Assessment on product level

Transcription

1 Annex Assessment on product level 0 Introduction Durability Options National furniture eco-labels and other EU Eco-labels Proposal for draft criteria Fitness for use Options National eco-labels and other EU Eco-labels Proposal for draft criteria Reparability Options National eco-labels and other EU Eco-labels Proposal for draft criteria Maintenance Options National eco-labels and EU Eco-labels Proposal for draft criteria Recycling Options National eco-labels and EU Eco-labels Proposal for draft criteria Reuse Options National eco-labels and EU Eco-labels Proposal for draft criteria Waste management hazardous substances Options Proposed criteria Transport Options National eco-labels and EU Eco-labels Proposal for draft criteria

2 9 Ergonomics Options National eco-labels and EU Eco-labels Proposal for draft criteria Safety Options National eco-labels and EU Eco-labels Proposal for criteria Packaging Options National eco-labels and EU Eco-labels Proposal for draft criteria Consumer information Options National eco-labels and EU Eco-labels Proposed draft criteria

3 0 Introduction In Annex B, the analysis is presented of environmental, health and safety related and performance issues on a product level. There seems to be no common approach of the national eco-labels on which categories of issues should be distinguished. An attempt is made to bring all relevant issues together which are addressed by national eco-labels for furniture or have been raised in the first meeting of the Ad Hoc Working Group. An explanation of what is understood by the different issues is given in the main report. The following issues can be distinguished: Performance Durability Fitness for use Environmental Reparability Maintenance Recycling Reuse Waste management hazardous substances Health and safety Ergonomics Safety Other Packaging Consumer information Transport It does not necessarily mean that all these issues need to be addressed by the EU Ecolabel. This depends on the findings of the analysis and on the discussions in the AHWG. For each issue the following aspects will be described: Options for formulating criteria The approaches adopted by the national eco-labels for furniture and relevant EU Eco-labels Proposal for draft criteria The following labels have been included in the analysis: Milieukeur meubelen (Stichting Milieukeur, The Netherlands); RAL-UZ 38, Grundlage für Umweltzeichenvergabe/Blauer Engel, (Umweltbundesamt, Germany); ÖkoControl für Möbel (Gesellschaft für Qualitäts ökologischer Einrichtungshäuser mbh. Germany); RAL-RG 430 Allgemeine Güte- und Prüfbestimmungen für Möbel/Goldene M (Deutsche Gütegemeinschaft Möbel e.v., Germany); Ecolabelling of Furniture and Fitments and of Wooden outdoor furniture, Nordic Swan (Nordic Ecolabelling, Nordic countries); Marque NF Environnement (France); 3

4 Richtlinie UZ 06 and UZ 34, (Österreichisches Umweltzeichen, Austria). On the basis of the approaches adopted by the national labels, an analysis is made of the different options that are available to tackle a certain performance issue. These options are weighted against each other on their pro s and contra s, also taking into consideration the fact that the chosen option has to fit in well with the broad approach of the EU Eco-label Furniture. Since the scope on material and product group level of the eco-label of Nordic Swan and Stichting Milieukeur are the most comparable to the proposed scope of the EU Eco-label Furniture, these labels will be leading in setting criteria for performance, health and safety related issues. Reference should be made to Directive 1999/44/EC on certain aspects of the sale of consumer goods and associated guarantees. This Directive regulates fitness for purpose of consumer goods and liability of the seller. From 1 January 2002 this Directive had to be implemented by the Member States. This Directive can be considered to provide a basic protection for consumers against inferior products and could therefore serve as safety net besides the quality criteria proposed in the EU Eco-label Furniture. 1 Durability 1.1 Options Most national eco-labels address the durability issue, but the criteria are very different. The following options can be distinguished: 1. Specified reference to national and international (Goldene M); 2. Non specified reference to national and international (Nordic Swan for indoor furniture), including specific performance levels; 3. Detailed, absolute (Nordic Swan for outdoor furniture) 4. Measure based (Stichting Milieukeur and Österreichisches Umweltzeichen); 5. Open requirements (ÖkoControl). Several labels distinguish different criteria on durability for contract furniture and outdoor furniture. With respect to contract furniture this has to do with the intensity of use. Therefore, contract furniture has to fulfil higher testing (Nordic Swan, Goldene M for school furniture). With respect to outdoor furniture, the criteria have to take into account the fact that outdoor furniture has to endure all sorts of weather conditions. This is possible in two ways: Formulating detailed, absolute (Nordic Swan, Goldene M); Formulating less stringent for durability in comparison with other (indoor) types of furniture (Stichting Milieukeur). 1.2 National furniture eco-labels and other EU Eco-labels Specified reference to (inter)nat. E.g. DIN for schoolchairs, EN /95 for outdoor furniture (Goldene M) 4

