1. Joint Research Centre Institute for Prospective Technological Studies
The European Commission’s in-house science service

2. EU Ecolabel criteria revision for Furniture
5th November 2014, Brussels
Images courtesy of photostock, David Castillo Dominici, John Casawa, Arvind Balaraman, Keerati, Renjith Krishnan and stockimages at FreeDigitalPhotos.net and Duba B8.

3. Timeline Event Date 1st AHWG meeting: Seville – 7 Oct. 2013
Feedback from stakeholders by – 30 Nov. 2013
EUEB update: Brussels – Mar. 2014
2nd AHWG meeting: Brussels May 2014
Feedback from stakeholders by Jul. 2014
EUEB update: Brussels Nov. 2014
Feedback from stakeholders by Nov. 2014
Inter-service consultation & voting………… first half 2015.
We are currently at the stage highlighted in red. It is obvious that we are near the end of the process and so it is EXTREMELY important that any major issues are brought up today that could affect positive votes from Competent Body representatives.

4. Product Scope
The product group “furniture” shall comprise free-standing or built-in units, whose primary function is to be used for the storage, placement or hanging of items and/or to provide surfaces where users can rest, sit, eat, study or work, whether for indoor or outdoor use. The scope extends to domestic furniture and contract furniture items used in domestic or non- domestic environments. Bed frames, legs, bases and headboards are included in the scope but not bed mattresses, which are covered by the criteria established by Decision 2014/391/EU.
The product group shall not comprise the following products:
Products whose primary function is not to be used as furniture. Examples….
Second-hand, refinished, refurbished or remanufactured furniture products.
(c) Furniture fitted into vehicles used for public or private transit.
Compared to the pervious version in TR 2.0, the product scope has been almost completely reworded. The main changes are:
The inclusion of the term contract furniture, which is a widely used term for furniture purchased by businesses
Clarification that, while the scope extends to beds, it does not specifically extend to bed mattresses themselves
The removal of the general exemption text to all fixtures and fittings and wood-based, plastic and metals that account for <3% of the product weight.
The inclusion of text that explicitly excludes 2nd hand and refurbished furniture, due to difficulties with verification, and the exclusion of vehicle furniture, which may generally have to comply with very different standards compared to household and other contract furniture.

5. Definitions
In Article 2 of the Act, definitions for the following terms have been provided:
Leather
Volatile Organic Compounds
Semi Volatile Organic Compounds
Recycled materials / wood
Wood based panels
Eliminable substance
Inherently biodegradable substance
Readily biodegradable substance
Finishing treatments
Paint
Varnish
Biocidal product
Wood preservative E1
Prolonged skin contact
Coated fabrics
Textiles
Upholstery
Non-bioaccumulative
The following terms related to furniture criteria have been defined in Article 2 of the draft Act. If anyone has any doubts or proposed changes to these definitions we can open the document and look at the specific wording now. Otherwise any relevant comments should be uploaded to BATIS prior to the 30 November.

6. Criteria structure Criteria Status Product description1.
Product description
Unchanged 2.
Hazardous substances
Major revision 3.
Wood and wood-based materials 4.
Plastics
Significant revision 5.
Metals 6.
Upholstery (covering materials)
Major revision, groups together previous criteria for leather and textiles and includes new criteria for coated fabrics. 7.
Upholstery (padding materials)
Minor revision 8.
Glass 9.
Final product requirements
10.
Packaging
Proposed to remove
11.
Information on the ecolabel
No significant change has been made to the first criteria regarding product description.
It can be seen that major changes have been made to the criteria for:
Hazardous substances
Wood and wood based materials
Upholstery (at least in terms of covering materials) and glass.
Significant changes have also been made to criteria for plastics, metals and final product requirements.
The aim of today's presentation is to communicate these significant and major changes and gather any initial feedback today, especially from competent bodies regarding any issues that may affect voting on the criteria.

