This document was last updated February 2011 
 
European Ecolabel 
ENV.G.2/SER2007/0073rl 
Commission Decision of 28 April 2011 
 
 
 
 
 
 
 
 
 
 
 
 
 
Revision of Ecolabel Criteria for Laundry 
Detergents 2008-2010 
 
 
Background report 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Prepared by 
Ecolabelling Denmark

This document was last updated February 2011 
 
INDEX 
1. SUMMARY ....................................................................... 2 
2. MARKET REVIEW ............................................................. 4 
2.1. 
EUROPEAN MARKET FOR LAUNDRY DETERGENTS AND ADDITIVES .................................... 4 
2.1.1. 
Laundry detergents .............................................................................................. 4 
2.1.2. 
Fabric softeners ..................................................................................................... 5 
2.1.3. 
Stain Removers ...................................................................................................... 6 
2.2. 
WASHING HABITS IN EUROPE ............................................................................................. 6 
2.3. 
ECOLABEL LICENSES AND PRODUCTS TODAY ..................................................................... 6 
3. PRODUCT GROUP DEFINITION ........................................ 8 
4. INTRODUCTION TO REVISED ECOLABEL CRITERIA ....... 10 
5. REVISED ECOLABEL CRITERIA ...................................... 13 
5.1. 
REVISED CRITERIA ............................................................................................................. 13 
5.1.1. 
General remarks .................................................................................................. 13 
5.1.2. 
Functional unit and reference dose .............................................................. 13 
5.1.3. 
Dosage (1) ............................................................................................................. 14 
5.1.4. 
Toxicity to aquatic organisms: Critical Dilution Volume (CDV) (2) .. 15 
5.1.5. 
Biodegradability of organics (3) .................................................................... 17 
5.1.6. 
Excluded or limited substances and mixtures (4) .................................. 21 
5.1.7. 
Packaging requirements (5) ............................................................................ 28 
5.1.8. 
Washing performance (fitness for use) (6) ............................................... 30 
5.1.9. 
Points (7) ................................................................................................................ 30 
5.1.10. 
Consumer information (8) ............................................................................... 32 
5.1.11. 
Information appearing on the ecolabel (9) ............................................... 34 
5.2. 
FORMER REQUIREMENTS NOT INCLUDED IN THE REVISED CRITERIA .............................. 34 
5.2.1. 
Insoluble, inorganic ingrediens ...................................................................... 34 
5.2.2. 
Phosphates............................................................................................................. 34 
5.2.3. 
Surfactants ............................................................................................................ 34 
5.2.4. 
Purity of enzymes ............................................................................................... 35 
5.3. 
OTHER ISSUES OF IMPORTANCE DISCUSSED DURING THE REVISION ............................. 35 
5.3.1. 
Renewable ingredients ...................................................................................... 35 
5.3.2. 
Nanomaterials....................................................................................................... 36 
5.4. 
RECOMMENDATIONS FOR FUTURE CRITERIA ..................................................................... 37 
ABBREVIATIONS AND DEFINTIONS .................................... 38 
6. REFERENCES ................................................................. 39 
APPENDIX 1: KEY ISSUES FOR THE REVISION - SUMMARY 42 
APPENDIX 2: MAIN ENVIRONMENTAL IMPACTS OF LAUNDRY 
DETERGENTS (IN BRIEF) .................................................... 44 
APPENDIX 3: TYPICAL INGREDIENTS IN LAUNDRY 
DETERGENTS ...................................................................... 47

Page 2 
1. SUMMARY  
The European Commission has assigned Ecolabelling Denmark with the task of updating 
the ecolabel criteria for laundry detergents as laid down in the Commission Decision 
1999/476/EC. DHI has provided technical comments to the draft background report and 
the draft criteria under a subcontract with Ecolabelling Denmark.   
 
The revised criteria address the issues pointed out in the preliminary report prepared for 
the Commission in June 2008 (Ecolabelling Denmark 2008) and further discussed at the 
Working Group meetings in the revision process during 2008-2009. Furthermore, the 
revised criteria address the issues that were recommended during the previous revision 
of the criteria (DHI 2003). See Appendix 1. 
 
As described in the preliminary report and further summarised in brief in Appendix 2, the 
main environmental impacts related to the production and use of laundry detergents are 
related to the energy used for heating of the washing water in the use phase, the energy 
used for extraction and processing of raw materials and the emission of chemicals to the 
environment after use. The scope of the ecolabel criteria primarily relates to the chemical 
composition of the products, and thus the impact on the aquatic environment, and the 
promotion of products that can be used at lower temperatures (≤ 30° C) compared to 
current average washing temperatures across Europe. It must be recognised that only 
certain parts in the product life-cycle may reasonably be controlled by ecolabel 
requirements. 
 
The major changes introduced with the revised criteria are summarised as follows: 
 
• 
The product group definition is expanded by inclusion of pre-treatment stain 
removers  
• 
All ingoing substances present in concentrations ≥ 0.010% (w/w) are 
encompassed by the ecological criteria. Compliance is required for preservatives, 
colouring agents and fragrances regardless of their concentration unless specific 
exceptions apply. 
• 
Calculation of critical dilution volume (CDV) converted to latest version of the DID 
list 
• 
More stringent requirements to dosage, CDV, biodegradability of organics  
• 
Exclusion of phosphates  
• 
Strict requirements for sensitising substances 
• 
Revision of packaging requirements 
• 
Introduction of a scoring system in favour of products with reduced energy 
consumption in the use phase (coldwater and low-temperature products) 
• 
A separate revision of the performance test (tender launched October 2009) has 
been conducted (led by Leitat Technological Center). The revised performance 
test supplements the revised criteria document.   
 
 
The revised criteria are expected to further reduce the environmental impact of laundry 
detergents, stain removers and fabric softeners. Imposing more stringent requirements 
on the total amount of chemicals and the toxicity and degradability of ingoing substances 
allows the impact on the external environment to be reduced. Furthermore, requirements 
in favour of reducing the energy consumption in the use phase (and to a minor extent 
also the packaging material used) will also reduce the overall impact on the environment. 
The revised criteria document has an increased focus on health aspects through 
minimising the content of sensitising substances.

Page 3 
In order to assess the impact of the revised criteria on existing ecolabelled products, the 
competent bodies in other European countries holding ecolabel licenses were contacted 
for assistance with information  on ecolabelled product formulations. Thus, representative 
product formulations based on current ecolabel licenses in Denmark, UK and France 
have been tested and evaluated according to the revised requirements. These product 
formulations cover both powders and liquids. Ecolabelled formulations (EU Flower) 
originating in other European countries have not been available. Although a more 
complete data set covering Ecolabelled formulations from other countries was wishful, the 
forwarded product formulations have provided some insight in geographical variations in 
ecolabelled product formulations. Additionally, more than 50 product formulations holding 
the Nordic Ecolabel (covering both heavy & low-duty laundry detergents and stain 
removers) have been used as a basis for setting and evaluating the revised criteria. 
Formulations of fabric softeners (non-ecolabelled) have also been made available by 
some of the Nordic manufacturers. Non-ecolabelled product formulations for market 
leading laundry detergents, fabric softeners and stain removers in Southern Europe have 
been supplied by UEAPME (European Association of Craft, Small and Medium-sized 
Enterprises) and ADEME (the French Environmental Agency). These formulations did not 
as a whole comply neither with the existing ecolabel criteria nor the revised criteria 
proposed. The access to this detailed information was, however, very useful with respect 
to obtaining knowledge on geographical variations in product composition for laundry 
detergents across Europe and in part also for validation of the revised criteria. 
 
Comments forwarded by various stakeholders during the revision process have also been 
used to adjust the criteria and take into account the regional differences that apply to 
laundry detergent formulations as well as consumer needs/expectations across Europe.

Page 4 
2. MARKET REVIEW 
A brief overview of the European market for laundry detergents, fabric softeners and stain 
removers is given below. The data are based on questionnaires sent out to relevant 
stakeholders (competent bodies, manufacturers, branch organisations etc.) in the initial 
phase of the revision.  
 
2.1. European market for laundry detergents and additives 
Table 2.1 shows estimates of the consumption of laundry detergents, fabric softeners and 
stain removers in Europe from 1995-2008. Data from 1995-2000 originate from the 
previous revision report (DHI 2003). It should be noted that the figures are rough 
estimates based on different sources of information. The figures are thus not directly 
comparable but give an idea of the overall consumption level.  
 
Table 2.1 Estimated annual consumption of laundry detergents in Europe 
Product 
Estimated consumption in tonnes/year 
 
19951 
19982 
20002 
2008 
Laundry detergents, powders
3,400,000 
3,600,000 
4,200,000 
4,000,0003 
Laundry detergents, liquids 
550,000 
620,000 
780,000 
Fabric softeners 
1,100,000 
950,000 
950,000 
1,200,0004 
Stain removers 
100,000 
100,000 
93,000 
110,0004 
1 AISE, 1996. 1994/1995 Statistical Tables (from DHI 2003) 
2 Danish consumption data used to estimate European consumption (from DHI 2003) 
3 Data based on average German consumption of 8 kg/person/year (Umweltsbundesamt 2008) 
scaled up to the total European population of ~500.000.000 (www.wikipedia.org)  
4 Data based on questionnaire received from UEAPME (UEAPME 2008) 
 
 
2.1.1. Laundry detergents 
The use of laundry detergents is estimated at 4,000,000 tonnes/year in EU in 2008 (Table 
2.1). The consumption pattern has regional differences throughout Europe. In northern 
Scandinavia, the average consumption is approximately 4-5 kg/person/year (Nordic 
Ecolabelling 2008, CSTEE 2003), while the average consumption in Germany 
approximates 8 kg/person/year (Umweltsbundesamt 2008) and about 12-13 
kg/person/year in Southern Europe (Dansk Kemi 2005, CSTEE 2003). The trend in 
Northern Europe is a decreased consumption (in tonnes) due to the use of compact and 
super-compact powders. The total value of the market for laundry cleaning in EU is 
estimated at 14,243 million Euro in 2008, corresponding to almost 50% of the total soap, 
detergent and maintenance industry (AISE 2008). 
 
The composition of laundry detergents (typical ingredients and their function) can be seen 
in Appendix 3.  
 
The European consumption also varies throughout the regions with respect to use of 
powder, liquids and tablets. Where traditional powders previously have dominated the 
market in most of Europe, compact and super-compact powders are now widespread, 
particularly in northern and central Europe (information from stakeholders, experience 
from Nordic Ecolabelling). Liquid laundry detergents have widespread use among e.g. 
British and Southern European consumers (Dansk Kemi 2005, UEAPME 2008, 
www.scienceinthebox.com), and it seems that this trend is also picking up in other 
countries. According to the information from UEAPME, liquid products account for

Page 5 
approximately 60% of the market in Southern Europe (UEAPME 2008). Liquid detergents 
are not widely used in northern Europe as yet but there may be a trend towards 
increased consumption for this product group. Laundry detergents in tablet form (both 
liquid and powder) have also entered the market.  
 
The figure below shows figures regarding distribution in product type, washing 
temperature and consumer habits for laundry detergents and additives for the 5 biggest 
European countries (year unknown).  
 
 
 
(source: www.scienceinthebox, 2008) 
 
2.1.2. Fabric softeners 
The use of fabric softener is estimated at 1,2 million tons/year in EU (UEAPME 2008) and 
estimated 90-95% of consumers use fabric softener (UEAPME 2008 and 
JohnsonDiversey 2008). Additionally, the figure above also suggests that the majority of 
the consumers in different regions of Europe use fabric softeners although the overall 
percentage may be smaller than 90%. Fabric softeners are always liquid products and 
are used in amounts varying from app. 30 ml up to 100 ml per wash depending on the 
concentration of the product. 
 
Fabric softeners are based on easily degradable cationic surfactants – esterquats and 
also contain preservatives (e.g. thiazolinones, bronopol, formaldehyde, benzalkonium 
chloride etc.), colouring agents and fragrances (a few products are without colour and 
fragrance).

Page 6 
2.1.3. Stain Removers 
The consumption of stain remover in EU is estimated at 110,000 tons per year (UEAPME 
2008). 
 
Stain removers are in all kinds of types from tablets (solid), powders, gels and liquids. 
They generally contain bleach, surfactants, enzymes preservatives, colouring agents and 
fragrance depending on type and usage. 
 
2.2. Washing habits in Europe 
In 2008, the International Association for soaps, detergents and maintenance products 
(AISE) commissioned a survey of consumer washing habits across Europe. In short, the 
survey showed the following figures (AISE 2008): 
 
• 
Preferred type of detergent: Regular laundry powders. In addition, regional 
preferences for regular liquids/gels (western Europe), tablets (UK/Ireland) and 
compact laundry powders (Scandinavia) also apply 
• 
Average washing temperature: 42.6°C (ranging from 40.1°C in Southern Europe 
to 54.5°C in Scandinavia) 
• 
Amount of washes conducted at 30°C or lower: 30% 
• 
Washing at full load: 49% 
• 
Awareness of differences between regular and concentrated products: 43% 
• 
65% of the consumers dose according to the recommendation provided by the 
manufacturer 
 
2.3. Ecolabel licenses and products today  
As per November 2010, ecolabel licenses have been awarded for 26 companies for 
laundry detergents. The licences cover approximately 120 trade names for laundry 
detergents for sale in many countries (www.eco-label.com). The licences are distributed 
as follows: 
 
Table 2.2 Number of EU Ecolabel licenses for laundry detergents (November 2010) 
Country
No. of licenses
Belgium 
1 
Czech Republic 
1 
Germany 
2 
Denmark 
2 
Spain 
1 
France 
5 
Italy 
10 
United Kingdom 
2 
Netherlands 
2 
Total 
26 
 
 
In Denmark, the Flower labelled laundry detergents account for <1% of the total market 
value (ACNielsen 2007) and the Flower thus holds a quite small market share. In 
comparison, laundry detergents labelled with the Nordic Ecolabel (the Swan) account for 
approximately 19% of the total market value in Denmark (ACNielsen 2007), 8% in 
Finland, 50% in Norway and 80% in Sweden (unpublished data from Nordic 
Ecolabelling). Thus, there is a great potential for ecolabelled products as such, although 
the Flower is less widespread compared to the Nordic Ecolabel in Scandinavia. No data

Page 7 
regarding the market shares of Flower labelled laundry detergents have been obtained 
from other European countries.