5 Non specified reference to (inter)nat. Detailed, absolute Measure based Durability, strength, safety and stability requirements in nat., Eur. or other internat., with specific reference to different (ISO) levels for testing. If a standard other than ISO/EN is fulfilled, proof of comparable appliance by test institute is required. If no standard exists, evaluation by independent test institute. (Nordic Swan). With respect to outdoor furniture: - Protection of wood that comes into contact with the ground and of end-grain timber in plywood sheets. - Design should be so that water cannot run off. - Any metal parts used in outdoor furniture must not contain material that can rust or discolour the furniture. Furthermore: - Requirement levels for durability, strength, safety and stability relevant to the product s area of use. - As a minimum requirement, the requirement levels for domestic use according to EN 581-1, and If for contract use, test against requirement levels relevant to contract use. - If a standard other than ISO/EN is fulfilled, proof of comparable appliance by test institute. (Nordic Swan) Guarantee for five years (indoor), three years (outdoor). Fillings can have loss in height and firmness of max. 20%. (Stichting Milieukeur). Open requirement Option between: - Reparability service; - Replacement warrantee for parts that wear out easily for at least 10 years, - A service telephone for customers; - A take back system (Österreichisches Umweltzeichen) The way wood is connected should contribute to long life-span. (ÖkoContro)l 1.3 Proposal for draft criteria Furniture is a product with a relatively long life. From the perspective of environment and resources, long life is an important parameter. For furniture, the environmental impact is limited during use and more associated with production and waste. That often means that a long durability can balance environmental impacts during production and waste. For this reason, criteria have to be formulated with respect to durability. This is supported by the fact that nearly all national eco-labels contain a criterion for durability. There seems to be overall consensus within the AHWG to make use of existing as much as possible. The existing international in the field of durability do not cover all products included in the scope of the EU Eco-label scheme. Therefore, the approach used by Nordic Swan seems to be a pragmatic way to deal with durability for several reasons: By referring to national and international in general it is not necessary to make a complete inventory of all existing. By referring to ISO testing levels an equal minimum quality standard is assured, even if different national testing methods are applied. 5

6 It is not necessary to make a comparison between if competing exist. It is left to the company applying for the label to choose between different existing. The company can choose a testing institute itself, under the condition that it is accredited. Different purposes of furniture are taken into account by differing between ISO testing levels for domestic use, normal contract and hard contract (restaurant/café) use. This means that domestic furniture has to apply with testing levels for domestic use and contract furniture with the testing levels of normal or hard contract use. Other than EN or ISO are acceptable as long as they correspond with the requirements defined by ISO. If no exist, an independent test institution may perform an evaluation of the product s safety, durability and fitness for use on the basis of the design and choice of materials. One comment on this proposal is that up till now the furniture industry is not very familiar with the application of ISO, EN or other. In particular SME's may need some guidance in what exist. For this reason it is suggested to refer in the scheme to the institutions that can provide this information, i.e. standardisation institutes and branch organisations. Outdoor furniture is not covered by the above-mentioned approach. Nordic Swan distinguishes a separate scheme for outdoor furniture, which contains detailed, absolute criteria on durability. There is an EN standard under development for outdoor furniture with respect to the durability under the influence of climatic conditions. However, this standard has not been accepted yet. It would be more in line with the approach for indoor furniture to refer to this EN standard when this is accepted (this may still take a long period of time). For indoor furniture the approach of Nordic Swan will be followed with respect to durability, strength, safety and stability requirements. A minimum quality standard has to be assured by a minimum testing level (these levels still need to be established). For more information on the applicable the applicant should refer to the national standardisation institute or the branch organisation for furniture. Assessment and verification: As a rule the products to be tested should be selected on the basis of the test standard. Unless otherwise specified, tests should be performed within the product family to which the product belongs. The weakest and most critical elements in terms of stability should be selected for testing, for example drawers with the biggest dimensions and longest travel, tables with the longest free spans, etc. The test institution must provide an account of variations within the product group represented by the tested products, and verify that the product is representative. Furthermore, information should be provided about the standard to which the product has been tested, the test institution and the test results. If applicable an account of how national correspond with ISO s requirements has to be given. If an alternative approach is followed information has to be provided on the test institution, the test report and the assessment criteria. 6