7. Haz. substances Major restructuring, i.e… re
Text aligned with Decision on Bed Mattresses
Logical approach considering bed manufacturers
Recently voted
But: newly drafted wording in other products for verification (do we copy this or stick with alignment with BM?). Feedback on this later please.
Look at criteria 2.1 and 2.2….(p.3 of Annex)
reworded
a) SVHC (Table of H phrases)
b) Derogations (11 entries)
c) Dyes and pigments
d) Biocides
e) Flame retardants
f) Plasticisers
g) Other
2.1. Derogations (24 entries)
2.2. SVHC (Table of H phrases)
Only mentioned as material specific sub-criteria where relevant in later criteria for particular materials.
The general text on hazardous substances related to articles 6(6) and 6(7) have be reworded to align with the bed mattress decision. This is logical if you think about how the Ecolabel application process appears from the point of view of a bed manufacturer. Plus this criteria has been recently voted.
However, it is worth noting that a new verification text has been prepared by our colleague Nick, in conjunction with input from ECHA and so I would like your opinions on what text we should go with for furniture (align with bed mattresses or align with the new text?). Although your opinions can come later, once you have had a chance to look at the text for other product groups today.
The text applying to different groups of hazardous substances, such as dyes and biocides etc, has been moved to material specific sub-criteria as per the request of CBs at the last meeting. The aim is that the criteria should be simpler to read for applicants since they first have to know what materials are in their product, then look at the criteria applicable to those materials.
There are more entries in the derogation table after carrying out a more thorough cross check with the criteria for paints and varnishes and other reasons, for example with formaldehyde now being introduced as a derogation if workplace health and safety exposure limits are respected instead of simply requiring that all resin formulations have <0.2% free formaldehyde…
14 January 2019

8. Wood criteria Major restructuring, i.e… 3.3 sub-criteria effectively
come from removed separate
criteria for haz. subs and
surface treatments.
Sustainability criteria has been changed as per stakeholder requests.
Formaldehyde emissions from E1  50%/65% E1 (p.10 of Annex)
Origin, traceability and sustainablity
b) Free formaldehyde in resin
c) Formaldehyde emissions from WBPs
d) Contaminants in recycled wood
e) Genetically modified wood
3.1 Legality and origin
3.2 Sustainability
3.3 Restricted substances
a) contaminants in recyc. wood
b) wood preservatives
c) flame retardants
d) vinyl chloride monomer
e) heavy metals in P&V
f) VOC in P&V
g) perfluorinated comp. in P&V
3.4. Formaldehyde emissions
The major restructuring of the criteria is illustrated by comparing the two tables. It appears that the wood criteria is more complex now but most of the changes are simply due to restructuring the criteria. For example the legality and origin of wood has been placed in a separate criteria to the sustainability criteria. A criteria for legality was required because the EUTR in its present form contains a number of exemptions which could effectively allow illegally harvested wood to be used in furniture sold in the EU. It is undesirable that such an exemption should extend to EU Ecolabel furniture. Furthermore, the legality criteria is separated from sustainability criteria due to the curious fact that wood certified as FSC or PEFC compliant is not considered as a direct and complete compliance with the legal requirements of the EUTR.
The sub-criteria in section 3.3 come from old sub-criteria for hazardous substances and surface treatments that have now been deleted as stand-alone criteria.
Other important changes are the specific mention of vinyl chloride monomer, which essentially prohibits the use of PVC foils with wooden panels and the reduction of the formaldehyde emission limits to 50% or 65% of E1 for final coated panels.

9. Plastics criteria Significant changes i.e…
Marking of plastic parts maintained, ISO or ISO 1043 permitted.
Recyclable plastics criteria removed  lack of support
Recycled content req. relaxed
BPA residue limits removed due to low exposure risks
PVC criteria changed from plastics having <50% Cl content and <1ppm VCM residue to a general ban on PVC based plastics
(criteria  p.16 of Annex)
4.1 Marking of plastic components
4.2 Restricted substances
a) Heavy metals in additives
b) vinyl chloride monomer
c) flame retardants
d) plasticisers
4.3 Recycled plastic content
Marking of plastic parts
b) Hazardous substances
c) Recyclable plastics
d) Recycled content
Again the significant restructuring of the criteria is illustrated by comparing the two tables. The marking of plastic parts has been maintained but now also permits the use of the more ambitious ISO 1043 marking system as well as the more limited ISO standard.
The recyclable plastics criteria has been removed as it was criticised as being burdensome to applicants and there was a general lack of support for this criterion.
The recycled content requirement has been relaxed, with the requirement only kicking in when the product is >20% plastic instead of 10% plastic by weight. And the minimum required recycled plastic content has been lowered to 30% from 50% for outdoor furniture – due to concerns expressed by one Competent Body with applicants struggling to find enough recycled plastic on the market.
The wording of the previous criteria for PVC essentially banned rigid PVC in parts greater than 50g and required that it also meet strict requirements for VCM monomer. The new wording is essentially an outright ban on PVC parts. However, the way the criteria is now structured, there is the possibility of having separate criteria relating to PVC as sub-criteria in foils for wood-based panels or in coated fabrics. The plastics criteria refers to non-composite materials that are purely made of plastic or combinations of plastic in a polymer blend. The main arguments against PVC are the fact that almost 100% of the polymer is made from a known human carcinogen (Category 1A – VCM), that the recycling rates of PVC are poor compared to other plastics and that when incinerated, PVC leads to the increased production of hazardous APC residues and arguably the increased production of dioxins and furans. I know PVC is a critical issue in furniture criteria and if it is to be banned, then it must be shown that alternative materials can do a similar job or better. If it is to be included, then what certain conditions must apply so that its adverse environmental impacts are limited. This could be requiring that PVC used is traceable to BAT production facilities, that a take-back or buy-back scheme exists for PVC components that is linked to a recycling scheme (to avoid it being incinerated), that the PVC has a minimum recycled content or is only permitted up to a maximum % of the total product weight.