Page 8 
3. PRODUCT GROUP DEFINITION 
Article 2 of the revised criteria defines the product group as follows:  
 
“The product group “Laundry Detergents” shall comprise: laundry detergents and pre-
treatment stain removers whether in powder, liquid or any other form which are marketed 
and used for the washing of textiles principally in household machines but not excluding 
their use in launderettes and common laundries. 
Pre-treatment stain removers include stain removers used for direct spot treatment of 
textiles (before washing in the machine) but do not include stain removers dosed in the 
washing machine and stain removers dedicated to other uses besides pre-treatment.  
This product group shall not comprise products that are dosed by carriers such as sheets, 
cloths or other materials nor washing auxiliaries used without subsequent washing, such 
as stain removers for carpets and furniture upholstery”. 
 
 
The criteria do not specifically exclude products for professional use in laundrettes and 
common laundries – as such products may be equivalent to household products in their 
content and use. However, the criteria are not intended for professional products used for 
specific applications in institutions and industry in industrial washing machines. The 
project group has recommended that separate criteria are developed for professional 
products. In October 2009 the Commission launched a tender for development of 
ecolabel criteria for professional laundry detergents, taking into account the specialised 
use and composition of such products. Criteria development for these product groups is 
currently ongoing (February 2011). 
 
At the 2nd and 3rd AHWGM the possible inclusion of fabric softeners and stain removers 
in the product group was discussed and several comments on this issue have also been 
forwarded to the project group during the revision process. According to the market 
survey, especially fabric softeners are used in high tonnages in Europe (> 1 mill. 
tonnes/year) and ecolabelled alternatives have been requested from various 
stakeholders. However, many stakeholders have also argued that fabric softeners and in-
wash stain removers introduce an extra, unwanted chemical load in the wash process 
and that a general use of such products should not be encouraged. Auxiliary products like 
softeners and in-wash stain removers are generally not considered necessary for 
achieving clean laundry under normal conditions. Regardless, the market data reveal a 
substantial use of fabric softeners which is not likely to decrease. Some stakeholders 
argue that ecolabelling of such products could misguide the consumer to believe that the 
products are considered as being “green” or beneficial, that they are necessary in the 
wash process and that the detergents in themselves are insufficient. The Commission 
has clarified that the role of the ecolabel is to offer environmentally better products and 
that the ecolabel should drive the development of environmentally better products within 
heavy use product groups. The Commission furthermore argues that for products such as 
fabric softeners, the consumption on a volume basis is not expected to change 
regardless of whether ecolabelled products are available or not, whereas the overall 
chemical load may be affected positively by introducing ecolabelled alternatives. It was 
thus proposed to include fabric softeners and pre-treatment stain removers in the 
ecolabel criteria. As agreement could not be reach between the Member States about the 
inclusion of fabric softeners – this product category was finally omitted from the criteria 
proposal. It should be noted that pre-treatment stain removers are applied in limited 
doses directly on difficult stains, and are not expected to have a significant contribution to 
the overall chemical load.

Page 9 
At the 3rd working group meeting a discussion of the product group definition was also 
raised. The terms heavy-duty and low-duty detergents are related to the designated use 
according to the product group definition. Some stakeholders were in favour of a 
definition relating to the chemical composition of the different product types rather than a 
functional definition. However, it is chosen to retain the product definition related to the 
use in agreement with the definitions laid down in the Detergent Regulation 
(648/2004/EEC). Furthermore, the market is developing all the time and the chemical 
composition of the products is thus not a static parameter.

Page 10 
4. INTRODUCTION TO REVISED ECOLABEL CRITERIA 
The revised ecolabel criteria for laundry detergents take into consideration the focus 
points pointed out in the preliminary report and also the issues recommended during the 
previous revision as summarised in Appendix 1. Appendix 2 summarises the main 
environmental impacts of laundry detergents in a life-cycle perspective, which forms the 
basis for the revised criteria. 
 
The scope of the revised ecolabel criteria primarily relates to the chemical composition of 
the products (and thus the impact on the aquatic environment) and the promotion of 
products that can be used at lower temperatures (≤ 30° C) compared to current average 
washing temperatures across Europe (chapter 2.2). One of the aims of the revision has 
been to create a simplified criteria document addressing the most important impacts of 
this product group on the environment in a life cycle perspective. The ecolabel criteria 
should thus provide a tool that enables distinction of products with an overall good 
environmental profile and good performance. 
 
The revised ecolabel criteria are divided into 
 
• 
Chemical requirements (no. 1-4) 
• 
Packaging requirements (no. 5) 
• 
Performance requirements (no. 6) 
• 
Point system promoting products with reduced energy consumption in the use 
phase (no. 7) 
• 
Requirements addressing consumer information (no. 8-9) 
 
 
In table 4.1, an overview is given comparing the current ecolabel criteria versus the 
suggested revised criteria for laundry detergents. The product group definition has been 
expanded to include pre-treatment stain removers. The revised criteria are explained in 
detail in chapter 5.

Page 11 
Table 4.1 Overview of current versus revised ecolabel criteria (heavy-duty and low-duty 
detergents) 
Requirement
Current criteria (2003)
Revised criteria (2009)
Ingredient concentration 
imposing ecological 
requirements 
≥ 0,1 weight % of the preparation 
≥ 0,010 weight % of the preparation 
for all ingoing substances. 
Compliance is required for 
preservatives, colouring agents and 
fragrances regardless of the 
concentration, except for req. no. 4a) 
Functional unit 
g/wash 
g/kg wash 
Total Chemicals 
(“Maximum dosage” in revised 
criteria) 
Limit: 100 g/wash  
(heavy- and low-duty detergents) 
Limit: 17 g/kg wash (~76,5 g/wash) 
for powders and 17 ml/kg wash ( 
~76,5 ml/wash) for liquids. 
Limits introduced for new product 
types (no. 1) 
Insoluble, inorganic ingredients 
Limit: 30 g/wash 
No requirements 
Toxicity to aquatic organisms 
(“Critical Dilution Volume, 
CDV” in revised criteria) 
Limit: CDV max 4,500 l/wash 
Limit: CDV max 35,000 l/kg wash for 
heavy-duty detergents and 20,000 
l/kg wash for low-duty detergents. 
CDV calculation based on new DID 
list (values not directly comparable). 
CDV limits introduced for new product 
types (no. 2) 
Phosphates 
Limit: 25 g/wash 
Phosphates not allowed (no. 4a) 
Biodegradability of surfactants 
Aerobic and anaerobic 
biodegradability required 
Aerobic biodegradability covered by 
legislation. 
Specific requirements for anaerobic 
biodegradability for surfactants 
replaced with a general requirement 
for the biodegradability of all organics 
(no. 3) 
Biodegradability of organics  
No requirements 
A general requirement limiting the 
amount of organics that are not 
readily biodegradable or anaerobically 
biodegradable (no. 3) 
Dangerous, hazardous or toxic 
substances or preparations  
( “Excluded or limited 
substances and mixtures” in 
revised criteria) 
Exclusion and limitation of certain 
substances and classifications 
Addition of limitations for toxic and 
sensitizing substances, exclusion of 
phosphate (no. 4a), and biocides 
used for other purposes than 
preservation  (no. 4a) 
Purity of enzymes 
Absences of production 
microorganisms 
No requirements 
Packaging requirements 
Weight of primary packaging:  
3,7 g/wash for tablets 
1,7 g/wash for others 
7,0 g/wash for products incl. refill 
packaging 
 
≥ 80% recycling of cardboard 
material 
Revised requirement. Introduction of 
weight utility ratio (WUR): 
Powders: 1,2 g/kg wash 
Others: 1,5 g/kg wash 
 
or min. 80% recycling 
(no. 5) 
 
Washing performance 
Compliance with “Performance 
test of household detergents 
Version 4 December 2002 
Compliance with new performance 
criteria for laundry detergents 
(adopted 2011).  
Point system (matrix) 
Not applicable 
Point system introduced, in favour of 
coldwater and low-temperature 
products (no. 7) 
Consumer information 
Various specifications for 
mandatory information 
Minor changes in text (no. 8) 
Information appearing on the 
eco-label 
Mandatory sentences 
Minor changes in text (no. 9)

Page 12 
 
In order to assess the impact of the revised criteria on existing ecolabelled products, the 
competent bodies in other European countries holding ecolabel licenses were contacted 
for assistance with information of ecolabelled product formulations. Thus, representative 
product formulations based on current ecolabel licenses held by Denmark, UK and 
France have been tested and evaluated according to the revised requirements. (Some of 
the product formulations in the Danish ecolabel license are furthermore marketed outside 
Denmark, e.g. in France). These product formulations cover both powders and liquids. 
Ecolabelled formulations (EU Flower) originating in other European countries have not 
been available. Although a more complete data set covering Ecolabelled formulations 
from other countries was wishful, the forwarded product formulations have provided 
insight in geographical variations in ecolabelled product formulations. Additionally, more 
than 50 different product formulations holding the Nordic Ecolabel (covering both heavy & 
low-duty laundry detergents and stain removers) have been used as a basis for setting 
and evaluating the revised criteria. Non-ecolabelled product formulations for market 
leading laundry detergents and stain removers in Southern Europe have supplied by 
UEAPME (European Association of Craft, Small and Medium-sized Enterprises) and 
ADEME (the French Environmental Agency). These formulations did – as a whole - not 
comply neither with the existing ecolabel criteria nor the revised criteria proposed. The 
access to this detailed information was, however, very useful with respect to obtaining 
knowledge on geographical variations in product composition for laundry detergents 
across Europe and in part also for validation of the revised criteria.  
 
The analysed products cover the following product types (including products ecolabelled 
with the Nordic Ecolabel (the Swan), the EU Ecolabel and products without an ecolabel): 
• 
> 60 heavy-duty product formulations (powders, liquids and tablets) 
• 
5 low-duty product formulations (powder and liquid) 
• 
3 pre-treatment stain removers (liquids) 
• 
10 fabric softeners (liquids)  
 
 
In Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 
November 2009 on the EU Ecolabel (Annex I) it is stated that the ecolabel criteria “shall 
be based on the best products available on the Community market in terms of 
environmental performance throughout the life cycle, and they shall correspond 
indicatively to the best 10-20 % of the products available on the Community market in 
terms of environmental performance at the moment of their adoption”. It is important to 
acknowledge that the ecolabel criteria are not supposed to encompass the majority of the 
product formulations on the market in any given country. At the working group meetings 
concern has been expressed by some competent bodies regarding compliance of current 
ecolabelled products with the revised criteria. It should also be emphasized that the 
current criteria date back to 2003 and that a tightening of the ecolabel requirements is an 
expected result of a revision process. Adjustments in the chemical composition and the 
overall performance are thus a natural outcome of transition to new requirements.

Page 13 
5. REVISED ECOLABEL CRITERIA 
5.1. Revised criteria 
5.1.1. General remarks 
The concentration of ingoing substances in the product, which implies a requirement for 
documentation of compliance with the ecological criteria, is generally defined at ≥ 0.010 
% by weight of the preparation. For preservatives, colouring agents and fragrance 
compliance with the ecological criteria are, however, required regardless of their 
concentration except for requirement no. 4b on excluded or limited substances and 
mixtures. Preservatives, colouring agents and fragrance often have a significant 
contribution to the overall environmental profile of the product (primarily the CDV), even 
in minute concentrations. Fragrances may be considered as mixtures for the calculation 
of the total chemicals, CDV and biodegradability of organics (using the data on the DID 
list). Pollutants (traces from the raw material production) present in concentrations ≥ 
0.010% by weight in the final product also have to comply with the criteria. 
 
In requirement no. 4 where limitations or exclusion applies to substances with specific 
hazard classifications, the risk phrases have been converted to the new hazard 
statements introduced with the Globally Harmonised System for classification, labelling 
and packaging of substances and mixtures (GHS), as implemented in Regulation (EC) 
No 1272/2008 in January, 2009 (new regulation on classification, labelling and packaging 
of substances and mixtures). With the implementation of GHS, substances must be 
classified according to this regulation after 1st of December 2010. For classification of 
mixtures is the corresponding date the 1st of June 2015. In the transition period from 1st of 
December 2010 to 1st of December 2015 substances must be classified after both 
systems and labelled and packed according to the GHS regulation. Accordingly, the risk 
phrases used in the existing classification system as well as in the GHS system are 
presented. 
 
5.1.2. Functional unit and reference dose 
The functional unit, i.e. the quantity of product used in calculating the ecological 
requirements, has been changed. Instead of relating to g/wash (a standard wash being 
defined as the dosage per 4.5 kg load), the functional unit now relates to g/kg wash. The 
functional unit is an administrative unit used only for calculation of compliance with the 
ecological requirements. 
 
This enables the setting of comparable and unambiguous limits for various product types, 
independent of the total dosage per wash. A functional unit expressed in g/kg wash also 
allows flexibility in selecting dosages related to different wash loads, e.g. one dosage for 
4-5 kg and one dosage for 6-8 kg. The dosage used for calculation of the ecological 
criteria relates to the dosage for a standard machine load of 4.5 kg for heavy-duty 
detergents and 2.5 kg for low-duty detergents. Alternatively, the dosage used for the 
calculations shall correspond to the average load size stated on the dosage scheme. 
Thus, if the recommended dosage is 60 g for a load of 3-5 kg, the functional unit will be 
60 g/4 kg per wash = 15 g/kg wash. 
 
The reference dose used for calculation of compliance with the ecological criteria and for 
the performance test is defined as the dosage recommended by the manufacturer to 
consumers for the water hardness of 2.5 mmol CaCO3/l and ‘normally soiled’ textiles for 
heavy-duty detergents and a water hardness of 2.5 mmol CaCO3/l and ‘lightly soiled’ 
textiles for low-duty detergents.

Page 14 
 
5.1.3. Dosage (1) 
 
Proposed requirement: 
The dosage corresponds to the recommended dosage in g/kg wash (powders/tablets) or 
ml/kg wash (liquids/gels). The recommended dosage for a water hardness of 2.5 mmol 
CaCO3/l for normally soiled textiles (heavy-duty detergents) and lightly soiled textiles 
(low-duty detergents), respectively, should be used. 
 