7 For outdoor furniture the approach of Nordic Swan will be followed as well or specified reference will be made to the EN standard under development. In the latter case it must be realized that this standard is still subject to change. Assessment and verification: Appropriate testing method, depending on which criterion is chosen. 2 Fitness for use 2.1 Options Fitness for use is addressed by several of the national eco-labels with respect to different product groups (domestic furniture, contract furniture and children furniture). It also forms part of the EU Eco-label for hard floor coverings. The following options can be distinguished: 1. Specified reference to national and international (Goldene M, Österreichisches Umweltzeichen); 2. Non specified reference to national and international (Environnement NF); 3. Detailed, absolute (Goldene M); 4. Open standard (EU Eco-label for hard floor coverings). 2.2 National eco-labels and other EU Eco-labels Specified reference to (inter)nat. E.g. DIN /85 for depth of cupboards and DIN EN 747 for children furniture (Goldene M) Non specified reference to (inter)nat. Detailed, absolute Open requirement The quality of the materials and product have to fulfill at least quality level S (standard) of ÖNORM 1610 (Österreichisches Umweltzeichen) Contract furniture which are within the scope of the eco-label fulfil the quality regulations of the concerning sector (Environnement NF) Specific with respect to e.g. width of sliding doors, the depth of wardrobes, the way backboards have to be connected to the back of a cupboard (Goldene M) The product shall be fit for use. This evidence may include data from appropriate ISO, CEN or equivalent test methods, such as national or in-house test procedures. (EU Ecolabel Hard floor coverings) 2.3 Proposal for draft criteria Considering the fact that furniture is a very broad and divers product group, there are many different international and national with respect to fitness for use. These do not cover all aspects. Wishing to cover all fitness for use aspects or as many as possible would mean that additional absolute would have to be formulated, as is done by Goldene M. This does not fit in with the desire to keep the Eco- 7

8 label practical and pragmatic. Furthermore, it would also confront manufacturers or retailers that want to apply for the label with very high testing costs. For this reason it is proposed to follow the pragmatic approach of the EU Eco-label Hard floor coverings. The product shall be fit for use. This evidence may include data from appropriate ISO, CEN or equivalent test methods, such as national or in-house test procedures. Assessment and verification: Details of the test procedures and results shall be provided, together with a declaration that the product is fit for use based on all information about the best application by the end-user. According to Directive 89/106/EEC a product is presumed to be fit for use if it conforms to a harmonised standard, a European technical approval or a non-harmonised technical specification recognised at Community level. 3 Reparability 3.1 Options Several labels hold measure based requirements on reparability. 3.2 National eco-labels and other EU Eco-labels Measure based Detachable parts should be kept in stock and/or production. These parts have to be deliverable during the effective period of fabrication and the manufacturer has to ensure that these parts stay deliverable during 5 years after ending production. (Environnement NF) All service parts (hinges, weels, etc.) of furniture should be separately deliverable for five years. (Stichting Milieukeur and Blauer Engel) - Easy disassembly of all parts of the furniture. - Disassembly for more than 90% of the furniture into: metals/inert materials/combustible materials. 1 - Separation possible of larger parts made of synthetic foam and massive plastics (> 200g). - Furniture boards with a synthetic or synthetic resin layer do not need to be separable in separate materials 2. - Disassembly of seating furniture: if the upholstery and/or filling are assembled to the main construction, these should be easily separable. Glued surfaces, which cannot easily be separated, are not permitted. Connections with clamps are permitted, if these connections can also be used for new parts. (Stichting Milieukeur) 1 Inert materials are stony materials and glass. Combustible materials are: plastics, textile, leather, rough fibers and woody materials. 2 The reason for this is that these boards are hardly recycled in practice. 8

