EU ECOLABEL CB FORUM AGENDA Monday 19 June 2017 Forum/CB... · [email protected] WAIDTLEW Jakob Ecolabelling Denmark +45 72 41 48 16 [email protected] WOLTMANN Lars SMK

- EU Ecolabel June 2017 CB Forum Agenda

EU ECOLABEL CB FORUM AGENDA

Monday 19 June 2017

14:00 – 16:30

Tuesday 20 June 2017

10:30-17:00

Avenue de Beaulieu

5,

B-1160 Brussels, meeting room C


Participant list

Last name First name Organisation Phone number Email address

AURANMAA Kirsi Ecolabelling Finland +358 400 949,491 [email protected]

BROUET Cindy AFNOR Certification French CB + 33 1 41 628712 [email protected]

BUTTNER Peter RAL gGmBH +4922412551652 [email protected]

CARMAN BURGOS

Stephanie Helpdesk (Deloitte Sustainability)

+33 1 40 88 70 88 [email protected]

CESAREI Gianluca ISPRA (technical support to the IT CB)

+35 06 5007 2853 [email protected]

DE RIDDER Kathelijne Belgian CB: FOD Volksgezondheid, Veiligheid van de Voedselketen en Leefmilieu

3 225 249 586 [email protected]

DOROSKO Kristine European Commission DG ENV [email protected]

EHRLICH Pavel CENIA +42 725 389 661 [email protected]

ERI Vilma Hungarian Ecolabelling Organization


ESKELAND Marianne Ecolabelling Norway +47 24 14 46 09 [email protected]

GAJARSKA Anita Slovakia Environment Agency +421 906 315,055 [email protected]

GAUVAIN Murielle AFNOR Certification French CB + 33 1 41 62 61 11 [email protected]

GODIN Fabienne Belgium CB : SPF Santé publique, Sécurité de la Chaîne alimentaire et Environnement

+32 2 529 9550 [email protected]

HAJEK Daniel Ministry of environment +,420,267,122,488

[email protected]

HEUTLING Susanne European Commission DG ENV [email protected]

HRISTOVA Nadejda MoeW +359 294 063 58 [email protected]

LUDAIN Sylvie European Commission DG ENV [email protected]

MANCUSKOVA Adriana Slovakia Environment Agency +421 906 314,014 [email protected]

RESCHL Josef VKI +43 15 88 77 206 [email protected]

RIMKUS Andrea RAL gGmbH +49 224,125,516 51

[email protected]

ROCHE-NAUDE Alice Helpdesk (Deloitte Sustainability)


SAHLBERG Ulla Ecolabelling Sweden +46 8 55 55 24 30 [email protected]

SAJDOKOVA Janna CENIA, Czech environmental information agency

+,420,267,125,226

[email protected]

SAUL Marilis Estonian Environment Agency 3,716,737,596 Marilis.saul @envir.ee

SCHOLTZ Henning RAL gGmbH 4 222 412 351 823 [email protected]

SCHORPION Hannelore Belgian CB: FOD Volksgezondheid, Veiligheid van de Voedselketen en Leefmilieu

(+32) 2 524 96 18 [email protected]

mailto:[email protected]
























Participant list

Last name First name Organisation Phone number Email address

SILTS Karen Estonian Environment Agency 37,258,362,399 [email protected]

STECHEMESSER Kristin German Environment Agency +49 340 2103 – 2666

[email protected]

TKACZYK Joanna PCBC S.A. +48 22 46 45 208 [email protected]

VAUGHAN Paul UK Ecolabel Delivery +44 12 96 42 39 15

[email protected]

VINHAS Ana Direção-Geral das Atividades Económicas

[email protected]

WAIDTLEW Jakob Ecolabelling Denmark +45 72 41 48 16 [email protected]

WOLTMANN Lars SMK +31 70 35 86 30 0 [email protected]









MONDAY 19 JUNE – CB FORUM DAY 1

DISCUSSION:

CBs adopt the January CB Forum minutes and June CB Forum Agenda.

AOB requests are proposed by IT (on medical paper rolls – for discussion on 19/06) and DE (on detergents – for discussion on 20/06).

2 2:15 pm Statistics

HD Presentation of the March internal CB statistics

DISCUSSION:

ISPRA: proposes to have a reporting period at the end of the year to be in line with their Italian national reporting periods (June and December).

HD: reminds CBs that previously reporting period were in January and in June but given the holiday periods around those time frames and the EC’s request to synch the reporting periods to the CB forum/EUEB meetings, it was changed to March and September.

EC: indicates that it would be nice to have reporting on a quarterly basis.

HD: replies that having 4 reporting periods would be difficult for CBs to manage, as the data collection process is burdensome and also requires the HD to follow up numerous times with CBs before receiving all information.

DK: reasons that as figures do not change that much in two to three months, it seems unnecessary to have more than two reporting periods.

FR: regarding the drop in TA from France, there are two factors: 1) Renewal of licences to comply with the new criteria; 2) An initiative supported by The Ministry of Environment providing both an environmental label and financial support (for TA and textiles). At the same time, there is an initiative from ADEME to provide support (including financial) for TAs to apply to the EU Ecolabel. All of these factors are contributing to consumer and company confusion on the EU Ecolabel. Licence holders are switching labels for economic and communication reasons.

ISPRA: regarding the drop in IT products, this is due to the cancelation of several thousand hard covering products from one main licence holder. ISPRA requests the HD to create a products/services graph.

CONCLUSION:

For the time being, the reporting periods will remain in March and September as no other CB besides IT expressed issues with the current periods. The HD will create the products/services graph and upload the statistics onto the EU Ecolabel website and CIRCA.

3 2:30 pm Logo guidelines

EC Presentation of changes in logo guidelines

DISCUSSION:

DK: informs that Ecolabelling Denmark’s communication department strictly enforces unaltered logo use for the Nordic Ecolabel logo on all packaging and communication material. The objective for this is to ensure that the logo is always presented in the same manner which will hopefully enhance its recognition. Using this logic, DK is not in favour of the EC’s proposal to allow the use of different background colours on the monochrome logo.

ISPRA: as the logo guidelines have been strictly enforced within IT over the past few years, communication on this change will be difficult to give to licence holders as it might harm the credibility of the IT EU Ecolabel team.

EC: reminds CBs that the colour background on the monochrome logo was allowed before 2015. CBs can refer licence holders to the amendment in Annexe II (as it is an official EC document) and the logo guidelines in order to help them communicate on this change.

1 2 pm Welcome

CHAIR Tour de table, adoption of agenda and March CB Forum minutes and June CB Forum Agenda & AOB requests


DE & UK: understand the concerns proposed by DK and ISPRA, but believe that allowing licence holders to uses various coloured backgrounds in the monochrome logo is a positive and practical change. This will notably facilitate logo printing and reduce costs on packaging (as less colours will need to be used).

UK: asks when the logo guidelines changes will be implemented.

EC: announces that the logo guidelines document will be updated once changes on Annexe II are made (most likely in November in time for the EUEB). The EC advises CBs to inform licence holders as of now on the expected changes so that they can prepare accordingly.