The dosage shall not exceed the following amounts: 
 
Product type
Dosage, powder/tablet
Dosage, liquid/gel
Heavy-duty laundry detergent
17.0 g/kg wash
17.0 ml/kg wash
Low-duty laundry detergent
17.0 g/kg wash
17.0 ml/kg wash
Stain remover (pre-treatment only)
2.7 g/kg wash
2.7 ml/kg wash*
* Estimated average dose to be used in CDV calculations. Actual dosing will depend on number of 
stains in any given wash-load. The estimated dose is based on a dosage of 2 ml per application 
and 6 applications per wash-load of 4.5 kg (liquid stain remover). 
 
Note: If recommendations for both prewash and subsequent wash apply, the total 
recommended dosage (prewash + subsequent wash) has to comply with the maximum 
dosage level. 
 
Motivation: 
The ecolabel criteria aim at providing sustainable products with minimum environmental 
impact for the consumer. By reducing the amount of total chemicals per dose the 
products become more concentrated and the amount of chemicals and packaging 
material used per wash is reduced to a minimum. 
 
The International Association for Soaps, Detergents and Maintenance products (AISE) 
has launched “Laundry Sustainability Project No 2 (LSP2)” for heavy-duty detergents by 
1st January 2009. LSP2 is a voluntary industry initiative. One of the goals of LSP2 is to 
lower the washing doses and optimising the use of packaging materials. AISE’s proposed 
maximum dose for heavy-duty laundry detergents (powders) is set at 85 g/wash or 135 
ml/wash (corresponding to ~19 g/kg wash or 30 ml/kg wash). For liquid detergents a 
similar project has recently been launched. The “Laundry Sustainability Project for Heavy-
Duty Liquids” (LSP-L) enters into force from July 2010 and proposes a maximum dosage 
of 75 ml/wash for liquid heavy-duty detergents (corresponding to ~17 ml/wash). 
 
The suggested ecolabel criteria suggest an even lower limit for the maximum dose for 
heavy-duty powders. Even though liquids generally have a lower content of active 
ingredients per dosage compared to powders, equal dosage limits are set for powders 
and liquids as the ecolabel should not encourage use of dilute products with a high water 
percentage. Recognising regional differences for laundry detergents between Northern 
and Southern Europe, the maximum dosage in the EU criteria is set at 17.0 g/kg wash for 
powders and 17.0 ml/kg wash for liquids. The dosage limits are established with 
reference to the dosage levels for the available formulations and should ensure 
compliance for compact products on the market but exclude regular (non-compact) 
products. This is based on an analysis of:  
 
• 
8 product formulations holding the EU Ecolabel (Denmark, UK and France) 
(average dosage: 15.7 g or ml/wash)

Page 15 
• 
> 50 product formulations (heavy-duty) holding the Nordic Ecolabel (the Swan) 
(average dosage 12.6 g or ml/wash)  
• 
12 non-ecolabelled products originating in Southern Europe, both compact and 
regular products (average dosage 27.8 g or ml/wash).  
 
 
According to comments from stakeholders, the average dosage for compact powder 
laundry detergents in Central and Southern Europe is in the range 70-80 g/wash (~16-18 
g/kg wash).  
 
The parameters that seem to differentiate the products the most are: 
 
- 
The dosage (ranging from 17 ml/wash to > 100 ml/wash for a 4.5 kg load) 
- 
The total chemicals content per wash (ranging from 0.6 g/kg wash to 1.4 
g/kg wash for a 4.5 kg load) 
- 
The content/presence of “minor ingredients” (on a weight basis) such as 
fragrance, silicone, and preservatives 
 
 
The former criteria (2003) has a maximum dosage level (total chemicals) of 100 g/wash 
corresponding to 22.2 g/kg wash. The lowered dosage levels in the revised criteria reflect 
the general tendency of developing more concentrated and/or compacted products. 
Furthermore, the development of efficient and innovative enzymes has facilitated partial 
replacement of some of the traditional washing chemicals. This is already seen in several 
products on the market (in Scandinavia) and results of such replacements have also 
been published by Novozymes (Nielsen and Skagerlind 2007).  
 
5.1.4. Toxicity to aquatic organisms: Critical Dilution Volume (CDV) 
(2) 
 
Proposed requirement: 
The critical dilution volume of the product must not exceed the following limits (CDVchronic): 
 
 
Product type
CDVchronic
Heavy-duty laundry detergent (all types)
35,000 l/kg wash
Low-duty laundry detergent (all types)
20,000 l/kg wash
Stain remover (pre-treatment only)
3,500 l/kg wash*
Fabric softener
7,500 l/kg wash
* CDV limit based on an estimated dosage of 2 ml per application and 6 applications per wash-
load of 4.5 kg for a liquid stain remover. Products dosed as e.g. powder or paste shall comply with 
the same CDV limit. 
 
The critical dilution volume toxicity (CDVchronic) is calculated for all ingredients (i) in the 
product using the following equation: 
 
 
where  
1000
 
TFchronic(i)
(i)
 
DF
(i)
weight 
  
= Σ CDV(i)
 
CDVchronic
 
⋅
⋅
=

Page 16 
 
weight (i) = the weight of the ingredient per recommended dose  
DF = the degradation factor 
TF = the chronic toxicity factor of the substance as stated in the DID list.  
 
 
Motivation: 
The CDV aims at setting a high standard and benchmark the ecolabelled products based 
on all ingredients in the final product. The method of calculating the CDV has been 
adjusted to fit the latest version of the DID list (2007 version). The formerly used 
parameters LF (loading factor) and LTE (long term effect) have been replaced with DF 
(degradation factor) and TF (toxicity factor). For further explanation of the calculation 
method and DID list parameter, reference is made to Detergents Ingredients Database 
Part A and B, 2007 (or later versions) available at the EU Ecolabel website.  
 
Generally, the use of chronic toxicity data are preferred as long term toxicity data are 
considered of higher quality and are giving a more precise/reliable estimate of 
environmental effects compared to acute toxicity data. The CDV values are thus based 
on chronic toxicity factors. For many substances on the DID list the “chronic” toxicity 
factors are, nevertheless, based on acute toxicity values and certain substances (such as 
fragrances, silicates, various surfactants) get a higher weight in the CDVchronic calculation 
than may be reasonable, due to the lack of chronic data. The proposed CDV values have 
taken this into account. It is, however, important that new chronic data are presented and 
made available. For substances for which the chronic TF values on the DID list are based 
on acute toxicity data, chronic ecotoxicity values presented to the competent bodies 
should be considered in order to correctly estimate the chronic TF for the substance. 
 
The CDV levels for heavy-duty and low-duty laundry detergents and stain removers have 
been established with reference to the Nordic Ecolabel Criteria for laundry detergents, 
version 6.0 (from 2008) and are furthermore based on calculated CDV values for the 
available product formulations. Liquid products generally have a lower level of total 
chemicals per functional unit compared to powders due to the water content in liquids. 
However, liquid detergents typically contain a much higher level of surfactants per 
functional unit compared to powders. Surfactants have a high contribution to the CDV, 
whereas powders often contain high amounts of relatively “inert” substances like zeolite, 
carbonates and sulphates etc. which generally have a low contribution to the CDV. Thus, 
the CDV levels are identical for powders and liquids. This implies that liquids have a 
higher contribution to aquatic toxicity per gram active ingredient. The critical dilution 
volume per wash is, however, the same. 
 
More than 50 different product formulations already on the market in Scandinavia 
(including heavy-duty detergents, low-duty detergents and pre-treatment stain removers) 
comply with the proposed CDV levels. A re-calculation of the available EU ecolabelled 
product formulations (8 different product formulations) shows that these products also 
comply with the proposed limits. Although a uniform correlation factor between the two 
calculation methods can not be derived, a comparison of the CDV values using the 
former and the new calculation method indicate, that the proposed CDV values are 
stricter compared to the old CDV requirement. Non-ecolabelled formulations supplied 
from southern Europe do not comply with the proposed CDV levels, indicating that 
regular products without optimised chemical profiles are not able to fulfil the ecolabel 
requirements.  
 
As evident from the discussions on the working group meetings, the CDV criterion is seen 
as one of the most important criteria regulating the environmental properties of the 
products.

Page 17 
 
5.1.5. Biodegradability of organics (3) 
 
Proposed requirement: 
The content of organic substances in the product that are 
- 
aerobically non-biodegradable (not readily biodegradable) (aNBO)  
- 
anaerobically non-biodegradable (anNBO)  
must not exceed the following limits: 
 
aNBO 
Product type
aNBO, powder
aNBO, liquid/gel
Heavy-duty laundry detergent
1.0 g/kg wash
0.55 g/kg wash
Low-duty laundry detergent
0.55 g/kg wash
0.30 g/kg wash
Stain remover (pre-treatment only)
0.10 g/kg wash
0.10 g/kg wash*
 
 
 
* aNBO limit based on an estimated dosage of 2 ml per application and 6 applications per wash-
load of 4.5 kg for a liquid stain remover. The aNBO limit shall comply with the same limit for 
products dosed as e.g. powder or paste. 
 
anNBO 
Product type
anNBO, powder
anNBO, liquid/gel
Heavy-duty laundry detergent
1.3 g/kg wash
0.70 g/kg wash
Low-duty laundry detergent
0.55 g/kg wash
0.30 g/kg wash
Stain remover (pre-treatment only)
0.10 g/kg wash
0.10 g/kg wash*
 
 
 
* anNBO limit based on an estimated dosage of 2 ml per application and 6 applications per wash-
load of 4.5 kg for a liquid stain remover. The aNBO limit shall comply with the same limit for 
products dosed as e.g. powder or paste. 
 
Motivation: 
A general requirement to the content of not readily biodegradable and not anaerobically 
biodegradable organics reduces the level of non-biodegradable organics to a minimum in 
ecolabelled laundry detergents and stain removers. The requirement for biodegradability 
of organics promotes ecolabelled products with an optimal biodegradation profile and that 
the possible accumulation of non-biodegradable substances in waste water sludge and 
other relevant environmental compartments is reduced.  
 
Substances commonly used in laundry detergents that are not aerobically biodegradable 
(aNBO) are e.g. polycarboxylates, CMC, silicone, PVNO/PVPI, phosphonates, polymers, 
fragrance, colour, optical brighteners (fluorescent whitening agents). 
 
Substances commonly used in laundry detergents that are not anaerobically 
biodegradable (anNBO) are e.g. surfactants (certain types), polycarboxylates, CMC, 
silicone, PVNO/PVPI, phosphonates, polymers, fragrance, colour, optical brighteners

Page 18 
(fluorescent whitening agents), iminodisuccinate, EDDS, polyaspartic and polyasparginic 
acid. Furthermore, data for anaerobic biodegradability are not available (according to the 
DID list) for a range of other substances commonly used, such as MGDA, various organic 
acids and glycol ethers etc. Note that TAED should be considered anaerobically 
biodegradable.1  
 
The levels for the content of aNBO/anNBO have been established with reference to the 
Nordic Ecolabel Criteria for laundry detergents, version 6.0 with some adjustments. 
Different levels of aNBO/anNBO thus apply for powder and liquid products, respectively, 
related to the difference in total chemicals for these products. More than 50 different 
ecolabelled product formulations already on the market in Scandinavia (both heavy-duty, 
low-duty and stain removers) comply with the proposed levels. A re-calculation of some 
of the products in the Danish and UK EU Ecolabel licenses shows that these 8 
formulations currently holding the EU Ecolabel also comply with the proposed limits. Non-
ecolabelled formulations supplied from southern Europe do not comply with the proposed 
aNBO/anNBO levels, indicating that regular products without optimised chemical profiles 
are not able to fulfil the ecolabel requirements.  
 
With a general requirement to the biodegradability of the organic substances, the 
aNBO/anNBO criterion combined with the CDV criterion ensures that the overall content 
of not readily biodegradable and/or toxic substances is limited, while at the same time 
allowing some flexibility in the product composition. The focus of the ecolabel criteria 
should address product and ingredient properties rather than limiting specific types or 
functionalities of substances, although some exceptions apply (specified in requirement 
no. 4). With a general focus on biodegradability, the ecolabel criteria allow a certain 
content of substances that do not degrade under aerobic/anaerobic conditions. There 
should be no distinction between which aNBO/anNBO substances that are used – 
provided that they comply with the overall criteria document and that the CDV value 
ensures that the overall content of acutely toxic substances is reduced. As both anNBO 
surfactants and various other organics such as optical brighteners, colouring agents, 
phosphonates etc. have been discussed in the context of the ecolabel as ingredients of 
possible concern, a more detailed perspective is given below. 
 
 
Surfactants 
In contrast to the former criteria, no specific requirements apply to biodegradability of 
surfactants. Ready biodegradability of surfactants is already required for products sold on 
the European market according to the Detergents Regulation (Regulation 648/2004/EC). 
Manufacturers of surfactants and/or detergents for industrial and institutional use may ask 
for derogation if the ultimate biodegradability fails to meet the criteria in Annex III to the 
Regulation (at least 60% or 70% depending on the test method within twenty-eight days). 
Surfactants not meeting the level of primary biodegradability stipulated in Annex II (at 
least 80%) will not be granted derogation. Regulation 648/2004/EC does not define 
requirements to anaerobic biodegradability of ingredients in detergents. By 2009 the 
Commission shall carry out a review of the application of the Regulation, and, where 
justified, present legislative proposals relating to anaerobic biodegradation. The status 
regarding the regulation is that it is currently not recommended that anaerobic 
biodegradability is used as an additional pass/fail criterion for the environmental 
acceptability of surfactants (COM 2009a).  
 
                                                 
1 The DID list (2007 version) indicates that there is no data regarding for anaerobic biodegradability for TAED 
(DID no 128). However, documentation for anaerobic biodegradability of TAED according to OECD 311 has 
been presented to Ecolabelling Denmark. The DID list should be revised accordingly and TAED should be 
considered anaerobically biodegradable in the calculation of anNBO.

