CB Forum Meeting, 11 March 2014

Avenue de Beaulieu 5,

B-1160 Brussels, meeting room C

Tuesday 11 March

10:30–17:00

  1. Welcome, adoption of agenda and of the minutes of last CB meeting (Chair) (10:30-10:35)
  2. Follow-up on the tasks from last CB meeting (10:45-11:30)
  1. Guidelines for choosing laboratories and tests institutes: report on the data submitted by CBs (EC)(15 min)
  1. Feedback on plastic parts for TVs (Criterion 4. Design for disassembly for TV) (Netherlands)(15 min)
  1. Follow up on Criterion 20 from French CB on Tourist Accommodation Services: how are other CBsimplementing this criterion? –(EC)Please refer to the note in the Annex (10 min)
  1. Link for the “EU Ecolabel toolbox ShMile 2” now available on EU Ecolabel website (EC) (5 min)
  1. Printed Paper:Criterion 4a.Emissions of Cu and Cr: How to define the number of printing jobs to calculate concentration of Cu or Cr?– Please refer to the note in the Annex (Italy)(11:30-11:40)
  1. Overall issues concerning handling applications (11:40-12:45)
  2. Licence Registration number discrepancies (UK) - Please refer to the note in the Annex (5 min)
  3. Laundry detergents for professional use: use of peraceticacid as bleaching agent (Belgium) –possible amendment? Please see note in Annex (10 min)
  4. Cleaning Vinegar and product scope EU Ecolabel criteria – Please refer to the note in the Annex (Netherlands) (10 min)
  5. Implementation of the new DID list (Chair)- how to behave when handling applications- Please see note in Annex (15 min)
  6. How CBs implement the new fee structure (annual fee: flat rate or based on annual sales?) Two issues arise: Firstly, applicants may choose to apply through a “less expensive” country, which links to the “origin of the product” issue. Secondly, should we go back evaluating turnovers? (Italy) (25 min)
  1. Chair Update on the conclusions taken at the Virtual CB Forum on 'hard floor coverings', 'printed paper' and'laundry detergents'(12:45-12:55)
  1. Logo use: French Cleaning Services company Adomplus – Ménage Ecologique à Domicile requests to use EU Ecolabel logo for marketing purposes - Please see note in the Annex (Helpdesk) (12:55-13:00)

Lunch (13:00-14:00)

  1. Communication and marketing activities on MS level (Helpdesk and EC) – Please see note in the Annex(14:00 -14:30)
  1. Update on the way licenses and trade names on the contract are defined and counted in each MS – Progress of the working group (EC) (20 min) (14:30-14:50)
  1. Discussion on the following product groups under revision/development (including scope) – 'wooden floor coverings', 'tourist accommodations +campsites', 'detergents', 'cleaning services' (IPTS) (60 min) (14:50-15:50)

Coffee break (15:50 – 16:05)

  1. AOB(16:05-17:00)

Annex / Notes to the agenda:

Point 2c:Follow up on Criterion 20 from French CB on Tourist Accommodation Services: how are other CBs implementing?

The action plan agreed by the Commission with France is the following:

1) A letter will be sent to all tourism accommodation holders to remind them the content of the criterion 20. It will be indicated that the yogurts cannot be accepted in a single dose packaging. However, it will also be clarified that home-made yogurt in single dose is accepted if the packaging (jars) used, are reused and reusable;

2) Tourism accommodation holders will be given 6 months maximum to be compliant with the criterion 20;

3) France will take advantage of meetings in region to inform also their license holders about this point;

4) The auditors will inform the hotel owners when they realize their checking.

The Commission expects other countries in similar situation to implement appropriate corrective actions within the same timeframe.

The Commission will ask each country having issued licences for tourism accommodations to provide an update on the situation during the CB Forum meeting and a final status of the issue at the June Competent Body Forum meeting.

Point 3: Printed Paper: criterion 4a. Emissions of Cu andCr: How to define number of printing jobs to calculate concentration of Cu or Cr?