FR: wonders if it would be possible to get a letter of intent from the European Commission which could be diffused to licence holders to inform them of this EC decision.

EC: will provide a draft version of the logo guidelines to CBs so they can communicate on the changes to their licence holders and applicants.

CONCLUSION:

A track change version has been circulated and will be discussed during the November CB Forum. The draft can be used by CBs to refer to the upcoming changes to their LH.

4 2:45 pm New ECAT_Admin release

EC – IT TEAM

Presentation of the updated ECAT_Admin

Questions & answers session

DISCUSSION:

DE: would like to know when the ECAT_Admin and the ECAT_Admin User Manual will be ready and if the portal and User Manuals will be translated in all EU languages.

IT Team: informs CBs that the test version of the ECAT_Admin portal is available for CBs to try out.

HD: states that the revision of the user manuals will be launched in July. Reminds that it was decided during the last meeting to remove the B2B and B2C boxes.

EC: informs that only the English version of the ECAT_Admin portal and the User Manual will be initially available as it will take some time for the EC to have it translated internally.

CHAIR: highlights that the User Manual translations are important for several countries because not all licence holders master EN sufficiently.

PT: proposes to have CB volunteers to test the new ECAT_Admin in order to give feedback on its functionality before the new version is released;

CHAIR: asks which CBs would be willing to test the ECAT_Admin.

CONCLUSION:

The HD will send the ‘test ECAT_Admin’ link to the CBs who volunteered (DE, DK, SE, HU, PT and BE) by 20/06. These CBs shall provide written comments and suggestions to improve the tool to the HD by 07/07. Once all of the comments are taken into account by the IT Team, the HD will ask the IT Team to publish the final validated version. The English version of the User Manuals will be published in July or August in English, at which time the EC will set a timeline for the translation of both the ECAT_Admin portal and the User Manuals.

3:30 pm Coffee Break


5 3:45 pm Wood-, cork- and bamboo-based floor coverings

SWEDEN Criteria 2,4e and 7

DISCUSSION: Criterion 4e – VOCs content in other used substances and mixtures

SE: raises a question about when exactly to test for the formaldehyde content of resin mixtures when assessing compliance with the 0.2% w/w limit in resin mixtures – because the result changes considerably depending on what time after mixing you test at. They have not found a conclusive and satisfactory answer from testing facilities on this matter either.

JRC: states that the calculation of the combined mixture that is used shall be investigated further. Reference was made to previous exchanges with a representative of the industry association Formacare about this same criterion when revising the EU Ecolabel criteria for furniture. The initial understanding was that no further testing of free formaldehyde was required, but that it was simply a case of adding up the in-can free formaldehyde contents of the different constituents of the resin formulation instead of testing emissions after combining these constituents. If in the end it is concluded that emissions are to be tested after mixing, then the time for testing should be immediately after mixing, i.e. T=0.

CONCLUSION: Criterion 4e – VOCs content in other used substances and mixtures

The JRC and SE will work together on this issue as there are no other CBs that have had experience with this criteria.

DISCUSSION: Criterion 2- Wood-, cork- and bamboo-based materials

SE: presents an example balance sheet which should be used in any product group where there are criteria for sustainable wood/fibres and where the product is not double labelled with FSC or PEFC.

JRC: agrees with the idea and states that an example balance sheet shall be presented for the paper product groups currently under revision, together with some rules which must be respected, such as the balance must never fall below 0 in any particular month. The JRC also informs CBs of the very recent allocation changes in the FSC scheme as it may also impact EU Ecolabel applications. Now only 10% of the certified sustainable virgin/recycled material has to actually arrive on site with remaining allocations possible by subtractions from balance sheets from other sites of the same company, even if the materials are not physically transferred between sites. JRC asks if CBs are aware of these changes and if it would impact their assessment efforts in any way.

SE: indicates that because the allocation can be across sites and not isolated to one site only, there may be difficulties to enforce multi-site allocations.

DK: believes that the approach of criteria 2 is clear in other product groups, such as copy and graphic paper, and suggests to apply the same approach to floor coverings.

CONCLUSION: Criterion 2 – Wood-, cork- and bamboo-based materials

SE will send out the worksheet presented during the presentation to CBs the week of 19/06 for feedback.

Based on this feedback, an approach for verification of WFC will be sent out by SE to CBs for consideration.

6 4 pm Lubricants

CZECH REPUBLIC

Test methods and laboratories

7 4:15 pm Virtual CB Forum Questions

CHAIR Information point on conclusions

Concluded CB Forums

5/4 Enzyme preparation classification – conclusion 4/5

14/3 IILD: Neutralizer – conclusion 9/5


Virtual CB Forum that will be discussed at the second session of the June CB Forum (June, 20th)

28/2 Printed paper – deadline 21st March

3/5 micro-plastics

Ongoing Virtual CB Forums

5/5 scope textiles – 26/05

DISCUSSION: 19/5 stripper o CHAIR: answers received virtually where in line: stripper is out of scope because it’s not a routine cleaning

product o DE: believes that strippers do not fall under all-purpose cleaners because it is neither a recurrent cleaner. o UK: believes that the JRC should know why strippers are considered to be out of the scope of EU Ecolabel

product groups.

DISCUSSION: 19/5 polish

CHAIR: recalls that it is was highlighted by FI in a Virtual answer that it is difficult to make the distinction between floor care products and floor coatings.

DK: informs CBs that the Nordic Swan discontinued the product group floor care products.

DE: believes that this polish does not fall under paint and varnishes because it doesn’t have a binder. In case it has a binder and complies with the performance criteria

NL: has received an application from a former Nordic Ecolabel licence holder for floor finish, Essential Industries (an American varnish company), as the Nordic Ecolabel pulled this product group from its scope. It is possible that more CBs will be contacted by former Nordic Ecolabel licence holders in order to obtain the EU Ecolabel certification.

SE: will gather information on Essential Industries in order to provide information to NL (as they received an application from this company, which formerly held the Nordic Ecolabel for its product).

IPTS shall provide feedback on whether they consider polish to be in or out of the scope because in the criteria exclude “c) coatings for particular industrial and professional uses, including heavy-duty coatings”.

CONCLUSION:

Stripper is considered to be out of scope of the HSC because it isn’t a routine cleaning product

The Chair will contact JRC to ask clarification on the exclusion of “c) coatings for particular industrial and professional uses, including heavy-duty coatings”

8 4:30 pm AOB & losing remarks

CHAIR Discussion on points raised at the beginning of Day 1 of the CB Forum

AOB from ISPRA: are ‘medical’ sheets of paper that bear the CE mark in or out of scope

DISCUSSION:

ISPRA: interprets Article II of the Regulation (which prevents the certification of medical devices) as preventing the use of ‘medical’ paper sheets with the CE mark as being out of scope as these sheets of paper are used in a medical setting. If all CBs agree, ISPRA proposes that CBs check internally and withdraw all the licences for products that are CE marked.