Page 19 
In an opinion concerning the environmental risk assessment of non biodegradable 
Detergent Surfactants under Anaerobic Conditions, the Scientific Committee on Health 
and Environmental Risks (SCHER) concluded that a requirement of anaerobic 
degradation of surfactants is not in itself regarded as an effective measure of 
environmental protection. The opinion states that “a poor biodegradability under 
anaerobic conditions is not expected to produce substantial modifications in the risk for 
fresh water ecosystems as the surfactant removal in the WWTP seems to be regulated 
by its aerobic biodegradability”. Furthermore, it is stated that “there is evidence indicating 
that fulfilling the criteria for ready and ultimate aerobic biodegradability is essential for 
achieving a significant dissipation/removal of surfactants in the WWTP, while anaerobic 
biodegradation plays a minor role in the overall dissipation/removal”. The information 
reviewed by the SCHER also states that “fulfilling the criteria for ultimate biodegradation 
under anaerobic conditions leads to a significant reduction in the surfactant sludge 
concentration in those cases where anaerobic sludge digestion process is included in the 
overall treatment. However, the measured concentrations of anaerobically degradable 
surfactants in sludge are still significant…” (SCHER 2005).  
 
It is recognised, that anaerobic biodegradability of surfactants is not the most important 
parameter influencing the overall environmental impact of laundry detergents. However, 
with the above limits for the content of anNBO combined with the CDV criterion, the level 
of non-anaerobically surfactants is in practice reduced to a few percent at maximum, as 
builders, co-builders, anti-foaming agents etc are expected to fill up the main part of the 
anNBO substances (based on the composition of available formulations). A general level 
for anNBO (as opposed to a pass/fail requirement for anNBO of surfactants) will allow 
some flexibility for the manufacturers of selecting the right balance for the content of 
anNBO substances such as builders, colouring agents, optical brighteners, surfactants 
etc. The major arguments for setting the anNBO limit at a level that effectively reduces 
the content of anNBO surfactants to a minimum are as follows: 
 
 
• 
Surfactants are used in high concentrations in laundry detergents and are the key 
ingredients contributing to the overall aquatic toxicity, when these products are 
used and released ‘down the drain’ (see LCA reference in Appendix 2). 
• 
The level of waste water treatment varies throughout Europe and some regions 
have poor or no treatment of waste water. The potential for surfactants and other 
organics to biodegrade ultimately under the redox conditions that prevail in the 
main environmental compartments are, therefore, a relevant inherent property for 
substances used in ecolabelled products. The environmental compartments 
include: (I) WWTPs: activated waste water treatment (aerobic) and sludge 
digestion (anaerobic); (II) aquatic systems: surface water and sediment-water 
interface (aerobic), and sediments (mainly anaerobic); and (III) soil systems: 
unsaturated soil (aerobic), saturated soil (mainly anaerobic), and sludge-amended 
soil (mainly aerobic with anaerobic hot spots).  
• 
It is recognised that anaerobically biodegradable surfactants (like e.g. soaps) are 
present in anaerobic compartments (together with surfactants that resist 
anaerobic degradation). However, anaerobic biodegradation of surfactants having 
this potential is assumed to occur, when the substances are desorbed from 
particles in sludge, sediment or soil and become bioavailable to microorganisms 
(only substances that are bioavailable can cause toxic effects). 
• 
Laundry detergents based on not anaerobically biodegradable surfactants are 
marketed Europe with estimated high market shares. Both authorities and 
consumer organisations several European countries are of the opinion that the 
use of non-anaerobically biodegradable surfactants should be limited in order to 
protect the environment (even though the opinion from SCHER and other parties 
indicate that anaerob biodegradability is not an effective measure of 
environmental protection).

Page 20 
• 
A large range of surfactants used in modern detergent products (primarily non-
ionic surfactants) already fulfil the requirement of anaerobic biodegradability. Note 
that many of the anaerobically biodegradable surfactants have a higher aquatic 
toxicity compared to surfactants that do not degrade under anaerobic conditions 
(as e.g. illustrated by the DID list).  
 
 
Non-surfactants  
Regulation 648/2004/EC does not define requirements to the biodegradability of non-
surfactant organic ingredients in detergents. Within the scope of the ongoing review of 
the Regulation, the relevance of biodegradability requirements of non-surfactant organics 
has also been evaluated. A report was elaborated for DG Enterprise regarding the human 
and environmental risk associated with non-surfactant ingredients and zeolite based 
detergents (RPA 2006). The report focuses on organic co-builders and other organic non-
surfactants in detergents with particular attention to not readily biodegradable substances 
or substances with other properties of particular concern. Based on a list of 50 non-
surfactant ingredients most commonly used (organics and inorganics, fragrances not 
included) the report identified 11 groups of substances of potential concern. Further 
analysis of these groups concluded that the following 6 substance groups were 
associated with a potential concern (some of them due to a lack of data): 
 
 
• 
Phosphonates: concern regarding degradation and ecotoxicity 
• 
EDTA/EDTA salts: concern regarding mobilisation of metals 
• 
NTA: classification as carcinogenic 
• 
Detergent Dyes: available data insufficient for conclusion of potential risks 
• 
Fluorescent Whitening Agent FWA-5: degradation products of potential concern 
• 
Triethanolamine: available data insufficient for conclusion of potential risks 
 
 
Some of the above findings were further evaluated in an opinion by the Scientific 
Committee of Health and Environmental risks (SCHER). SCHER has thus indicated that 
there may also be a potential environmental risk associated with the use of 
polycarboxylates under worst case conditions, but further data are needed to validate this 
(SCHER 2007). The status regarding the review of Regulation 648/2004/EC is that it is 
currently not recommended that biodegradability requirements are introduced for non-
surfactant organics in laundry detergents. Even though several substances are not 
readily biodegradable, the low toxicity of these substances indicates that there is no risk 
for either human health or the environment (COM 2009b). 
 
The ecolabel criteria consider all the above substances (and other possible substances of 
concern such as fragrances) either through the general requirements to CDV and 
aNBO/anNBO and/or by specific substance requirements. EDTA/EDTA salts and NTA 
are excluded due to specific concerns (as described under requirement no. 4). 
Phosphonates, dyes, optical brighteners, solvents, fragrances etc are subject to 
regulations through the CDV and aNBO/anNBO criteria. 
 
Optical brighteners 
As optical brighteners were explicitly mentioned as a focus point after the previous 
revision (and as optical brighteners are excluded e.g. in the Nordic Ecolabel Criteria for 
laundry detergents), some further details are presented below regarding this substance 
group: 
 
In Europe, the optical brighteners (or: fluorescent whitening agents, FWA) most 
commonly used in laundry detergents are FWA-1 and FWA-5 (RPA 2006). FWA-1 and

Page 21 
FWA-5 generally have low to moderate aquatic toxicity, a low potential for 
bioaccumulation and are not readily biodegradable. FWA-1 and FWA-5 may, however, 
undergo rapid photo degradation. Photo degradation of FWA-1 leads to numerous 
metabolites that have not been identified. The main photo degradation products of FWA-5 
are readily biodegradable. (HERA 2003 & 2004). However, concern still remains 
regarding the ecotoxicological properties of the degradation products of FWA-5 (RPA 
2006). FWA-1 and FWA-5 are, to a large extent, adsorbed to sludge in waste water 
treatment plants (HERA 2003 & 2004).  
Optical brighteners work by depositing on fabrics during laundering to enhance the 
brightness of light coloured fabrics and do not have any impact on the cleaning 
performance of the products (the ability to remove soil and stains). As the substances 
remain in the textiles after washing, the substances are in close contact with the skin. 
There is no evidence of sensitising properties of the substances. Optical brighteners are 
used in low concentrations in the products (< 0.2%) and according to the HERA risk 
assessment reports the estimated risk for health and environment is low. Although the 
substances may not be considered necessary for the main function of the products – the 
removal of soil and stains - the use of FWAs seem to have a large influence on the 
consumer’s perception of clean clothes.  
 
5.1.6. Excluded or limited substances and mixtures (4) 
 
Proposed requirement: 
a) Specified excluded ingredients  
The following ingredients must not be included in the product, neither as part of the 
formulation nor as part of any preparation included in the formulation: 
– 
Phosphates 
– 
EDTA (ethylenediamine tetraacetate) 
– 
Nitromusk and polycyclic musk  
 
 
b) Hazardous substances and mixtures 
According to the Article 6(6) of Regulation No 66/2010 on EU Ecolabel, the product or 
any part of it thereof shall not contain substances or mixtures meeting the criteria for 
classification with the hazard classes or categories in accordance with 
Regulation (EC) No1272/2008 specified below nor shall it contain substances referred to 
in Article 57 of Regulation (EC) No 1907/2006. 
 
This criterion applies to all ingredients present in concentrations > 0.010 % 
(preservatives, coloring agents and fragrances included).  
GHS Hazard Statement1
EU Risk Phrase2
H300 Fatal if swallowed 
R28 
H301 Toxic if swallowed  
R25 
H304 May be fatal if swallowed and enters airways  
R65 
H310 Fatal in contact with skin  
R27 
H311 Toxic in contact with skin  
R24 
H330 Fatal if inhaled  
R23/26 
H331 Toxic if inhaled  
R23 
H340 May cause genetic defects  
R46 
H341 Suspected of causing genetic defects  
R68 
H350 May cause cancer  
R45 
H350i May cause cancer by inhalation 
R49 
H351 Suspected of causing cancer  
R40

Page 22 
H360F May damage fertility 
R60 
H360D May damage the unborn child 
R61 
H360FD May damage fertility. May damage the unborn child 
R60/61/60-61  
H360Fd May damage fertility. Suspected of damaging the unborn 
child 
R60/63  
H360Df May damage the unborn child. Suspected of damaging 
fertility 
R61/62  
H361f Suspected of damaging fertility 
R62 
H361d Suspected of damaging the unborn child 
R63 
H361fd May damage fertility. May damage the unborn child 
R62-63  
H362 May cause harm to breast fed children  
R64 
H370 Causes damage to organs  
R39/23/24/25/26/27/28 
H371 May cause damage to organs  
R68/20/21/22 
H372 Causes damage to organs 
R48/25/24/23 
H373 May cause damage to organs  
R48/20/21/22 
H400 Very toxic to aquatic life  
R50. R50/53  
H410 Very toxic to aquatic life with long-lasting effects  
R50/53  
H411 Toxic to aquatic life with long-lasting effects  
R51/53   
H412 Harmful to aquatic life with long-lasting effects 
R52/53   
H413 May cause long-lasting effects to aquatic life  
R53 
EUH059 Hazardous to the ozone layer 
R59 
EUH029 Contact with water liberates toxic gas 
R29 
EUH031 Contact with acids liberates toxic gas 
R31 
EUH032 Contact with acids liberates very toxic gas 
R32 
EUH070 Toxic by eye contact 
R39-41 
Sensitizing substances  
H334 May cause allergy or asthma symptoms or breathing 
difficulties if inhaled 
R42 
H317 May cause allergic skin reaction 
R43 
1 Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures, 
amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 
1907/2006 
2 Directive 67/548/EEC with adjustment to REACH according to Directive 2006/121/EC and Directive 
1999/45/EC as amended 
 
 
Derogations: the following substances or mixtures are specifically exempted from this 
requirement:  
Surfactants  
In concentrations 
< 25% in the 
product 
H400 Very toxic to aquatic life 
R 50 
Biocides used for 
preservation 
purposes* 
H410 Very toxic to aquatic life with long-lasting 
effects 
H411 Toxic to aquatic life with long-lasting effects 
R50/53 
 
R51/53 
Fragrances 
H412 Harmful to aquatic life with long-lasting effects 
R52/53 
Biocides used for 
preservation 
purposes* 
Enzymes** 
H334 May cause allergy or asthma symptoms or 
breathing difficulties if inhaled 
R42 
Bleach catalysts  
** 
Enzymes** 
H317 May cause allergic skin reaction 
R43 
Bleach catalysts ** 
NTA as an impurity 
in MGDA and 
H351 Suspected of causing cancer 
R40

Page 23 
GLDA*** 
Optical brighteners 
(only for heavy duty 
laundry detergent)  
H413 May cause long lasting effects to aquatic life  
R53  
 * Referred to in Criterion 4e. This exemption is applicable provided that biocides' bioaccumulation potentials 
are characterized by log Pow (log octanol/water partition coefficient) <3.0 or an experimentally determined 
bio- concentration factor (BCF) ≤100.  
**Including stabilizers and other auxiliary substances in the preparations 
*** In concentrations lower than 1.0% in the raw material as long as the total concentration in the final product 
is lower than 0.10% 
 
 
c) Substances listed in accordance with article 59(1) of Regulation (EC) No 
1907/2006 
No derogation from the exclusion in Article 6(6) of the Regulation (EC) No 66/2010 shall 
be given concerning substances identified as substances of very high concern and 
included in the list foreseen in Article 59 of Regulation (EC) No 1907/2006, present in 
mixtures, in an article or in any homogenous part of a complex article in concentrations 
higher than 0.010%.  
 
d) Specified limited ingredients - fragrances 
Any ingredients added to the product as a fragrance shall be manufactured and handled 
following the code of practice of the International Fragrance Association (IFRA). The code 
can be found on IFRA website: http://www.ifraorg.org.  
 
The recommendations of the IFRA Standards concerning prohibition, restricted use and 
specified purity criteria for materials shall be followed by the manufacturer. 
 
Fragrance substances subject to the declaration requirement provided for in Regulation 
648/2004/EEC of the European Parliament and of the Council on detergents (Annex VII) 
and which are not already excluded by criterion 4b and (other) fragrance substances 
classified H317/R43 (May cause allergic skin reaction) and/or H334/R42 (May cause 
allergy or asthma symptoms or breathing difficulties if inhaled) shall not be present in 
quantities ≥ 0.010% (≥100 ppm) per substance. 
 
e) Biocides 
The product may only include biocides in order to preserve the product, and in the 
appropriate dosage for this purpose alone. This does not refer to surfactants, which may 
also have biocidal properties. 
 
Motivation: 
By defining criteria which imply that substances characterised by certain intrinsic 
properties shall not be used in ecolabelled products, the ecolabel may respond to doubts 
in relation to the safe use of specific chemicals, and thereby address environmental or 
consumer concern (e.g. substances that are classified as Carcinogenic, Mutagenic, toxic 
to reproduction (CMR), environmentally hazardous and sensitizing substances). 
Substances on the candidate list and substances anticipated to enter the candidate list 
for authorization under REACH (substances of very high concern) are also excluded from 
ecolabelled products ECHA (the European Chemicals Agency) defines substances of 
very high concern as substances being classified as CMR and substances fulfilling the 
PBT criteria or the vPvB criteria. (Furthermore, case by case studies of other problematic 
substances, such as endocrine disrupters, may enter the list). Substances fulfilling the 
PBT and vPvB criteria will thus be excluded from ecolabelled products.