The Criterion states:
The amount of Cr and Cu discharged into a sewage treatment plant must not exceed, respectively, 45 mg per m2 and 400 mg per m2 of printing cylinder surface area used in the press.
The Assessment and Verification states:
Compliance with this criterion shall be assessed by dividing the content of Cr and Cu, as determined by the annual analytical test and by the cylinder surface used in the press during the printing. The cylinder surface used in the press during printing is calculated by multiplying the cylinder surface ( = 2πrL, where r is the radius and L the length of the cylinder) by the number of printing productions during a year (= number of different printing jobs).

One of our applicants interpreted this criterion in the following way: the number of printing jobs is the number of cylinder rotations. However, the final value of concentration for Cu and Cr is very low.

Do you (CBs) agree with this interpretation? Shouldn't it instead divide the emission value of Cr and Cu by the total surface of all the cylinders carved in a year?

The User Manual states:
The Cr and Cu concentration determined in the last analytical test by an accredited laboratory, is multiplied by the waste water amount discharged into the sewage, which will lead to the yearly amount of Cr and Cu sent to the sewage.
This amount is divided by the galvanized cylinder surface area produced for all print jobs in the year.
The cylinder surface used in the press during printing is calculated by multiplying the total cylinder surface of a machine (= number of cylinders x 2πrL, where r is the radius and L the length of the cylinder) by the number of printing productions during a year (= number of different printing jobs).
Please note that the calculation of the total surface is complex because in rotogravure printing, the length and radius of the produced cylinders for print jobs is selectable. Therefore, the result obtained by multiplying the total surface area of an average cylinder set by the number of print jobs in the last year could also be accepted.

Point 4a: Licence Registration Number discrepancy (Question proposed by UK CB)

On p.4 of the EU Ecolabel Logo Guidelines, the box for displaying theRegistrationNumber (XX/YY/ZZZ) shows that ‘YY’ for the product code is two digits.The example on p.4, reads: IT/20/012 which represents the code for all purpose cleaner. However, the criteria document states that the product code for APC’s is ‘020’. Some product codes in the criteria documents show two digits and some three e.g. Paint is 07 and Tissue Paper is 004.

Can theRegistrationNumber logo display two or three digits in respect of the product code in the same way that the guidelines state that the country code can also be extended if necessary?

After taking a look at the ECAT, it is clear that even within the same product group, Member States assign either two or three numerical digits for the “YY” product group code. What should be the interpretation of the EU Ecolabel Logo Guideline’s indications? Should the product group code always be two numerical digits, or should it always correspond to what the Commission Decision states? The EU Ecolabel Logo Guidelines should be revised based on the conclusion.

Point 4b: Laundry detergents for professional use: use of peraceticacid as bleaching agent (Belgium) –possible amendment?

In Criterion 2: “Toxicity to aquatic organisms: Critical Dilution Volume (CDV)” it is written that acetic acid has to be used for the calculation instead of peracetic acid. So it looks like the peracetic acid is allowed.

But peracetic acid is classified R50, so it is not compliant with criterion 4b and no derogation is foreseen for it.

Because of his degradation in the washing process there should be no reason to forbid the use of peracetic acid; it is an environmental friendly alternative for bleaching.

Should an amendment be proposed?

Point 4c: Cleaning Vinegar and product scope EU Ecolabel critiera – Please refer to the note in the Annex (Netherlands) (10 min)

In The Netherlands, a candidate applicant contacted the Dutch CB with regard to an EU Ecolabel application for cleaning vinegar (“produced on a natural and sustainable way.”). The Dutch CB hasreferred to the definition of the product group of all-purpose cleaners and sanitary cleaners, and have asked him to check whether, in his view, the candidate product would fall under the current scope of this product group (because art. 1 says: “detergent products”). As a next step, he sent the Dutch CB a product group proposal form, which you find attached. This proposal, prepared by the candidate applicant, is not yet sent to Brussels. It seems that he expects the Dutch CB to us to give an advice on the content of the proposal.

