Minutes and summary Revision of European Ecolabel and GPP Criteria for furniture 1 st Ad-Hoc Working Group meeting JRC-IPTS, Seville, 7 October 2013

Transcription

1 Minutes and summary Revision of European Ecolabel and GPP Criteria for furniture 1 st Ad-Hoc Working Group meeting JRC-IPTS, Seville, 7 October 2013 DISCLAIMER: The views expressed are purely those of the writer and are intended to reflect the discussions at the above mentioned meeting. They may not in any circumstances be regarded as stating an official position of the European Commission. Discussion points 1 Key results from the techno-economic and environmental analysis Scope and definition Product description and hazardous substances Product description Hazardous substances Azo-dyes Flame retardants Phthalates Halogenated polymers Bisphenol A and compounds thereof Biocides Nanomaterials Materials Wood-and wood-based Timber Trade Regulation % certified/recycled wood(-based) materials

2 4.1.3 Other forestry and vegetal materials Recycled wood fibres Production of wood-based materials, formaldehyde Formaldehyde emission from untreated raw wood-based materials Plastics and metals Textiles, latex and PU foams Leather Glass Energy embodied in the materials used Light sources Surface treatments Durability, safety, ergonomics and fitness for use Recycling and waste Packaging Green public procurement

3 Seating plan 3

4 Agenda SCHEDULE 1. Opening and welcome 10:00 10:15 2. Political objectives of the EU Ecolabel and of Green Public Procurement 10:15 10:25 3. Ecolabel and Green Public Procurement criteria process description 10:25 10:40 4. Key results from the techno-economic and environmental analysis - Presentation and discussion 5. Scope and definition of the product group within EU Ecolabel and GPP - General overview and discussion 10:40 11:20 11:20 12:00 Coffee break 12:00 12:15 6. EU Ecolabel criteria for Furniture Product description and hazardous substances 12:15 13:30 Lunch break 13:30 14:30 7. EU Ecolabel criteria for Furniture Materials 14:30 15:30 8. EU Ecolabel criteria for Furniture Surface treatment, assembly, final product and packaging 15:30 16:30 Coffee break 16:30 16:45 9. GPP criteria for Furniture Proposed approach 16:45 17:15 10 Criteria for Furniture summary 17:15 17: Conclusion, closure of the workshop 17:45 18:00 4

5 1 Key results from the techno-economic and environmental analysis The main results of the background were presented. A question arose about the indicators used in the LCA analysis and why biodiversity was not taken into account. The scope of the indicators has been narrowed based on existing product category rules for this product group and the observation of the product environmental footprint. It would be possible to include other indicators, but that is not considered to alter the outcome of the analysis, i.e. that materials and their manufacturing are responsible for the main environmental impact. Furthermore, it was asked on how a combination of materials was handled. JRC responded that the analysis shows that wood is the best performing material compared to metal and plastics. Durability however has to be taken into account, especially for outdoor furniture. For the market data, it was asked if the sources where all mentioned in the background document. JRC confirmed that all data sources have been referenced in the document. 2 Scope and definition Stakeholders generally agreed on the definition and the extension of the scope to all materials. This will imply a change in the name of the product group from Wooden furniture to Furniture. Opening up to different materials should be reflected in the criteria document where criteria should be set for all materials. It has been proposed to set a cut-off limit for materials that are to be covered by criteria. This was generally accepted as it would be difficult to create criteria for all possible materials (e.g. stone, hemp). This will also help to keep the criteria development workable and practical. Objections to widen the scope were put on hold depending on the criteria for different materials that would be developed. Also regarding the consumer, a wrong signal could be given if treating wood, metal and plastic similar, even if they differ in environmental performance. Another approach could be to lower the content of wood (e.g. from 90% to 70%) for domestic indoor furniture. Other options could be explored for office, school and outdoor furniture. Moreover, it should be indicated clearly to the consumer that outdoor furniture has to be used outdoors because of potential concerns for indoor air quality. It was generally accepted that also leather should be included in the scope. One practical example is that manufacturers sometimes make furniture with different upholstery material options, where the consumer can choose between leather and textile. 3 Product description and hazardous substances 3.1 Product description The product description as proposed was generally accepted by the stakeholders. 5