UK: interprets Article II of the Regulation as referring to product groups that cannot be developed under the EU Ecolabel scheme, however, not individually assessed products within an existing product group. This being said, if a product that has the CE mark falls under an existing product group, CBs should be able to certify it. However, as there are different interpretations of Article II, the European Commission should provide an official note to clarify the article II of the regulation;

PL: consulted an expert that states that paper marked with the CE logo should theoretically be intended to clean wounds or body parts and paper rolls to cover an examination table does not have the bear the CE mark.

CONCLUSION:

CBs shall check with their licence holders to see what the intended use of these ‘medical’ sheets are and how they consider the CE mark to play a role in the classification of their paper products (as a medical device or not).


TUESDAY 20 JUNE – CB FORUM DAY 2

DISCUSSION:

AOB requests are proposed by DK & SE (on detergents), SE.

EC: thanks Hannelore Schorpion and Murielle Gauvin for their 2-year term as Chair and Vice Chair and announces the vacancy for these positions.

CONCLUSION:

CBs shall send their written interest for the CB Forum Chair and Vice Chair position to the EC by mid-September to be considered for the election which will take place during the November CB Forum.

10 11:00 Printed Paper (see Annex)

a. DENMARK Implementation of final criteria

DISCUSSION: Question 1) de-inking:

DE: We re-use tests on de-ink ability in different applications in case they come from the ink producer or when the printing authorised this.

FI : points out that while the criteria states that tests need to be carried out on each type of paper that a producer would like to certify, the user manual is less clear on the number of tests that need to be conducted on the products.

DE: reminds that additional tests need to be systematically conducted when there are different varnishes on the paper because the quality and coating can change the results. Due to the numerous products certified, it is costly and time-consuming to do a test for every similar product. Tests are preferably conducted on ‘high risk’ products (products that are composed differently from others that have already been tested) to ensure that resources are being used wisely. DE also believes that if the paper has a different binder or varnish than what has already been tested, then a new test needs to be done. However if the supplier of the pigment has changed, then it is not necessary to retest (as long as the previous tests show that the first pigment has been tested in the ‘worst possible scenario’.

DK: wonders what would happen if there was a change to the ink? What if there is a change to the ink?

DE: it depends on the change, if we need a new test or not. We also consult with test institutes to make this decision.

ISPRA: We ask for a new test unless they can prove the first test was performed in the worst condition.

CONCLUSION: Question 1) de-inking

It is not necessary to test the final product when they work within a frame of approved inks and paper. Tests can be used in different applications when they who paid for the test approve this. If the paper has a different binder or varnish than what has already been tested, then a new test needs to be done. If the ink changes it is not always necessary to retest, only if the changes negatively impacts the result.

DISCUSSION: Question 2 – How to indicate trade names on ECAT

DK: reminds CBs that generic names for products used to be allowed on ECAT, however, as of 2014, it was decided that all trade names should be entered into ECAT as individual products.

DE: indicates that while they require for licence holders to exhaustively provide the name of all of their products’ trade names in the Annex II of the contract, they are more lenient on how this information is presented on ECAT. Furthermore, there are practical reasons as to why this is not enforced on their licence holders: 1) A printing house does not want to publicly disclose on ECAT that they have a licence for confidentiality reasons. 2) Any printing house has numerous trade names, therefore it would be a laborious task to register them all in ECAT.

9 10:30 Welcome

CHAIR Tour de table and AOB requests

EC Announcement on the opening of the Chair position


UK: agrees with DE and believes that there should be more flexibility in the requirements to input information onto ECAT. Furthermore, as trade names change frequently, it would be too time consuming for licence holders to update this information within the system.

ISPRA: indicates that they would like to know if other CBs also request the additional information that the former policy officer, Carla Pinto, stipulated in 2014 from their licence holders, such as their list of consumables per product (this information was only requested for this product group).

NO: believes that there is a need to treat printing house as services because until the entire printing house is certified, it is not possible to validate each individual trade name (and consequently register each of them into ECAT). It is suggested to list the categories of products on the ECAT instead of the individual trade names.

ISPRA: highlights that this new leniency on how to enter information into ECAT will be difficult to justify to its licence holders, as common practice in IT was to enforce that each trade name was properly registered in ECAT.

CONCLUSION: Question 2 – How to indicate trade names on ECAT

Contracts will continue to be the official document with all listed trade names, however it is not necessary for licence holders to register all individual trade names in ECAT (general categories of products can be instead indicated).

DK and the EC will collaborate to propose an amendment for the UM during the November CB forum in order to make the stipulation on including each trade name for a licence in the ECAT more flexible.

b. CZECH REPUBLIC

Follow-up on the virtual CB forum discussion on criterion 5 waste paper

See Annex for context.

DISCUSSION:

DK, DE & NL: company averages for waste should not be taken when considering criterion 5; each product should be individually analysed to determine whether or not the 19% waste threshold is respected.

CHAIR: in the example that the Czech CB presented which lists all products and their waste levels, all of the products that are highlighted in yellow would pass (as they are below the 19% waste threshold), while only the product named ‘5 + 2’ would pass for the green products would be accepted (as they are below the 10% waste threshold).

DK: indicates that if the waste percentage was unknown, if the average was at 19% at the company level, and if they provided a declaration saying that the company has reason to believe each individual product was below the threshold, then they could have accepted it. However, as the information per product’s waste percentage is available and provided by the company, they have to consider each product individually.

DE: suggests that CZ checks back in with the company to see if there are waste reduction measures that the site could be applied, which could potentially drive down the product-specific waste threshold to below 19%.

NO: shares that in practice, once a printing house respects the criteria for the EU Ecolabel, their entire processes are generally compliant with the EU Ecolabel, even if not all of their products have the EU Ecolabel certification. Therefore, for CZ’s example it could be possible that considering the company’s average waste would be an accurate representation of all products.

CHAIR: indicates that NO’s approach would have been valid if the waste levels per product were not available, however, as they are available, they must be considered.

CONCLUSION:

When information on waste is available on the individual product level, each individual product must be below the applicable waste threshold in order for the product to be accepted into the scheme. If the information does not exist on the product level, then the company has to create a sincerity declaration indicating that they attest that all products theoretically are below the applicable threshold.


11 12:00 Copying and graphic paper

JRC-IPTS Compatibility and correlation of test methods used for criteria verification

DISCUSSION Emission testing for pulp and paper production:

JRC: Would like more explanation about the actual test methods used to generate emission data for calculations. Some of the standards specifically mentioned in the existing criteria have now been withdrawn (e.g. ISO 351 for Sulfur in coal). No mention is made of "or equivalent methods" in the Copying and Graphic Paper criteria but this surely must be allowed. For example, there are cheaper and more environmentally friendly tests for COD (e.g. ISO 15705 instead of ISO 6060) – are these being used? When measuring P, is total P measured or just "dissolved P"? The same standards provide methods for both analyses. According to BREF it should be allowed to accept TOC data in lieu of COD measurements so long as a correlation has been established between TOC and COD at the site level. When discounting S and NOx emissions due to onsite electricity generation, why is there a factor fo 2 applied to electricity but not fuel?

