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/ UNION EUROPEENNE DE L’ARTISANAT ET DES PETITES ET MOYENNES ENTREPRISES
EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE
EUROPEAN ASSOCIATON OF CRAFT, SMALL AND MEDIUM-SIZED ENTERPRISES
UNIONE EUROPEA DELL’ ARTIGIANATO E DELLE PICCOLE E MEDIE IMPRESE

UEAPME's opinion on 6th August 2002 draft Commission Decision establishing revised ecological criteria for the award of Community Eco-Label to laundry detergents and amending

Decision 1999/476/EC

UEAPME and other members of the Ad Hoc Working Group revising the current eco-label criteria on laundry detergents proposed modifications of the different draft criteria submitted in the last months in order to take account of the technical progress and to achieve a better dissemination of the Eco-label on this product group. It must be considered that, so far, only three companies have eco-labelled products belonging to this group, even though laundry detergents are extremely widespread on the market. More in details, UEAPME makes the following suggestions:

Total chemicals

UEAPME welcomes the fact that its proposal to fix the amount of total chemicals at 100 g/wash was approved.

Powder laundry detergents

Foreword: despite the fact that eco-label criteria for this kind of product were among the first ones to be approved, there are very few examples of eco-labelled powder laundry detergents on the market. This is very likely due to the excessively high requirements of the criteria. Therefore, only two EU countries have Eco-Labels on the products currently on the market and only one product exists in Italy. In order to understand the proposals UEAPME is going to make, the following two aspect must be taken into considerations:

  1. The reference product (IEC-A*) was set ten years ago. Many things have changed since: washing machines, fabrics, the different kinds of dirt, but above all, the market. Undoubtedly, the quality of powder laundry detergents has progressively fallen. This is why nowadays a comparison with such a high reference product is no longer justified.
  2. The washing test requires a series of criteria to be compulsorily met. Two of these criteria (defined as "low priority") can also be partially met. Another lower acceptability level is set for them.

On the basis of these preliminary remarks, UEAPME makes the following proposals:

Main proposal: every EU country should be given the possibility to establish its national market leading product. This should be considered as the reference product and all the other products applying for the eco-label should compare their performances with it. In this case, the criteria for the washing test would not be modified.

Secondary proposal: Modifying the washing test in order to make it cheaper and less stringent. This means modifying at least the criteria which are harder to achieve:

  • The degree of whiteness according to Ganz: according to the current criterion the difference between the reference product and the product to be tested must be less than the value 15. This is increased to 20 in case of low priority. UEAPME proposes that these values are increased to 20 and to 30 in case of low priority.
  • The current washing performances foresee the maximum score of 20 cpu (cleaning performance units). This criterion is very difficult to comply with, since the reference product has a very high washing performance. UEAPME proposes to increase this limit to 30 cpu, in order to allow many other powder laundry detergents to be granted the Eco-Label.

Laundry detergents for woollen products

Foreword: laundry detergents for woollen products should not have an extreme washing performance, otherwise they damage the fibres. The current reference product is, therefore, questionable, since it has 57,5% of surfactants (the average products on the market have 15-18%) and 15% polycarboxylates (the average products on the market have 3-5%). This is probably the reason why there is only one eco-labelled product on the market. This reference product is not really suitable for "light duties" and its formula is close to laundry detergents for "heavy duties". Therefore, UEAPME makes the following proposals:

Main proposal: every EU country should be given the possibility to establish its national market leading product. This should be considered as the reference product and all the other products applying for the eco-label should compare their washing performances with it.

Secondary proposal: Modifying the washing test in order to make it cheaper and less stringent. This means modifying at least the criteria which are harder to achieve:

  • Basic degree of whiteness: according to the current criterion the difference between the product to be tested and the reference product must be higher than the value 4. This value is set to 2 in case of low priority. UEAPME proposes that these values are diminished to 2 and to 1 in case of low priority.
  • The current washing performances foresee the maximum score of 10 cpu (cleaning performance units). This criterion is very difficult to comply with, since the reference product has a very high washing performance. UEAPME proposes to increase this limit to 15-20 cpu, in order to allow many other laundry detergents for woollen products to be granted the Eco-Label.

Liquid laundry detergents

In its previous position papers on the revision of these criteria, UEAPME had already highlighted that it is easier for SMEs to manufacture liquid rather than powder laundry detergents. In this framework, UEAPME had also underlined that liquid laundry detergents can be easily found in shops in Southern Europe where they have a significant market share. Currently, liquid laundry detergents represent around 12% (with an increasing trend) of the laundry detergents market in Spain, Greece and Italy. This is an important market share which, according to UEAPME, should be able to apply for the EU flower. At the moment the procedure to be followed demands that the washing test for liquid laundry detergents has to be carried out using the same reference product for powder laundry detergents (IEC-A*). This is not possible, since no liquid laundry detergent can ever have the same cleaning performance than a powder laundry detergents. As a consequence, there is still no liquid laundry detergent with the Eco-Label and the situation will not change till the procedure stays as it is now! UEAPME's request has never received an answer so far, let aside being put on the agenda of the Ad Hoc Working Group to be discussed. Therefore, UEAPME reiterates its position as follows:

Main proposal: every EU country should be given the possibility to establish its national market leading product. This should be considered as the reference product and all the other products applying for the eco-label should compare their washing performances with it.

Secondary proposal: the reference product should not be the same as for powder laundry detergents, but it should coincide with the reference product for woollen laundry detergents (light duties). This would give us the possibility to use a product already adopted by test laboratories and, still more important, to test liquid products through liquid products. The test criteria would be the same as for woollen laundry detergents.

Brussels, 13th September 2002