6 3.2 Hazardous substances If stakeholders believe a derogation of certain substances (or H statements and R phrases) is necessary, this has to be clearly indicated to the JRC together with information for justification. A template for this information can be found in the draft criteria proposal and in the BATIS system. Comments have to be posted in the BATIS system as well. In general it was indicated by JRC that is not the intention of the EU Ecolabel to exclude groups of substances as a whole. This option could be explored only if supported by sound scientific and technical evidence. Other environmental labels have excluded certain groups of substances. It is important to know exactly which substances are used for which purposes. It was asked to the stakeholders to provide information about the specific functional substances used in the production of furniture (e.g. nanomaterials, flame retardants, phthalates, binding agents, solvents). A horizontal approach is welcome by different stakeholders. The line to follow would come out from the horizontal task force that is working on how to tackle this issue. JRC explained that even if substances are classified and excluded according to article 6(6) and 6(7) of the EU Ecolabel regulation, it is possible to restate certain chemicals in the criteria. This is in line with EU Ecolabel criteria for other product groups and could give a guidance and indication to verification bodies, manufacturers and consumers. A stakeholder confirmed that consumers are interested in the chemicals used in a certain product. A stakeholder raised the opinion to also differentiate in the criteria about hazardous substances among substances used in different materials. This would facilitate the assessment and verification. From experience of the Nordic Ecolabel, a horizontal derogation should be given to substances classified as R42, R43, R51 and R52 and contained in the product up to a certain percentage by weight. Otherwise, it would not be feasible to have any ecolabelled product. A producer stated that it is sometimes difficult to know what is exactly inside the product and clear testing rules should be provided. Industry is already following certain standards concerning hazardous substances. Focus should be on the final product, the output of a process, and not on the processes itself. An example given was for Cr(VI): if no Cr(VI ) is present in the final product, it proves that the process has been correctly managed. The European Furniture Association has recently developed its own sustainability guidelines, including information on substances used in furniture. These should become available soon and will be shared with the Commission. When aligning with other EU Ecolabels, care has to be taken to be consistent, e.g. for flame retardants TCEP is allowed in bed mattresses if not added intentionally Azo-dyes With respect to azo dyes, it was accepted to align this criterion with the EU Ecolabel criteria for bed mattresses and textiles. There is no need to extend this criterion to other materials, except for leather where these dyes are used. 6

7 3.2.2 Flame retardants It was proposed not to make a distinction between reactive and additive flame retardants, following the line for recently developed criteria for other EU Ecolabel products. Excluding additive flame retardants which could be safe to use, non-classified, would not be the right way forward. Moreover, reactive flame retardants would be more relevant in other product groups. This was generally accepted by the stakeholders. No objections are given to exclude the halogenated flame retardants listed for the moment. JRC asked for more information about which flame retardants (both halogenated and non-halogenated) are used for furniture. It seems that in the furniture product group flame retardants are only used for foams and textiles. As such it could be beneficial to align also here with EU Ecolabel criteria for bed mattresses and textiles. Industry supports not to exclude whole groups of substances and would prefer a list of specific substances to be excluded. A stakeholder raised the question if it is really necessary to maintain halogenated flame retardants in the ecolabelled product. Complete exclusion of halogenated flame retardants could be based on LCA analysis and scientific information. Also reference to the San Antonio statement was given. It was also mentioned that reactive flame retardants usually migrate less. Regarding flame retardants, care has to be taken according to public procurement contracts. In some Member States (e.g. UK, France, Italy), mandatory regulations are in place regarding fire safety. UK seems to have the most stringent fire safety regulations. A possibility could be to define different rules regarding to functionality and the fitness for use/purpose. Different levels of safety exist and could be proposed Phthalates Only the listed phthalates DnOP, DIDP and DINP were subject to discussion. DNOP seems to be produced only at a lab scale and is actually not on the market. These three phthalates are not classified as hazardous, but concern has been expressed in childcare articles and toys. Liver toxicity for babies between 0-18 months can occur if the article is extensively in contact with the mouth. Recent ECHA studies have confirmed this concern for these products. Even if furniture is not a toy, it could be an article for children (beds, chairs, etc.). These phthalates are excluded in other ecolabels and alignment is preferable. A stakeholder mentioned that furniture and children safety is taken care of in a mandate that has been sent to ECN for the development of a new standard which includes chemical requirements and hazardous substances. Another stakeholder mentioned that the EU Ecolabel should go beyond a legal baseline and is in favour of excluding these phthalates Halogenated polymers Halogenate polymers cannot be excluded on the basis of H- and/or R-phrases as they are not classified as such. However, concerns were raised about the monomer used. It was stated by different stakeholders that it is possible to exclude this group based on the experience of other 7

8 ecolabels where exclusion did not obstruct the release of licenses (e.g. Austrian ecolabel and Blue Angel). This shows that the exclusion of these polymers is not the reason that only one license had been given so far for the EU Ecolabel. Also here, alignment with other ecolabels is preferable Bisphenol A and compounds thereof The exclusion of bisphenol A on itself is based on the classification as H361f (Suspected of damaging fertility). Polycarbonates are made of bisphenol A. Information of the traces left of bisphenol A in this polymer would be provided by stakeholders. In general, it was asked for an exemption for impurities and byproducts until a certain percentage. More input from stakeholders on this topic is welcome Biocides It has been clarified that the thresholds defined for the mixture (3:1) CMIT/MIT refer to the chemical product used for treating the furniture product and do not refer to the final furniture product. It was mentioned that dimethylphumarate is not allowed in the EU. Pentachlorophenol and its salts and esters are included in the REACH Regulation according to restricted substances. Obviously, the same holds for textile and leather. Impregnation of indoor furniture is sometimes needed, especially in Mediterranean countries, e.g. Spain. A European standard should be available for indoor impregnation. Information would be provided to the Commission. Organotin, PCP, carbine and nano-silver should be excluded. Also residues on leather should be restricted Nanomaterials The general line to be followed according to the Commission is only to exclude nanomaterials based on their classification as hazardous or based on sound scientific proof that the material is hazardous. Other stakeholders wanted to ban all nanomaterials and only allow them if safety is proven, based on the precautionary principle. JRC asked the stakeholders to provide information on which nanomaterials are used in the furniture sector. 4 Materials It was generally agreed that small pieces (<50g) should not be encompassed by any requirement on materials. 8

9 4.1 Wood-and wood-based Timber Trade Regulation The proposal to not put any reference in the criteria to the Timber Trade Regulation was not generally accepted. It is important to take into account to who the criteria are addressed and which status the applicant has, operator or trader. Traders apparently only need to provide documents on the suppliers they work with while this is not a guarantee for legal timber. These can also be traders and manufacturers outside of Europe. Traceability is an important issue. An extra confirmation or statement in the ecolabel criteria is not seen as redundant. The assessment and verification for sustainable sourcing is an important point % certified/recycled wood(-based) materials It is generally accepted that 100% of the used wood(-based) material should be sustainably sourced, whether or not certified. Reference to the current proposal in copy and graphic paper has been made. A minimum of 70% certified/recycled solid wood was generally accepted, while a gradual phase-in to 100% is desirable for some stakeholders. Some stakeholders argued that no distinction should be made in the % for wood-based materials. Other stakeholders argued that the % for wood-based materials should be lower; 40% would be acceptable. The main reason for a lower % for certified/recycled wood-based materials is the possibility to use such a high amount of recycled material in the production of wooden board panels and their quality. Different viewpoints were raised as one stakeholder argued that it could be maximum 30%, while another one stated that up to 80% is possible. An important issue is the definition of recycled wood-based materials. This has to be taken care of as confusion could arise on what is recycled material: only from post-consumer waste or also pre-consumer waste or byproducts. By-products could be seen as raw materials. The Waste Directive has to be taken into account. Apparently in the FSC and PEFC scheme there is no difference between solid wood and wood-based material. Requirements on certified wood were questioned by a stakeholder as sustainable managed woods also exist without certification schemes. In Germany for example there is legally binding forest management and Europe has a long history on wood legislation. European wood is probably sustainably managed in most cases. A stakeholder asked if these percentages could also be valid by verifying the final product instead of the different materials/boards. One table top could be made of different materials. This was encountered by the statement that it would be easier to look at the different boards separately and would avoid to have documents for every different product type or variation. It was asked to keep both options open, i.e. to declare the percentage for different materials or for the final product. 9

10 4.1.3 Other forestry and vegetal materials FSC certification exists for all materials coming out of forests. Bamboo for example coming out of a forest could be certified. However, bamboo coming from a plantation would not be certified. For non-forest bamboo, in particular, there should exist an approach for certification schemes, but there is no certification yet. Ratan and willow are other materials that are commonly used in the furniture industry. These usually come out of a forest and could thus be FSC labelled. Materials that are not certified could fall under materials for which no criteria are set and could thus be limited up to a certain % Recycled wood fibres A proposal was for more restrictive limits for recycled wood fibres according to the newly updated European standard EN 71-3:2013 (Safety of toys, Migration of certain elements) regarding the migration of certain elements. However, a well-established standard is currently followed by the industry, i.e. the standard of the European Panel federation, which is based on the old EN 71-3 standard. The EPF standard does not include all the elements described in the EN 71-3, but only the elements relevant for furniture. For most elements the EPF standard goes beyond the updated EN71-3 standard. Extra elements relevant for furniture are described in the EPF standard and are not in the EN standard. The test methods in the updated EN 71-3 standard are difficult to apply on wood. It is thus generally agreed to keep the limit values of the EPF standard. Moreover, as this standard is already followed by industry it has been suggested by some stakeholders to delete this criterion as a whole. Another stakeholder suggests going beyond the EPF limits Production of wood-based materials, formaldehyde The limit values of 0.2 %(w/w) of free formaldehyde content in products or preparations used in the panels and in binding agents, adhesives, and glues for plywood panels or laminated wood panels has been generally accepted Formaldehyde emission from untreated raw wood-based materials A proposal was done to limit the emission of formaldehyde from particle and fibreboards in their raw state, i.e. prior to machining or coating. The proposed limit value would be 50% of the threshold value that would allow it to be classified as E1 according to the European standards. Most stakeholders think that this limit value is too strict. It could be lower than the E1-values, but 50% lower is too strict. The fact that it is too strict was experienced in the Nordic Ecolabel. Other stakeholders are in favour of keeping the E1 limit as the formaldehyde content is strongly related to the quality of the boards, especially for MDF and HDF, which could influence the lifetime. A possibility could be to differentiate between different types of boards. The Blue Angel label and the Japanese E4Star applies the 50% E1 limit and do have licences, so the EU Ecolabel could go beyond the industry standards. It is important to find out which products are labelled in the Blue Angel, products from solid wood or from wood-based materials. Lower emissions are possible in practice, but this would rise the cost tremendously. In Spain, only about 10% of the production would meet the 50% E1 limit value. Further, it is argued that this criterion should refer to the emissions from the final product and not to the raw materials, also considering that other materials could limit the 10

11 migration of formaldehyde. It would be more important to have a criterion on formaldehyde emissions from the final product. 4.2 Plastics and metals For plastics it was proposed that if the final product contains more than 10% by weight plastic, plastic materials must consist of at least 50% by weight of recycled materials. For metals, it was proposed that if the final product contains more than 50% by weight of metal, metals must consist of at least 50% by weight of recycled materials in the case of steel and aluminum, 20% by weight of recycled materials in the case of other metals. These proposals were generally not accepted by the stakeholders. This means that for the moment there are not any specific criteria neither for plastics nor metals. JRC stressed that criteria for these materials are necessary as the scope is proposed to be widened and that these materials are regularly used for furniture. The same requirements are stated in the Nordic ecolabel. In the French label, 30-40% recycled material is asked for. A demand for 50% recycled plastics would exclude all high-strength plastics and metals. A derogation could be made for these material components that need to be strong. It was stated that 50% recycled material is possible for certain plastics (PE, PP, PET), but that for other plastics it would be difficult to achieve. Moreover, it is not done in the furniture industry. Recycled metals and plastics usually go in other product streams and the production of furniture is only a niche market for these recycling industries. Verification of the amount of recycled material would be difficult and it is not clear which documents should be asked for. Certain chemicals could be perpetuated. It is important to know which material goes in the recycling stream. Moreover, not all recycled plastic is good plastic as collection, cleaning and transport processes should be also taken into account in the assessment of the environmental impacts. It is remarked that the absence of criteria for metals and plastics could lead to the situation in which only criteria for wood have to be applied, even in case the percentage by weight of plastics or metals in the products is significant (e.g. for a product consisting of 10% plastics, 50% metals and 40% wood). An alternative could be setting a minimal threshold on the content of wood. Some stakeholders asked to rely on embedded energy to select among materials. A remark is made why for example copper, which is highly recyclable, is not mentioned explicitly. The purpose of this criterion is to increase the recycling of metals. However, for steel all scrap is already used. Moreover, different routes to recycle steel could be followed and it should not be the purpose of the EU Ecolabel to favor one of these routes. 11

12 One of the stakeholders suggested a criterion focused on recyclability rather than recycled content, but another one argued that the criterion should set actual facts instead of potential facts since in principle everything can be recycled. Stakeholders were asked to present alternative proposals and supporting information that can address setting criteria in this important area. 4.3 Textiles, latex and PU foams It was generally agreed that a harmonization between EU Ecolabel for textiles, bed mattresses (latex and PU foams) is desirable. However, care has to be taken that the criteria for hazardous substances are aligned as well together with the fitness for use (e.g. peeling). The flame retardant TCEP for example is currently excluded in the furniture proposals, while allowed in bed mattresses if not intentionally added. A remark was made on what to do with natural padding materials. The question was raised if also here a certain limit % of weight should be introduced. 4.4 Leather JRC initially proposed to exclude leather from the scope, but this was not welcomed by the stakeholders. In Italy a technical standard for leather is available and the development of EU Ecolabel criteria for footwear should be followed up. The Blue Angel has criteria on leather as well. Main issues for leather would be Cr(VI), formaldehyde, metal complex dyes and waste water discharges (as for textile), tanning and finishing agents and VOC emissions. In Europe there is extensive legislation. For imported leather reference could be made to existing EU legislation on tanneries. 4.5 Glass A certain % of recycled glass is welcomed, but no input has been given. No objections where found to exclude lead glazing, crystal glass or mirror glass when glass is used more than 10% by weight. 4.6 Energy embodied in the materials used To be able to calculate the energy embodied in a product, an energy factor for each material should be defined. This would be complicated by some practical difficulties. Even more difficult would be the definition of thresholds for different furniture product types. It was mentioned that EPDs (environmental product declaration) exist which describe the energy embodied in a material. Also the Dutch Stichting Milieukeur provides information, but does not set limits. A proposal form stakeholders was to report the energy embodied in the product, possibly indicating it on the label, but not to set a threshold at the moment. Other people argued that this criterion is similar to the one on the content of recycled material and should be removed. The energy embodied in a material is dependent on the amount of recycled material and that would be difficult to define. The same remark was given for plastic materials. 12

13 For plastics however, it would be straightforward to define the energy embodied in the material as good data should be available from the Canadian plastics association. For wood and wooden materials, it proves to be very difficult. No standards are available and the technologies change rapidly. The same wooden product manufactured by different companies could lead to very different energy consumptions. It would be thus better to use site-specific data, taking into account local emissions. Different processes used for the same material should be taken into account. In case this criterion will be set, it was proposed to provide exemptions for renewable energy sources. A stakeholder argued that the energy embodied should be measured considering also the manufacturing process and not only the input materials. 4.7 Light sources It was proposed that in the case where a lighting function is available in the product, fittings must be equipped with light sources classified with energy class A. This was generally accepted. A remark has been made to also look into furniture with electronics and electrical components that are not lights. Such furniture could be excluded from the scope. 5 Surface treatments It was proposed that products used for surface treatments may contain up to 5% by weight volatile organic compounds (VOC), a certain applied quantity could be used per m² and a VOC content limit for adhesives could be set to 3%. This limit of 5% is seen as very strict and many treatments would be excluded in this way. This limit allows only water-borne coatings to be used and spray technology would not be allowed. The VOC content is also strongly related to quality. A proposal is to link VOC emission limits to quality. A limit on the applied quantity per m² could be difficult when curved surfaces are coated. A remark has been made that the 5% limit relates to the VOC in the product with which the furniture is treated. As these are volatile components the content will change over time. Better would be to have an output criterion, based on the emissions of total VOC from the product. This idea was supported by several stakeholders as indoor emissions can be very important, especially for example in schools. Moreover, VOC emissions do not only occur from surface treatments. References to the EU Ecolabel for bed mattresses, the Blue Angel and the Nordic Swan have been made. It was also mentioned that limitations on chemical ingredients, hazardous substances and VOC would lead to a low quality of the surface treatment so there would not be any ecolabelled furniture. If limits on products would retain, distinguishing between water based products and solvent based products could be beneficial. Another proposal is to define different criteria for the different materials to be surface treated (wood, metal, plastic), because different paints and varnishes are used for these materials. An example is given for the treatment of metal with chromium (chrome plating). It could be better to go 13