SE: confirms that they already accept TOC data in lieu of COD data for emissions to water and that the typical correlation is 4:1 of TOC: COD, but will vary slightly from site to site. Regarding the factor of 2 applied to electricity, SE explains that this was based on a standard equation that recognises the higher order energy for electricity than heat and was the result of collaboration with CEPI and manufacturers.

JRC: points out that no specific testing frequency is specified in the existing Copying and Graphic Paper criteria and that, where relevant, this should at least be as frequent as specified in BREF (i.e. daily for COD, weekly for Total P) but that even BREF is vague with respect to the frequency of testing for emissions to air (S and NOx).

ISPRA: considers that the continuous measurement test for air emissions was more reliable than others (this is also in line with the Italian national law), which makes it is less burdensome for Italian licence holders to comply. They add that spot testing by the ISO 11564 standard (for calibration of continuous monitors) was expensive and should not be required more than twice a year. It should also be possible to deviate from annual average data if the production campaign for the EU Ecolabel products was only during a limited period.

SE: points out that it is not very clearly stated how often measurements should be taken and that continuous measurement test for air emissions are better. Furthermore there are no guidelines on how many tests should be performed per year.

JRC: confirms that BREF states that emissions to air from some paper mill process units is required, but for all others periodic measurements apply with now further definition. This may apply where smaller units do not justify the cost of continuous monitoring equipment. It was added that the EU Ecolabel criteria allow the possibility to estimate S emissions based on the S content of the fuel burned. JRC proposes to add a standard for measuring S in biomass as a well as coal and oil. When submitting fuel based S emission calculations, is it assumed that all S is emitted to the atmosphere?

SE: confirms that they assume that all S in fuels is emitted to the atmosphere when this data is submitted instead of exhaust gas measurements.

FR: asks what the deadline is for the consultation and if the JRC plans on requesting feedback from the ad hoc working group (JRC sent a PowerPoint presentation the week prior to the CB Forum and CBs have not yet had time to consider the test method for criteria verification).

JRC: requests CBs to provide feedback on the relevance of the ‘information on emission data’ sheet by the 12th of July. The JRC, furthermore, requests feedback from the emission subgroup.

CONCLUSION:

CBs, in particular SE and ISPRA will share written feedback to JRC about how they apply the emissions to air equation via tests by 12 July.

12:30 – 1:30 pm

Lunch


See Annex for context.

CONCLUSION:

No issues were brought up by CBs.

DISCUSSION:

IPTS: It was agreed that criterion should be reviewed on a substance by substance base. The new criteria for detergents and the accompanying derogation conditions have been written with this in mind.

BE: reminds that because of practical reasons, CBs consider the incoming substances into the mixture when validating a product (this was agreed at the CB Forum).

FR: explains that for a fragrance could be classified H411 in spite that each of the substances are below the accepted threshold. For this reason FR also thinks the mixture should be looked at.

ISPRA: We used to look at the classification of the mixture but as it was agreed at the CB Forum to look at the classification of the ingoing substances we now follow this approach

UK: believes that CBs need to see how to consider a ‘common approach’ for relevant product groups. For example, some product groups indicate that mixtures and ingoing substances should be considered, while others stipulate that only substances should be considered. It is therefore not clear as to why certain product groups vary in approaches. The conclusion for this point should however be isolated to detergents.

CONCLUSION:

It was agreed that for detergents each of the incoming substances should be considered instead of the whole mixture, as previously agreed.

DISCUSSION:

JRC: Caps, spray system, spoon inside the box of powder product, viscosity and corresponding nozzle, are examples of dosing system

JRC: states that in regards to a ‘dosing system’, EU Ecolabel products should have instructions on their labels that match with the ‘dosing system’.

DK: would like to understand if the ‘dosing system’ that the JRC mentions in the criteria consists of an actual measuring cap that is physically present within the packaging, or if it would also be acceptable to provide instructions for consumers on how to properly dose the product, or even have a dosing system purchasable online.

JRC: explains that the dosing system could be either or both of the examples that DK gave. Regarding the instructions, it could for example indicate the number of drops or teaspoons needed of the product. ‘made available’ doesn’t mean it has to be physically present, you could also express the dosage in number of tea spoons and everybody has a tea spoon.

BE & DK: believe that at its current state, this criterion leaves room for interpretation and that the clarification that the JCR gave should be further clarified in the User Manual. When is the combination of viscosity and nozzle for example for a HDD sufficient? There are no thresholds provided.

12 1:30 pm New detergents criteria

a. CHAIR New packaging criteria – CBs have been requested to check with their applicants if the New criterion is feasible and if a clarification in the user manual is needed. conclusion = no issue

b. JRC-IPTS Criterion hazardous substances: substances vs. mixtures

c. JRC-IPTS What should CBs accept as a ‘dosing system’?


CONCLUSION:

The criterion for dosing systems intended to mean that either a physical ‘dosing system’, such as a cap can be present within the product, or that dosing instructions matching the dosing system should be available on the label to guide the user.

The JRC is requested to clarify this further in the User Manual.

DISCUSSION:

DE: Companies that buy mass balance are easier to track because only a verification of the invoices is necessary to ensure that the orders have been purchased. If palm oil is bought directly, then a calculation must be done to carry out the verification. Certificates for book and claim and/or mass balance are requested from the company in March as purchases can be made up through February (so irrelevant to ask before that time). There is a current trend for companies to use mass balance.

SE: We check mass-balance certificates in April of each year. CONCLUSION:

This point is an information point. JRC will add additional specifications on how CBs can interpret the criteria on palm oil to the User Manual.

CONCLUSION: Opacifiers

According to the answers already received through the Virtual CB Forum and the note circulated by BE insoluble synthetic polymer particles such as opacifiers should be considered as micro-plastics according to the micro-plastic definition for detergents. For example, STYRENE/ACRYLATES COPOLYMERS (e.g. CAS# 9010-92-8)

CONCLUSION: Wax

According to the answers already received through the Virtual CB Forum and the note circulated by BE insoluble synthetic wax are considered as micro-plastics according to the definition for detergents.

DISCUSSION: Should we accept biodegradable micro-plastics

DE: believes that existing tests are not fit for insoluble micro-products. Some tests do not reflect the conditions faced in a marine environment.

CHAIR: suggests to keep this in mind for the revision in order to include it in the future criteria and reminds that the exception for biodegradable micro-plastics isn’t written in the definition.

DE: indicates that the EU Ecolabel Regulation only has a test for biodegradation of soluble chemicals through composting but does not have a mention on insoluble plastic particles.

SE: We don’t have specific cases of biodegradable micro-plastics, the exception is there to allow this in case this would exist in the future

CONCLUSION:

Biodegradable micro-plastics should be considered as micro-plastics given the current definition.

d. DENMARK How do CBs apply the new criteria on palm oil?

e. CHAIR Micro-plastics: specific questions


DISCUSSION:

DE: believes that the new framework for the detergent group should include information on how to select the reference product. Common practice in DE is that the operator of a company usually selects a reference product, and ask the CB for their validation. DE tests a product against a German reference product even if it is sold in another country, for example Romania. DE tests a floor cleaner against a floor cleaner and the dilution should be similar and also the ph should be in a similar range, DE would test an acid APC cleaner against a basic one. The description hon how DE proceeds at the moment of selection of the reference product for APC, kitchen cleaner and glass cleaner for which no generic product is available (text from Blue Angel RAL-UZ194).