9 - Materials have to be easily separated. - Adhesive bindings between wood and wood based materials is permitted. - The use of composite materials is not permitted. - Adhesive bindings are only permitted if this is necessary with respect to the ergonomic construction of the back of the seat. - The individual parts, especially parts that wear out fast, have to be easily separable. - Essential parts that wear out fast have to be deliverable for at least 10 years after ending of production of the specific model. (Österreichisches Umweltzeichen) 3.3 Proposal for draft criteria All existing criteria in the field of reparability are based on the same principle: that service parts have to be deliverable during a certain number of years after purchase of the product. From the side of manufacturers and retailers objections have been raised against this approach: It is very difficult to guarantee the availability of spare parts, in particular if producers are out of business. It poses SME's for the problem how to keep a stock of all parts for such a long period of time. Care should be taken not to develop criteria which make it impossible for SME's to apply for the Eco-label. For some parts of furniture products, repair is for safety reasons not allowed. Some furniture exists of only one part (e.g. chairs made of PVC), which makes reparation impossible. The producer or retailer should not be held responsible for wrong use by the consumer. Therefore, some sort of arbitration should be incorporated in the scheme to determine if the consumer has wrongly used or treated the product. From environmental point of view, on the other hand, one can point to the fact that reparability ensures a longer life-span of the product. As mentioned in paragraph 1.3 a long life time can balance environmental impacts of furniture during production and waste. It is therefore an issue that should not be ignored. To counter the above-mentioned objections some manufacturers are of the opinion that it is better to rely on technical with respect to durability than to set criteria for reparability. This also appears to be the approach of eco-labels that refer to international and national with respect to durability, like Nordic Swan and Goldene M. These eco-labels do not contain separate criteria on reparability. For example, Nordic Swan did not set any for reparability since these would have to be very product specific and detailed (e.g. what is considered a spare part?). Another suggestion was made by the AHWG, namely to make reparability an extra feature within the Eco-label, e.g. an A plus within the label. However, this is an approach which can not be followed by the EU Eco-label (and most of the national eco-labels) Presuming that the criteria with respect to durability provide sufficient insurance with respect to a long life span, and the fact that legally, consumers are given a certain warrantee, it is proposed to set no criteria on reparability. 9

10 No criteria are set with respect to reparability. This issue could be taken up again in a revision of the criteria. 4 Maintenance 4.1 Options Few labels contain criteria with respect to maintenance. The options are: 1. Detailed, absolute with respect to the maintenance product (Nordic Swan); 2. Measure based with respect to maintenance itself (Stichting Milieukeur); 3. Consumer information (Goldene M and Nordic Swan). 4.2 National eco-labels and EU Eco-labels Detailed, absolute Measure based Specific requirements with respect to maintenance products for outdoor furniture: - Not classified as hazardous to health in Nordic countries. - Maximum of 2% by weight of substances that fulfil the criteria for environmental harmfulness according to the relevant regulations in Nordic countries, or according to the EU classification system Directive 67/548/EEC with specific conditions and changes. - Biocides contained in maintenance products must not be bio accumulative. - Surface treatment agents may contain a maximum of 5% by weight of organic solvents. - No halogenated organic compounds, halogenated organic flame retardants, phthalates, aziridine and polyaziridines, along with pigments and additives based on lead, tin, cadmium, chromium VI, mercury and their compounds. (Nordic Swan) Cleaning of products should be possible without organic based solvents. (Stichting Milieukeur) 10

11 Consumer information Information on cleaning and care has to be provided. (Goldene M) The manufacturer/supplier should recommend specified requirements (see above) regarding maintenance products and should specify the recommended product s trade name. (Nordic Swan) 4.3 Proposal for draft criteria There are two environmental aspects relevant to maintenance. Maintenance and care safeguard the furniture s life-span. However, maintenance can also constitute extensive environmental impact. Many of the maintenance products available to consumers on the market today contain environmentally hazardous substances and organic solvents. The Eco-label cannot impose requirements on the consumer s choice of maintenance product, but demands can be placed on the producer to recommend less environmentally harmful maintenance products. The Nordic Swan eco-label for outdoor furniture contains very detailed information on which products to use and even requires the producer to mention the brand s name of the most appropriate cleansing product. This would not work in the European market since so many different products are on the market. Therefore, the criteria should be kept more pragmatic. Cleaning of products should be possible without organic based solvents. Information on cleaning and care has to be provided. Assessment and verification The applicant and/or his supplier shall provide a declaration completed with documents to support this declaration that this criterion is met. A maintenance instruction has to be included with the product. 5 Recycling 5.1 Options Recycling requirements on product level are very limited in existing schemes. Most recycling requirements are on a material level (see also annex A). Several options are available to deal with recycling on product level: 1. Non specified reference to international and national legislation (Nordic Swan and NF Environnement); 2. Measure based (Ökocontrol, Nordic Swan, EU Eco-label Hard floor coverings, NF Environnement, Österreichisches Umweltzeichen); 3. Consumer information (Stichting Milieukeur, EU Eco-label Mattresses). 11

12 5.2 National eco-labels and EU Eco-labels Non specified reference to (inter)nat. The producer or importer of ecolabelled products ensures that national legislation governing recycling schemes for products and packaging are fulfilled in the Nordic countries in which the ecolabelled product is sold. (Nordic Swan) Measure based Waste during production which cannot be reused at location and containing more than 5% of organic materials has to be disposed of in authorized installations according to national legislation. (NF Environnement) Products have to be recyclable or fit for reuse. Materials have to be separable. (Ökocontrol) Waste generated during furniture production has to be reduced and recycled as far as possible. Waste deriving from renewable resources may be exploited for energy purposes. (Nordic Swan) At least 70 % (by weight) of the total waste generated by the process or the processes shall be recovered according to the general terms and definitions established by Council Directive 91/156/EEC of 18 March 1991 amending Directive 75/442/EEC on waste. (EU Eco-label Hard floor coverings) Possibility of disassembly at end of life of each element heavier than 50 gram. (NF Environnement) Consumer information The producer or retailer has a take back obligation. (Österreichisches Umweltzeichen) Consumer information on the best way of discarding the furniture has to be provided. (Stichting Milieukeur) Please consult your local authority on the best way to dispose of your old mattress. (EU Eco-label Mattresses) 5.3 Proposal for draft criteria The environmental impact of furniture is to a large extent associated with waste. According to information of UEA, it is likely that most furniture waste is dumped although no detailed official statistics are available. An increase in consumption of furniture contributes to a rise in the amount of waste associated with furniture and vice-versa. Increased recycling and re-use of furniture has the opposite effect. ( Therefore, recycling of the materials used in furniture after end of life should be encouraged. It goes without saying that national legislation in the field of recycling has to be fulfilled, but this is an obligation for all manufacturers and does not need special mentioning in the Eco-labelling scheme. Several aspects are necessary to take into account when formulating criteria for recycling at product level: 12

