Minutes of the meeting

Transcription

1 EUROPEAN COMMISSION DIRECTORATE GENERAL JRC JOINT RESEARCH CENTRE Institute for Prospective Technological Studies (Seville) Sustainable Production and Consumption Unit 2 nd Ad-Hoc Working Group (AHWG) meeting for the revision of the EU Ecolabel criteria for Wooden floor covering Thursday 28 th May 2014, 09:30 17:00 Albert Borschette Conference Centre (CCAB) Room 3B Rue de Froissart, 36, 1040 Brussels, Belgium Minutes of the meeting 1

2 Participants List Name Surname Organization 1 Kirsi Auranmaa Motiva Services Oy 2 Alicia Boyano JRC-IPTS 3 Blandine Cupidon BEUC / EEB 4 Antonio de la Torre OCU 5 Shane Donatello JRC-IPTS 6 Marianne Eskeland Ecolabelling Norway 7 Markus Kirschner HDH e.v 8 Sylvie Ludain DG ENV 9 Hans Moons JRC-IPTS 10 Xavier Noyen PEFC 11 Reinhard Oppl Eurofins CPT 12 Carla Pinto DG ENV 13 Rocio Rodriguez-Quintero JRC-IPTS 14 Ulla Sahlberg Ecolabelling Sweden 15 Eric Sitters EFRA 16 Theo Smet EPFL 17 Daniela Toma Ministry of Environment of Romania 18 Joanna Tkaczyk Polish competent Body 19 Paul Vaughan Defra 20 Candela Vidal-Abarca Garrido JRC-IPTS 21 Jakob Waidtloew Ecolabelling Denmark 22 Domenico Zuccaro ISPRA 2

3 Agenda SCHEDULE 1. Opening and welcome 09:30 09:45 2. Political objectives of the EU Ecolabel and process description 09:45 10:00 3. Summary of the process up to 2 nd AHWG meeting and general overview of the meeting 10:00 10:30 4. EU Ecolabel criteria for Wooden Floor Covering- Revision of the name and scope 10:30 11:15 Coffee break 11:15 11:30 5. EU Ecolabel criteria for Wooden Floor Covering - Revision of criteria and discussion: Sustainable wood and wood-based materials 12:30 13:00 Lunch break 13:00 14:00 6. EU Ecolabel criteria for Wooden Floor Covering - Revision of criteria and discussion: Restriction on hazardous substances and specific 14:00 15:00 substances 7. EU Ecolabel criteria for Wooden Floor Covering - Revision of criteria and discussion: Production process (energy savings and waste 15:00 15:30 management) 8. EU Ecolabel criteria for Wooden Floor Covering - Revision of criteria and discussion: Formaldehyde in wood-based board 15:30 16:00 Coffee break 16:00 16:15 9. EU Ecolabel criteria for Wooden Floor Covering - Revision of criteria and discussion: Finished product (indoor emissions, fitness for use and 16:00 17:00 maintenance) 10. EU Ecolabel criteria for Wooden Floor Covering - Revision of criteria and discussion: Information 17:00 17: EU Ecolabel criteria for Wooden Floor Covering - Conclusion, next steps and closure of the workshop 17:15 17:30 3

4 Contents Overview of process for EU Ecolabel criteria development Scope and definition of product group "Wooden Floor Covering" Discussions on Criterion 1: Sustainable managed wood... 6 Discussions on Criterion 2 and 3:... 8 Restrictions on hazardous substances... 8 Discussions on Criteria 4: Manufacturing process Discussions on Criteria 5 and 6: Formaldehyde emissions from core board panels and final product requirements Discussions on Criteria 7: User information and information appearing in the label