ISPRA: highlights that the market share should be very important in identifying a reference product. Its use should, furthermore, be specified, for example by clarifying whether or not the product is ‘fit for all conditions’, or if they are more or less adapted for dirt removal, etc. It should, furthermore, have more information on the active content which cleans the product, and it should be clear if it is for the domestic or industrial market.

CONCLUSION:

Information point, see discussions above.

3:30 pm Coffee Break

DISCUSSION:

DE: points out that in order to comply with legislation, the producer is held responsible for displaying ingredients on secondary packaging although it is not compulsory to do so on transportation packaging. Therefore producers should clearly understand what is secondary and transport packaging. DE also believes that if the shop owner removes the packaging before putting the product on the shelves, this packaging should be considered as transportation packaging.

DK: believes that this example is also valid for products shipped to hotels. As the end user is the customer and not the hotel in this scenario, the packaging that holds the final end-user product would be considered as transport packaging.

CONCLUSION:

JRC will add the definition of transport packaging to the User Manual.

CONCLUSION:

CB’s are in favour to use the same definition for micro-plastics in rinse-off cosmetics and detergents given the fact that no definition is given for rinse-off cosmetics. The JRC will add the definition to the User Manual.

f. BELGIUM What do CB’s ask for to approve a market product as a reference product for the performance test of hard surface cleaners?

13 3:45 pm Rinse-off cosmetics

a. CHAIR Secondary packaging definition

b. CHAIR Follow-up Virtual CB Forum question UK: Which definition of micro-plastics shall be used for Rinse-of-Cosmetics


AOB from DE: DID List

DISCUSSION:

DE & FR: would like to know when the new DID list should be used and when it will be available on the website.

CHAIR: informs CBs that the new DID list will be used for detergents when the new criteria will be implemented.

DE: proposes to give applicants for rinse-off cosmetics a transition period to facilitate the switch to the new DID list.

CHAIR: all CBs agree that after October 1st, applicants will have to use the new DID list for rinse-off cosmetics.

DE & FR: would like to know if the additional information that was in the Annexe of the former criteria could be added to the part B of the DID list (as a copy/paste from the annexe of the 6 product groups).

CONCLUSION:

For detergents, if there is a minor formulation change, the old DID list can be used. For any other major updates in an existing licence, or for new licences, the new DID list shall be used.

For RoC, the new DID list shall be used for any new applications and reformulations after 01/10/2017.

Additional information regarding testing of biodegradability will be added in the Part B of the DID list as agreed upon between NO and DG ENV during the detergents criteria revision process;

The EC will publish the new criteria and the new DID list at the same time on the website.

AOB from DE: which reference dosing should be used for I&I detergents?

CONCLUSION:

The worst case test that should be used is soiling and water hardness.

AOB from SE: why are paper fibres excluded from the soil improver product group?

CONCLUSION:

SE will forward this issue to the JRC.

AOB from DK: formic acid

DISCUSSION:

DK: indicates that had to reject a formulation from a potential applicant who used formic acid as a new classification of chemicals has been published. However, this is problematic to their CB because they are aware that other EU Ecolabel certified products using formic acid are still on the market. The potential applicants see that situation as unjust because the products using formic acid are relatively cheaper.

BE: indicates that in the situation that DK describes, their CB considers the most valid safety data sheet for verification and leaves it is up to the licence holders to keep their licence up to date according to changes in classifications. We ask for an annual declaration to remind them to ensure continuous compliance with the criteria.

NL: adds that their CB asks licence holders to check the equations used for classifications, but as there is an exhaustive and compiled database for classifications does not exist, it is difficult for their CB to check each of the equations used by licence holders.

ISPRA: indicates that their CB tries to keep a database on Excel but as in the NL, it is not possible to look at the classification of all products. Like in BE, they give the responsibility to licence holders to ensure they are compliant with criteria. A suggestion, although it would be time consuming, would be for CBs could send a letter to inform licence holders of the new classification brought up by DK.

UK: points out that this approach would not be feasible to carry out for all classification changes for substances. Furthermore, it might not be necessary to communicate on this particular classification change because new criteria for detergents will soon be published (meaning that licence holders will have to reapply and comply with the new criteria). Therefore, certified products with formic acid will only stay on the market for few more months.

14 4:45 pm AOB & Closing remarks

CHAIR Discussion on points raised at the beginning of the CB Forum


UK: adds that a more practical action plan on this matter should be set in motion as substance changes are not an issue isolated to detergents. It is suggested that CBs systematically hold producers responsible for complying with the criteria and to stay up to date on classification changes.

NO: suggests to DK to award the licence in question, informing the company that they will have to comply with the new criteria in a couple of months (once they carry out the revision).

ISPRA: propose to CBs to wait until the publication of the new detergent criteria, to inform them of the new classification in order to avoid two communications campaigns.

NL: propose to add a standard note on the user manual to ask for tests to be sent once a year.

FI: does not think this will be feasible because the process is time and resources consuming both for the applicant and the Competent Body.

UK: needs to have a general and consistence process for this issue. Other chemicals might be under this scope as well and communication only on certain substances might be confusing for licence holders. Derogation is not the solution.

CONCLUSION:

This is a recurrent problem and a solution to handle cases like this should be sought. The idea of asking licence holders to provide an annual declaration has been considered as a good solution by several CBs.

DK LH will file a formal complaint and the EC will provide a letter to let CBs know about this formal complaint. CBs will then get in touch with their licence holders to let them know on the formal complaint and the change in the classification;

The European Commission request the task force on chemicals to come to the November CB forum with a strategic plan to act on these types of issues.


Annex

5. Wood-, cork- and bamboo-based floor coverings

A big floor producer has shown interest to apply for a licence for their products in Sweden. In that connection, there have been discussions about how to interpret the criteria 2 and 4e. The changes the producer needs to do in the production to fulfil the criteria will be expensive. Therefore, we would like to ensure that CB Forum shares our interpretation of them. Criterion 2 ‘. Where a certification scheme allows the mixing of uncertified material with certified and/or recycled materials in a product or production line, a minimum of 70% of the wood, cork and/or bamboo shall be sustainable certified virgin materials and/or recycled material…’ Assessment and Verification ‘ … the applicant shall provide audited accounting documents that demonstrate that at least 70% of the materials originate from forests or areas managed according to Sustainable Forestry Management principles and/or from recycled sources that meet the requirements set out by the relevant independent chain of custody scheme. FSC, PEFC or equivalent schemes shall be accepted as independent third-party certification….’ The question here is what documentation is actually required to verify that 70% of the ecolabelled product or production line is sustainable certified material. (In this case only FSC and PEFC certification schemes are considered.) Swedish interpretation: There are two ways to verify the amount certified material: 1) If the ecolabelled wood floor covering is double certified with FSC or PEFC (Their logo is printed on the packaging) only a valid CoC certificate of the floor producer is needed. 2) An additional section where it can be seen the amount of certified material allocated to the EU Ecolabelled products is added in the company’s FSC/PEFC accounting system (in the balance sheet) for the certified material, see appendix. The 70% certified material is counted on an annual basis and checked once a year by the CB. Criterion 4e 4.e. VOCs content in other used substances and mixtures “…..Free formaldehyde of liquid aminoplast resins used in the manufacturing of the floor coverings shall be less than 0.2% weight by weight….’ Assessment and verification ‘.. The applicant shall provide test reports demonstrating that the free-formaldehyde content in the liquid aminoplast resins is less than 0.2% weight by weight in accordance with standard EN1243…’ According to our potential applicant the requirement level 0.2% for the free formaldehyde in liquid aminoplast resins is very stringent. There are serious doubts about that any of the today used impregnation chemicals can comply with the criterion with the limit 0.2% free formaldehyde. However, the big wood floor producers are often manufacturing their own resins and we have got indication that our potential applicant could do the needed changes and pass the requirement in near future.