13 Disassembly is a prerequisite to ensure recycling, but is difficult to test (it will come down to expert judgement). Disassembly is more expensive than moulding furniture, after which the materials are separated for recycling. Recycling needs a take back system of products. This brings about certain problems: o The change of materials by consumers (e.g. painting etc.) should be taken into account when setting criteria for take back. o Take back of furniture is of no use when there is no system to handle products that are taken back. o There is discussion on the fact if the responsibility for take back has to be posed either on the retailer or the manufacturer. o The costs of take back of products will directly or indirectly be paid by the consumer. None of the approaches of existing labels provides a solution to the above-mentioned dilemma s. It would be very ambitious to require the set up of a take back system for all types of furniture. For this reason it is suggested to only impose criteria with respect to recyclability, but not to require the set up of a take back system. Products have to be recyclable or fit for reuse. Materials have to separable. In the user manual with the product the options of recycling and reuse have to be mentioned. Furthermore, consumers have to be pointed to the fact to contact their local authorities on the best way to dispose of old furniture. Assessment and verification: The applicant shall provide appropriate information on the construction and composition of the product on the basis of which the certificating institute can assess whether the product is separable and recyclable. The applicant shall provide a sample of the product s packaging and of the information supplied with the product. 6 Reuse 6.1 Options Reuse is only covered by two schemes. The options are: 1. Measure based (Ökocontrol); 2. Consumer information (Stichting Milieukeur). 13

14 6.2 National eco-labels and EU Eco-labels Measure based Consumer information Products have to be recyclable or fit for reuse. (Ökocontrol) Reuse of materials has to be mentioned as an option to the consumer. (Stichting Milieukeur) 6.3 Proposal for draft criteria Reference is made to the proposed criterion for recycling. 7 Waste management hazardous substances 7.1 Options No requirements were found with respect to waste management of hazardous substances in the national eco-labels or other EU Eco-labels. The main reason for this is probably that the management of hazardous substances is already part of national legislation. 7.2 Proposed criteria It is proposed not to set a criterion for waste management of hazardous substances. 8 Transport 8.1 Options Only one label contains a criterion with respect to transport, which can be categorised as: 1. Measure based standard (NF Environnement). 8.2 National eco-labels and EU Eco-labels Measure based Space during transport and storage has to be optimised. (NF Environnement) 14

15 8.3 Proposal for draft criteria Optimised use of space during transport and storage is not only in the interest of the producer and retailer from an environmental point of view, but is probably also aimed at for economical reasons. For this reason it seems unnecessary to put this requirement into the scheme. Moreover, it may be very difficult to verify compliance with this requirement. It is proposed not to include a criterion on transport in the EU Eco-label Furniture. 9 Ergonomics 9.1 Options Very few of the national eco-labels contain ergonomic criteria. The following options are presented: 1. Specified reference to national (Österreichisches Umweltzeichen); 2. Detailed, absolute (Österreichisches Umweltzeichen); 3. Open requirement (ÖkoControl). 9.2 National eco-labels and EU Eco-labels Specified reference to (inter)nat. Detailed, absolute Open requirement Sizes of seats and desks for use in schools have to fulfil the criteria of ÖNORM A (Österreichisches Umweltzeichen) With respect to office and swivel chairs: - Testing according to ÖNORM A 1675; - Seat and back have to be upholstered; - The wheels have to be light and quickly responding; - The break system has to fulfil the necessary safety requirements according to appropriate norms; - A spring has to intercept jerking when adjusting the seat in height; - Operation of adjustability mechanisms has to be possible without using force and from seating position, with the exception of the back; - The back should be adjustable for large persons; - Armrests have to be present; - Upholstery has to be breathable and permeable for vapour; - The combination of upholstery, shape and seat has to prevent sliding and ensure a full use of the seat; - Information on correct seating has to be provided; - Dynamic seating principle: this has to be supported by the construction of the seat. (Österreichisches Umweltzeichen) The product has to adapt to the human being and not the other way around. This applies to chairs (depth and height), beds (height) and kitchens (height work top). (ÖkoControl) 15