10. Metals criteria Significant changes, i.e…
Description of metal criteria removed
Hazardous substances criteria split up and reworded  electroplating is specific to metals, the other coating criteria aligns with requirements for wood coatings.
Recyclable metal criterion removed due to lack of support.
Recyc. content req. removed due to: verification difficulty & existing high recyc. rates (criteria  p.19)
5.1 Restricted substances
a) Electroplating restrictions
b) heavy metal in paints/ primers
c) VOC content in paints/primers
d) Perfluorinated compounds in paints / primers
Description of metal used
b) Hazardous substances
c) Recyclable metals
d) Recycled content
The metal criteria have been simplified somewhat. Previous criteria for the description of metal used was removed due to a lack of support and potential overlap with the product description. The hazardous substance criteria has been expanded and is specific to metal components. One part that may be missing the possible derogation for lubricants used in gas lifts of office chairs  any input on that? In any case it would most likely be entered in the general derogation table, not under the metal criteria.
The recyclability criteria, like the equivalent criteria for plastics, was removed due to criticism and a lack of support.
The recycled content has been removed simply due to the fact that metal recycling rates are already very high due to the economic value of scrap metal. Thus it could be argued that requiring recycled metal in one product simply reduces the recycled content of another product. Furthermore, the availability of recycled metal varies significantly from region to region and will depend on the rate of growth in metal demand worldwide. Issues with verification arise due to the continuous or semi-continuous nature of operation of metal smelters and annual averages of recycled content do not necessarily represent a particularly accurate estimation of the real recycled content of the product.
Nonetheless it is recognised that the criteria for metal is quite weak and so we would like to know what the opinions of the Competent Bodies are about the recycled content requirement. If it really has to be included or if some other requirement, such as metal sourced from BAT smelters (and if this is verifiable – due to the fact that furniture manufactures do not tend to buy metal directly from smelters).

11. Upholstery criteria (coverings) Major restructuring, i.e…
General move from upstream  final product (criteria p.20)
Red criteria only kick in if >1% w/w of leather or textile covering materials in product
6 Upholstery covering materials
6.1 Leather
a) physical requirements
b) restricted substances in leather
d) restricted subs in production process
6.2 Textiles
b) restricted substances in textiles
c) restricted subs in production process
6.3 Coated fabrics
b) restricted substances
7 – Leather
a) Animal origin
b) Final tannery effluent
c) Final product leather req.
d) Hazardous substances
8 – Textiles
Cotton
b) Elastane
c) Polyamide (nylon)
e) Final product testing
The major restructuring of the criteria is self-evident from the tables. In an attempt to simplify the verification process for applicants and Competent Bodies, and because, unlike footwear, leather or textiles may only represent a small fraction of the total product weight, there has been an attempt to shift the criteria more towards the final product and away from upstream processes. Coated fabrics, which includes upholstery plastics referred to as artificial leather, have now been included. Regardless of the total weight of leather, textiles or coated fabrics used in upholstery coverings, the durability of the material is important – which is reflected in the physical requirements sub criteria for each material. Also, because the materials are likely to come into direct and prolonged skin contact with users, it is important to have criteria that set limits for restricted substances in the final product. Only if the leather or textiles exceed 1% of the product weight would further assessment of the hazardous chemicals used in their production be required. Feedback from a representative of the coated fabric industry stated that coated fabric production could also meet the requirements set out for hazardous substances used in the manufacture of textiles but that a minor derogation for H411 and H412 would be required for coated fabric varnishes and stabilisers.

