Minutes on the revision of the EU Ecolabel for …susproc.jrc.ec.europa.eu/textiles/docs/1st AHWG textile...3 Session 1 – Introduction and background A brief introduction to the

EUROPEAN COMMISSION JOINT RESEARCH CENTRE Institute for Prospective Technological Studies (Seville) Sustainable Production & Consumption Unit

(Draft) Minutes of the 1st Meeting of the AHWG for the revision of the EU Ecolabel for textile products

Held on Wednesday 22nd February 2012 At the Institute for Prospective Technological Studies (IPTS) in Seville, Spain

Attendees

Raffaella Alessi ISPRA (Italian Competent Body) [email protected] Mauro Cordella JRC IPTS (Meeting chair) [email protected] Bernard Defraye CIRFS European Man-made Fibres Association [email protected] Arno Dermutz VKI (Austrian CB) [email protected] Nicholas Dodd JRC IPTS (Technical presentations) [email protected] Adil El Massi Euratex [email protected] Marianne Burum Eskeland Ecolabelling Norway [email protected] Silvia Ferratini European Commission, DG ENV [email protected] Michela Gioacchini Hugo Boss Ticino SA [email protected] Susanne Heutling German Federal Environment Agency (UBA) [email protected] Kilian Hochrein W.L.Gore & Associates [email protected] Jason Kibbey Sustainable Apparel Coalition [email protected] Renata Kaps JRC IPTS, Product Bureau [email protected] Florian Kohl Albemarle Europe representing EFRA [email protected] Jiannis Kougoulis JRC IPTS, Product Bureau [email protected] Jean-François Luthun FEDEREC textiles [email protected] Emilie Machefaux ADEME (French Competent Body) [email protected] Leena Nyqvist-Kuusola Ecolabelling Finland [email protected] Sirko Prußig CEA-PME [email protected] Philip Reynolds FIRA International Limited [email protected] Hannelore Schorpion Federal Public Service Health, Belgium [email protected] Jens Soth EEB - European Environmental Bureau [email protected] Daniela Toma Ministry of Environment, Romania [email protected] Paul Vaughan UK Ecolabel Delivery [email protected] Jakob Waidtlöw Ecolabelling Denmark [email protected] Oliver Wolf JRC IPTS, Product Bureau [email protected] Łukasz Woźniacki BEUC and EEB [email protected]

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Agenda

Arrival and coffee 09:00 – 09:30

1. Opening and welcome Introduction to the political objectives of the EU Ecolabel and of Green Public Procurement

2. Introduction and background Work programme and timeline, existing product group scope and definition

3.

Preliminary findings – presentation and discussion Legislative framework, stakeholder questionnaire feedback, results of the market and technical analysis, conclusions and recommendations on the scope and focus.

Coffee break 11:00 – 11:15

4. Textile fibre criteria area – presentation and discussion Overview of the existing criteria, the key issues proposed to be addressed by the revision and draft proposals for revisions.

Lunch break 13:15 – 14:30

5. Processes and chemical criteria area – presentation and discussion Overview of the existing criteria, the key issues proposed to be addressed by the revision and draft proposals for revisions.

Coffee break 16:00 – 16:15

6. Fitness for use criteria area – presentation and discussion Overview of the existing criteria, the key issues proposed to be addressed by the revision and draft proposals for revisions.

7. Proposals for new criteria – presentation and discussion Key issues proposed to be addressed and draft proposals for new criteria.

9. Revision of the criteria for textiles Concluding discussion and summary of the key points raised.

10. Next steps Close of meeting 18:00

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Session 1 – Introduction and background

A brief introduction to the EU Ecolabel and the revision process for textile products was

provided by JRC-IPTS European Commission. The AHWG will be the first of two meetings

designed to obtain feedback from stakeholders. The next AHWG will be held later in 2012.

