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UEAPME

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UEAPME ...

     UNION EUROPEENNE DE L’ARTISANAT ET DES PETITES ET MOYENNES ENTREPRISES EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE EUROPEAN ASSOCIATON OF CRAFT, SMALL AND MEDIUM-SIZED ENTERPRISES UNIONE EUROPEA DELL’ ARTIGIANATO E DELLE PICCOLE E MEDIE IMPRESE

    UEAPME comments on the draft criteria for soaps and shampoos

    dated 5 September 2005

UEAPME is extremely disappointed with the proposed criteria sent on 16 September 2005 and

    cannot support them. The criteria are the same as in the first draft document. The document does

    not take into account the discussions that took place in the Ad Hoc Working Group. Furthermore,

    these criteria are unrealistic and do not correspond to the reality of the European market of soaps

    and shampoos.

UEAPME has provided much information and data on the market situation regarding soaps and

    shampoos. Yet, none of this information has been taken into account in the last criteria. So once

    again, UEAPME would like to propose the following modifications to the criteria.

    ECOLOGICAL CRITERIA

    1. TOXICITY TO AQUATIC ORGANISMS

    The latest draft proposes the following values:

    Shampoo, shower products and liquid soaps: 16 000 l/g AC

    Solid soaps: 3 500 l/g AC

    Conditioner: 20 000 l/g AC

UEAPME has showed that these values are inadequate for Southern Europe and therefore proposes

    the following:

    Shampoo, shower products and liquid soaps: 30 000 l/g AC

    Solid soaps: 7 000 l/g AC

    Conditioner: 90 000 l/g AC

    3. AEROBIC BIODEGRADABILITY

    The latest draft proposes the following values:

    Shampoo, shower products and liquid soaps: 25 mg/g AC

    Solid soaps: 15 mg/g AC

    Conditioner: 50 mg/g AC

UEAPME has showed that these values are inadequate for Southern Europe and therefore proposes

    the following:

    Shampoo, shower products and liquid soaps: 500 mg/g AC

    Solid soaps: 300 mg/g AC

    Conditioner: 500 mg/g AC

    MAISON DE L'ECONOMIE EUROPEENNE - RUE JACQUES DE LALAING 4 - B-1040 BRUXELLES

    TEL ?32 2 230.75.99 - FAX ?32 2 230.78.61 - E-MAIL info@ueapme.com

    4. ANAEROBIC BIODEGRADABILITY

    The latest draft proposes the following values:

    Shampoo, shower products and liquid soaps: 25 mg/g AC

    Solid soaps: 15 mg/g AC

    Conditioner: 50 mg/g AC

UEAPME has showed that these values are inadequate for Southern Europe and therefore proposes

    the following:

Shampoo, shower products and liquid soaps: 100 mg/g AC

    Solid soaps: 50 mg/g AC

    Conditioner: 400 mg/g AC

    5. FRAGRANCES

    The latest draft proposes that:

    “fragrance must not be added to products that are marketed specifically at babies/infants of age

    less than 3 years”.

This point has already been discussed in the AHWG. The majority of participants were against this

    criterion which would exclude both South and East European manufacturers. UEAPME therefore

    proposes to not exclude fragrances from any age group.

    8. HAZARDEOUS INGREDIENTS

    According to the latest draft “Ethylenediaminetetraacetate (EDTA) and its salts and not readily

    biodegradable phosphonates may only be added in solid soaps and only in a maximum content of

    0,6 mg/g AC”.

In order to ensure coherence among all the detergent criteria, UEAPME suggests excluding

    completely the use of EDTA while phosphonates could be used within the limits set out below:

    ? non biodegradable phosphonates up to 0,6 mg/g AC

    ? biodegradable phosphonates below 35% up to 5 mg/g AC

    ? easily biodegradable phosphonates up to 15 mg/g AC

    9. PACKAGING

    According to the latest draft “the Weight/Content Relationship (WCR) must be < 0,30g packaging/g

    product”.

This packaging ratio (< 0,30g packaging/g product) will penalise traditional manufacturers who use

    glass as packaging. For glass bottles the ratio should be 1g packaging/product.

    10. PERFORMANCE

    Regarding performance “the cleaning or conditioning efficiency of the product must be

    demonstrated through a laboratory test. The efficiency of the product must be equal to, or better

    than a comparison product. The comparison product may be a market leading product for the same

    usage and in the same area as the product is being marketed. The market leading product can be

    chosen among the 4 highest selling products in the area the product is being marketed. The

    MAISON DE L'ECONOMIE EUROPEENNE - RUE JACQUES DE LALAING 4 - B-1040 BRUXELLES

    TEL ?32 2 230.75.99 - FAX ?32 2 230.78.61 - E-MAIL info@ueapme.com

comparison product may also be a generic product. The comparison product must be approved by

    the relevant Competent Body.”

There is currently no “official test” that can assess the performances of the various cosmetic

    products. This will lead to considerable differences from one Member State to another, resulting in

    unnecessary complications with respect to the free circulation of goods in the internal market.

