REVISION OF ECO-LABEL CRITERIA FOR...

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REVISION OF ECO-LABEL CRITERIA FOR TEXTILES

REPORT AT THE END OF PHASE 1 A contract for a possible revision of ecol-label criteria for textiles was signed between the European Commission and AFAQ-AFNOR Certification. ASQUAL and Institut Français du Textile et de l'Habillement (IFTH) were involved in this study to support the main contractant. CONTRACT AND ACTIONS TAKEN The contract has been presented with 2 phases : The first phase is defined as having the objective to look at the necessity of revision of the Eco-label for textiles. If a revision is needed, a second phase will be engaged to propose precise evolutions in this award. This report has been structured in order to answer the first phase, knowing that the contract will cease at the end of phase 1 if the product group is to be withdrawn or prolonged without change. As we will understand later, several criteria are proposed to be revised after long exchange of information between the various trends, coming from the consensus of opinions expressed at the meeting. Four tasks in phase 1 were listed in the contract. And we will present hereafter the content of each one with a general view of the actions taken during this first period devoted to their study. Phase 1 with 4 tasks : Task 1 Consultation: "The contractor forms an Ad hoc Working Group with all the relevant interest groups involved such as industry (Corporate ans SME's, Trade Unions, Retailers, Importers , Environmental and consumer organisations, European Union as well as non European Union interested parties, Eco-label competent bodies and relevant Commission Services". "The contractor shall organise and chair at least one meeting of this Ad hoc Working Group (Although 2 would be preferable)".


Actions taken a) An Ad'hoc Working Group was set up at the beginning of 2006 with a composition given in

annex 1. One can see that it is composed of a large number of organisations representing the various interests listed above.

b) Two meetings were organised during phase 1 : The first one took place in Paris on 27 March 06. The proposed agenda is given as annex 2 and an introduction report was attached as annex 3. A power point presentation was used to help the discussion . see annex 4. After the meeting, minutes were written – See annex 5. And it was simultaneously proposed to the attendees to send their comments and new proposals. Many replies were made, and some examples of comments are in annex 6. Those comments were used to be discussed at the second meeting. In such a way, it appeared not necessary to introduce a special complementary questionnaire. The second meeting was organised in Brussels 3 October 2006 under the proposed agenda in annex 7. A Power Point presentation was set up to support the large discussion – annex 8 The Minutes of this second meeting were written – see annex 9 Task 2 "Under the contract, one shall evaluate the past, current and likely future success of the product group, including environmental benefits and taking into account the success of related product group". Actions taken At this stage, it was considered that the success of the Eco-label for textiles was rather poor. But at the same time, it was evident that an other label - a private label called OEKOTEX - was successfully adopted by a large number of companies. This is the reason why it was decided to compare the Eco-label content and the OEKOTEX label one in order to try to harmonize common criteria where possible. It would, at the same time, help manufacturers using the Eco-label to be in line with OEKOTEX, using the same methods (where applicable, as some OEKOTEX methods are confidential) and making the same assessment, including the same level for the specifications of the performances. The content of the public rules of OEKOTEX are given by the Association OKOTEX - Gottardstr. 61 Postfach 2156 CH - 8027 Zurich. And we will see later that this comparison will be made for each relevant criteria among the 40 criteria which are taken into account in the Eco-label for textiles.


Task 3 : "Under the contract, one shall update and extend market and life cycle information and analysis as appropriate". As we will see in the following developments, important criteria have to be updated, because of new research , or new standards appeared between May 2002 and today. Several replies received from the members of the Ad'hoc Working Group are also dealing with the necessity of changing test methods for new ones more appropriate or trying to extend the scope of the Eco-label for textiles to leather and floorcovering for instance. We will come back below on these subjects widely discussed at the second meeting. A difficulty appears at this level, connected to the manufacturers already using the present rules for this Eco-label as they are familiar with the existing documents. It will be necessary to be cautious in this field for assuring a good continuity in the use of the Eco-label for textiles. Task 4 : Under the contract, one "presents the results of these evaluations and analyses to one or more meetings of EU eco-label competent bodies and on the basis of these consultations recommending whether the ecological criteria and related assessments and compliance verification requirements should be either prolonged, withdrawn or revised. In this respect, particular regard will be paid to the likehood of this recommendation receiving a high level of support". In line with this task, discussion took a strong place in order to know the interests and priorities of the members of the Ad'hoc Working Group for some of the 40 items presented in the Eco-label for textiles. In this respect, it was particularly stressed on natural fibres, focusing on cotton (bio-cotton or ethic cotton). And it was proposed to set up a special Task Group for this item, in order to find the best proposals in this field. This could also apply to other new types of fibres which are just appearing on to the market such as corn (or maize), soya, bamboo and other protein fibres issued from milk, as examples. This very new trend will probably have to be followed with a special eye as the spirit of "natural" underlines this evolution in the textile and clothing chain. It will certainly be a major parameter of expansion for this industry because future expanding and growing markets in the western countries could come from this side. But, as it occurs in each new market, marketing arguments must be observed very seriously under protection of the consumer policy. But, in a first step, we want to remember the economical situation of the European textile industry with some main figures for textile/clothing/man-made fibres in 2005 (Euratex data) :


Turnover : 198 000 billion € Number of employees : 2 220 000 people Number of companies : 155 000 Main trading partners in textile and clothing for 2005 : Textiles import China : 22 % Turkey : 15 % India : 10,5 % Pakistan : 6,5 % United States : 5 % Textiles export United States : 12;4 % Romania : 10 % Turkey : 7,4 % Tunisia : 6,1 % Morocco : 5,7 % Clothing import China : 31,4 % Turkey : 14,9 % Romania : 6,7 % Bangladesh : 6,6 % India : 6,0 % Clothing export Switzerland : 17,1% United States : 13,7 % Russia : 11,3 % Japan : 8,4 % Norway : 4,6 % Dealing with the production of fibres, it is not very easy to see the exact global production all over the world. We got figures giving the average reality in this field for the years 1999 and 2000. We put here a range usually acceptable showing the importance of what we will speak about later, when discussing the criteria on properties.


The production of fibres is about 50 Millions tons with the following repartition :

Cotton : 38 -40 % Synthetic filaments : 30 %

Divided in : 17,5 % polyester 7,5 % polyamide 4 % polyolefine

Synthetic staple : 24 % Divided in : 14 % polyester 6 % acrylic 2,5 % polyolefine 1,5 % polyamide

Cellulosic staple : 4 % Wool : 2-3 %

Cellulose filaments : 1 %

Other fibres : about 1 % maximum

According to the 2005 European statistics from Euratex, we can find some complementary information to see the economical importance of trade between the 25 members of the European Union and the rest of the world. FIBRES TRADE BETWEEN EU 25 COUNTRIES AND REST OF THE WORLD At first, we will observe the trade among fibres with the following figures (unit : tons) : Import Export Natural fibres 987 468 Divided in :

Silk 4,0 0,5 Wool 277,0 77,7 Cotton 572,1 242,0 Other vegetable fibres 133,7 147,6 With flax 21,1 144,5

Man made fibres: 521,1 511,3 Divided in :

Synthetics 453,0 353,8 Artificial 33,8 99,6


YARNS AND THREADS TRADE BETWEEN EU 25 COUNTRIES AND REST OF THE WORLD Secondly, we can look at the statistics on trade between the 25 countries of the European Union and the rest of the world from yarns and threads to fabrics and carpets with the following results, and the same units (1000 tons). Import Export

Yarns and threads 1153 466,7 Woven fabrics 968,6 678,6 Knitted fabrics 120,8 113,0 Carpets 267 266,7 Other textiles 1017,4 1335,2 (and nonwoven) 152,1 203,1

FINAL PRODUCTS TRADE BETWEEN EU 25 COUNTRIES AND THE REST OF THE WORLD Statistics available from Euratex on trade between the 25 countries of the European Union and the rest of the world are the following (with unit : 1000 000 euros) Import Export

Home textiles 3,8 0,8 Garments 53,4 14,8

Divided in : Men's clothing 7,0 2,2 Women's clothing 16,2 4,2

Others 20,7 6,2 During the discussions of the second meeting of the Eco-label for textiles, it appeared that some members wanted to get more information about these statistics. And they are given here for further consideration at the next meeting planned for the beginning of 2007, if the European Commission definitely agrees on the revision of the present version of this Ecolabel. RESULTS OF THE EVALUATIONS AND ANALYSES Now, we will take the Commission decision of 15 May 2002 document and its annex as the reference in order to report on a synthesis of the discussions including the main arguments and historical points we consider interesting to be presented at phase 2. This is intended to help the members of the Ad'hoc Working Group to make the best proposals at this second stage.


1) Article 2 of the Commission decision of 15 May 2002 - Ecolabel to Textile products Chapter 2 : "Textile, clothing and accessories : consisting of at least 90 % by weight of textile fibres". This is in contradiction with the European Directive 96-73 dealing with the composition of textile products where a percentage of 80% is defined. All the competent bodies agreed to be consistent with this Directive. Proposal of the consultant: To replace 90 % by 80 % The same figure is considered for interior textiles. Chapter 3: Wall and floor coverings are excluded in the current criteria. At the first meeting, it was proposed to re-introduce wall and floor coverings. This subject was discussed again at the second meeting. The European Carpet Association represented by M. Van de Vrande explained the situation as follows: The EU carpet industry does not feel that the EU Ecolabel is suitable for its products . The reasons are : 1- 80% of the EU based carpet industry applies the GUT label which deals with the relevant health and environmental aspects of these products . And it is a market and production controlled system. 2-An important part of the products under 5702 and almost all the products under 5703 and 5704 are considered as being building materials , and consequently have to comply with CE marking and (actually only in addition in Germany ) also with the “ Banzulassung “ 3-The only products in their view which might be suited for the official EU Ecolabel are mats for bath , etc …which are sold together with towels and similar products . In a number of cases , they are made of natural fibres like cotton .

Summarising , we can say that the EU carpet industry , in view of the above arguments , does not wish to participate .

Proposal of the consultant : To allow mats and rugs made of fibres only:

- if they are made of 100% of textile fibres . - if they are not included in the Construction Product Directive.

To suppress the sentence "wall and floor coverings are excluded" to include these related products.


Chapter 3 : Leather is excluded in the current criteria. About the proposal to extend to leather products , COTANCE said that it does not enter in the definition because 80% by weight of textile fibres . For them , there is no demand from the market and no volunteer from the industry . For Austria , we must focus on textile . Other criteria should be proposed for leather. For the Nordic Swan, and the Dutch competent body ,there is no problem to include leather because on one part leather is included in Nordic swan and because it can be considered as a new fibre . For BBE, we must clarify the situation as it can correspond to an other product group , as CTBA said . It was also the opinion of the French Technical Centre for leather .It was considered that : - Textile and leather are different materials .

- The test methods are not the same - It's seems very complex to include leather because others criteria would be included

- It would not be textile Ecolabel but leather and textile Ecolabel - It's closer to shoes than textile.

Proposal of the consultant: To exclude leather

Chapter 3 : Non-woven textiles Non-woven textiles are those which are neither woven nor knitted, for example felt. They are cheap to manufacture. Non-woven fabric is manufactured by putting fibres or filaments together in the form of a sheet and then binding them either with an adhesive or by interlocking them with serrated needles such that the inter-fibre friction results in a strong fabric. They are made of:

Synthetic fibres : 75 % Cellulose fibres : 20% Natural fibres : 5%

Non-woven materials are used in numerous applications, including:

• Hygiene o Baby diapers o Feminine hygiene o Adult incontinence products

• Wipes o Domestic o Technical

• Filters • Geotextiles • Carpet backing • Composites


Today, there are several requests from customers for non woven. Non woven products represent an important and growing share of the technology and textile market. 50 to 60 % of non-woven products are produced for a unique use - disposable -(hygiene products for example) and others 40 à 50 % have a longer life cycle (geotextile for example). Several technologies are existing: - Dry laid: fibres from bale are carded with binder impregnation. - Spunlaid: polymer chips are extruded followed by steps of fibre dispersion, laydown and

bonding - Wet laid: Web is made with fibre and water slurry and binder impregnation - Air laid: the non woven is coming from short fibres put on a moving wire mesh to bonded

with air Production of non-woven in Europe (1995-2004) - source EDANA

Proposal of the consultant : For non-woven , to be discussed about new Criteria dealing with biodegradability and chemical bonding -


2) Annex –Framework- Assessment and verification requirements. Chapter 4 "at normal conditions (65 % RH + 2 %...) as specified in ISO 139 Textiles – Standard atmosphere for conditioning and testing". This ISO 139 standard has been revised and the tolerance for relative humidity is now + or - 4 % ; See ISO 139, part dealing with this evolution . See annex 10. Proposal of the consultant : To replace + 2 % for + 4 % for relative humidity: 65 % RH + 4 %. CRITERIA – TEXTILE FIBRE CRITERIA 1 – Acrylic

Economic situation of acrylic fibre consumption and production in Europe - tons (Source: CIRFS):

An historical presentation of this fibre has been written by CIRFS which is of interest for consumer members who are not necessarily aware of this question.

Acrylic fibres were first developed 50 years ago. From a generic point of view , acrylic fibres are composed of linear macromolecules having at least 85 % by mass of acrylonitrile units in the chain. Modacrylic fibres contain less than 85% of acrylonitrile. Acrylic fibres are one of the major fibre products, reaching a volume of more than 2,6 million tonnes world-wide, growing on a global basis but stable in the EU, USA and Japan. Acrylic


fibres are supplied in the form of staple or tow (apart from minor filament quantities in Japan) for end-uses based on outstanding properties. For textile applications, blends with either natural or man made fibres are often used. A variety of non-ionic co-monomers (4 -12 %) are added by manufacturers in order to lower the glass-transition temperature for easier processing and for dyeability reasons. In addition ionic co-monomers (0,5-1 %) are used for certain dyeing techniques. Fibres based on 100% acrylonitrile are destined for technical, non-textile end-uses. From a fibre manufacturing point of view , acrylic fibres are produced through wet spinning (80 % of total, using several solvents) or through dry spinning (using dimethylformamide as the solvent), from polyacrylic based polymers synthesised by free radical initiated polymerisation. The production and consumption of acrylic fibres in Europe can be considered as mature. This means that focus in the industry is on product/marketing specialisation and process efficiency. Investments into new installations consequently do not take place in Europe. The main technologies used in Europe are:

1. Emulsion/suspension polymerisation & wet spinning (solvents NaSCN, DMF, DMAc) 2. Suspension polymerisation & dry spinning (solvent DMF) 3. Solution polymerisation & wet spinning (solvent NaSCN) Discussions showed no real problem with this topic. There isn't any modification, the criterion is confirmed. Proposal of the consultant : No change 2 - Cotton and other natural cellulose seed fibres (including kapok)

Economic situation of cotton in Europe (tons): 2002 2003 2004 2005 Production UE-25 475 964 434 713 516 413 474.000 (Greece + Spain + Portugal) Imports Extra UE 860 327 682 395 520 298 444 107 Exports Extra UE 183 855 237 840 279 875 224 052 Apparent Consumption UE-25 1 152 436 879 268 756 836 694 055 Code NC 520100 Source : Eurocoton on DG Agriculture and Eurostat /CITH This table shows an important decrease of the apparent consumption of cotton in Europe between 2002 and 2005. This situation is due to the development of garments made of chemical


fibres (microfibres...) and other cellulose fibres (viscose, Lyocell...). But the European production of cotton is relatively stable even if there is a slight decrease between 2004 and 2005. Economic situation of cotton in the world (tons):

Selected statistics on cotton production for the major cotton producing countries (ICAC, season 2004/05).


Several comments coming from competent bodies:

Theme Competent body Comments Harmonization Danish competent

body

The flower has banned 20 pesticides and Oeko-tex has banned more than 50. It would be useful to have a greater degree of harmonisation between the two labels. Of course it is not possible to compare the results if the Oeko-tex test has been made on a coloured textile but if it has been made on raw fibres or yarn before wet treatment , the applicant should be allowed to use an Öko-tex certificate.

Organic cotton Danish competent body

To make a closer look into the use of organic cotton. Should it be obligatory or can we award producers using certified organic cotton?

Renewable resources

Lenzing There should be a bonus when the fibre comes from renewable resources (wood) and not from crude oil.