Written feedback on the draft Preliminary Report and draft Technical Report and Criteria

Proposals was requested within four weeks by the 21st March 2012. The documents can be

downloaded from the JRC IPTS Product Bureau website using the following link:

http://susproc.jrc.ec.europa.eu/textiles/stakeholders.html

The stakeholder feedback obtained during the AHWG meeting will be used to develop the

criteria proposals which will be presented to the EU Ecolabel Board. The evidence base for

the criteria revision will also be used to develop, in parallel, criteria for Green Public

Procurement (GPP). JRC-IPTS European Commission then presented a brief overview of:

• the current scope, aim and structure of the Ecolabel criteria,

• the technical terms of reference for the revision,

• the current status of the Ecolabel in the market,

• initial feedback from stakeholders on the scope.

Input was then invited from stakeholders on the product scope.

Input from stakeholders

The ecolabel should apply to different parts of the supply chain and these require clearer

definition. The ecolabel should assist producers in sourcing/identifying ecolabelled fibres and

fabrics. In seeking to do this it should aim for consistency with other labels/standards e.g.

GOTS, GRS, Oeko-tex 1000.

The scope should focus on the end-use for products. Furniture fabrics should be kept within

the scope. Specialist technical fibres should be addressed – although criteria in this area may

require more detailed analysis and may be more relevant to GPP (e.g. firefighting, military).

E-textile electronic elements are best addressed by the WEEE rules as they are a separate

supply chain.

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Professional cleaning products should be addressed but clarification is needed and specific

criteria may be required – particularly for micro-fibre products. The fitness for use criteria

would also then require revising.

The scope would benefit from further definition in relation to plastic membranes and coatings

and the 90% weight threshold. Reference was made to the Nordic Swan which is proposing

to move to a lower 10% threshold. The overall threshold could be lowered to 75-80%. The

downside of this is that criteria may then be required for the other elements of the clothing or

interior textile item.

Consideration should be given to accessories such as buttons and closings that may contain

elements such as nickel that can be allergens.

The clause which allows other fibres to be considered even if there are no criteria applying to

them should be deleted.

The Ecolabel criteria will provide an evidence base that can be used to develop GPP criteria.

The interrelationship between the Ecolabel criteria and the Textile BREF and BAT were felt

to be important.

Key actions arising from Session 1

Specialist technical fibres require further definition and investigation

Cleaning products, including microfiber products, require further definition and

investigation

The weight threshold requires further consideration in relation to specific product

compositions

A better understanding is needed of the concerns raised in relation to the GOTS

standard

BREF should be a main point of reference for the revision

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Session 2a – Preliminary findings: market analysis

JRC-IPTS European Commission then presented a brief overview of the market analysis

section of the draft Preliminary Report which comprised:

1. The structure of the EU market

2. Breakdown of the market for the three main product segments

3. EU and national labelling schemes

4. Private labelling and industry initiatives

5. Stakeholder questionnaire feedback on labelling

Input was then invited from stakeholders on the market analysis, industry innovation and

implications for the approach to the revision.


The forms of fibres in products/end-uses should be addressed – for example, polycotton

blends. The balance of natural/sythetic fibres presented should be checked against the fibre

proportions in end-products on the market.

Whilst there is wide use of recycled polyester the feedstock is largely based on and reliant on

plastic bottle waste streams. A major challenge is recovery of clothing products for re-

use/recycling – this is difficult and limited at the moment. It should a key area of focus. The

question was also raised as to how fibres with a certain % content can be analysed and

verified.

Brands that introduced take-back have tended to scale them back and move towards making

use of existing national infrastructures. In some countries there exists significant textiles

recycling infrastructure. Some Member States were aware of there being limitations on the

infrastructure that was available.

In relation to labelling initiatives the ‘Cradle to cradle’ approach should be included which

focus on technical/biological cycles. It has been used/refered to by the Dutch, Swiss and

Canadian governments.

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Key actions arising from Session 2a

The end-markets for blended fibres should be further investigated and the EU market

share for cotton and synthetics should be checked. Blended fibre data for the EU was

requested from CIFRE by IPTS.

The following end of life issues should be further evaluated(see also synthetic fibres

and the new criteria proposals):

o re-use of textiles

o associated take-back infrastructure

o the sourcing and verification of recycled feedstocks

Refer to GPP policies in the Netherlands for an example of the application of Cradle to

Cradle criteria

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Session 2b – Preliminary findings: technical analysis

JRC-IPTS European Commission presented a brief overview of the technical analysis section

of the draft Preliminary Report which comprised:

1. Legislative framework

2. LCA evidence base

3. Key environmental issues highlighted by LCA studies

4. Further environmental issues proposed for consideration

5. Stakeholder questionnaire feedback on issues and coverage

6. Proposed approach to the revision

Input was then invited from stakeholders on the proposed approach to the revision and the

focus areas for environmental improvement.


