1. Ecolabel Horizontal Task Force on Chemicals
Findings and proposed approach
12th March 2014, Brussels
Joint Research Centre, Institute for Prospective Technological Studies

2. Overview of presentation
Main findings: Approach paper
Update on HTF members participation
Overview of the proposed approach
Major changes since November 2013 version
Supplementary findings
Actions
Recommendations
Open issues 2 2

3. Progression of the proposal (1)
Active participation: Austria, CEFIC, Denmark, DG ENV, EEB/BEUC,
Eurometaux, Germany, UK
JRC-IPTS paper, Feb 2012
First HTF meeting, Mar 2012
Approach paper, Oct 2012 (proposal v1)
Second HTF meeting, Nov 2012
Approach paper, Feb 2013 (proposal v2)
EUEB meeting, March 2013
Approach paper, Oct 2013 (proposal v3)
EUEB meeting, Nov 2013

4. Progression of the proposal (2)
Final draft for discussion, Jan 2014
Third HTF meeting, Jan 2014
Approach paper, Feb 2014 (final version)
EUEB meeting, March 2013
Actions, Recommendations and Open issues

5. Article 6(6) and 6(7) The overall approach
Extracts from the summary:
‘[Articles 6(6) and 6(7)] have the objective of avoiding the
presence of inherent hazards in the ecolabelled products.’
‘The overall approach proposed retains its basis in the avoidance
of hazards, but where substitutes are not yet available risk and
exposure shall be considered in order to protect consumers.’

6. Article 6(6) and 6(7) The overall approach
Scientific principles based on, as far as possible, consensus
points from comments and discussions.
Mixtures, articles, complex articles
Group substances by function
Reflect substitution potential
Precautionary approach
Prioritise hazard classes
Set concentration limits
Transparent derogations
Trace hazards along life cycle
Complemented by verification to provide assurance to consumers

7. The approach itself Structure of the six tasks
Aim: Headline aims, objectives and scope of the task
Sub-tasks
Activities to be carried out by criteria developer
Indicative timescale
Decision-making basis for the task
Reference point for criteria developer
Underlying ‘methodology’ they can follow
Annex
1. Hazard differentiation
2. Substitution and Derogation information

8. + Six step approach to criteria development Task 1
Product definition and bill of components, materials and substances
Task 2
Screening for restricted substances and hazard classifications
Task 5
Specification of the criteria and derogation conditions +
Task 6
Specification of assessment and verification requirements
Task 3
Product hazard substitution and green chemistry & engineering initiatives
Task 4
Screening and investigation of derogation requests

9. Evidence base and criteria development + +
Development of evidence base
Preliminary scoping
Questionnaires and early interaction with stakeholders
Development of criteria proposals
Ad Hoc Working Group (AHWG) 1
Scrutiny of initial technical evaluation and criteria proposals
Optional: Sub-group
Steer approach, provide substitution information, scrutiny of derogatons
Substitution evidence
Technical evidence to define the ambition level of the criteria
Ad Hoc Working Group (AHWG) 2
Scrutiny of revised criteria proposals following stakeholder technical input + +
Derogation requests
Screening for hazards, functional need, performance and substitute availability
EU Ecolabelling Board
Scrutiny of revised criteria proposals in parallel with AHWG1 and 2

10. Finalising the proposal Key open issues discussed by HTF
How to address different types of products?
Agreement on modular approach proposed by JRC-IPTS
Cut-offs: Articles 0.1%, Mixtures 0.01%, SVHC 0.1% (0.01%)
Allow use of ingoing mixture classifications instead of ingredient?
Ingredients to be screened
Treat allergens as priority hazards?
Treat as priority unless SVHC or exposure not relevant
What happens if derogations become obsolete?
See recommendation 2.1
Are consumer preferences essential functions?
General view was no, difficult to evidence look at technical basis first

11. A modular approach to products (1)
Product screening
A modular approach to products (1)
3.1 Product definition and inventory
Aim: To build-up a profile of the material and chemical composition of the product and associated articles, accessories, parts and consumables.
Inclusion of secondary materials such as packaging, consumables and accessories
Grading of inventory according to ability to obtain information from suppliers
Inclusion of residual substances and contaminants in the inventory
Identification of product articles that are in direct contact with the consumer

12. A modular approach to products (2)
Product screening
A modular approach to products (2)
Aim: Allow for adaptation of the approach based on the distinct composition of the product
Identify which components or ingredients are relevant to the product, depending on whether it is a chemical mixture of an article
Carry out a screening according to the proposed modular rules and scope
Where required apply to horizontal screening to a mixture of an article: -
Process residues and contaminants
Chemical additives, coatings and treatments
Main question: What is included in the inventory and on which concentration level?

13. A modular approach to products (3)
Product screening
A modular approach to products (3)
Aim: Provide a product screening guide to support the modular approach for components and ingredients
Chemical mixtures
Chemical ingredients
Organic and mineral ingredients
Final product mixture
Articles and their component parts
Homogenous material components/parts
Complex component devices
Connectors, fixtures and adhesives
Consumables
Horizontal screening
Process residues and
contaminants
Chemical additives,
coatings and treatments
Main question: What is included in the inventory and on which concentration level?

14. Rules for differentiated treatment
Hazard listing
Rules for differentiated treatment
Aim: Recognise that hazards are categorised according to their degree of hazardousness and use this as basis for differentiation
Group 1 Hazards subject to complete restriction
Article 57 and Candidate List (SVHC) substances, CMR Cat. 1B and 1B, ELC substances
Combinations with vP + T or vB + T (T=Acute Tox Cat.1/2)
Group 2 Priority hazards for restriction
CMR Cat.2, Acute Tox Cat.1/2, STOT Cat.1, Aquatic Cat.1/2, Allergens Cat.1
Group 3 Hazards to which greater flexibility shall be applied
Aquatic Cat.3/4, Acute Tox Cat.3, STOT Cat.2
Main question: What is included in the inventory and on which concentration level?

15. Rules for differentiated treatment
Enabling better read across to US EPA/Green Screen
Main question: What is included in the inventory and on which concentration level?

16. Findings going forward 1. Actions to be undertaken
1.1 Modification of standard legal text
JRC-IPTS and DG ENV
1.2 Implementation of proposed approach
To be reviewed on the basis of feedback from revisions
Main question: What is included in the inventory and on which concentration level?

17. Findings going forward 2. Recommendations of the HTF
2.1 Reviewing validity of derogations
Revisit only if there is an identified need or prolongation
2.2 Endocrine disruptors
An interim and precautionary position to be developed
Main question: What is included in the inventory and on which concentration level?
2.3 Nanomaterials
Contact DG ENTR and ECHA regarding current process

18. Findings going forward 3. Open issues for discussion and investigation
3.1 Dynamic verification of the Candidate List
Should applicants demonstrate ongoing compliance?
3.2 Changes to CLP classifications reflecting ATP’s
Derogations may require reviewing during validity period
Main question: What is included in the inventory and on which concentration level?
3.3 Establishment of further White Lists
Should they be developed, if so how to be maintained?
3.4 Use of hazard screening tools
e.g. US Green Screen, but benchmarks and verification?

19. Thank you for your attention
Nicholas Dodd
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