Draft - JRC IPTS - Sustainable Production and Consumption - Europa

EUROPEAN COMMISSION
JOINT RESEARCH CENTRE
Institute for Prospective Technological Studies (Seville)
Sustainable Production & Consumption Unit
(Draft) Minutes of the 2 nd Meeting of the AHWG for the revision
of the EU Ecolabel for textile products
Held on Wednesday 26 th and Thursday 27 th September 2012
Room AB-2A, Albert Borschette Conference Centre, Brussels
Attendees
Raffaella Alessi ISPRA ecolabel@isprambiente.it
Annamaija Bergius CEFIC abe@cefic.be
Mauro Cordella JRC IPTS (Meeting chair) mauro.cordella@ec.europa.eu
Bernard Defraye CIRFS European Man-made Fibres Association def@cirfs.org
Nicholas Dodd JRC IPTS (Technical presentations) nicholas.dodd@ec.europa.eu
Adil El Massi Euratex adil.elmassi@euratex.eu
Marianne Eskeland Ecolabelling Norway mbe@ecolabel.no
Silvia Ferratini European Commission, DG ENV silvia.ferratini@ec.europa.eu
Juan Antonio de Ferrer CEPSA juanantonio.deferrer@cepsa.com
Michela Gioacchini Hugo Boss Ticino SA Michela_Gioacchini@hugoboss.com
Isabella Gornall Burson Marsteller representing EFRA isabella.gornall@bm.com
Jiannis Kougoulis JRC IPTS, Product Bureau jiannis.kougoulis@ec.europa.eu
Malgorzata Kowalska JRC IPTS, Product Bureau Malgorzata-agata.Kowalska@ec.europa.eu
Pierre Lebon Asqual pierre.lebon@asqual.com
Jean-François Luthun FEDEREC textiles jfluthun@ebsesperance.fr
Emilie Machefaux ADEME (French Competent Body) emilie.machefaux@ademe.fr
Jelle Mertens International Antimony Association jelle@antimony.be
Karin Moosbauer Lenzing k.moosbauer@lenzing.com
Cecile Nourigat
Nyqvist-
Burson Marsteller representing EFRA cecile.nourigat@bm.com
Leena Kuusola Ecolabelling Finland leena.nyqvist-kuusola@motiva.fi
Dritan Osmani JRC IPTS, Product Bureau Dritan.osmani@ec.europa.eu
Carla Pinto European Commission, DG ENV Carla.pinto@ec.europa.eu
Sirko Prußig CEA-PME sprussig@googlemail.com
Hannelore Schorpion Federal Public Service Health, Belgium hannelore.schorpion@milieu.belgie.be
Daniela Toma Ministry of Environment, Romania dana.toma@mmediu.ro
Stefanie Trompetter MADE-BY Stefanie.Trompetter@made-by.org

Dirk Van Hessche
Van
Plastics Europe dirk.van.hessche@plasticseurope.org
Martine Schoorisse Bioforum martine.vanschoorisse@bioforum.be
Paul Vaughan UK Ecolabel Delivery paul.vaughan@oakdenehollins.co.uk
Jakob Waidtlöw Ecolabelling Denmark jwa@ecolabel.dk
Oliver Wolf JRC IPTS, Product Bureau oliver.wolf@ec.europa.eu
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Agenda
Wednesday 26 th September (14:30 – 18:00)
Start time 14:30
Opening and welcome
1. Introduction to revision of the EU Ecolabel and Green Public Procurement (GPP)
criteria
Product group scope and definition
2.
Product group scope and definition revisions
Coffee break
Textile fibre criteria area – presentation and discussion
3. The key issues proposed to be addressed by the revision, findings of follow-up
research and revised proposals for revisions.
Close of meeting 18:00
Thursday 27 th September (09:30 – 13:30)
Start time 09:30
Processes and chemical criteria area – presentation and discussion
4. The key issues proposed to be addressed by the revision, findings of follow-up
research and revised proposals for revisions.
Coffee break
Fitness for use criteria area – presentation and discussion
5. The key issues proposed to be addressed by the revision, findings of follow-up
research and revised proposals for revisions.
New criteria areas – presentation and discussion
6. Care labelling, end-of-life and CSR criteria: findings of follow-up research and
revised proposals.
