Detergent phosphates and detergent ecotaxes€¦ · 5. Ecotaxation of detergent phosphates and other economic instruments 16 5.1 Criteria for the design of ecotaxes and their application

Detergent phosphates and detergent ecotaxes: a policy assessment.

C E E PCentre Européen d'Etudes des Polyphosphates

EUROPEAN CHEMICAL INDUSTRY COUNCIL

Dr. Jonathan KöhlerDepartment of Applied Economics University of Cambridge, UK.

This report was prepared by Dr. Jonathan Köhler,Department of Applied Economics - University of Cambridge,UK, for the Centre Européen d'Etudes des Polyphosphates,the Western European phosphate industry's joint researchassociation (a European Chemical Industry Council - CEFIC -sector group). March 2001.

Dr. Jonathan KöhlerDept. Applied EconomicsUniversity of Cambridge,Sidgwick AvenueCambridge CB3 9DE, United KingdomTel (44)1223 33 52 89 Fax (44) 1223 33 52 99E-mail: [email protected]

avenue E. van Nieuwenhuyse 4, bte2B1160 Bruxelles, BelgiumTel (32) 2 676 72 11Fax (32) 2 676 73 01Email : [email protected] web : http://www.ceep-phosphates.org

A report prepared for the CentreEuropéen d'Etudes des Polyphosphates -a European Chemical Industry Council

(CEFIC) sector group. March 2001

C E E PCentre Européen d'Etudes des Polyphosphates EUROPEAN CHEMICAL INDUSTRY COUNCIL

Photos front cover :Chevallier, Bourgoin-Jallieu, France.

Printed on100% recycled/woodfree paper

Detergent phosphates and detergent ecotaxes : a policy assessment

Dr Köhler,

Dept. Applied Economics,

Page N°Executive Summary 3

1. Introduction 6

2. The use of phosphates in household laundry detergents 62.1 The alternatives to phosphate use as a builder in detergents 7

3. Detergent phosphates in waste water: are they a pollutant? 93.1 Phosphates and eutrophication 93.2 Contribution of detergent phosphates to phosphate loading 10

4. Policies on detergent phosphates and their consequences 114.1 Pollution control policies 114.2 Consumer reactions and trends in phosphate use 15

5. Ecotaxation of detergent phosphates and other economic instruments 165.1 Criteria for the design of ecotaxes and their application to detergents 175.2 The French TGAP 185.3 Tradeable permits 20

6. Implications for the detergent phosphate industry 216.1 Position in the supply chain and detergent market conditions 216.2 Structure of the detergent phosphate industry 22

7. Possible future policies for phosphates 227.1 Objectives of future policies on phosphates 237.2 Applicable environmental policies and their economic implications 237.3 Taxation of domestic phosphate products 237.4 Policies for diffuse sources 24

8. Summary and Conclusions 24

9. References 27

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Dr. Jonathan Köhler has five years' experience asResearch Officer at the Department of AppliedEconomics, Cambridge University, UK.He specialises in research into environmental andtransport policy using macro-econometric models.His work covers areas such as greenhouse gasabatement and climate change policy analysis,ecotaxes, expenditure on environmentallysensitive goods. He co-authored "International Competitivenessand Environmental Policies" (Cheltenham, 1998)and his recent work includes reports for the Cambridge University, UKEuropean Commission and for the OECD.

Contents

t ecotaxes : a policy assessment

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Executive Summary

The reason that the use of phosphates in detergentsremains an issue is that there is a continuing problemwith eutrophication, which is the nutrient enrichmentof water, and which can lead to the growth of algaeand cyanobacterial blooms in European surfacewaters. These are unsightly, often have an unpleasantodour and can be toxic. The growth of algae andcyanobacteria also depend on the water temperatureand the availability of sunlight for photosynthesis.Warm water temperatures and plenty of sunlight maycombine with slow flowing or stationary water to givethe conditions under which blooms can grow.Eutrophication is caused by inputs of nutrients,phosphorus and/or nitrogen, into surface waterecosystems that are far higher than the natural level.The main sources of phosphorus in Western Europeare animal manure and fertilisers used in intensivelivestock agriculture and human waste in urban wastewater. Phosphates used in domestic laundry detergentsmay make a significant contribution to the phosphatecontent of urban waste water in some areas.

Phosphates and STPP in particular perform a vitalfunction in modern synthetic detergents, althoughthere are substitutes, of which the most successful iszeolite combined with polycarboxylate. Life cycleanalyses suggest that there is little to choose betweenSTPP and zeolite-polycarboxylate formulations interms of their environmental impact, but STPPremains the most effective ‘builder’ in laundrydetergents.

In order to control eutrophication, many countrieshave acted to control the use of STPP in laundrydetergents. Laundry detergent formulations usingSTPP are no longer sold in Germany, Italy,Switzerland, Austria and Norway in Europe, as well asthe US and Japan. More recently, more coherentpolicy packages regarding eutrophication have beendeveloped, with one of the main actions being theinstallation of equipment to remove phosphorus fromurban waste water.

Another policy tool has been the adoption ofecolabels. There is no clear message to be put acrossby such a system, as the phosphate content ofdetergents is often not a significant contributor toeutrophication. This is reflected by the Scandinavianand EU detergent ecolabels, which allow phosphatesto be included.

These policies have been partially effective so far. Itis now generally accepted that a large reduction inphosphorus loading can enable surface waters torecover from cyanobacterial blooms and turbidity, buteach site has to be considered individually. Therefore,the continuing investment in phosphorus removal insewage plants will eventually control cyanobacterialblooms in many instances, in particular where themain nutrient loading comes from urban waste water.Countries such as Italy, where blooms are still a majorproblem and there are relatively few phosphorusremoval installations will benefit considerably fromthese policies.

Future policy should be based on local responses tolocal problems within an overall legal framework, apoint insufficiently emphasised in the currentliterature but clearly developed in the new EU WaterFramework Directive. Continuing investment inphosphate removal at sewage plants is the first part ofa policy to control eutrophication. The next step,which is much more difficult, is to control phosphorusloading from agriculture. Then there is the question ofwhat to do with the phosphorus when it has beenremoved. Phosphorus removal in sewage plantsproduces sludge, which must be used or disposed of.As it has high transport costs, the most economicoption is to use the sludge as fertiliser in the areasurrounding the sewage treatment plant. However,there are obstacles to sludge spreading. Limits forheavy metal content and the presence of othercontaminants such as brominated flame-retardants orpathogens and farmers’ refusal for image/food qualityreasons mean that sludge spreading may beinsufficient. There are several alternatives. Thesimplest is to dry and incinerate the sludge, but thisrequires careful treatment to control combustionproducts. There are alternative uses, such as dryingand using for building materials or paving slabs, as hasbeen practised in Japan. A further possibility is torecover and recycle the phosphorus in a form useableby the phosphate industry or as fertiliser. All thesealternatives require investment in some degree.Recycling into industrial processes has the additionalcomplication that phosphate manufacturers wouldhave to alter their production organisation to acceptthe recycled phosphorus instead of phosphate rock,although since the rock has quite a high heavy metalcontent, the production process could probably bemade cheaper. Regional recycling as a fertiliser, eitherdirectly or after simple processing, may offer betterlogistics and economics.

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Any further regulatory controls on phosphates indetergents would be very unlikely to influence theextent of cyanobacterial blooms. Since each localproblem has to be resolved by regional action, policiessuch as a general tax on detergents are not relevant asenvironmental policies.

This report considers ecotaxation in particular. Thefundamental principle of ecotax design is that it shouldprovide an incentive for the polluter to change theirbehaviour in a way that reduces the undesirable orpolluting activity, in this case eutrophication. Smith(1997) argues that the earmarking of tax revenues doesnot have an economic justification, but is used to makethe introduction of a tax more acceptable.

The use of a national tax on detergents containingphosphates is problematic for several reasons. Anational tax takes no account of local variations, so alarge proportion of taxpayers will be facing extra costsfor no environmental gain. In many areas, the mainphosphate loading will come from agriculturalsources, so a detergent tax does not address theproblem. Even if the main problem comes from urbanwaste water, a reduction in detergent use will notprevent eutrophication in most cases. Consumers willalways wish to wash clothes and will not be verysensitive to changes in detergent prices. Householdexpenditure on detergents is also a small proportion ofexpenditures, so a significant increase in price ofdetergents is unlikely to cause consumers to use muchless. An impracticably high rate of tax on detergentswould be necessary to have any significant impact onthe incidence of eutrophication.

In overall environmental terms, given that there islittle difference in life cycle impact between thephosphate and non-phosphate detergents, there is notmuch point in taxing just phosphate detergents asopposed to all detergents. If there is a significantdifference in tax levels or only a tax on phosphatedetergents, there will be a reduction in demand forphosphate detergents.

The sole example of a tax on detergent phosphates isthe French TGAP, which taxes all detergent purchaseswith a somewhat higher rate of tax applicable tophosphate-containing detergents. The TGAP ondetergents will not be successful at addressing theenvironmental problem of cyanobacterial bloomscaused by eutrophication, although it will slightlyimprove the overall efficiency of the tax system. Theimpact on social equity is small. It will not change

consumer behaviour. Taxing all detergents rather thanonly those with STPP has no significantenvironmental implications and will maintain a placefor STPP formulations in the French detergent market.

With regards to the phosphate industry, the overallconclusion is that STPP manufacture can remain arelatively small, but significant activity for thechemical industry for the foreseeable future and thateffective policies to control eutrophication are entirelycompatible with the continued or even expanded useof STPP in laundry detergents. In recent years, therehas been innovation in new products such as‘compact’ powders and tablets. These help to preventthe excessive use of detergents and therefore reducethe environmental impact of detergents. STPP isparticularly suitable for use in both of these new typesof product and this should contribute to the continuingpresence of STPP in the detergent market.

In terms of policies for detergent phosphates, anyfurther controls by regulation or taxation would bevery unlikely to influence the extent of cyanobacterialblooms and algae. Since each local problem has to beresolved by regional action, policies such as a generaltax on detergents are not relevant as environmentalpolicies.

Future policy should be based on local responses tolocal problems within an overall legal framework, apoint insufficiently emphasised in the currentliterature, but highlighted in the new EU directive onwater treatment. Continuing investment in phosphateremoval at sewage plants is the first part of a policy tocontrol eutrophication. The next step, which is muchmore difficult, is to control phosphorus loading fromagriculture. This could be achieved through acombination of improved use of fertilisers andmanures and taxes on the use of phosphates inagriculture.

Since phosphate removal will become morewidespread, this problem will have to be addressed.For now, recycling technology is being developed andis close to being applicable on an industrial scale.Therefore, policy should encourage the formation ofmarkets for sludge or recycled phosphate products.There are many ways in which this could be achieved:by voluntary agreement with water companies,phosphate manufacturers and agricultural businesses;by legislation to require the removal and disposal ofphosphorus and the associated by-products or bytaxation on point and diffuse sources of phosphorus.


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1. Introduction

Laundry detergents are an item that appears oneverybody’s shopping list; they perform one of thebasic household functions. An important ingredient ofmany detergents is phosphate in the form of sodiumtripolyphosphate (STPP). Its introduction in syntheticdetergents in 1948 heralded a step increase inperformance over the soap-based products that hadbeen used before. Subsequently, the markets forsynthetic detergents grew rapidly in Europe and theUS and the production of STPP became a significantpart of the phosphate industry, although it has alwaysremained a relatively small part of the market incomparison to fertilisers, which account for 85% ofphosphate production.

One consequence of the use of STPP in the domesticenvironment can be increased phosphate in householdwaste water, which may then contribute to thephosphorus load in rivers, lakes and inshore waters.The presence of phosphates in waste water can be anenvironmental issue because of “eutrophication”, theincrease of nutrient levels in water, which can lead toenvironmental problems such as the formation of largemasses of algae or blooms which are unsightly,causing slow moving water to be turbid, and may betoxic. Therefore the use of STPP in detergents hasbeen controlled and its use reduced. The removal ofphosphates in sewage treatment plants has been shownto be very effective in reducing the phosphate load inrivers and lakes. However, the presence ofcyanobacterial blooms and turbidity is still animportant environmental issue in many Europeancountries.

This report considers the potential for further controlof STPP use in household detergents as a part ofenvironmental policy for phosphorus, the probableeffectiveness of tighter controls for improving theenvironment and the consequences for the consumerand the STPP industry. Commercial laundryoperations and detergents used in industry are notaddressed. Although a quantitative economic analysisis beyond the scope of this report, qualitativeprovisional conclusions are drawn for the probableimpact of the different policy instruments on theenvironment and the phosphate industry. Section 2explains why phosphates play such an important partin many laundry detergents and briefly surveys thealternative chemicals that can be used. Section 3covers the environmental issues associated with

phosphates in surface waters – the problems which candevelop due to eutrophication – and considers whetherdetergent phosphates play a significant role. Section 4surveys the history of environmental policy ondetergent phosphates, including a discussion of thenew French tax (TGAP) and the subsequent reactionsin the consumer markets. Section 5 contains a briefqualitative analysis of the current market conditionsfor STPP. Section 6 proceeds to consider the ways inwhich environmental policy might effectively addressthe continuing issue of eutrophication in the future andthe economic implications of the policies. Section 7concludes.

2. The use of phosphates inlaundry detergents

The reason why phosphate compounds and inparticular STPP are used in detergents is that they turnout to perform several very useful functions. No othersingle chemical product has been found whichperforms the same combination of functions as‘builders’ and contributes so effectively to theperformance of modern household detergents, wherewashing temperatures are low and soiling of theclothes is generally relatively light. STPP performs thefollowing functions (Davidsohn & Milwidsky, 1978):

1. As with all complex phosphates,STPP isalkaline, so it counteracts hardness inwater.‘Hardness’ means that the water contains salts such ascalcium chloride or magnesium chloride, which willleave crusty deposits on the clothes. Dirt and thetextiles may also contain calcium and magnesiumions. STPP reacts with these salts to combine theminto other phosphate containing compounds which donot precipitate, so avoiding further deposits ofprecipitated crystals on the clothes. This has theadditional advantage of preventing deposition on theheating elements in the washing machine (Merkenichand Gohla, 1979).

2. A combination of 50% detergent and 50%STPP provides a more effective washing performancethan using 100% detergent, other factors being equal.Condensed phosphates increase the surface activity ofthe active washing compounds (Ullmann, 1999). Anadditional effect is that the alkaline STPP raises the pHvalue in the wash liquid (i.e. acts as a chemicalbuffer), which means that the ions in the dirt andtextile fibres become more strongly charged. This in

nt ecotaxes : a policy assessment

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turn leads to increased repulsion between the ions inthe dirt and in the textile, thus increasing washingperformance. Of all the phosphate compounds, STPPhas the greatest synergy in these respects.

3. Complex phosphates such as STPP‘deflocculate’, which means that they break up largeparticles of e.g. mud or clay into smaller ones.Furthermore, they keep fine particles in suspension inthe washing water and prevent them recombining, thusavoiding redeposition on the clothes. Related to thisproperty of deflocculation, they emulsify oilymaterials, that is they also break up oily masses intosmaller particles.

4. Because of the alkalinity of STPP, it willredissolve Calcium and Magnesium compounds thatare present from detergent in previous washes and willreactivate any remaining soap. Therefore, theperformance of the detergent is enhanced in this case.

This combination of functions means thatphosphates and STPP in particular can play a veryimportant role in the washing process. If phosphatesare not used, they must be replaced with some materialor combination of materials that performs a similarcombination of functions, if the performance of thedetergent is to be maintained. In recent years, there hasbeen innovation in new products such as ‘compact’powders and tablets. These help to prevent theexcessive use of detergents and therefore reduce theenvironmental impact of detergents. STPP isparticularly suitable for use in both of these new typesof product.

2.1 Alternatives to Phosphates in Detergents

As will be shown in sections 3 and 4 below, concernabout the environmental impact of phosphates insynthetic detergents resulted in the introduction ofvarious controls and restrictions on the use ofphosphates in household detergents. This led to asearch for alternative builders. Several replacementshave been tried:

Sodium citrate

Sodium citrate was utilised as a builder, but it hassome disadvantages (Stinson, 1987). It is considerablymore expensive than STPP (twice as much at thattime) and does not perform as well in removing

calcium and magnesium ions. This lower performanceis least marked at very low temperatures.

Ethylene diamine tetraacetic acid (EDTA) and Nitrilotriacetic acid (NTA)

Both of these chemicals are effective at abstractingcalcium and magnesium ions and NTA in particularcan largely replace STPP as a builder (Perry et al,1984). However, it does not buffer as strongly as STPPand is less effective as a particle disperser. The mainproblems with NTA are that there has been someevidence that it is carcinogenic and its great strength incombining with metal ions has caused fears that heavymetals in sewage sludge may be taken up and hencemobilised (Perry et al, 1984).

This could then result in peak concentrations ofheavy metals in rivers and lakes being above regulatedlevels. Brouwer and Terpstra (1995) argue that thislatter risk is not significant. These environmentalconcerns have resulted in both EDTA and NTA beingexcluded from EU Ecolabelable automatic dishwasherand domestic laundry detergents.

Zeolite A and its cobuilders

The most successful alternative has been zeolite A, arelatively inert substance derived from aluminiumoxide (Landbank, 1994). It has a reasonableperformance in abstracting calcium and magnesiumions but is limited as a builder. It does not bufferduring the washing process and does not preventredeposition of soil particles in the wash liquid, so ithas to be used with a cobuilder, usuallypolycoarboxylic acids.

These are oil-based compounds that soften waterand keep soil particles in suspension. Zeolite-PCAbuilders are now used in almost all countries whereSTPP is no longer used, in particular the USA,Germany and Italy. It is also extensively used in liquiddetergents. Its real advantage appears to be that itnever been perceived as presenting a seriousenvironmental problem, although concern has beenexpressed over the impact of PCAs on heavy metals inwater sources (CES, 1991) and it provides reasonableperformance for modern household detergentpowders.

