Additional studies. Studies by Ecolabelling Norway:

Transcription

1 Agenda 1. Welcome and presentation of participants 2. Presentation of studies made 3. Overview of the proposed criteria 4. Definition of the product group 5. Environmental criteria 6. Health related criteria 7. Performance criteria 8. Packaging 9. Any other business

2 Additional studies Studies by Ecolabelling Norway: Impact of proposed requirements tested on 21 new formulations from Southern Europe. A number of external studies including: Anaerobic degradability of surfactants - Danish EPA 2002 Substitution of surface-active ingredients in cosmetic products - DHI 2004 Environmental guidance document - Danish EPA 1999

3 Substitution report Danish EPA Commissioned Report. Incl. surface active ingredients and preservatives Environmental impact assessed- litterature/ tests Most surface active ingredients less harmful to the environment. 24 ingredients tested for anaerobic degradability, most were degradable under anaerobic conditions. Conditioners often contain environmentally harmful cationic surafactants but less harmful alternatives exist. High bioaccumulation potential high toxicity. Modification of ISO 11734: Promising results.

4 Results from study of exact formulations The 21 new formulations plus the 50 we already have yielded the following results: CDV (l/g E AC) : Average liquid products except conditioners , range Average solid soaps 4 400, range Average conditioner , range Aerobically poorly biodegradable non-surfactants (mg/g AC): Average liquid products except conditioners 38, range Average solid soaps 15, range 0-47 Average conditioner 85, range Anaerobically poorly biodegradable toxic ingredients (mg/g AC): Average liquid products except conditioners 57, range Average solid soaps 13, range 0-39 Average conditioner 189, range Many ingredients not documented

5 Proposed changes in criteria Requirement levels for CDV and poorly biodegradable ingredients increased Requirement on endocrine disrupters adapted to new knowledge Test of mildness: 2 alternatives presented Packaging: Some additives excluded Box 2: Required information alongside ecolabel proposed

6 Changes in requirement levels The levels changed to achieve 30 % market share. Manufacturers must substitute preservatives and some surfactants to qualify for the label. Some manufacturers must also reduce the amount of fragrance. Some other ingredients must also be substituted.

7 CDV New limits Shampoo, shower products and liquid soaps: mg/g AC Solid soaps: mg/g AC Conditioner: mg/g AC In order to fulfil the CDV limit manufacturers must: i) substitute preservatives ii) reduce amount of perfume iii)substitute some surfactants iv)eliminate some other harmful ingredients such as Triclosan

8 Aerobic degradability Proposed limit on aerobic not degradable non-surfactants: Shampoo, shower products and liquid soaps: 25 mg/g AC Solid soaps: 15 mg/g AC Conditioner: 50 mg/g AC All surfactants must be aerobically degradable, definition of surfactants identical to Detergents Directive.

9 Anaerobic degradability Proposed limit on anaerobic not degradable toxic (LC/EC50<100) ingredients: Shampoo, shower products and liquid soaps: 25 mg/g AC Solid soaps: 15 mg/g A Conditioners: 50 mg/g AC The main problem is not poor degradability but lack of test results. Perfume, preservatives and surfactants gives problems. Almost all surfactants have acute toxicity < 100 mg/l.

10 Surfactants and anaerobic degradability Future aim: Elimination of all anaerobically poorly degradable ingredients. Different strategies possible: A) Surfactants eliminated first B) Toxic ingredients eliminated first Practical result of strategy A and B very similar when we consider impact on surfactants. Mostly practical reasons for proposing B)

11 Packaging One added requirement on additives: Additives based on Cd, Hg, Pb, organic tin compounds and halogenated organic compounds excluded. Endocrine disrupters also excluded. Reason: Additives prone to leak from landfilled packaging. May also give problems in incineration and recycling. No explisit limitation of specific materials. PVC has a potentially higher impact than other materials but the usage of PVC is low.

12 Endocrine disrupters Last list of potential or suspected EDs published by the Commission in Nov List contain 114 compounds, of which most are regulated through other regulations. Phatalates the most important group of EDs that occur in cosmetic products. No test have been validated yet. Proposal: All ingredients on the list excluded.

13 Product quality Cleaning efficiency and mildness main quality parameters in common for most products. No standard methods exist. Easy to formulate a product that cleans effectively, more difficult to formulate a product that is mild at the same time. Mildness very important for many consumers.

14 Mildness Requirement on mildness varies according to the user and the use situation. E.g. health personell that washes hands frequently. No standard test exist. The RBC test is simple and straightforward but not chosen for validation. Hen Egg Test/Chorio Allantoic Membrane (HET/CAM) seem to come out as the one to be validated. Problem: Veterinarian is needed.

15 Mildness: Our proposal Our proposal. Two alternatives: A. No requirement to test for product mildness. B. Product mildness must be demonstrated through in-vitro or in-vivo tests. Tests must be performed by neutral part Comparison with market average required Test must follow Colipa Guidelines.

16 Information for the consumer Consumer may be advised on a) Why the product has been ecolabelled. b) How to use the product in a way that minimizes environmental impact. Proposal: No information about product usage a) Lack of space b) Difficulty in persuading consumer to use little, and colder water when washing the hair or body. Proposal: Box 2 text as follows: * low impact on aquatic life * little use of hazardous substances * increased health safety