An LCA has been carried out by the Swedish Government (2003) for upholstered furniture

which considered the impacts of coatings such flame retardants.

Lensing have been involved in an LCA for regenerated cellulose fibres carried out by M.Patel

(University of Utrecht)

Grenelle I legislation in France has introduced principles for assessing and communicating the

impacts of products (BPX 3323). Supporting LCA has been prepared for textiles.

Key actions arising from Session 2b

EFRA to forward Swedish LCA study looking at coatings

EEB/BEUC to provide reference for cellulose fibre LCA study

ADEME to provide English summary of Grenelle textile LCA study

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Session 3 – Textile fibre criteria area

JRC-IPTS European Commission presented a brief overview one-by-one of the proposed

revisions to the fibre criteria, with a focus on the following fibres:

1. Natural fibres – Cotton, wool and flax

2. Synthetic fibres – Common and fibre-specific criteria

3. Regenerated fibres – Cellulose fibres

Input was then invited from stakeholders on the main areas of proposed revision.

C2 Cotton and other natural cellulosic seed fibres (including kapok)

The criteria proposals presented focussed on the potential for a minimum certified organic

content, consideration of IPM/responsibly sourced cotton, consideration of recycled cotton

and additions to the existing pesticide list.


Organic cotton still accounts for a small share of the cotton market. There were significant

concerns raised about the reliability of certification routes and whether false claims are being

made for high % content by retailers. There is more supposedly ‘certified’ cotton than

‘organic’ cotton on the market and the word organic is not protected. An example was given

of a major retailer that was not able to substantiate organic claims. Cotton is not often traced

back to the farmer and there is too much reliance on self-declaration. There is not enough

information for manufacturers as to how/where to obtain certified cotton.

The EU Regulation 834/2007 and the use of transation certificates as evidence should be the

main verification route for this criterion. Some strong concerns were raised about the GOTS

system but there was also recognition by some stakeholders of its role in the market as a

major verification route. An alternative view was that labels with integrity should be

considered for harmonisation – GOTS, Good Environmental Choice (Sweden), Cotton in

Africa and Fair Trade were referred to as systems that should also be looked at.

Feedback on organic cotton availability differed widely, from difficulties as price/availability

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in the market fluctuates to relative ease of sourcing and competitive pricing. Could a high %

be sustained for 10-20% EU cotton products? The viewpoints and experiences with

availability may reflect the varying buying power of different companies. Concern was raised

that large buyers are influencing the price/availability for smaller manufacturers/retailers. A

better understanding of the market dynamics is needed to inform the revision.

Opinions varied on increasjng the minimum % content. On one hand the Nordic Swan is

proposing to reduce from 100% to 10% because it is too difficult to achieve and is not having

the desired market impact. Availability and price was seen as a key barrier. On the other hand

it was felt that a high % is required to drive the market and make the product meaningful to

consumers and examples were given - although concerns were still raised about the potential

impact on current licenses. Availability and price in this case was not seen as a significant

barrier.

The idea of a graded criterion and specifically the Better Cotton Initiative raised concerns

about the verification route as there are no specific criteria. It may be too early for this to be a

verification route. The environmental improvement potential is looking promising but BCI

has only had one harvest so there is not enough data yet. Concern was also raised that it didn’t

have specific enough criteria and doesn’t exclude GM cotton. Organic cotton was felt to be

the only route that ensures this. More market intelligence is needed as to the current BCI

market share.

The pesticide list should be reviewed for its relevance to substances used/restricted not just in

Europe but internationally. Specific additional pesticides should be added – aldacarb and

xxxx. Advice provided by the International Cotton Advisory Committee should be refered to.

The criterion currently verify the raw fibre. It was noted that very limited pesticide residue

remains on the fibre – it is application to the crop as a whole that is the more important

consideration.

Regarding water use it was stated that organic production results in better soil water retention,

so to some extent it does address water use. Not all cotton growing areas reliant on high

levels of irrigation. Approximately 50% are rain irrigated. More specific criteria are

required.

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C5 Greasy wool and other keratin fibres (including wool from sheep, camel, alpaca,

goat)

The criteria proposals presented focussed on revisions to the testing routines, parasiticide list,

wastewater treatment limit values and organic/chlorine-free wool verification.


It was agreed that there is a challenge for Australian and New Zealand producers to meet the

current criteria. However, there was disagreement in relation to the nature of the technical

barrier. Producers would need to make substantial investment to install on site treatment

works to meet the proposed threshold of 20g. Consideration is also needed in relation to the

different types/grades of wool that are sourced/required by producers.

In relation to organic wool there appear to be many different definitions of what ‘organic’

means so this would require clarification. A view was expressed that the Ecolabel should not

move to a minimum requirement. Feedback is required from license holders and

manufacturers – particularly the wool producer associations.

C4 Flax and other bast fibres (including hemp, jute and ramie)

The presentation sought input from stakeholders on energy use during the retting and pre-

treatment stage for flax fibres.


New technologies do exist that can reduce energy use associated with fibre retting/pre-

treatment. However, comparative benchmark data does not appear to exist and the LCA used

may not be representative of performance across the industry. An LCA report by Master of

Linen (France) may provide more specific information for this fibre.

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C/1/3/7/8/9 Synthetic fibres

The proposed revisions presented focussed on the potential to introduce criteria common to all

synthetic fibres comprising a benchmark for process energy use and/or minimum recycled

content. Technical revisions to fibre-specific criteria were also presented for discussion.


The initial proposition of an energy benchmark is challenging as more scoping would be

needed of energy use or CO2 emissions values and these may vary within each fibre criteria.

The allocation of emissions or energy use to different process stages would need to be

clarified for this to be workable. There are too many possible variations to establish

meaningful benchmarks and the performance range/distribution by industry would be needed

to set a benchmark. It was felt that it would be better to work with existing certifying and

accounting schemes. Another approach would be to require the fibre producer to be certified

to ISO 50001 on energy management.

The technical requirements for different yarns will influence both the energy used for

manufacturing and the recycled content that can be achieved. A high recycled content will

have implications for the strength and dye fastness of the fibre – particularly for micro-fibres.

The question was asked as to whether microfibres can be manufactured with a recycled

content.

A requirement for recycled content needs to be weighed against durability and functionality

from a lifecycle perspective. Performance across all LCA midpoints should also be

considered rather than just energy use or GWP.

Some views were expressed against having a recycled content requirement. This is because

chemical constituents would be kept in circulation as a result. The ‘cradle to cradle’ approach

would, however, be favoured.

Specifically for polyester concern was raised in relation to the source of post-consumer waste

for the fibres. This is understood to be largely based on plastic bottles and the demand

for/availability of this feedstock. More information/analysis is needed to determined whether

this can be sustained. The balance of environmental benefits between the performance of

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mechanical and chemical recycling requires clarification and definition. An LCA study by

the University of Utrecht should be considered.

It is understood that there has been industry work on recycling nylon. The problem is

recovering the clothing. There was an awareness of two projects working on nylon 6

recycling but these are a small market share. Further input is needed from CIFRE and Plastics

Europe.

The option to promote the re-use of textiles was raised. For example, France has a high

percentage of textiles being collected by their national systems. However, a proportion is

thermally recycled – i.e. incinerated. For some synthetic fibres such as polypropylene there

was an opinion that this may be the best option.

Technical points relating to specific fibres were discussed:

C1 Polyamide – More evidence was required for harmonisation with the Blue Angel

on N2O emissions. It would be better to link this criteria to BREF.

C3 Elastane – Aromatic di-isocyanates are reactive chemicals and therefore the

occupational exposure level should be considered.

C7 Polyamide – The proposed emissions limits for nylon 6,6 may be difficult to

achieve. Stakeholders will follow-up on this with more technical evidence.

C8 Polyester – The scope of the existing VOC limit value was expanded in 2009 to

include spinning so effectively the resin ELV was reduced.

C9 Polypropylene – check with stakeholders

There was an opinion expressed that the original reasoning behind the criteria – and therefore

why they should be kept/updated – was missing from the report. BREF should be used as the

main reference point.

C6 Man-made cellulose fibres (including viscose, lyocell, acetate, cupro and triacetate)

The proposed revisions presented focussed on the potential to shift the focus towards low

AOX pulp production and the sustainable sourcing of feedstock. Process energy and finishing

detergents were raised as issues for further investigation.

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In general the move from a focus on fibre performance to pulp production was supported but

there were concerns relating to how this would be managed by Competent Bodies. The

specific grade of pulp used to manufacture cellulose fibres requires further consideration.

Certified pulp of the required grade was understood to be more difficult to obtain.

For production in China there are currently barriers to timber certification. It was understood

that bamboo plantations can be certified FSC. The potential for organic certification for

plantations should also be considered as a route to achieving environmental improvement.

It was suggested that the poorer performance of non-EU production plant may be less related

to processes or electricity grid mix but more closely related to local regulatory conditions.

Feedback had been received from a major manufacturer via a Competent Body that an

achieveable level of certified timber content could be 25%. They also provided feedback that

the AOX limit value would be difficult to achieve. Chlorine gas-free processes can be

achieved.

A view was expressed that these forms of fibres are not highly energy intensive to produce

and therefore the process energy benchmark may not be a critical issue. Detergents was left

as an open issue


Cotton fibres

o Ensure Regulation 834/2007 is fully addressed, including non-EU control

systems, and review issues relating to other emerging labels e.g. GOTS

o Written responses outlining concerns relating to GOTS are invited from

stakeholders by IPTS

o Obtain more details market data on conventional and organic cotton, including

EU market penetration, certification routes and sourcing issues

o Explore further underlying criteria for alternative improvement schemes

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o Further data and evidence to be provided by stakeholders on organic cotton

soil water retention

o Stakeholders to confirm proposed additions to pesticide list

o Review suggested improvements to the pesticide list and determine the level of

environmental improvement it provides

Wool fibres

o Investigate the specific operational and regulatory conditions that apply to

wool scouring in Australia and New Zealand

o Euratex to provide wool producer association contacts

o Obtain industry feedback on organic certification options

Flax fibres

o Review comparative LCA study - Relevant references to be confirmed by

EEC/BEUC

Synthetic fibres

o Follow-up data collection and discussion with industry representatives in

relation to process energy use – stakeholders to provide feedback

o Review ISO 50001 and the associated environmental improvement potential

o Follow-up data collection and discussion with industry representatives in

relation to the technical potential for fibre recycled content

o IPTS to email details of fibres with recycled content to CIFRE for

review/comment

o Further use of BREF to check/revise the fibre-specific technical revisions

o Consult with the Blue Angel/UBA on polyamide proposals

o CIFRE to provide technical opinion on fibre-specific proposals

Regenerated cellulose fibres

o The market availability of the specific grade of pulp used is to be further

investigated

o Consult with leading fibre manufacturers with regards to certified pulp

availability, process energy use and AOX limit values

o Finishing agents remain an open issue for further investigation

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Session 4 – Processes & Chemicals criteria area

New C10 Hazardous substances and mixtures

The proposed revisions presented focussed on the need for a new criteria which implements

Articles 6 and 7 of the Ecolabel Regulation. The draft wording of the criteria was outlined,

including a listing of risk phrases/hazard statements. Potential approaches to tailoring of the

criteria to make it implementable were also outlined for discussion and the need for

derogation requests to be submitted was highlighted.


The criteria focuses on the end product so it should not be used to replace other chemical

criteria. This is because their focus is on avoiding the use of certain substances in production

processes. However any of the chemicals used in upstream processes could be in the final

product.

This approach has been put into practice with the Blue Angel label and has already led to four

derogations. The Blue Angel approach was to define substance groups and the approach is

based on what is possible now. The limits of technical knowledge about chemical

transformations that occur have been a problem. Impurities could also be an issue downstream

in the product. There is a real difficulty managing this type of criteria, particularly in relation

to Material Safety Data Sheets.