12. Glass criteria Major restructuring, i.e…
Recyclability criteria removed due to lack of support
Hazardous substance criteria focussed on heavy metals only
Recycled content criteria removed due to lack of input regarding recycling rates with different glass types.
Information to the consumer emphasised to avoid improper recycling of furniture glass.
Replacement glass etc. covered by final product criteria
What about decorative glass? Look at criteria (Annex p.31)
10 – Glass
a) Recyclability of glass
b) Hazardous substances
c) Recycled content
8 – Glass
8.1 Heavy metals in glass
8.2 Information to the consumer
The recyclability criteria for glass has been removed due to criticism of the criterion and a lack of support.
The recycled content criterion has been removed due to a lack of input regarding current practices and realistic recycled contents for the different glass types that may be used in furniture.
The hazardous substance criteria has been focused exclusively on heavy metals, since these are the main hazardous materials that can be included within the glass matrix.
Information about the correct disposal of furniture glass is emphasised to reduce the risk of incorrect disposal that could contaminate entire batches of post-consumer glass collected in kerbside schemes.
Regarding hazardous substances, the use of decorative glass and mirror glass may be more complex due to the use of protective coatings, dyes, pigments, inks and other chemicals in the glass coating. Perhaps it would be more appropriate to exclude decorative and mirror glass from the scope entirely? Opinions on this?

13. Final product criteria Significant changes, i.e…
EoL guidance removed due to lack of support
Originally thought that safety req. covered by GSPD and CE marking but may not be the case…
Ergonomics limited to office/school chairs and desks only.
VOC emission criteria is the biggest challenge….
11 – Final product
a) Product performance (durability, safety, strength)
b) Design for reparability/ refurbishment/ reuse
c) End of life guidance
d) VOC emissions
e) Low energy light bulbs
9 – Final product requirements
9.1 Fitness for use
a) Durability
b) Strength
c) Ergonomics
9.2 Warranty / Disassembly / spare parts
9.3 VOC emissions
The approach to the final product criteria is similar to before although some changes have been made. End of life guidance criteria and the low energy light bulb criteria have been removed. There are still a number of changes that could be adopted here. For example, should safety criteria be included in the new criteria? Or is this covered by the GPSD? Should a more flexible approach be provided where a long product warranty can be accepted in lieu of providing evidence of compliance testing for the durability and perhaps the strength requirements? The standards for ergonomics only extend to chairs and desks in schools and offices – should this be included here, even though it only applies to some furniture products?

14. Final product criteria VOC emissions Test parameters?
What VOCs to measure?
What limits?
Cannot compare with VOC limits for construction materials
Furniture products are far more complex.
Current draft criteria allows manufacturers to avoid testing if they use no upholstery or no coatings, low VOC coatings or low overall quantities of VOC containing coatings.
Limits and tests defined by BIFMA for office seating & workstations (US).
Limits defined by Blue Angel RAL UZ 117 (Low emission upholstered furniture) for armchairs and leather.
So let's take a closer look at what the BIFMA and Blue Angel criteria say…

15. Blue Angel RAL-UZ 117 VOC emissions Textile covered armchair Leather
Substance
3rd day
28th Day
28th day
Chamber conc.
Product specific emission rate
Formaldehyde
≤240 µg/h
≤60 µg/m3
Other aldehydes
TVOC
≤1800 µg/h
≤450 µg/m3
TSVOC
≤320 µg/h
≤80 µg/m3
C-substances
≤10 µg/m3 (total)
≤1 µg/m3
(single value)
TVOC (no LCI)
≤40 µg/m3 (individual substances)
R-value ≤1
No LCI =
95 VOCs
The Blue Angel VOC limits are included in the Table here. It should be pointed out that very different approaches are taken for textile based armchairs and leather based ones. In the textile based armchair, the whole product is tested whereas for leather, it is only representative samples that are tested. Why is this? Limits are defined for formaldehyde, other aldehydes, TVOC and TSVOC. Testing is also required for carcinogenic VOCs but it is not clear how many substances this would require analysis for. The sum of TVOC for compounds without an LCI is something that I would like to avoid in EU Ecolabel criteria because it currently represents around 95 substances and the limits may be overly stringent. The R value, as far as I understand is an average coefficient of the concentrations of individual VOCs with LCI values divided by their respective LCI values. Although this would require the analysis of sum 80 individual VOCs, it is far more justifiable than the limits for substances with no LCI values.
Methods based on ISO
Armchair: air flow rate: 4.0m3/h specified (loading = 1 product).
Leather: surface specific flow rate of 1.5m3/m2/h

