may be changed in order to obtain an ecolabelling license. 3. The ecolabelling criteria may be used in benchmarking, i.e. in developing new product formulations without the intention of applying for a license. 4. The market share of products that fulfils the criteria increases. 5. The consumer's awareness increases which means they are more likely to do what they can in order to reduce the environmental load caused by dishwashing. It is very difficult to estimate or calculate the actual environmental load from ecolabelling criteria. Firstly it is impossible to know what would have happened if the criteria had not existed. Additionally the product formulations of the conventional powders and other products that do not fulfil the criteria are not known well enough. The greatest difficulty stems from the fact that, because of the environmental matrix the producers can choose which parameters they want to work on in order to fulfil the total score parameter. They can choose to decrease CDV, phosphate content or content of organic compounds that are not biodegradable aerobically or anaerobically. However, calculations can be made to show the magnitude of the environmental benefit potentially achievable through ecolabelling. Table: Potential reduction of environmental load if all products in Europe would fulfil the proposed ecolabelling criteria Parameter Total chemicals Phosphates anbdo annbdo Chlorine bleaches Non anaerobically biodegradable surfactants CDV translated as Organic chemicals Inorganic chemicals Reduction tons ton tons tons tons tons 1200 billion litres 9000 ton tons These calculations show the potential benefits if all products on the European market are ecolabelled. The results must not be interpreted as accumulative. The reduction will not be tons of total chemicals and tons phosphates and tons non-aerobically biodegradable organics, etc. A certain overlap will happen. This is especially true for non-anaerobically degradable surfactants as these are, by definition, annbdo compounds. Chlorine bleaches are however kept out of the calculations of potential CDV reduction. The potential CDV reduction has been calculated from the chemicals that will be removed from European products if all products are ecolabelled. The quantity of billion litres signifies the quantity of water necessary to dilute these "extra" chemicals to a level that no effects of the m will be noticed. In order to make this more comprehensible the CDV reduction has been translated as a reduction of 9000 tons organic chemicals (with a medium toxicity and removal rate) and tons inorganic compounds. Page 14 (14)