Significant concerns were raised in relation to Material Safety Data Sheets as a means of

verifying compliance with this criteria. They can often be incomplete and inaccurate –

particularly for non-EU suppliers. The 0.1% threshold does not relate to the hazard or level of

risk, it is an arbitary cut off point for labelling. It was felt that few companies would be a

position to make requests for derogations.

Leading companies within the industry are committed to ‘green chemistry’ but this is a long-

term project and cannot be achieved now. Reference needs to be made to industry initiatives

and best practice in this area – for example:

• restricted substance lists (RSL’s) with reference to Article 57/59,

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• industry roadmaps (an example was given which has 11 priority groups of chemicals),

• the work of organisations such as AFIRM

• process management systems such as Bluesign.

The ecolabel should work with the industry best practice and not create a parallel process to

REACH. The Candidate list is a good starting point. Validated testing is required which

should be ‘court proof’.

The state of the supply chain makes this potentially very difficult to operate. It can be very

difficult for suppliers to comply with RSL’s so they should be easily understandable. What is

really needed overall because of the disjointed and international nature of the textile supply

chain is better supply chain management and information flows. Systems such as Bluesign

could also be relevant as they focus on process optimisation.

The establishment of a horizontal task force for this criteria was highlighted as a forum in

which practical approaches to implementation will be developed. This could be a significant

resourcing issue for Competent Bodies and for manufacturers.

C11 Biocidal and biostatic products

The proposed revisions presented focussed on the exclusion on a precautionary basis of the

biocide nanosilver.


The discussion focussed on nanosilver. There were differences of opinion between member

states on whether to exclude the substance based on the balance of current scientific evidence.

The risk posed needs to be evaluated based on evidence – is there greater risk due to the

distinct form of silver?

Nanosilver was understood to already carry a H Statements/R Phrases 50-53 and so would

require derogation. It was stated it that nanosilver does currently meets the requirements for

classification but it was not clear whether it can be classified.

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Clarification was requested as to the typical weight / proportion of nanosilver added to

products. There may be specific applications in which biocide applications are important

requirements – particularly in public procurement e.g. military, health services. Some

member states do not see any reasons to add such products and have also banned nanosilver in

public procurement.

The regulatory context created by the new Biocidal Products Regulation (which comes into

force in 2013) and how this will relate to REACH should be considered.

C16 Bleaching agents

The proposed revisions presented focussed on the deletion of an exclusion for regenerated

cellulose fibres.


Further investigation was requested in relation to making the criteria stricter for regenerated

cellulose fibres.

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Dye relate criteria

The proposed revisions presented focussed on bringing together four existing dye-related

criteria supported by a listing of excluded dyes to be provided in the appendix. A restriction

on the use of metal complex dyes to specific fibres – wool and polyadmide – was also

outlined.


C17,21-23 Dye relate criteria

The issue of energy use and efficiency may need to be considered from the point of view of

different dyeing processes – as covered by BREF.

C20 Metal complex dyes

The appearance of silk in the text was highlighted – this could be deleted along with the text

in the pre-amble which permits other fibres. However, some member states highlighted the

possible relevance of wool/silk blends.

C27 Wastewater treatment for discharges from wet processing

The proposed revisions presented focussed on the potential to use BREF to make the current

wastewater criteria more applicable to different processes.


There was some concern as to whether a single COD figure works. There was some positive

feedback for the proposed BREF-derived approach.

C29/30 Finishing and C25 Printing

The relevance of process energy use and the potential to make improvements was raised as a

potential area of focus for the revision.


There was limited discussion of these criteria.

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C26 Formaldehyde

The proposed revisions presented focussed on different options in relation to formaldehyde

limit values.


It was clarified that this substance is used to reduce the need for ironing. It therefore can

advantages in the use phase.

The criteria should distinguish between different applications i.e. clothing and furniture.

Some GPP derogations are likely to be requested for specific applications.

A general view was expressed that the existing values should be retained. This was also the

view that the Blue Angel had reached. The test methods should be reviewed as they may not

take into account the effect of hydrolysis once in use.

C28 Flame retardants

The proposed approach to the revision was outlined including the exclusion of substances

according to Articles 6 & 7, review of the definition of reactive and additive retardants and

the need to consider the main requirements/applications of flame retardant substances.