Next steps
7.
Resume of AHWG and next steps in the EU Ecolabel revision process
Close of meeting 13:30
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Session 1 – Introduction and background
A brief introduction to the EU Ecolabel and the revision process for textile products was made by
JRC-IPTS European Commission. This will be the second of two AHWG meetings designed to obtain
feedback from stakeholders.
Written feedback on the draft Preliminary Report and draft Technical Report and Criteria Proposals
was requested within four weeks by the 24 th October 2012. The documents can be downloaded from
the JRC IPTS Product Bureau website from 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 at the end of November with a view to
Interservices consultation during December-January followed by presentation to the EU Ecolabel
Board for voting in March 2013.
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:
o the current scope, aim and structure of the Ecolabel criteria,
o the market analysis for EU textile products,
o the technical analysis based on LCA evidence,
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Session 2 – Product group scope and verification
Product scope definition
Proposed revisions presented included more specific product definitions for clothing and interior
textiles, a list of exclusions and lowering of the threshold for definition of a textile product to 85%.
Input from stakeholders
Synthetic material not covered within the scope of the criteria requires further consideration. The
Nordic Swan sets thresholds for membranes and coatings of 20%. All of other materials could be set
at a limit of 15%.
The inclusion/exclusion of a number of products requires clarification so that stakeholders can be
consulted e.g. cleaning products, bags, rucksacks. Would it not be better to just have a list of what is
excluded, as what happens if something is not included? This point requires clarification.
It was also suggested that it may be better to introduce the list of products ’such as…’ rather than a
definitive list ’defined as…’
IPTS clarified that cleaning products are proposed for exclusion because of the greater complexity of
the associated fitness for use criteria that would be required (with reference to the Nordic Swan).
It was queried as to why products such as tents should not be included if they met all the criteria and
as to whether the definition of electrical devices should include fibres as an application was not known
to exist.
It was clarified that the Textile Names Directive 121/2008 was repealed in May 2012 and a new
definition of 80% introduced.
Actions arising from the discussion:
o Clarify and improve wording of inclusions/exclusions, including cleaning products, rucksacks
and bags;
o Review potential for a maximum % content for synthetic materials not covered by the criteria
– specifically membranes, coatings and fillings – with reference to the Nordic Swan;
o Cross-check the reference to the revised Textile Names Directive;
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Assessment and verification
A proposed new requirement for certification schemes to be operated in line with the ISO Guide 65
was presented.
Input from stakeholders
It was considered challenging and difficult for Competent Bodies to verify this requirement to the
level stated in the proposal. A simple declaration would be the best option.
This would require mutual recognition of certification schemes. The only thing that could be possible
is to accept accredited certification bodies, which could be listed in the criteria in order to leave no
doubt, but then this list would need to be maintained.
It was stated that it would be easy to check the status of the certification body as it will be written on
any certification issued by them.
It was stated that the ISO/IEC Guide 65 has been replaced by a new ISO standard 17065.
Actions arising from the discussion:
o Review the potential for requiring a simple declaration;
o Change the reference from ISO Guide 65 to ISO 17065.
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Session 3 – Textile fibre criteria area
Criteria pre-amble
Proposals to improve the clarity of how the fibres are presented and to lower the threshold for recycled
content to 70% were presented.
Input from stakeholders
It was queried as to why silk does not have criteria. It is becoming more important for high quality
products in combination with other fibres. It was also queried as to why aramid fibre, which typically
has applications such as fire service and military, should not be included.
IPTS clarified that neither of the fibres were as significant from a market perspective. Silk had not
been raised in previous meetings/stakeholder written feedback. Aramid was being considered within
the scope of GPP, however, further LCA evidence is needed to evaluate the environmental impacts
associated with its manufacture.
It was also clarified that a revised threshold of 70% is proposed for recycled content, above which the
relevant fibre criteria do not apply.
Actions arising from the discussion:
o Scientific evidence for the environmental impacts of silk fibres should be reviewed with a
view to deciding whether to include/exclude silk fibres;
o A further attempt should be made to obtain LCA evidence for aramid fibres;
C2 Cotton and other natural cellulosic seed fibres (including kapok)
Revision proposals to increase the minimum organic cotton content to 10%, to introduce a higher
minimum of 50% for specific products, to introduce IPM cotton as an alternative option to IPM cotton
(with same minimum requirements and to add two pesticides to the current testing list were presented.
