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

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

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

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

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.’

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

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

+ 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

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

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

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

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?

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?

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?

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?

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?

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

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?

Thank you for your attention Nicholas Dodd Tel. +34 954 48 84 86  e-mail nicholas.dodd@ec.europa.eu Contact -