16 9.3 Proposal for draft criteria It may be desirable to formulate ergonomics criteria for office chairs and school furniture, sub-groups where ergonomics play an important role. On the other hand, may vary in different countries and it may be expected that the market for office chairs and school furniture will regulate itself on this issue (producers will follow demand for ergonomics certified products). This and the fact that only two of the national labels have set criteria regarding ergonomic aspects and the fact that the requirements will probably be very hard to verify unless certification is required, it is proposed not to set any for ergonomics. It is proposed not to include a criterion on ergonomics. 10 Safety 10.1 Options Only Österreichisches Umweltzeichen and Goldene M contain specific safety requirements. Nordic Swan has included safety issues together with durability, strength and stability. The following options can be distinguished: 1. Specified reference to international and national (Österreichisches Umweltzeichen and Goldene M); 2. Non specified reference to international and national, including specific levels to comply to (Nordic Swan) National eco-labels and EU Eco-labels Specified reference to (inter)nat. - Desks have to be adjustable in height and fulfil the criteria of ÖNORM A 1676 and ÖNORM EN Swivel chairs have to fulfil the criteria of ÖNORM A 1675 or DIN 4551 regarding the seize, fundamental technical safety of shape, stability and strength. - Desk chairs have to fulfil the criteria of ÖNORM A 1610 Part 5 concerning the materials and their effect, stability, distortion and durability. - If a gas spring is used for the adjustment in height then this has to fulfil the prescribed safety requirements. - Textile upholstering has to fulfil ÖNORM EN ISO (Österreichisches Umweltzeichen) Non specified reference to (inter)nat. Safety requirements of E DIN EN (Goldene M) Durability, strength, safety and stability requirements in nat., Eur. or other internat., with specific reference to different (ISO) levels for testing. If a standard other than ISO/EN is fulfilled, proof of comparable appliance by a test institute is required. If no standard exists, evaluation by independent test institute. (Nordic Swan). 16

17 5.3 Proposal for criteria It is suggested to follow the approach of Nordic Swan and to refer to existing international and national in the field of safety and to require that specific quality levels (according to ISO) are met. This does not need a separate criterion if the approach as suggested in paragraph 1.3 is followed. Special attention should be paid to the fire safety of the product. The producer can make use of international to test fire behaviour. However, none of the national ecolabels or other EU Eco-labels require testing on fire behaviour. Within the first meeting of the Ad Hoc Working Group it was stated that in case no flame retardants are used, the consumer should be made aware of the fact that the product is not fire safe. This is however not in line with the approach followed by the national labelling schemes and the EU Eco-label. Moreover, this would require further specification indicating what is meant by 'not fire safe' and further specification based on the flammability of the materials used. It is proposed to follow the approach of Nordic Swan and to refer to existing international and national in the field of safety, with a reference to minimum testing levels. Safety can be included in the same criterion as durability. For this reason no separate criterion is needed (see paragraph 1.3). It is proposed not to set a criterion with respect to flammability when no flame retardants are used. 11 Packaging 11.1 Options Nearly all national eco-labels for furniture contain criteria with respect to packaging. In other EU Eco-labels packaging is only dealt with in the label for footwear. The following options are used: 1. Detailed, absolute (Goldene M, Österreichisches Umweltzeichen, Nordic Swan, Milieukeur, EU Eco-label Footwear); 2. Measure based (Österreichisches Umweltzeichen, Blauer Engel, NF Environnement). 17

18 11.2 National eco-labels and EU Eco-labels Detailed, absolute Used plastics have to be free of halogenated organic compounds and cannot be based on styrol compounds. (Österreichisches Umweltzeichen) Plastic material containing chlorine is not permitted. (Nordic Swan) The amount of weight of package material may not exceed 40 kg, unless for sound reasons. (Goldene M) Packaging needs to be made of one type of recyclable material (cardboard, paper, polyethene, polypropene, polystyrene). Packaging may consist of more materials if this can be separated easily by hand in recyclable parts consisting of one material. (Stichting Milieukeur) Measure based If packed in carton boxes, package should consist of at least 80% recycled material. If in plastic bags, then it should be recycled material (EU Eco-label footwear) The one who brings packaging in the market has either a take back obligation or the obligation to participate in a collecting and recycling system. (Österreichisches Umweltzeichen) Packaging has to be breathable insofar as possible. (Blauer Engel and Österreichisches Umweltzeichen) - Packaging should be made of easy recyclable materials or materials of renewable sources. - Complex non recyclable composites are permitted if it is used in multirotation packaging. This criterion applies to packaging of end products and packaging used by suppliers. (NF Environnement) 11.3 Proposal for draft criteria Reference is made to the European Directive on packaging and packaging waste 94/62/EC. The Directive contains essential requirements which all packaging introduced onto the EU market has to satisfy. The CEN has developed with respect to the implementation of the essential requirements, some of which are under revision (EN EN 12432). The Directive aims at reducing packaging waste and indicates methods how to achieve this, one of which is recycling. DG Environment has a policy to encourage the use of recycled material as much as possible. This would lead to the adoption of the requirement of the EU Eco-label Footwear (cardboard: 80% recycled, plastics 100% recycled). Relevant branch organisations have been consulted on the question if it is feasible to require recycled material. If packaging is made of cardboard it should not be a problem. 18