It also results in increased volumes of sludge fromsewage treatment plants in comparison to STPP.Zeolites and PCAs contribute significantly to volumesof sludge produced by sewage works, probably


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generating significantly more sludge than detergentphosphates in cases where either sewage P-removal isnot necessary, where P-removal is carried outessentially by biological processes or if P-recycling isinstalled. The inclusion of zeolites in detergents isestimated to increase sewage works sludge productionby 15% (FRWA, 1996).

Comprehensive life-cycle comparisons of STPP andZeolite A – PCA has been undertaken for Europeanconditions (Landbank, 1994 and Landbank, 1995).They found that the overall environmental impact ofthe two builder systems was roughly equal in both theUK, which has relatively simple waste water treatmentand in Scandinavian countries which have veryadvanced waste water systems. Landbank (1995)concludes that using STPP exclusively as a builder isthe option with the lowest environmental impact interms of waste water treatment only.

This is mainly because zeolite builders result in agreater volume of sludge from sewage treatmentworks and because zeolites and PCAs have norecycling value, whereas phosphorus can be usefullyrecovered and recycled. Although Life Cycle Analysismethodology has evolved since these studies, morerecent work (EMPA, 1999) has confirmed thecoherence of theses studies’ data and conclusions.

In summary, there has been extensive research intoalternatives to phosphates and STPP in particular as abuilder. For household powder detergents, which areusually required to operate with medium to lightsoiling of the washing and washing machines utilisingrelatively low temperatures, STPP is the mostappropriate builder taking into account itsenvironmental impact and cost to the detergentproducers. It is particularly useful for heavy soiledwashes, it is extensively used in industrial laundrydetergents as well as in dishwasher detergents, even incountries where it is no longer present in householddetergents.

3. Detergent phosphates in wastewater: are they a pollutant?

This question has to be addressed in two stages:firstly, do phosphates in water cause environmentalproblems and secondly, if there is a problem, whatis the contribution of household waste water and inparticular detergent phosphates to these problems?

3.1 Phosphates and Eutrophication

The environmental issue associated with phosphatesis eutrophication and the subsequent growth of bloomsof cyanobacteria and microscopic algae.Eutrophication describes a situation in which a bodyof water receives an increased supply of plantnutrients which provide the conditions for the rapidgrowth of these blooms. Both phosphorus andnitrogen are essential chemicals for plant growth, butare only required in very small quantities under‘natural’ conditions. Therefore, if the supply of eitherof these nutrients is suddenly increased, the conditionsfor plant growth will change and the eco-system willadapt. In particular, given suitable environmentalconditions, blooms will form. Jones and Alexander(1989) and Haas et al. (1988) provide empiricalevidence that phosphorus can be the limiting nutrientdetermining the extent of blooms. The growth of algaeand cyanobacteria also depend on the watertemperature and the availability of sunlight forphotosynthesis. Warm water temperatures and plentyof sunlight may combine with slow flowing orstationary water to give the conditions under whichblooms can grow.

It is important to note that the size of blooms isgoverned by these different limiting factors. If thewater is warm, there is plenty of sunlight and therequisite minerals, but initially a low level ofphosphate, then the introduction of phosphate willcause a growth of the blooms. However, if there isalready plenty of phosphate and the growth is limitedby, say, nitrogen, then the addition of phosphate willnot cause any growth. The relationship betweenbiomass and phosphorus has been statisticallyestimated in the ‘Vollenweider model’, but because ofthe other potentially limiting factors, there is nocontinuous function between biomass and the quantityof phosphate (Reynolds, 1992). Cranfield et al. (1989)report that while blooms are associated witheutrophication, there is generally a low correlationbetween cyanobacterial biomass and total phosphorus


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or total nitrogen. Gde and Gries (1998) consider thatbiological productivity cannot be accurately predictedby simple phosphorus load approaches.

Algae and cyanobacterial blooms are a problem forthe environment. The growth of large masses of theseblooms may lead to the deoxygenation of deeperwaters, threatening rare fish species and invertebrates.Reeds and other submerged plants may be lost andthere can be indirect effects on herbivorous birdspecies. There is thus a loss of the variety of habitatand hence diversity of species (Lund and Moss, 1990).The blooms may also block water filtration systems.Cyanobacterial blooms in particular may have anoffensive odour and colour, forming noxious scumsand may be toxic (Howard, 1994). Kelly andPontefract (1990) report an incident at Rutland Water,

UK in 1989 in which a total of 15 dogs and 20 sheepdied after drinking contaminated water. Turner et al.(1990) report an incident at Rudyard lake, Staffs., UKwhere a group of soldiers suffered from gastro-intestinal ailments, one from hallucinations andanother from atypical pneumonia. In 1989, 169 waterbodies in England and Wales were considered to haveproblems with cyanobacteria and 68% of 78 sitestested were found to have cyanobacterial toxins(NRA, 1990). However, Lund and Moss (1990)consider that in the UK, the growth of cyanobacterialblooms is localised, rather than a widespread problemacross the UK. They also report that the incidence ofenvironmental problems due to eutrophication in the

UK was at a similar level in the 1980s compared withthe 1970s. Up to 1989, 16 European countries hadreported blooms (Lawton and Codd, 1991) andblooms have been reported in Australia, Canada,Japan, South Africa and the USA (Howard, 1994).Morse et al. (1993) summarised the situation inEurope at the beginning of the 1990s in the followingtable:

3.2 Contribution of detergent phosphates tophosphate loading

Detergent phosphates are a significant, butsecondary, source of phosphates in rivers and lakes.Humans and animals are by far the most importantsources. Morse et al. (1993) state that of phosphorusinput to the aquatic environment in the EU, the most

important contributors are livestock waste (34%),human waste (24%) and agricultural fertilisers (16%).Detergent phosphates form 10%. UKWIR (1997) statethat for waste water input to sewage plants, the mostimportant source is human waste, detergents formbetween 9% and 50% and that manufacturers’estimates were 40%; a current manufacturers’ estimateis 20-25% (Duley, 2000); and industrial processescontribute 9% in the UK. Between 30% and 90% ofphosphorus loading in rivers is from non-point sourcesi.e. agriculture (Sharpley et al., 1995) and this range isconfirmed by McCann and Easter (1999) who statethat in the Minnesota River, US, non-point sourcescontribute 35% of phosphate loading with low rainfallup to 90% loading in high rainfall. There are some


Country Extent Key areas affected

Belgium High Most inland watersDenmark High Most inland waters, North Sea, Kattegat, BalticFrance Low Loire, Meuse, Saone and possibly other riversGermany High Many inland waters, Bavaria, Rhine, North Sea,

BalticGreece Medium Potential threat to limited inland and coastal watersIreland Medium Potential threat to inland watersItaly High Most lakes and reservoirs, Rivers Arno, Tevere, Po,

AdriaticLuxembourg MediumNetherlands High All inland watersSpain Medium Many inland watersPortugal LowUK Low Lough Neagh, Anglia, some other local areasSwitzerland High Many lowland lakesSource: Morse et al. (1993)

Table 1: Extent of waters affected by eutrophication

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surface waters in which the phosphorus load isdominated by point sources. In 1989 the river Po,Italy, received 67% of phosphorus from point sourcesand 29% from agriculture; the German Rhine received77% from point sources and 23% from agriculture in1985. For 1989-1992 in all of (West) Germany, 52%came through point sources and 42% from agriculture(EEA, 1998b). UKWIR (1997) make the claim that‘If, as seems probable, this load is dominated byparticulate and biologically unavailable forms then itis reasonable to deduce that the soluble andbiologically active phosphate fraction discharged torivers is often 85-90% derived from secondary sewagetreatment’ (UKWIR, 1997, p19). However, thisassertion is not supported by any evidence and is incontradiction to Morse et al. (1993) and McCann andEaster (1999).

The conclusion to be drawn from this evidence isthat phosphates may indeed cause seriousenvironmental problems. Kolber (1990) states thatdetergents led to 40% of water ‘over-fertilisation’ inAustria. However, the conditions under which theseproblems arise are limited and inherently site specific.Thus it is not possible to determine in general whetherthe removal of a certain amount of phosphate willreduce the incidence of blooms or whether an increasein will cause blooms to develop or grow. Furthermore,the contribution of household detergents to the totalphosphate load that finds its way into rivers, lakes andreservoirs varies considerably. Where phosphorusloading is dominated by waste water inputs,phosphorus from detergents might contribute up to25% or so of the phosphorus loading. Therefore, thereduction or removal of phosphates in detergents willonly have an environmental impact under veryspecific and limited conditions and where phosphateremoval has not been installed in sewage works.

4. Policies on detergent phosphatesand their consequences

In response to the harm being done to theenvironment, the potential factors causingeutrophication – i.e. increased input of nitrogen andphosphates into watercourses, lakes and seas – wererapidly identified. In the case of detergents, theincrease in phosphorus input due to the introduction ofsynthetic detergents was perceived to be a majorcontributor to eutrophication. The question then washow to reduce this nutrient loading. Policies inresponse to the growth of eutrophication as a problemhave followed the general course of environmental

policy, starting by setting national standards throughregulation, through international agreements wherenecessary.

Most policy on phosphates has been of this nature.There were two relatively obvious courses of action:the restriction of phosphates in household detergentsand the treatment of waste water in sewage plants toremove phosphorus. With the more recent trendtowards the use of economic instruments, such astaxes and charges, the taxation of phosphates is nowbeing considered and has been enacted for detergentsin France in particular. Ecotaxes are considered indetail in section 5 below. A significant aspect of policyformation was the rapid acceptance by industry thatchanges were necessary; there have been manyvoluntary agreements to reduce phosphate use indetergents and these have led to significant reductionsin phosphate use. The reasons for this are consideredin section 6 below.

4.1 Pollution control policies

The three main sources of phosphorus are livestockwaste, human waste and agricultural fertilisers.However, the relative contributions will varysignificantly, depending on the particular site. Ruralareas with intensive agriculture have the highestcontributions from agriculture to their surface waterresources, while urban water will have the maincontribution from waste water.

Therefore, policy mechanisms must be able to takeaccount of local conditions. This suggests that at leastimplementation of policy should be decentralised, asin the French system of management by river basin(CFEGP, 1999) and as defined by the new EU WaterFramework Directive (EUCC, 2000).

A further important consideration is thepracticability or simplicity of operation of the policy.It is much easier to implement monitoring, controlsand investments for point sources of pollution than fordiffuse sources. Urban waste water is collected anddischarged through sewage plants which are pointsources of phosphorus. In contrast, agriculturalmanure and fertiliser creates a phosphorus load byleaching into groundwaters which then are washedinto rivers and lakes, creating a diffuse source.Because sewage plants can be easily monitored andcontrolled in contrast to the diffuse sources fromagriculture, policy so far has tended to concentrate onurban waste water.

This has the limitation that the most importantsource of phosphates, human waste from the body’sprocessing of food, is dependent solely on population


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levels and cannot be limited at source. Detergents havebeen the other main contributor. Both human anddetergent phosphates, along with industrial sourcesdischarged into sewers, can be effectively removeddown to very low levels by the installation of sewagecollection and of advanced sewage treatment, wherepublic policy requiring this is decided andimplemented.

There are several types of policy instruments thathave been applied to reducing phosphate input tosurface waters:

4.1.1 Command and Control instruments

Phosphate levels in detergents and also in fertiliserinput to agriculture can be specified by legislation oradministrative instruments. As explained in section 3above, detergents are not the largest contributor tophosphate input in urban waste water. However, giventhat the main contributor is human waste, which as abiological function cannot be reduced, controllingphosphates in detergents offered the best way ofreducing phosphate input into urban waste water.

The response of individual countries has dependedon the severity of the problem and its geographicalextent. In 1985, Italy introduced a restriction of 4%STPP content in household detergents (a low enoughproportion to prevent effective use of STPP) innegotiation with industry. This was followed byregulatory bans on phosphates in household detergentsin Switzerland and Norway and subsequently Austriain 1994.

Many US states introduced bans in the early 1990sand Japan also discontinued the use of STPP indetergents. In the Netherlands, Denmark and Germanythe use of STPP was not banned, but particularly inGermany the governments negotiated with thephosphate industry for a voluntary agreement.Furthermore, consumer opinion also turned againstphosphates in particular because of high profileenvironmental claim advertising by phosphate freebrands and the demand for detergents with STPPdropped to such an extent that there are now nohousehold detergents using STPP sold in thesecountries.

However, since cyanobacterial blooms and algae arestill a widespread problem in Italian surface andcoastal waters, regulating detergents in this way doesnot seem to be effective. Morse et al. (1993) found thatthere were no examples of phosphate limits indetergents making any large impact on eutrophicationand FEM (1986) concluded that moving to phosphate

free detergents would not measurably changephosphorus inputs from the river Redon into LakeGeneva.

This type of blanket instrument also ignores localvariations in conditions, for example whether most ofthe phosphate comes from waste water or agriculture.It is therefore likely to be inefficient in economicterms and in many cases will not solve the problem.One way in which regulation can be effective in thecontext of phosphates is to specify either treatmentstandards or emissions standards for waste watertreatment.

4.1.2 Waste water treatment

The other obvious possibility is to treat waste waterat sewage plants to reduce the phosphorus content ofdischarges. The technology for waste water treatmentis well established, but requires significant investment,which in countries with public water treatment had tocome from government budgets. Thus a publicperception of a severe problem was necessary for sucha policy to be enacted. Treatment of urban waste waterto remove phosphorus has the greatest potential tochange the output into rivers and lakes, because itworks on all the phosphate content of waste waterinstead of only the small fraction from detergents.

Also, phosphate removal in sewage works isgenerally installed at the same time as nitrogenremoval, thus also reducing the input of this nutrient tosurface waters. Denmark, Germany, the Netherlands,Switzerland and Sweden have all installed a largenumber of phosphate removal systems. Germany andthe Netherlands are among the signatories to the RhineAction programme, which required a 50% reduction ininputs of phosphorus and nitrogen to surface waters(van der Kleij et al., 1991).

A potentially far-reaching step was taken by the EUin 1991 with adoption of the Directive on Urban WasteWater Treatment (Directive 91/271/EEC). The impactof this directive, which came into force in 1991 withthe requirements regarding phosphate removalapplicable by 31/12/1998, is assessed in IEEP (1999).Progress has been variable in the different memberstates, both in the designation of sensitive areas thatrequire phosphate removal and in the installation oftreatment systems.

While phosphate discharges have been reduced,phosphate concentrations are far above their naturallevels in many areas in Europe and eutrophicationcontinues to be a serious problem. Although fullcompliance with the EU directive still requires farmore extensive phosphate removal, policy is now


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changing towards a water catchment based and hencelocalised approach, within the context of national andEU policy.

The new Water Framework Directive maintains therequirements of existing Directives (e.g.91/271) as theminimum baseline to be developed at the catchmentlevel. Since the growth of cyanobacterial blooms andalgae is very dependent on the local conditions, a moreintegrated approach to nutrient load at a local leveloffers the possibility of more efficient and effectiveaction.

The technology exists to remove 95% or more ofphosphate from waste water, if the mostcomprehensive treatment systems are fitted (IEEP,1999). Consequently, if countries such as Italy (wherewaste water treatment is relatively limited and thereare serious problems with cyanobacterial blooms andalgae) move towards compliance with the Directive byinstalling more treatment plants, eutrophication due tophosphorus should decrease and this might have aconsiderable effect on the overall problem. Sweden,Switzerland and the Great Lakes region of the USA,for example, have implemented phosphate removalprogrammes, which have controlled the extent ofeutrophication (Landbank, 1995). I

In Sweden they have therefore not considered itnecessary to put any controls on phosphates indetergents. EEA (1999) considers that the number ofheavily polluted rivers in Western Europe has fallenfrom 25% in 1975-80 to approximately 5% in 1992-98, especially because of the installation of wastewater treatment following the Urban Waste WaterDirective.

This will have been very effective where there was ahigh proportion of the phosphorus load from pointsources, as in the river Rhine. It must be emphasised,however, that because cyanobacterial blooms andalgae are dependent on the specific local conditions,each incidence has to be analysed and treatedindividually for a fully effective policy to bedeveloped. Remember also that this does not reducethe problem due to non-point sources of phosphorusfrom agriculture.

Phosphorus removal through waste water treatmentraises two issues. The first is that the operating costsof the sewage plant are increased. While someprocesses could produce a revenue from sellingnutrient rich sludge for use as fertiliser or by recyclingto phosphorus to phosphate manufacturers, this is notcurrently profitable (Driver et al., 1999). Therefore,the finance must be raised either from public sourcesor through water charges. This will explain the delayin implementing the EU directive in some cases.

However, the costs have not prevented countries suchas Germany and Switzerland from installing manyphosphate removal plants, so the costs are probablynot a major barrier where eutrophication is perceivedto be a serious problem.

The second issue is that phosphorus removal usingthe current commercial processes results in theproduction of phosphorus rich sludge, which mustthen be disposed of. The simplest solution is to use thesludge as fertiliser, but there are further problems. Ifthe EU directive is implemented fully, there will bemore sludge produced than is required for agriculture.Furthermore, most sludge will be produced in urbanareas and would have to be distributed to theagricultural areas. This would involve largetransportation costs.

There is also a concern that the sludge would alsocontain a high proportion of heavy metals, whichwould also be of concern if their use in fertilisersincreased the metal concentration in the food chain.The recovery of phosphorus for use by industry, wherethe metal concentrations are much lower than the rawmaterials sources now available could solve theseproblems, but the cost of recycling phosphorus in thequantities required by industrial producers is stillmuch higher than the cost of the raw material.However, if phosphorus has to be removed and the useof sludge is restricted, this may become the mosteffective solution.

A further possibility is to dry and incinerate thesludge, but this requires careful control over thecombustion products, which is potentially difficultbecause of the large number of different chemicals andconstituents of the sludge and therefore expensive iffurther pollution is to be avoided, as well as thehandling of solid by-products. Of concern are theheavy metals, mercury, dioxins and furans, acid gases,as well as NOx and N2O (Werther and Ogada, 1999).Another possible use is to dry the sludge and use it forconstruction materials. In Tokyo, it is used forpavement construction (Guardian, 1998).