The issue now is when, in the impregnation process, the concentration of the free formaldehyde should be measured when the floor producers are manufacturing the resin and impregnate the paper on site. In the storage tanks, the content of free formaldehyde considerably changes over time. In a freshly prepared resin the content is high, but reduces over time as the chemical reaction melamine-formaldehyde goes on for a while. When this is finished, the free formaldehyde content rises again due to hydrolysis. The hydrolysis will go on during the impregnation of the paper and the free formaldehyde concentration will increase throughout the process. According to the standard EN 1243 the test should be done over a time period. Our question is when in the process the test period should start and how long it should be. Should the test period start at the beginning of the impregnation process or at the end of it? The problem is that the resin producers may make several tests along the production process and report the lowest test results to us. Therefore, we would like to have an agreement on when in the manufacturing process the samples for the free formaldehyde test should be taken and tested. We would also like to know the background for the very stringent requirement level and if other CBs have experience of the testing of the free formaldehyde in the impregnation process.

6. Lubricants test methods

Czech Republic has an applicant who wants the Ecolabel for two-stroke oils for marine applications, and the problem is Criterion 6 , (d) at least the technical performance criteria laid down in ‘NMMA Certification for Two-Stroke Cycle Gasoline Engine Lubricants’ of NMMA TC-W3). This test is too costly for their applicant, so CBs were searching for another accredited test method or laboratory, but they haven’t found anything, which they could use. They also searched in ECAT for similar licences, but they haven’t found any. Question: Do you have some experience in this field? Could you recommend some relevant laboratory?

10 a. DENMARK – Printed paper: implementation of final criteria

A Danish governmental institution (hereafter the implementation institution) working with the implementation of EU law in Denmark reacts on claims regarding possible different (and stronger) implementation of EU regulations in Denmark compared to other Member States. This letter deals specifically with EU Ecolabel criteria for printed paper. The implementation institution has instructed the Danish Environmental Protection Agency (Danish EPA) to do a check in two cases with regards to the criteria for printed matter. The Danish EPA finds it relevant to discuss this in the CB Forum, in order to ensure equal understanding and implementation of the criteria. The two cases below have been taken up by the implementation institution, and references to any countries are also on behalf of this institution. Case No. 1:

In Germany, it is accepted that generic tests are used as evidence of authorisations for the use of the EU Flower on printed matter. This means that a number of positive tests, which have already been completed by other printing companies with the same printing technology, can be used as evidence in other printed matter applications, without having to pay for new tests on identical raw materials and materials.


Danish EPA elaboration of the case: The case deals with recyclability of a printed matter, Criterion 3, and page 17 in the User’s Manual. ‘Generic tests’ are not explicitly mentioned in the criteria or User’s Manual, which refers to a ‘reference case’: Testing must be performed on a final product representative of the worst case reference. In our understanding, Germany is in line with the test requirements described in the User’s Manual. Ecolabelling Denmark has the same interpretation of the requirements and accepts in the same way other already completed test showing compliance with the criteria. For an ink this means that ’de-inkability score «shall be poor or better, equal to ’0’ or above, and shall (usually) be performed on three types of paper: uncoated, coated and surface-sized paper. Recognition of a test also requires that the tests are available. Other Competent Bodies views are welcome here.

Case No. 2:

The EU central register, ECAT, shows products that have obtained the EU Ecolabel certification in Europe. It seems that German, Dutch, Finnish and Romanian licensees have obtained registration of their licence under very wide trade names, unlike in Denmark, where licences are assigned a specific print or title.

Danish EPA elaboration of the case: The case deals with what is addressed in Criterion 1 and in the User’s Manual page 6. The User’s Manual specifies that an application for printed paper products can be made for:

A specific printed paper product identified by its trade name (e.g., magazine XXX) or

A single category of products (e.g., magazines, brochures, books, newspapers). In this case, the category

of products shall be identified as precisely as possible (e.g., magazines, glued, format X-Y, pages A-B).

This was agreed by the CB Forum in March 2013, and licence holders should be asked to change their trade

names accordingly.

As Case No. 2 implies wide trade names do exist in ECAT.

One case could be Finnish licence FI-28-003 to Erweko Oy with the trade name: Sheetfed offset printed

products.

Another example could be Rumania licence No.: RO/028/002 for several wide trade names: Ziare,

reviste, cataloage, broşuri şi flyere

Even Denmark has also registered licences with wide trade names, e.g. licence

DK/28/002 with the trade name: Husstandsomdelte reclaimer.

The Danish EPA understands that ECAT is functioning in the way that it is the licence holder who is

responsible for adding new information, changing trade names, etc.


Conclusion

The Danish EPA suggests that all licence holders are informed about the requirement in the User’s Manual

with regards to trade name.

Licence holders are given a 3-month time limit from the CB Forum meeting to make the relevant changes to

ECAT.

Other Competent Bodies views are welcome here.

10 b. CZECH REPUBLIC – Follow-up on the virtual CB forum discussion on criterion 5 of the

