1. Revision of the EU Ecolabel criteria for the product group of soaps, shampoos and hair conditioners (Rinse-off cosmetic products)
JRC- IPTS
November 2012

2. Project timeline and deliverables for criteria development
Project start
1st consultation
Market analysis
Technical analysis
Working Document (incl. criteria)
1ST AHWG Meeting
– 20th February 2012
Stakeholders feedback
Further
consultation
Background Report
& Criteria Proposal
2nd AHWG Meeting
– 28th September 2012
Work in progress towards 2nd draft proposal
Further stakeholder consultation
Stakeholders feedback
Criteria proposal for
ISC and RC
EUEB meeting
EUEB
vote
NOW

3. Product scope and definition
For future development as a separate product group:
EU Ecolabel criteria for leave-on cosmetic products or all cosmetic product?
Product scope and definition
The product group “Rinse-off cosmetic products” shall comprise soaps, shampoos, hair conditioners and pre-shaving preparations products,
i.e. "any rinse-off products intended to be placed in contact with the epidermis and the hair system with a view exclusively or mainly to cleaning them. That product group shall also comprise any rinse-off products intended to be placed in contact with the hair system with a view to improve the condition of the hair (hair conditioners) and any rinse-off products intended to be placed in contact with the epidermis with a view to protect it and to lubricate the hair before shaving (pre-shaving formulations)".
Question
Shall the following extension be made:
"Shampoos for animals are eligible for EU Ecolabel"
Split views among stakeholders

4. Draft criteria proposal
Life Cycle Phase
Environmental area
Criterion
(as numbered in the proposal)
Production
Safety of the
Product, more sustainable production
Criterion 3 – Excluded or limited substances and mixtures
Criterion 5 – Sustainable sourcing of palm oil
Use
Performance
Criterion 6 – Fitness for use
Criterion 7 – User information
End of life
Limiting use of substances harmful for the
aquatic environment
Criterion 1 – Critical Dilution Volume
Criterion 2 – Biodegradability
Limitation of packaging
waste
Criterion 4 – Packaging requirements

5. Update and discussion points
1. Criterion - Critical Dilution Volume
2. Criterion - Biodegradability
3. Criterion - Excluded/limited substances and mixtures
4. Criterion – Packaging
5. Criterion - Sustainable sourcing of palm oil
6. Criterion - Fitness for use
7. Criterion – Information appearing on the Ecolabel
Update
Question
Questions
Question
Update - clarification
Update
Update - clarification

6. Criteria
Criterion 1 – Toxicity to aquatic organisms: Critical Dilution Volume (CDV)
Update
Action
Further analysis of threshold values as follow up from feedback received after 2nd AHWG.
Limits for new products e.g. pre-shaving preparations.
Criterion 2 –Biodegradability
Update
Action
Further analysis of threshold values as follow up from feedback received after 2nd AHWG.
Limits for new products e.g. pre-shaving preparations.
Question
Anaerobic biodegradability of all surfactants:
Shall all surfactants (anionic, cationic, non-ionic and amphoteric) be biodegradable under anaerobic conditions?

7. Criteria Criterion 3 – Excluded and limited substances and mixtures
Update
Action
Proposal in general remains. Relevant point:
Further analysis of restrictions on sensitizing fragrances,
Derogation request for surfactants. Regarded as open issue relevant for other similar product groups as due to 2ATP to CLP “workhorse” surfactants are expected to be classified.
Question
1. Sub-criterion 3a. Should the following substances:
- nanosilver
- isothiazolinones
- EDTA
be explicitly excluded?
2. Sub-criterion 3e and 3f regarding bio-concentration limits:
Should the values of logPow and bioconcentraition factor BCF remain as proposed or should be less strict and aligned with CLP Regulation (logPow <4 and BCF < 500).

8. Criteria Criterion 4 - Packaging
Update
Action
Proposal for new packaging formula (Packaging Impact Ratio, PIR) remains. Relevant point: Further specification of limit value for PIR.
Industry stakeholders raised concerns regarding exclusion of hydrocarbon propellants in pre-shaving preparations (for aerosol dispensers there is niche/very low market share of products without hydrocarbon propellants).
Question
1. Should in criterion 3a hydrocarbon propellants be banned from Ecolabel?
2. Could you please provide us indicative information on the market share of pre-shaving products without hydrocarbon propellants?

9. Criteria Criterion 5 - Sustainable sourcing of palm oil
Update
Action
Few comments received. Many stakeholders accepted the proposal.
Proposal is limited to sustainable sourcing of palm oil. Sourcing of other ingredients is desired; though this is not possible though due to limited knowledge and certification schemes.
Question
Should the criterion proposal remain and requirements on sustainable sourcing of palm oil be addressed in this Ecolabel criteria revision?
Criterion 6 – fitness for use
Update
Action
Several comments received on testing for fitness for use requirements.
Analysis and integration of feedback received is ongoing and will be reflected in revised proposal.

10. Thank you very much for your attention
Criteria
Criterion 7 - Criterion – information appearing on the Ecolabel
Update
Suggestions
Regarding sub-criterion 7a. Proposal is as follows:
“To minimize the environmental impacts of this product apply proper dosage of the product and rationally consume water, in particular hot water”.
Should this information be placed next to the label or be less prescriptive and allow applicant to decide where this information should be given (e.g. product label, website).
Please provide us with your views.
Thank you very much for your attention