There was general support for the proposed direction and approach. The differentiation

between reactive and additive retardants should be re-evaluated. Brominated retardants

should not be differentiated and retardants in general should be addressed by the criteria on

hazardous substrances. The concerns raised by some member states with stricter fire

regulations should be taken into account.

Few of the retardants listed in the report are used in textiles. Flame retardants used for PPE

and furniture may use decaBDE. Some fibres have inherent flame retardant properties such as

modacrylic.

A derogation will be required for antimony trioxide which is used as a synergist in

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combination with a number of flame retardants. Other flame retardant substances that may be

required should be looked at substance by substance. Thresholds could the be set in line with

the hazardous substances criteria

The permanency of flame retardant treatments should be considered within the criteria. The

incorporation of the function should be as permanent as possible.

A view was expressed in favour of banning all halogenated flame retardants and in the case of

one Member State all flame retardant substances. It was stated that alternatives already exist

which can be used to meet Member State’s fire safety requirements. The Blue Angel

excludes all flame retardants.


Hazardous substances and mixtures

o Investigate industry current best practice – e.g. RSL, Zero Discharge

Roadmap, AFIRM, Bluesign

o Identify potential sources of product testing data in order to further prioritise

process elimination

Dyes

o Review dye process improvement potential with reference to BREF

Wastewater treatment

o Review how/whether BREF could be used to differentiate between processes

Biocides

o Norwegian CP to forward biocide technical study

o Further evaluation of scientific evidence and regulatory position in relation

nanosilver with reference to the Commissions approach on product groups

Formaldehyde

o Investigate use phase advantages, the validity of test methods to the

environment in which products are used and the availability of suitable

substitutes

Flame retardants

o Investigate specific textile applications, the flame retardant substances

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commonly used and identify whether they are labelled

o Further technical evidence to be provided by EEB/BEUC

o Follow-up the likely derogation request for Antimony Trioxide with EFRA

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Session 5 – Fitness for use criteria area

The proposed revisions presented focussed on two specific criteria – dimensional change

tolerances and the derogation of baby clothing from the colour fastness to light criteria.


A general comment was made that this criteria area should take a broader approach to

durability as this is of high importance in all LCA results. There are recognised testing

standards which could be specified to determine the durability of textile products e.g. based

on a set number of laundry cycles.

C34 Dimensional changes

It should be clarified whether the criteria covers bathing cloths.

C39 Colour fastness to light

There is trade-off between this criteria and reduction in the use of bleaches during production.

There was concern about the proposal to derogate baby clothing as colours should not run.


The full range of durability standards and testing methods, and evidence of the

associated improvement potential, should be further investigated with industry input

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Session 6 – Proposed new criteria areas

Corporate Social Responsibility (CSR)

A proposed new set of criteria intended to address environmental and social issues in the

supply chain were presented. One environmental criteria would address energy, waste and

water management, with the proposed aim of replacing/strengthening existing Criteria 33.

Three social criteria would address human rights, labour rights and occupational health and

safety. Examples of third party certification routes were presented.


The criteria as presented may be too comprehensive and therefore difficult to verify.

Competent Bodies will need to be able to verify and often they prefer to try and carry out site

visits. The cost and the effort for small companies, which make up the majority of the textile

supply chain, would be too great – particularly if management systems such as ISO14001 are

required. The definition of manufacturing sites requires clarification.

The Nordic Swan currently has criteria which may be a useful reference point. They are

based on ILO conventions. Companies can either sign up to an existing code and/or must

publish a report on their homepage. SA8000 should be considered.

A concern regarding this criteria is that it can raise public expectations, which could the be

dangerous for the ecolabel. In the Blue Angel there is the potential for bad practices to be

reported, with scope following investigation to then revoke a license - a kind of ‘safety net’.

The criteria should not mix too many different systems and codes of conduct. It should not

say which programme is good and which isn’t. More information is needed on what is

possible/practical and what is not.

It is important to recognise that CSR relates to organisations and not products. The approach

should be inclusive and there is the need for an approach based on codes of conduct – which

should represent the minimum commitment prescribed. There is, however, also a danger that

other schemes may be competitors e.g. Oeko-tex.

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Animal welfare should be addressed in relation to wool. Sheep mulesing is an issue receiving

increasing attention. Feathers taken from live birds was also raised.