commission decision

From the virtual CB forum question raised by Czech Republic Question problem 1: Shall we assess the products as ‘newspapers’ and ‘not newspapers’ (magazines, supermarket leaflets) according to the content (not hard news, non-newsprint paper grade) or strictly according to the type of paper weight (between, 40 and 65 g/m2)? ; Questions problem 2:1) Is it possible to set an average of two maximum percentage limits of waste paper to assess the criterion 5, when printing house uses the Coldset rotation technology? 2) How to assess the total amount of waste paper produced annually in the printing house, what is the limit? Is that number defined by the technology? If so, then which limit should be chosen, when the printing house is producing newspapers and a lot of other products as well? Discussion DK: Question problem 1: The most important point is that the company shall not apply for ‘a group of products’. As agreed in March 2015 the product shall be the commercial name, eg. the name of the product listed in table 1 in the explanation. I think this solves most of the issues. DK’s comment to the question here is that only newspapers shall be evaluated as newspapers. Other types of printed matter can use ‘news print paper’. The limit (for waste paper) is set based on the technology and not the paper used. In regards to the paper CB’s also agreed that all used paper shall have a valid EU Ecolabel licence. New print paper is defined to have a grammage between, 40 and 65 g/m2. Hence only product that uses this paper can be labelled. If a cover having 90 g/m2 is used – this cover shall have a licence according to coping and graphic paper document. Questions problem 2.1): In principle yes. In the user manual the possibility of calculating an annual average is given. In this case an average based on the weight of the newspaper and non-newspapers could be calculated. And then the specific product in questions should have a waste percentage below the average. But since it is possible for this printing house to calculate the waste percentage for each product I would base the evaluation of each product on this. Or to be more specific we would not accept a newspaper with a specific calculated waste percentage higher than 10% – even if the average for all products is below 10%. 2) The answers are listed in point 1. But to repeat the limit listed in 5b waste paper shall be fulfilled by the all ecolabelled products. There are two ways to document this: • Calculate for the specific product, as listed in the example table 1 • Or as an annual average where the waste percentage is fulfilled – and importantly also arguments why the specific product will have a lower (or the same) waste percentage than the average; FI : 1) I think that the definition in article 2 (6) is very clear. Newspaper means a publication issued daily or weekly containing news and printed on newsprint paper grade that is made from pulp and/or recovered paper, the weight of which ranges between 40 and 65 g/m2. News can be ‘soft’ or ‘hard’. Other products


which are printed on newsprint paper, but don’t fit the definition (for example catalogues) are ‘other printed products printed on newsprint paper’. 2) Answer to question 2 Maximum allowed amount of waste paper is 10% for newspapers and 19% for other coldest rotation products. According to the user manual the applicant may provide calculations regarding the total amount of waste paper produced annually in the printing house and declare that these results can be assumed as valid for the EU Ecolabelled production. The threshold value should then be calculated in proportion to a number of newspapers and other products produced. For example, if the total paper use is 2000 tons/year of which 1200 tons is used in the production of newspapers and 800 tons is used in the production of other printed products, the maximum allowed amount for waste paper is 13.6%. DK stated that ‘as agreed in March 2015 the product shall be the commercial name, e.g. the name of the product listed in table 1 in the explanation’. I think that the situation at the moment is a bit confusing. The following text can be found in the UM: ‘An application for printed paper products can be made for: –A specific printed paper product identified by its trade name (e.g., magazine XXX) or –A single category of products (e.g., magazines, brochures, books, newspapers). In this case, the category of products shall be identified as precisely as possible (e.g., magazines, glued, format X-Y, pages A-B).’It is also said: –‘Only the trade names of printed paper products covered by an EU Ecolabel licence can be listed in ECAT and on the contract. Reference to categories of products (e.g., magazines, brochures, books, newspapers) shall not be listed.’ and –’Whenever an EU Ecolabel licence is awarded to categories of products, the printing company is not allowed to use the EU Ecolabel in the same category of printed paper products, whose trade names are not listed in Appendix 2 to the EU Ecolabel contract. ‘So, in practice you always have to apply licence for every trade name. But if you visit ECAT, you notice that EU Ecolabel has been granted also for categories of products. For example, the first licence on the list (DK/28/003) covers ‘Household distributed commercials’. FI thinks the most reasonable practice is to grant the licence for the category of products and it should be enough if the licence holder provides a list of all their EU Ecolabelled printed products to the competent body on a regular basis (for example once or twice a year) with samples of the products. The list shall include at least trade names and types of the products, customers, a number of copies printed and selling prices; FI : wants to add that FI would count commercials which look like newspapers as newspapers even if the content can’t be counted as ‘news’. NL: agrees with what has been said: only newspapers shall be evaluated as newspapers, other types of printed matter can use ‘news print paper’. All used substrate paper shall have a valid EU Ecolabel licence. Commercial trade names of all EU Ecolabel certified printed paper products need to be specified in the EU Ecolabel contract. This is important to ensure that every certified product is traceable to the accompanying EU Ecolabel licence. Regarding criterion 5, we would suggest to calculate the waste percentage for each product and base the evaluation of each product on this, like has been said. This is the option followed by our licence holder in his application dossier; UK: Regarding one of the questions here, UK’s requirement is to grant a licence for a category of printed paper products and on a regular basis (as per Finland) CB ask for a list of these by customer; Partial conclusion on the questions raised by CZ: Problem 1: Article 2 Definition newspapers: Shall we assess the products as ‘newspapers’ and ‘not newspapers’ (magazines, supermarket leaflets) according to the content (not hard news, non-newsprint paper grade) or strictly according to the type of paper weight (between, 40 and 65 g/m2)? All CB’s who replied had the same view:


Newspaper means a publication issued daily or weekly containing news and printed on newsprint paper grade that is made from pulp and/or recovered paper, the weight of which ranges between 40 and 65 g/m2. News can be ‘soft’ or ‘hard’. Other products which are printed on newsprint paper, but don’t fit the definition (for example catalogues) are ‘other printed products printed on newsprint paper’. Problem 2: Criterion 5 b) – Waste paper Approaches between CB’s differ, some CB’s very this at product level, others by printing method, not at product or group level. This issue will be discussed during the next CB Forum. For ANNEX refer to the Virtual and Physical CB Forum Excel sheet on CIRCA.

12. New detergents criteria

a. New packaging criteria – CBs have been requested to check with their applicants if the

New criterion is feasible and if a clarification in the user manual is needed. Please send your findings to the chair by the 15th of June

b. Criterion hazardous substances: substances vs. mixtures

JRC-IPTS will present how they envisaged the implementation of this criterion. This agenda point is to check with CB’s that they have the same understanding on how this should a implemented.

c. What would CBs accept as a ‘dosing system’?

Clarification from JRC-IPTS on what could be accepted as a dosing system. In case you have specific examples, please send them to JRC-IPTS before 09/06/2017.

d. How do CBs apply the new criteria on palm oil?

Do you have experience with the criterion on palm oil? Please share your experience with the other CB’s by giving a demo.

e. Micro-plastics:

Definition: ‘microplastic’ means particles with a size of below 5 mm of insoluble macromolecular plastic obtained through one of the following processes: (a) a polymerisation process such as poly addition or polycondensation or a similar process using monomers or other starting substances; (b) chemical modification of natural or synthetic macromolecules; (c) microbial fermentation; specific questions

Are opacifiers, which are small particles of insoluble polymers, micro-plastics?

Are wax emulsions considered as micro-plastics

Are stryrene/acrylates copolymers (e.g. CAS 9010 — 92-8) micro-plastics?

Should we accept micro-plastics that are biodegradable?


f. The framework for testing performance for hard surface cleaning products specifies that if a marketed product is used

as reference product this shall be approved by the competent body in charge of the application prior to the testing. This market product should be present in the region, where the applicant’s product is to be marketed and making the same claims about cleaning properties as the applicant’s product. Furthermore for concentrated all-purpose cleaners and kitchen cleaners, the reference product shall have the same application, comparable dilution ratio and Ph-value as the test product. A marketed product can be selected regardless of sales volume. It can also be another EU Ecolabel product that has the same intended use. Can you please share experience with the approval of those reference products?