Input from stakeholders
Disappointment was expressed about the potential weakness highlighted in relying on final fibre
pesticide testing. Specific additional pesticides were suggested that are commonly used in conjunction
with GM cotton – Glyphosate and Ammonium Sulfamate were cited. Moving to organic and IPM
cotton would mean that cotton couldn’t be bought on the spot market.
Concerns were raised that greater minimum requirements for organic cotton would restrict the
Ecolabel to a low market share. The experience with the Nordic Swan is that a high content standard
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has not been successful.
The justification for raising the minimum content requirement was queried. In particular the issue of
potential false content claims by manufacturers was raised as a major concern, and it was claimed that
there is not enough organic cotton on the market to meet all the content claims being made. The
ethical impact of possible increased land use was also highlighted.
Feedback from some industry stakeholders suggests that a 50% content requirement for organic cotton
is too high.
The method of calculating the content claim to be verified by Competent Bodies requires greater
clarity – is it based on the final product or an annual average?
IPTS clarified that very different views had been received from stakeholders in advance of the
meeting, with some Competent Bodies and brands/manufacturers proposing a content requirement of
between 50-100%. The proposal is an attempt to bridge the very different opinions, reflect strategies
in the market today and to ensure a higher level of environmental improvement.
It was felt that organic cotton and IPM cotton should not be considered together or as equal in terms of
minimum requirements. The requirements for IPM were not considered to be at the same level. It was
felt that there are currently not real IPM criteria but guidelines. There are big differences between
them in terms of improvement potential. One view was that IPM minimum requirements should be
higher.
IPTS clarified that there is clear evidence from UN/FAO of an improvement potential of between 30-
90% for IPM cotton, the problem is the ability to verify this improvement. Schemes do include specific
criteria. Licenseholders had also fed back the need to have IPM as an alternative option to organic
cotton.
It was also noted by IPTS that a Competent Body had suggested that feedback be obtained from the
four IPM schemes on IPTS’s evaluation of their strengths and weaknesses.
A question was raised as to whether membership of the BCI IPM scheme would be sufficient in terms
of verification.
It was clarified by IPTS that this would not be sufficient, the verification requirements in the proposal
would need to be met.
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Actions arising from the discussion:
o With regard to pesticide tests:
- Check the proposed additional pesticides for relevance to the criteria;
o With regard to organic cotton:
- Review the proposed % minimum requirements and the associated justification;
- Obtain further background from Euratex on false content claim concerns;
o With regard to IPM:
- The criteria should be redrafted so that it considers IPM differently from organic
cotton;
- Recommend which IPM scheme would be acceptable at this point in time and obtain
feedback from the four schemes.
C3 Elastane
The proposal for an occupational exposure limit for di-isocyanates was presented.
Input from stakeholders
It was stated that the solvent DMAC, which is used to manufacture elastane and also acrylic and
aramid, has been proposed for addition to the ECHA Candidate List for Authorisation.
The question was raised as to whether there are alternatives to DMAC as its Candidate List status may
rule out the use of acrylic and elastane fibres. Further information will be provided by CIRFS.
IPTS clarified that this would be addressed under the hazardous substances criteria and that there
may be an option for derogation if there are no alternatives.
It was clarified that elastane is generally used in clothing at 20-30% blend and that although
alternatives to DMAC exist their toxicology is similar.
Clarification was requested where the proposed occupational health and safety limit value for diisocyanates
was derived from. In the EU there are mandatory levels – is this stricter than this level?
IPTS clarified that it was from the Blue Angel label scheme in Germany.
Actions arising from the discussion:
o CIRFS to provide background information about DMAC, its applications, alternatives and the
proposal for Authorisation;
o A comparison is to be made between the proposed di-isocyanate limit value and mandatory
levels in the EU, with input from CIRFS and Blue Angel.
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C4 Flax and other bast fibres (including hemp, jute and ramie)
Revision proposals to introduce a requirement for retting at ambient temperature were presented.
Input from stakeholders
It was commented that the COD limit to the receiving waters should be specified with a limit value of
% requirement.
Actions arising from the discussions:
o Review the potential for a COD limit value or a % requirement
C5 Greasy wool and other keratin fibres (including wool from sheep, camel, alpaca, goat)
Revisions proposals to link the wool scouring COD limit to the level of grease recovery, to require
value recovery from by-products and to improve the approach to sampling for ectoparasiticide testing.
Input from stakeholders
The final COD achieved for the 180 g/kg starting value (= 45 g/kg wool) was felt by one Competent
Body to be too high. A lower COD limit of 24 g/kg should be achieveable in New Zealand.
IPTS clarified that it based the proposals on discussions with the two remaining New Zealand
scourers as well as a review of BAT technology. Differentiation could be made between fine and
course wool, as the final COD would be closer to 24 g/kg for coarse wool.
Specific comments had been submitted by Danish Licenseholders, which should be taken into
consideration. The reference to the EU wastewater treatment directive should be replaced with a
specific COD limit value or % COD reduction. A query was raised about the potential for an energy
benchmark, as energy use was mentioned in the presentation.
IPTS clarified that research highlighted that wool can require as much energy to scour as to
manufacture synthetic fibres and there was good experience in New Zealand operating a benchmark.
However, IPTS recognised that most stakeholders were not in favour of energy benchmarks.
Actions arising from the discussions:
o Split the COD criteria into coarse and fine wool so that the COD targets better relate to
operational conditions;
o Review comments submitted by Danish licenseholders and follow-up on the issues raised;
o Replace reference to Wastewater Treatment Directive with specific COD limit value or %
COD reduction.
10

C6 Man-made cellulose fibres (including viscose, lyocell, acetate, cupro and triacetate)
Revision proposals were presented to lower the OX limit, to introduce an energy self-sufficiency
requirement for dissolving pulp production and to introduce a requirement for 25% of pulp to be from
certified sustainable sources with the remaining balance from legal sources.
Input from stakeholders
It was stated that Cupro is no longer manufactured in the EU. The need for reference to it in the
criteria was therefore questioned.
The BAT limit values were queried – please check that the VOC levels are correctly quoted for
filament fibre processes.
An annual increment was not considered possible by Competent Bodies because of the need to renew
licenses if conditions change. The % that certified sustainable fibre content requirement could reach
should be clarified if this approach is introduced.
Concern was raised that the energy self-sufficient proposal would only be achieveable for integrated
production sites, of which there are only a limited number in the world, so it would restrict potential
licenses. The criteria should be feasible for suppliers of market pulp. A specific figure would be
needed in the final proposal, if the criteria is shown to be feasible.
IPTS clarified that they understood that integrated production was very limited, and the criteria was
worded to apply to integrated production and market pulp production. BREF has been referred to in
order to identify the BAT technology referred to.
The reference to AOX in the criteria requires clarification as the ISO standard referred in the
verification conditions measures OX. The criteria could be made simpler by stating that elemental
chlorine gas is excluded, reflecting the use of ECF technology. The current Nordic Swan criteria were
suggested as a reference point.
Actions arising from the discussions:
o Check for the continued relevance of Cupro on the market;
o IPTS to liaise with Lenzing, who will put out an enquiry to their market pulp suppliers to find
out how many could meet the criteria;
o Check the Nordic Swan criteria for paper products as they provide a reference to ECF pulp
production;
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C7 Polyamide
Revision proposals to harmonise the VOC limits with those in the Blue Angel and to introduce a
minimum recycled content of 3% were presented.
Input from stakeholders
Concern was raised that the emission limits are not in line with the BREF for Polymers.
Concern was raised that the proposed 3% recycled content minimum was very low and would not
justify the modification of production lines to achieve this. Further feedback will be provided from
CIRFS members, but it is possible that a higher % will be recommended.
The recyclability of fibre should also be addressed by the criteria. For example, it is known that
polyamide 6,6 is more difficult technically to recycle.
Recycled content was felt by some stakeholders to be only one possible environmental improvement
and that others should be considered.
Actions arising from the discussions:
o Reference and justification for the N2O limit value to be checked/reviewed;
o CIRFS to provide feedback and % content proposal to IPTS within the formal consultation
period;
o Option to consider the recyclability of polyamide 6,6 fibres to be reviewed further;
C8 Polyester
Revision proposals to introduce a minimum recycled content requirement of 50% for staple fibre and
20% for filament fibre with some specific exemptions were presented.
Input from stakeholders
Recycled content was felt by some stakeholders to be only one possible environmental improvement
and other options should be considered.
The market diffusion of recycled content was queried, with fleece being suggested as the only
significant product. CIRFS clarified that 70% of staple fibre manufactured in the EU is made from
100% recycled content.
IPTS further clarified based on discussions with industry stakeholders that polyester with a recycled
content is being used in a wide range of clothing and interior textile applications.
12

The proposal for various exemptions from the recycled content criteria was welcomed, although they
will need to be more specific and may need to be broader, in order to reflect industry feedback relating
to the different end-uses. Problems with controls on the quality of production outside of the EU were
cited as a potential problem.
The proposal to maintain the current limit value of 260 ppm for antimony catalysts was welcomed and
it was stated evidence shows that the catalyst is bound within the fibre.
Actions arising from the discussions:
o Further refine and specify the recycled content exemptions in conjunction with stakeholders;
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Session 4 – Chemicals and process criteria area
New proposals to interpret the standard legal text for hazardous substances with proposed new criteria
11 and 12 were presented. Criteria 11 would bring together and update existing substance restrictions
contained within the criteria into a Restricted Substance List (RSL). Criteria 12 would, with a focus
on dyeing, printing and finishing processes, restrict the use of substances classified with specific
hazard statements, with the derogation of specific hazard statements for specific groups of substances,
and under certain conditions.
Input from stakeholders
C10 Hazardous substances and mixtures
The combined proposals for Criteria 10-12 were considered complex and so a summary of the
proposals was requested so that it can be circulated to other stakeholders for their comment.
The consistency with REACH and the Candidate List was welcomed, including the potential for
derogations. Do substances that are restricted need to be specifically listed?
The wording "substitution as far as possible" seemed not to be clear enough. The reference to
substances vs preparations (and viceversa) was also not considered clear.
The proposals for testing require greater clarification in terms of how they will minimise potential
costs. It makes no sense to test for everything and so a targeted approach should be used. It was
suggested that testing and declarations could be combined within the verification requirements.
Declarations could be allowed where good quality information is provided about the substances used.
C11 Restricted Substance List (RSL)
It was noted that some old criteria were restricting some substances that were not present on the final
product, but used in the processes, and this is something that should be kept. It was also noted that not
all the substances are restricted or Authorised by REACH or appear on the Candidate List e.g. high
molecular weight phthalates.
The focus of the criteria therefore requires clarification. The potential for declarations of non-use
should be left open to complement testing e.g. for azo dyes.
The potential for verification using Oeko-Tex 100 certification was discussed. The overlap between
the criteria requires clarification. The assessment and verification was felt difficult for CBs. A
consistent approach is needed.
14

Comments relating to specific substance groups:
The wording for the restriction of APEO’s requires amending in-line with written feedback
provided by various stakeholders.
Blends that may be restricted by the proposed changes to metal complex dyes should be
checked e.g. wool-viscose, wool-polyamide. The limit values should also be reviewed based
on information to be provided by Norwegian Competent Body.
The treatment of biocides and flame retardants that are not added as finishes but instead as
additives during fibre manufacturing should be clarified. The reference to existing EU
authorisation procedures should make verification easier.
There are forms of silver biocides other than the nanosilver that should be banned.
C12 Subsitution of hazardous substances used in dyeing, printing and finishing
The overall approach was seen as being workable. However, the 2 year phase out period was not seen
as being compatible with the licensing process for the Ecolabel as licenses would need to be re-issued.
The difference approaches being proposed for different product groups was noted and the potential for
a special Horizontal Task Force meeting to discuss was also proposed. Concern was raised because of
the limited time for Competent Bodies and Licenseholders to become familiar with the proposals,
which could mean that a lot of last minute changes would be needed. Could a 3rd AHWG be a
possibility?
Greater clarity is needed as to how suppliers will report to the applicant. The explanations provided in
the User Manual will be very important to ensure it is clear for the applicant.
REACH Annexes I and II provide a framework for providing information on substances, with
consideration of exposure scenarios relating to human health and the environment, with human health
including workers and consumers.