4.1.3 Voluntary agreements between governments

and industry

There are several voluntary agreements to limit theuse of phosphates in detergents by the detergentindustry. In some countries such as Germany and Italy,and more recently Ireland, the voluntary agreement isin effect equivalent to a “ban” of phosphates inhousehold laundry detergents. In most other Europeancountries, and in some EU Accession countries,


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voluntary agreements are in place limiting detergentphosphate levels to the minimum necessary forphosphates to play an effective role in the detergent.So there is little more that can be achieved here.

4.1.4 Information and ecolabels, education,codes of practice

More information on product content could beprovided to the consumer when they purchasedetergent products. However, there is no clearmessage to be put across by such a system, as thephosphate content of detergents is often not asignificant contributor to eutrophication. This isreflected by the Scandinavian “White Swan” and EUdetergent ecolabels, which allow phosphates to beincluded (this was confirmed for these ecolabels whenthe criteria were revised and updated, in both cases in1999).

Use of detergent phosphates can be reduced byproviding accurately sized measuring cups fordetergents, while tablets are very effective in that theycontrol the quantity of chemicals for each wash. Themain variable then is the amount of washing in themachine. Codes of practice are applicable to the use ofmanure and fertiliser in agriculture; although currentlymainly applied to nitrates, this can reduce over-application of manure and can reduce runoff ofphosphate from fertilisers and manure intogroundwater.

4.1.5 Recycling phosphates from waste water

A further alternative is to extract the phosphorusfrom the waste water stream in such a form that it canbe reused, either in agriculture as a fertiliser or byphosphate manufacturers as a substitute for the rawmaterial, phosphate rock. Recycling by spreadingsludge is the most effective environmental option inmany cases (Edge, 1999). However, this possibilitymay be limited by several factors. Sludge is bulky andtherefore has high transport costs, so there must be ademand close to the sewage treatment plant if theeconomic cost is not to be high.

While this is in general the case in the UK, it is notso in many parts of Europe and the US (Greaves et al.,1999). In some regions where there is a highpopulation density and limited agricultural land, theremay be more sludge produced than is suitable forspreading. This has been found to be the case in theNetherlands and in a study in the Lothian region ofScotland (Towers and Horne, 1997). There are alsoserious concerns about the concentrations of heavy

metals in sludge from waste water, to the extent thatthe European commission has proposed much strictercontrols on the composition of sludge used forspreading (CEC, 2000).

The other route is to extract phosphorus from wastewater streams in a form suitable for reuse by industryfor phosphate or fertiliser manufacture. There are twotechniques currently under development:crystallisation of calcium or magnesium phosphateand precipitation of struvite crystals(magnesium/potassium ammonium phosphate). Fullscale pilot plants are already running using theseprocess routes in Holland, Italy and Japan. Othertechnological approaches are also being investigatedincluding ion exchange, membranes, sludgefractioning and biological pathways.

The technology for production of struvite frommanure is also being developed (Schuiling andAndrade, 1999). The problem here is one of economicincentives: the manufacturers would have to changetheir production systems to accept the recycledphosphorus thus incurring extra costs. Given currentphosphate rock prices and the reasonable availabilityof the raw material in at least the short term, recycledphosphorus would be more expensive than the rawmaterial, so some form of regulation or subsidy wouldbe required to create a market for recycledphosphorus. Driver et al. (1999) consider that thesetechniques will become more widely used when morephosphorus removal systems are installed in sewageworks and the problem of what to do with thephosphorus becomes more acute.

4.2 Consumer reactions and trends inphosphate use

Laundry detergents are an essential consumptionitem, that is used very regularly and purchasedfrequently. The emergence of eutrophication as anenvironmental issue together with increased consumerawareness of environmental issues was capitalisedupon by certain companies in the 80’s and early 90’sto carry out extensive and aggressive anti-phosphateadvertising campaigns for phosphate free detergentbrands, increasing the perception of phosphates indetergents as environmentally damaging.

In some countries, this led to phosphates indetergents being banned while in Denmark, Germanyand the Netherlands, the importance placed byconsumers on environmental issues destroyed themarket for detergents containing STPP.


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In countries such as France and the UK, there is alsoa widespread opinion that phosphates are bad for theenvironment. Since the detergent market is verycompetitive and marketing oriented, the consequenceof this has been that detergent manufacturers havereduced the use of STPP in detergents. In France,detergents contained 24% STPP on average in 1985which was reduced to 10% in 1998.

The introduction of ‘eco-friendly’ detergent brandsin response to this perception was a temporaryphenomenon, as the major manufacturers changedtheir main products to use less STPP anyway (KeyNote, 1997).

The consumer choice literature reflects thissituation, in which phosphates are mentioned as anenvironmental issue (Que Choisir, 1999 and Which,1994; Which, 1999). Both Which articles indicate thepresence of STPP in the detergents under test andmention that phosphates can cause an environmentalproblem, but that fertilisers are more important.

To summarise; in Europe, the USA, Japan and othercountries where the environment is a major issue, theuse of STPP in detergents has either been stopped orhas fallen very considerably and is continuing to bereduced. In other countries such as Russia, China andLatin America, where there are also potentially largeconsumer markets, the use of detergents is increasinggenerally and there is little tendency to try andminimise the use of STPP.

5. Ecotaxation of detergentphosphates and other economicinstruments

The modern trend in environmental policy has beento move towards the use of ‘economic instruments’.There are two main types of economic instruments:taxes/subsidies and tradeable permit systems.

These types of measures have long been proposedby economists, because under suitable conditions theyoffer the possibility of taking the costs of pollutionabatement into account as well as the pollutionreduction and therefore being economically efficientwithout requiring complicated and expensiveadministration, in particular taxes and permit trading.The idea is that if there are external costs to societyimposed by some activity, such as the use ofdetergents, then the user of the detergent should facecosts that reflect the external costs. In order to set aneconomically optimal level of permitted pollution by

regulation, it is necessary to know the costs to thepolluter of meeting the permitted level.

Such information is often not available. Economicinstruments do not require detailed knowledge of eachpolluter’s costs, they use market mechanisms toprovide incentives for polluters to reduce pollution atminimum cost to themselves. Thus if a tax is levied one.g. household detergents by the weight, this providesan incentive for households to use less detergent. Theywould then in the long run start to prefer washingmachines etc. that use less detergent and the industrywould change their designs to meet the changeddemand.

This does not require detailed knowledge of costs bythe lawmaking body, but does require some system tocollect the taxes. Therefore, taxes are usually mostappropriate where there is a tax collection systemalready in place.

In the case of taxes for externalities, this is known asa ‘Pigovian’ tax. If the costs to society of theexternality and the costs to the user of reducingproduction or consumption of the polluting activity orgood are known, it is possible to calculate a tax that, atequilibrium, equates the marginal external cost and theabatement cost. This is then an optimum position forthe society.

The advantage is that the tax provides an economicincentive for polluters to change their behaviour andeach individual polluter can choose their level ofabatement and hence the amount of tax they pay. Thusit is easy to take account of differences in abatementcosts between different polluters. Under a system ofregulation, in order to achieve the same level ofeconomic efficiency where polluters have differingabatement costs, each polluter must be regulatedseparately, leading to large administration costs. In thecontext of eutrophication, a national tax has thedisadvantage that it does not allow for the differencein requirements for the reduction of phosphatesbetween basins, so the effects may be insignificant orappropriate in some areas.

The only example of a tax on detergents is theFrench TGAP, discussed below. Taxation of pollutingactivities is much more common, both in Europe andin other OECD countries. Ekins (1999) surveysEuropean environmental taxes. Belgium and theNetherlands have introduced surplus manure charges,which are based on the emissions of phosphorusand/or nitrogen in excess of the environmentallyacceptable manure loads per hectare. Norway, Swedenand the USA have introduced fertiliser charges whichare taxes on products rather than taxes directly relatedto the pollution caused.


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5.1 Criteria for the design of ecotaxes and theirapplication to detergents

The fundamental principle of ecotax design is that itshould provide an incentive for the polluter to changetheir behaviour in a way that reduces the undesirableor polluting activity. It should address the problem athand, in this case eutrophication. If a tax is to achievesome desired level of pollution abatement, the firstcriterion is that it should be set at a level which willprovide the requisite economic incentives for thepolluters to change their behaviour. It will rarely bepracticable to achieve a first best optimum in simpleeconomic terms, because the details of abatementcosts for all polluters will not usually be known by theregulator. Smith (1997) considers environmental taxdesign.

There is a trade-off between low administrativecosts and the effective targeting of a tax. Usually, amore effective tax requires more measurement ormore complex charging schedules. Another factor isthe use of the revenues generated by a tax. Therevenues may be designated for use in the same areafrom which the tax is raised (known as earmarking)e.g. paying for the installation of water treatment orthey may be used to reduce other taxes such asemployment taxes to improve the overall efficiency ofthe taxation system. Smith (1997) argues that theearmarking of tax revenues does not have an economicjustification, but is used to make the introduction of atax more acceptable.

Efficiency may also be dependent on the assignmentof control over the tax. An environment department ismore likely to set a socially optimal level of taxcompared to a finance ministry which is concernedwith raising revenues. However, the revenues shouldbe assigned to a ministry where environmental taxesgenerate a small part of the total. This avoids thetendency to use environmental taxes as the maingenerator of funds for environmental programmes andthus for the tax levels to bet set artificially high.