What do you check for the reference product?

What does is mean that the reference product has to make the same claims? Does this simply mean that both have to be e.g. floor cleaners? But e.g. if a reference product claims also a disinfecting effect.

When is the dilution ratio and the Ph-value comparable?

Do you check other characteristics of the reference product? [Example from RAL (German CB)] Procedure for the selection of a reference product from the Blue Angel A-UZ194

Appendix 2 to the Basic Award Criteria according to RAL-UZ194 for Hand Dishwashing Detergents, All-Purpose

Cleaners, Sanitary Cleaners and Glass Cleaners

Fitness for use of all-purpose, sanitary and glass cleaners

The product must be fit for use and meet the requirements of the consumer.

For all-purpose cleaners and kitchen cleaners, the effective removal of grease must be verified.

For glass cleaners, a streak-free finish must be verified.

For bathroom cleaners, the removal of lime soaps and limescale must be verified. For acidic toilet cleaners, the removal

of limescale deposits must be verified.

The effectiveness of the products shall be tested using

- a suitable and verifiable laboratory test or

- a suitable and verifiable consumer test.

In both cases, the completion and documentation of the test are subject to concrete conditions that are explained in the

following regulatory framework: ‘Framework for testing the performance of all-purpose cleaners, window cleaners and

sanitary cleaners’.

The reference product used shall be a product that ranks amongst the 4 leading products on the market in Germany.

The selected product must be justified (e.g. with a GFK report). The following reference products can be used without

the need for justification for non-commercial/industrial products:

For all-purpose and kitchen cleaners:

Der General ‘Bergfrühling’

Meister Proper ‘1 für alles’

denkmit ‘Allzweckreiniger’

Ajax ‘Frischeduft’

Sidol ‘Küchenkraft’

Meister Proper ‘Express Power Fettschmutzreiniger’


For liquid scouring cream and solid scouring paste, the following reference product can be used:

Viss Scheuermilch

For solid products (pastes), the correct ratio of paste/water shall be determined based on the information provided on

the label and a corresponding mixture is then tested in comparison to this scouring cream.

For glass cleaners:

Sidolin ‘Streifenfrei’

Viss ‘Glas & Flächen’

For commercial/industrial all-purpose cleaners, kitchen cleaners or glass cleaners, a different reference product can

also be used as an alternative where the scope of application according to the information provided on the label is as

identical as possible. Examples:

A ‘gentle-acting floor cleaner’ compared to a ‘gentle-acting floor cleaner’

A ‘surfactant-free maintenance cleaner’ compared to a ‘surfactant-free maintenance cleaner’

The selection of the relevant market-leading product is to be justified (e.g. with a GFK report). Products with the same

scope of application from the following companies can be used as a reference product without the need for

justification:

Buzil

Diversey

Dr. Schnell

Ecolab

Kiehl

Tana

For acidic toilet cleaners and bathroom cleaners, the cleaning effect must correspond at least to that achieved by the

no-name reference product, which is described in the following IKW performance test ‘Recommendation for the quality

assessment of acid toilet cleaners’ (SÖFW Journal, 126th Year, 11, P. 50–56, 2000). The reference product is to be used

for toilet and bathroom cleaners; although the pH value must be adjusted to 3.5 when testing bathroom cleaners.

For laboratory tests on all-purpose cleaners, kitchen cleaners and glass cleaners, the following recommendation should

be applied ‘Recommendation for the Quality Assessment of the Product Performance of All-Purpose Cleaners (SÖFW

Journal | 130 | 9–2005), a performance test carried out in accordance with “Qualitätsnormen für Fußbodenpflege- und

reinigungsmittel” (SÖFW | 371 | 10–1986) “; (‘IPP-Gardner Test’) (Quality standards for floor care and cleaning

products) will also be accepted.


In order to verify a sufficient level of quality in the test to assess the fitness for use of all-purpose cleaners and kitchen

cleaners (effective removal of grease), the testing laboratory or the manufacturer laboratory shall document the

required number of strokes in the results section of the test report in accordance with the IKW ‘Recommendation for

the Quality Assessment of the Product Performance of All-Purpose Cleaners’ (SÖFW Journal, 130, 9/2005, page 58)

using the IKW test soil with the IKW reference cleaner (dosage: 5 ml undiluted) for achieving cleaning value 2:

Reference number of strokes: The IKW reference cleaner is set as standard to at least 4 strokes (ideally 5–15 strokes) for

cleaning value 2.

For laboratory tests on acidic toilet cleaners, the following recommendation should be applied ‘Recommendation for

the Quality Assessment of acid toilet cleaners’.

For laboratory tests on bathroom cleaners, the following recommendation should be applied ‘Recommendation for the

Quality Assessment of Bathroom Cleaners’ (SÖFW Journal | 129 | 11–2003).

Summary:

Cleaner

Ready-to-use (RTU) product or a diluted concentrate

Required fitness for use

Test method Diluted product

Reference product

All-purpose cleaner

Concentrate Grease remover IKW test in (1) Paragraph 5a

Undiluted see above

Glass cleaner RTU ‘streak-free finish’ IKW test in (1) Paragraph 5b

Undiluted see above

Sanitary cleaner —acidic toilet

cleaner RTU

Ability to remove limescale

IKW test in (2);

limescale

removal index

≥ 1.0

Undiluted Standard toilet cleaner in (2)

Sanitary cleaner —bathroom cleaner

RTU


IKW test in (2) or IKW test in (3) in Paragraph 3.1.2

Undiluted

Standard toilet cleaner in (2), pH value set to 3.5

Removal of lime soap IKW test in (3) Undiluted


Sanitary cleaner —bathroom cleaner

Concentrate


IKW test in (2) or IKW test in (3) in Paragraph 3.1.3

Undiluted


Removal of lime soap IKW test in (3) Undiluted



Sanitary cleaner —kitchen cleaner

RTU Grease remover IKW test in (1) Paragraph 5a

Undiluted see above

(1): Recommendation for the Quality Assessment of the Product Performance of All-Purpose Cleaners (SÖFW Journal | 130 | 10–2004), a performance test carried out in accordance with the ‘Qualitätsnormen für Fußbodenpflege- und reinigungsmittel’ (SÖFW | 371 | 10–1986); (‘IPP-Gardner Test’) (Quality standards for floor care and cleaning products) will also be accepted (2): Recommendations for the quality assessment of acidic toilet cleaners (June 1999) (3): Recommendation for the Quality Assessment of Bathroom Cleaners (SÖFW Journal | 129 | 11–2003)

13. Rinse-off Cosmetics

Secondary packaging: The chair will share the examples that have been shared by other CB’s and some other examples. The goal is to have a common understanding on what secondary packaging is. Follow-up Virtual CB Forum question UK: Which definition of micro-plastics shall be used for Rinse-of-Cosmetics?

Documents

EU ECOLABEL CB FORUM AGENDA Monday 19 June 2017 Forum/CB... · [email protected] WAIDTLEW Jakob Ecolabelling Denmark +45 72 41 48 16 [email protected] WOLTMANN Lars SMK