Several points have been discussed during the meeting: Concerning the pesticides list, it would be interesting to get closer to Oeko-Tex list in order to harmonise both labels. Moreover, the list has to be updated. The List of pesticides in the Oekotex standard 100 is: Name of pesticides

Present in the Ecolabel list

Present in the Oekotex list

Name of pesticides Present in the Ecolabel list


2,4,5-T X Endrine X X 2,4-D X Esfenvalerate X Azinophosmethyl X Fenvalerate X Azinophosethyl X Heptachlor X X Aldrin X X Heptachloroepoxide X Bromophos-ethyl X Hexachlorobenzene X X Captafol X X Hexachlorcyclohexane, α X X Carbaryl X Hexachlorcyclohexane, β X X Chlordane X X Hexachlorcyclohexane, δ X X chlorobenzilate X Lindane X Chlordimeform X X Malathion X Chlorfenvinphos X MCPA X Coumaphos X MCPB X Cyfluthrin X Mecoprop X Cyhalothrin X Metamidophos X X Cypermethrin X Methoxychlor X


DEF X Mirex X Deltamethrin X Monocrotophos X X DDD X Parathion X X DDE X Parathion-methyl X X DDT X X pentachlorophenol X Diazinon X Phosdrin/Mevinphos X Dichlorprop X phosphamidon X Dicrotophos X Propethamphos X X Dieldrin X X Profenophos X Dimethoat X Quinalphos X Dinoseb and salts X X Toxaphene X X Endosulfan, α X Trifluralin X Endosulfan, β X The Oekotex list proposes 54 pesticides and Ecolabel is concerned by 22 pesticides. Comparing with the Ecolabel list, 3 are listed in Ecolabel and not in Oekotex:

- chlorobenzilate - pentachlorophenol - phosphamidon

In Oekotex, the list takes into account the pesticides for all natural fibres. No difference is made between the fibres : on the contrary, the Ecolabel list is different for cotton or wool.

Take into account more organic cotton and increase the percentage The organic agriculture deals with a balance between the means and equipment used and the nature. The naming « organic » is controlled according to the European standard specification of the Regulation 2092/91 dated June 24th 1991 which determines 3 basic principles :

– Plots have to be organically grown during at least a period of conversion of 3 years before first harvesting,

– Growing is made without or with a minimum of chemical products : fertility is ensured through natural products ,

– Control of crop pest, diseases and weed has to comply with the following criteria : • Use of existing varieties • Use of low quantities of herbicide, fungicide and insecticide • Harvesting by hand if possible • Flame cultivation • Three course crop rotation

The organic cotton is growing according to the principles of organic agriculture: • It follows the principle of crop rotation : Lucerne / cereal / cotton, • It uses « Natural insecticides » : ladybugs and natural fertilizers : compost, liquid

manure, • It seems that the yield is equivalent,


According to the report coming from Organic Exchange: "Organic Cotton Market Report Spring 2006 - Executive Summary" During the past five years, the global organic cotton market experienced strong growth and robust expansion at the retail, manufacturing and farming level. Key findings include: • The number of brands and retailers offering their customers organic cotton products increased exponentially in North America, Europe and Japan from 2001 to 2005. In four years, the number of brands and retailers with significant organic cotton programs grew from 5 companies to more than 30. The number of small brands and retailers in North American, European and Asian markets has mushroomed from a few hundred to more than 1,200 companies by the end of 2005. • Estimated global retail sales of organic cotton products increased from $245 million in 2001 to $583 million in 2005, reflecting an annual average growth rate of 35%. • To meet growing demand for organic cotton products by brands and retailers, more manufacturers have entered the market and are offering organic cotton yarns, fabrics and finished goods. Manufacturer demand for organic cotton fibre increased from 5,720 metric tons in 2000 to 32,326 metric tons in 2005, an estimated annual average growth rate of 93%. • Many organic cotton farmers expanded production during this time and new organic cotton farming projects were developed. Organic fibre production increased dramatically during this time, from 6,480 metric tons in the 2000-01 harvest to 31,017 metric tons projected for the 2005-06 harvest, reflecting an average annual growth rate of 76%. • Market conditions are projected to tighten in the next three years. Forward planning, pre-plant contracting, increased technical, financial and marketing assistance for farmers, development of new farming projects and other actions can ensure supplies expand to meet projected demand in 2008 and beyond. From 2006 to 2008, growth is expected to accelerate at all levels. Specifically: • Brand and retail demand for organic cotton products is projected to increase by an average annual rate of 110% during this time, as companies continue to implement long term commitments to increase the use of organic cotton and new brands and retailers enter the market. • Estimated global retail sales are projected to grow to $2.6 billion by the end of 2008, reflecting a 116% average annual growth rate. • Manufacturer demand for organic cotton fibre is expected to grow to 99,662 metric tons in 2008, an average annual growth rate of 75%. • Organic cotton production is expected to expand in response to increased demand for organic cotton fibre. The scale and rate of growth will be determined by factors including the level of planning and forward contracting undertaken in specific supply chains, farmer access to technical, financial and marketing resources and support, the number of new farming projects developed and the number of organic food producers who decide to grow cotton in rotation with food crops.


The organic cotton is certified by an independent organisation who analyses the soil and inspects the harvesting.

Source: Report from Organic Exchange: "Organic Cotton Market Report Spring 2006 - Executive Summary"

The qualification « organic cotton » is valid if more than 95% of the cotton used complies with the EEC Regulation Nr.2092/91. It has been decided to organise a small Working Group on pesticides and organic cotton. Proposal of the consultant : Organic cotton still represents a narrow market, it could be restrictive to consider only organic cotton and to exclude classic cotton. The bonus is that using

organic cotton, the test of pesticides is no more necessary. A final decision will be made on this criterion after the working group meeting. This Working Group could also deal with pesticides. Criterion 3 : Elastane At the first meeting, 2 main topics were discussed:

(a)The criterion about organotin is not clear (b) The emission of aromatic diisocyanates is difficult to prove

Some comments coming from competent bodies:

Theme Competent body Comments Organotin CIRFS The criterion about organotin is no more relevant, it has

been phased out years ago.

Air emission of aromatic diisocyanate

Danish competent body

The requirement of 5 mg aromatic diisocyanates pr. kg fibre produced seems very high. The Danish CB had application with results much lower (0.005 mg/kg). The reason for this could be that it is not specified where the measurements should be done. It is free for the applicant to choose whether they will test in the chimney or inside the factory.

Elastane production has been increased for several years, mainly in USA and Asia. The world production was about 230 000 tons in 2005. It increased twofold between 2000 and 2005. Europe is an important consumer of elastane which is used today in a lot of garments and technical textiles.

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Evolution of world elastane production (tons) Source L'industrie textile - 2004


Proposal of the consultant : To remove criterion "organotin" according to CIRFS proposal. The measurement should be done in the chimney. Air emission of aromatic diisocyanates needs to be clarified. Criterion 4 : Flax and other bast fibres The world production of flax and other bast fibres has been increased since 2000. Economic situation of the production of flax and other bast fibres in the world -tons (Source: CIRFS):

Unit: '000 tons The COD criterion concerns the pool retting. At the first meeting, it has been proposed that it would be easier to have a limit rather than a reduction a percentage of COD or TOC. This subject has been discussed again at the second meeting. In France; according to the legislation (February 1998, the 2nd), textile firms can't discharge water containing more than 300 ppm COD in natural water (river for example). For water connected to a water treatment plant, the limit is 2000 ppm COD. Proposal of the consultant : For all the document :Try to put a quantified limit value for the COD (in natural water, in water plant treatment ) - The values need to be discussed. Criterion 5 : Greasy wool and other keratin fibres The market evolution of wool is the following: � 1990 : World Production = 1 994 024 tons clean � 2004 : World Production = 1 220 968 tons clean � 2005 : World Production = 1 228 169 tons clean (estimated)


Nowadays, wool represents about 2% of the world market of textile fibres and decreases every year. During the meeting, several points have been discussed:

Pesticides list:

Harmonization with Oeko-Tex list . Update the list .

The pesticide list for Oekotex is the same as the list for cotton. For Ecolabel , the list is different and the limit value is different. It depends of the nature of the pesticide. Name of pesticides

Present in the Ecolabel list


Name of pesticides Present in the Ecolabel list


2,4,5-T X Endrine X X 2,4-D X Esfenvalerate X Azinophosmethyl X Fenchlorphos X Azinophosethyl X Fenvalerate X X Aldrin X X Heptachlor X Bromophos-ethyl X Heptachloroepoxide X Captafol X Hexachlorobenzene X Carbaryl X Hexachlorcyclohexane, α X X Chlordane X Hexachlorcyclohexane, β X X Chlordimeform X Hexachlorcyclohexane, δ X X Chlorfenvinphos X X Lindane X X Chlorpyriphos X Malathion X Coumaphos X MCPA X Cyfluthrin X MCPB X Cyhalothrin X Mecoprop X Cypermethrin X X Metamidophos X DEF X Methoxychlor X Deltamethrin X X Mirex X DDD X X Monocrotophos X DDE X Parathion X DDT X X Parathion-methyl X Diazinon X X Pentachlorophenol Dichlorprop X Phosdrin/Mevinphos X Dichlorfenthion X Propethamphos X X Dicrotophos X Profenophos X Dieldrin X X Quinalphos X Diflubenzon X Toxaphene X Dimethoat X Triflumuron X


Dinoseb and salts X Trifluralin X Endosulfan, α X Endosulfan, β X The Oekotex list proposes 54 pesticides and Ecolabel is concerned by 20 pesticides. Comparing with Ecolabel list, 5 are listed in Ecolabel and not in Oekotex:

- Chlorobenzilate - Dichlorfenthion - Fenchlorphos - Pentachlorophenol - Triflumuron

Some competent bodies stress the problem connected with the tests methods which are not reliable. Private tests methods exist but they are very expensive and not communicated. According to the competent body, organo-chlorine pesticides such as lindane have not been used for several years .They are replaced by pyrethroïdes or other types. During scouring , pesticides are removed from the wool to the waste water. Residual traces of pesticides on wool are very difficult to detect and need very accurate and expensive equipment.

COD: It would be easier to have a limit rather than a reduction of percentage . In France; according to the legislation (February 1998, the 2nd), textile firms can't discharge water containing more than 300 ppm COD in natural water (river for example). For water connected to a water treatment plant, the limit is 2000 ppm COD. According to the BREF, scouring of wool can generate between 150 and 500 g/kg of COD in the waste water.

Take into account organic wool

Organic wool is coming from the sheep raised under strictly regulated conditions (organic food, no antibiotics or pesticides…) Producers have a lot of difficulties to comply with those criteria in large herds, the quantities of organic wool are consequently limited. Thought, untreated wool is more developed through a local network. Its objective is to promote an area by supporting the local wool and respecting the natural environment. Untreated wool follows some principles depending on the producer. These are some examples:

- No toxic pesticide treatment on the fleece - Biodegradable soap used during washing - No carbonizing (treatment using sulphuric acid) - Greasing with a vegetable oil - No heavy metal, toxic dye… for the later finishing treatments.


Proposal of the consultant For all the document: Try to put a quantified limit value for the COD (in natural water, in water plant treatment ) - The values need to be discussed Information on pesticides test method and its reliability needs to be precised, and the relevance of this test needs to be discussed (diverging points of view). Criterion 6 : Man made cellulose fibres Viscose fibres are made from regenerated cellulose. In the last decade production has stabilised at approximately 2,6 million tonnes world-wide (Europe : 600 thousand tons). Economic situation of cellulose fibres consumption and production in Europe - tons (Source: CIRFS):

An historical presentation of this fibre has been written by CIRFS: Viscose fibre is produced by dissolving cellulose through the xanthation process (reaction of alkali cellulose with carbon disulphide) and regeneration by means of wet spinning into a spinning bath-containing sulphuric acid and sulphates. It is preferably supplied to market end-uses (textile products and non woven) where the outstanding hydrophilic (moisture absorption) properties (for instance in direct contact with the skin or with mucous membranes) are relevant. In terms of quantities, the major viscose product is staple fibre and minor quantities are produced as filament in 100% articles for textiles like linings or industrial yarns like tyre cord.


In recent history in Europe textile viscose filament end-uses are receiving increased competition (resulting into phasing out of capacity) by cheaper competitive yarns based on polyester and polyamide, whereas viscose staple fibre and viscose tyre cord keep a strong position. Focus of viscose fibre producers activities in Europe for many years had been on process optimisations concerning efficiency as well as ecology and safety of work (emissions to the workplace and environment),but also on product (flame-retardant, bioactive for example through polymer modification) and end use specialisation (non woven). According to the "Environmental Assessment of Textiles" elaborated in 1997 by the Danish Environment Protection Agency, there are no reasons to have emission of AOX during the production of viscose. Only chlorinated bleaching can generate this type of emission. Proposal of the consultant : This criterion concerning AOX is about bleaching .So we propose to remove part (a) about AOX (to be included in part 16 "bleaching agents") Criterion 7 : Polyamide An historical presentation of this fibre has been written by CIRFS: Polyamide fibres have been developed worldwide into a large business, showing continuing growth at world level with output at over 4 million tons, but a mature market in Europe with an output of around 700.000 tons. A slight decrease in staple fibres quantities has been compensated by an increase in filament yarns, as a uniform global tendency. Polyamide fibres include the dominating PA 6 as well as PA66 but also other Polyamides like PA4.6, PA6.10, PA12 and the like are being marketed or developed. Typical market segments generally for Polyamide fibres are: apparel (hosiery / lingerie / knitting / outdoor protective textiles), carpets, industrial and technical products (air bags, coated fabrics, luggage, tarpaulins, ropes, monofilament yarns for brushes and filters, fishing nets),and tyres. Economic situation of polyamide fibres consumption and production in Europe - tons (Source: CIRFS):



Theme Competent body Comments N2O emission CIRFS The criterion is relevant for and happens during

monomer production. Can’t be traced and influenced by a fibre producer.

The implementation of the criterion about N2O emission is difficult. The level seems very high. The consensus should be to reduce the level for being more stringent. Process and N2O emissions

Oxidation of cyclohexanol-cyclohexanone by nitric acid leads to a production of adipic acid and N2O, about 0,3 T N2O for 1T of adipic acid.

At the end of 1990, France chose, in order to reduce N2O emissions, the technique of conversion to nitric acid (recycle) and nitrogen (removed in the air). This technique allowed to decrease N2O emissions of about 90 %.

Proposal of the consultant : This criterion concerns the chemical production of the monomer and can’t be controlled by the textile fibre producer. It makes sense to cancel this criterion. Criterion 8 : Polyester


An historical presentation of this fibre has been written by CIRFS: Polyester fibres have been developed and patented during the forties of the last century and were marketed from the fifties on, accounting now for the largest share of man made fibres with a global quantity above 25 million tons per year. Based on similar polymer technologies other important quantities are applied in packaging (bottles) and film end uses. Polyester fibres, covered by the generic description, are based on terephthalic acid with the differing glycols like butanediol, propylenglycol and the mainly used ethyleneglycol. Polyesters based on other acids like naphthalene dicarbolic acid (PEN fibres) or lactic acid (PLA fibres) are from a generic point of view different products. During the production of polyester, catalysts are used, they are heavy metal salts of cobalt and manganese, sodium bromide and antimony (III) oxide (used in the polycondensation step). Economic situation of polyester consumption and production in Europe - tons (Source: CIRFS):

Several points have been discussed:

To take into account other catalysts Emission of VOC seems very high



Theme Competent body Comments CIRFS Reduction of VOC seems not to be feasible

VOC emission

Danish competent body

The requirement of 1.2 g VOC kg fibre produced seems very high. The Danish CB have had to applications with results much, much lower (0.001 g/kg). The reason for this could be that it is not specified where the measurements should be done. It is free for the applicant to choose whether they will test in the chimney or inside the factory. Nor is the any information about how many and which VOC that should be tested for

According to measure realised in a polyester producer company, emission of VOC is very much higher than 1.2 g VOC/kg. The European legislation proposes a VOC Directive - 1999/13/CE (11 /03/1999)

• The aim: reducing of 57 % of VOC emissions due to the use of organic volatile solvents between 1990 and 2010.

• Several activities fields are concerned including Printing and Dry cleaning • The Directive is improved for all new installation and will improve for all current

installations at least in October 2007 the 31st.

VOC Directive: Limited value

Activity Limit value for consumption of

solvents ton/year

Limit value for emission

mgC/m3

Limit value for emission g/kg

Héliogravure, flexographie, impression sérigraphique en rotative, contrecollage ou vernissage (conso en solvant > 15 t/an)

15-25

> 25

100

100

20

20

Dry cleaning 20

Proposal of the consultant : The measurement should be done in the chimney and this criterion has to be discussed again in Phase 2 (diverging points of view).


Criterion 9 : Polypropylene World production of polyolefin fibres (over 95% PP fibres) expanded in 2004 by 2,2% or 140,000 tons to 3 million tons, whereby 47% were filament yarns, 20% staple fibres and 33% tapes (Table 5).

Proposal of the consultant Waiting for information from EATP: European Association for Textile Polyolefins Other fibres Polyethylene AFNOR received a request for extending the scope to polyethylene. According to the European decision, polyethylene is not excluded but there is no specific criterion. Polylactide This new fibre has been developed as a biodegradable one based on corn. The world production reaches 140 000 tons. Elastomultiester This new generic name has been published in 2006. It concerns a bi-component of two different polyesters with elastic properties: see criteria on Polyester.


Proposal of the consultant Add the sentence: " Some fibres such as silk, polyethylene or polylactide are not listed in this part: it means that there is no restriction to award them under the production criteria."

Process and chemicals criteria

Criterion 10 : Auxiliaries and finishing agents for fibres and yarns Several points have been discussed:

The biodegradability and elimination of auxiliaries and finishing agents (c) See lubricants Ecolabel


Theme Competent body Comments Biodegradation Danish body

competent

It seems that it is very difficult to find suitable spin finish to the production of polyester. Only very few of them are sufficiently biodegradable.

PAH Danish body competent

It is not possible to find a mineral oil with content of PAH less than 3%

This criterion refers to primary spinning which needs to be explained: Definition of Primary spinning: Chemical fibres are extruded in continuous filaments (Primary spinning), then they can be: • directly used; • cut in fibres with several sizes in order to spin with a process similar to cotton or wool. Some information on auxiliaries and finishing agents for fibres and yarns: They are put on the fibre during spinning and they are removed during pre-treatment of dying. They contribute to an important part of the emission of the pollution in water and air in the dying firms. These are: • lubricants, • emulsifying agents, • wetting agents, • antistatic agents, • other additives (for example biocidal agents, antioxidants…).


Specific information about spinning oil: The most used are the following: • mineral oils (coming from petroleum). They generate air emission during heat treatment.

Their biodegradability is difficult to obtain, they are removed by absorption. • Moreover, the presence of polyaromatic hydrocarbons (PAH) is a problem for the pollution of

water. The quantity depends on the process of refining. Mineral oil with pharmaceutical quality contains less than 0.1 ppm of polyaromatic hydrocarbons but they are three times more expensive than conventional oils.

• oils composed of esters (based on natural grease or oil). They are more stable in contact

with heat and are biodegradable. Their use is reducing, but they are used for low cost products because they are cheap. They begin to replace mineral oils in primary spinning, and are largely used during secondary spinning.

• synthetics oils (including synthetic esters, additives of ethylene or propylene oxide (EO/PO),

silicones.). They resist to high temperature (up to 200°C), then they are very stable in contact with heat. Some of them have a good biodegradability but some have a high molecular weight and are difficult to biodegradable. For example, silicones having the highest level of COD are very difficult to biodegradable. But they are bioeliminable. For them, APEO are used and an important percentage (about 40 %) remains on the fibre after washing ; what can causes emission in the air during heat treatment.

Biodegradability The Lubricants Ecolabel (Decision 2005/360/EC) proposes the following criteria: "Biodegradability and bioaccumulative potential: The product shall not contain substances that are both non-biodegradable , and (potentially) bioaccumulative. However, the product may contain one or more substances with a certain degree of degradability and potential or actual bioaccumulation up to a cumulative mass concentration as indicated in Table below.


A substance is considered ultimately biodegradable (aerobic) if: 1. In a 28-day biodegradation study according to OECD 301 A-F or equivalent tests, the following levels of biodegradation are achieved: — in OECD 301 tests based upon dissolved organic carbon : ≥ 70 %, — in OECD 301 tests based upon oxygen depletion or carbonic dioxide generation : ≥ 60 % of the theoretical maxima. 2. The BOD5/ThOD or BOD5/COD ratio is larger than 0,5. In the OECD test the 10-day window principle will not necessarily apply. If the substance reaches the biodegradation pass level within 28 days but not within the 10-day time-window, a slower degradation rate is assumed. A substance is considered inherently biodegradable if it shows: — a biodegradation > 70 % in the OECD 302 C test for inherent biodegradation or equivalent test method, or — a biodegradation > 20 % but < 60 % after 28 days in the OECD 301 tests based on oxygen depletion or carbon dioxide generation, or — biodegradation ≥ 60 % in ISO 14593 (CO2 headspace test). A substance whose primary function is thickening shall be considered inherently aerobically biodegradable if it shows a biodegradation higher than 20 % in the OECD 302 C for inherent biodegradation or equivalent test methods. All of the aquatic toxicity requirements shall then apply also to the degradation products, which have been scientifically proven to be derivates of the thickener, after exposure to the aquatic environment. A substance is non-biodegradable if it fails the criteria for ultimate and inherent biodegradability. A substance does not bioaccumulate if its MM > 800 or has a molecular diameter > 1,5 nm (> 15 Å). A substance with MM < 800 or molecular diameter < 1,5 nm (< 15 Å) does not bioaccumulate if: — the octanol-water partition coefficient log Kow < 3 or > 7, or


— the measured BCF is ≤ 100. Since most substances used in lubricants are quite hydrophobic the BCF-value should be based on the lipid weight content and care must be shown to ensure a sufficient exposure time." Proposal of the consultant : The sum of each compound is taken into account. To Increase the level of PAH (3%). For all the document, to include biodegradability criterion proposed by Lubricants Ecolabel. Criterion 11 : Biocidal or biostatic products Several points have been discussed:

Harmonization with Oeko-Tex list. To be in accordance with the Directive 98-8 CE.


Theme Competent body Comments Danish body competent

Instead of just banning them , the Flower should develop criteria for biocides and allowing the best ones.

Sanitized Antimicrobial finishes belong to the group of textile chemical which produce a positive change in the functional properties of textile fibres.

Introduce biocidal products

CIRFS Our members are strongly innovate in bioactive fibres and textiles, which means products that remains active during the use phase. We should develop criteria that allow certification of this product class. Reference can be made to certification rules for bioactive textile and fibres developed by Oeko-Tex some 3 years ago and the development and implementation of the Biocide Directive in Europe with including textile application.

According to BREF, mothproofing agents based on permethrine and on cyfluthrine (carpet sector) and some bioactive products can be very toxic for aquatic life.


Description of bioactive products There are several possibilities for bringing a bioactive functionality : • Spin treatment of polymer during extrusion of fibres and filaments. • Finishing . • New technologies of surface treatment: Micro-encapsulation, Grafting ,… Examples of bioactive fibres: Fibres anti bacteria, anti fungal, anti-dust mites. The active function is mainly based on triclosan, metals (sliver ions, copper sulphur, zinc) and pyrethrinoïde for some treatments. Directive 98/8/EC (presentation coming from Sanitized) Active substances which were on the market as biocides as of May 14, 2000, are considered to be ”existing ingredients” and all have to be reviewed within 10 years to determine whether or not they comply with the requirements of the directive. Biocidal Products will have to be authorised after the corresponding active is listed in Annex 1 of the Directive. Active substances not on the market at this date are considered to be ”new ingredients” and have to be authorised accordingly. The BPD categorises the active substances and biocidal products into product types (PT) depending their uses. The authorisation procedure for biocidal products requires a risk evaluation of all intended uses. Textiles treated with products containing active substances which are authorised under the BPD for this type of application can therefore be regarded as safe. The Oeko-Tex standard 100 concept is based on: Production Ecology This covers all of the stages of manufacture, from fibre production to the make-up of the finished article. The production processes should be environmentally sound, fulfilling suitable criteria such as air quality, effluent waste and noise generation. Human Ecology This deals with the influence of textiles in their next "environment", i.e., the consumer or end user of the products and addresses the screening of such products for any toxic substances that could potentially cause harm to the consumer. Disposal Ecology This is concerned with the disposal of a product once it has completed its useful working life-span, addressing suitable recycling methods as well as the natural biodegradability of the product. In 2001 Oeko-Tex decided to fundamentally restructure the regulation on bioactive and flame-retardant products.


Active chemical products will be assessed by independent toxicologists. The assessment is based on information, test reports, formulas , etc,… which have been provided by the manufacturers. The test reports considered for the assessment have been analysed and approved by accredited toxicological and/or dermatological institutes. Based on the results of these external assessments, the approved products are considered harmless to human health as long as they are appropriately used as designated and are listed in list of "Accepted Active Chemical Products". List of "Accepted Active Chemical Products"

Auxiliaries for biological active finish Name of the product Country Producer ACTIGARD® AM 23-13 CH Sanitized AG, Burgdorf AEM 5772 (Aegis Microbe Shield)

B Devan Chemicals NV, Ronse-Renaix

Antimicrobial AlphaSan RC 2000

USA Milliken Chemical, Spartanburg

Coopex 50 N F Kwizda France, Marly le Roi Eulan SPA 01 D Bayer Chemicals AG, Leverkusen GREENFIRST® anti-acariens PROFYL EK 16

F Breyner, Vienne

Guacil TX ROK SK Chemicals Co., Ltd, Seoul HEALTHGUARD™ PLB AU Global Speciality Chemicals, Campbellfield THEA-FLAN (30A, 30E) J ITO EN, LTD, Sizuoka-ken Troysan Polyphase P-100 NL Troy Chemical Company BV, Maasluis ULTRA-FRESH NM 100 CAN Thomson Research Associates, Toronto Proposal of the consultant: To delete the sentence point (b): " Biocidal or biostatic products shall not be applied to products ." The producer has to prove that the product complies with the requirements of the European Directive.


Criterion 12 : Stripping or depigmentation The evolution of the techniques for stripping and depigmentation has been discussed: Proposal of the consultant It needs to be clarified, waiting for more information from the Finishing Manufacturers . The criterion is not easy to be understood. Criterion 13 : Weighting According to producers, it seems that this criterion isn't still relevant. Proposal of the consultant: to delete the criterion Criterion 14 : Auxiliary chemicals Auxiliary chemicals are used for several reasons:

- To make the fabric hydrophilic for bleaching, dyeing, printing… - In some cases, to make the fabric hydrophobic: anti-dirt, impermeable treatment… - To neutralise grease or other chemical compounds.

We can have:

o Wetting agents o Detergents o Antifoam agents (Acetyl Glycol) o Dispersing agents (lignin sulfonates, products of condensation of sulfonates of naphthalene and

formaldehyde, copolymers of ethylene oxide / propylene oxide o Levelling agents o Sequestering agents o …

According to the type of the dyes and the process, we can use several auxiliary chemicals. They are not fixed on the fibres ; then they are removed in the waste water. According to BREF, some of them can generate a negative effect on environment. • Alkylphenolethoxylates (APEO) : they can be used in the formulation of tension-active

agents (detergents, wetting agents, levelling, etc.). Their metabolites (octylic phenols and nonylic) are very toxic for aquatic life, they are on the list of "Priority Substances" concerning by Directive on Water 2000/60/CE, and nonylic phenol is identified as "Priority hazardous Substance").

• Sequestering agents, as EDTA, DTPA et NTA. These agents can generate compounds very stable with metals and the biodegradability of EDTA and DTPA is very low.

Proposal of the consultant


To precise the kind of auxiliary chemicals (wetting agents, detergents...). To put in annex - for all the document - a list of risk phrases which are not allowed. Criterion 15 : Detergents, fabric softeners and complexing agents Some comments coming from competent bodies:

Theme Competent body Comments Risk phrases Danish body

competent

The risk phrases should be considered

Softeners are used to modify the touch of the fabric. They reduce the friction between fibres. They are either used in the dyeing machine just after rinsing, or as a finishing treatment, using a pad before the stenter. They can be added at the same time as other resin. Textile softeners are aqueous emulsions or dispersions of insoluble active substances such as:

- Non ionic or cationic - Paraffin and polyethylene waxes - Organic silicone components

The formulation of these softeners requires additives but European producers do not use APEO anymore. The use of non-ionic softeners ( such as fat acids or amides , esters) is increasing. They have no affinity for fibres. On the contrary, connected to their affinity, the cationic softeners give a more durable soft effect than the non-ionic products. Furthermore, they are more efficient at lower concentrations. The cationic agents used as softeners are:

- Quaternary ammonium components ( for instance dimethyl stearyle or distearyle ammonium).

- Components formed by the reaction of a fat acid with a polyamide . - Imidazolins that can be acetylised or added to ethylene oxyde.

The use of silicone based softeners is increasing: in addition of their softening effect, they give to the fabric waterproof properties. Most of time now, the pad treatment is preferred , using concentrate solutions that are entirely transferred to the fabric. If not, the softener is applied in the dyeing machine , using a diluted solution; part of it goes to the waste water: Fat acids are generally highly biodegradable. Cationic softeners are toxic for aquatic life. Silicone products are partly eliminated. Softeners are high molecular weighted chemical products ,so their volatility is poor. Some waxes or fat components may be thermally degraded in the stenter when high temperatures are used. Proposal of the consultant:To put in annex - for all the document - a list of risk phrases which are not allowed. The criterion needs to be clarified. Criterion 16 : Bleaching agents Including the same criterion for all cellulose has been discussed.



Theme Competent body Comments Origin of fibre LENZING The criteria is in favour of natural fibres.

We don't understand why the emission from linen, bast and cotton shall be less harmful than those from the fibre industry?

Chlorinated bleaching agents

Danish body competent

Chlorinated bleaching agents should be excluded.

Bleaching can be realised on all the presentation of the textile (fibres, all kind of fabrics). For cellulose fibres, the main chemical products used are the following : • hydrogen peroxide (H2O2), • sodium hypochlorite (NaClO): it can generate, in contact with organic compounds,

absorbable organohalogens compounds (AOX). • sodium chlorite (NaClO2): it generates chloride salts which are less toxic The consumption of chlorine products for bleaching has decreased, but they are still used for some applications (synthetic embroidery, cotton) , also for economical reasons. Proposal of the consultantThe limit on AOX needs to be discussed. The exclusion could only concern sodium hypochlorite . Criterion 17 : Impurities in dyes The evolution of the market has been discussed. Some comments coming from competent bodies:

Theme Competent body Comments Evolution Danish body

competent

All these criteria need to be looked upon and updated.

Impurities in dyes depend on the chemical type of the dyes. Dyes can include metals, they are used for two reasons: - they are catalysts during the production of some dyes and can appear as impurities. - the metal is including into the dye and gives a metal complex dye.


The main used metals in dyes are copper (reactive azo-dyes), nickel and chrome in metal dyes for wool, silk and polyamide. These dyes are used for some colours (green, pink) and mainly to obtain the best colour fastness especially to light. They are necessary and can't be replaced. The problem of metals in metal complex dyes is less important than the problem of impurities of free metal in dyes. In fact, using in good conditions metal complex dyes, only a very few quantity of dyes is removed in the waste water. Moreover, the metal is linked to the dye molecular and can't be separated from the molecule. And we have to take into account treatment of waste water: some treatments like filtration or actives sludge absorption remove the dyes from the waste water but other treatments can liberate the metal (like advanced oxidation). Proposal of the consultant: The criterion needs to be precised: waiting for more information from dyestuff manufacturers. Criterion 18 : Impurities in pigments The evolution of the market has been discussed. Pigments are not soluble into water and solvents. Organic pigments are mainly based on benzoic compounds. Inorganic pigments (mineral) are based on metals (titanium, zinc, barium, lead, iron, molybdenum, antimony, zirconium, calcium, aluminium, magnesium, cadmium or chrome). Proposal of the consultant: The criterion needs to be precised: waiting for more information from dyestuff manufacturers. Criterion 19 : Chrome mordant dyeing Chrome mordant dyes are normally not used anymore because of the toxicity of chromium except for some cases on wool. Proposal of the consultant : Confirmed Criterion 20 : Metal complex dyes Some comments coming from competent bodies:

Theme Competent body Comments Remove Danish body

competent

Metal complex dyes should be avoided even if some colours (pink and turquoise) cannot be labelled.

Discussion with several point of view:


- The problem of using metal complex dyes is that they contain heavy metals that are toxic in the environment. - But without them, it is difficult to obtain a range of special colours and shades like pink and turquoise. The main used metals in dyes are copper, nickel and chrome in metal dyes for wool, silk and polyamide. These dyes are used for some colours (green, pink) and mainly to obtain the best colour fastness especially to light, they are necessary and can't be replaced. If metal complex dyes are not allowed, it would lead to cancellation of 50% of dyes on wool and polyamide which are however the best qualities found at present time. Proposal of the consultant :We suggest to confirm the possibility of using metal complex dyes because one of the aim of this revision is to develop the Textile European Ecolabel and not to reduce its application field. Criterion 21 : Azo dyes Several points have been discussed:

New investigation on pigments . Use European Standard EN 14362-1 and 2.


Theme Competent body Comments To update Danish body

competent

All these criteria need to be updated

The directive 2002/61/EC of 19 July 2002 relating to restrictions on the marketing and use of certain dangerous substances and preparations (azodyes) gives the list of aromatic amines which are not allowed:



The criteria 21 lists exactly the same aromatic amines. But Oeko-Tex Standard 100 added recently 2 aromatic amines: 2,4-Xylidine (CAS number 87-62-7) and 2,6-Xylidin (CAS number 95-68-1) Proposal of the consultant : To add 2 aromatic amines: 2,4-Xylidine (CAS number 87-62-7) and 2,6-Xylidin (CAS number 95-68-1). To refer to European Standard EN 14362-1 and 2. Criterion 22 : Dyes that are carcinogenic, mutagenic or toxic to reproduction Oeko-Tex Standard 100 lists the dyestuffs classified to be carcinogenic. It's exactly the same list as Ecolabel one. Proposal of the consultant: Confirmed.


Criterion 23 : Potentially sensitising dyes 21 dyestuffs classified to be allergenous are included in the Oeko-Tex Standard 100 and only 18 are proposed by Ecolabel. The 3 potentially sensitising dyes included in Oeko-Tex and not in Ecolabel are the following:

- C.I. Disperse Blue 1 - C.I. Disperse Brown 1 - C.I. Disperse Yellow 3 But Disperse Blue 1 and Yellow 3 are already in criterion 22 and must not belong to criterion 23.

Proposal of the consultant: To add potentially sensitising dye: C.I. Disperse Brown 1. Criterion 24 : Halogenated carriers for polyester Normally, polyester is dyed at 130°C without carriers. But in some cases, in order to prevent from other fibres damages (wool), polyester is dyed at 100°C and needs a carrier to swell the fibre. Proposal of the consultant: Confirmed . Criterion 25 : Printing This criterion got a consensus confirmed in the Ad’hoc Working Group. Proposal of the consultant: Confirmed, according to the consensus reached at the last meeting. Criterion 26 : Formaldehyde Several points have been discussed:

Harmonization with Oeko-Tex Test and no declaration

Formaldehyde is naturally present in the environment and is coming from a lot of human activities. Its mainly sources are cars, tobacco, refineries... and textiles industries. Formaldehyde generates irritations on eyes, throat or skin depending to the concentrations.


Formaldhehyde is classified as toxic. It can be found in several applications:

• easy-care resins for cellulose • printing paste • varnish (buttons) • softeners

In the label Oekotex there are 4 classes:

- Class 1 (baby): no formaldehyde - Class 2 (contact with skin): 75 ppm - Class 3 (without contact with skin): 300 ppm - Class 4 (decoration material): 300 ppm

Proposal of the consultant: To make tests and not only a declaration . Replace "final fabric" by "on the sample" in the text. Harmonisation with Oeko-Tex: to be discussed (different points of view). Criterion 27 : Waste water discharges from wet processing Several points have been discussed:

The limit of COD (25g/kg) seems too high Precise the term "discharge"

The company is no responsible of the waste water when it is discharged by the communal water treatment plant. Proposal of the consultant: To revise To remove "Offsite": take into account only the waste water coming from the company. To remove "surface" in the sentence "surface water" . Criterion 28 : Flame retardants There are now new technologies . So at first there should be a checking related to these new processes. Flame retardant agents are more and more important in the market and they are obligatory for some articles (protection garments, decoration materials for collectivities). Flame retardant agents have to protect textile against combustion without modifying the touch, colour and appearance of the fabric. They are mainly used on cotton and synthetic fibres.


Flame retardant properties can be added by a lot of chemical products: they are used as an additive agent or they can be combined to the textile. Several others approaches are used to obtain these properties: • To add chemical products during the primary spinning, • To develop modified fibres with intrinsic flame retardant proprieties • To coat one face of a textile with flame retardant products. In Oeko-Tex there are two lists: one for products and a second for fibres. Several points have been discussed:

Harmonization with Oeko-Tex See the evolution on new technologies

There is a risk on the human health if the chemical substance is not included in the heart of the fibres. Criteria are concerning only fabric, not fibres and yarns We have to make a difference between durable and not durable treatment. For durable treatments, flame retardant agents react with the fibre and allow a permanent property. It is different with not durable treatment because the agent is removed during the washing. Then they are applied on fabrics that are not washed, or that can be treated during each washing. The flame retardant agents are mainly: • inorganic compounds

They are salts soluble into water (diammonium phosphate, aluminium sulphate, ammonium sulphate, etc).The treatment is not durable. Other substances can be used: zirconium (the most used) or titan salts. These salts do not generate a significant pollution on water.

• halogen organic compounds (Brome compound), • organophosphors compounds,

Some products included in these substances classes (for example pentabromodiphenylether, chloroparaffins C10-13) have been identified as "Hazardous Priority Substances” because of their toxicity, their property to be persistent and to be bio-accumulable, or they have been concerned by the Regulation (CEE) 793/93, which is about the assessment and the management of risks of actual substances.



Theme Competent body Comments Technologies CIRFS

2 existing basic technologies: - based on fabric finishing with FR chemicals - based on fibres with intrinsically FR properties. The restriction in the existing criteria is relevant for the fabric finishing technology and not for fibres based on polymerisation.

Proposal of the consultant: To limit flame retardants to those which are accepted under the positive European list in harmful substances directive. To remove phrase risk list and put it in annex. To change the position of this criterion and insert it after the criterion 11 "Biocidal or biostatic products". Criterion 29 : Shrink resistant finishes According to the text, halogenated shrink-resistant substances or preparations shall only be applied to wool carded slivers. During the first meeting the term "Anti felting" has been proposed: This treatment is used to prevent wool from felting and make it washable in a washing-machine. It is mainly applied on combed wool slivers but also on loose wool. The process which combines a chemical oxidant treatment and a resin is the most used for the moment. The chemical treatment is traditionally realised using chlorine agents. These agents may react with other components and form AOX. That is the reason why alternative treatments have been developed ( peroxysulfate, enzymes…). Then, polymers are applied on the surface of fibres in order to mask the scales with a film. The resins are also responsible for AOX in wastewater because the fabrication process involves epichlorhydrine. Proposal of the consultant: Limit of AOX in waste water: to be discussed if necessary for carded wool or combed wool . Replace " Shrink resistant" for "Anti felting" Replace "carded" for "combed" and add "loose wool". Criterion 30 : Finishes At first to precise the definition of finishes it is important to connect this criteria with the biocide directive The hurdle of 0,1% seems stringent related the risk “dangerous for the environment”.


Several points have been discussed:

Define what kind of finishes. Put the risk phrases list in the Annex. 0.1% by weight is appropriated?

The word “finishes” covers all treatments that are likely to give to the textile fabrics the final properties requested: visual effect, touch, some specific characteristics such as waterproof or easy care. Some of them are dedicated to some fibre types: easy care for cellulose fibres, anti static for synthetic fibres, anti felting or anti moths for wool. Generally, the treatment is realised as a separate operation after dyeing ( but the treatment against moths for instance is added to the dyeing bath) The finishing solution or aqueous dispersion is applied with pad technologies and transferred onto the fabric. Then, it is dried and polymerised in a stenter.

Some comments about fabric finishes: 0.1% by weight isn't appropriated because some substances are toxic if their quantity is very low (less than 1%) and others are toxic at a higher level. It's depend of the substances. In the Safety Data Sheets, information on chemical substances are given if the chemical formula contains more than 0.1% of these chemical substances. Proposal of the consultant: To keep 0.1% by weight Put the risk phrases list in the Annex Criterion 31 : Fillings Proposal of the consultant: To harmonise with mattress Ecolabel but didn’t got the information when writing this report .It will be introduced as soon as available . Criterion 32 : Coatings, laminates and membranes Coating: A textile is covered by a resin which is turned into a coating film Laminates: A film or a foam is associated with a textile using a glue (can be several layers) Membranes: An example of laminate with a breathable synthetic film. Two main kind of coating products on the market:

- vinyl products - polyurethane

Some other applications exist which are more expensive: - silicones


- Teflon... Several points have been discussed:

To extend the scope (Teflon, outdoor textile): some people are against inclusion of Teflon because of its toxicity .

Is antimony still used in the Polyester membranes? Polyester membrane is not made with antimony: this criteron concerns the production of the polymer. In the same way, organo tin and aromatic diisocyanate emissions concern the production of polyurethane. Proposal of the consultant: Put the risk phrases list in the Annex The criteria 32a and 32 b are not relevant because they concern the polymers production and not the coated application. The scope needs to be clarified because of including or not Teflon . Criterion 33 : Energy and water use Some competent bodies proposed to add limits on water or energy consumption. The problem is that the consumption is so variable: it depends on the activity, the size of the company, the localisation... Proposal of the consultant: To be clarified: diverging points of view and decision at the next meeting.

Fitness for use Criterion 34 : Dimensional stability during washing and drying The indication of the shrinkage must be labelling if it does not fit the tolerances: is it relevant and what does it mean for the consumer? Proposal of the consultant: To refer to European standard: Add EN ISO 6330: Domestic washing and drying method Not to allow the products whose results are out of the tolerances. Criterion 35 : Colour fastness to washing Proposal of the consultant: To refer to European standard: EN ISO 105-C06.


Criterion 36 : Colour fastness to perspiration Why wool and silk should be considered differently from other fibres? A level of 3 for perspiration is generally not admitted in the main specifications. Proposal of the consultant: To refer to European standard: EN ISO 105-E04. To keep level 3-4 for all kinds of products . Criterion 37 : Colour fastness to wet rubbing The level 2-3 is too low and does not refer in general to good quality products. An exception must be made for denim and pigment printed fabrics. Proposal of the consultant: To refer to European standard: EN ISO 105-X12. To propose:

- a general level of 3-4 and - 2-3 for denim and pigment printing fabrics.

Criterion 38 : Colour fastness to dry rubbing Proposal of the consultant: To refer to European standard: EN ISO 105-X12. To add "pigment printed fabrics" for the level 3-4. Criterion 39 : Colour fastness to light This criterion is only relevant to products exposed to light. Proposal of the consultant: To refer to European standard: EN ISO 105-B02. To propose this criterion only to products exposed to light. Criterion 40: information appearing on the label Box 2 must be changed Proposal of the consultant: To be clarified: write at least one criterion


New criteria Some new criteria have been proposed:

- Health and safety - Management criteria as staff training or staff awareness - Ethical notion

Proposal of the consultant: Ethical notion is not in European Commission Regulation and considered as not workable for the moment, under Euratex position. The other ones are not directly concerned by Ecolabel criteria.


Conclusion

Most of the studied above criteria need to be revised, as agreed by the Ad hoc Working Group members.

As a result, the consultant proposes to engage phase 2.


ANNEX LIST

1 - Composition of the Ad Hoc Working Group 2 - Agenda for the first meeting in Paris - 03/27/2006 3 - Introduction Report for the Paris meeting 4 - Power Point presentation during the meeting in Paris 5 - Minutes of the meeting in Paris 6 - Examples of replies and comments after the first meeting used at the second meeting 7 - Agenda for the second meeting in Brussels: 10/03/2006 8 - Power Point presentation during the meeting in Brussels 9 - Minutes of the meeting in Brussels 10 - ISO 139 - Part presenting the new tolerance for relative humidity: +/- 4%


Annex 1

Composition of the Ad'Hoc Working Group

51N:\SECRETARIAT\RB\IFTH\Ecolabel Textile Européen\REport3rdof (dernière version 22 11 06).doc





Annex 2

Agenda for the first meeting in Paris -

03/27/2006


REVISION OF THE ECOLABELLING CRITERIA FOR TEXTILES PRODUCTS The first meeting will take place in :

AFNOR 11 rue Francis de Pressensé St Denis la Plaine 93 (RER B St Denis la plaine stade de France)

date: March 27th 2006, 10am- 4 pm draft Agenda

1. Introduction 2. Scope of the contract and time schedule 3. Presentation of the present European ecolabel 4. Market situation for textiles 5. Discussion on each actual criteria : round table and opinions of the

participants 6. Conclusions on criteria to be revised and time table 7. Any other business


Annex 3

Introduction Report for the Paris meeting

03/27/2006


FIRST MEETING OF THE WORKING GROUP TEXTILES PRODUCTS THIRD REVISION

Paris 27TH of March 2006


THE EUROPEAN ECOLABEL ON TEXTILE PRODUCTS The European Ecolabel on textile products is now under revision and AFNOR has been chosen by the European Commission to conduct this revision. Since 1992, only 67 certificates have been delivered in Europe: DK (27), IT (11), FR, SE (7), ES, EL (3), DE (2), UK,PT, NO, FI, CZ, B (1) mainly for textiles for interior and clothes, some products for protective wear fabrics and other uses. This label is not really successful in the textile industry and the revision should help to increase its development and to convince the textile industry to get more involved Economic situation The European Textile and Clothing industry has a longstanding tradition of leadership in terms of innovation, fashion and creativity, and despite increasingly fierce global competition and significant relocation of manufacturing to low-wage countries; it continues to represent one of Europe’s major industrial sectors with an annual turnover of 215 billion Euro and a total workforce of 2.6 million in 20031. It is a major player in world trade, the first in textile exports and the third in clothing. With a total of more than 110,000 companies in the EU, of which some 95 % are SMEs, it covers a fascinating industrial landscape, producing a myriad of different consumer and industrial products, using countless knowledge intensive and highly specialised production processes and related technologies. In the textiles area, Europe has maintained a degree of competitiveness, which has been enhanced by innovative products and processes in particular in the growing field of technical textiles, covering end-uses in transportation, road-building, land-reclamation, housing, sporting equipment, protective wear, surgical and medical devices and others.


The major end-use however still remains apparel where European manufacturers have led the world in terms of fashion and creativity, across all forms of clothing. Nonetheless, in comparison to the spinning and weaving of textiles, clothing manufacturing is highly labour-intensive, and steps are urgently needed to overcome this disadvantage as compared to lower wage countries. While labour cost disadvantages are the most notable challenge to be overcome by the European industry if it is to retain its leading edge in global competition, there are a great number of other equally challenging conditions that the industry currently faces. These include trade barriers in certain important export markets, strict environmental and safety legislation imposed by European political will but not adequately rewarded by European consumer choice; a growing shortage of qualified human resources. In the context, the European Textile Ecolabel is a differentiation factor for the European companies. To develop this Ecolabel, a public communication will be taken place and the European Commission is answering if a revision is necessary. Comparison between Oeko-tex Standard 100 and Ecolabel Since 1992, about 50 000 Oeko-tex certificates have been attributed to about 6500 companies in 68 countries. This pure textile label is the most developed in the world. The above tables compare the Ecolabel and the Oeko-tex criteria.

ECOLABEL OEKO-TEX

INTEREST Toxicological and environmental parameters

Toxicological parameters

APPLICATION FIELD

Textile clothing and accessories Home textile Yarns, fibres Fabrics

4 products classes: I: babies II: direct contact to skin III: without direct contact to skin IV: decoration material

CERTIFICATION PROCESS

Organism: chosen by the European Commission Admission / Renewal

• Audit in some countries • Product tests and declarations• Process tests and

declarations

Organism: Oeko-tex Association Member Admission

• Audit in some countries • Product tests

Renewal

• Product tests

N:\SECRETARIAT\RB\IFTH\Ecolabel Textile Européen\REport3rdof (dernière version 22 11 06).doc

PRODUCT TESTS ECOLABEL OEKO-TEX pH X

Formaldehyde X X Heavy metals / Organotin compounds

X X

Pesticides X X Chlorinated phenols X Phtalates X Arylamines (dyes) X X Carcinogen dyes X (same criteria) Allergen dyes X X Chlorinated benzene and toluene (carrier) X X Biological active products X X Flame retardant products X X Colour fastness X X VOCs: Volatile organic components X X Determination of odours X

Moreover, the European Textile Ecolabel takes into account a lot of criteria concerning process and chemical parameters. European regulations Since 2000, some new regulations have been published ,directly or indirectly linked withproducts :

First, there is a general requirement on security; the directive 92/59 hasuperseded by the directive 2001/95. This regulation requires a producer or a rmarket reliable products. The basic intent of this text is to define a reliable prodproduct that conforms to the relevant standards.

Some standards have been developed under a mandate given to CEN by the E

Commission. This is the case of the EN 14682 standard: Safety of children’s Cords and drawstrings on children’s clothing – Specifications. which has been pin December 2004 .

Even if the product test is taken into account by European Ecolabel and Oeko-tex, they are different: on the test method or on the limit value

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Another standard should be published in the same way within this year, the EN 14872: Burning behaviour of nightwear: Requirements and Specifications.

Then there is the directive 2002/61 concerning the interdiction of dyes which are capable

of releasing one of the 22 amines listed in the Directive and considered as carcinogenic.

The directive 94/27 regulates the quantity of nickel that could be released by products which are in direct contact with the skin.

The Integrated Pollution and Control named IPPC directive 96/61 deals with the

reduction of the pollution in the industrial plants. Since October 1999, new plants have been subjected to these requirements. In October 2007, existing plants will be subjected too.

Lastly, in December 2005, six kinds of phtalates have been prohibited for toys and child

use and care articles that can be put in mouth ( Directive 2005/84). Objectives of the Ecolabel revision The main objectives of this third revision are:

1. -to update the scope of the textile Ecolabel and the existing criteria 2. -to take the new regulations or mandated standards into account

3. -to create a synergy between Oeko-tex and Ecolabel in order to facilitate the access to

the applicants

4. -to take new criteria under consideration, especially as far as environment and sustainable development are concerned.


Annex 4

Power Point presentation during the meeting in Paris

03/27/2006


27th of March 2006 1st working group 3rd revision

THE EUROPEAN ECOLABEL TEXTILES PRODUCTS

3rd revision



THE EUROPEAN ECOLABELTEXTILE PRODUCTSLAST DATA NOVEMBER 2005

67 licensees

DK (27), IT (11), FR, SE (7), ES, EL (3), DE (2), UK,PT, NO, FI, CZ, B (1)

Mainly for textiles for interior and clothes; some productsfor protective wear fabrics and other uses



THE EUROPEAN ECOLABELTEXTILE PRODUCTSThe product group ‘textile products’ shall comprise:

Textile clothing and accessories: clothing and accessories (such as handkerchiefs, scarves, bags, shopping bags, rucksacks, belts etc.) consisting of at least 90 % by weight of textile fibres;Interior textiles: textile products for interior use consisting of at least 90 % by weight of textile fibres. Wall and floor coverings are excluded;Fibres, yarn and fabric: intended for use in textile clothing and accessories or interior textiles.

For ‘textile clothing and accessories’ and for ‘interior textiles’:down, feathers, membranes and coatings need not be takeninto account in the calculation of the percentage of textilefibres.

Revised Confirmed Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTS1. Acrylic

(a) The residual acrylonitrile content in raw fibres leaving the fibre production plant shall be less than 1,5 mg/kg.

(b) The emissions to air of acrylonitrile (during polymerisation and up to the solution ready for spinning), expressed as an annual average, shall be less than 1 g/kg of fibre produced




THE EUROPEAN ECOLABELTEXTILE PRODUCTS2.Cotton and other natural cellulosic seed fibres (including

kapok)

Cotton and other natural cellulosic seed fibres (hereinafter referred to as cotton) shall not contain more than 0,05 ppm (sensibility of the test method permitting) of each of the following substances :aldrin, captafol, chlordane, DDT,dieldrin,endrin,heptachlor,hexachlorobenzene,hexachlorocyclohexane (total isomers),2,4,5-T,chlordime-form, chlorobenzilate, dinoseb and its salts, monocrotophos, pentachlorophenol, toxaphene, methamidophos, methylparathion, parathion, phosphamidon.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS3.Elastane

(a)Organotin compounds shall not be used.

(b)The emissions to air of aromatic diisocyanates during polymerisation and spinning, expressed as an annual average, shall be less than 5 mg/kg of fibre produced.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS4.Flax and other bast fibres (including hemp, jute, and ramie)

Flax and other bast fibres shall not be obtained by water retting, unless the waste water from the water retting is treated so as to reduce the COD or TOC by at least 75 %for hemp fibres and by at least 95 %for flax and the other bast fibres.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS5.Greasy wool and other keratin fibres (including animal hair from

camel, alpaca, goat...)

(a)The sum total content of the following substances shall not exceed 0,5 ppm :ã -hexachlorocyclohexane (lindane), á -hexachlorocyclohexane,â -hexachlorocyclohexane,ä -hexachlorocyclohexane,aldrin,dieldrin,endrin,p,p'-DDT, p,p'-DDD.

(b)The sum total content of the following substances shall not exceed 2 ppm:diazinon,propetamphos,chlorfenvinphos,dichlorfenthion,chlorpyriphos,fenchlorphos.

(c)The sum total content of the following substances shall not exceed 0,5 ppm:cypermethrin,deltamethrin, fenvalerate,cyhalothrin,flumethrin.

(d)The sum total content of the following substances shall not exceed 2 ppm:diflubenzuron,triflumuron.

.Revised Confirmed Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTS6.Man-made cellulose fibres (including viscose, lyocell, acetate,

cupro, triacetate)

(a)The level of AOX in the fibres shall not exceed 250 ppm.

(b)For viscose fibres, the sulphur content of the emissions of sulphur compounds to air from the processing during fibre production, expressed as an annual average, shall not exceed 120 g/kg filament fibre produced and 30 g/kg staple fibre produced. Where both types of fibre are produced on a given site, the overall emissions must not exceed the corresponding weighted average.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS6.Man-made cellulose fibres (including viscose, lyocell,

acetate, cupro, triacetate)

(c)For viscose fibres,the emission to water of zinc from the production site,expressed as an annual average,shall not exceed 0,3 g/kg.

(d)For cupro fibres,the copper content of the effluent water leaving the site,expressed as an annual average,shall not exceed 0,1 ppm.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS7.Polyamide

The emissions to air of N2O during monomer production, expressed as an annual average,shall not exceed 10 g/kg polyamide 6 fibre produced and 50 g/kg polyamide 6,6 produced.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS8.Polyester

(a)The amount of antimony in the polyester fibres shall not exceed 260 ppm. Where no antimony is used, the applicant may state ‘antimony free ’(or equivalent text) next to the eco-label.

(b)The emissions of VOCs during polymerisation of polyester, expressed as an annual average, shall not exceed 1,2 g/kg of produced polyester resin.(VOCs are any organic compound having at 293,15 K a vapour pressure of 0,01 kPa or more, or having a corresponding volatility under the particular conditions of use).




THE EUROPEAN ECOLABELTEXTILE PRODUCTS9.Polypropylene

Lead-based pigments shall not be used.




THE EUROPEAN ECOLABELTEXTILE PRODUCTSPROCESSES AND CHEMICALS CRITERIA

The criteria in this section apply, where appropriate, to all stages of production of the product, including the production of the fibres. It is nevertheless accepted that recycled fibres may contain some of the dyes or other substances excluded by these criteria, but only if they were applied in the previous life-cycle of the fibres.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS10.Auxiliaries and finishing agents for fibres and yarns(a)Size: At least 95 %(by dry weight) of the component substances of any sizing

preparation applied to yarns shall be sufficiently biodegradable or eliminable in wastewater treatment plants, or else shall be recycled.

(b) Spinning solution additives, spinning additives and preparation agents for primary spinning (including carding oils, spin finishes and lubricants):At least 90 %(by dry weight) of the component substances shall be sufficiently biodegradable or eliminable in waste water treatment plants.

This requirement does not apply to preparation agents for secondary spinning (spinning lubricants, conditioning agents),coning oils, warping and twisting oils, waxes, knitting oils, silicone oils and inorganic substances.

(c)The content of polycyclic aromatic hydrocarbons (PAH) in the mineral oil proportion of a product shall be less than 1,0 % by weight.

. Revised Confirmed Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTS11.Biocidal or biostatic products

(a)Chlorophenols (their salts and esters),PCB and organotincompounds shall not be used during transportation or storage of products and semi-manufactured products.

(b)Biocidal or biostatic products, active during the use phase, shall not be applied.

.Revised Confirmed Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTS12.Stripping or depigmentation

Heavy metal salts (except of iron) or formaldehyde shall not be used for stripping or depigmentation.

.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS13.Weighting

Compounds of cerium shall not be used in the weighting of yarn or fabrics.

.

.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS14.Auxiliary chemicals

Alkylphenolethoxylates (APEOs), linear alkylbenzene sulfonates(LAS), bis (hydrogenated tallow alkyl) dimethyl ammonium chloride (DTDMAC), distearyl dimethyl ammonium chloride (DSDMAC), di(hardened tallow) dimethyl ammonium chloride (DHTDMAC), ethylene diamine tetra acetate (EDTA), and diethylene triamine penta acetate (DTPA) shall not be used and shall not be part of any preparations or formulations used.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS15.Detergents,fabric softeners and complexing agents

At each wet-processing site, at least 95 % by weight of the detergents, at least 95 %by weight of fabric softeners and at least 95 % by weight complexing agents used shall be sufficiently degradable or eliminable in wastewater treatment plants.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS16.Bleaching agents

In general, AOX emissions in the bleaching effluent shall be less than 40 mg Cl/kg.In the following cases,the level shall be less than 100 mg Cl/kg:

— flax and other bast fibres,— cotton, with a degree of polymerisation below 1 800,and which is

intended for white end products.This requirement does not apply to the production of man-made

cellulose fibres.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS17.Impurities in dyes

The levels of ionic impurities in the dyes used shall not exceedthe following:Ag 100 ppm; As 50 ppm; Ba 100 ppm; Cd 20 ppm; Co 500 ppm; Cr 100 ppm; Cu 250 ppm; Fe 2 500 ppm; Hg 4 ppm; Mn 1 000 ppm; Ni 200 ppm; Pb 100 ppm; Se 20 ppm; Sb50 ppm; Sn 250 ppm; Zn 1 500 ppm.

Any metal that is included as an integral part of the dye molecule (e.g.metal complex dyes, certain reactive dyes, etc.) shall not be considered when assessing compliance with these values, which only relate to impurities.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS18. Impurities in pigments

The levels of ionic impurities for pigments used shall not exceed the following: As 50 ppm; Ba 100 ppm, Cd 50 ppm; Cr 100 ppm; Hg 25 ppm; Pb 100 ppm; Se 100 ppm; Sb 250 ppm; Zn 1 000 ppm.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS19.Chrome mordant dyeing

Chrome mordant dyeing is not allowed.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS20.Metal complex dyes.If metal complex dyes based on copper, chromium or nickel are used:

(a) In case of cellulose dyeing, where metal complex dyes are part of the dye recipe, less than 20 % of each of those metal complex dyes applied (input to the process) shall be discharged to waste water treatment (whether on-site or off-site).

In case of all other dyeing processes, where metal complex dyes are part of the dye recipe, less than 7 % of each of those metal complex dyes applied (input to the process) shall be discharged to waste water treatment (whether on-site or off-site).

(b)The emissions to water after treatment shall not exceed: Cu 75 mg/kg (fibre,yarn or fabric); Cr 50 mg/kg; Ni 75 mg/kg.

. Revised Confirmed Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTS21.Azo dyesAzo dyes shall not be used that may cleave to any one of the following

aromatic amines:

4-aminodiphenyl (92-67-1), Benzidine (92-87-5), 4-chloro-o-toluidine (95-69-2)2-naphthylamine (91-59-8), o-amino-azotoluene (97-56-3), 2-amino-4-nitrotoluene (99-55-8)p-chloroaniline (106-47-8), 2,4-diaminoanisol (615-05-4), 4,4'-diaminodiphenylmethane (101-77-9)3,3'-dichlorobenzidine (91-94-1), 3,3'-dimethoxybenzidine (119-90-4), 3,3'-dimethylbenzidine (119-93-7), 3,3'-dimethyl-4,4'-diaminodiphenylmethane (838-88-0), p-cresidine (120-71-8), 4,4'-methylene-bis-(2-chloraniline)(101-14-4), 4,4'-oxydianiline (101-80-4), 4,4'-thiodianiline (139-65-1)o-toluidine (95-53-4), 2,4-diaminotoluene (95-80-7), 2,4,5-trimethylaniline (137-17-7)4-aminoazobenzene (60-09-3), o-anisidine (90-04-0).




THE EUROPEAN ECOLABELTEXTILE PRODUCTS22.Dyes that are carcinogenic, mutagenic or toxic for reproduction

(a)The following dyes shall not be used:

C.I.Basic Red 9C.I.Disperse Blue 1C.I.Acid Red 26C.I.Basic Violet 14C.I.Disperse Orange 11C.I.Direct Black 38C.I.Direct Blue 6C.I.Direct Red 28C.I.Disperse Yellow 3




THE EUROPEAN ECOLABELTEXTILE PRODUCTS22.Dyes that are carcinogenic, mutagenic or toxic for reproduction(b) No use is allowed of dye substances or of dye preparations containing

more than 0,1 % by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):

R40 (limited evidence of a carcinogenic effect),R45 (may cause cancer),R46 (may cause heritable genetic damage),R49 (may cause cancer by inhalation),R60 (may impair fertility),R61 (may cause harm to the unborn child),R62 (possible risk of impaired fertility),R63 (possible risk of harm to the unborn child),R68 (possible risk of irreversible effects),as laid down in Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws,

regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances (1 ), and its subsequent amendments.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS23.Potentially sensitising dyes

The following dyes shall only be used if the fastness to perspiration (acid and alkaline) of the dyed fibres, yarn or fabric is at least 4

C.I.Disperse Blue 3 C.I.61 505C.I.Disperse Blue 7 C.I.62 500C.I.Disperse Blue 26 C.I.63 305C.I.Disperse Blue 35C.I.Disperse Blue 102C.I.Disperse Blue 106C.I.Disperse Blue 124C.I.Disperse Orange 1 C.I.11 080C.I.Disperse Orange 3 C.I.11 005C.I.Disperse Orange 37C.I.Disperse Orange 76

(previously designated Orange 37)C.I.Disperse Red 1 C.I.11 110C.I.Disperse Red 11 C.I.62 015C.I.Disperse Red 17 C.I.11 210C.I.Disperse Yellow 1 C.I.10 345C.I.Disperse Yellow 9 C.I.10 375C.I.Disperse Yellow 39C.I.Disperse Yellow 49




THE EUROPEAN ECOLABELTEXTILE PRODUCTS24.Halogenated carriers for polyester

Halogenated carriers shall not be used.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS25.Printing

(a)Printing pastes used shall not contain more than 5 %volatile organic compounds (VOCs :any organic compound having at 293,15 K a vapour pressure of 0,01 kPa or more, or having a corresponding volatility under the particular conditions of use).

(b)Plastisol-based printing is not allowed.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS26.Formaldehyde

The amount of free and partly hydrolysable formaldehyde in the final fabric shall not exceed 30 ppm for products that come into direct contact with the skin, and 300 ppm for all other products.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS27.Waste water discharges from wet-processing

(a)Waste water from wet-processing sites (except greasy wool scouring sites and flax retting sites) shall, when discharged tosurface waters after treatment (whether on-site or off-site),have a COD content of less than 25 g/kg, expressed as an annual average.

(b)If the effluent is treated on site and discharged directly to surface waters, it shall also have a pH between 6 and 9 (unless the pH of the receiving water is outside this range) and a temperature of less than 40 °C (unless the temperature of the receiving water is above this value).




THE EUROPEAN ECOLABELTEXTILE PRODUCTS28.Flame retardantsNo use is allowed of flame retardant substances or of flame retardant preparations

containing more than 0,1 % by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):

R40 (limited evidence of a carcinogenic effect),R45 (may cause cancer),R46 (may cause heritable genetic damage),R49 (may cause cancer by inhalation),R50 (very toxic to aquatic organisms),R51 (toxic to aquatic organisms),R52 (harmful to aquatic organisms),R53 (may cause long-term adverse effects in the aquatic environment),R60 (may impair fertility),R61 (may cause harm to the unborn child),R62 (possible risk of impaired fertility),R63 (possible risk of harm to the unborn child),R68 (possible risk of irreversible effects),as laid down in Directive 67/548/EEC and its subsequent amendments.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS29.Shrink resistant finishes

Halogenated shrink-resist substances or preparations shall only be applied to wool slivers.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS30.Finishes

No use is allowed of finishing substances or of finishing preparations containing more than 0,1 %by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):





THE EUROPEAN ECOLABELTEXTILE PRODUCTS31.Fillings

(a)Filling materials consisting of textile fibres shall comply with the textile fibre criteria (Nos 1 —9) where appropriate.

(b)Filling materials shall comply with criterion 11 on ‘Biocidal or biostatic products ’and the criterion 26 on ‘Formaldehyde ’.

(c)Detergents and other chemicals used for the washing of fillings (down,feathers,natural or synthetic fibres) shall comply with criterion 14 on ‘Auxiliary chemicals ’and criterion 15 on ‘Detergents, fabric softeners and complexing agents ’.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS32.Coatings, laminates and membranes

(a)Products made of polyurethane shall comply with criterion 3(a) regarding organic tin and criterion 3(b) regarding the emission to air of aromatic diisocyanates.

(b)Products made of polyester shall comply with criterion 8(a) regarding the amount of antimony and criterion 8(b) regarding the emission of VOCs during polymerisation.




(c)Coatings, laminates and membranes shall not be produced using plasticisers or solvents, which are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):





THE EUROPEAN ECOLABELTEXTILE PRODUCTS33.Energy and water use

The applicant is requested, on a voluntary basis, to provide detailed information on water and energy use for the manufacturing sites involved in spinning, knitting, weaving and wet processing.




THE EUROPEAN ECOLABELTEXTILE PRODUCTSFITNESS FOR USE CRITERIA

The following criteria apply either to the dyed yarn, the final fabric(s),or the final product, with tests carried out as appropriate.

34.Dimensional changes during washing and drying35.Colour fastness to washing36.Colour fastness to perspiration (acid, alkaline)37.Colour fastness to wet rubbing38.Colour fastness to dry rubbing39.Colour fastness to light




THE EUROPEAN ECOLABELTEXTILE PRODUCTS40.Information on the eco-label labelling

Box 2 of the eco-label shall contain the following text:

—reduced water pollution—hazardous substances restricted—whole production chain covered




THE EUROPEAN ECOLABELTEXTILE PRODUCTSNew possible criteria linked with

- Sustainable development (ethics...) - Environnemental mangement (staff awareness, data

registration…) - …



Annex 5

Minutes of the meeting in Paris

03/27/2006


Revision of the Community Eco label criteria for textile products (Decision 2002/371/EC)

MINUTES OF THE FIRST ADWG MEETING

27 MARCH 2006 IN PARIS

1 AGENDA OF THE MEETING

1. INTRODUCTION 2. SCOPE OF THE CONTRACT AND TIME SCHEDULE 3. PRESENTATION OF THE PRESENT TEXTILE PRODUCTS 4. DISCUSSION ON EACH CRITERIA : ROUND TABLE AND OPINIONS OF THE PARTICIPANTS 5. CONCLUSIONS ON CRITERIA TO BE REVISED AND TIME TABLE 6. ANY OTHER BUSINESS

The results of the discussions and the input provided will be taken into account in finalising the draft report for the next meeting to be held in Brussels in October 2006 2 PARTICIPANTS List of participants is available. File attached 3 SCOPE OF THE CONTRACT This minutes forms part of a project to prepare a draft Commission Decision establishing revised ecological criteria for the award of the EU Eco-label to textile products. This project has been assigned to AFNOR, the French competent body for the EC Eco label. The practical development of the project is carried out by ASQUAL, an association specialist of all type of textiles and of all tests for textile. The project takes place within the framework of the EC Regulation 1980/2000 on a revised Community Eco-label award scheme. The objective of the Community eco-label award scheme is to promote products which have the potential to reduce negative environmental impacts, as compared with the other products (functional unit) in the same product group, thus contributing to the efficient use of resources and a high level of environmental protection. This objective shall be pursued through the provision of guidance and accurate, non deceptive and scientifically based information to consumers. The environmental impacts shall be identified on the basis of examination of the interaction of the products with the environment, including the use of energy and natural resources, during the life cycle of the product. The objective of this project is : To provide a document which can be used as a basis for a draft Commission establishing revised criteria for the award of the Community Eco-label to textile products.


Sub-objectives of this project (and corresponding time table) are : In the phase 1 (2006) – 1 (or 2) meeting of the Ad Hoc Working Group. • To form an ad’hoc working group, with all relevant interest group, including industry, SMEs,

trade unions, … • To evaluate the past, current and likely future success of the product group (bed

mattresses), including the related potential environmental benefits, • To establish, update and extend as appropriate market information and life cycle

considerations, • To present the results of these evaluations and estimate whether the ecological criteria

related assessment, as well as compliance verification requirements should be either prolonged, withdrawn or revised.

In the phase 2 (2006- 2007) – 2 meetings of the Ad How Working Group. • To develop a revised criteria proposal, covering the relevant environmental aspects related

to the product group, that can be successfully proposed to the Eco-label Regulatory Committee,

• To prepare a list of relevant options for testing and methods the different proposed revised criteria,

• To prepare a user manual for applicants and competent bodies • To prepare a final report including :

o related documents used for completing the work and meeting the objectives, list of interested parties involved in the work or that have been consulted or expressed their opinion, executive summary.

o Details of the proposed marketing and communication strategy. 4 DEFINITION AND SCOPE OF THE PRODUCT GROUP At first the consultant indicates the target that he would like follow. To day many producers have the label OEKOTEX which is a label focused on the health criteria. In the European ecolabel there are some criteria very close to the criteria Oekotex. So the interest to find synergies between these two labels would be a good thing for producers and for the increasing of the number of licensees. A comparison between these two labels is presented (cf slides). If there are comparison it will be with Oekotex 100, Oekotex 1000 having not a big success and not very far form the European ecolabel. After a round table it seems that the idea is interesting for the participants even there will be some things to check about the tests , about the costs, about the limits…. The product group “textile products” as defined in the old decision is : Textile clothing and accessories : clothing and accessories (such as handkerchiefs, scarves, bags, shopping bags, rucksacks, belts and so on..) consisting of at least 90% by weight of textile fibres; Interior textiles : textile products for interior use consisting of at least 90% by weight of textile fibres. Wall and floor coverings are excluded;


Fibres, yarn and fabric: intended for use in textile clothing and accessories or interior textiles For textile, clothing and accessories” and for “interior textiles” : down, feathers, membranes and coating need not to be taken into account in the calculation of the percentage of textile fibres. About the definition the consultant says that the directive gives an other definition: at first about the percentage by weight of textile fibres and secondly about the classification of textiles. The directive indicates 80% by weight of textile fibres, the consultant proposes to go towards this proposal. NL proposes to add leather products NO proposes to add floor carpets and agrees on the adding of leather products B would like to include textile for garden and agrees for leather products The commission thinks that the harmonisation with the directive on textiles can be a good idea and the extension on other products also ASQUAL will check this possibility and bring information for the next meeting The scope should be revised 5 LISTING OF CRITERIA Criterion 1: Acrylic No modification, criteria confirmed Criterion 2 : Cotton and other natural cellulosic seed fibres (including kapok) A majority of people would like a revision of this criteria. The main modifications will be on pesticides (ban, harmonisation with oekotex..) and biologic cotton (increasing of the % of organic cotton) Criteria must be revised Criterion 3 : Elastane The criteria on organotin is not very clean . UK asks for a clarification of this criteria For NL and DK for some producers it is difficult to prove this criteria Criteria must be revised Criterion 4 : Flax and other bast fibres NO asks for a limit of COV. It would be easier to check than a reduction as indicated in the current decision


Criteria must be revised Criterion 5 : Greasy wool and other keratine fibres NO asks for checking the list of pesticides. The limits seem difficult to check. For COD it is the same problem than for COV. It would be easier to have a limit rather a reduction of a %. NL asks for finding a synergie with the criteria oekotex. Criteria must be revised. Criterion 6 : Man made cellulose fibres This criteria seems very stringent. It stays only one company which produces this type of fibre. For that criteria the consultant must find arguments for a potential revision. Criterion 7 : Polyamide The implementation of this criteria is difficult It must be confirmed. No revision Criterion 8 : Polyester The amount of antimony seems appropriate. The criteria for COV seems to high for some competent bodies. Criteria must be revised. Criterion 9 : Polypropylene New process exist now so the consultant will have to check this criteria. Criteria must be revised and updated.

Process and chemicals criteria Criterion 10 : Auxiliaries and finishing agents for fibres and yarns This criteria seems very difficult to check. A discussion should be on biodegradability and elimination. The consultant could look at the ecolabel for lubricants. Criteria must be revised. Criterion 11 : Biocidal or biostatic products


In oekotex there is a possibility to use biocides because some products today use this type of ingredients for some use. The consultant should be think about the use of biocide perhaps with some hurdles, a checking with the directive biocide could be useful. Criteria must be revised. Criterion 12 : Stripping or depigmentation Criteria must be revised. Criterion 13 : Weighting This criteria is still relevant. No revision. Criterion 14 : Auxiliary chemicals This substance can give odour to final products . The consultant should check this point. Criteria must be revised. Criterion 15 : Detergents, fabric softeners and complexing agents Criteria must be revised. Criterion 16 : Bleaching agents Criteria must be updated and revised. Criterion 17 : Impurities in dyes To be revised. Criterion 18 : Impurities in pigments To be revised. Criterion 19 : Chrome mordant dyeing This substance is only used for wood. To be confirmed


Criterion 20 : Metal complex dyes This criteria must be revised in particular related to certification procedures. Criterion 21 : Azo dyes New investigation is necessary for that criteria and also new interpretation on dyes and pigments. To be revised. Criterion 22 : Dyes that are carcinogenic, mutagenic or toxic to reproduction To be updated Criterion 23 : Potentially sensitising dyes to be updated. Criterion 24 : Halogenated carriers for polyester To be moved and confirmed. Criterion 25 : Printing To be confirmed Criterion 26 : Formaldehyde In the label Oekotex there are 4 classes Class 1 no formaldehyde Class 2 75 ppm Class 3 75 ppm Class 4 300 ppm It seems that there is an agreement for taking the limits of Oekotex but the consultant will have to check the tests and the limits of detection. To be revised. Criterion 27 : Waste water discharges from wet processing the limits should be revised. The limit of 25g/kg seems too high. A precision of the term ”discharge” should be done To be revised.


Criterion 28 : Flame retardants There are now new technologies so at first there should a checking related these new process. In oekotex there are two lists one for products one for fibers To be revised Criterion 29 : Shrink resistant finishes this criteria must be revised for bringing more precision Criterion 30 : Finishes At first to precise the definition of finishes it is important to connect this criteria with the biocide directive The hurdle of 0,1% seems stringent related the risk “dangerous for the environment”. To be revised. Criterion 31 : Fillings It is important to discuss this criteria with all the competent bodies. To be revised. Criterion 32 : Coatings, laminates and membranes polyester membrane is not made with antimony. We need more information from coatings producers. New technologies exist now Criterion 33 : Energy and water use the consultant will check if he can find new data because the label of fitness for use. all comments from partners should be very useful. to be revised. Fitness for use The competent bodies should send their comments about the credibility of the current tests. There are some European standards for fitness for use for textiles. The commission says that we must choose the European standards if there are. The consultant will propose some new for the next meeting.


The information appearing on the label Box 2 must be changed Some new criteria Health and safety Management criteria as staff training or staff awareness To think about the simplification of procedures


Annex 6

Examples of replies and comments after the first meeting used at the second meeting


COMITE INTERNATIONAL DE LA RAYONNE ET DES FIBRES SYNTHETIQUES

INTERNATIONAL RAYON AND SYNTHETIC FIBRES COMMITTEE

AVENUE VAN NIEUWENHUYSE, 4 B – 1160 BRUSSELS BELGIUM

e-mail : [email protected]

TEL. : (32-2)676.74.55FAX : (32-2)676.74.54

Sept 06

Comments from CIRFS member companies on the revision of the ecolabelling criteria for textile products General Comment on Article 2 It is suggested to include a reference to nonwoven products ,as they represent an important and growing share of the technology and textile market (could be included after alinea starting with Fibres…). Also nonwoven endproducts (disposables and non-disposables) should be mentioned Comments on fiber criteria 3.Elastane According to our members the use of organotin has been phased out years ago,so seems not to be relevant anymore 7.Polyamide The problem of the N2O emission criterium is that it is relevant for and happens during monomerproduction,which cannot be traced and influenced by a fiber producer 8.Polyester A reduction of VOC during polymerization (now 1.2 g/kg resin)seems not feasible,at least not for the dominating technology of direct esterification 11.Biocidal or biostatic products Our members strongly innovate in bioactive fibers and textiles,which means products that remain active during the use phase.We should develop criteria that


allow certification of this product class.Reference can be made here to certification rules for bioactive textiles and fibers developed by Oekotex some 3 years ago and the development and implementation of the Biocidal Directive in Europe with including textile applications 28.Flame retardants Our members draw the attention to the 2 existing basic technologies for flameretardant textiles: based on fabric finishing with FR chemicals and based on fibers with intrinsically flameretardant properties.Fibers with intrinsic FR properties are achieved during polymerization with certain monomers.Those monomers result to be part of the molecular chain like any monomer.Our interpretation is that the restrictions in the existing criteria is relevant for the fabric finishing technology and not for FR fibers based on (co)polymerisation


September 27nd, 2006

Suggestions and comments to the revision of the criteria of textile products from the Danish competent body: Product group definition – article 2. In this article wall and floor coverings are excluded in the current criteria. This is probably due to the fact that floor coverings often are made of both textile fibres and a layer of thick rubber underneath. However with this formulation we also exclude small carpets and rugs made op 100% textile fibres. We suggest that we change the formulation in order to allow carpets and rugs made of fibres only. In the current criteria document there are no criteria for leather and skins. However the Nordic ecolabel – The Swan – has developed criteria for these materials. The Flower could use these criteria and thereby expand the product group with a minimum of work. I have attached the relevant criteria as an appendix. Cotton The flower has banned 20 pesticides Öko-tex has banned more than 50. It would be useful have a greater degree of harmonization between the two labels. Of course it is not possible to compare the results if the Öko-tex test has been made on a coloured textile but if it has been made on raw fibres or yarn before wet treatment the applicant should be allowed to use an Öko-tex certificate. We propose a closer look into the use of organic cotton. Should it be obligatory or can we award producers using certified organic cotton. Elastane The requirement of 5 mg aromatic diisocyanetes pr. kg fibre produced seems very high. The Danish CB have had to applications with results much, much lower (0.005 mg/kg). The reason for this could be that it is not specified where the measurements should be done. It is free for the applicant to choose whether they will test in the chimney or inside the factory.


Polyester The requirement of 1.2 g VOC kg fibre produced seems very high. The Danish CB have had to applications with results much, much lower (0.001 g/kg). The reason for this could be that it is not specified where the measurements should be done. It is free for the applicant to choose whether they will test in the chimney or inside the factory. Nor is the any information about how many and which VOC that should be tested for. It seems that is very difficult to find suitable spin finish to the production of polyester. Only very few of them are sufficiently bio degradable. Auxiliaries c) According to our experience it is not possible to find mineral oils with a content of PAH on less than 3%. Biocidal or biostatic products Since the current criteria were developed in 2001 it has become more normal to use different kind of biocides in clothing. Instead of just banning them the Flower should develop criteria for biocides and allowing the best ones. Detergents, fabric softeners and complexing agents Instead of just looking at the bio degradability we could consider also to look at the risk phrases and thereby to exclude those are worst to the environment. Bleaching agents Chlorinated bleaching agents should be excluded. Dyes, pigments, azo dyes etc. All these criteria need to be looked upon and updated. Talk to the manufactures (CIBA, Clariant, BASF, DyStar etc.) Metal complex dyes


Metal complex dyes are a very popular group of dyes. They are cheap and without them it is difficult to obtain a range of special colours and shades. The problem by using them is that they contain heavy metals that are toxic in the environment. Some Danish textile manufactures (both with and without the Flower) have decided not to use metal complex dyes at all due to their negative environmental effects. According to them it is still possible to be competitive on the market to provide the costumers a large range of different colours and shades. Only a few colours (like pink and turquoise) are not possible. It is our judgement that metal complex dyes are not necessary in modern textile production and that we therefore should avoid them. It is true that there will be some colours that we can not put the label on but we can still label all the others. Formaldehyde It would be useful to harmonise with Öko-tex.


Annex 7

Agenda for the second meeting in Brussels :

10/03/2006


REVISION OF THE ECOLABELLING CRITERIA FOR TEXTILES PRODUCTS The second meeting will take place in :

BRUSSELS Av de Beaulieu 5

date: Tuesday, October 3rd 2006, 10am- 4 pm draft Agenda

8. Approval of the minutes of 27th of March 9. Discussion following the first meeting on each actual criteria : round table

and opinions of the participants 10. Conclusions 11. Any other business


Annex 8

Power Point presentation during the meeting in Brussels

10/03/2006


Revision of the ecollabelling criteria - 2nd meeting October 3rd 2006

THE EUROPEAN ECOLABELTEXTILE PRODUCTSThe product group ‘textile products’ shall comprise:

Textile clothing and accessories: clothing and accessories (such as handkerchiefs, scarves, bags, shopping bags, rucksacks, belts etc.) consisting of at least 90 % by weight of textile fibres;Interior textiles: textile products for interior use consisting of at least 90 % by weight of textile fibres. Wall and floor coverings are excluded;Fibres, yarn and fabric: intended for use in textile clothing and accessories or interior textiles.

For ‘textile clothing and accessories’ and for ‘interior textiles’:down, feathers, membranes and coatings need not be takeninto account in the calculation of the percentage of textilefibres.

Confirmed Revised Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTSAgreed

To be consistent with the Directive 96-73: 80 % by weight of textile fibres

To be discussed:

Include:

LeatherCarpetsOutdoor textile Wall paperNon woven



Comments

- Interest for widening the scope to leather product and floor carpets?

• EURATEX (and its carpets manufacturers members) is opposed to the inclusion of textile floor coverings

• Allow carpets and rugs made of fibers only (reference to the Nordic Ecolabel)

• Tests methods, materials, requirements and performances are not the same between textile and leather. Leather should not be added in the textile ECOLABEL (Contact: COTANCE).

- Include criteria connected with furniture- Include non woven products - Request from customers

THE EUROPEAN ECOLABELTEXTILE PRODUCTS



THE EUROPEAN ECOLABELTEXTILE PRODUCTS1. Acrylic

(a) The residual acrylonitrile content in raw fibres leaving the fibre production plant shall be less than 1,5 mg/kg.

(b) The emissions to air of acrylonitrile (during polymerisation and up to the solution ready for spinning), expressed as an annual average, shall be less than 1 g/kg of fibre produced




THE EUROPEAN ECOLABELTEXTILE PRODUCTS2.Cotton and other natural cellulosic seed fibres (including

kapok)

Cotton and other natural cellulosic seed fibres (hereinafter referred to as cotton) shall not contain more than 0,05 ppm (sensibility of the test method permitting) of each of the following substances :aldrin, captafol, chlordane, DDT,dieldrin,endrin,heptachlor,hexachlorobenzene,hexachlorocyclohexane (total isomers),2,4,5-T,chlordime-form, chlorobenzilate, dinoseb and its salts, monocrotophos, pentachlorophenol, toxaphene, methamidophos, methylparathion, parathion, phosphamidon.





2.Cotton and other natural cellulosic seed fibres (including kapok)

To be discussed:

Pesticides list:Harmonization with Oeko-Tex listUpdate the list

Increase the percentage of organic cotton




2.Cotton and other natural cellulosic seed fibres (including kapok)

Comments:

- Bonus for these fibre because they are made from renewable resources

- Organic cotton: award producers using organic cotton. Should it be obligatory?

- Harmonization with Oeko-Tex: pesticides list and same sample for the tests.




(a) Organotin compounds shall not be used.

(b) The emissions to air of aromatic diisocyanates during polymerisation and spinning, expressed as an annual average, shall be less than 5 mg/kg of fibre produced.

To be discussed:

(a) Criteria not clear(b) Difficult to prove





Comments

- The use of organotin has been phased out years ago. The criteria isn’t relevant anymore.

- Air emission of diisocyanate: it is not specified where the measurement should be done.



THE EUROPEAN ECOLABELTEXTILE PRODUCTS4.Flax and other bast fibres (including hemp, jute, and ramie)

Flax and other bast fibres shall not be obtained by water retting, unless the waste water from the water retting is treated so as to reduce the COD or TOC by at least 75 %for hemp fibres and by at least 95 %for flax and the other bast fibres.

To be discussed:

It would be easier to have a limit rather than a reduction of a percentage




THE EUROPEAN ECOLABELTEXTILE PRODUCTS5.Greasy wool and other keratin fibres (including wool from sheep,

camel, alpaca, goat)(a)The sum total content of the following substances shall not exceed 0,5 ppm

:ã -hexachlorocyclohexane (lindane), á -hexachlorocyclohexane,â -hexachlorocyclohexane,ä -hexachlorocyclohexane,aldrin,dieldrin,endrin,p,p'-DDT, p,p'-DDD.

(b)The sum total content of the following substances shall not exceed 2 ppm:diazinon,propetamphos,chlorfenvin-phos,dichlorfenthion,chlorpyriphos,fenchlorphos.

(c)The sum total content of the following substances shall not exceed 0,5 ppm:cypermethrin,deltamethrin, fenvalerate,cyhalothrin,flumethrin.

(d)The sum total content of the following substances shall not exceed 2 ppm:diflubenzuron,triflumuron.

.





5.Greasy wool and other keratin fibres (including wool from sheep, camel, alpaca, goat)

To be discussed:

Pesticides list:Harmonization with Oeko-Tex listUpdate the list

COD: It would be easier to have a limit rather than a reduction of a percentage

Take into account organic wool



THE EUROPEAN ECOLABELTEXTILE PRODUCTS6.Man-made cellulose fibres (including viscose, lyocell, acetate,

cupro, triacetate)

(a) The level of AOX in the fibres shall not exceed 250 ppm.

(b) For viscose fibres, the sulphur content of the emissions of sulphur compounds to air from the processing during fibre production, expressed as an annual average, shall not exceed 120 g/kg filament fibre produced and 30 g/kg staple fibre produced. Where both types of fibre are produced on a given site, the overall emissions must not exceed the corresponding weighted average.

To be discussed:

(a) The level of AOX in the fibres (Criteria 16)




THE EUROPEAN ECOLABELTEXTILE PRODUCTS6.Man-made cellulose fibres (including viscose, lyocell,

acetate, cupro, triacetate)

(c) For viscose fibres,the emission to water of zinc from the production site,expressed as an annual average,shall not exceed 0,3 g/kg.

(d) For cupro fibres,the copper content of the effluent water leaving the site,expressed as an annual average,shall not exceed 0,1 ppm.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS7.Polyamide

The emissions to air of N2O during monomer production,expressed as an annual average,shall not exceed 10 g/kg polyamide 6 fibre produced and 50 g/kg polyamide 6,6 produced.

Comments:The problem of the N2O emission criterium is relevant for and happens during monomerproduction. Can’t be traced and influenced by a fibre producer





(a)The amount of antimony in the polyester fibres shall not exceed 260 ppm. Where no antimony is used, the applicant may state ‘antimony free ’(or equivalent text)next to the eco-label.

(b)The emissions of VOCs during polymerisation of polyester, expressed as an annual average, shall not exceed 1,2 g/kg of produced polyester resin.(VOCs are any organic compound having at 293,15 K a vapour pressure of 0,01 kPa or more, or having a corresponding volatility under the particular conditions of use).

To be discussed:

Take into account other catalystsEmission of VOCs very high





Comments:

- A reduction of VOC during polymerisation seems not feasible, at least not for the dominating technology or direct esterification.

- Air emission of VOC: it is not specified where the measurement should be done and which VOC should be tested.

- The requirement (1.2 g VOC/kg) seems very high.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS9.Polypropylene

Lead-based pigments shall not be used.

To be discussed:

Take into account other catalysts




THE EUROPEAN ECOLABELTEXTILE PRODUCTSPROCESSES AND CHEMICALS CRITERIA

The criteria in this section apply, where appropriate, to all stages of production of the product, including the production of the fibres. It is nevertheless accepted that recycled fibres may contain some of the dyes or other substances excluded by these criteria, but only if they were applied in the previous life-cycle of the fibres.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS10.Auxiliaries and finishing agents for fibres and yarns(a)Size: At least 95 %(by dry weight) of the component substances of any

sizeing preparation applied to yarns shall be sufficiently biodegradable or eliminable in wastewater treatment plants, or else shall be recycled.

(b) Spinning solution additives, spinning additives and preparation agents for primary spinning (including carding oils, spin finishes and lubricants):At least 90 %(by dry weight)of the component substances shall be sufficiently biodegradable or eliminable in waste watertreatment plants.This requirement does not apply to preparation agents for secondary spinning (spinning lubricants, conditioning agents),coning oils, warping and twisting oils, waxes, knitting oils, silicone oils and inorganic substances.

(c)The content of polycyclic aromatic hydrocarbons (PAH) in the mineral oil proportion of a product shall be less than 1,0 % by weight.

. Confirmed Revised Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTS10.Auxiliaries and finishing agents for fibres and yarns

To be discussed:

Biodegradability and elimination (c) See lubricants Ecolabel

.



THE EUROPEAN ECOLABELTEXTILE PRODUCTS10.Auxiliaries and finishing agents for fibres and yarns

Comments

- It is not possible to find a mineral oil with content of PAH lessthan 3%

- Only very few of spin finish for polyester are sufficiently biodegradable.




(a) Chlorophenols (their salts and esters),PCB and organotincompounds shall not be used during transportation or storage of products and semi-manufactured products.

(b) Biocidal or biostatic products shall not be applied to products so as to be active during the use phase.





Agreed

(b)Biocidal or biostatic products shall not be applied to products so as to be active during the use phase.

To be discussed:

Harmonization with Oeko-Tex listTo be in accordance withthe Directive 98-8 CE

.

11.Biocidal or biostatic products




Comments- Reference to certification rules for bioactive textile and fibres developed by Oeko-Tex and to the development and implementation of the Biocide Directive in Europe including textile application.- Antimicrobial finishing corresponds to a need of the consumer.- The wear comfort, natural fibres properties and the textile’s use life are increased. - Development of criteria allowing the best products.



THE EUROPEAN ECOLABELTEXTILE PRODUCTS12.Stripping or depigmentation

Heavy metal salts (except of iron) or formaldehyde shall not be used for stripping or depigmentation.

To be discussed:

Evolution?




THE EUROPEAN ECOLABELTEXTILE PRODUCTS13.Weighting

Compounds of cerium shall not be used in the weighting of yarn or fabrics.

To be discussed:

Is it still used?




THE EUROPEAN ECOLABELTEXTILE PRODUCTS14.Auxiliary chemicals

Alkylphenolethoxylates (APEOs), linear alkylbenzene sulfonates (LAS), bis(hydrogenated tallow alkyl) dimethyl ammonium chloride (DTDMAC), distearyl dimethyl ammonium chloride (DSDMAC), di(hardened tallow) dimethyl ammonium chloride (DHTDMAC), ethylene diamine tetra acetate (EDTA), and diethylene triamine penta acetate (DTPA)shall not be used and shall not be part of any preparations or formulations used.

To be discussed:

Include smelt auxiliary (perfumes)





At each wet-processing site, at least 95 % by weight of the detergents, at least 95 %by weight of fabric softeners and at least 95 % by weight complexing agents used shall be sufficiently degradable or eliminable in wastewater treatment plants.

To be discussed:

Remove " eliminable"





Comments

The risks phases should be considered




In general,AOX emissions in the bleaching effluent shall be less than 40 mg Cl/kg. In the following cases,the level shall be less than 100 mg Cl/kg:

— linen and other bast fibres,— cotton, which has a degree of polymerisation below 1 800,and which is intended

for white end products.This requirement does not apply to the production of man-made cellulose fibres.

To be discussed:

Same criteria for all cellulosic fibres





Comments:

- The criteria is in favour of natural fibres. Why shall the emission from linen, bast and cotton be less harmful than those from the fibre industry?

- Chlorinated bleaching agents should be excluded.





The levels of ionic impurities in the dyes used shall not exceed the following:Ag 100 ppm; As 50 ppm; Ba 100 ppm; Cd 20 ppm; Co 500 ppm; Cr 100 ppm; Cu 250 ppm; Fe 2 500 ppm; Hg 4 ppm; Mn 1 000 ppm; Ni 200 ppm; Pb 100 ppm; Se 20 ppm; Sb 50 ppm; Sn 250 ppm; Zn 1 500 ppm.Any metal that is included as an integral part of the dye molecule (e.g.metal complex dyes, certain reactive dyes, etc.) shall not be considered when assessing compliance with these values, which only relate to impurities.

To be discussed:

Evolution of the market?





Comments






The levels of ionic impurities for pigments used shall not exceed the following: As 50 ppm; Ba 100 ppm, Cd 50 ppm; Cr 100 ppm; Hg 25 ppm; Pb 100 ppm; Se 100 ppm; Sb 250 ppm; Zn 1 000 ppm.

To be discussed:

Evolution of the market?





Comments





THE EUROPEAN ECOLABELTEXTILE PRODUCTS19.Chrome mordant dyeing

Chrome mordant dyeing is not allowed.

Agreed

Precise : Criteria only for wool (change the presentation)




THE EUROPEAN ECOLABELTEXTILE PRODUCTS20.Metal complex dyes.If metal complex dyes based on copper, chromium or nickel are used:

(a) In case of cellulose dyeing, where metal complex dyes are part of the dye recipe, less than 20 %of each of those metal complex dyes applied (input to the process) shall be discharged to waste water treatment (whether on-site or off-site).

In case of all other dyeing processes, where metal complex dyes are part of the dye recipe, less than 7 %of each of those metal complex dyes applied (input to the process) shall be discharged to waste water treatment (whether on-site or off-site).

(b)The emissions to water after treatment shall not exceed: Cu 75 mg/kg (fibre,yarn or fabric); Cr 50 mg/kg; Ni 75 mg/kg.

. Confirmed Revised Cancelled



THE EUROPEAN ECOLABELTEXTILE PRODUCTS20.Metal complex dyes

To be discussed

Comments

Metal complex dyes should be avoided even if some colours (pink and turquoise) cannot be labelled.



THE EUROPEAN ECOLABELTEXTILE PRODUCTS21.Azo dyesAzo dyes shall not be used that may cleave to any one of the following

aromatic amines:4-aminodiphenyl (92-67-1), Benzidine (92-87-5), 4-chloro-o-toluidine (95-69-2)2-naphthylamine (91-59-8), o-amino-azotoluene (97-56-3), 2-amino-4-nitrotoluene (99-55-8)p-chloroaniline (106-47-8), 2,4-diaminoanisol (615-05-4), 4,4'-diaminodiphenylmethane (101-77-9)3,3'-dichlorobenzidine (91-94-1), 3,3'-dimethoxybenzidine (119-90-4), 3,3'-dimethylbenzidine (119-93-7), 3,3'-dimethyl-4,4'-diaminodiphenylmethane (838-88-0), p-cresidine (120-71-8), 4,4'-methylene-bis-(2-chloraniline)(101-14-4), 4,4'-oxydianiline (101-80-4), 4,4'-thiodianiline (139-65-1)o-toluidine (95-53-4), 2,4-diaminotoluene (95-80-7), 2,4,5-trimethylaniline (137-17-7)4-aminoazobenzene (60-09-3), o-anisidine (90-04-0).