The current proposal is vague and imprecise from a technical and scientific point of view.

    Furthermore all the responsibility lies with the Competent body.

UEAPME is also very concerned about the cost of tests. Indeed, the laboratories UEAPME

    contacted on this issue suggest that the testing costs are well beyond the means of SMEs.

    Therefore UEAPME would like to stress once again that a decision has already been taken

    based on the mildness of the formula.

The in-vitro and in-vivo tests which guarantee the safety of the product are in some cases made

    official and published (see for instance, the l’HETCAM Test in the French Official Journal).

    Moreover they are economical and in line with Point 11 of the criteria “increased health safety”.

    This sentence would be more coherent if the dossier of the product contained a series of tests on

    skin irritation.

UEAPME is convinced that the proposed testing procedure is not feasible and suggests carrying out

    the following procedure:

    A. To formulate a product per product group following the proposed ecolabel criteria.

    B. To carry out performance tests as proposed against one of the four best selling products in

    France and in Italy (UEAPME can supply some data and samples if needed) to check if the

    formulation passes the performance test against best selling products in France and Italy.

    C. To carry out consumer test where the proposed formulations should perform fairy well (they

    do not have to be of the highest excellence, but they have to be accepted by consumers).

    The outcome will either be:

    (i) eco-label cosmetics can really be applied in the two (by far) biggest markets

    in Europe. This will lead to good results for the Ecolabel Cosmetics.

    OR

    (ii) the eco-label criteria are impossible to apply in France/Italy/other countries

    for large volumes: in this case nobody can say that the criteria are ready and

    OK for application = obviously they should be revised and start again with

    step A.

Finally the accompanying note indicates that “We have proposed to omit the mildness test

    requirement because experts we have consulted believe such a requirement will not lead us to the

    desired result. They say that a much better way to make sure the products are mild is to regulate the

    ingredients, e.g. by eliminating allergenic compounds. They also say that the ranking of products

    varies a lot from one test method to another. Furthermore there are many producers across Europe

    who are sceptical to patch tests and the HETCAM test. They claim the tests do not give a good

    picture of the products mildness and some claim the tests are too sensitive and cumbersome

    (requires a veterinarian).”

This approach is absolutely incorrect. The mildness of a cosmetic measures the level of skin

    irritation i.e. it considers the substances containing the phrases R36-38-41-34-35 and not the R42

    and R43 phrases. Acting upon the allergenic compounds does not correspond to the skin irritation of

    MAISON DE L'ECONOMIE EUROPEENNE - RUE JACQUES DE LALAING 4 - B-1040 BRUXELLES

    TEL ?32 2 230.75.99 - FAX ?32 2 230.78.61 - E-MAIL info@ueapme.com

    a cosmetic. Requesting that an eco-label is “hypoirritant” is an important guarantee for consumers but it has nothing to do with allergies.

As far as the HETCAM TEST is concerned, please see the comments above.

MATRIX CALCULATION

    As the “matrix calculation” shows, the excel sheet evaluating the environmental impacts of various

    parameters is illogical.

Substances such as perfumes, phosphonates or dyes already have well defined values. It is therefore

    inconceivable that these substances should be taken into account again when the CDVtox is

    calculated.

CDVtox already contains toxicity and biodegradability parameters. It is therefore both technically

    and scientifically incorrect to add to at a later stage.

On this point UEAPME only see two feasible possibilities

    1. maintain the levels proposed under point 1 of this document by UEAPME for all the

    parameters st version of the matrix calculation, drawn up by UEAPME which 2. adopt the 1

    excludes substances which have previously already been taken into account. In this

    second case it will be possible to review the limits under point 1 and to slightly

    reduce the limits.

In conclusion, UEAPME is committed to see that the criteria adopted are precise, scientifically

    valid and supported by official literature. UEAPME cannot under any circumstances accept that

    SMEs, in particular from Southern Europe are excluded from the eco-label scheme.

UEAPME acknowledges and understands the cultural and historical motivation at the basis of the

    criteria but cannot accept that these criteria are identical to those of the Nordic Swan. The European

    market is very diverse. It has different requirements and it is not acceptable that some geographical

    areas are privileged over others.

    Brussels, 23 September 2005

    For further information on this position paper, contact:

Christel Davidson, Environmental Policy Advisor,

    UEAPME,

    Rue Jacques de Lalaing, 4,

    B-1040 Brussels.

    Tel: +32 2 2307599

    E-mail: c.davidson@ueapme.com

     UEAPME is the employer's organisation representing the interests of crafts, trades and SMEs from the EU and accession countries at European level.

    UEAPME has 78 member organisations, which represent crafts and SMEs across the whole of Europe, covering over 11 million enterprises with nearly 50 million employees.

    UEAPME is a European Social Partner.

    MAISON DE L'ECONOMIE EUROPEENNE - RUE JACQUES DE LALAING 4 - B-1040 BRUXELLES

    TEL ?32 2 230.75.99 - FAX ?32 2 230.78.61 - E-MAIL info@ueapme.com

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