Page 24 
 
a) Specified excluded ingredients  
The groups of substances that are excluded from the products have been expanded to 
include phosphates. 
 
Phosphates are currently not limited by Regulation 648/2004/EC (February 2011) but a 
proposal for amendment of the regulation regarding the use of phosphates and 
phosphororous compounds in household laundry detergents is currently in public 
consultation. The proposal for regulation of the content of phosphates and phosphorous 
compounds in household laundry detergents suggests that products containing more than 
0.5% phosphorous by weight shall not be placed on the market after 1 January 2013.  
The current proposal confirms that eutrophication caused by the use of phosphate is still 
a subject of high relevance.  
 
In the revised Ecolabel criteria phosphates are excluded from ecolabelled products based 
on the following arguments: 
 
• 
Phosphates are already banned in laundry detergents in some European 
countries and limited by legislation or voluntary actions in other countries (e.g. 
Norway, Sweden, Switzerland, Czech Republic, France, Germany, Italy, Austria, 
Netherlands, Belgium and Poland) and are furthermore expected to be restricted 
through the foreseen amendment to Regulation 648/2004/EC. Thus, allowing 
phosphate in ecolabelled products will contradict national bans already 
implemented. 
• 
Many regions in Europe (primarily eastern Europe) have limited or poor waste 
water treatment with limited capacity for phosphate removal in the waste water. In 
these areas there is a significant risk of phosphate eutrophication (CSTEE 2003). 
• 
Chemical phosphorous removal in sewage treatment is expected to increase the 
volume of sludge from approx. 15% to more than 50%, resulting in sludge of lower 
quality that may not be suitable for agricultural use (CSTEE 2003). 
• 
Many of the large retailers in Western Europe have voluntarily decided to phase 
out phosphates in laundry detergents due to the public concern of eutrophication. 
• 
High market shares of phosphate free detergents are already a reality in several 
European countries (CSTEE 2003). 
 
 
Phosphate emission from agriculture and point sources (including waste water from 
households and industry) are the major contributors of P to the aquatic environment (EEA 
2005). However, phosphates from detergents (laundry, dish wash) play only a minor role 
in the overall phosphate emissions to the aquatic environment, especially in areas where 
phosphate is effectively removed in waste water. In a European quantitative risk 
assessment of the eutrophication of polyphosphates in detergents, it is estimated that on 
average, less than 5% of the overall P contribution is related to laundry detergents (INIA 
2009). Point sources still have a significant contribution to the overall P emissions. The 
major P contributions to point sources arise from human metabolism (INIA 2009). 
Generally, the emissions of P via point sources have decreased during the last 30 years. 
This is mainly due to improved waste water treatment, especially in Northern and 
Western Europe, following the implementation of the EU Waste Water Treatment 
Directive (1991/271/EC). (EEA 2005). Eastern European countries seem to be following 
this development although Directive 1991/271/EC is not fully implemented in many 
member states (EEA 2005, CEEP 2007). 
 
The most important alternative substances for phosphates in laundry detergents are 
zeolites, which are typically used in combination with polycarboxylates and

Page 25 
phosphonates, and silicates and citrates. Other phosphate alternatives that are currently 
used to a minor extent in laundry detergents include iminodisuccinate, MGDA and GLDA. 
A total ban on phosphates would lead to a much reduced amount of sludge from the 
waste water treatment plants (WWTPs) using chemical phosphate removal and is not 
suspected to affect the biological processes in the WWTP.  
 
The replacement of phosphates in laundry detergents with the above mentioned 
alternatives is not expected to cause adverse effects in the environment, and a positive 
side effect could be lower operation costs related to reduction in the use of chemicals for 
phosphate precipitation in the WWTP. Zeolites, which is the main alternative to 
phosphate, do not pose a risk to health and environment (HERA 2004 and 2005). 
However, an important aspect of the use of zeolites is the contribution to the volume of 
waste water sludge as approximately 90% of the zeolite entering the WWTPs is 
incorporated into the sewage sludge (HERA 2004 & 2005). In the opinion from The 
Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) it was 
concluded, that “the use of zeolites in detergent products should not increase the amount 
(volume) of sewage sludge produced, or lead to a sewage sludge of unacceptable quality 
for agricultural use (CSTEE 2003). SCHER evaluated the potential risk related to the co-
builders phosphonates and polycarboxylates, which are used in both phosphate and 
zeolite based detergents (RPA 2006), and have concluded that only limited data are 
available and that further assessments should be conducted. For both phosphonates and 
polycarboxylates, the available data indicate that there may be a potential environmental 
risk under worst case conditions, but further data are needed to validate this. It is 
furthermore indicated that the potential risks of phosphonates and polycarboxylates are 
expected to be higher for zeolite-based than for P-based detergents (SCHER 2007). Still, 
phosphates and polycarboxylates are generally present in very low concentrations 
compared to zeolite and phosphate. Through the ecolabel criteria, the content of 
phosphonates and polycarboxylates is limited through the general requirements to aNBO 
and anNBO. 
 
The benefits of moving from phosphate based to zeolite based detergents have been 
assessed for each of the EU-25 countries. The greatest benefits are estimated in 
countries with high phosphate detergent use, low provision of tertiary sewage treatment 
and severe problems with eutrophication. Based on this assessment, there are only few 
or some benefits to gain in Northern and Central Europe, whereas the most benefits from 
moving to phosphate free detergents are assumed to be gained in the Baltic, eastern and 
southern European countries (Czech Republic, Slovakia, Poland, Spain, Portugal, Latvia 
and Lithuania) (RPA 2006). 
 
 
EDTA can re-mobilise metals from sediments and soils leading to contamination of 
surface and ground waters. The aerobic and anaerobic biodegradability of EDTA are 
furthermore limited. Risk assessment of EDTA has concluded a need for limitation of the 
risk in a range of applications, although not for domestic detergents as the use of EDTA 
in these products is limited (EU RAR 2004). Exclusion of EDTA in the ecolabel criteria is 
thus a preventive measure. This also ensures that it can be communicated to the 
consumers that ecolabelled products are EDTA free.  
 
 
Nitromusk and polycyclic musk generally have unwanted health and environmental 
properties. Some are already excluded through the exclusion of CMR substances. 
Communication with suppliers of fragrance (personal communication, 2009) has 
confirmed that many companies all over Europe still use polycyclic musk in consumer 
products. The use of nitromusk is apparently very limited, but manufacturers outside 
Europe still produce for example Musk Ambrette, which is prohibited by IFRA. Exclusion 
of nitro- and polycyclic musk is thus still considered relevant as a preventive measure.

Page 26 
 
 
Note that  APEO’s and derivatives were excluded in the 2003 criteria as their 
degradation products are not readily biodegradable and as some degradation products 
are suspected of endocrine disrupting effects. This applies e.g. to Nonylphenol and 
Nonylphenolethoxylates (Danish EPA 2002, DHI 2007). APEO and derivatives have, 
however, been phased out of a range of industrial applications by voluntary actions in 
different industrial sectors. APEO’s have since 2004 been excluded from laundry 
detergents through the Detergents Regulation (648/2004/EEC). 
 
b) Hazardous substances and mixtures 
Exclusion of CMR substances, toxic substances and environmentally hazardous 
substances are a general requirement for ecolabelled products according to Regulation 
(EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on 
the EU Ecolabel. In addition the requirement also addresses substances classified as 
sensitizers. Allergy is an increasing problem. Some ingredients used in laundry 
detergents and auxiliary products are designed to stay in/leave traces in the textile (e.g. 
fragrances). Other substances may be left in the textile due to incrustation of poorly 
soluble substances or poor/insufficient rinsing in the washing process. Thus, a limitation 
of the content of sensitizing substances is foreseen to minimise the risk of allergic 
reactions. By exclusion of substances with certain hazardous properties, the most critical 
substances regarding human health and environment are excluded from the products. 
According to the EU Ecolabel Regulation, derogation from this requirement is only 
possible if it is not technically possible to substitute such substances or if the overall 
environmental benefit from using the abovementioned substances can be demonstrated. 
Certain derogations have thus been introduced for laundry detergents, for example 
regarding the use of surfactants classified as environmentally hazardous. In ecolabelled 
laundry detergents, the majority of the surfactants typically used are classified R50 
(H400): Very toxic to aquatic life. (This e.g. applies to non-ionic surfactants categorised 
as DID no 25, 28, 29 and 34). In the revised criteria, surfactants classified R50 (or H400) 
are not prohibited as this would require a shift towards other types of surfactants such as 
non-anaerobically biodegradable anionic surfactants. Other derogations apply for 
enzymes, biocides, bleach catalysts, fragrances and optical brighteners as these 
substances (except fragrances) cannot be substituted while still maintaining satisfactory 
performance of the products. Enzymes and bleach catalysts (including stabilisers and 
other additives in the formulations) are e.g. derogated as these substances are important 
for the function of the products and may also reduce the content of other active 
ingredients (primarily surfactants) in the product. Both enzymes and certain bleach 
catalysts can lead to savings of the overall environmental impact by reducing the volume 
of the total chemicals, the CDV and/or by facilitating wash at lower temperatures. 
 
Although fragrances do not contribute to the performance of laundry detergents, 
fragrances are to a certain extent derogated from the requirement as it is recognised that 
a large proportion of the consumers require fragranced products - also when purchasing 
ecolabelled products. The possibility of marketing fragranced product variants is an 
important sales parameter, and the prevalence of ecolabelled products is heavily 
compromised if fragrances are not allowed. 
 
c) Substances listed in accordance with article 59(1) of Regulation (EC) No 
1907/2006 
Through this requirement “Substances of very high concern” will be restricted from use in 
ecolabelled products. Such substances are CMR substances (addressed in requirement 
4b) and substances fulfilling the PBT and vPvB criteria as defined under REACH. 
Furthermore, other substances of very high concern identified on a case-by-case basis

Page 27 
from scientific evidence as causing probable serious effects to human health or the 
environment might enter the candidate list (e.g. endocrine disrupting chemicals). 
 
d) Specified limited ingredients - fragrances 
The requirement stating that fragrance must be manufactured and/or handled following 
the code of practice of the International Fragrance Association (IFRA) ensures 
compliance with IFRA standards. 
Many fragrance formulations contain a range of sensitizing substances. By limiting the 
content of allergenic substances to a minimum, the risk of allergic reactions when using 
ecolabelled products for laundry washing is minimised. The limit implies that fragrances 
present in ecolabelled products will not require declaration on the label according to the 
Detergents regulation, as the limit for declaration is set at 0.010 % (100 ppm).  
 
e) Biocides 
This requirement ensures that biocides used for other purposes than preservation are not 
used in ecolabelled laundry detergents. Antimicrobial or disinfecting ingredients added for 
other purposes than preservation are generally unwanted in laundry detergent and other 
household products as disinfection is not required for household washing and cleaning. In 
case of infectious diseases in the household, the washing temperature should be raised 
to ≥ 60°C, which is also a mandatory washing advice in the revised criteria. Due to their 
mode of action, substances with disinfecting or antimicrobial properties generally have a 
high aquatic toxicity and are often poorly biodegradable due to inhibitory effects on 
bacteria. Use of antimicrobials and/or disinfecting agents should also generally be 
reduced in relation to the possible development of resistant bacteria. Claims of 
antibacterial effects are seen on detergent products currently on the European market 
(e.g. stain removers and cleaning products).  The use of e.g. nanosilver as bactericides in 
products marketed outside Europe has been reported and the EU Ecolabel should be 
prepared for the possible appearance of such products on the European market in the 
future (The Project on Emerging Nanotechnologies; Nanogist Co. 2009).

Page 28 
5.1.7. Packaging requirements (5) 
 
Proposed requirement: 
 
• 
Weight/utility ratio (WUR) 
The weight/utility ratio (WUR) of the product must not exceed the following values: 
 
Product type 
WUR 
Powders 
1.2 g/kg wash 
Others (e.g. liquids, gels, tablets,  capsules) 
1.5 g/kg wash 
 
 
WUR is calculated only for primary packaging (including caps, stoppers and hand 
pumps/spraying devices) using the formula below. 
 
WUR = Σ [(Wi + Ui)/(Di * ri)] 
 
Where: 
 
Wi = the weight (g) of the packaging component (i) including the label if applicable. 
Ui = the weight (g) of non-recycled (virgin) material in the packaging component (i). If the 
       proportion of recycled material in the packaging component is 0% then Ui = Wi.  
 
Di = the number of functional units contained in the packaging component (i). The  
       functional unit = dosage in g/kg wash 
ri = recycling figure, i.e. the number of times the packaging component (i) is used for the    
same purpose through a return or refill system (r=1, if the packaging is not re-used for 
the same purpose. If the packaging is reused r is set to 1 unless the applicant can 
document a higher number.  
 
 
Exceptions: 
Plastic/paper/cardboard packaging containing more than 80% recycled material is 
exempted from this requirement. 
 
Packaging is regarded as recycled if the raw material used in the packaging has been 
collected from packaging manufacturers, the distributive stage or the consumer stage. If 
the raw material is industrial waste from the material manufacturer’s own production 
process, then the material will not be regarded as recycled. 
 
• 
Plastic packaging 
Only phthalates that at the time of application have been risk assessed and have not 
been classified according to requirement 4b (and combinations hereof) may be used in 
the plastic packaging.

Page 29 
• 
Labelling of plastic packaging 
To allow for identification of different parts of the packaging for recycling, plastic parts in 
the primary packaging must be marked in accordance with DIN 6120, Part 2 or the 
equivalent. Caps and pumps are exempted from this requirement. 
 
 
Motivation: 
a) Weight/utility ratio (WUR) 
In a life-cycle perspective, the packaging has a relatively low impact on the environment 
(Appendix 2). However, it is still relevant to reduce the consumption of packaging material 
to a minimum in accordance with the aim of the packaging and packaging waste directive 
(Directive 94/62/EC). From a communication point of view, it is also an important signal to 
the consumers that packaging is reduced to a minimum for ecolabelled products. 
 