16. BIFMA M7.1:2011 VOC emissions Substance
Emissions limits (systems 168h
Emission limits 168h
TVOC
≤ 0.5 mg/m3
≤ 0.25 mg/m3
Formaldehyde
≤ 50 ppb
≤ 25 ppb
Total Aldehydes
≤ 100 ppb
4-Phenylcyclohexene
≤ mg/m3
≤ mg/m3
Chamber conc. values above relevant to LEED EQ Credit 4.5 for low-emitting materials
Substance
ANSI/BIFMA M7.1 Open plan workstation
ANSI/BIFMA M7.1 Closed plan workstation
TVOC
≤ 42.3 µg/m2.h
≤ 85.1 µg/m2.h
Formaldehyde
≤ 345 µg/m2.h
≤ 694 µg/m2.h
Total Aldehydes
≤ 2.8 µmol/m2.hr
≤ 4.5 µmol/m2.hr
4-Phenylcyclohexene
The Blue Angel VOC limits are included in the Table here. It should be pointed out that very different approaches are taken for textile based armchairs and leather based ones. In the textile based armchair, the whole product is tested whereas for leather, it is only representative samples that are tested. Why is this? Limits are defined for formaldehyde, other aldehydes, TVOC and TSVOC. Testing is also required for carcinogenic VOCs but it is not clear how many substances this would require analysis for. The sum of TVOC for compounds without an LCI is something that I would like to avoid in EU Ecolabel criteria because it currently represents around 95 substances and the limits may be overly stringent. The R value, as far as I understand is an average coefficient of the concentrations of individual VOCs with LCI values divided by their respective LCI values. Although this would require the analysis of sum 80 individual VOCs, it is far more justifiable than the limits for substances with no LCI values.
Emission rate values above relevant to the ANSI/BIFMA e Furniture Sustainability Standard
California has limits for 32 individual VOCs in the open plan office furniture bid specification (can use BIFMA method).

17. BIFMA M7.1:2011 VOC emissions Basic test principles
Sample conditioned in chamber for 72h
Duplicate samples taken at 72h and 168h (7d).
Power-law model used to predict conc. at 14d (assumptions).
Air flow rate range depends on chamber size:
Large chamber (20-55m3): L/s
Medium chamber (3-20m3): L/s
Small chamber ( m3): L/s/m2 *
*corresponds to a loading rate of m2/m3
Air quality and control according to ASTM D6670
T=23.0 +/- 0.5oC; RH=50% +/-5%; pressure=10-25Pa +/-5
>0.4m space between test piece and chamber walls
Look at VOC criteria (p.34 of Annex)
The Blue Angel VOC limits are included in the Table here. It should be pointed out that very different approaches are taken for textile based armchairs and leather based ones. In the textile based armchair, the whole product is tested whereas for leather, it is only representative samples that are tested. Why is this? Limits are defined for formaldehyde, other aldehydes, TVOC and TSVOC. Testing is also required for carcinogenic VOCs but it is not clear how many substances this would require analysis for. The sum of TVOC for compounds without an LCI is something that I would like to avoid in EU Ecolabel criteria because it currently represents around 95 substances and the limits may be overly stringent. The R value, as far as I understand is an average coefficient of the concentrations of individual VOCs with LCI values divided by their respective LCI values. Although this would require the analysis of sum 80 individual VOCs, it is far more justifiable than the limits for substances with no LCI values.

18. Final product criteria Fitness for use standards
Cheap furniture = less durable furniture = shorter lifetime = higher life cycle impact
Previous criteria had a simple list of standards, not very helpful.
Proposed to focus on the most relevant standards and provide some further detail, i.e.
Opinions on this? Is it appreciated? Would it help simplify compliance? Is it necessary? EN
Hardware for furniture - Strength and durability of hinges and their components - Hinges pivoting on a vertical axis
Tests: Overload tests; ;Functional tests; Corrosion resistance
(St + D) Pass Overload test = no fracture of any component of joint, no loosening of any joint or fixing component, no impairment of function of any component or part after vertical tests where doors open within 3-5secs and close within 3-5secs and (where relevant) after horizontal overload tests.
(D) – Pass of the functional test = the closing force of hinges with self- closing spring mechanisms shall not be less than 0,5N before and after durability tests; deflection sagging shall not be more than 0,5% of the width of the door after durability tests
(D) – Pass of the corrosion resistance test = 3 cycles AHT when measured according to EN ISO
14 January 2019

19. Packaging Request to remove the criteria for packaging
Rationale includes:
Not identified as a key env. impact in LCA
Further verificaton efforts for CBs and applicants
Lack of cohesion between criteria for different products
Arguments in favour include:
Visual impact on consumer (purchase choices)
Relative envi. impact can vary widely within product scope
Opinions (esp. of CBs) on removing packaging criteria?
14 January 2019 19

20. Thank you for your attention
Follow-up contacts
Oliver Wolf
Tel
Shane Donatello
Tel  
European Commission, Joint Research Centre (JRC),
Institute for Prospective Technological Studies (IPTS),
Sustainable Production and Consumption Unit,
Edificio EXPO C/ Inca Garcilaso 3,
41092, Sevilla, SPAIN
Website: