Småhus, flerbostadshus och förskolebyggnader - Svanen

Nordisk Miljømerking
Hus, leiligheter og barnehager 089/versjon 2
Høringssammenstilling, oppdatert 10. august 2010
available on the market, which will significantly improve the overall energy and material
balance of the building (see examples above).
BING calls on the Nordic Ecolabel to achieve consistency between the Background
report and the draft ecolabelling text, to remove the ban of halogenated flame retardants
or limit it to brominated flame retardants or, at least, allow the use of those flame
retardants for which the EU risk assessment has concluded that the substance is not
hazardous and hence no classification and labelling is required.
European Council for Plasticisers and Intermediates (ECPI)
Substances should not be grouped (Prohibited Substances, 017 and 022)
Grouping substances by family is entirely inappropriate as many “families” of chemicals
consist of substances which are both structurally and toxicologically quite different.
Phthalates are one such example. The phthalate “family” consists of numerous
substances, each of which has a different chemical structure which gives it its own
characteristics. Whereas phthalates such as DEHP, DBP and BBP are classified as
category 2 reproductive toxicants, there are those such as DINP and DIDP which have no
hazardous properties and which are therefore quite different.
There are no grounds for prohibiting the use of DINP and DIDP
There are no grounds on which the use of Di-isononyl phthalate (DINP) and Diisodecyl
phthalate (DIDP) should be prohibited from use:
• DINP and DIDP have been the subject of a comprehensive EU risk assessments 1
conducted over a 10 year period. The conclusion of the risk assessment reports is
that no risk reduction is required for any current application of DINP or DIDP.
• DINP and DIDP are not classified or labelled under the EU Dangerous Substances
Directive for any hazardous properties. This has been confirmed by expert review
within the EU regulatory process.
• DINP and DIDP are not PBT or vPvB substances. This is also addressed in the
EU Risk Assessments. Published laboratory and field studies have shown that
DINP and DIDP do not bioaccumulate or biomagnify in the food chain. These
studies are based on advanced analytical techniques which can detect trace levels
of the substances in the environment. Detection capability does not equate to risk
to health or the environment.
• DINP and DIDP are not endocrine disrupters as defined by Weybridge 2 , REACH
and other international definitions. DINP has been subject to a comprehensive 2generation
rodent study - the test recognized by OECD to be one of the most
rigorous tests for effects on the reproductive system mediated via the endocrine
system. More than 10 years ago, assessments of the oestrogenic potential of DINP
using yeast cells and human cell models showed a weak response for DINP. The
report authors warned that the relevance of these results to a whole animal was
unclear and that further tests were recommended 3 . Additional tests were carried
out in cells and in suitable whole-animal models and the original findings were
not confirmed 4 . Additionally, proposed effects of DINP on testosterone and other
proposed anti-androgenic effects from non-guideline research studies 5 , 6 ,are of
unclear significance and have not been confirmed in the robust OECD Guideline
two-generation rodent study 7 .
88 (165)