The former requirement establishing a limit of the weight of the primary packaging per 
wash is no longer considered applicable as the criterion in practice did not include liquid 
products (or: plastic packaging) and to some extent limited the possibility for ecolabelling 
of tablets and powders in cardboard boxes. The general trend of increased market shares 
of liquid laundry detergents and possibly also tablets has created a need for adjustment 
of the packaging requirement enabling packaging for e.g. liquids, tables and sachets to 
comply with the criteria. Products other than powders generally have a higher proportion 
of packaging relative to the volume of product, and more resources are thus used for 
packaging of such products. On the other hand, dosing via liquids, tablets and other 
forms of unit dosing is anticipated to reduce the risk of overdosing of the products. It is 
also recognised that different types of products may be needed for different applications 
and that the consumers in some countries prefer liquids or tablets relative to powders.  
 
The requirement limiting the amount of packaging per wash has been modified and the 
concept weight/utility ratio (WUR) has been adopted from the Nordic Ecolabel Criteria for 
laundry detergents, version 6.0 with minor modifications. More than 50 different 
ecolabelled product formulations already on the market in Scandinavia (powders, liquids 
and tablets) comply with the proposed levels. A re-calculation of some of the products in 
the Danish EU Ecolabel licences show that the formulations (tablets and powders) 
currently holding the EU Ecolabel also comply with the proposed WUR ratio.  
 
With respect to the recycling figures (ri) for re-used packaging components, a higher 
number than 1 can be used if the applicant can demonstrate that the packaging 
component is actually recycled. This can be demonstrated e.g. by indicating the sales (or 
expected sales – figures should be provided by the retailer) of primary packaging versus 
refill packaging, respectively. Alternatively, provided that both primary and refill packaging 
is equally available for the consumer at all times, the applicant may estimate the number 
of times the primary packaging can reasonably be re-used by refill. (The extent of re-use 
of a cardboard box is e.g. expected to be lower than a plastic or metal container). 
 
b) Plastic packaging 
This requirement is new and will prohibit the use of problematic phthalates as plasticisers 
in plastic packaging. Some of the phthalates most frequently used in plastics are 
classified as being toxic to reproduction (DEHP,DBP,BBP). Several other phthalates are 
suspected of causing endocrine disrupting effects (DHI 2007). Due to these concerns, 
the phthalates DEHP, DBP, BBP, DINP, DIDP and DNOP have e.g. been 
prohibited/limited for use in toys and childcare articles (Directive 2005/84/EC). Other 
ecolabel criteria, e.g. the EU Ecolabel criteria for footwear (2009/563/EEC), also prohibit 
the use of phthalates of concern. The possible risk associated with the use of phthalates

Page 30 
in plastic packaging for laundry detergents is unknown, but the possible use of potentially 
endocrine disrupters in ecolabelled laundry detergents and their packaging is generally 
unwanted. 
 
5.1.8. Washing performance (fitness for use) (6) 
 
Proposed requirement: 
The product shall comply with the performance requirements as specified for the relevant 
product type according to the EU Ecolabel laundry detergents performance test's latest 
version that can be found here: 
http://ec.europa.eu/environment/ecolabel/ecolabelled_products/categories/laundry_deter
gents_en.htm 
 
Motivation: 
Documentation of performance is crucial for the credibility of the Ecolabel. Fulfilling the 
requirement for performance ensures that the product is fit for use and fulfils the 
consumer’s expectations of a satisfactory functioning detergent. The test protocol has 
been revised as a separate activity assigned by the EU Commission and has been 
conducted by Leitat Technological Center parallel to the revision of the EU Ecolabel 
criteria. The test protocol is a separate document serving to supplement the Ecolabel 
criteria for laundry detergents. 
 
5.1.9. Points (7) 
 
Proposed requirement: 
a) Heavy-duty laundry detergents 
A minimum of 3 points must be achieved from the matrix below. (The maximum 
achievable points are 8 points for coldwater products, 7 points for low-temperature 
products and 6 points for other products). 
 
Climate profile 
Coldwater product (washing performance documented at ≤ 20 °C) 
2 P 
Low-temperature product (washing performance documented at > 20 °C to 
≤ 30 °C) 
1 P 
Maximum dosage 
Max dosage ≤ 14 g/kg wash (powder, tablet) or ≤ 14 ml/kg wash (liquid, gel) 
2 P 
Max dosage ≤ 16 g/kg wash (powder, tablet) or ≤ 16 ml/kg wash (liquid, gel) 
1 P 
CDV 
CDVchronic < 25,000 l/kg wash 
2 P 
CDVchronic between 25,000 to 30,000 l/kg wash 
1 P 
aNBO  
aNBO ≤ 75% of limit value 
1 P 
anNBO  
anNBO ≤ 75% of limit value 
1 P 
Minimum points to be achieved for Flower labelled products 
3 P

Page 31 
b) Low-duty laundry detergents  
A minimum of 3 points must be achieved from the matrix below. (The maximum 
achievable points are 8 points for coldwater products, 7 points for low-temperature 
products and 6 points for other products). 
 
Climate profile 
Coldwater product (washing performance documented at ≤ 20 °C) 
2 P 
Low-temperature product (washing performance documented at > 20 °C to 
≤ 30 °C) 
1 P 
Maximum dosage 
Max dosage ≤ 14 g/kg wash (powder, tablet) or ≤ 14 ml/kg wash (liquid, gel) 
2 P 
Max dosage ≤ 16 g/kg wash (powder, tablet) or ≤ 16 ml/kg wash (liquid, gel) 
1 P 
CDV 
CDVchronic < 15,000 l/kg wash 
2 P 
CDVchronic between 15,000 to 18,000 l/kg wash 
1 P 
aNBO  
aNBO ≤ 75% of limit value 
1 P 
anNBO  
anNBO ≤ 75% of limit value 
1 P 
Minimum points to be achieved for Flower labelled products 
3 P 
 
 
Motivation: 
As described in Appendix 2, lowering of the washing temperature will greatly influence 
the overall environmental impact of laundry detergents. The purpose of the scoring 
system has two functions: 1) to promote coldwater and low-temperature products which 
reduce the energy consumption during the wash stage and 2) promote (other) products 
with very low emissions of hazardous substances to the environment. With this scoring 
system, products fulfilling the performance test at 30 °C  will have to perform even better  
on parameters like TC, CDV, aNBO and anNBO than stated by the mandatory 
requirements compared to products with documented performance at lower washing 
temperatures (< 30 °C). The scoring system is a sim ple “pass/fail” system reflecting the 
main environmental impacts of the products.  
 
Based on an analysis of the existing coldwater/low-temperature products on the market 
holding either the Nordic Ecolabel or the EU Ecolabel (heavy-duty laundry detergents), 
the chemical parameters of such products is relatively similar to other ecolabelled laundry 
detergents used at washing temperatures of 40 °C an d above. The CDVchronic values for 
the available coldwater formulations are, however, higher than for other, comparable 
products due to the choice of builder. The builder in question (inorganic compound) has a 
relatively high contribution to the CDVchronic due to a lack of chronic toxicity values on the 
DID list. Acute data are thus used to estimate chronic values and in spite of a low acute 
toxicity, acute data have a relatively high contribution to chronic CDV values.  On the 
other hand, the analysis also showed that it is possible for existing EU ecolabelled 
products used at washing temperatures at 40-60 °C t o achieve at least 3 points as 
required (available formulations from Denmark, UK and France). Thus, the requirement is 
expected to promote the development of products that facilitate reduced CO2 emissions 
in the washing phase and/or products with very low emissions of hazardous substances 
to the aquatic environment. 
 
A prerequisite for washing at low temperatures or in cold water is that the washing 
machines have programmes facilitating washing at temperatures lower than 30 °C. An 
enquiry to different manufacturers of washing machines (Danish head offices for Miele, 
Gorejne, Bosch/Siemens and Asko Vølund) confirm that many of the newer models have

Page 32 
an option for using “cold water“ (i.e. the temperature of the inlet water). However, some of 
the manufacturers also emphazise that especially in regions with hard water, the 
deposition of calcium combined with soap and other detergent ingredients provide a 
substrate for development of bio-film in the machine. This problem increases with 
decreasing washing temperatures and may lead to a reduced lifetime of the machine and 
possibly problems with smell. It is, however, not expected that all washes in a household 
are conducted at temperatures <30 °C, and following  the machine manufacturer’s 
instructions and running a high temperature maintenance wash (≥ 60 °C) now and then 
with a suitable (bleach containing) detergent should prevent possible problems with smell 
or biofilm. Washing in cold water has been a reality for many years in other regions, e.g. 
Spain and countries outside Europe (Japan, Asia), indicating that washing machines as 
well as detergents have been adapted to or developed for this use. 
 
At present, the market for low temperature products are mainly related to heavy duty 
detergents.  
 
5.1.10. Consumer information (8) 
 
Proposed requirement: 
a) Dosage instructions 
The recommended dosages shall be specified for ‘normally’ and ‘heavily’ soiled textiles 
and various water hardness ranges relevant for the countries concerned and referred as 
appropriate to the weight of textile. (Not applicable for stain removers). 
 
The difference between the dosage recommendations for the lowest water hardness 
range (soft) for normally soiled textiles and the highest water hardness range (hard) for 
heavily soiled textiles may not differ by more than a factor of 2. (Not applicable for stain 
removers). 
 
The reference dosage used for the washing performance test and for assessment of 
compliance with the ecological criteria on ingredients shall be the same as the 
recommended dosage on the package for ‘normally soiled’ textiles and a water hardness 
corresponding to 2.5 mmol CaCO3/l. 
 
If only water hardness lower than 2.5 mmol CaCO3/l are included in the 
recommendations, the maximum dosage recommended for ‘normally soiled’ shall be 
lower than the reference dosage used in the washing performance test (water hardness 
2.5 mmol CaCO3/l). 
 
b)   
Information on the packaging 
The following washing advices (or equivalent) shall appear on the packaging of EU 
ecolabelled products within the product group except for pre-treatment stain removers. 
The washing advices may be present either as text or symbols: 
 
– 
“Wash at the lowest possible temperature 
– 
Always wash with full load 
– 
Dose according to soil and water hardness, follow the dosing instructions  
– 
If you are allergic to house dust, always wash bedding at 60°. Increase wash 
temperature to 60° C in case of infectious diseases   
 
  
Using this ecolabelled product and following the dosage instructions will contribute to the 
reduction of water pollution, waste production and energy consumption.”

Page 33 
 
c)  
Claims on the packaging 
In general, claims on the packaging shall be documented either through performance 
testing or other relevant documentation (e.g. claims of efficiency at low-temperatures, 
claims of removal of certain stain types, claims of benefits for certain types or colours of 
textile or other claims of specific properties/benefits of the product).  
 
• 
E.g. if a product claims efficiency at 20 °C, the efficiency test must be performed at ≤ 
20 °C (and correspondingly for other temperature cl aims below 30 °C). 
• 
E.g. if a product claims to be efficient on certain stain types, this must be 
documented with efficiency test 
 
 
d) Information on the packaging – additional requirements for stain removers 
The removal of stains for which no performance test has been conducted, must not be 
claimed on the product. 
 
 
 
Motivation: 
The information required on the packaging of ecolabelled products addresses dosing 
instructions and optimised use of the products in order to facilitate correct dosing and the 
lowest possible environmental impact of the washing process. Overdosing of laundry 
detergents is a common phenomenon (Brückner 2007, Elforsk 2005). It is questionable if 
more accurate dosing information/information text on the packaging will alter the habits of 
the consumer, as a large proportion of the consumer’s dose “by the feel” (Brückner 2007, 
Elforsk 2005). According to the AISE survey of European washing habits, only 65% of the 
consumers dose according to the recommendations provided by the manufacturers (AISE 
2008). Campaigns like AISEs voluntary industry initiative (the wash-right campaign, 
www.washright.com) has introduced clear and visible labelling in the form of easily 
recognisable pictogram’s on the packaging (voluntary commitment for manufacturers). 
Such pictograms are considered very informative. However, the possible introduction of 
similar pictograms in the ecolabel criteria has been evaluated, but it is concluded that this 
may cause confusion. An introduction of unique ecolabel pictograms will increase the 
“burden” of information for manufacturers already committed to using the wash-right 
symbols. The space is often very limited on the packs due to the many declaration and 
consumer information requirements already laid down by the Detergents regulation, as 
well as the demand for placing the information in many different languages by the 
manufacturers. The manufacturers may choose whether the washing advices are placed 
as text or symbols, giving the possibility of using the wash-right symbols and adding the 
remaining information required by the Ecolabel. 
 
The requirement ensures that the recommended dosage on the package complies with 
the dosage used to document the performance of the product. Furthermore, the 
requirement ensures that claims of the efficiency and specific benefits of the products are 
documented. Even though lowering of the wash temperature is generally recommended 
in order to reduce the energy consumption, the washing advices takes into account 
special conditions that may apply for consumers allergic to house dust and in case of 
infections diseases in the household.

Page 34 
5.1.11. Information appearing on the Ecolabel (9) 
 
Proposed requirement: 
Optional label with text box shall contain the following text: 
 
- Reduced impact on aquatic ecosystems 
- Limited hazardous substances 
- Performance tested 
 
The guidelines for the use of the optional label with text box can be found in the 
"Guidelines for use of the Ecolabel logo" on the website: 
http://ec.europa.eu/environment/ecolabel/promo/logos_en.htm 
 
 
Motivation: 
According to Regulation (EC) No 66/2010, three key environmental characteristics of the 
ecolabelled product shall be stated in each criteria document and may be displayed in the 
optional label with text box.  
 
5.2. Former requirements not included in the revised criteria 
5.2.1. Insoluble, inorganic ingrediens 
 
Former requirement: 
The requirement limiting the content of insoluble, inorganic substances to 30 g/wash is 
excluded in the revised criteria. 
 