CSR is shortly to be addressed as a horizontal issue by a separate Task Force of the Ecolabel

Board. A number of stakeholders requested whether they could participate in Task Forces.

ED1 Design for durability

A proposed new criteria intended to further improve the durability of products was presented.

The criteria would focus on specific design features and aftercare services.


This was considered to be an important issue. The outdoor industry was given as an example

of best practice. Functional feedback is obtained from the field. Product guarantees relating

to functional integrity are provided for some products. Testing procedures are used to assess

the durability of products.

The focus for the criteria requires clarification – could it be applied to all products? It may be

more relevant to extending the life of garments.

ED2 Design for recycling

A proposed new criteria intended to support recycling/re-use at the design and post-consumer

phases was presented. The criteria would focus on specific design considerations and take-

back options.


It was felt that this criterion should be combined with ED1. The range of possible products

within the product group make it challenging to have a single criteria though.

The economics of options for specific fibres should be considered further alongside the

availability of existing infrastructure/take-back schemes for collection – there are some fibres

that are not economically feasible to recycle. This is a better option than promoting product-

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specific closed loops as the logistics are more costly. UK retailer Marks & Spencers was

cited as an example – they incentivise consumers to take old clothes to charity stores. It was

commented, however, that the market may not yet ready as some countries do not have

collection infrastructure.

A greater emphasis should be placed on re-use and extending the life of products. Reference

was made to a study on textile re-use carried out for the JRC. The important issue is to ensure

that garments enter a collection system. Experience from France, which has an extensive take-

back infrastructure, is that some products such as blends do create problems for separation, re-

use and recycling.

CL1 Energy saving advice

A proposed new criteria intended to improve environmental performance during the use phase

was presented. The criteria would focus on the use of packaging and care labelling to provide

consumers with advice.


This would be aimed at the consumer during the use phase. It was noted that habits may vary

by country (e.g. more line drying in south of Europe so it may therefore be better to wash at

higher temperature?) and some products have care labels which apply across the EU. Finland

was given as an example.

How would the advice be different from a ‘normal’ product. There may be specific guidance

at an EU or Member State level that could be referred to. We should be careful to ensure that

any amendments to the guidance ensure that a garment is still cleaned adequately and does not

deteriorate in quality.

Distinguishment should be made between domestic and industrial/professional laundry

conditions. The latter use less energy and chemicals.

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CL2 Avoidance of air freight

A proposed new criteria intended to highlight the environmental impacts of air transport was

presented. The criteria would focus on the labelling of products.


A clarification was requested with regard to the LCA data used to justify the criterion – is it

based on improvements across all the midpoints rather than just CO2? Shipping performs

better on CO2 emissions but no on other emissions such as sulphur due to use of bunker fuel.

This may not always be realistic because of the lead-times within the industry. Air freight

may therefore be needed to avoid having stock remaining.

This could be retained as a CSR reporting issue rather than as a specific criterion with a

labelling requirement.


CSR

o Simplified minimum criteria / committments should be identified and then

used to compare existing schemes/initiatives

o A mechanism for revoking a license based on reported risks/violations should

be identified

o The Horizontal Task Force should be a reference point for criteria development

o The potential to address the specific animal welfare issues highlighted should

be further investigated

Design for durability

o A wider range of recognised standards for textile durability should be

investigated

o The scope of the criteria should be further determined based on the potential

for measures to be implemented

Design for recycling

o The availability of take-back infrastructure at Member State level should be

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investigated

o Further details of the French textile take-back system to be provided by

FEDEREC and other stakeholders

o A study carried out by Oakdene Hollins for JRC which looked at re-use should

be reviewed

Energy saving advice

o EU and Member State care labelling systems should be further investigated

o A literature review of research on EU consumer clothes washing habits is

required

o Cross reference this criteria with Danish Standard’s work on the Ecolabel for

professional laundry detergents

Avoidance of air freight

o Check LCA midpoint comparison with shipping

o Review models for CSR reporting

Minutes on the revision of the EU Ecolabel for …susproc.jrc.ec.europa.eu/textiles/docs/1st AHWG textile...3 Session 1 – Introduction and background A brief introduction to the

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