In the case of detergents, the polluter is the consumer,either household or industrial. Given that theenvironmental costs are borne through eutrophication,the policy objective should be to reduce the nutrientloading into surface waters where cyanobacterialblooms and algae are a problem. Where the nutrient inquestion is phosphorus, the main sources of phosphorusshould be identified and then policies put in place toreduce the phosphate loading. This makes the use of anational tax on detergents containing phosphatesproblematic for several reasons.

A national tax takes no account of local variations,so a large proportion of taxpayers will be facing extracosts for no environmental gain. In many areas, themain phosphate loading will come from agriculturalsources, so a detergent tax does not address theproblem. Even if the main problem comes from urbanwaste water, since detergents contribute a smallproportion of phosphates, a reduction in detergent usewill not prevent eutrophication in most cases. It shouldalso be noted that demand for detergents is relativelyinelastic; consumers will always wish to wash clothesand will not be very sensitive to changes in detergentprices.

Household expenditure on detergents is also a smallproportion of expenditure: EUROSTAT (1992, 1993)shows that expenditure on all cleaning andmaintenance products is between 0.5% and 1.5% onaverage in most EU countries, so a significant increasein price of detergents is unlikely to cause consumers touse much less. Therefore, an extremely high rate of taxon phosphate detergents would be necessary to haveany significant impact on the incidence ofcyanobacterial blooms and algae.

The impact of a tax on all detergents compared to atax on phosphate detergents

There are several issues associated with taxdifferentials between phosphate and non-phosphatedetergents. A tax on all detergents partially loses thefundamental point mentioned above of addressing theenvironmental problem, as non-phosphate detergentsdo not influence eutrophication. In terms of moregeneral environmental objectives, Landbank (1994,1995) find that there is no significant differencebetween the life cycle environmental impact ofphosphate and non-phosphate detergents.

So if the policy concern is the environmental impactof detergents in general, a tax on all detergents islogically consistent. If a tax is introduced whichdifferentiates strongly between phosphate and non-phosphate detergents by having a much higher rate oftax on phosphate formulations, then there will be asubstitution effect. Non-phosphate detergents are aclose substitute for phosphate detergents in theconsumer market, since they wash reasonably wellunder household conditions, so consumers will switchfrom phosphate to non-phosphate formulations tosome extent.

This would have the following impacts: there wouldbe little reduction in overall detergent use (assumingnon-phosphate detergents were not taxed heavily),there would be a reduction in phosphate loading inwaste water (depending on the relative significance of


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detergent phosphates) and there would be a largereduction in the revenues from the tax, as consumersswitched to the low tax non-phosphate formulations.

The conclusion here is that in overall environmentalterms, given that there is little difference between thephosphate and non-phosphate detergents, there is notmuch point in taxing just phosphate detergents asopposed to all detergents. If there is a significantdifference in tax levels or only a tax on phosphatedetergents, there will be a reduction in demand forphosphate detergents.

A further consideration, applicable to fiscal policy ingeneral, is welfare or social equity. In most Europeancountries, it is felt that fiscal policy should work toreduce the difference in incomes or expenditures onbasic goods across the society. This implies that a taxon consumer expenditure should be borne at leastequally by the better off social groups, or that thereshould be some form of compensation for poorersocial groups.

5.2 The French TGAP

The one example of a tax specifically on phosphatesin household detergents is the French ‘Taxe Généralesur les Activités Polluantes (TGAP)’, which came intoforce in January 2000. The TGAP contains severaldifferent taxes on various activities which are seen aspolluting. These include: activities modifying watermovement and flow, gravel extraction, industrialoutputs of heated water and radioactivity, pesticides(but not fertilisers) and laundry detergents.

The stated objective of the TGAP is to reducepolluting activities through an improved application ofthe polluter pays principle and the raising of revenuesto finance the 35 hour week and hence employment(CFEGP, 1999). The TGAP is also presented as havingthe objective of modifying consumer behaviour. Thepart of the tax applied to detergents is levied on thesales price to the consumer as follows (FMF, 2000):

Detergents with:less than 5% STPP 470 FF/tonne

5-30% STPP 520 FF/tonne

more than 30% STPP 570 FF/tonne

This represents 2.35-2.85 FF for a 1 kilo standarddetergent packet, which is approximately between 2-3% of the sale price for concentrated powders and10% for the cheaper powders. The expected revenuefor the first year is 500 million FF, out of a total of 4

billion FF for the TGAP. Applying the criteria forefficient taxes outlined above, it can be seen that theTGAP detergent tax does apply directly to the issue ofconcern i.e. the presence of detergents in urban wastewater. Furthermore, the collection of the tax will berelatively simple, because the systems in place forVAT on consumer products can be used. The finalrates that have been applied are such that there willprobably be a slight reduction in detergent use,because detergents have a low elasticity of demand i.e.sales volumes are not very sensitive to changes inprice. The variation in rates of 0.5 FF or between 0.4%and 2% per packet is probably so small that anyconsequent reduction in sales in not detectable. Theseprice variations are certainly much smaller than pricedifferences between different products and promotionsetc.

Assessment of the TGAP on detergents

Applying the criteria outlined above, the TGAP hasa few positive aspects. Because the use of phosphatesin detergents is taxed, it does address eutrophicationdirectly. Since the revenues are intended to reduceemployment costs, it improves the general economicefficiency of the tax system. It is also reasonablyeffective in political terms: it appears to addresseutrophication, but is small enough not to impose largeadditional costs on the consumer. Because alldetergents are taxed at approximately the same level,there will probably be no large extra switch away fromdetergents with STPP, so the one remaining STPPmanufacturer in France will probably continueproduction.

However, it will not achieve its environmental aimsof reducing cyanobacterial blooms and algae insurface waters. As discussed above, STPP is a smallpart of the phosphate load and so this marginaladditional load will only be significant in a smallnumber of cases. As the change in detergent use due tothis tax will be small, the change in STPP input intourban waste water will also be small. Detergent STPPforms 9-50% of the phosphate input to waste waterand a maximum 25% of the input to rivers, lakes andreservoirs. Assuming the maximum of the range, 50%,if there is a 5% reduction in detergent use, then therewould be a 2.5% reduction in STPP input into wastewater and a 1.25% reduction in phosphate input tosurface waters as a maximum where phosphateloading was dominated by urban waste water. Even forwaters sensitive to the phosphate load, this is veryunlikely to have any great effect on the growth ofcyanobacterial blooms. Given the large proportion ofnutrient input from agriculture in many areas, it is


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necessary to address these inputs in order to have anysignificant impact.

The result of the political process has been a tax onall detergents at more or less the same level. In so faras the alternative detergent formulations excludingSTPP also have undesirable environmentalconsequences, the slight differentiation between STPPand non-STPP detergents is desirable in terms of theoverall environmental impact of the tax. Given that thelife cycle analyses (Landbank, 1994 and 1995; EMPA,1999) do not find much difference in environmentalimpact between STPP detergents and the zeolite/PCAalternative, this is reasonable. However, it is not clearthat the environmental impact of zeolites is addressedby the tax and this was not stated as an objective of theTGAP.

With regards to social equity, the TGAP ondetergents applies to all purchases equally. This meansthat households which wash more, especially largefamilies, will have a higher increase in expenditure.Since low income groups tend to have larger familiesand the elasticity of expenditure is low, the tax willeffect poorer social groups more and is thereforeinequitable. This impact is partly offset by thefinancing of the 35 hour week, which will benefithouseholds where one or more members are inemployment. Poor households which are not inemployment, or which do not see a reduction inworking hours, will face the largest impact.EUROSTAT (1992) shows that the overall averagehousehold expenditure on cleaning and maintenanceproducts is 0.88% of total expenditure. The pooresttwo deciles spend 1.09% and 1.13% of their budgetson this, while the top quartile spends 0.74%.Therefore, it can be concluded that although the tax isinequitable, the effect is slight.

The overall conclusion is that the TGAP ondetergents will not be successful at addressing theenvironmental problem of cyanobacterial blooms andalgae, although it will slightly improve the overallefficiency of the tax system. The impact on socialequity is small. It will not change consumer behaviour.Taxing all detergents rather than only those with STPPhas no significant environmental implications and willmaintain a place for STPP formulations in the Frenchdetergent market.

5.3 Tradeable permits

Tradeable permit systems operate by issuing a seriesof permits to engage in a polluting activity. Thesepermits can then be traded on a market, so thatpolluters with low abatement costs can sell extrapermits and polluters with high abatement costs canbuy permits. This has several advantages. Inparticular, with modern IT systems, it is cheap toadminister. As with taxes, it allows polluters tooptimise their behaviour, without requiringinformation about each individual polluter. In realisticconditions of limited information about the costs ofthe different polluters, it provides a simple method ofdetermining how much emissions there will be,because this is set by the number of permits that areissued. Tradeable permit systems have not beenwidely used in environmental policy so far, but therehave been highly successful applications to SO2 andCO2 emissions in the U.S. Tradeable permit systemsare most suitable for situations in which there are adiscrete but significant number of polluters, so thatmonitoring is relatively straightforward, and there areplenty of actors wishing to trade. Thus it would berelatively simple to introduce such a system for wastewater treatment, where there are a large number ofdiscrete facilities. A system for detergentmanufacturers would be more difficult to operate,because the industry is very concentrated and there areonly a few manufacturing facilities.