About this proposal, the Dutch CB contacted Jakob – the Danish CB being leading in the last revision of cleaning products etc. Below you read Jakob’s response: “The products shall be mixtures of chemical substances”, and therefore it does notfall under the product scope, according to the Danish view. Nicholas and Carla do think that it is indeed a relevant question whether ‘cleaning vinegar’ falls under the current product scope. If not, in the upcoming revision research attention canbe paid to this issue. But that will take time, the current criteria being valid until (at least) 28 June 2015.

The Dutch CB would very much appreciate to hear the opinion of the CB Forum about whether an EU Ecolabel application can be made for cleaning vinegar under the current product definition of the EU Ecolabel criteria for all-purpose cleaners and sanitary cleaners or not. During the meeting I can give a (very) brief presentation of this question.

Point 4d: Implementation of the new DID list: how to behave when handling applications (Chair)

The new DID list is foreseen to be approved soon and will be followed by its implementation. Since the new DID list has changed some of the values this will have an impact on our daily work handling applications.

Based on discussion already taken place in the Nordic scheme, Denmark would like to suggest the following:

1: applications received after the implementation shall be handled using the new DID list. (In the Nordic scheme applicants can choose either lists – but not mix values from the two lists)

2: changes in already existing licenses (recipes) can be based on either the old list or if the applicant prefers to have a new calculation only based on the new list.

In our opinion it will put too much work on both the CB´s and the license holders if we insist to only use the new list when changing a recipe.

Text proposed:

”The most up to date version of the DID list available at the time of application should be used, and will be available from the Competent Body dealing with the application. The list can also be found at the following web address: ………..”

Point 6:Logo use- French Cleaning Services company,Adomplus – MenageEcologique à Domicile requests to use EU Ecolabel logo for marketing purposes

This company only uses EU Ecolabelled cleaning products from ULTRA VERT (FR/020-06, IT/20/09, FR/020/13). For that reason, Adomplus is interested in using the EU Ecolabel logo to show its clients that about their environmental commitment via EU Ecolabelled products without actually being certified as an EU Ecolabelledlicence holder (working group for Cleaning Services has been recently launched by IPTS).

We understand this company’s interest in marketing their cleaning services with the EU Ecolabel, however, there is no mention of this situation in the logo guidelines and since their company does not bear the EU Ecolabel, we believe that it is not possible for Adomplus to use the logo for marketing purposes.

However, based on his insistence, we propose to the CB Forum the company’s below flyer. In the right hand side, it has the EU Ecolabel logo and the three licence registration numbers corresponding to the products that they use. Below the registration number, the Helpdesk has introduced the phrase in an attempt to demonstrate that while the company is not an EU Ecolabelledlicence holder, they only use ULTRA VERT’s EU Ecolabelledproducts:

“Nous utilisons les produits de nettoyage de la marque UTLTRA VERT, certifies par l’Ecolabel Européen“.
Translation in English:
«We use ULTRA VERT cleaning products which are certified by the EU Ecolabel».

We would like to know if this type of logo use is possible if accompanied by the above phrase, or another phrase. It should be noted that the Helpdesk has not authorisedAdomplus the right to use the below flyer and instead asked them to wait for the conclusions of the CB Forum. The Helpdesk also invited them to take part in the product group development process. See below for the proposed flyer:

Point 7: Session on communication and marketing activities on MS level

In March 2013 (cf. March 2013 CB Forum minutes) it was decided that a special session on communication and marketing activities will be held yearly at the CB Forum (November or March) to plan promotional activities for the upcoming year. The main objective is to share information on future activities, maximise synergies and improve coherence.

The Helpdesk will develop a three question survey that will be sent out to CBs. The answers to this mini questionnaire will help identify planned/previously planned communication and marketing activities on the Member State level, and will address which types of marketing activities have been/are feasible. The compiled answers of this short survey will be presented at the CB Forum by the Helpdesk to enable the identification of common ideas amongst CBs and would facilitate the creation of possible action plans for future marketing and communication strategies. The main goal of this initiative is to prepare and structure the session’s discussions in order to increase its efficiency and the potential to foster concrete outcomes.

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