5 Overview of process for EU Ecolabel criteria development. After welcoming the stakeholders and a round of introductions, JRC-IPTS presented the process for criteria revision and development for the "Wooden Floor Coverings" product group. The presentation was finished by highlighting the coming steps of this process. The deadline for sending written comments through BATIS system was set on 30 th June and the 3 rd EU Ecolabel draft proposal announced for October The last step of this process is expected to take place during the first half of Scope and definition of product group "Wooden Floor Covering". A brief summary of the main environmental impacts of this product group as reported in the Preliminary Report and their link with the proposed EU Ecolabel criteria was introduced. During this presentation, only relevant figures and facts found during the investigations were commented. The text on the scope and definition was introduced and several questions were addressed to stakeholders regarding several aspects that were pointed out as feedback for the time being. The first question was related to a possible lower threshold on wood and wood-based materials. During the 1 st AHWG, a lower threshold of 80% wt of wood-based materials vs the current 90% wt was proposed. This limit is proposed to be slightly decreased to 70-75% wt by the industry stakeholders to ensure that laminate floorings are included in this product group. Currently, laminate flooring is the main wood-based floor covering produced and consumed in Europe. According to the market data, about 90-93% of laminate floor coverings is high direct flooring (HDF). HDF contains about 80% wt wood material and approximately 2-4% wt woodbased materials contained in the paper layers. Therefore, a maximum threshold of 75% wt of wood fibers should be proposed to include laminated flooring in this product group. Advantages and disadvantages of this new proposal were summarized during the discussion. Among the advantages, and because of the lack of applications, this proposal opens the EU Ecolabel criteria set to a wider market share. Among the disadvantages, it was pointed out that this changes could entail further environmental impacts (in terms of indoor air quality and emissions coming from the flooring, recyclability, end-of-life, hazardous waste, etc.) since higher amount of non-wood-based materials (e.g adhesives) would be included. All in all, the general opinion seems to be favorable to the proposed change. Additionally, hybrid products on HDF core with a large variety of surface layers going from carpet to PVC could fall more easily under this definition. The larger range of product might require the development of further EU Ecolabel criteria. The lower wood-based material in the flooring triggers the proposal for a new product group's name that better reflects the inclusion of other materials. During the 1 st AHWG, the name "wood-based floor covering" was proposed. Additional proposals were suggested during the period for commenting and during the meeting such as "plant-based floor coverings" or "woodderivative floor coverings". These last two proposals are, however, being considered as confusing from the consumers perspective since they may make consumers have the impression of being buying wooden floor coverings while the floor coverings are not made of 100% wt wooden materials. Stakeholders suggested that the name "wood-based floor coverings" does not reflect the floor coverings made of cork and bamboo that are not wooden materials. This name does not neither reflect the hybrid products that could be awarded with the EU Ecolabel. Therefore, it was 5

6 proposed as new name "wood-based, cork and bamboo floor coverings", which better reflects the materials the floor coverings can be made of. Regarding the definition of this product group, the inclusion of several terms were discussed. Among these terms, the need to include terms such as "pre-manufactured", "pre-finished" or "ready for installation" in the definition was discussed. The use of the term "non-structural" was regarded as non-necessary as it is implied already by the use of the word "covering". Moreover, it was pointed out that CEN/TS dedicated to flooring makes a difference between both terms "flooring" and "floor covering". In fact, there are no set definitions but quite a lot of them, depending on the subject of the standard. The inclusion of the terms "pre-manufactured", "prefinished" or "ready for installation" would imply a narrowing of the scope since only those floorings that are totally finished prior to installation would fall under the definition. High-end floorings that need a surface treatment after being installed would be excluded. Stakeholders expressed opposite opinions regarding this change in the scope. On the one hand, they expressed that a narrower scope would restrict the amount of products that can apply for the EU Ecolabel, especially those that are expected to easily comply with the criteria. On the other hand, they considered unfair that both types of floorings should comply with the same level of ambition of the EU Ecolabel criteria, as the compliance would be much more challenging for the pre-finished floorings. Additionally, limiting the EU Ecolabel to prefinished floorings would allow to better control the raw materials used and control the emissions.. Finally, a consensus was achieved on the non-inclusion of the adhesives and underlayers needed for the installation of the floor covering in the scope of this product group. Industry strongly recommends the promotion of floating installation since it is considered environmentally friendlier and is easier to be recycled in the end-of-life stage. Information and recommendation about these materials will be included as requirement in the user information criteria. Discussions on Criterion 1: Sustainable managed wood The criterion regarding the sustainable certification of wood-based materials, cork and bamboo was presented. The wording presented in this meeting differs from that included in the technical report uploaded in BATIS for commenting. For this reason, the slides presented in this meeting will be uploaded and stakeholders were asked to comment on the most updated wording presented. The main changes with respect to the first proposal were highlighted during the presentation as well as the efforts to harmonize the wording of this criterion with other criteria dealing with the sustainable certification of wood and wood-based materials across the EU Ecolabel criteria sets. Several examples for different ways of assessment and verification were shown by means of "non-real" examples. Several aspects of the criterion wording and their implications for the assessment and verification were pointed out during the discussions. Firstly, it was commented that the requirement "All wood, cork and bamboo shall be covered by the chain of custody certificates issued..." prevents from the need of balance sheets (as shown in one of the examples) but it obliges the floor covering manufacturers to be awarded with the chain of custody. This requirement therefore makes the assessment and verification of the minimum sustainable certified material and the remaining 30% wooden material coming from noncontroversial sources easier, but it increases the cost of the products without bringing any further environmental benefits. 6

7 A representative of one of the sustainable certification schemes explained how the scheme works. It was explained that for the remaining 30% wt of the wooden material that is not sustainable certified, non-controversial sources have to be demonstrated, so that the total amount of wooden material is covered by PEFC, FSC or equivalent certificates (70% sustainable certified materials and 30% controlled material). Concerning the chain of custody, it was explained that all players involved should be awarded with the chain of custody (from the forest to the shop). It was insisted that a whole chain of custody is needed to ensure the validity of the certificates. This is also needed to ensure the traceability of the material, being this aspect one of the main advantages of relying on a robust scheme such PEFC or FSC. If valid certificates are assumed, the percentage from sustainable managed forest will be never lower than 70%. Regarding the type of materials that should be covered as certified materials, it was expressed that the requirement should not only cover wooden materials (eg solid wood, wood chips or wood fibers) but also other types of materials such as cork and bamboo. This requirement, however, can be unrealistic if there are no certification schemes for those materials (eg. cork or bamboo) or if the amount of certified material on the market is very low. Regarding the threshold of 70% of sustainable certified wood-based materials, cork and bamboo, most of the stakeholders considered that this limit is ambitious but feasible at the same time. It was also highlighted that this minimum simplifies the assessment and verification of the criterion through any of the label on the market. Wishes to reach 100% sustainable certified wood-based materials, cork and bamboo were expressed, however, it was also recognized the need for flexibility related to the supply of certified wood on the market. 100% sustainable certified material is regarded as a challenge. Finally, it was stated that the availability of certified wood is around 30% of the total wood production in Europe, cork around 15% or lower and we don t have data for bamboo. Regarding the requirement "Uncertified material shall be covered by a verification system which ensures that it is legally sourced and meets any other requirement ", it was recommended to move it to the beginning of the criterion wording. Additionally, it was commented that national/regional ecolabels go beyond these requirements and that specifications of what is included in the verification system should be provided. It was requested that the criteria should allow for further investigation into the supply chain if the Competent Body deems it necessary as there have been a number of cases where the wood has been supplied as "sustainably certified" which in fact was found out to be a fraudulent declaration. Questions regarding the inclusion of other certification schemes under "or equivalent" were pointed out by the stakeholders. Regarding this point, it was pointed out that the current proposed criterion is largely in favour of PEFC and FSC and discriminates against any other schemes. In this sense, it was asked if national schemes such as those coming from Canada or Indonesia could be considered as equivalent. There are other national certification schemes that are widely used by SMEs due to their lower cost. Moreover, it was asked if locally sourced wooden materials in EU that are also locally processed at local sawmills can be considered. Restricting the verification on FSC and PEFC prevents lot of SMEs to apply for the EU Ecolabel. Therefore "or equivalent" is included in the requirement. Further concerns about the exclusion of GMO wood and shortcuts in supply in the coming years was also expressed. It was commented that large surface of forest are GMO forest in South- America. At this point, it was suggested that when required, further explanations and clarifications to the criterion wording can be included into the User Manual that comes along the EU Ecolabel criteria set. 7

8 Specific questions about the added value of the sustainable certification for cork and bamboo were brought on the table. It was pointed out that the nature of both materials makes almost impossible to cause deforestation in the forest where they are harvested. Additionally, it was indicated that cork floorings are made of by-products and "cork residues" coming from the bottlestopper industry and that bamboo certification does not apply to bamboo grown in plantations,. Finally, a comment dealing with the accreditation and certification was added. It was pointed out that accreditation and certification are different things ruled by EU Regulation 765/2008. Discussions on Criterion 2 and 3: Restrictions on hazardous substances Restructured criteria dealing the restriction of hazardous substances were presented during the 2 nd AHWG meeting. The wording of criterion 2: "General restriction on hazardous substances" differs from the wording included in the technical report uploaded as HTML version in BATIS and ready for commenting. Examples of changes in the wording used concern "substance", "preparations" or "chemical products". Therefore, these slides will be uploaded in BATIS and stakeholders are kindly requested to comment on the most updated criteria version. Several changes have been introduced in these two criteria in comparison to the draft presented during the 1 st AHWG meeting. These changes include the whole product as basis for the calculation of the limits of hazardous substances that can be contained in the final product (0.1% wt) and the reference to the content of substances and preparations classified with one or several H-phrases and not to those substances or preparations that have been used during the manufacturing process but that are not remaining in the final product. The proposed threshold (0.1% wt of classified substances) is welcome by the industry. Criterion 2 has been restructured into two sections. The first one restricts the use of substances classified as SVHC that cannot be derogated, while the second one restricts the use of substances that are classified with one or several H-phrases and that could be derogated if needed. Stakeholders expressed their concerns on the low number of derogations proposed. Regarding this point, industry members pointed out that there will be derogation requests for the following substances: - biocides and preservatives for water based substance of preparations (adhesives, lacquers, etc.) - substances used for repairing the flooring during the manufacturing process regarding to VOC content limits It was also pointed out that likely the derogation on flame retardants may not be needed as the building code does not require the use of flame retardants for this product group. Other stakeholders expressed their concerns regarding the lack of strictness of the 0.1%wt threshold when applied on the basis of the whole product. They indicated that it should be necessary to look at and restrict the use of hazardous substances that are used in very small quantities, even if the quantity used is so small that it does not reach the limits for classifying the preparation they are part of. It was indicated that these restrictions are the main purpose of criterion 3. Regarding this point, it was suggested that clarifications should be included into the user manual. It was observed that if the full recipe is needed for the assessment and verification, these can be 8

9 difficult for the producers and it was suggested that the assessment and verification should be done based on the list of ingredients and the safety datasheets of the preparations used. Criteria 3 deals with bans for specific substances, and concerns were expressed about the following points: - in general, it should be avoided to exclude cork and bamboo from the requirements by using the words such as "wood" or "wooden". Cork and bamboo are not wooden materials and these adjectives prevent cork and bamboo to comply with the criteria. - "restriction of pollutants in recycled wood": stakeholders welcome the inclusion of national schemes that are equivalent or stricter than EPF as proof of compliance. However, it was also pointed out that it will bring different levels of strictness across Europe. It was commented that the testing of the EPF standard is carried out by means of laboratory testing as well as quality control in the production facilities. Industry members pointed out that the amount of recycled wood was increasing in the recent past although not at the same pace in all the Member States. However, regarding the relevance of this sub-criterion, it was pointed out that although it should be extended to recycled cork and bamboo materials, currently they are not separately collected and recycled. Regarding the use of recycled wood in the wooden and wood-based panels, it was commented that particle boards can contain recycled content but the high density fibreboard (HDF) typically used in wood-based flooring cannot contain any recycled wood content. - "flame retardants" and "biocides" are not required for floor coverings and not commonly used in this indoor product group. If flame retardants or biocides need to be added to the recipe, it is because the type of flooring has not properly been chosen for the application. Only in very exceptional cases are flame retardants added to the recipe. No unanimous opinion was expressed on the need for a derogation, since they are not generally used but can be required in public procurement tenders. Industry expressed the need for keeping the derogation for using biocides as preservatives for in-can preparations due to the increasing use of water-based coatings. - "VOCs and formaldehyde": a cornerstone question about how to approach the use chemicals that contain and likely release VOCs and formaldehyde arose during the discussions. This point was also commented during the 1 st AHWG meeting where two alternatives to comply with the requirement of manufacturing and checking low-emitting products were proposed. The first alternative consisted in using solely preparations without formaldehyde and/or very low quantity of formaldehyde. The second one consists in demonstrating that the final product is a lowemitting floor covering, regardless the raw materials used. Different opinions were expressed on this point. Some stakeholders suggested that the best way of controlling the production of a low-emitting product is to control the low content of VOCs and formaldehyde in the raw materials while others suggested that it is only important to demonstrate the low emission of VOCs and formaldehyde during the use phase of the product. Additional requirements do not bring any added value to the product and they increase the cost of testing. Industry stakeholders confirmed that it is suitable to set requirements for emission of final product to 50% E1 emission but that there is absolutely no need for requiring 50% E1 emission for core boards that are going to be covered. Additionally, it was stated that the limits and thresholds for VOCs in substances, adhesives and surface treatments seem to be appropriate. The limit on free-formaldehyde in the adhesives was regarded as appropriate as well because the percentage of free-formaldehyde content in resins really depends upon how the resin has been prepared. If hardeners are added in the formulation, 0.2%wt can be achieved and even comply 9

10 with 0.1%wt in some cases. The only problem regarding the assessment and verification of this requirement is that the recipe for the preparation of the resin is generally not provided to the manufacturers and it should be directly sent to the competent body for verification. Finally, it was stated that halogenated organic compounds shall not be used in this product group whereas plasticizers can be used in some hybrid products. Discussions on Criteria 4: Manufacturing process It was generally accepted that the criterion on energy consumption should be refined. Stakeholders pointed out the possibility of including in this criterion the energy needed during the whole lifecycle of the product, including the transportation of the raw materials and final products based on estimations. In this sense, loopholes of manufacturers that produce the flooring in faraway developing countries with low labor costs and less automated production facilities will be avoided. Similarly, considering the total life-cycle energy consumption would imply environmental credits for manufacturing the flooring in countries with a high share of renewable energy in their national electricity mix, ie Iceland. In this sense, it would be more appropriate instead to look at a criterion that better reflects EN and requires environmental product declarations (EPDs). The energy consumption during production is clearly a part of any such declaration. Further information will be provided on this point. Rewording of the current proposed EU Ecolabel is also needed. It was proposed to modify the clause "one year prior to the date of the application" by "annual average" and allow this to be calculated from more than 3 months data. With the current wording, an applicant with new production facilities would have to wait up to 1 year before applying. Improving in the wording of this criterion was also identified as needed. Especially regarding the type of fuels to be used in the calculations, the mix of fuels or the year the application is based. Regarding the waste minimization management plan criteria, it was pointed out that the initiatives required are very difficult to verify and therefore it would be better to withdraw the criterion. If this criterion is kept, the need of having the management plan in place for only several months (eg three) in order to allow the new installation to comply with the criterion was pointed out. In general, it was highlighted that the criterion should be tailored to fall in line with the philosophies of ISO 14001, ISO and ISO so that these certificates could be used as proof of compliance. Discussions on Criteria 5 and 6: Formaldehyde emissions from core board panels and final product requirements. Disregarding the possible alternatives to reach and assess a low-emitting final product commented above, the criterion proposed concerning the emissions of formaldehyde from the core board seems to be feasible to the industry. Feedback was provided that actually E1 10

11 emissions level is mandatory in Europe and that 50% E1 or 65% E1 emissions can be achieved for a MDF panel, even if it is more costly. Laminate floorings can easily comply with the 50% of E1 requirement in the final product. However, by requiring 50% of E1 emissions from unfinished boards, the testing costs and effort of compliance are increased in general, without an actual improvement on the emissions from the final product. Additionally, it was highlighted that the compliance with this criterion would depend upon a) the market availability of 50% E1 boards and b) any differences in technical properties of 50% E1 boards versus E1 boards. The proposed limits for the indoor climate criterion (TVOC and TSVOC as well as formaldehyde) were pointed out to be too low. Stakeholders suggested bringing this criterion in line with the requirements of Blue Angel and Nordic Labelling. Threshold of 300 mg/m 3 for TVOC and 100mg/m 3 for TSVOC were mentioned. Additionally, it was proposed to allow the possibility of stopping the testing if very low emissions are observed after three days. This information was pointed out to be included in the user manual. The limits for formaldehyde emissions should also be revised as the currently proposed one is too strict. Values of around 0.06 g/m 3 were proposed, which are in line with the above mentioned national/regional schemes. Similarly, the proposed limit on cancerogenic VOC is too low and can fall under the current detection limits. A new limit of 0.01mg/m3 was proposed, which is in line with the Finnish standard. Even if this limit is below the detection limit of some substances, it was indicated that the declaration provided cannot be strictly true, but would normally be accepted. Regarding the standards in accordance to which the testing should be carried out, the introduction of the TS/CEN standard was welcome and clarifications on the "or equivalent" were added. The term "or equivalent" is required from the legal perspective whenever a private initiative is pointed out as a mean of compliance. The sub-criterion addressing the fitness for use of the floorings needs to be revised. It was pointed out that some of the standards are not suitable for this purpose, e.g. bamboo flooring. Also, it was stated that it will be difficult for floors other than laminate (e.g. parquet) to demonstrate compliance with class 32. Stakeholders provided information about the relevant standards and norms as shown in the following table. Standard or norm EN Laminate floor coverings. Specifications, requirements and test methods EN Laminate floor coverings. Elements with directly applied printing and resin surface layer. Specifications, requirements and test methods EN Laminate floor coverings. Elements with acrylic based surface layer, electron beam cured. Specifications, requirements and test methods EN Loose-laid panels. Semi-rigid multilayer modular floor covering (MMF) panels with wear resistant top layer EN Resilient, textile and laminate floor coverings. Essential characteristics EN Wood flooring. Terminology EN Wood flooring. Multi-layer parquet elements EN Wood-based panels Wood veneer floor coverings EN Wood flooring. Characteristics, evaluation of conformity and marking Type of flooring Laminate floorings Hybrid products Parquet flooring 11

12 It was also mentioned that the classes are well-established only for laminate floorings but that this is not the case for other types of flooring. For example, lacquered floorings are not tested by this standard. It was also pointed out that the wear resistance is measured based on the corundum content and not on the thickness of the floor and that the determination of wear resistance of lacquered-oiled surfaces (eg bamboo flooring) is very difficult to measure and hardly any norm exists in this respect. The wear resistance of parquet floorings depends on the direction of the fiber. Finally comments on the maintenance criteria pointed out that the use or non-use of organic solvents cannot be controlled by the manufacturers and therefore the sub-criterion on maintenance is difficult to demonstrate. However, it was also pointed out, that the criterion only requires that the floor covering can be cleaned without using organic compounds, giving this possibility to the end users. Information and recommendations on the maintenance of the product should be provided in the user information criterion Discussions on Criteria 7: User information and information appearing in the label Regarding the information to be included in the user information criteria, it was required to provide information at least about the following points: - recommendations for installing the floor coverings as floating floor covering or fixed parquet flooring, referring to the best environmental installation alternatives. - recommendations and instruction on the floor covering installation. In case of requiring glues, EMICODE glues should be recommended. - recommendations on the maintenance of the product No further comments were provided on the presented information requirements. Closing of the meeting The meeting closed presenting the next steps for the coming months as follows: - Mid-June: updating of the project progress to the EU Ecolabel Boarding - 30 th June: deadline for submitting the comments on the 2 nd EU Ecolabel criteria proposal - October 2015: release of the 3 rd EU Ecolabel criteria proposal - End of the project: 1 st semester 2016 and summarizing the main discussions held and the conclusions drawn, as follows: - Several points concerning the scope and definition need to be discussed in the coming EUEB meeting and evaluated considering stakeholders feedback. These points concern the proposed lower wood-based material content down to 75% wt and the inclusion/exclusion of high-end floorings. The definitions of the different types of floorings will be revised and reworded in line with those included into the standards (whenever possible). - A revision of the wording of sustainable certified wood criterion has been identified as needed. This revision should include both the main criteria text as well as the assessment 12

13 13 and verification text. Stakeholder's feedback regarding the inclusion or exclusion of certified bamboo and cork is required. - A revision of the wording of the criterion dealing with the general hazardous substances will be carried out. This revision will concern the wording of the raw materials needed for the manufacturing the floorings. - Although generally speaking, the restrictions included in criterion: specific hazardous substances have been welcome, a revision is needed concerning the wording and the extension of these restrictions to other materials apart from wooden materials. Some of the identified substances (eg halogenated organic compounds, flame retardants or biocides) are scarcely used in this product group while other such as plasticizers needs to be investigated for inclusion. - Further research is still needed to better address the environmental impacts caused during the manufacturing of the flooring regarding the energy consumption and waste management plans. Investigation will be focused on the boundaries to account the energy consumption by the flooring as well as the assessment of the both section by means of ISO and ISO Withdrawing the last option will also be considered. - One of the major issues identified during the discussions concern the VOCs and formaldehyde content and emissions from the final product. Decision should be taken on how to assess and verify this aspect: testing of the final product, testing of the raw materials or both? Depending on the decision taken, a revision of the proposed thresholds will be also needed. - Finally, the criterion dealing with fitness for use should be refined. The performance classes suggested in this proposal correspond to laminate floorings, while bamboo and solid wood floorings are classified in accordance with other standards. Further information will be investigated.