A request was made in relation to flame retardants for R40 (H351) to be considered as Category B. A
question was posed as to how many substances that fall below the concentration thresholds would
therefore be derogated from within Category B.
IPTS confirmed that a sample of substances had been tested, including those submitted for derogation
by stakeholders, however a definitive answer cannot be provided at this stage.
15

Actions arising from the discussion:
o Prepare a summary of criteria 10,11 and 12 and circulate to stakeholders;
o Consider how the approach may be further refined by reference to the Horizontal Task Force
and, potentially, a 3rd AHWG;
o With regards to C11 RSL:
- Wording of APEO restriction to be amended in-line with written feedback;
- Norwegian Competent Body to provide further information in relation to metal
complex dyes, blends that may be restricted and metal limit values;
- The biocides wording requires clarification that it applies to all finishes.
- The status of fibre additives as opposed to finishes is to be confirmed;
o With regards to C12 Hazard substitution:
o Consider the Categorisation of R40
C13 Dyeing, printing and finishing process efficiency
A new proposal was presented to introduce a criteria addressing process efficiency. The requirements
would be based on BAT improvements identified from the textile BREF and industry best practice.
Input from stakeholders
There are an increasing number of checklists for manufacturers covering energy and water use e.g.
CPO12 carbon footprinting training tool. These not only suggest technologies but also quantify
possible advantages e.g. energy and financial savings. Tools which include this information are more
convincing. The checklist should highlight the savings and the benefits.
A general concern was raised about the additional burden of the criteria. It was highlighted that the
application of BAT Techniques under IPPC Directive is limited to certain production capacity
thresholds. This is to minimise the burden for SME’s of investment in expensive BAT techniques.
It was questioned as to why a manufacturer would want to hold both Oeko-Tex 1000 and the Ecolabel.
They will choose labels according to their market.
Actions:
o Review potential to allow different tools/checklists to be used to achieve compliance;
o Consider how the checklist could be improved to highlight savings and benefits;
o Review IPPC threshold and whether this is should be applicable to this criteria;
16

C27 Waste water from discharges from wet-processing
Revision proposals to harmonise the criterion with Oeko-Tex 1000, Bluesign and GOTS were
presented. Higher requirements were also outlined as derogation conditions (linked to proposed
Criterion 12).
Input from stakeholders
A possible errata was noted – the COD should be g/kg instead of mg/kg? It was also noted that by
moving from g/kg to g/l the criteria would not treat fairly those making water savings as the specific
value may then be higher.
Actions arising from the discussions:
o Check the units used in the criteria
C26 Formaldehyde
Revision proposals were presented to align the proposals with Oeko-Tex 100, with the exception of
skin contact clothing at 75ppm.
Input from stakeholders
The revised proposals were not seen as being acceptable by a number of Competent Bodies. Why was
it not acceptable at 30ppm?
Actions arising from the discussions:
o Re-review rationale and limit values
C15 Detergents, fabric softeners and complexing agents
Revision proposals were presented to harmonise the criterion with those in the recently approved
professional laundry detergents criteria, with ionic and cationic detergents being required to be
biodegradable under anaerobic conditions.
Input from stakeholders
It was noted that Detergents Regulation 684 bans surfactants that are not biodegradable under aerobic
conditions. Reference to this would simplify the criterion. The ISO standard 6060 could also help
simplify the approach, refering to mg/l figures.
Actions arising from the discussions:
o Consider potential to reference Regulation 684 and ISO standard for biodegradability;
17

Flame retardants
Revision proposals to restrict the use of flame retardants unless they are required to meet Member
State fire regulations or ISO/EN product safety standards, and to introduce a requirement for them to
meet certain durability requirements were presented.
Input from stakeholders
With regards to durability it was highlighted that a soak test would be more relevant for textiles that
are not removable. It was highlighted that such tests are not designed to test for consumer exposure. A
query was raised as to how derogations would work for flame retardants.
IPTS confirmed that these were linked to regulatory need, technical need and the proposed new
durability criteria.
Actions arising from the discussions:
o Amend durability tests for non-removable textiles;
18

Session 5 – Fitness for use criteria area
Durability of finishes
A new proposal to introduce durability requirements for flame retardant, water repellent, softener and
easy care finishes was presented. Fibres and fabrics with inherent properties would be exempted.
