CB Forum Meeting: Tuesday 24 November 2015

Transcription

1 CB Forum Meeting: Tuesday 24 November 2015 Avenue de Beaulieu 5, B-1160 Brussels, meeting room C 10:00-17:00 Organisation Phone number address HRUBY Pavel CENIA pavel.hruby@cenia.cz WAIDTL W Jakob Ecolabelling Denmark jwa@ecolabel.dk ESKELAND Marianne Ecolabelling Norway mbe@ecolabel.no KOEL Mari-Liis Estonian Ministry of Environment DE SOUSA PINTO Carla European Commission DG ENV Carla.pinto@ec.europa.eu FERRATINI Silvia European Commission DG ENV Silvia.FERRATINI@ec.europa.eu LUDAIN Sylvie European Commission DG ENV Sylvie.ludain@ec.europa.eu KOUGOULIS Jiannis European Commission DG ENV Jiannis.Kougoulis@ec.europe.eu KAPS Renata European Commission JRC IPTS Renata.Kaps@ec.europe.eu DONATELLO Shane European Commission JRC IPTS Shane.DONATELLO@ec.europa.eu KOWALSKA Malgorzata European Commission JRC IPTS Malgorzata-Agata.KOWALSKA@ec.europa.eu SCHORPION Hannelore Belgian CB Hannelore.Schorpion@milieu.belgie.be DE RIDDER Kathelijne Belgian CB kathelijne.deridder@milieu.belgie.be WOLF Oliver European Commission DG ENV Vinhas Ana Direcçăo-Geral Das Actividades Económicas Ana.Vinhas@dgae.min-economia.pt SCHOLTZ Henning RAL ggmbh Henning.scholtz@ral-gGmbH.de 1

2 1. Welcome, adoption of agenda and June 2015 CB Forum minutes, AOB requests, & Chair/Vice Chair election (EC/Chair) (10:00-10:15) The agenda was rearranged as some of the speakers were not able to attend the meeting. Regardless, the November CB Forum Agenda and June CB Forum Minutes were accepted. Considering that Gianluca Cesarei (ISPRA), the former CB Forum Chair, could not attend, participants were asked whether they agreed to have Hannelore take over the role of CB Forum Chair. All CBs that were present supported Hannelore Schorpion (BE CB) as the new Chair. Hannelore informed them that any ideas for specific discussions in the framework of the CB Forum are welcome and should be addressed to her. Hannelore Schorpion was elected as the CB Forum Chair. The election of the Vice-Chair was postponed to the next meeting. 2. Presentation of the finished EU ECOLABEL TOOLBOX (see Annex) (France-absent) (10:15-10:40) The EC indicated that it attended a meeting organised by the Bordeaux Regional division of AFNOR on TAs. Notable observations were made at this meeting: Some licence holders are very active in promoting the EU Ecolabel. They would like to identify attainable concrete actions in order to improve visibility, and to join efforts to promote the EU Ecolabel scheme. It was proposed to discuss this possibility at the EUEB level, through the setup of a Task Force to upscale these actions at the EU level. The first action could be to identify stakeholders who would contribute to that promotion. The EU Ecolabel toolbox (ADEME) is accessible from the EU Ecolabel website on the Product Groups and Criteria page. A discussion on how the toolbox can be implemented without duplicating data gathering is foreseen between the EU Ecolabel team, ADEME and the consultants running the project. Further discussion is postponed to the next EUEB. Any written comments can be sent to the EC (Silvia). In response to the Estonian CBs s question on if data will be available in English, the EC informed that this would be checked. 3. EU Ecolabel updates (EC) (10:40-11:30) a. General updates The EC gave a presentation on general updates, which will be uploaded in CIRCA. Due to the fact that the November EUEB meetings were postponed, the EC will check if the planning for wooden floor coverings can still be maintained. It is crucial at this stage to get written feedback on the draft that was circulated last October. The EC will send a reminder. 2

3 Even if the latest amendment for P&V is still pending publication, a new draft (non-official) version of the UM that takes into account the latest changes is needed, in order to allow CBs to instruct licence holders on how to prepare new applications. The EC will provide such a draft. It was pointed out that there is still one mistake in the Excel sheet for laundry detergents: Applicants cannot fill in the information on the amount of water in liquid products, as the field is blocked. The EC will upload a corrected version ASAP. The interpretation given by the Helpdesk to the French CBs on how the licence number can be displayed together with the EU Ecolabel logo should be added to the "EU Ecolabel Logo Guidelines" in order for all CBs to act in the same way. The Helpdesk will update the "EU Ecolabel Logo Guidelines" accordingly. The EC asked CBs to double-check statistics before they are submitted to the Helpdesk because sometimes the evolution of the number of licences and products seems quite odd. It was highlighted the importance of having accurate statistics published on the EU Ecolabel website, as they are the official ones used for communication purposes. b. Optimise promotion efforts for the newly released EU Ecolabel videos: presentation of the new Videos library and FAQs (see Annex) The presentation given on how the EU Ecolabel videos can be used will be uploaded in CIRCA. CBs felt the need to have more promotional material such as leaflets, etc. The EC will discuss with the Helpdesk on the possibility to share communication material on a common space. The need to respect pictures/videos copyrights was highlighted (info on that will be provided together with the promotional material). c. Update on communication activities: promotion of EU Ecolabel success stories on Euronews and update on the contract for the drafting of a communication strategy for the EU Ecolabel The EC gave a presentation, which will be uploaded in CIRCA. CBs asked the Commission to be involved in the development and implementation of the foreseen Communication Strategy for the EU Ecolabel. Once a proposal is developed by the contractor, a specific slot at the CB Forum will be dedicated to present it to CBs. 3

4 4. Guidance on how to count P&V products (see Annex) (EC/Helpdesk-absent) (11:30-11:55) It was noted that if 2 languages appear on one label it should only be counted as 1 product this is a general remark in the guidance The EC requested the Helpdesk to provide feedback to Greece, informing them that their interpretation of the guidance to count P&V products is correct. 5. EXCEL calculation sheet (RoC): How to find the version/questions on how to use/improvement proposals for EXCEL sheets (after finalising the revision of the criteria for all detergents PGs) (see Annex) (Germany) (11:55-12:05) This point of the agenda was moved to the next CB Forum meeting. 6. LUBRICANTS: Issues to be taken into account during the upcoming revision process based on the experience of CBs (EC) (12:05-12:50) The EC gave a presentation, which will be uploaded in CIRCA. CBs were requested to provide the EC (Sylvie LUDAIN) any information that could be useful to take into account for the revision of lubricants by 15 January During the revision, it will be very important that the CBs who have licences share any information on new classification of ingredients, etc. with IPTS without disclosing sensitive info. LUNCH (12:50-13:50) 7. Raising awareness on security aspects related to the usage of EC IT systems like ECAT (see Annex) (ENV IT Team) (13:50-14:05) This point of the agenda was moved to the next CB Forum meeting. CBs were informed that a meeting organised by the EC was to be held in early December between the Helpdesk, EC and IT Department in order to discuss how ECAT and its related portals can be improved. 4

5 8. Virtual CB Forum conclusions (EC) (14:05-14:35) a. TEXTILE PRODUCTS (2014/350/EU), Criterion 14(a) Hazard classification restrictions in table 5 - PARTIAL The EC will send the partial conclusion validated by IPTS by 4 December This partial conclusion will be inserted in the Excel sheet prepared by the DK CB, which will be sent out as Virtual CB forum, together with the feedback provided by JRC/IPTS. b. PAINTS & VARNISHES (2014/312/EU) - deadline 23 rd October 2015 The Helpdesk will send the final conclusion by 4 December. c. CONVERTED PAPER PRODUCTS (2014/256/EU) - deadline 23 rd October 2015 Based on the feedback received by BE, DK, FR and IT, it was decided to amend the guidance for providing statistics in respect of the product group "Converted Paper Products". In the particular case of envelopes, the elements to take into account when counting the number of products shall be: Colour (only 2 categories are to be considered: white or coloured); Commercial Name / Brand; Under other features, it should be considered the following: - grammage of the paper used as substrate, - window (yes or no) and - closure type (e.g. gum, glue, latex) (yes or no). For practical reasons, "size" should not be considered. d. LUBRICANTS (2011/381/EU) - Deadline 2 nd November 2015 The Virtual CB forum conclusion sent on November 16 th should be considered as valid. 9. Overall issues concerning handling applications (Denmark & France-absent) (14:35-16:05) a. RINSE-OFF COSMETICS: Use of turnover as a user test (see Annex) (Denmark) (14:35-14:50) This point of the agenda was moved to the next CB Forum meeting. 5

6 b. TEXTILES: Interpretation/discussion of requirements (see Annex) (Denmark) (14:50-15:35) By 4 December 2015, the EC will circulate the interpretations suggested by Denmark along with the feedback provided by the JRC/IPTS through the Virtual CB Forum. A webinar may be organised by JRC/IPTS on the issues before Christmas, to agree on and explain final interpretations. After the meeting, it was decided by the EC to have this discussion at the January 2016 CB Forum, after circulating the Excel sheet with the interpretations as a virtual CB Forum question. c. SANITARY TAPWARE: interpretation of criterion 2 (see Annex) (France-absent) (15:35-16:05) The EC indicated that it is not foreseen to update of the guidance document "Legal requirements of the Member States of the EU". The responsibility for products to meet legal requirements lies with producers, which goes beyond the EU Ecolabel s scope. 10. Follow-up on the tasks from last CB meeting (EC) (16:05-16:45) a. PAPER PGs: Update on the requested amendment to criteria on «residual monomers» in C&GP and newsprint paper PGs and new classification of Sodium Acrylate (see Annex) (16:05-16:10) No developments were made on this, due to the fact that no official derogation request form was provided to the EC. The assessment of this issue will be addressed in the revision of the paper products. b. TEXTILES: Update on criterion 1 «cotton» and «GMO-cotton» (see Annex) (16:10-16:20) The EC explained the rationale behind the new formulation of the organic cotton requirement in the draft criteria for footwear, and the intention to have the same requirement in an upcoming amendment on textiles. CBs highlighted their reluctance in making a criterion more stringent during the period of validity of a set of EU Ecolabel criteria adopted recently, and raised the need to have a proper discussion at the EUEB level. The EC informed the CBs about a test that could be used to verify if cotton from GMO origin. The information concerning this verification option will be circulated (added to the Excel sheet prepared by Denmark). 6

7 Two CBs pointed out that they avoid the mixing of GMO and organic cotton by using the organic cotton in a specific part of the product line. They meet the requirements on an annual basis but at product level GMO and Organic cotton are not used together. After the meeting, the EC decided to have a specific session at the January 2016 EUEB meeting, to discuss the organic cotton requirement. c. PAINTS &VARNISHES: New amendment covering a derogation on ADH/MeOH (see Annex) (16:20-16:40) The EC informed participants that the amendment on P&V, which covers a derogation on ADH/MeOH has been positively voted. As new requests for amendments have been put through, Norway highlighted that a strategy to deal with reclassification of substances is needed. This could be one that includes the acceptance to have some EU Ecolabel products classified. The EC explained that Norway s comment will be included as one of the topics to be dealt within the Chemical TF. d. Follow up on 2014 DID List Update (see Annex) (16:40-16:45) The EC explained that a minor update of the DID list will be carried out in 2016 in collaboration with the Nordic Ecolabel. This will include the deletion of substances that are no longer allowed in detergents. 11. AOB (16:45-17:00) The need to have another CB Forum meeting in January 2016 was discussed. The interpretation/discussion of the requirements on textiles was considered urgent. It will be decided if this point should be discussed at a physical CB Forum meeting in January 2016 or if a webinar-based meeting before Christmas shall be held to discuss/explain the interpretations provided by the DK CB. After the meeting, it was decided by the EC to have this discussion at the January 2016 CB Forum, after circulating the Excel sheet with the interpretations as a virtual CB Forum question. 7

8 Annex: 2. Presentation of the finished EU ECOLABEL TOOLBOX Demonstration of the EU Ecolabel Toolbox: online application edited by ADEME International to deploy internationally EU Ecolabel on tourism accommodation and campsite. The tool is a free application dedicated for accommodations wishing to obtain or to renew the EU Ecolabel licence. This tool will be available for all partner countries. This toolbox provides a public front office (delivering criteria, FAQ, extra tips to obtain the EU Ecolabel, the marketing guides, presentation form for accommodation, map of EU Ecolabel accommodations, ), a work front office (diagnostic application, proof models for each criteria, action plan management, cost analysis and business plan creation) and statistics application (for local governments, ADEME and Competent Bodies). 3b. Optimise promotion efforts for the newly released EU Ecolabel videos: presentation of the new Videos library and FAQs The Commission will present the translated "Fall in Love with EU Ecolabel" videos, the Videos library on the EU Ecolabel website and will provide replies to FAQs on how to use the videos. Any questions on how to use the videos should be sent by November 16 th to the Helpdesk. 4. Guidance on how to count P&V products Greece has reported concerns on how to count P&V products. According to the guidance, each different volume size, colour (number of tints referred in the application), and commercial name/brand is considered to be a separate product. When Greece tested this counting method for only one of their licence holders, they came up with a total of nearly 1000 products. If Greece continues to count the products of all of its licence holder, they may reach up to Comparing to other countries, this number is extremely high. As Greece is currently creating a manual for its paint producers, they would like to know how other countries count their P&V products. See excel table attached as well as the EC s guidance document on how to count licences and products. 5. EXCEL calculation sheet (RoC): How to find the version/questions on how to use/improvement proposals for EXCEL sheets (after finalising the revision of the criteria for all detergents PGs) Germany aims to illustrate, on the basis of the RoC EXCEL calculation sheet, on how to find information concerning the version (in older calculation sheets) and how to find the differences between different versions of the same EXCEL calculation sheet. This procedure will be proposed to improve the EXCEL calculation sheets to be developed after the revision of EU Ecolabel criteria for the detergents' family (6 PGs) is concluded. 6. LUBRICANTS: Issues to be taken into account during the upcoming Revision revision process based on the experience of CBs The Commission will collect CBs views on their experience in the implementation of the Commission Decision, issues to be improved and recommendations for the criteria revision process. 7. Raising awareness on security aspects related to the usage of EC IT systems like ECAT The presentation will talk about "IT security while using Commission systems: am I concerned?" and will address the following aspects: - Overview - What are the threats you are exposed to in the cyberspace? - How is your PC infected? - Who is behind security threats and what are their motivations? - How can you be protected? 9a. RINSE-OFF COSMETICS: Use of turnover as a user test Denmark would like to discuss whether the use of turnover can be accepted as user test in Rinse off cosmetic. In the Nordic Ecolabel this is an alternative and it should be discussed if this should be possible in the future also for the EU Ecolabel. 8

9 9b. TEXTILES: Interpretation/discussion of requirements In Denmark several colleagues are involved in the renewal of Textile licenses. In order to give the same information to applicants and in order to handle applications in an equal manner, Denmark listed all decisions and internal agreements in the attached excel sheet. The intention of this point is not to present all decisions nor to explain them, however, other CBs might find the interpretations useful; Denmark s point of view may be beneficial to share. The Excel sheet compiling the list of interpretations is sent together with the invitation and questions/doubts should be sent to the Helpdesk and Jakob Waidtløw by November 16 th. 9c. SANITARY TAPWARE: interpretation of criterion 2 A French customer who wants to apply for EU Ecolabel sanitary tapware has submitted to the French CB the following question: In criterion 2, it is stated: Organic materials in contact with drinking water shall be tested in accordance with the respective requirements of the Member State where the product will be placed on the market. A certificate or, if appropriate, test results issued by national authorities or responsible laboratories shall be submitted. Additionally, if required by the national regulations or the Member State where the product is placed on the market, test results for enhancement of microbial growth and assessment of odor and flavor assessment of water shall be submitted. a. In the guidance, we only can access to the respective requirements of 12 Member States. Is there a document which gives the legal requirements of the other Members Sates? Moreover, the guidance has been made available in June Who is in charge of updating this guidance? b. Once the product has been certified for selling in France, what will happen if the license holder wishes to commercialize the same reference in another country? How can the CB guarantee that this reference is in conformity with the legal requirements in the new selling country? Has the license holder to submit a particular request (with a specific form)? And what about the products that are sold out of EU? Can we benefit from the Polish experience (according to ECAT, this is the sole CB who has certified a sanitary tapware)? 10a. PAPER PGs: Update on the requested amendment to criteria on «residual monomers» in C&GP and newsprint paper PGs and new classification of Sodium Acrylate This point dates from the April 2015 CB Forum. Since then, the EC consulted with the JRC regarding an amendment on the following context: Criterion 4.e of Decision 2011/333/UE (Copying & Graphic Paper); Decision 2012/448/UE (Newsprint Paper); Decision 2014/256/UE (Converted Paper Products) states: 4(e) Residual monomers The total quantity of residual monomers (excluding acrylamide) that may be or have been assigned any of the following risk phrases (or combinations thereof) and are present in coatings, retention aids, strengtheners, water repellents or chemicals used in internal and external water treatment shall not exceed 100 ppm (calculated on the basis of their solid content) [ ] The competent body may exempt the applicant from these requirements in relation to chemicals used in external water treatment. In this case sodium acrylate, existing as a monomer in some polymer dispersions used in paper production, is now classified as H400/H410. Earlier it was not classified. Because of this classification change, it is no more possible to use polymer dispersions containing more than 100 ppm of sodium acrylate in paper production. A Finnish chemicals supplier Kemira brought up this question. The issue was encountered as the REACH registration data of Sodium Acrylate (CAS ) was published by ECHA. Once the information is published, it can be considered as binding and reliable since based on the studies. If a substance has not been classified earlier with any hazardous phrases, a material with monomers of such substance has been EU Ecolabel compliant. If, based on the registration data, the substance is re-classified as environmentally hazardous (H400/H410 in the case of sodium acrylate), the EU Ecolabel criteria for monomers gets strict allowing only levels of < 100 ppm. To a material that has been previously approved to the criteria with levels exceeding the 100 ppm limit, it is a drastic change and will take some time and effort to modify the material or the production process to reach the lower levels if possible at all. While considering options for modifications, we would like to have an opinion and guidance on the issue how to best proceed to comply with the EU Ecolabel criteria. Since the change in the substance data applies on a generic level and will impact more than a few companies, a generic rule on the issue would be appreciated. The Finnish CB supports the request of a major producer of raising the limit to 1000 ppm. At the June 2015 CB Forum, the EC did not receive any formal derogation request from KEMIRA on this subject. The Finnish CB informed that the person in charge of filling in the application was on vacation. As of 23 October, the EC has not received this form from KEMIRA. 9

10 10b. TEXTILES: Update on criterion 1 «cotton» and «GMO-cotton For criterion 1, option a indicates that all cotton blended to organic cotton should be 100% non-gmo. However, option b allows for the use of GMO cotton, As result of non-gmo traceability, almost no one chooses option a. As concluded at the June 2015 CB Forum, aside from applying option b instead of option a, there is no legal solution to offer while a formal solution is being evaluated. The EC will report on the advancement of this issue at the November CB Forum. 10c. PAINTS & VARNISHES: New amendment covering a derogation on ADH/MeOH The EC will report on the proposed upcoming amendment to the criteria that will resolve the the issues identified with regards the use of IPBC. See also background below: There are some P&V applicants want to use IPBC for outdoor paints and varnishes formulation. According to the appendix substance and derogation list, IPBC can be used up to 0.65% but in the concentration, the final paint will be classified as H412. Can derogations overrule criterion 5a on overall restrictions to classifications of risk phrases? If the derogation allows a level of 0.65% IPBC, but this causes the final product to be classified, can it be accepted or not? It is possible that a sentence is needed in criterion 5a to state that even though a derogation is in place the final product will not bear any classification with one of the final H phrases? Whether or not the final product can be classified, the EC will verify to see with legal services to formulate an opinion about the derogation. 10d. Follow up on 2014 DID List Update (EC) This point originates from the conclusions of the April 2015 CB Forum which indicated that Norway would look into the feasibility of updating the 2014 DID list. The EC will now report on the conclusions drawn. 10