Motivation: 
A requirement limiting the content of insoluble, inorganic ingredients is not considered a 
key parameter in reducing the environmental impact of laundry detergents. Insoluble 
inorganics are mainly present in form of zeolites. Zeolites do not pose a risk to health and 
environment (HERA 2004 and 2005). However, an important aspect of the use of zeolites 
is the contribution to the volume of waste water sludge as approximately 90% of the 
zeolite entering the WWTPs is incorporated into the sewage sludge (HERA 2004 & 
2005). In an opinion from The Scientific Committee on Toxicity, Ecotoxicity and the 
Environment it was concluded, that “the use of Zeolites in detergent products should not 
increase the amount (volume) of sewage sludge produced, or lead to a sewage sludge of 
unacceptable quality for agricultural use (CSTEE 2003).  
 
5.2.2. Phosphates 
 
Former requirement: 
The requirement limiting the content of phosphates to 25 g/wash is replaced with a total 
exclusion of phosphates. Reference is made to requirement no 4a, addressing excluded 
substances and mixtures.  
 
Motivation: 
Reference is made to the motivation presented under requirement No 4: Excluded or 
limited substances and mixtures. 
5.2.3. Surfactants

Page 35 
The revised criteria have no unique requirements for surfactants. Reference is made to 
requirement no 3, addressing the biodegradability of the total content of organics in the 
products.  
 
5.2.4. Purity of enzymes 
 
Former requirement: 
The requirement regarding the absence of production microorganisms is excluded in the 
revised criteria. 
 
 
Motivation: 
The former requirement for enzymes was introduced due to concern about genetically 
modified organisms. Most detergent enzymes are produced by genetically modified 
micro-organisms (GMM) today. In this way, enzymes with high purity for the targeted 
washing conditions (e.g. cold wash) can be developed (personal communication with 
Novozymes, 2009).  
 
Use of GMM is regulated through EU’s directive on contained use of GMM (Directive 
90/219/EEC). Absence of production strains in enzyme products is one of the 
requirements in this directive. In addition, Novozymes explains that regardless GMM or 
non-GMM, production micro-organisms are removed during the recovery process. The 
requirement of absence of production micro-organisms is thus unnecessary. 
 
5.3. Other issues of importance discussed during the revision 
5.3.1. Renewable ingrediens 
During the latest years a lot of attention has been put to the use of fossil fuel based 
ingrediens versus vegetable based ingrediens. This discussion is relevant considering the 
future limitations on fossil fuels and the concern of global warming. Global warming is to a 
high extent related to the burning of fossil fuels.  
 
In laundry detergents it is mostly surfactants and various polymers that are derived from 
the petro-chemical industry. Many of the bulk ingredients in the detergents are inorganic 
(e.g. builders like zeolite, silicates, carbonates) and are not replaceable by renewable 
resources. Some renewable raw materials are already used in laundry detergents such 
as soaps (typically derived from vegetable oils). Other ingredients may partly consist of 
renewable materials such as Alkyl Polyglycosides (APG) and biopolymers.  
 
Although the environmental benefits of moving away from petro-chemical based 
ingredients seem obvious, replacement with renewable resources are associated with 
some concerns - both ecologically, economically and socially. Major topics of concern are 
loss of natural habitats (e.g. rainforest, other areas of high biological value) and increased 
food costs combined with reduced food supplies (WWF 2009, RSPO 2009). Roundtable 
for Sustainable Palm Oil (RSPO) is one of the initiatives that aim at promoting the growth 
and use of sustainable vegetable oils. A possible promotion of the use of renewable raw 
materials in ecolabelled detergents would imply that the production of renewable raw 
materials (especially vegetable oil production) is sustainable. Some important 
considerations in relation to a possible integration of requirements promoting renewable 
substances are: 
 
- 
It is presently uncertain if there is an overall benefit of a (partial) replacement of 
renewable raw materials with non renewable raw material with respect to climate

Page 36 
impact. Relevant data for global warming potential on ingredients used in laundry 
detergents (renewable as well as non renewable) have not been identified during the 
criteria revision process. Based on the available LCA’s it is mostly the use of laundry 
detergents that contributes to global warming through considerable energy 
consumption. The climate impact from extraction and processing of raw materials is 
secondary to the use phase.  
- 
If sustainability requirements are to be imposed on the use of renewable raw 
materials, compliance is in practise expected to be difficult for many manufacturers 
due to challenges of procurement of the relevant documentation. If proper 
documentation for renewable cannot be obtained, this might lead to increase in use of 
non-renewable raw materials compared to the situation today. It is not desirable to 
promote increased use on non-renewable raw materials. 
- 
The availability of renewable raw materials for detergents may be limited and 
expensive and may put a strain especially on smaller manufacturers. 
- 
There is currently not much experience with promoting renewable raw materials within 
EU ecolabelling of chemical products. In the EU Ecolabel criteria for Lubricants there 
is a requirement regarding the amount of renewable oil but only little experience has 
been gained through this product group. 
 
An example of “green” or (partly) renewable ingredients for detergents is Methyl ester 
sulfonates (MES). MES have been on the market for some years but has so far not been 
price competitive to e.g. LAS, which on a global scale is one of the most widely used 
surfactants in laundry detergents. However, with increasing petro-chemical prices and 
improvement of the MES production process, MES may become a realistic alternative to 
petro-chemical based surfactants such as LAS. MES have been highlighted for their high 
biodegradability, low aquatic toxicity and good environmental profile. MES are obtained 
from plant and tallow resources and are being promoted as “green surfactants” with 
application both within the detergent and personal care industry. Although the benefits of 
MES as a possible replacement for substances like LAS have been highlighted and 
although regulatory and environmental bodies advocate the use of green chemistry, 
concerns about feedstock availability have also been expressed in relation to the use of 
MES (Satsuki 1994, Research and Markets 2009).  
 
At this stage it is thus chosen not to impose requirements regarding the use of renewable 
substances, as assessment of the environmental and socioeconomically impact of such a 
requirement is highly complex and out of scope of this criteria revision. 
5.3.2. Nanomaterials 
Some stakeholders, especially the consumer organisations, have expressed concern 
regarding the possible use of nanomaterials/nanoparticles in laundry detergents. The 
concerns are related to the possible use of nanosilver as a bactericide are addressed 
under requirement no. 4e as biocides cannot be used for other purposes than 
preservation of the product itself. Other concerns are related to the current absence of 
safety assessment methods and the potential large ecological footprint of the 
manufacture of nanomaterials. Nanosized materials are currently not sufficiently 
characterized and methods for risk and safety assessment (incl. analytical methods and 
test methods for ecotoxicological and toxicological properties) are not sufficiently 
developed and harmonized. The EU Scientific Committee on Emerging and Newly 
Identified Health Risks (SCENIHR) concluded that: “Current risk assessment 
methodologies require some modification in order to deal with the hazards associated 
with nanotechnology” (SCENIHR 2006). As discussed at the 3rd. AHWGM, exclusion of 
certain substances or substance groups need to have relevance for the product group. A 
question was raised, mainly towards the manufacturers, whether 
nanoparticles/nanomaterials are currently used in laundry detergents in Europe.

Page 37 
According to the participants this is not an issue at present. Furthermore, the use of 
bactericidal substances is addressed through requirement no. 4e prohibiting the use of 
antimicrobial and disinfecting substances for other purposes than preservation. 
 
5.4. Recommendations for future criteria 
A range of subjects have been discussed during the present criteria revision and some 
topics have either been out of scope of the current revision or have been considered 
premature in the context of the current market for laundry detergents. The working group 
has thus pointed out some key issues, which are suggested addressed within the next 
revision of the criteria: 
 
• 
Increased focus on energy use (carbon footprint) and further promotion of cold-
water products  
• 
Increased level of compaction/decreased dosage 
• 
Possibility of introduction of requirements for use of renewable, sustainable raw 
materials 
• 
Evaluation and tightening of requirements for the newly introduced product 
category: pre-treatment stain removers  
• 
Revision of the DID list

Page 38 
ABBREVIATIONS AND DEFINTIONS  
 
AISE
The International Association for Soaps, Detergents and 
Maintenance products
aNBO
Anaerobically not biodegradable substances
anNBO
Anaerobically not biodegradable substances
BCF
Bioconcentration Factor
Coldwater product
A coldwater product is in the context of the ecolabel 
criteria defined as products that have a documented 
washing performance at ≤ 20 °C
CDV
Critical Dilution Volume
°dH
German degree of hardness. (14 °dH is considered 
medium water hardness)
DID-list
Detergents Ingredients Database list
EDTA
Ethylenediamine tetraacetate
Functional unit
The quantity of detergent (in grams) used per kg textile 
during washing/treatment. (calculated as the dosage per 
standard wash/4.5 kg)
GHS
Globally Harmonised System of Classification and 
Labelling of Chemicals
GLDA
Glutamic acid diacetic acid
GMM
Genetically modified micro-organisms
Heavy-duty detergents
Detergents used for ordinary washing of white and 
colored textiles (at any temperature)
IFRA
International Fragrance Organisation
LogKow
Log Octanol-Water partition coefficient
Low-duty detergents
Detergents promoting special fabric care: e.g. low 
temperature wash, use for delicate fabrics such as wool 
and silk, use for delicate colors
Low-temperature product
A low-temperature product is in the context of the 
ecolabel criteria defined as products that have a 
documented washing performance at> 20 °C to < 30 °C
LSP2
Laundry Sustainability Project No 2 (AISE Voluntary 
industry initiative for sustainable cleaning)
MGDA
Methylglycin diacetic acid
NTA
Nitrilotriacetic acid
PPM
Parts per million. Measuring unit (100 ppm = 0.010%)
TC
Total Chemicals
WUR
Weight Utility Ratio
WWTP
Waste water treatment plant

Page 39 
6. REFERENCES 
 
ACNielsen 2007: Miljømærkning Svanen og EU Blomsten. Rapport til Dansk Standard. 
Februar 2007 [Ecolabelling The Swan and the EU Flower. Report to Danish Standards. 
February 2007] 
 
AISE 2008: AISE Annual Review 2008. Towards Sustainable Cleaning: A.I.S.E. highlights 
from 2008. http://www.aise.eu/downloads/AISE_AR2008FINAL.pdf 
 
Brückner 2007: Anna Bruckner, Anke Kruschwitz and Rainer Stamminger, Universität 
Bonn: Consumer washing behaviour: results of a survey involving 100 households. 54 
Sepawa Kongress mit European Detergents Concerence, 10-12. October 2007.  
 
CEEP 2007: Phosphates: a good environmental solution for detergents. August 2007, 
CEEP (Centre Europeen d’Etudes des Polyphosphates). 
 
COM 2009a: Commission report (COM(2009)0230) concerning anaerobic biodegradation 
(May 2009).  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2009:0230:FIN:en:PDF 
 
COM 2009b: Commission report (COM(2009)0208) on the biodegradability of the main 
non-surfactant organic detergent ingredients (May 2009).  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2009:0208:FIN:en:PDF 
 
CSTEE 2003: Opinion of the Scientific Committee on Toxicity, Ecotoxicity and the 
Environment on “The environmental impact (reduction in eutrophication) that would result 
from banning sodium tripolyphosphate (STPP) in household detergents”. Adopted 12-13. 
November 2003. 
 
Danish EPA 2002: Miljøprojekt nr 704, 2002: Nonylphenol og nonylphenolethoxylater i 
spildevand og slam [Environmental project No. 704, 2002: Nonylphenol and 
nonylphenolethoxylates in waste water and sludge]. Miljøstyrelsen, Miljø- og 
Energministeriet 2002. 
 
Dansk Kemi 2005: Vaskemidler anno 2005 [Laundry detergents anno 2005]. Dansk Kemi, 
86, Nr 8, 2005 
 
DHI 2003: Revision of Ecolabel criteria for laundry detergents. Final Report. (Annex 6: 
Statement from Regulatory Committee meeting on 4 December 2002). DHI Water & 
Environment, dk-Teknik Energy & Environment, May 2003. 
 
DHI 2007: Study on enhancing the Endocrine Disrupter priority list with a focus on low 
production volume chemicals. Report to DG Environment, May 2007. 
http://ec.europa.eu/environment/endocrine/documents/final_report_2007.pdf 
 
ECB 2006: Classification proposal. Trisodium nitrilotriacetate CAS-No.: 5064-31-3. 
European Chemicals Bureau ECBI/05/06 Rev. 1 
(http://ecb.jrc.it/classlab/0506r1_DE_NTA.doc) 
 
Ecolabelling Denmark 2008: Revision of Ecolabel Criteria for Laundry Detergents & 
Dishwashing Detergents, Preliminary report. June 2008.

Page 40 
EEA 2005: Source appointment of nitrogen and phosphorus inputs to the aquatic 
environment. EEA report no 7/2005. European Environmental Agency. 
 
Elforsk 2005: Hvilken indflydelse har vaskeadfærden på den 
mængde energi en familie bruger på tøjvask. PSO-projekt nr. 337-009. Slutrapport. [What 
influence does the washing habits have on the amount of energy a family uses on laundry 
washing. PSO-project No. 337-009. Final report]. December 2005. 
(http://www.elforsk.dk/doks/337-009/slutrapport_337-009.pdf) 
 
 
EU RAR 2004: European Union Risk Assessment Report. Tetrasodium 
Ethylenediaminetetraacetate (NA4EDTA) CAS No: 64-02-8, EINECS No: 200-573-9. 
Volume 51. 
 
HERA 2003 & 2004: Human and environmental risk assessment of Fluorescent 
Brightener FWA-1 (draft) and Fluorescent Brightener FWA-5 (draft). 
www.heraproject.com  
 
HERA 2004 & 2005: Human and environmental risk assessment of Zeolite A (final) and 
Zeolite  P & -X (draft). www.heraproject.com  
 
IARC 1999: IARC Monographs on the evaluation of carcinogenic risks to humans. 
Volume 73. WHO International Agency for Reseach on Cancer. Lyon, France 1999. 
 
INIA 2009: Development of an European quantitative eutrophication risk assessment of 
polyphosphates in detergents. Green Planet Research Report GPR-CEEP-09-1- Final, 
April 2009. 
http://ec.europa.eu/enterprise/sectors/chemicals/files/docs/ceep_study_final_report_0420
09_en.pdf 
 
JohnsonDiversey 2008: Answer to questionnaire send out be Ecolabelling Denmark 
 
Nanogist Co. 2009: Nanogist Co., Ltd. Korean Company marketing e.g. laundry 
detergents with antimicrobial properties. http://www.alibaba.com/product/nanogist-
100647666-101251773/Nano_Silver_Laundry_Detergent.html 
 
Nielsen and Skagerlind 2007: Per H. Nielsen and Peter Skagerlind: Sustainable 
Innovation. Cost-neutral replacement of surfactants with enzymes – a shortcut to 
environmental improvement for laundry washing. Household and Personal Care Today. 
No. 4/2007. 
 