19 For plastic material however, it appears to be a very hard criterion to comply with, for several reasons: Recycled plastic is not used for packaging material on a large scale. Although plastic packaging material is collected for recycling purposes, it is mainly used to produce other products and not for packaging material. Packaging material composed of recycled plastic is mainly hard plastic, like crates. This is (probably) not used by the furniture industry. Recycled plastic foil is of inferior quality. Recycled plastic foil is for its dark colour less attractive from a marketing point of view. Since the approach of Stichting Milieukeur is less stringent but still fits in well with the objective of encouraging recycling of packaging material, it is suggested to combine this approach with the one of EU Eco-label Footwear. Packaging needs to be made of one type of recyclable material (cardboard, paper, polyethene, polypropene, polystyrene). Packaging may consist of more materials if this can be separated easily by hand in recyclable parts consisting of one material (cardboard, paper, polyethene, polypropene, polystyrene). Where cardboard is used for the final packaging of furniture, it shall be made from a minimum of 80% recycled material. Assessment and verification: A sample of the product packaging shall be provided on application, together with a corresponding declaration of compliance with this criterion. 12 Consumer information 12.1 Options All national eco-labels indicate what consumer information should be provided. This is done either in a very elaborate way or kept very simple. It is done on the basis of measure based National eco-labels and EU Eco-labels Measure based An instruction for assembly and one for use have to be included. The instructions for use need to fulfil DIN (8418-2/88). (Goldene M) Maintenance instructions have to be included with the furniture and for outdoor furniture also instructions on durability (including weather resistance). (Stichting Milieukeur) - Instructions for cleaning and maintaining the product with specific instructions for the different materials; - Information regarding which have been applied in testing the product s properties of use; 19

20 - Illustrated assembly instructions if the item of furniture or fitment is so constructed that it needs to be assembled; - Information about the materials used in the product and how these can be recycled or treated in an environmentally friendly manner. - With respect to outdoor furniture the consumer is informed as to the best way to use, maintain and store it. (Nordic Swan) - Instruction on parts subject to wear and their repair or replacement, if applicable repair service, and 5 years deliverance spare parts; - Type and source of wood; - Other materials; - Instruction on construction or transportation of the product; - Instruction on assembly; - Durability. (Blauer Engel) - Name and address of holder of label; - Modeldescription; - Quality of furniture according to ÖNORM A (S or H) - Used wood type, and other materials; - Used materials for surface treatment; - Measurements; - Maintenance instruction; - For office and school furniture information on ergonomic design of workplace or classrooms. (Österreichisches Umweltzeichen) The product shall be sold with relevant user information, which provides advice on the product's proper and best general and technical use as well as its maintenance. In detail is indicated what information has to be provided on the packaging and/or on documentation accompanying the product. (EU Ecolabel Hard floor coverings) - NF Environnement label and information; - Information on waste disposal at end of life; - Information on maintenance (Environnement NF) 12.3 Proposed draft criteria In the previous paragraphs it has already been indicated what information should be provided on issues like maintenance, recycling, etc. In summary, the following information should be supplied: Consumer information should consist of: Information regarding which have been applied in testing the product s durability, safety and fitness for use; Information on cleaning and care; Information on the options of recycling and reuse and the fact that local authorities should be contacted on the best way to dispose of old furniture; An instruction for assembly; 20

21 With respect to outdoor furniture the consumer is informed about the best way to use, maintain and store it. Verification and assessment: The applicant shall provide a sample of the information material supplied with the furniture. 21