THE EUROPEAN ECOLABELTEXTILE PRODUCTS21.Azo dyes

To be discussed:

New investigation on pigmentsUse European Standard

CommentsAll these criteria need to be updated




THE EUROPEAN ECOLABELTEXTILE PRODUCTS22.Dyes that are carcinogenic, mutagenic or toxic to reproduction

(a)The following dyes shall not be used:

C.I.Basic Red 9C.I.Disperse Blue 1C.I.Acid Red 26C.I.Basic Violet 14C.I.Disperse Orange 11C.I.Direct Black 38C.I.Direct Blue 6C.I.Direct Red 28C.I.Disperse Yellow 3




THE EUROPEAN ECOLABELTEXTILE PRODUCTS22.Dyes that are carcinogenic, mutagenic or toxic to reproduction(b) No use is allowed of dye substances or of dye preparations containing

more than 0,1 % by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):

R40 (limited evidence of a carcinogenic effect),R45 (may cause cancer),R46 (may cause heritable genetic damage),R49 (may cause cancer by inhalation),R60 (may impair fertility),R61 (may cause harm to the unborn child),R62 (possible risk of impaired fertility),R63 (possible risk of harm to the unborn child),R68 (possible risk of irreversible effects),as laid down in Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws,

regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances (1 ), and its subsequent amendments.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS22.Dyes that are carcinogenic,

mutagenic or toxic to reproduction

To be discussed:

To update



THE EUROPEAN ECOLABELTEXTILE PRODUCTS23.Potentially sensitising dyes

The following dyes shall only be used if the fastness to perspiration (acid and alkaline)of the dyed fibres, yarn or fabric is at least 4

C.I.Disperse Blue 3 C.I.61 505C.I.Disperse Blue 7 C.I.62 500C.I.Disperse Blue 26 C.I.63 305C.I.Disperse Blue 35C.I.Disperse Blue 102C.I.Disperse Blue 106C.I.Disperse Blue 124C.I.Disperse Orange 1 C.I.11 080C.I.Disperse Orange 3 C.I.11 005C.I.Disperse Orange 37C.I.Disperse Orange 76

(previously designated Orange 37)C.I.Disperse Red 1 C.I.11 110C.I.Disperse Red 11 C.I.62 015C.I.Disperse Red 17 C.I.11 210C.I.Disperse Yellow 1 C.I.10 345C.I.Disperse Yellow 9 C.I.10 375C.I.Disperse Yellow 39C.I.Disperse Yellow 49





23.Potentially sensitising dyes

To be discussed:

To update



THE EUROPEAN ECOLABELTEXTILE PRODUCTS24.Halogenated carriers for polyester

Halogenated carriers shall not be used.

Agreed

Change the presentation




THE EUROPEAN ECOLABELTEXTILE PRODUCTS25.Printing

(a) Printing pastes used shall not contain more than 5 %volatileorganic compounds (VOCs :any organic compound having at 293,15 K a vapour pressure of 0,01 kPa or more, or having a corresponding volatility under the particular conditions of use).

(b) Plastisol-based printing is not allowed.




THE EUROPEAN ECOLABELTEXTILE PRODUCTS26.Formaldehyde

The amount of free and partly hydrolysable formaldehyde in the final fabric shall not exceed 30 ppm for products that come into direct contact with the skin, and 300 ppm for all other products.

To be discussed:

Harmonization with Oeko-TexTest and no declaration





(a) Waste water from wet-processing sites (except greasy wool scouring sites and flax retting sites) shall, when discharged tosurface waters after treatment (whether on-site or off-site),have a COD content of less than 25 g/kg, expressed as an annual average.

(b) If the effluent is treated on site and discharged directly to surface waters, it shall also have a pH between 6 and 9 (unless the pH of the receiving water is outside this range)and a temperature of less than 40 °C (unless the temperature of the receiving water is above this value).





To be discussed:

COD: high levelRemove "discharge to surface"



THE EUROPEAN ECOLABELTEXTILE PRODUCTS28.Flame retardantsNo use is allowed of flame retardant substances or of flame retardant preparations

containing more than 0,1 % by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):





THE EUROPEAN ECOLABELTEXTILE PRODUCTS28.Flame retardants

To be discussed:

Harmonization with Oeko-TexSee the evolution on new technologies

Comments:2 existing basic technologies: - based on fabric finishing with FR chemicals - based on fibers with intrinsically FR properties.

The restriction in the existing criteria is relevant for the fabric finishing technology and not for fibers based on polymerisation.



THE EUROPEAN ECOLABELTEXTILE PRODUCTS29.Shrink resistant finishes

Halogenated shrink-resist substances or preparations shall only be applied to wool slivers.

To be discussed:

"Antifelting "




THE EUROPEAN ECOLABELTEXTILE PRODUCTS30.Finishes

No use is allowed of finishing substances or of finishing preparations containing more than 0,1 %by weight of substances that are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):





THE EUROPEAN ECOLABELTEXTILE PRODUCTS30.FinishesTo be discussed:

Define what kind of finishesPut the risk phrases list in the Annex0.1% by weight is appropriated?





(a)Filling materials consisting of textile fibres shall comply with the textile fibre criteria (Nos 1 —9) where appropriate.

(b)Filling materials shall comply with criterion 11 on ‘Biocidal or biostatic products ’and the criterion 26 on ‘Formaldehyde ’.

(c)Detergents and other chemicals used for the washing of fillings (down,feathers,natural or synthetic fibres)shall comply with criterion 14 on ‘Auxiliary chemicals ’and criterion 15 on ‘Detergents, fabric softeners and complexing agents ’.





To be discussed:

Discussion with Eastern Countries




(a)Products made of polyurethane shall comply with criterion 3(a) regarding organic tin and criterion 3(b) regarding the emission to air of aromatic diisocyanates.

(b)Products made of polyester shall comply with criterion 8(a) regarding the amount of antimony and criterion 8(b) regarding the emission of VOCs during polymerisation.





(c)Coatings, laminates and membranes shall not be produced using plasticisers or solvents, which are assigned or may be assigned at the time of application any of the following risk phrases (or combinations thereof):






To be discussed:

To extend the scope (Teflon, outdoor textile)Need more information from coating industryIs antimony still used in the Polyester membranes?



THE EUROPEAN ECOLABELTEXTILE PRODUCTS33.Energy and water use

The applicant is requested, on a voluntary basis, to provide detailed information on water and energy use for the manufacturing sites involved in spinning, knitting, weaving and wet processing.

To be discussed:

To refer to BAT documentsGive limits?Data from partners are welcome





The following criteria apply either to the dyed yarn, the final fabric(s),or the final product, with tests carried out as appropriate.

34.Dimensional changes during washing and drying35.Colour fastness to washing36.Colour fastness to perspiration (acid, alkaline)37.Colour fastness to wet rubbing38.Colour fastness to dry rubbing39.Colour fastness to light





To be discussed:

To refer to European StandardsAll competent bodies should say their comments on levelHarmonization with Oeko-Tex Standard 100




THE EUROPEAN ECOLABELTEXTILE PRODUCTS40.Information appearing on the eco-label

Box 2 of the eco-label shall contain the following text:

—reduced water pollution—hazardous substances restricted—whole production chain covered

To be discussed:

Box 2 must be changed: Provide a list of possible sentences and the company will choose




THE EUROPEAN ECOLABELTEXTILE PRODUCTSNew criteriaTo be discussed:

Environmental management (data registration, environmental policy, staff awareness, staff training...)Optical brightenerEnd-use

AgreedEthical notion: not included




THE EUROPEAN ECOLABELTEXTILE PRODUCTSOthers comments:

- Ecolabel is expensive- The application process is challenging


Annex 9

Minutes of the meeting in Brussels


Revision of the Community Eco label criteria for textile products (Decision 2002/371/EC)

MINUTES OF THE SECOND ADWG MEETING

3 OCTOBER 2006 IN BRUXELLES

1 AGENDA OF THE MEETING

7. INTRODUCTION 8. SCOPE OF THE CONTRACT AND TIME SCHEDULE 9. PRESENTATION OF THE PRESENT ECOLABEL TEXTILE PRODUCTS 10. DISCUSSION ON EACH CRITERION : ROUND TABLE AND OPINIONS OF THE PARTICIPANTS 11. CONCLUSIONS ON CRITERIA TO BE REVISED AND TIME TABLE 12. ANY OTHER BUSINESS

2 PARTICIPANTS List of the participants is available. File attached At first, general points have been made by the BEE. For BEE, it seems that we must have a global strategy of what we want for this ecolabel. How do we think about the promotion, how will we communicate on the new criteria. Today when we listen to consumers, the most important things concern organic cotton, pesticides and social issues. Do we intend to ban some substances not relevant for an ecolabel? For UK, health issues and animal issues have a high impact. So we must think about that. The Commission should think about the best way to explain to the consumers the difference between OEKOTEX, organic cotton and the European ecolabel. Related to the social aspects the revision of the regulation for the European ecolabel doesn’t allow this extension for the moment even if there are good reasons for taking into account that point. Points discussed

About the scope During the last meeting, it was proposed to change the definition of a textile product and to take this of the directive 96-73 concerning textile products. The modification concerns the % of textile by weight of textile fibers.


This definition is accepted.

Extension to leather products About the proposal to extend to leather products, COTANCE says that it doesn’t enter in the definition because 80% by weight of textile fibers. For them, there is no demand from the market and no volunteer from the industry. For Austria we must focus on textile. Other criteria should be proposed for leather. For the Nordic swan and the Dutch competent body, there is no problem to include leather because on one part leather is included in Nordic swan and because it can be considered as a new fiber. For BEE we must clarify the definition it can correspond to an other product group as CTBA says.

For the next meeting ASQUAL must bring information on the leather market, question CTC about that proposal and get back information from the producers which have the Nordic swan for leather product.

Extension to floor coverings This product group depends of the construction product directive 89/106 . These products must respect very stringent standards for quality and seem not very concerned by this ecolabel. For Norway and other countries as Belgium interior textiles are already included and a carpet for a bathroom can be already concerned by the European ecolabel;

The conclusion of this discussion is that rugs and mats i.e. textile floor coverings that are not glued to the floor are already within the scope as interior textiles. Carpets i.e. floor coverings that are glued to the floor should not be in the scope. This should be clarified in the new criteria doc.

Inclusion of non woven textile When we look at the definition of the textiles directive the non woven products are already included. For BEE we must be careful of single use products.

For the next meeting ASQUAL will have to bring :

more precision for the definition more information about leather products and its market more information on non woven market and products from construction product directive


Criterion 2 : cotton and other natural cellulosic seed fibres A discussion has been launched on pesticide list, on the increasing of organic cotton, on the harmonisation with oekotex. ASQUAL precises that the test method for pesticide are made on final product with oekotex and on yarn with the European ecolabel. For increasing the quantity of organic cotton it seems difficult for the professionals because the quantity of raw materials. For BEE the fact to increase organic cotton is a benefit for the communication because in this case the message is clear. It answers to different problematics as European legislation, benefit of consumers, social benefits and climate change. For Norway and Belgium it is better to valorize the efforts made by the organic cotton production but also take into account the reality of production of raw material. ASQUAL proposes to organise a small working group only on that point, meeting which could be held in December in the same time than the other meetings. In this group we will find Marianne from Norway, Marleen from Belgium, Arno from Austria, X from Danemark and the BEE.

The date will be confirmed by AFNOR.

Critèrion 3: Elastane Danemark asks for a more stringent criteria for diisocyanate.

ASQUAL must check near the licensees

Criterion 4: Flax and other bast fibers In the actual decision the criteria in expressed in %. People ask for a limit. For COD check with the producers

ASQUAL must check near the licensees

Criterion 5: Greasy wool and other keratin fibers It seems that the pesticide tests are today very expensive for the producers. More the tests are not reproductible and repeatable. For Norway it is better to have tests than nothing.

BEE will bring information from their contacts with pesticide organisation ASQUAL will bring more data from the different tests made today.


Criterion 6: Man made cellulose fibres The working group needs more data on that criteria ; it seems that it would be interesting to add a criterion on effluents

ASQUAL will bring more data from the producers about that proposal.

Criterion 7 : polyamide Austria would like to have a more stringent limit For the European association on fibers it is very difficult to have data on the production of monomers.

ASQUAL will bring more data from the producers about that proposal.

Criterion 8 : polyester The requirement of 1,2 g VOC/kg seems not too difficult for producers which work with BAT. The hurdle depends a lot of technology used. Some questions from competent bodies concerned the measurement of VOC. It seems that the directive for cars gives indication on the measurements of VOC.

For these different criteria ASQUAL must look on BAT for having an idea about hurdles.

Criterion 9 polypropylene BEE precises that there were studies about catalysts and it can permit to improve that criterion

Processes and chemicals criteria

Criterion 10 : auxiliaries

ASQUAL must bring precision and data on 10b, on what we call primary spinning and secondary spinning. The consultant must check the criteria on biodegradability. Some fibers as viscose are not biodegradable because their manufacturing process. So the industry asks for some exception. Austria asks questions about mineral oil and would like some precision on that criteria. Some association don’t agree on the hurdle of 3%.


ASQUAL must bring more information on auxiliaries and look to the decision on lubricants.

Criterion 11 : biocidal or biostatic products Mr Marconi from Sanitized brings information on biocidal products (see slides of the presentation). He precises that Oekotex 100 accepts some biocide for some specificities and in the same time ensures the safety of users. In the directive biocide there is a list with authorized substances . The discussion shows that we need more information on that point. Some people said that the European ecolabel should accept only products very useful and that biocidal products don’t correspond to that target. The competent bodies need more information of the market and what it represents to day. For the industry the revision of criteria should take into account the new innovation and the demand of consumers which increases. For Euratex we must not close the door and authorize some type of products. For the consultant the directive biocide accepts some products and thinks that the ecolabel can accept some of them.

ASQUAL must bring information on that market and on chemical substances used. BEE will send to the consultant a report from the Swedish association for conservation.

Criterion 13: weighting This criterion is no more relevant, it is no more used. It will be cancelled.

Criterion 14 : auxiliaries chemicals It will be preferable to use risk phrases rather than the list of ingredients. The definition must be précised.

Criterion 15 : detergents As before the definition of fabrics softeners must be précised. An harmonisation with the detergents regulation will have to be done.

Criterion 16 : bleaching agents In this revision some competent bodies would like the exclusion of chlorinated agents.


France says that it depends of the process of some fibers, for cotton there are degree of polymerisation one of them obliges to use chlorine.

Criterion 17 and 18 : impurities

ASQUAL must check with the producers CIBA proposes to follow the directive for impurities in pigments

Criterion 19 : chrome mordant dyeing This criterion must not changed because we use chrome for polyamide

Criterion 20 : metal complex dyes Some competent bodies as DK would like to delete this possibility. For Belgium, Autria and France the fashion changes very often and it is difficult to forbid some colours. For BEE we should have a clear message and it follows the proposal of DK. For Euratex the hurdle of 7% is too low and they propose to increase up to 10%.

Criterion 21 : Azo dyes This criterion needs to be revised

Criterion 22 : dyes For that criterion it would be better to be conformed with some parts of the directive for toys.

Criterion 24 : halogenated carriers for polyester

The consultant will put this criteria with the criteria on polyester fiber

Criterion 26 : formaldehyde At first the consultant should propose hurdles which take into account Oekotex. UK asks for a clarification: is this criteria applied only for the final product or also for yarn and fabrics? Some competent bodies ask for a criteria more stringent.


Some others asks for the possibility to include a criterion on the waste in water. An explanation on annual average and on the test 6060 would be useful. Belgium says that in her country no laboratory uses this standard. Austria asks for a relationship with BAT document.

Criterion 28 : Flame retardants Norway asks for risk sentences for that criteria. For a positive list it would be of the responsibility of the Commission to decide. UK precises that Oekotex authorizes some flame retardants. They do tests and some FR are used in fibers and in final product.

The consultant will have to look at that possibility and check how Oekotex takes into account risk sentences.

Criterion 29 : shrink resistant finishes Replace “shrink resistant” by “antifelting The consultant shall have to add lose wool”

Criterion 30 : Finishes Write rather “fabric finishes”

The consultant shall have to check the % of 0,1%

Criterion 31 : Fillings CTBA proposes to harmonize this criteria with bed mattresses in connection with the meeting which will take place on 4 October.

Criterion 32 : Coatings Some competent bodies would like to extend the scope to “Teflon” and to “outdoor textile”

Norway will send information about Teflon to the consultant, they don’t agree on this extension. Teflon is rather used for outdoor textiles. Other issues The next meeting will be held in Paris A meeting will be organised in December for organic cotton The dates will be proposed rapidly by AFNOR


Annex 10

ISO 139 - Part presenting the new tolerance for relative humidity: +/- 4%


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