Nordic Ecolabelling 2008: Data from Ecolabelling Norway and personal communication 
with national trade organisations: Teknokemiske föreningen Finland 2008 and KEMI 2006 
 
Research and Markets 2009: Frost and Sullivan: Global Methyl Ester Sulphonate Market. 
(Only abstract available).http://www.researchandmarkets.com/reports/835631 
 
RPA 2006: Non-surfactant Organic Ingredients and Zeolite-based Detergents. Final 
Report prepared for the European Commission. Risk & Policy Analysts Limited (RPA) 
June 2006. 
 
RSPO (2009): http://www.rspo.org/ 
 
Satsuki 1994: Teruhisa Satsuki: Methyl Ester Sulfonates: A Surfactant based on Natural 
Fats. In Proceedings of the 3rd World Conference on Detergents: Global Perspectives. 
AOCS Press 1994.

Page 41 
 
SCHENIHR 2006: Opinion on The appropriateness of existing methodologies to assess 
the potential risks associated with engineered and adventitious products of 
nanotechnologies. 
 
SCHER 2005: Scientific Committee on health and environmental risks. Opinion on 
“Environmental Risk Assessment of non Biodegradable Detergent Surfactants under 
Anaerobic Condition” Adopted by the SCHER during the 8th plenary meeting of 25 
November 2005. 
 
SCHER 2007: Scientific Committee on Health and Environmental Risks 
(SCHER). Non surfactant Organic Ingredients and Zeolite-based Detergents 
Adopted on 29 May 2007. 
 
The Project on Emerging Nanotechnologies: Consumer products. An inventory of 
nanotechnology-based consumer products currently on the market. 
http://www.nanotechproject.org/inventories/consumer/ 
 
Umweltsbundesamt 2008: http://www.umweltbundesamt.de/uba-info-presse-
e/2008/pe08-033.htm 
 
UEAPME 2008: Answer to questionnaire send out be Ecolabelling Denmark 
 
WWF (2009):  
http://www.panda.org/about_our_earth/about_forests/deforestation/ 
http://www.panda.org/what_we_do/footprint/forestry/

Page 42 
APPENDIX 1: KEY ISSUES FOR THE REVISION - SUMMARY 
 
Key issues as presented in the preliminary report:  
 
(Revision of Ecolabel Criteria for Laundry Detergents & Dishwashing Detergents. 
Preliminary report. June 2008. Ecolabelling Denmark, DHI Water, Environment, Health) 
 
 
• 
Clarification on scope of the criteria 
• 
Incorporation of the current DID list and DID list parameters in the criteria 
• 
Reducing the environmental impact through strengthening of values for CDV, total 
chemicals, phosphates, promotion of compact/super compact products 
• 
Lowering the climate impact though promotion of low-temperature products 
(requirements in favour of these) 
• 
Requirements to vPvB substances 
• 
Possibility for promotion of easy-to dose products  
• 
Restrictions in content of organics that are not readily/anaerobically biodegradable 
and stricter limitations for use of phosphates 
• 
Restriction on use of preservatives  
• 
Clarification of performance requirements, the need for revision/optimisation of the 
test should be evaluated  
• 
Possible expansion of product group with fabric softeners and stain removers in 
order to gain environmental benefits from all products used in the washing 
process (if environmental benefits can be identified)  
• 
Enhancement of consumer information regarding dosing and washing means

Page 43 
Key issues as suggested during the previous revision (2002):

Page 44 
APPENDIX 2: MAIN ENVIRONMENTAL IMPACTS OF LAUNDRY 
DETERGENTS (IN BRIEF) 
 
The main environmental impacts related to the use of laundry detergents are related to 
the energy used for heating of the washing water in the use phase, the extraction and 
processing of raw materials and the emission of chemicals to the environment after use. 
Other environmental impacts relate to the production and transportation of raw materials 
and the final products, and disposal of solid waste. Primary contributors to solid wastes 
are ashes from energy generation in the use phase, sludge from waste water treatment, 
and waste from the ingredient supply stage (AISE 2001). In addition, laundry detergents 
(and auxiliary washing products) may give rise to health related problems such as allergy 
and skin irritation. 
 
Life-cycle analyses (LCA’s) for laundry detergents clearly show that the use phase and 
the product formulation are the largest contributors to most of the environmental impacts 
deriving from laundering. This has been concluded in LCA’s where a range of 
environmental indicators have been considered, namely: primary energy consumption, 
total solid waste, water consumption, potential impacts on aquatic eco-toxicity, 
eutrophication, acidification, human toxicity, photochemical oxidant formation, depletion 
of the ozone layer and climate change (AISE 2001, Procter & Gamble, Van Hoof et al 
2003).  
 
This indicates that the environmental impact of laundry detergents can be influenced by 
lowering the washing temperature (use phase), optimising the chemical composition of 
the laundry detergents and increasing the level of compaction. Large energy savings can 
be obtained by using super compact detergents in preference of regular powders. The 
environmental burden may be decreased by up to 50% with the use of super compact 
products compared to regular powders. With super compact products, efficient chemistry 
means less detergent per wash and good performance at lower temperatures. Lowered 
washing temperatures and lower consumption of detergents (incl. packaging) will cause 
decreased CO2 emissions and reductions in solid waste. With respect to the contributions 
to the aquatic toxicity, the major contributions from detergent ingredients arise from 
surfactants and fragrances. This underlines the relevance of having requirements 
addressing these substances in the ecolabel criteria. 
 
The environmental impacts of laundry detergents are illustrated by the below LCA figure 
showing the relative environmental contributions from the different phases of the lifecycle 
of a generic laundry detergent, divided into the categories of energy consumption, water 
emissions and solid waste.

Page 45 
 
 
Fig 1: Life-Cycle Analysis of a Generic European Fabric Washing Powder. (AISE 2008) 
 
 
The figure clearly shows that the energy consumption in a cradle to grave perspective 
primarily is connected to the use phase, followed by the processing of raw-materials. 
Water emissions are dominant in the disposal phase while solid waste is produced mainly 
in the use phase (ashes from energy generation).  
 
In a comparative life-cycle assessment of laundry detergent formulations in the UK, the 
relative contribution to primary energy was calculated for different kinds of formulations, 
including powders, liquids and tablets. The result of the LCA showed, that the use phase 
(washing process) is the key contributor (>70% of the total contribution) for most of the 
environmental indicators analysed. Furthermore, the study concluded that compact 
formulations (powder and liquids) are environmentally preferable, mainly because of the 
lower use of chemicals per wash (Van Hoof et al 2003).

Page 46 
 
 
Fig 2: Contribution from the various life-cycle stages to primary energy for year 2001 UK laundry 
formulations (Van Hoof et al 2003) 
 
 
It should be kept in mind that energy consumption during use and the environmental 
impact of the ingredients used are incomparable parameters. Thus – a product that 
performs well at low temperatures may still have a large impact on the aquatic 
environment (depending on the level of sewage treatment etc.). Keeping focus on the 
ecotoxicological properties and biodegradability of the ingredients should thus still have a 
high focus in the ecolabel criteria. 
 
 
References:  
AISE 2001: The Life-cycle Assessment of European Clothes Laundering. Report 2: LCA 
of Compact Fabric Washing Powder & main wash process. AISE LCA taskforce. 
 
Procter & Gamble: Cutting Environmental Effect by half: Compact detergents can do it! 
Part I: The LCA Approach. www.scienceinthebox.com 
 
Procter & Gamble: An evaluation of the environmental profile of laundry detergents for 
washing at low wash temperatures. 
http://www.scienceinthebox.com/en_UK/pdf/Ariel%20Cold%20Wash%20Low%20Temper
ature%20Energy%20Savings%20Sustainability.pdf) 
 
Van Hoof, G; Schowanek, D and Feijtel, T.C.J 2003: Comparative Life-Cycle Assessment 
of Laundry Detergent formulations in the UK. Part 1: Environmental fingerprint of five 
detergent formulations in 2001. Tensidde Surf. Det. 40, pp 266-275, 2003. 
 
 
RP: Regular powder 
CP: Compact powder 
PT: Powder tablet 
CL: Compact liquid 
LT: Liquid unit-dose

Page 47 
APPENDIX 3: TYPICAL INGREDIENTS IN LAUNDRY 
DETERGENTS 
Composition of laundry detergents  
 
Laundry detergents are composed of a range of ingredients that give the final product its 
different characteristics. The most common ingredients are listed alphabetically below 
(not all of them are necessarily present in a given product). 
 
 
Anti-redeposition agents 
Anti-redeposition agents are added to prevent the dirt that is removed from the clothing 
from reattaching itself. Accordingly they also prevent the clothing from taking on a greyish 
color. Commonly occurring anti-redeposition agents in laundry detergents are CMC 
(carboxymethyl cellulose), CEC (carboxyethyl cellulose), starch-based compounds or 
other polymers.  
 
Bleaching agents 
Bleaching agents are added to remove or decolorize (whiten or lighten) a type of stain 
that is not removed by the surfactants, i.e. colored stains such as red wine or tea. 
Bleaching agents work by cutting the stain molecule into smaller pieces that are more 
easily dissolved and removed. Alternatively, bleaching agents may work by removing the 
color of the stain so it becomes invisible. These two processes may work simultaneously 
on a given stain. Bleaching agents used in laundry detergents include borate, perborate, 
percarbonates, hydrogen peroxide and sodium hypochlorite.  
 
Buffering agents 
Buffering agents work by upgrading or protecting the cleaning efficiency of the surfactant. 
As washing proceeds, the alkalinity or pH drops. Under acidic (low pH) conditions, 
cleaning is reduced. Buffering agents stabilize the pH, and keep this drop from being too 
severe and reducing the cleaning. 
 
Builders/sequestering agents 
Builders/sequestering agents are primarily added to bind calcium in the water and in the 
soils on the clothing. The binding of calcium allows the surfactants better access to clean 
the clothes, as the soil molecules are often bound to the fabric by calcium ion bridging. 
The binding of calcium also prevents the ions to react with other detergent ingredients 
and precipitate from the solution. Builders are thus a very important ingredient in laundry 
detergents in areas in which hard water is used for washing. The builders used in laundry 
detergents include e.g. phosphate, phosphonate, zeolite, silicates, carbonate and citrate. 
Often more builders are used in one product, creating a builder system. There is wide 
variation in the builders used in the European countries. One reason for this is the 
difference in the number of households connected to treatment plants and whether the 
treatment plants are capable of removing builders from the water. Another reason is the 
difference in water hardness in different regions.  
 
Colorants 
Coloring agents are added to laundry detergents for aesthetic reasons and/or to aid the 
marketing of the products. Coloring agents have no effect on the ability of the product to 
clean clothes.  
 
Corrosion-inhibiting substances  
Corrosion-inhibiting substances protect the washing machine against corrosion. Silicates 
are the most commonly used, and they also function as stabilisers for perborates (see 
bleaching agents).

Page 48 
 
Dye-transfer inhibitors (DTIs) 
A DTI is a substance that prevents the transfer of dyes from one textile to another during 
the wash. DTI’s are either polymers or copolymers; the most commonly used DTI is PVP 
(Polyvinylpyrrolidon).  
 
Enzymes 
Enzymes are proteins that are used in laundry detergents to break down particularly 
difficult stains. Enzymes also help to improve wash results at low temperatures. Enzymes 
function by breaking down difficult stains into smaller parts which can then be more 
readily removed. The enzymes do not lose the functionality after use on a given stain. 
Enzymes used in laundry detergents and stain removers include protease, lipase and 
amylase. Each enzyme has its own defined target, i.e. fat stains, protein stains etc. 
Enzymes can replace large quantities of chemicals with the same function. 
 
Fabrics whitening agents (optical brighteners) 
Fabrics whitening agents or optical brighteners are fluorescent whitening agents that 
reflect the ultra-violet rays of the sun as white, visible light. This gives the clothing an 
impression of whiteness and accordingly cleanness. Optical brighteners are frequently 
already present in clothing, and the quantity left by the washing process helps to give an 
impression of cleanness. Optical brighteners/fabric whiteners do not bleach or remove 
color from the textile. 
 
Fillers 
Fillers are added to laundry detergents to give the product structure. In powder products 
sodium sulphate is often used as filler - in liquid products the filler is water.  
 
Fragrances (perfume) 
Fragrances are added to give the product a particular smell or to conceal an unpleasant 
smell in the raw materials used in the products. Fragrance has no effect on the ability of 
the product to clean the clothes. Fragrance is a mixture of many different aromatics. 
Commonly little information is available on the environmental effects of fragrance, but 
generally fragrances are regarded as environmentally harmful. Allergies to fragrances are 
common.  
 
Hydrotropes 
Hydrotropes help increase the solubility of other ingredients in liquid products.  
 
Preservatives 
Preservatives are frequently added to liquid products to prevent the growth of bacteria in 
the product and thereby extend its durability. Surfactants sometimes have a preservative 
effect.  
 
Soap 
Soap is used for cleaning the fabric by reducing surface tension and loosening, 
dispersing, and suspending the soil. Soap also softens fabrics naturally. Soap may also 
be used as a suds inhibitor. 
 
Solvents 
Organic solvents are primarily used in liquid products to dissolve the ingredients. Typical 
solvents are alcohols. Alcohols also add an anti-freeze property so that the detergent 
may be shipped and stored in cold climates.

Page 49 
Suds inhibitors 
Suds inhibitors are added to reduce the quantity of suds (foam) in the washing machine. 
Suds inhibitors in laundry detergents include silicone or surfactants with this particular 
property.  
 
Surfactants 
Surfactants are added for a number of reasons, the main purposes being their washing 
and surface active properties. They remove soils from the clothing and keep it suspended 
in the washing solution. Some surfactants perform other functions such as foam 
inhibition. Examples of surfactants used in laundry detergents include alkylether 
sulphates, alkyl sulphates, alcohol ethoxylates and alkylphenol ethoxylates.