Input from stakeholders
Fibre additives are incorporated into fibres which have been tested to last more than 50 wash cycles. It
was also noted that not all finishes are intended to remain on the fibre e.g. those applied to enable
efficient spinning. The current wording should distinguish between functions incorporated into a fibre
and those added to the surface. Durability therefore not only applies to surface finishes.
It was noted that if the durability of a textile product is high then it will improve its life cycle
performance and increase its value and potential for re-use.
Actions arising from the discussions:
o Clarify how criteria distinguishes between additive and reactive functions, and between final
product and intermediate product;
19

Session 6 – Proposals for new criteria areas
Corporate Social Responsibility (CSR)
A new proposal was presented to introduce a requirement for compliance of production sites with the
eight ILO core labour standards.
Input from stakeholders
There was general support for the criteria as proposed. The proposal is pragmatic.
It is important that we don’t discriminate against EU manufacturers. The criteria is concerned more
with manufacturing sites in developing countries.
The risk to the Ecolabel’s reputation of any contraventions occuring should be considered – there are
clearly risks with and without the criteria. But with this new criteria expectations would be raised.
The frequency of verification could be an issue. The Nordic Swan, for example, carries out control
visits. An opinion was expressed that it is too early for verification by third party schemes. This
could come later once there is greater experience with the criteria. Discussions with licenseholders in
Denmark highlighted that they tend to have only limited control over their supply chain.
Actions arising from the discussions:
o Review the verification requirements – with regards to frequency and third party schemes
Product re-use and recycling
A new proposal was presented that would require applicants that produce branded final products, or
that have a direct interface with textile consumers via retail stores or contractual agreements to provide
consumers or clients with take-back routes for repair, re-use or recycling.
Input from stakeholders
The general view was that although it is recognised as being important the Ecolabel is not the correct
policy instrument to address this issue. For example, it would not be practical if the licenseholder
exports to many EU countries.
The criteria may also require significant risk and investment because before applying for the Ecolabel
the applicant may not have a system in place. It was suggested that commercial textile suppliers could
be asked to pilot take-back services.
20

The consensus reached was that the only practical possibility at this stage is to provide information to
consumers on the product or on a website. The consumer should be informed. This could therefore be
the first step.
Actions arising from the discussions:
o Reduce the criteria scope to focus on the provision of information to the consumer;
o Textile service providers could still be required to provide take-back services.
Energy saving advice
A new proposal was presented that would require applicants that produce branded products to use
marketing, packaging and swing tags to communicate energy saving measures to ecolabel consumers.
Input from stakeholders
The proposal was felt to be too prescriptive and that instead the applicant should just be asked to
provide information to the consumer on potential energy savings. It should not be a pass/fail criteria
for applicants.
The criterion should not be implemented in a way that imposes disproportional costs. Information
provided via the internet would be acceptable.
It was noted that consumer campaigns have focussed on providing specific information on energy and
financial savings from specific measures e.g. the benefits of washing at 30 o C.
IPTS clarified that this could work but that it is important that the specific three messages that are
highlighted in the Technical Report are the main point of reference.
Actions arising from the discussions:
o Reduce the criteria scope to focus on the provision of information to the consumer;
o The wording/focus of the three energy saving messages is to be finalised;
Certification of B2B processes
A proposal by certain Competent Bodies and stakeholders to certify and/or maintain a database of
processes that meet the Ecolabel criteria was presented for discussion.
The proposal would make it easier for brands and manufacturers to identify suppliers, which would be
particularly beneficial for those that regularly use different/new suppliers in order to deliver new
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products to the market.
Input from stakeholders
A proposal to label and/or maintain a database of production processes that meet the criteria (e.g.
dyehouses, printers, finishers) was briefly discussed. The need for this had been raised by Competent
Bodies and industry stakeholders because it would assist in identifying pre-approved suppliers.
This would need to be voluntary as manufacturers may not wish to reveal or share details of their
suppliers as this is intellectual property.
It was felt that the Ecolabel may not yet be mature enough for this proposal and that it was unclear
how it would be resourced and co-ordinated. However, it is a good objective and could help in
seeking to emulate the success of certifications such as GOTS.
Actions arising from the discussions:
o Further discussion of the proposal at the November EUEB and invitation for further comment
from stakeholders;
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