Permit trading is useful in that it allows polluters totrade permissions to pollute, so that they can minimisethe combined cost of pollution abatement and buyingpermits. Thus the overall result is that the combinationof the level of pollution and the amount spent onpollution abatement is optimal for a chosen level ofpollution, which is set by the quantity of permitsavailable. Permit trading has only been used in a fewcases, notably in the US for SO2 emissions frompower stations, where the cost of abatement has beenfound to have been much less in the long run than wasinitially estimated.


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6. Implications for the detergent phosphate industry

6.1 Position in the supply chain and detergentmarket conditions; competitive position

Phosphates are an intermediate product in thedetergent supply chain. The production of STPP isbased on phosphorus rock as the raw material fromwhich phosphoric acid is manufactured. Thetechnology also exists to recycle phosphates.Detergent phosphate forms a relatively small part ofoverall phosphate production: about 10% of phosphaterock are used for detergent phosphates. The fertiliserindustry much bigger with about 80% of raw materialdemand, so the raw material price is determined byconditions in the fertiliser industry. Raw materials areapproximately 75% of the selling price of STPP(Driver, 2000). STPP is sold to detergentmanufacturers and detergents are sold through retailoutlets, mainly grocery stores/supermarkets.

The consumer detergent market is veryconcentrated, both in retail and in supply. In 1998,Proctor & Gamble and Unilever had over 75% of theUK powder detergent market (Key Note, 1999). Theretail market is large, expenditure on fabric cleaningproducts in the UK was £1.18 billion in 1998 with afurther £98 million on machine dishwashing products(Key Note, 1999). It is mature; overall demand isroughly constant, although there is a slow long termdecline in volumes in Europe. This is due to fewerpeople being employed in manual labour andimproved performance of detergents. Requiredquantities have decreased from 200g detergent/washto 70-80g/wash, with lower washing temperatures,shorter wash cycles and a lower water use. Therefore,competition is intense with the manufacturersspending heavily on advertising (£76.8 million forfabric detergents in 1998, Key Note (1999)) andinnovation in new products such as ‘compact’powders and tablets.

STPP is particularly suitable for use in both of thesenew types of product, so some increase in the use ofSTPP as these product types develop can be expected.The lifetime of a detergent formulation is only of theorder of 1 year (Driver, 2000). The market fordishwasher detergents, in which STPP is usually usedas the builder, is expanding but was only 22% of thelaundry detergent market in 1998 (Key Note, 1999).

The competitive position of STPP manufacturerscan be summarised as follows: there is a readily

available substitute for the product in zeolite plus therequired additional compounds. There is overcapacityin zeolite production, so zeolite prices are relativelylow (Gomez, 2000). Since detergent production ishighly concentrated and there is a substitute availablefor phosphates and formulations are changedfrequently, market power is in the hands of thedetergent manufacturers. Because the detergent retailsector is competitive, margins for the detergentmanufacturers are low and because they have marketpower in buying the intermediate products, marginsfor STPP manufacturers are also low. There ishowever, little competition in STPP production frommanufacturers outside Europe because of poor qualityof STPP from certain non EU producers and becausethe product does not travel well.

6.2 Structure of the detergent phosphateindustry

The STPP industry is also heavily internationallyconcentrated, with the main manufacturers being partof international industrial chemical companies(CFEGP, 1999). There is also overcapacity in theEuropean phosphate industry. After STPP wasintroduced by Proctor and Gamble in 1948, the marketand production increased rapidly until most countrieshad at least one manufacturer. The issue ofeutrophication and the subsequent bans andrestrictions then caused a rapid decline in the industry,with many plants being closed up to 1992 (Driver,2000). This led to consolidation of the industry intofive producers in Europe. Two of the largestcompanies have recently been combined; Rhodia tookover Albright and Wilson plc. and now has roughly50% of the European manufacturing capacity (Gomez,2000).

The concentration has been associated with cutbacksin capacity, the latest of which is that Rhodia UKrecently announced the closure of 2 of the 3 UK STPPplants with 300 redundancies. The reduction of140,000T of effective capacity will mean that plants inEurope will improve from operating at 50-55%capacity to over 80% capacity (Chem Eng News,2000). CFEGP (1999) estimates the turnover of thesole STPP plant in France at 350Mn FF/year, with 150employees (Gomez, 2000).

Internationally, there are detergent markets whichmight expand. China is the best example, but there isplenty of recently installed manufacturing capacity.There is a relatively low level of detergentconsumption in Russia and Eastern Europe and littleuse of zeolites as a builder so there is potential for


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growth there (Gomez, 2000). Latin America and SouthEast Asia are also potential markets, although as STPPand powder detergents are quite difficult to transport,it is more probable that local manufacturing plants willbe constructed.

7. Possible future policies for phosphates

Having surveyed the use of STPP in laundrydetergents, the environmental issues and the currentstate of the markets, the possibilities for the futurecourse of environmental policy for phosphates cannow be considered. The most recent availableevidence demonstrates that eutrophication is still aproblem in many parts of the EU, in spite of aconsiderable history of policy measures over the last25 years. EEA (1998a) found that only 10% of 1000river measurement sites across Europe had phosphorusconcentrations below 50 g/l (the natural backgroundmaximum). It has been found that the cyanobacterialblooms may be extremely stable, especially in shallowwaters, so that reduction of phosphorus input alonewill not restore the waters (Hosper, 1998). There havebeen some successes.

For example in Lake Veluwe, the Netherlands, theinstallation of phosphate removal in the sewage worksdischarging into the lake in 1979 and additionalflushing in 1985 enabled the lake to recover by theearly 1990s, 10 years after the reduction in nutrientloading (van der Molen et al., 1998). The Swiss policyof waste water treatment has also had some success inreducing the incidence of cyanobacterial blooms andalgae, in particular in Lakes Geneva and Neuchatel(Lang and Reymond, 1996). EEA (1998b) shows thatmean phosphorus concentrations in European riversgenerally decreased between 1987-91 and 1992-96 inWestern Europe and in some countries of easternEurope. However, there are still many sites with veryhigh phosphate concentrations. EEA (1998b) alsostates that reductions in phosphorus loading fromsewage works now need to be followed by reductionsin loading from agriculture, as this is now relativelymore important.

7.1 Objectives of future policies on phosphates

The conclusion to be drawn from the abovesummary is that action on phosphates will remain onthe policy agenda in the EU. The objectives of futurepolicy should be twofold:

1. to continue monitoring the extent ofcyanobacterial blooms and algae in surface andcoastal waters and identify the nutrient loadingsthat are supporting the growth of cyanobacterialblooms;

2. given that phosphate loading is thedetermining factor in many cases, to achieve largereductions in phosphate inputs to surface waterswhere eutrophication is a problem.

7.2 Applicable environmental policies andtheir economic implications

Reduction in the contribution from detergent STPP(the secondary source of phosphorus in sewage) has amarginal effect on the overall phosphate loading andwill have no effect on eutrophication in many cases. Ifa particular ecosystem is nutrient limited byphosphorus and point sources form the majority of thephosphorus input, a reduction in the loading will havesome effect in reducing the extent of cyanobacterialblooms and could conceivably induce a shift in theecosystem balance which removes blooms as a seriousproblem. However, this is only true for a small rangeof conditions. It is much more likely that only a largereduction in phosphorus loading will achieveconditions in which blooms disappear. This isextremely hard to predict, not least because theresponse time of the ecosystems appears to be of theorder of 10 years (van der Molen et al., 1998). The EUUrban Waste Water Directive is therefore anappropriate response to this problem, in that itspecifies conditions under which action has to betaken and provides a basis for installing waste watertreatment which can drastically reduce phosphateloading.

The implication of these considerations is that wastewater treatment should become more widespread andtherefore government policy needs to be directedtowards dealing with either increased sludgeproduction and disposal via spreading, incineration orother uses or phosphate recycling. Markets for sludgeor recycled phosphorus do not currently exist and theeconomics are still uncertain. Therefore policy shouldbe directed to creating markets on a small scale, so thatthe technology and market structures can bedeveloped. It is necessary to give phosphatemanufacturers and the fertiliser industry an incentiveto invest in new equipment to accept recycledphosphate instead of the raw material or phosphoricacid i.e. to create a demand for recycled phosphorus.


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Given the uncertainties and variations in localconditions, in particular the transport costs of sludgeand the varying demand from potential customersclose to sewage works, all the different possibilitiesshould be encouraged. This will enable the mosteconomically efficient methods to be selected in eachlocal area.

7.3 Taxation of domestic phosphate products

Since there is a legislative framework in placerequiring phosphorus removal from the waste waterstream, there is little benefit in environmental terms inhaving a general tax on detergent phosphates. Theonly significant point of such a tax would be to raiserevenues for the government. Thus the French TGAPis only partially successful, because it is intended toprovide finance for the 35 hour week in France(CFEGP, 1999). It will not contribute towardsachieving its stated environmental objectives. Theintroduction of taxes on detergent phosphates inparticular will probably accelerate the decline of STPPmanufacture in Europe.

The increase in costs might well cause detergentmanufacturers to switch to zeolites, which are bothreadily available and cheap. Furthermore, detergentmanufacturers are consolidating production over thewhole of Europe. If they are only running a singlemanufacturing facility, the requirement to sell intomarkets where STPP products are not sold willstrengthen the tendency to cease using STPP in theirdetergent formulations (Driver, 2000). While STPPdoes not employ a very large number of people,because production is very concentrated in largefacilities, closing plants has significant effects on thelocal economy, as can be seen in the case of theRhodia UK plant at Whitehaven UK, with 300redundancies in an already economically depressedregion.

7.4 Policies for diffuse sources

A detailed examination of diffuse sources ofphosphorus loading in surface waters is outside thescope of this paper. However, it is now generallyaccepted that diffuse sources from agriculture form themost important part of phosphorus loading in manyinland surface waters. Since phosphate removal fromdiffuse sources is impracticable, the approach tocontrolling these sources has to be one of managingthe initial use of fertilisers and the careful use and/ordisposal of manure (Parr et al., 1999). Policy can

provide incentives by taxing excess fertiliser andmanure use, as in Belgium and the Netherlands (Ekins,1999). A further possibility would be to recyclephosphate from animal manure, which could becomeeconomically attractive in areas of intensive livestockproduction (Greaves et al., 1999). There is a potentialsynergy with waste water treatment here: if a marketfor recycled phosphorus from waste water treatmentplants is developed, it would be much easier for farmsto locate a demand for their recycled phosphorus. Parret al. (1999) also make the point that since the mainproblem stems from intensive livestock farming,policies to encourage mixed farming will also reducethe incidence of high phosphorus loading.

8. Summary and Conclusions

The reason that the use of phosphates in detergentsremains an issue is that there is a continuing problemwith eutrophication, which is the nutrient enrichmentof water, and which can lead to the growth of algaeand cyanobacterial blooms in European surfacewaters. These are unsightly, often have an unpleasantodour and can be toxic. These growths are caused byinputs of nutrients, phosphorus and/or nitrogen, intosurface water ecosystems that are far higher than thenatural level. The main sources of phosphorus inWestern Europe are animal manure and fertilisers usedin intensive livestock agriculture and human waste inurban waste water. Phosphates used in domesticlaundry detergents may make a significantcontribution to the phosphate content of urban wastewater in some areas.

Phosphates and STPP in particular perform a vitalfunction in modern synthetic detergents, althoughthere are substitutes, of which the most successful iszeolite combined with polycarboxylate. Life cycleanalyses suggest that there is little to choose betweenSTPP and zeolite-polycarboxylate formulations interms of their environmental impact, but STPPremains the most effective ‘builder’ in laundrydetergents.

In order to control eutrophication, many countrieshave acted to control the use of STPP in laundrydetergents. These policies have ranged from outrightbans in Switzerland and Austria and an almostcomplete ban in Italy through voluntary agreementswith industry in Germany and the Netherlands totaxation of detergent purchases in France. Particularlyas a result of extensive and aggressive advertisingcampaigns by certain “phosphate-free” brands ofdetergents in the 1980’s, the consumer has oftenperceived the use of phosphates as environmentally


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damaging, resulting in the abandonment of STPPdetergent formulations in Germany, the Netherlandsand Denmark. The response of industry to these changingmarket conditions has been quite dramatic, because of thehighly competitive nature of the detergent industry andthe importance of product image and marketing. Laundrydetergent formulations using STPP are no longer sold inGermany, Italy, Switzerland, Austria and Norway inEurope, as well as the US and Japan. The amount of STPPin laundry detergents has been reduced significantly inother European countries; for example in Francedetergents contained 24% STPP in 1985 which wasreduced to 10% in 1998.

These policies have formed part of a policy package,of which the other main element has been theinstallation of equipment to remove phosphorus fromurban waste water. This has the potential to be a muchmore effective approach in reducing phosphorusloadings, because it is possible to remove more than90% of all phosphate in the waste water stream anddetergent phosphates form less than half of the totalphosphorus input to urban waste waters. Under theumbrella EU Urban Waste Water Treatment Directive,countries such as Germany and the Netherlands haveinstalled phosphorus stripping equipment extensively.Sweden also has a comprehensive system of sewagetreatment.

These policies have been partially effective so far.Phosphate loading has been reduced in many surfacewaters that were heavily polluted, such as the Rhineand the extent of cyanobacterial blooms and algae hasbeen reduced. However, experience in the Netherlandsshows that it can take 10 years or more for surfacewaters to recover the ecosystem balance that existedbefore eutrophication. There are factors that can makethe eutrophic state very stable; flushing of lakes toprevent release of phosphorus from sediments mayalso be required. A further complicating factor is thatthere is no simple linear relationship betweenphosphate loading and the growth of cyanobacterialblooms. It is now generally accepted that a largereduction in phosphorus loading can enable surfacewaters to recover from cyanobacterial blooms andalgae, but each site has to be considered individually.Therefore, the continuing investment in phosphorusremoval in sewage plants will eventually controleutrophication in many instances, in particular wherethe main loading comes from urban waste water.Countries such as Italy, where cyanobacterial bloomsand algae are still a major problem and there arerelatively few phosphorus removal installations willbenefit considerably from these policies.

As the policies for urban waste water treatment havebeen put in place, attention has increasingly turned todiffuse sources of nutrients, manure and agriculturalfertiliser. Here, the policy problem is more complex,because it is not possible to remove phosphorus at a fewpoint sources. Therefore, policy has to be directed at goodfarming practice in the use of fertilisers and manure, withpossibly taxation of fertilisers to discourage their use.

Future policy should be based on local responses tolocal problems within an overall legal framework, apoint insufficiently emphasised in the currentliterature, but highlighted in the new EU directive onwater treatment. Continuing investment in phosphateremoval at sewage plants is the first part of a policy tocontrol eutrophication. The next step, which is muchmore difficult, is to control phosphorus loading fromagriculture. Then there is the question of what to dowith the phosphorus when it has been removed.Phosphorus removal in sewage plants producessludge, which must be used or disposed of. As it hashigh transport costs, the most economic option is touse the sludge as fertiliser in the area surrounding thesewage treatment plant. However, if there is already aproblem with phosphorus loading from agriculture,and in many cases because of increasing concernsabout sewage sludge use relating to metal, chemical,pathogen content or other issues, this will not bepracticable.

There are several alternatives. The simplest is to dryand incinerate the sludge, but this requires carefultreatment to control combustion products. There arealternative uses, such as drying and using for buildingmaterials or paving slabs, as has been practised inJapan. A further possibility is to recover and recyclethe phosphorus in a form useable by the phosphateindustry or as fertiliser. All these alternatives requireinvestment in some degree. Recycling has theadditional complication that phosphate manufacturerswould have to alter their production organisation toaccept the recycled phosphorus instead of phosphaterock, although since the rock has quite a high heavymetal content, the production process could probablybe made cheaper.

Since phosphate removal will become morewidespread, this problem will have to be addressed.For now, recycling technology is being developed andis close to being applicable on an industrial scale.Therefore, policy should encourage the formation ofmarkets for sludge or recycled phosphate products.There are many ways in which this could be achieved:by voluntary agreement with water companies,phosphate manufacturers and agricultural businesses;by legislation to require the removal and disposal of


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phosphorus and the associated by-products or bytaxation on point and diffuse sources of phosphorus.

Finally, what are the implications for detergentphosphates and the STPP manufacturers? Demand forthe various consumer products is predicted to be roughlyconstant in the short to medium term i.e. the next 10years, say. If policy on phosphorus follows the courseoutlined above, there is no reason why STPP should notremain an important part of detergent formulations.Indeed, with the widespread introduction of phosphorusremoval, STPP formulations could be reintroduced in thecountries where they have been replaced by zeolite.Sweden has comprehensive phosphorus removal systemsand therefore permits the unrestricted use of STPP indetergents. They could be marketed as anenvironmentally friendly alternative, as zeolites producemore sludge and do not have the possibilities forrecycling and reuse that phosphates have. There remainsconsiderable overcapacity in STPP manufacturer, so it isprobable that some plants will close in the next few years,even with the recent consolidation of Rhodia andAlbright & Wilson. The overall conclusion, therefore, isthat STPP manufacture can remain a relatively small, butsignificant activity for the chemical industry for theforeseeable future and that effective policies to controleutrophication are entirely compatible with the continuedor even expanded use of STPP in laundry detergents.There is continuous innovation in new products such as‘compact’ powders and tablets. STPP is particularlysuitable for use in both of these new types of product, sosome increase in the use of STPP as these product typesdevelop can be expected.

In terms of policies for detergent phosphates, anyfurther controls by regulation or taxation would be veryunlikely to influence the extent of cyanobacterial bloomsand algae. Since each local problem has to be resolvedby regional action, policies such as a general tax ondetergents are not relevant as environmental policies.

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STPP (sodium tri poly phosphate) ready for detergent production.

Documents

Detergent phosphates and detergent ecotaxes€¦ · 5. Ecotaxation of detergent phosphates and other economic instruments 16 5.1 Criteria for the design of ecotaxes and their application