14 for polished steel/aluminium than a treatment with chromium. Exceptions could be allowed if the chromium treatment would be done in a closed bath where no emissions occur. UV lacquer has the risk phrases R51 and R53. VOC emissions in a factory are usually taken care of in the factory itself where limits are set and after-burning can be used. Safety for workers is usually taken care of in particular safety standards. It is also noted that manufacturers already try to limit the use of adhesives as much as possible. Regarding practicability of the criterion, it is noted that it would be easy to verify and deliver data sheets for products used in the production of furniture. VOC emissions related the final product would require testing for each product. Testing costs for testing on the final product should be taken into account. 6 Durability, safety, ergonomics and fitness for use Regarding durability and safety it is generally agreed that EN or ISO standards should be followed. Most furniture is covered in these standards and a complete list of these standards will be sent to JRC. Also other ecolabels can be useful to have an overview of the available standards. It was noted that if no test standard is available it should be addressed to CEN/TC207. Independent testing should only be made by institutions accredited with the ISO17025 standard. Regarding ergonomics, different stakeholder views were noted. Most of the stakeholders were in favor to have a criterion on ergonomics. Ergonomics is related to the performance of the product and is important for marketing to consumers. Other stakeholders expressed that ergonomics has nothing to do with an ecolabel that looks at environmental performance. Moreover, ergonomics for school and office furniture would fall under the Workplace Directive. A big difference is noted between Nordic and other countries and different labels of ergonomics exist. Reference is made to Möbelfakta Sweden which is a system based on three areas of requirements; environment, quality and social responsibility. 7 Recycling and waste It was proposed that assembly should be done by reversible methods (screws) in order to allow disassembly and remanufacturing. More clarification should be given on what this means, if it means e.g. that no glue can be used. If no glue can be used, criteria on adhesives would be redundant. However, glues are mainly used for wooden products. Also the meaning of easy to recycle and/or disassemble should be clarified. It was noted that the intention is to easily separate different materials. This could be problematic for some wheels that for example can cover a plastic housing with metal inside. Another example that was given was for metal holdings that could be glued in a wood panel. Another remark was made on how to demonstrate that something is easy to recycle. Durability has to be taken in to account as well. 14

15 A question was raised if a take back scheme would be feasible. This would be difficult to implement and would be possible for big companies only. The proposal that plastic parts above 50g should be visibly labeled was questioned by a stakeholder as it would not serve any practical use and would not facilitate recycling. Other stakeholders argued that marking of plastics is useful for recycling and can avoid contamination. 8 Packaging No comments were received on the proposal for packaging. One remark is to explore if the restriction on the use of chlorine gas as a bleaching agent could be integrated in the hazardous substances criterion. Information to be displayed on the label will be decided more in the end of the process when most criteria are defined. A good explanation to the consumer is necessary. 9 Green public procurement It was noted that about half of the sales can be in tenders from public procurement for certain manufacturers. Public authorities usually take a look at price first, but also take environmental issues into account. However, as they usually have money they can take environmental issues into account. Many countries have nationally adjusted versions of the Training Toolkit on GPP. The Italian standards for example are difficult to reach. In public procurement, usually only a few environmental criteria are taken in to account. It happens that a choice is made for the one which is easiest to verify instead of the one that provides the biggest impact. Certification of sustainable wood is such an example. Difficult to demonstrate would be for example the content of recycled material. Procurement people are usually not suited for technical decisions, but training programmes exist. Fire safety requirements can be different for different target groups, e.g. hospitals, prisons. Suggestions were made to push the ecolabel forward in GPP. JRC answered that it is difficult to maintain the same level of ambitious for Ecolabel and GPP criteria because of practical reasons. A procurer needs to receive offers and products need to be on the market. The fact that procurers are usually not suited for technical decisions does not make it easier. As such, usually GPP criteria are narrower in scope or less strict than Ecolabel criteria. GPP criteria however are important for the industry. GPP criteria should be simple, but not low in requirement. A comparison for different GPP criteria in different countries should be made. UK, Germany Italy and the Netherlands (Senternovem) are suggested. In the UK for example attention is drawn to re-used and refurbished furniture. A database has been set up to exchange information about products or parts that can be re-used. 15

16 A stakeholder suggested that the most difficult criterion to reach for GPP would be the criterion on hazardous substances. It is important that Ecolabelled products fulfils GPP criteria. Practical information from stakeholders on procurement practices across the EU (e.g. technical differences between products, associated life cycle costs, practical examples of criteria) are welcome. 16