Revision of European Ecolabel Criteria for 
Hand Dishwashing Detergents
PRELIMINARY REPORT
 
for 
 
THE REVISION OF ECOLOGICAL CRITERIA FOR HAND 
DISHWASHING DETERGENTS 
 
1) Introduction 
2) Scope and definition 
3) Market analysis 
4) Technical/Environmental analysis 
5) Product innovations and improvement 
potential
Authors: Josephine Arendorf, Katherine Bojczuk, 
Dan Skinner, Laura Golsteijn, Anne Gaasbeek, 
Alicia Boyano, Galyna Medyna, Renata Kaps 
October 2014

2
 
 
Development of European Ecolabel  
Criteria for Hand Dishwashing Detergents 
 
 
 
 
 
 
 
Preliminary Report 
 
Working Document 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Authors: Josephine Arendorf, Katherine Bojczuk, Dan Skinner, Laura Golsteijn, 
Anne Gaasbeek, Alicia Boyano, Galyna Medyna, Renata Kaps 
 
 
 
 
DG JRC (IPTS) October 2014

3
 
 
 
 
 
 
 
 
 
 
 
DISCLAIMER 
The views, recommendations and proposals expressed in this report are those of the authors’ and do not 
necessarily reflect the opinion of the JRC IPTS or the European Commission. Recommendations made in this 
report should not be taken as a political or legal signal that IPTS or the European Commission intends to take a 
given action.

4
 
ABBREVIATIONS AND ACRONYMS 
AISE 
 
International Association for Soaps, Detergents and Maintenance Products 
AE 
 
ethoxylated alcohol 
aNBO 
 
aerobically non-biodegradable 
anNBO  
anaerobically non-biodegradable 
APD 
 
alkyl phenol derivative 
APEO 
 
alkylphenol ethoxylate 
ASP 
 
Advanced Sustainability Profile 
BCF 
 
bioconcentration factor 
BPD 
 
Biocidal Products Directive (98/8/EC) 
BPR 
 
BIocidal Products Regulation, Regulation (EU) 528/2012) 
BRIC 
 
Brazil, Russia, India and China 
CADD 
 
consumer automatic dishwasher detergents 
CAGR 
 
compound annual growth rate 
CDV 
 
critical dilution volume 
CFC 
 
chlorofluorocarbon 
CLP 
 
(EU Regulation on the) Classification, Labelling and Packaging of Substances and Mixtures 
COMEXT  
statistical database on trade of goods managed by Eurostat 
DADMAC 
diallyldimethylammonium chloride 
DD 
 
dishwasher detergents 
DID list  
Detergents Ingredient Database 
DTPA 
 
diethylene triamine pentaacetic acid 
EC 
 
European Commission  
EC50 
 
median effective concentration 
ECHA 
 
European Chemicals Agency 
EDTA 
 
ethylenediaminetetraacetic acid 
EEA 
 
European Economic Area 
EU 
 
European Union 
GDP 
 
gross domestic product 
GHG 
 
greenhouse gas 
GHS 
 
Globally Harmonized System of Classification and Labelling of Chemicals 
GLDA 
 
glutamic acid diacetic acid 
GPP 
 
Green Public Procurement 
I&I 
 
industrial and institutional 
IC50 
 
median inhibition concentration 
IIDD  
 
industrial and institutional dishwasher detergents 
IFRA 
 
International Fragrance Association 
IKW 
 
Industrieverband Körperpflege- und Waschmittel e. V. 
ISO 
 
International Organisation for Standards 
KOW 
 
octanol-water partition coefficient 
LAS  
 
linear alkylbenzene sulphonate 
LCA 
 
life cycle assessment 
LCIA 
 
life cycle impact assessment 
LC50 
 
median lethal dose 
LHC 
 
Liquid household cleaner 
MGDA  
methylglycinediacetic acid 
NACE 
 
Nomenclature des Activités Économiques dans la Communauté Européenne

5
n.e.c. 
 
not elsewhere classified 
NLT 
 
natural land transformation 
n.p.r.s 
 
not packaged for retail sale 
NTA 
 
nitrilotriacetic acid 
PBT 
 
persistent, bio-accumulable and toxic 
PET 
 
polyethylene terephthalate 
ppm 
 
parts per million 
PRODCOM 
PRODuction COMmunautaire (Community Production) 
p.r.s 
 
Packaged for retail sale 
PVC 
 
polyvinyl chloride 
REACH  
Registration, Evaluation, Authorisation and restriction of CHemicals 
SVHC 
 
substances of very high concern 
TAED 
 
tetraacetylethylenediamine 
vPvB 
 
very persistent and very bio-accumulable 
WUR 
 
weight/utility ratio

6
TERMS AND DEFINITIONS 
Domestic hand 
dishwashing 
detergents 
In this report, denotes hand dishwashing detergent products which are intended for use 
principally in households.  
Professional,  
institutional or 
industrial hand 
dishwashing 
detergent 
In this report, denotes hand dishwashing detergent products with are intended for use 
solely by professional users in the industrial and institutional sector.  
‘Industrial and institutional detergent’ means a detergent for washing and cleaning outside 
the domestic sphere, carried out by specialised personnel using specific products. 
Cleaning 
According to EN ISO 862 Surface active agents – Vocabulary, a process in which dirt (stains) 
are removed from their substratum and put into solution or into dispersion.1  
According to AS/NZ 4187, the removal of soil and a reduction in the number of 
microorganisms from a surface, by a process such as washing with detergent solution 
without prior processing. 
Detergents 
Any substance or preparation containing soaps and/or other surfactants intended for 
washing and cleaning processes. Detergents may be in any form (liquid, powder, paste, 
bar, cake, moulded piece, shape, etc.) and marketed for or used in households, or for 
institutional or industrial purposes. 
Bio-accumulative 
The tendency for a substance to be accumulated in an organism due to difference in the 
rate of intake and loss of the substance from the organism. 
Biocide 
Chemical substance or microorganism which can deter, render harmless, or exert a 
controlling effect on any harmful organism by chemical or biological means.2  
Biocidal products 
Active substances and preparations containing one or more active substances, put up in 
the form in which they are supplied to the user, intended to destroy, render harmless, 
prevent the action of, or otherwise exert a controlling effect on any harmful organism by 
chemical or biological means.2 
Enzymes 
Proteins that speed up the rate of chemical reactions without interacting in the reactions 
themselves. 
ISO 14024  Type I 
Environmental 
label 
A voluntary multicriteria-based, third party program that awards a license that authorises 
the use of environmental labels on products indicating overall environmental preferability 
of a product within a particular product category based on life cycle considerations. 
EU Ecolabel 
The ISO 14024 Type I environmental label from the European Union that is valid 
throughout Europe. 
Surfactant 
Any organic substance and/or preparation used in detergents, which has surface-active 
properties and which consists of one or more hydrophilic and one or more hydrophobic 
groups of such a nature and size that it is capable of reducing the surface tension of water, 
and of forming spreading or adsorption monolayers at the water air interface, and of 
forming emulsions and/or microemulsions and/or micelles, and of adsorption at water-
solid interfaces. 
Standard 
A document established by consensus and approved by a recognised body that provides, 
for common and repeated use, rules, guidelines or characteristics for activities or their 
results, aimed at the achievement of the optimum degree of order in a given context. 
                                                             
 
1 In the everyday sense, the effect of detergence is the cleaning of surfaces. It is the result of setting in motion many different physical-
chemical phenomena. The dirt or stains are undesirable additions on the surface and/or inside the substratum 
2 Based on Regulation (EC) No 528/2012of the European parliament and of the council of 22 May 2012 concerning the making available on 
the market and use of biocidal products (L 167/1 OJEU 27.8.2012) Available from: 
http://ec.europa.eu/environment/chemicals/biocides/index_en.htm.

7
TABLE OF CONTENTS 
1. 
INTRODUCTION.................................................................................................................11 
1.1 
Background................................................................................................................................. 11 
1.2 
Purpose of this document .......................................................................................................... 11 
1.3 
EU Ecolabel for hand dishwashing detergents ........................................................................... 11 
1.4 
Investigation overview................................................................................................................ 11 
2. 
LEGAL REVIEW, SCOPE AND DEFINITION............................................................................13 
2.1 
Introduction................................................................................................................................ 13 
2.2 
Scope and definition................................................................................................................... 13 
2.2.1 
Product definition............................................................................................................................ 13 
2.2.2 
Current EU Ecolabel product scope and definition........................................................................... 13 
2.3 
Feedback from stakeholder consultation................................................................................... 14 
2.3.1 
Summary of stakeholder recommendations for revision of existing criteria ................................... 22 
2.4 
Review of legislation – key changes since the 2011 revision...................................................... 23 
2.4.1 
Regulation EC/66/2010 (the EU Ecolabel Regulation)..................................................................... 23 
2.4.2 
Regulation (EU) No 259/2012 (the Detergents Regulation) ............................................................ 23 
2.4.3 
Regulation (EU) No 528/2012 (the Biocidal Product Regulation) .................................................... 24 
2.4.4 
Regulation (EC) No 1272/2008 (The CLP Regulation) ...................................................................... 24 
2.5 
Review of national Ecolabels ...................................................................................................... 25 
2.6 
Proposed scope and definition................................................................................................... 44 
3. 
MARKET ANALYSIS ............................................................................................................45 
3.1 
Introduction................................................................................................................................ 45 
3.1.1 
Economic indicators......................................................................................................................... 45 
3.2 
Market structure......................................................................................................................... 50 
3.2.1 
Global overview, market size........................................................................................................... 50 
3.2.2 
EU overview, market size................................................................................................................. 50 
3.2.3 
EU market structure, national level................................................................................................. 50 
3.2.4 
Manufacturers and market share.................................................................................................... 51 
3.2.5 
Supply chain and raw materials ...................................................................................................... 53 
3.3 
Trends and innovations .............................................................................................................. 55 
3.3.1 
Market trends.................................................................................................................................. 55 
3.3.2 
Sustainable cleaning product innovations....................................................................................... 59 
3.3.3 
Eco-labelling .................................................................................................................................... 61 
3.3.4 
Consumer trends and market innovations....................................................................................... 63 
3.4 
Summary..................................................................................................................................... 65 
4. 
TECHNICAL ANALYSIS ........................................................................................................67 
4.1 
Technological aspects................................................................................................................. 67 
4.1.1 
Supply chain for HDD production..................................................................................................... 67 
4.1.2 
Description of the HDD production processes.................................................................................. 68 
4.1.3 
HDD detergents ingredients ............................................................................................................ 68 
4.1.4 
User behaviour ................................................................................................................................ 68 
4.2 
LCA review .................................................................................................................................. 69 
4.2.1 
Selection criteria.............................................................................................................................. 69 
4.2.2 
Detailed revision and quality assessment of available studies ........................................................ 70 
4.2.3 
LCA review: results........................................................................................................................... 73 
4.2.4 
Summary of the findings / Summary of the key environmental impacts for hand dishwasher 
detergents .................................................................................................................................................... 76 
4.3 
Non-LCA impacts......................................................................................................................... 77 
4.3.1 
Toxicity to aquatic organisms.......................................................................................................... 77 
4.3.2 
Risk assessment of chemical release ............................................................................................... 79 
4.3.3 
Sustainable sourcing........................................................................................................................ 79 
4.4 
In-house LCA studies................................................................................................................... 79 
4.4.1 
Methodology ................................................................................................................................... 79 
4.4.2 
Goal definition................................................................................................................................. 80 
4.4.3 
Scope of the study ........................................................................................................................... 80 
4.4.4 
Functional unit and reference flow.................................................................................................. 80 
4.4.5 
System description and boundaries................................................................................................. 81 
4.5 
Life cycle inventory..................................................................................................................... 81

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4.5.1 
Raw materials and ingredients manufacturing ............................................................................... 82 
4.5.2 
Manufacturing................................................................................................................................. 83 
4.5.3 
Packaging ........................................................................................................................................ 84 
4.5.4 
Transport/distribution ..................................................................................................................... 84 
4.5.5 
Use................................................................................................................................................... 84 
4.5.6 
Disposal ........................................................................................................................................... 85 
4.5.7 
Data quality..................................................................................................................................... 85 
4.5.8 
Life cycle impact assessment........................................................................................................... 85 
4.6 
Sensitivity analysis ...................................................................................................................... 88 
4.6.1 
Full sink versus direct application.................................................................................................... 88 
4.6.2 
Amount of warm water ................................................................................................................... 89 
4.6.3 
Temperature of the water ............................................................................................................... 89 
4.6.4 
Surfactant origin.............................................................................................................................. 90 
4.6.5 
Product dosage................................................................................................................................ 91 
4.6.6 
Electricity mix .................................................................................................................................. 91 
4.6.7 
Impact method ................................................................................................................................ 92 
4.6.1 
Sensitivity of the surfactant to the database................................................................................... 94 
4.7 
Summary of findings................................................................................................................... 96 
5. 
PRODUCT INNOVATIONS AND IMPROVEMENT POTENTIAL ...............................................97 
5.1 
Introduction and approach......................................................................................................... 97 
5.2 
HDD product innovations ........................................................................................................... 97 
5.2.1 
Compaction ..................................................................................................................................... 97 
5.2.2 
Natural/renewable ingredients ....................................................................................................... 97 
6. 
Conclusions.......................................................................................................................98 
ANNEXES.....................................................................................................................................101 
Annex I: Hand dishwashing detergent ingredients.............................................................................. 101 
Annex II: Stakeholder survey ............................................................................................................... 102 
Annex III: Life cycle impact assessment............................................................................................... 116 
Annex IV: Contribution analysis of different life cycle stages.............................................................. 117 
Annex V: Sensitivity analysis ................................................................................................................ 118 
Annex VI: Place settings....................................................................................................................... 122 
Annex VII: Detailed feedback from the stakeholders to the first questionnaire ................................. 123 
Annex VIII: Detergents production process and chemistry involved................................................... 131

9
LIST OF TABLES AND FIGURES 
Table 1: Summary of respondents to questionnaire.....................................................................................14 
Table 2: Summary of responses to the stakeholder questionnaire ..............................................................15 
Table 3: Summary of the comments received from stakeholders in response to the questionnaire...........18 
Table 4: Summary of suggest changes for HDD ............................................................................................22 
Table 5: Alternative voluntary labelling schemes .........................................................................................25 
Table 6: Product group definitions and scope from alternative voluntary labelling schemes......................28 
Table 7: Overview of the requirements of different ecolabels for HDDs for household use........................31 
Table 8: Comparison of excluded substances ...............................................................................................43 
Table 9: PRODCOM cleaning product categories, code and description ......................................................45 
Table 10: Comparison of the categorisation criteria for PRODCOM and EU Ecolabel for HDD....................46 
Table 11: Production of manufactured cleaning products in EU-28, value and tonnes, 2013 .....................46 
Table 12: COMEXT detergent code and description .....................................................................................47 
Table 13: Intra-EU trade of cleaning products, import and exports, 2013 ...................................................47 
Table 14: Extra-EU trade of cleaning products, imports and exports, 2013 .................................................48 
Table 15: Summary of intra- and extra-EU trade ..........................................................................................49 
Table 16: Market value of dishwashing detergents (EU-27 + CH + NO), 2012..............................................50 
Table 17: Largest manufacturers in European* DD** market, % breakdown by retail value, 2013 ............51 
Table 18: Dishwashing detergents*, top 10 brands (brand share, %), Europe**, 2013...............................52 
Table 19: Expected growth in the I&I market for kitchen and catering detergents (€ m), 2013–16 estimate
.......................................................................................................................................................................53 
Table 20: Western Europe, distribution channels by value (%), 2009 ..........................................................53 
Table 21: Total home and fabric care speciality ingredients market53: % of revenues by chemical type, 
Europe, 2008 .................................................................................................................................................54 
Table 22: Home and fabric care speciality ingredients market53: impact of top eight industry challenges 
ranked in order of impact, Europe................................................................................................................54 
Table 23: Percentage change in the EU market (sales value) for HDDs........................................................56 
Table 24: Share of items being washed up manually (%)..............................................................................58 
Table 25: EU Ecolabel HDD products manufactured and sold, by country (EU-28 + Norway)......................61 
Table 26: EU Ecolabel HDD products on the European market (EU-28) .......................................................62 
Table 27: Number of Nordic Swan labelled HDDs on the EU-28 market ......................................................62 
Table 28: Publicly available LCAs on dishwashing detergents ......................................................................70 
Table 29: Evaluation of comprehensiveness based on the PEF methodology..............................................72 
Table 30: Summary of study by Van Hoof et al.............................................................................................73 
Table 31: Summary of study by Van Hoof et al.............................................................................................75 
Table 32: Summary of study by ASP..............................................................................................................76 
Table 35: Toxicity values and degradation data for example detergent ingredients in the DID-list ............78 
Table 34: Key assumptions............................................................................................................................82 
Table 35: General formula of liquid HDD, .....................................................................................................83 
Table 36: Ecoinvent data inventory for a HDD frame formula......................................................................83 
Table 37: Primary & secondary packaging for a HDD....................................................................................84 
Table 38: Aggregate midpoint results for an HDD ........................................................................................86 
Table 39: Assumptions ‘full sink’ vs ‘direct application’................................................................................88 
Table 40: Overall summary of the key environmental considerations linked to the Ecolabel criteria.........96 
Table 41: Outcomes of sensitivity analysis and actions in Ecolabel criteria .................................................99 
Table 42: Life cycle impact contribution of an HDD....................................................................................117 
Table 43: Life cycle impact contribution of a HDD (in percentages)...........................................................117 
Table 44: Impact contribution of the ‘full sink’ versus ‘direct application’ scenario ..................................118 
Table 45: sensitivity to the amount of heated water..................................................................................118 
Table 46: Impact contribution of surfactant origin.....................................................................................119 
Table 47: Impact contribution of the product dosage sensitivity ...............................................................119 
Table 48: Impact contribution of energy source sensitivity........................................................................120 
Table 49: Life cycle impact contribution of an APC, according to ILCD midpoint.......................................120 
Table 50: the ingredients of detergent base powder..................................................................................132

10
Table 51: typical post dosing ingredients....................................................................................................132 
 
Figure 1: Sales value (€ m) of HDDs in six European countries, 2013...........................................................51 
Figure 2: Actual and projected total retail value (€ m) of dishwashing detergents* in Europe**, 2008-18 55 
Figure 3: Actual and projected sales value (€ m) for countries with top five market share in dishwashing 
detergent value across Europe, 2008-18 ......................................................................................................56 
Figure 4: Market value and % share of all household dishwashing detergents, Europe, 2012 ....................57 
Figure 5: Total actual and projected sales (€ m) of dishwasher detergents, 2007-16, (FR,PL,IT,UK,DE,DK) 57 
Figure 6: Dishwasher possession rates (%), EU-28, 2013..............................................................................58 
Figure 7: Ecover’s Share Increase (% of total household care) in the UK 2004-08 .......................................59 
Figure 8: Supply chain for home and fabric care products ...........................................................................67 
Figure 9: Steps of a life cycle assessment, according to UNE-EN ISO 14040: 2006 ......................................79 
Figure 10: Schematic representation of the life cycle of a HDD. ...................................................................80 
Figure 11: Inventory inputs and outputs.......................................................................................................82 
Figure 12: Impact contribution of different life cycle stages of a HDD (See abbreviations in Table 38) ......86 
Figure 13: Normalised endpoint results for an HDD (see abbreviations in Table 38)...................................87 
Figure 14: Sensitivity full sink versus direct application (see abbreviations in Table 38) .............................88 
Figure 15: sensitivity to amount of water (See abbreviations in Table 34) ..................................................89 
Figure 16: Sensitivity to temperature of water (See abbreviations in Table 38) ..........................................90 
Figure 17: Sensitivity to formulation (See abbreviations in Table 38) ..........................................................90 
Figure 18: Sensitivity dose HDD (see abbreviations in Table 38)..................................................................91 
Figure 19: Sensitivity to electricity mix (See abbreviations in Table 38).......................................................92 
Figure 20: Impact contribution of different life cycle stages of HDD according to the ILCD method...........93 
Figure 21: Comparison between the environmental impact at endpoint of 1 kg of ethoxylated alcohols 
from coconut oil in Ecoinvent and in Agri-Footprint.....................................................................................94 
Figure 22: Comparison between the environmental impact at endpoint level of 1 kg of ethoxylated 
alcohols from palm kernel oil in Ecoinvent and in Agri-Footprint ................................................................95 
Figure 23: Relationship between LCI parameters (left), midpoint (middle) and endpoint indicator (right) in 
ReCiPe 2009.................................................................................................................................................116

11
1. INTRODUCTION 
1.1 Background 
The EU Ecolabel is a policy instrument designed to encourage the production and consumption of more 
environmentally friendly products and services through the certification and specification of products or 
services which have a reduced environmental footprint. They form part of the European Commission’s action 
plan on Sustainable Consumption and Production and Sustainable Industrial Policy adopted on 16 July 2008.  
 
The EU Ecolabel is a voluntary scheme coordinated by the European Commission3 which is used to distinguish 
environmentally beneficial products and services. The EU Ecolabel is awarded to a product through a process in 
which an applicant has to demonstrate that the specified Ecolabel criteria for a particular product group are 
met. The successful applicant is then allowed to use the EU Ecolabel logo and advertise the product as having 
been awarded the EU Ecolabel.  
 
 
1.2 Purpose of this document 
This document forms part of the stages of revising the criteria for EU Ecolabel for hand dishwashing detergents. 
It encapsulates the activities and outputs of Tasks 1-4 (Definition and scope, Market analysis, Technical analysis 
and Product innovations and opportunities for improvement). This report represents a first evaluation of likely 
areas for investigation as a result of stakeholder surveys, market analysis, review of life cycle assessment (LCA) 
studies and known concerns with existing criteria including changes in hazardous substance classification of 
commonly used ingredients. It identifies where there is scope for strengthening the EU Ecolabel and which 
criteria should be removed, amended or further developed.  
 
The information contained in this document provides an overview of changes to the hand dishwashing 
detergents market since the last revision of the criteria in 2011, and a technical analysis to understand where 
the greatest environmental impacts arise in their life cycle.  
 
This report is also being used as a consultation document to gain feedback, evidence and opinion from 
stakeholders and experts on proposed changes and significant environmental issues.  
 
 
1.3 EU Ecolabel for hand dishwashing detergents 
The EU Ecolabel criteria for ‘hand dishwashing detergents’ (HDDs) were adopted in 2011 (Commission Decision 
2011/382/EU).4 The aim of these criteria was to promote HDDs that correspond to the top 10-20 % of 
environmental performing products available on the Community market considering the whole life cycle of 
production, use and disposal. These criteria are due to expire in 2016. A breakdown of the number of Ecolabel 
products for the HDD category can be found in the market analysis section of this report. 
 
 
1.4 Investigation overview 
The revision process takes the existing criteria document as the starting point and seeks to update these, taking 
into account technological and economic changes in the European market, relevant legislative change and 
improved scientific knowledge.  
                                                             
 
3 Regulation (EC) No 66/2010 of the European Parliament and the council of 25 November 2009 on the EU Ecolabel (L 27/1 OJEU 
30.1.2010) 
4 Commission Decision (2011/382/EU) of 24 June 2011  on establishing the ecological criteria for the award of the EU Ecolabel to hand 
dishwashing detergents  (C(2011) 4448) (L 169/40 OJEU 29.6.2011)

12
 
To review the existing EU Ecolabel, the following aspects have been investigated: 
1) Product definition and categorisation, relevant legislation.  
2) Economic and market analysis. 
3) Technical analysis including environmental performance investigation.  
4) Product innovations and improvement opportunities for hand dishwasher detergents.

13
 
2. LEGAL REVIEW, SCOPE AND DEFINITION 
2.1 Introduction 
The aim of the first task is to conduct a review of the practicality of the existing product group definition and 
scope. The areas where the existing criteria and scope are no longer in line with current legislation or 
alternative voluntary labelling schemes will be identified. The review will consider feedback from stakeholders, 
literature reviews, legal reviews and alternative ecolabels. The first task has been divided into the following 
sub-tasks: 
1. An introduction to the existing product scope and definition 
2. A summary of the feedback received from the stakeholder questionnaire 
3. A review of existing EU legislation that is likely to affect the criteria revision 
4. A review of alternative and national ecolabels for hand dishwashing detergent 
5. The proposed scope and definitions for the hand dishwasher detergents category (abbreviated as HDD 
in this document). 
 
2.2 Scope and definition 
2.2.1 
Product definition 
Within the context of the EU Ecolabel and this report, the definition used for detergents is taken from the 
definition of detergents used in the Regulation (EC) No 648/2004 (the Detergents Regulation).5 
 
‘Detergent’ means any substance or mixture containing soaps and/or other surfactants intended for 
washing and cleaning processes. Detergents may be in any form (liquid, powder, paste, bar, cake, 
moulded piece, shape, etc.) and marketed for or used in household, or institutional or industrial 
purposes. 
 
Before discussing in detail the classification of HDDs, it is important that certain key concepts of their 
composition are described. HDD formulations are made up of several components of which the major active 
component is surfactants. Other components of detergents include solubility enhancers, preservatives, 
fragrances, enzymes, dyes and opacifiers. As a result the overall composition of HDDs varies significantly and 
this affects the impact of the product on the environment and on human health. Further information on HDD 
ingredients can be found in Annex I.  
 
2.2.2 
Current EU Ecolabel product scope and definition 
The Commission Decision 2011/382/EU4 defines ‘hand dishwashing detergents’ as the following: 
 
The product group ‘hand dishwashing detergents’ shall comprise all detergents intended to be used to 
wash by hand dishes, crockery, pots, pans, kitchen utensils and so on.  
 
The product group shall cover products for both private and professional use. The products shall be a 
mixture of chemical substances and must not contain microorganisms that have been deliberately added 
by the manufacturer.  
 
 
                                                             
 
5 Regulation (EC) No 648/2004 of the European Parliament and the council of 31 March 2004 on detergents(L 104/1 OJEU 8.4.2004) 
Available from: http://ec.europa.eu/enterprise/sectors/chemicals/documents/specific-chemicals/detergents/index_en.htm

14
2.3 Feedback from stakeholder consultation 
In order to obtain feedback on the current EU Ecolabel product scope and definition for HDDs, a questionnaire 
was sent to stakeholders. A blank copy of the questionnaire can be found in Annex II. The target groups for the 
questionnaire were European Ecolabel competent bodies, industry, technology institutes and trade 
associations. Ten stakeholders formally responded to the consultation by returning the completed 
questionnaire. The respondents feature a mixture of stakeholders, as summarised in Table 1.  
 
Table 1: Summary of respondents to questionnaire 
Stakeholder 
Number of respondents 
Competent bodies 
4 
Environment Agency 
5 
Industry 
5 
Consulting agency 
 
Testing institute 
2 
Industry association 
2 
 
The responses and comments from stakeholders gathered from the questionnaire are presented in Table 2 and 
Table 3. These responses will be used along with scientific evidence to direct the revision of the criteria for the 
HDD product category.

15 
Table 2: Summary of responses to the stakeholder questionnaire 
Number of 
responses 
Criterion 
Existing EU Ecolabel Criteria 
Questions 
Yes 
No 
N/A 
Do you find the existing product group definition 
easy to understand? 
17 
 
1 
Is the current definition appropriate and suitable 
for this product? 
17 
 
1 
Scope and definition 
The product group ‘Hand Dishwashing Detergents’ comprises all detergents 
intended to be used to wash by hand dishes, crockery, cutlery, pots, pans, 
kitchen utensils and so on. 
 
The product group shall cover products for both private and professional 
use. The products shall be mixtures of chemical substances and must not 
contain micro-organisms that have been deliberately added by the 
manufacturer. 
Is the current definition of hand dishwashing 
detergents excluding any type of product that 
should be included? 
4 
14 
 
Is the CDV limit strict enough? 
10 
5 
3 
1. Toxicity to 
aquatic 
organisms: 
Critical Dilution 
Volume (CDV) 
The current criteria specify that the critical dilution volume of the product 
must not exceed the following limits (CDVchronic): 
Product type 
CDVchronic 
Hand dishwashing detergents  
3800 L/1 L of solution 
 
Is CDV the most appropriate method for 
assessing aquatic toxicity? If not, which 
assessment method should be considered? 
12 
2 
4 
Are requirements for anaerobic biodegradability 
necessary for this product group? Which other 
parameters could be considered? 
6 
6 
6 
Are the current limits effective in distinguishing 
between the state-of-the-art and the best 
environmentally performing products in the HDD 
product group? 
5 
7 
6 
2. Biodegradability 
of surfactants 
The current criteria specify that each surfactant in the product shall be 
readily biodegradable (aerobically). 
 
For anaerobic biodegradability of surfactants the following requirements 
apply: 
Feature 
Criterion 
Surfactants classified as H400/R50 
None permitted 
Total weight of anaerobically non-
biodegradable surfactants that are 
not classified as H400/R50 
< 0.20 g/1 L of dishwashing water 
 
Are the current limits set for anaerobic 
biodegradability of surfactants strict enough? 
9 
5 
4 
Are there any additional ingredients which 
should be specifically excluded or limited from 
EU Ecolabel HDDs? 
5 
8 
5 
Are any additional derogations required? 
2 
9 
6 
Are there any substances or mixtures which no 
longer need to be excluded? 
4 
8 
6 
3. Excluded or 
limited 
substances and 
mixtures 
The following ingredients must not be included in the product: 
• APEO (alkyl phenolethoxylates) and derivatives thereof 
• EDTA (ethylenediamine tetraacetic acid) 
• 5-bromo-5-nitro-1,3-dioxane 
• 2-bromo-2-nitropropane-1,3-diol 
• diazolinidylurea 
• formaldehyde 
• sodium hydroxyl methyl glycinate 
• nitromusks and polycyclic musks. 
Are further requirements needed for the use of 
biocides in the product? 
3 
8 
7

16 
Number of 
responses 
Criterion 
Existing EU Ecolabel Criteria 
Questions 
Yes 
No 
N/A 
There are restrictions on the use of quaternary ammonium salts and 
biocides. 
 
The following derogations are in place: 
Substance 
Hazard 
statement 
Risk phrase 
Surfactants (in concentrations 
<25 % in the product) 
H400 and H412 
R50 and R52-
53 
Fragrances 
H412 
R52-53 
Enzymes 
H334 and H317 
R42 and R43 
NTA as in impurity in MGDA and 
GLDA 
H351 
R40 
 
Are there any additional fragrance ingredients 
which should be specifically excluded or limited 
from EU Ecolabel HDDs? 
1 
12 
5 
4.  Fragrances 
Under the current criteria the following requirements on fragrances apply: 
a) Nitro- and polycyclic musk-based fragrances are prohibited as in Criterion  
b) Any substance added to the product as a fragrance must have been 
manufactured and/or handled in accordance with the code of practice of 
the International Fragrance Association. The code can be found on IFRA’s 
website: http://www. ifraorg.org 
c) Other fragrances may be limited to < 100 ppm (g/g) by the requirements 
of Regulation (EC) No 648/200 (Annex VII) or where they are classified 
H317/R43 may cause allergic skin reaction and/or H334/R32 may cause 
allergy or asthma symptoms or breathing difficulties if inhaled.  
d) Fragrances are not permitted in HDDs for professional use. 
Are there any further requirements needed for 
fragrances? 
5 
7 
6 
5.  Corrosive 
properties 
The current criteria state that the product shall not be classified as a 
‘Corrosive’ (C) mixture with R34 or R35 in accordance with Directive 
1999/45/EC, or as a ‘Skin Category 1’ mixture in accordance with 
Regulation (EC) No 1272/2008. 
Are the requirements on corrosive properties 
sufficient? 
13 
 
5 
Do you think that is it necessary to have a 
criterion on packaging requirements for this 
product group? 
12 
3 
3 
Are the WUR limits acceptable for HDDs currently 
on the market? 
8 
5 
5 
6.  Packaging 
requirements 
The existing criteria specify the following requirements on packaging: 
a) Plastics that are used for the main container must be marked in 
accordance with EC Directive 94/62/EC or DIN 6120 part 1 and 2 in 
connection with DIN 7728 part 1. 
b) If the primary packaging is made of recycled material, any indication of 
this on the packaging shall be in conformity with the ISO 14021 standard 
Should additional criteria be set to further 
3 
12 
3

17 
Number of 
responses 
Criterion 
Existing EU Ecolabel Criteria 
Questions 
Yes 
No 
N/A 
promote the use of recycled materials in 
packaging? 
c) Only phthalates that at the time of application have been risk assessed 
and have not been classified according to criterion 3c may be used in the 
plastic packaging 
d) The weight utility ratio (for primary packaging) must not exceed the 
following values: 1.2 g/L use solution 
Should there be restrictions on combinations of 
materials used for packaging? For instance to 
encourage design for recycling (like the new 
proposed criterion for rinse-off cosmetics). 
2 
11 
5 
7.  Washing 
performance 
(fitness for use) 
The existing criteria state that the product shall be fit for use, meeting the 
needs of the consumer. 
The criteria state that the product shall comply with the performance 
requirements as specified in the latest version of the EU Ecolabel HDD 
performance test which can be found here: 
http://ec.europa.eu/environment/ecolabel/documents/performance_test.
pdf   
Stakeholders were asked to provide comments – 
see comments section 
5 
5 
 
8.  User instructions 
Under the existing criteria, the product shall bear the following information 
on the packaging: 
a) ‘Do not use running water but immerse the dishes, and use the 
recommended dosage’ (or equivalent text) 
b) Information on the recommended dosage shall appear on the packaging 
in a reasonably sufficient size and against a visible background. The 
information shall be provided in millilitres (and tea spoons) of product for 
5 litres of dishwashing water suitable for ‘dirty’ and ‘less dirty’ dishes. 
c) An indication of the approximate number of washes that the consumer 
can perform with one bottle is recommended but voluntary. 
Are additional requirements and instructions for 
dosage needed? 
6 
9 
3 
9.  Information 
appearing on the 
EU Ecolabel 
An optional label with text box shall contain the following text: 
• Reduced impact on aquatic life 
• Reduced use of hazardous substances 
• Reduced packaging waste 
Clear user instructions 
Is there any other information which should be 
included on the EU Ecolabel claims text? 
1 
13 
4

18 
 
Table 3: Summary of the comments received from stakeholders in response to the questionnaire 
Criterion 
Question 
Comment 
Do you find the existing product group definition easy 
to understand? 
Is the current definition appropriate and suitable for 
this product? 
Scope and 
definition 
Is the current definition of hand dishwashing 
detergents excluding any type of product that should 
be included? 
No comments 
 
Is the CDV limit strict enough? 
Higher strictness for the CDV limit was assessed as possible by the stakeholders. Indeed, it was 
commented that existing products have much lower CDV values than the thresholds and even 
concentrated products have no difficulties in complying with the criterion. It was suggested that a 
value of 2500litres/litre of solution is possible.  
1. 
Toxicity to 
aquatic 
organisms: 
CDV 
Is CDV the most appropriate method for assessing 
aquatic toxicity? If not, which assessment method 
should be considered? 
Stakeholders commented that they did not have enough information about alternative methods. 
It was also suggested that the most appropriate method to assess the aquatic toxicity of the 
dishwashers would be an environmental risk assessment. CDV is a hazard approach that evaluates 
ingredient by ingredient the hazard and does not follow REACH approach.  
Are requirements for anaerobic biodegradability 
necessary for this product group? Which other 
parameters could be considered? 
Some stakeholders suggested that anaerobic biodegradability is not a relevant environmental 
parameter and instead of it, research on the availability of the raw materials regarding the 
anaerobic biodegradability should be performed. Other stakeholders commented on the fact that 
detergents EU Ecolabels should align with the rinse-off cosmetics EU Ecolabel and promote high 
standards and, thus, should require anaerobic biodegradability for surfactants.  
Are the current limits effective in distinguishing 
between the state-of-the-art and the best 
environmentally performing products in the HDD 
product group? 
Anaerobic biodegradability does not define the environmental performance of surfactants, if they 
are already readily biodegradable (aerobically). Additionally it was pointed out that there are 
products that contain surfactants that are anaerobically biodegradable.  
2. 
Biodegrada
bility of 
organics 
Are the current limits set for anaerobic 
biodegradability of surfactants strict enough? 
Different points were arisen for this question. Stakeholders consider that the current limits are 
too strict although the anaerobic biodegradability is not a relevant parameter from the 
environmental point of view. The limit of 0.20g/1L was mentioned as being too high and some 
stakeholders said that all surfactants should be anaerobically biodegradable.  
3. 
Excluded 
or limited 
substances 
Are there any additional ingredients which should be 
specifically excluded or limited from EU Ecolabel 
HDDs? 
Endocrine disruptors, vPvB, PBT and SVHC, enzymes, quaternary ammonium salts, 
chloromethylisothiazolinone.

19 
Criterion 
Question 
Comment 
Are any additional derogations required? 
Derogations for H400 for enzymes & H411 for surfactants were named.  Derogations similar to 
the amendment made to the I&I laundry and dishwashing detergents criteria could be considered 
since the derogation for surfactants classified as H411 <2.5 %, is not included in this document yet 
and some proteases can be classified as H400. Possible derogations for H317 and H412 for 
preservatives.  
Are there any substances or mixtures which no longer 
need to be excluded? 
APEO: are not used due to their limited biodegradability, NTA. 
and 
mixtures 
Are further requirements needed for the use of 
biocides in the product? 
Research on more sustainable preservatives could be useful. 
Are there any additional fragrance ingredients which 
should be specifically excluded or limited from EU 
Ecolabel HDDs? 
 
4. 
Fragrances 
Are there any further requirements needed for 
fragrances? 
Fragrances should be allowed in professional products. A revision of the CDV calculation of 
fragrances was requested by the stakeholders. It was commented that actually a total (100 %) 
concentration for every perfume is needed while the inclusion of the CDV calculation for every 
ingredient (if available) would be better and would stimulate the use of more sustainable 
fragrances.  
5. 
Corrosive 
properties 
Are the requirements on corrosive properties 
sufficient? 
According to the response, industry initiatives such as Detnet should also be considered.   
Do you think that is it necessary to have a criterion on 
packaging requirements for this product group? 
An affirmative response was received because the packaging of these products is ultimately part 
of the package purchases by the final consumer. On the other hand it was also pointed out that 
too strict requirements on packaging could lower its quality and lose customers.  
Are the WUR limits acceptable for HDDs currently on 
the market? 
No agreement on this point was reached. On the one hand, comments were received regarding 
the high strictness of this criterion (especially considering the low environmental impact caused 
by packaging in comparison to the dishwasher itself) and on the other hand, it was commented 
that this limit could be stricter to be in line with other national schemes such as Nordic Swam.  
Should additional criteria be set to further promote 
the use of recycled materials in packaging? 
Several opinions were commented on this point. For example, it was pointed out the need of 
keeping in mind that although recycled materials are increasingly available on the market and it 
would be good to stimulate recyclability, any recycling criteria should go beyond the current limits 
of this market.  
Other alternatives such as the bio-based plastics and new forms of packaging materials were 
suggested to be investigated since they can also reduce the environmental impacts.  
6. 
Packaging 
require-
ments 
Should there be restrictions on combinations of 
materials used for packaging? For instance to 
encourage design for recycling (like the new 
An agreement on the existence of restrictions on combinations of materials used for packaging 
was expressed by several stakeholders. Non-compatible materials have been identified as the 
major barrier to increase the recyclability rate of packaging.  However, several points were

20 
Criterion 
Question 
Comment 
proposed criterion for rinse-off cosmetics). 
proposed to be further analysed, among them:  
- certain kind of packaging that cannot be recycled at all and for which there are efficient and 
economically viable alternatives with the same functionality on the market should be banned  
- restriction should be studied for the use of low weight laminated pouches that have several 
environmental advantages, but that, however, are difficult materials to be recovered 
- easy-to-empty, easy-to-access and easy-to-separate concepts could also make easier the 
recycling process 
Different opinions were expressed regarding the washing performance tests. On the one side, it 
was commented that the lab tests are not relevant for use in practice, such as the foam criteria, 
and bring unnecessary costs and the protocols should require fewer parameters. On the other 
side, it was stated that the IKW test protocol is sufficient if the current five repetitions are 
increased up to 20 repetitions. 
Additionally, it was suggested that a chemical characterization should be attached to the 
performance tests to allow further quality control.  
7. 
Washing 
perform-
ance 
(fitness for 
use)  
Please provide us with your comments on the 
washing performance test and, if appropriate 
proposals for modification 
Ingredients for the soil preparation should be available locally (at least within one country). 
Instead of ‘local’ source or ‘not specified’ some clarifications are needed because the use of 
specific ingredients can one-sidedly influence the plate numbers. Concerning this matter, the 
reference product is unfortunately rather robust. 
8. 
User 
instruct-
ions 
Are additional requirements and instructions for 
dosage needed? 
Several additional requirements and instruction were suggested: 
- More exact measuring units should be included e.g. “in millilitres (and teaspoons) for consumer 
products and in millilitres for professional products", 
- including several choices replacing and by or, 
- expressing the dosage per litre of water because professional sinks are often bigger than 5 litres, 
- advise the customer to apply for a rinse step after the hand wash,  
- make the meanings of "dirty" and "normally soiled" clearer.  
9. 
 Inform-
ation 
appearing 
on the EU 
Ecolabel 
Is there any other information which should be 
included on the EU Ecolabel claims text? 
Add a claim on the performance of products. 
Should further criterion be developed, either because 
all the issues are not already covered or because of 
recent developments which affect the environmental 
performance of HDDs? 
Other issues to be included into the scheme are: 
- sustainable sourcing of materials (e.g renewable materials) can be assessed by schemes 
already in place 
- professional use training and/or product information sheets to stimulate sustainable use 
0. 
Further 
issues or 
hot spots 
for HDDS 
Do you consider it feasible to link the CDV and 
An agreement on the no-linkage between CDV and the performance criteria was expressed. Two

21 
Criterion 
Question 
Comment 
performance criteria? If yes, please explain your 
approach 
examples were added: fragrances dominate CDV score but do not contribute to the technical 
performance and acidify materials with low CDV score are bad degreasers 
Do you know of any examples of the use of 
nanomaterials in HDDs? Should their use be banned 
from this product group and why? 
Although no examples were given, nanomaterials should be banned in relation with possible 
health concern.

22
2.3.1 
Summary of stakeholder recommendations for revision of existing criteria 
Based on the feedback received from the stakeholders, we recommend that the revision of the criteria should 
focus on the following areas: aquatic toxicity, anaerobic biodegradability, review of excluded ingredients, 
packaging, washing performance, user instructions and renewable raw materials.  
 
Following the review of stakeholder feedback and alternative ecolabels and voluntary agreements, suggested 
changes to the criteria have been collated. A summary of the relevant suggested changes and further actions to 
be taken are summarised in Table 4. 
 
Table 4: Summary of suggest changes for HDD 
Criterion 
Suggested change 
Further action 
CDV limit could be lowered, 2500 
is possible. 
Further stakeholder engagement required. 
Toxicity to 
aquatic 
organisms 
Adjust CDV values according to 
changes in product formulation 
since last revision 
Acquire CDV limits of HDD products from industry and 
competent bodies, and then check these values against 
the current limits. 
Biodegradability 
of surfactants 
Stakeholders suggested that the 
requirements are too strict for 
anaerobic biodegradability 
Further investigation required into the availability of 
surfactants for HDD which are anaerobically 
biodegradable.  
Exclude endocrine disruptors 
Investigate the use of endocrine disruptors in APC 
products and how they are dealt with in EU regulations. 
Derogation for enzymes with 
H400 
Further investigation into the use of enzymes with this 
classification is required. 
Exclude nanomaterials 
Further investigation on the use of nanomaterials in 
APCs is required. 
Exclusion for no longer required 
for APEO 
As it does not meet requirements of Detergents 
Regulation. 
Excluded or 
limited 
substances 
Subsitilisin 
Apart from the feedback received through the 
stakeholders consultation, DG ENV received a request 
for derogating the enzyme subsitilisin that has recently 
changed classification 
WUR limits should be revised, 
some stakeholders think that 
they are too strict 
Further investigation into packaging used for HDD 
products is required. 
Packaging 
requirements 
 
Add criteria to encourage ease of 
recycling 
Align with approach taken for rinse-off cosmetics.  
 
Washing 
performance 
Ingredients for the soil 
preparation should be general 
available instead of local source 
Review soil preparation for fitness for use test and 
ensure that ingredients used are available in most EU 
countries.  
User 
instructions 
For professional use, dosage 
should be in ml per litre. 
Further investigation required on typical dosage 
instructions for professional HDD products.  
Dosage 
Dosage in teaspoons is not 
relevant for professionals  
Add clarification that dosage in ml and teaspoons is 
only required for products intended for consumer use. 
Additional 
criteria  
Sustainable sourcing of palm oil 
derivatives 
Further information to assess the relevance of a 
criterion for sustainable sourcing of palm oil 
derivatives.

23
2.4 Review of legislation – key changes since the 2011 revision 
2.4.1 
Regulation EC/66/2010 (the EU Ecolabel Regulation) 
Regulation EC/1980/20006 on a revised Community eco-label award scheme was replaced by Regulation 
EC/66/20107 on the EU Ecolabel (the EU Ecolabel Regulation) to increase its effectiveness and streamline its 
operation.   
 
A number of key changes, relevant to this product group, were incorporated: 
1) Criteria would be determined on a scientific basis (Ecolabel Regulation - Art.6.3) 
2) There would be a focus on the most significant environmental impacts over the product life cycle 
(Ecolabel Regulation - Art.6.3.a) 
3) The substitution of hazardous substances with safer substances (Ecolabel Regulation – Art.6.3.b) 
4) Any substances classified according to Regulation (EC) No 1272/2008 (The CLP Regulation)8 as hazardous 
to the environment, toxic, carcinogenic, mutagenic or toxic for reproduction  and referred to in Art.57 of 
Regulation EC/1907/2006 (the REACH Regulation) would be restricted (EU Ecolabel Regulation - Art.6.6) 
5) Derogations may be given in respect of the above, if substitution or use of alternative materials is not 
technically feasible.  However no derogations are possible in respect of substances of very high concern 
(SVHC) identified in accordance with the procedure set out in REACH - Art.59 (EU Ecolabel Regulation - 
Art.6.7). 
 
In developing practical means to implement the Regulation, the EU Ecolabelling Board has identified the hazard 
classifications for substances and preparations which would be restricted in all product criteria.  
 
2.4.2 
Regulation (EU) No 259/2012 (the Detergents Regulation)  
In 2012 the Detergents Regulation (Regulation (EU) No 259/2012)9 was revised. The Detergent Regulation 
amends the Regulation (EC) No 648/2004 (the Detergents Regulation 2004)10 and limits the use of phosphates 
and phosphorus compounds in consumer laundry detergents and consumer automatic dishwasher detergents 
(CADDs) in the EU-28, to reduce their contribution to eutrophication and to reduce the cost of their removal 
during waste water treatment. The limit applies to all phosphorus compounds, so that they are not simply 
substituted for each other. However, this revision does not apply to HDDs but this product category may be 
covered in future revisions.  
 
One Member State and one EEA State have been allowed to maintain in place national phosphorus limits that 
are stricter than the Detergents Regulation 2012:  
• Since July 2011, Sweden has restricted the authorised phosphate content of detergents to 0.5 %, and 
intends to maintain these rules until further notice, whilst also waiting for the evaluation of the 
Commission (according to Art.16 of the Regulation). This exception is valid until 1 January 2017. 
• Norway prohibits the manufacture, import and sale of HDDs with phosphorus content of 0.2 % or higher 
(by overall weight). This exception is valid until 1 January 2017. 
 
                                                             
 
6 Regulation (EC) No 1980/2000 of the European Parliament and of the Council of 17 July 2000 on a revised Community eco-label award 
scheme 
7 Regulation (EC) No 66/2010 of the European Parliament and of the Council of November 25 2009 on the EU Ecolabel. 
8 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 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 
9 Regulation (EU) No 259/2012 of the European Parliament and of the Council of 14 March 2012  amending Regulation (EC) No 648/2004 
as regards the use of phosphates and other phosphorus compounds in consumer laundry detergents and consumer automatic dishwasher 
detergents (30.3.2012 OJEU L 94/16) 
10 Regulation (EC) No 648/2004 of the European Parliament and of the Council of 31 March 2004 on detergents (8.4.2004 OJEU L 104/1)

24
2.4.3 
Regulation (EU) No 528/2012 (the Biocidal Product Regulation)  
The Directive (98/8/EC) 11 (the Biocidal Products Directive or BPD) applies to insecticides and products that 
have anti-microbial properties, this includes disinfectants. In household cleaning products biocides may be 
used in small amounts as preservatives to maintain product quality and/or as disinfectants.12 The original BPD 
regulated the placing of biocidal products on the EU market. The BPD applied only to products containing 
active agents that imparted biocidal properties to the product into which they were incorporated.  
 
When the BPD went into force, it was already being criticized as too complicated and inadequate in some 
respects. Demands for simpler and quicker authorization procedures and, EU-wide authorization came 
especially from industry. Authorities from the Member States called for uniform testing and evaluation during 
authorization and consumer and environmental non-governmental organizations criticized the lack of rules on 
articles treated with biocides and on biocide use phases.  
 
Regulation EU/528/201213 (the BPR) concerning the making available on the market and use of biocidal 
products repeals and replaces the BPD. Due to the requirements mentioned above the BPD was reviewed and 
implemented some modifications concerning: prohibiting the use of active biocidal substances with extremely 
hazardous profiles; authorization by Member States of active substances if the exposure to humans or the 
environment is negligible; labelling substitution candidates of the substances that will be gradually replaced; 
and, overall, simplifying and expediting authorization procedures for products in the entire European market. 
In this respect, the BPR includes the stepwise introduction of union authorization by 2020 with an increase in 
the transparency of the process. Finally the BPR increases the consumer protection as a higher number of 
substances cannot be made available to the general public and further information will be available on-line.  
 
 
Under BPR, the mandate for the regulation of biocidal products has been transferred to the European 
Chemicals Agency (ECHA), with the aim being further convergence with the biocidal requirements of REACH. 
The BPR also establishes a Register for Biocidal Products, which allows the Member States, the Commission and 
ECHA to make available to each other the particulars and scientific documentation submitted in connection 
with applications for authorisation of biocidal products. 
 
2.4.4 
Regulation (EC) No 1272/2008 (The CLP Regulation)  
The use of many (often incompatible) national systems for providing information on hazardous properties and 
control measures of chemicals requires multiple labels and Safety Data Sheets (SDSs) for the same product. 
This causes confusion for customers of these chemicals and increases the burden on companies complying with 
many different regulations. To address this, the CLP Regulation14 on the Classification, Labelling and Packaging 
of Substances and Mixtures was developed to harmonise the process, requiring only one set of labels for all 
products sold throughout the EU.  
 
The CLP Regulation entered into force on 20 January 2009 and implemented the UN Globally Harmonised 
System at EU level. The new system of classification, labelling and packaging was implemented by 1 December 
2010 for substances, and will be implemented by 1 January 2015 for mixtures. However, substances and 
mixtures will still have to be classified and labelled according to the predecessor Directive 67/548/EEC15 (the 
                                                             
 
11 Directive 98/8/EC of the European Parliament and of the Council of 16 February 1998 concerning the placing of biocidal products on the 
market 
12 Scientific Committee on Emerging and Newly Identified Health Risks SCENIHR, Assessment of the Antibiotic Resistance Effects of 
Biocides, EC DG-SANCO, 2009. Available from: http://ec.europa.eu/health/ph_risk/committees/04_scenihr/docs/scenihr_o_021.pdf 
13 Regulation (EU) No 528/2012 of the European Parliament and of the Council of 22 May 2012 concerning the making available on the 
market and use of biocidal products. 
14 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 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 (31.12.2008 OJEU L 353/1) 
15 Directive of 27 Tune 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, 
packaging and labelling of dangerous substances (67/548/EEC) (16.8.67 OJEC No 196/1)

25
Dangerous Substances Directive) and Directive 1999/45/EC16 for preparations until 1 June 2015. 
 
 
2.5 Review of national Ecolabels  
As well as the EU Ecolabel, which operates Europe-wide, there are national labels in Europe that can be sought 
out for HDDs, including ‘Nordic Swan’ (Nordic Countries) and the Austrian Ecolabel. A number of labels are also 
used outside the EU, including ‘Green Seal’ (predominantly used in the USA) and the ‘Environmental Choice’ 
labelling programme (New Zealand).17 The aim of this section is to identify where these alternative ecolabels 
have product categories for HDDs. As the EU Ecolabel is a multi-attribute certification, only multi-criteria 
ecolabels will be compared in this section. An overview of the alternative voluntary labelling schemes, including 
industry voluntary agreements, is presented in Table 5 . 
 
A search on standards conducted as part of this study found that there were no standards relating directly to 
HDDs. Instead standards were mostly found relating to testing of washing performance and attributes of 
ingredients found in detergents. These have not been included in this study.  
 
Table 5: Alternative voluntary labelling schemes 
Labelling program 
Region 
Product category 
Date of adoption/last revision 
Nordic Swan  
Denmark, 
Finland, Iceland, 
Norway, 
Sweden. 
Hand dishwashing detergents18 
Version 5.0: 21 March 2012 – 
31 March 2016 
Blue Angel 
Germany 
No criteria for HDD 
N/A 
Austrian Ecolabel 
Austria 
UZ19 Hand dishwashing 
detergents 
Version 5.1 issued July 2011 
Bra Miljöval (Good 
Environmental 
Choice) 
Sweden 
Chemical products19 
Last issued 2006 
Czech Ecolabelling20 
Czech Republic 
Detergents for hand 
dishwashing21 
Last issued 2012 
Ecocert 
Global (founded 
in France) 
Natural detergents and Natural 
detergents made with organic22 
Last revised May2012 
GS-52 Specialty cleaning for 
household products23  
Last issued July 2013 
Green Seal  
USA 
GS-53 Specialty cleaning products 
for industrial and institutional 
use24  
Last issued July 2013 
                                                             
 
16 Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 concerning the approximation of the laws, 
regulations and administrative provisions of the Member States relating to the classification, packaging and labelling of dangerous 
preparations (30.7.1999 OJEC L 200/1) 
17 Information on ecolabels on detergents, including hand dishwashing detergents can be found on the following website: 
http://www.globalecolabelling.net/categories_7_criteria/list_by_product_category/1300.htm 
18 Nordic Ecolabelling of Hand dishwashing detergents, 025 Hand dishwashing detergents, version 5.0, 28 May 2012. Available from 
http://www.nordic-ecolabel.org/criteria/product-groups/ 
19 Good Environmental Choice criteria: Chemical products, Version 2006:4, Swedish Society for Nature Conservation, available from: 
http://www.naturskyddsforeningen.se/sites/default/files/dokument-media/bra-miljoval-engelska/bmv-kem-chemical-crit.pdf 
20 http://www.ekoznacka.cz/ 
21 Technical Guidelines, Detergents for hand dishwashing, V67, 2012, Ministry of Environment available from: 
http://www.cenia.cz/web/www/web-pub2.nsf/$pid/MZPMSFHMV9DV/$FILE/672012.pdf 
22 Ecocert Standard: Natural detergents and natural detergents made with organic, May 2012, Ecocert Greenlife SAS, available from: 
http://www.ecocert.com/sites/default/files/u3/Natural-Detergents-made-with-Organic-Ecocert-Greenlife-11.05.2012.pdf 
23 Green Seal Standard for speciality cleaning products, GS-52 Edition 2.2 April 2014. Available from: 
http://www.greenseal.org/GreenBusiness/Standards.aspx?vid=ViewStandardDetail&cid=2&sid=38

26
Labelling program 
Region 
Product category 
Date of adoption/last revision 
Environmental 
Choice  
New Zealand 
EC-01-14 Hand Dishwashing 
Detergents25 
Last issued January 2014 
Korea Eco-Label 
Korea 
No criteria for HDD 
N/A 
AISE Charter for 
Sustainable Cleaning 
Europe 
Household Manual Dishwashing 
Detergents26 
Last issued January 2014 
Singapore Green 
Label 
Singapore 
Dishwashing Detergents27 
Last issued May 2013 
Good Environmental 
Choice Australia 
Australia 
Hand Dishwashing Detergents28 
Last issued January 2006 
Green Choice 
Philippines 
Liquid dishwashing29 
Last issued 2008 
Green Label Scheme 
Hong Kong 
Hand dishwashing detergents30 
Last issued 2010 
Green Mark 
Chinese Taipei 
Dishwashing detergents31 
Last issued January 2012 
 
Nordic Swan32: The Nordic Swan became the official Ecolabel for the Nordic countries in 1989. It is a voluntary 
scheme that used a life cycle based approach to evaluate a product’s impact on the environment. At present 
there are 63 product categories covered by the Nordic Swan; these include products and services. Each Nordic 
country has a national office which is responsible for licensing, auditing, marketing and criteria development. 
As per the EU Ecolabel, the Nordic Swan uses the same DID list for data on ingredient ecotoxicity and 
degradability.  
 
Austrian Ecolabel33: The Austrian Ecolebel scheme was created in 1990 as an initiative by the Austrian 
Environment Ministry. The intention of the label is to inform the public about the environmental impacts of 
products and services. The Ecolabel covers products, services, as well as schools and other educational 
institutions. The standards are based on the principle of life cycle assessment and cover four main areas: 
consumption of raw materials and energy, waste and emission, marketing and transportation, disposal and 
recycling.  
 
Bra Miljöval (Good Environmental Choice)34: Good Environmental Choice (or Bra Miljöval in Swedish) is the 
ecolabelling system established by the Swedish Society for Nature Conservation. An LCA-based approach is 
employed for the testing and award procedure. At present the system covers 11 product areas including 
chemical products.  
 
Czech Ecolabelling35: The Czech Ecolabel was launched in 1994 and is administered by CENIA, the Czech 
Environmental Information Agency. The Ecolabel covers a wide range of products and services, and for many of 
these it employs the EU Ecolabel criteria. The criteria for product groups which exist in both labelling schemes 
are gradually being unified.  
                                                                                                                                                                                              
 
24 Green Seal Standard for speciality cleaning products for industrial and institutional use, GS-53 Edition 2.2 April 2014. Available from: 
http://www.greenseal.org/GreenBusiness/Standards.aspx?vid=ViewStandardDetail&cid=2&sid=42 
25 The New Zealand Ecolabelling Trust: Licence criteria for hand dishwashing detergents, EC-01-14, January 2014. Available from: 
http://www.environmentalchoice.org.nz/docs/publishedspecifications/ec0114_hand_dishwashing_detergents.pdf 
26 AISE Charter for Sustainable Cleaning: Advanced sustainability profiles for household manual dishwashing detergents, 2014. Available 
from: http://www.sustainable-cleaning.com/content_attachments/documents/ASPs_MDW_1January2014.pdf 
27 Singapore Green Labelling Scheme Certification Guide: Dishwashing Detergents, May 2013. Available from: 
http://www.sec.org.sg/sgls/standards-criteria.php 
28 The Australian Ecolabel Program: Cleaning Products, Version 2.2 November 2013. Available from: 
http://www.geca.org.au/media/medialibrary/2012/08/GECA_15-2006_Hand_Dishwashing_Detergents_May_2012.pdf 
29 Green Choice Philippines, GCP 2008031 Liquid dishwashing, 2008. Available from: http://www.pcepsdi.org.ph/downloads.html 
30 Hong Kong Green Label Scheme, Product environmental criteria for Hand dishwashing detergents (GL-003-004), 2010. Available from: 
http://www.greencouncil.org/hkgls/GL003004_ver2.pdf 
31 Chinese Taipei Green Mark criteria for Dishwashing Detergents (25), 2012. Available from: 
http://greenliving.epa.gov.tw/GreenLife/uploadfiles/Criteria/25/465c9ca4-48fd-4f28-95a2-84b4ec4bf90f.pdf 
32 More information available at: http://www.nordic-ecolabel.org/ 
33 More information available at: http://www.umweltzeichen.at/cms/home/produkte/content.html 
34 More information available at: http://www.naturskyddsforeningen.se/in-english 
35 More information available at: http://www1.cenia.cz/www/ekoznaceni/ekologicky-setrne-vyrobky

27
 
Ecocert36: Ecocert is an inspection and certification body founded in France in 1991. Its focus is on sustainable 
development and organic agricultural products. Ecocert develops internationally recognised standards for 
products, systems and services. The product categories include natural cleaning products, paintings and 
coatings from natural origin and inputs eligible for use in organic farming. The basic principle of the label is to 
protect our planet and its resources, to protect and inform the consumer and to reduce unnecessary waste and 
discharges. In France Ecocert is accredited by the French Accreditation Committee (Cofrac). 
 
Green Seal37: Green Seal is an independent non-profit certification organisation that operates in the USA and 
was established in 1989. Green Seal uses a life cycle approach to evaluate the environmental impacts of 
products, services and companies. It develops its criteria for product categories with input from industry, 
government, academia and the public.  
 
Environmental Choice (New Zealand): The Environmental Choice ecolabel is operated by the New Zealand 
Ecolabelling Trust and is endorsed by the New Zealand government. The ecolabel was launched in 1992 and has 
standards based on life cycle considerations, for a wide range of products, services and companies 
 
Korea EcoLabel: The Korean Ecolabel was launched by the government of the Republic of Korea in 1992. The 
label uses a life cycle based approach and is verified by an independent organisation. The Korea Eco-Label 
covers a wide range of products and services. 
 
The Charter for Sustainable Cleaning: This charter is a voluntary initiative of AISE.38 The charter aims to 
encourage both consumers and industry to adopt more sustainable approaches to cleaning. The charter is 
based on a life cycle analysis  and covers initiatives and activities ranging from human and environmental safety 
of chemicals and products, to eco-efficiency, occupational health and safety, resource use and consumer 
information. In order to participate in the program, companies must report annually on key performance 
indicators. The charter has an advanced sustainability profile (ASP) for Household Manual Dishwashing 
Detergents.39 The ASPs are sustainability criteria which have been created for each AISE product category, 
taking into account a life cycle approach. However, there are no limits values set for environmental impacts 
such as aquatic toxicity and biodegradability. The ASP for a given product category describes the product group 
characteristics which the industry considers represent a good sustainability profile. 
 
Singapore Green Label: The Singapore Green Label Scheme was launched by the Ministry of the Environment 
in 1992. Since 1995 the scheme has been run by the Singapore Environment Council (SEC), who are an 
independently managed non-profit and non-government organisation. The green label considers overall 
product environmental impacts such as raw materials, manufacturing process, health impacts and disposal. The 
label covers a wide range of products, but does not cover services and processes. In addition there are five 
levels of certification: basic, bronze, silver, gold and platinum. Products are scored across all five criteria 
categories and the overall certification level is equal to the lowest score in any category. 
 
Good Environmental Choice Australia: The Australian Good Environmental Choice program was launched in 
November 2011 and is currently managed by a not for profit organisation. The program is complaint with ISO 
14024 and provides standards for a wide range of products and services. The scheme aims to enable 
consumers to choose certified products and standards and have confidence that they have a lower impact on 
the environment, human health and address important social considerations. 
 
Green Choice Philippines: Launched in 2008, the National Ecolabelling Programme - Green Choice Philippines 
(NELP-GCP) is a voluntary, multiple criteria-based, and third party programme that aims to encourage clean 
manufacturing practices and consumption of environmentally preferable products and services. This 
                                                             
 
36 More information available at: http://www.ecocert.com/ 
37 More information available at: http://www.greenseal.org/Home.aspx 
38 More information available at: http://www.sustainable-cleaning.com/en.home.orb 
39 More information available at: http://www.sustainable-cleaning.com/content_attachments/documents/ASPs_MDW_1January2014.pdf

28
government project is seen as an important marketing instrument to complement laws and regulations for 
environmentally preferable products and a guide to consumers' purchasing preferences. The project is under 
the auspices of the Department of Trade and Industry and the Department of Environment and Natural 
Resources. 
 
Hong Kong Green Label Scheme: The Hong Kong Green Label Scheme (HKGLS) is an independent, non-profit-
making and voluntary scheme for the certification of environmentally preferable products launched in 
December 2000 by Green Council (GC). The scheme sets environmental standards and awards its ‘Green Label’ 
to products that are qualified regarding their environment attributes and/or performance. As with all 
ecolabelling schemes, the aim is to encourage manufacturers to supply products with good environmental 
performance and provide a convenient means for consumers to recognise products that are more 
environmentally responsible, thus promoting a more sustainable pattern of consumption. 
 
Chinese Taipei Green Mark: The Green Mark Program is the official eco-labelling program in Chinese Taipei 
which was founded in 1992 by the Environmental Protection Administration (TEPA). At present, the Program 
has issued Green Mark eco-label certificates to nearly 6,000 products under 112 product categories, including 
various cleaning products, office supplies and equipment, energy/water-saving products, home appliances, 
information technology products, construction materials, etc. The Program is instrumental in the government’s 
green procurement program which has been in place since 2002, as the Green Mark products are designated as 
the top priority products for government agencies and all publicly-owned enterprises/schools/hospitals to 
choose from. 
 
In addition to feedback from the stakeholders, the current scope and definition of the EU Ecolabel criteria for 
HDD have also been compared to those of other national ecolabelling schemes. An overview of the Ecolabelling 
schemes and the product definitions used (for the schemes which provide product definitions) is given in Table 
6. It should be noted that not all standard documents for ecolabels provide category or product definitions. 
 
Table 6: Product group definitions and scope from alternative voluntary labelling schemes 
Labelling 
program 
Product category 
Definitions & scope 
EU Ecolabel 
Hand dishwashing 
detergents 
The product group ‘hand dishwashing detergents’ shall comprise 
all detergents intended to be used to wash by hand dishes, 
crockery, cutlery, pots, pans, kitchen utensils and so on. 
The product group shall cover products for both private and 
professional use. The products shall be a mixture of chemical 
substances and must not contain microorganisms that have been 
deliberately added by the manufacturer. 
The Nordic 
Swan  
Hand dishwashing 
detergents 
Liquid hand dishwashing detergents for the retail market and for 
professional use can be Nordic Ecolabel. The primary function of 
the product is as a detergent for hand dishwashing.  
Products that are intended for disinfection or to prevent the 
growth of micro-organisms (e.g. bacteria) are not included in the 
product group. 
Products are considered professional if more than 80 % of sales 
are to the professional market.  
Austria 
Ecolabel 
Hand dishwashing 
detergents 
Same definition as used in the EU Ecolabel 
Sweden Bra 
Miljöval (Good 
Environmental 
Choice) 
Chemical products 
 
Washing-up liquids: Products that are used for hand washing 
porcelain, glass, kitchen utensils and the like.

29
Labelling 
program 
Product category 
Definitions & scope 
Czech 
Ecolabelling 
Detergents for hand 
dishwashing 
Same definition as used in the EU Ecolabel 
Ecocert40 
 
Natural detergents and 
Natural detergents 
made with organic 
Any substance or preparation containing soaps and/or other 
surfactants intended for washing and cleaning processes. 
Detergents may be in any form (liquid, powder, paste, bar, cake, 
moulded piece, shape, etc.) and marketed for or used in 
household, or institutional or industrial purposes. 
New Zealand 
Environmental 
Choice  
EC-01-14 Hand 
Dishwashing 
Detergents 
This category includes all liquid hand dishwashing detergents for 
household use, the main function of which is washing up by hand. 
Singapore 
Green Label 
Dishwashing 
Detergents 
This category includes all detergents intended for use in automatic 
domestic dishwashers and all detergents intended for use in 
automatic dishwashers operated by professional users but similar 
to automatic domestic dishwashers in terms of machine size and 
usage. This category also includes all liquid hand dishwashing 
detergents for household use, the main function of which is 
washing up by hand.  
Good 
Environmental 
Choice 
Australia 
Hand Dishwashing 
Detergents 
This category includes all liquid hand dishwashing detergents for 
the retail trade or for professional use, the main function of which 
is washing up by hand. Products with the purpose of disinfecting 
or limiting growth of micro-organisms (e.g. bacteria) are not 
included in this product category.  
No separate criteria but 
DD are covered under 
Speciality Cleaning 
Products for Household 
Use (GS-52) 
Hand dish cleaning product. A product labelled and intended for 
manual washing of dishes, utensils, pots, pans, glasses, cups and 
other food service tools. 
Green Seal 
(USA) 
No separate criteria but 
IIDD are covered under 
the Speciality Cleaning 
Products for Industrial 
and Institutional Use 
Category (GS-53) 
Hand dish cleaning product. A product labelled and intended for 
manual washing of dishes, utensils, pots, pans, glasses, cups and 
other food service tools. 
Philippines 
Green Choice  
Liquid dishwashing 
These criteria are applicable to liquid dishwashing. 
Hong Kong 
Green Label 
Scheme 
Hand dishwashing 
detergents 
The criteria apply to all hand-wash dishwashing detergents. 
Rinsing agents are not covered in this document. 
Chinese Taipei 
Green Mark 
Dishwashing 
detergents 
This standard is applicable to synthetic cleaning agents (‘product’) 
used for kitchenware cleaning and meet the definitions of CNS 
3800. 
 
The most relevant ecolabel schemes in terms of HDD use are the EU Ecolabel for HDDs, the Nordic Swan for 
HDDs, New Zealand’s Environmental Choice for HDDs and Sweden’s Good Environmental Choice for chemical 
products. These schemes have been selected above others because of their completeness in the household 
HDD category.  
                                                             
 
40 Ecocert is a certification body that developed standards  as a partnership between ECOCERT Greenlife, a certification body in the 
environmental field, and certain detergent professionals who have long expressed the need to find a solution to the following problems 
http://www.ecocert.com/sites/default/files/u3/Natural-Detergents-made-with-Organic-Ecocert-Greenlife-11.05.2012.pdf

30
Additionally, the AISE Charter for Sustainable Cleaning for household manual dishwashing detergents has also 
been investigated, as the charter consists in criteria that are addressing the same hotspots that the above-
mentioned ecolabel schemes.  
In the following section (see Table 6) the criteria of these schemes are compared. This review highlights the 
different approaches taken to ecolabelling and the level of detail employed by different schemes. The excluded 
substances for different ecolabels are compared in Table 8. Please note that for ease of comparison, some 
details of environmental criteria for HDDs have been excluded.  
 
The EU Ecolabel and the AISE Charter have the least restrictive guidelines in terms of the limited substances 
that are permissible in a certified product, with the Nordic Swan, New Zealand Environmental Choice and 
Sweden’s Good Environmental Choice all providing extensive lists. However, it should be noted that in the 
EU Ecolabel some of these substances are limited by other umbrella legislation, such as the EU Ecolabel 
Regulation and its Article 6.6 on the limit of use of hazardous substances. Sweden’s Good Environmental 
Choice scheme also provides good detail on the use of surfactants, and all describe clear user instruction 
requirements. Environmentally hazardous substances and toxicity to aquatic environments are considered in 
detail in all schemes with the exemption of the AISE Charter. Clear guidance on packaging and consumer 
information is provided by all schemes, with the New Zealand Environmental Choice label placing the most 
restrictions on applicant products. This scheme also provides good detail on the requirements for waste 
management, energy management and product claims, which are largely lacking from the other schemes’ 
criteria. The criteria from the Austrian Ecolabel and the Czech Ecolabel have been excluded from this table as 
they have been harmonised with the EU Ecolabel criteria. The Australian Good Environmental Choice programs 
product category for HDDs is no longer open for new applicants; instead HDD are now covered under the 
‘cleaning products’ category.  
 
No ecolabels were identified which have separate criteria for professional and domestic HDDs. In some cases 
one criteria document covers both automatic and hand dishwashing detergents, for example the Green Mark 
programme and the Singapore Green labelling scheme. In the Green Seal labelling scheme HDDs are included 
as part of a large product group named ‘speciality cleaning product’s. The criteria for both of these ecolabels 
have been excluded from the detailed review in the table below as they are not very relevant for hand 
dishwashing and do not provide a good comparison for the EU Ecolabel.

31 
Table 7: Overview of the requirements of different ecolabels for HDDs for consumer use 
EU Ecolabel (hand dishwashing detergents) 
Nordic Swan (hand dishwashing 
detergents) 
Environmental Choice New Zealand (hand 
dishwashing detergents) 
Bra Miljöval (Good  
Environmental Choice) (chemical 
products) 
Limited substances 
Fragrances: Any substances added to the product 
as a fragrance must have been manufactured 
and/or handled in accordance with the code of 
practice of the International Fragrance 
Association.  
 
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. It is prohibited to claim on the 
packaging or by any other communication that the 
product has an antimicrobial action. 
Fragrances: if fragrance is used this must 
be done in accordance with IFRA 
guidelines.  
The following substances must not be 
included in the product at levels >100 ppm 
(0.010 %) per substance: 
• 26 fragrance substances encompassed 
by the declaration requirement in the 
Detergents Regulation 648/2004/EEC 
and its subsequent amendments 
• Fragrances classified as H317 (R43) or 
H334 (R42) 
 
Preservatives: must not be 
bioaccumulating. The requirement applies 
to all preservatives in product ingredients 
and raw materials.  
 
Colorants: must not be bioaccumulating 
(logKow < 4.0 or BCF < 500). 
 
Prohibited substances: The product must 
not contain the following substances. 
• alkylphenol ethoxylate (APEO) or its 
derivatives 
• alkylphenol derivatives (APDs) 
• ethylenediaminetetraacetic acid (EDTA) 
and its salts 
• Quaternary ammonium salts that are 
not readily biodegradable 
• Methyldibromoglutaronitrile (MG) 
• Nitromusks and polycyclic musks 
• Substances with potential for endocrine 
disruption of Category 1 or 2 in 
accordance with official EU lists. 
Fragrances: Fragrances must be produced 
and used in accordance with the code of 
practice compiled by IFRA.  
 
Biocides and preservatives: The product 
may only include biocides in order to 
preserve the product, and in the 
appropriate dosage for this purpose alone. 
 
This criterion does not apply to ingredients 
(e.g.: quaternary ammonium salts) added 
for other functions but which may also have 
biocidal properties. 
 
Colorants: Colouring agents may be added 
to liquid products only, provided they have 
been approved a food additive or are not 
bioaccumulative. The colouring agent is not 
considered to be bioaccumulative if the BCF 
<100 or if Log KOW < 3.0. Where there is 
information on both BCF and Log KOW, the 
values for BCF must be used.  
 
Banned substances: The product shall not 
be formulated or manufactured with the 
following compounds or substances:  
• ethylenedinitrilotetraacetic acid  or EDTA 
or any of its salts 
• nitrilotriacetic acid or any of its salts 
(NTA) 
• diethylenetriaminepentaacetic acid 
(DTPA) or any of its salts 
• alkylphenol ethoxylates (APEOs) or their 
derivatives 
• reactive chlorine compounds such as 
Fragrances: No more than 0.5 % by weight 
fragrance content is permitted in the 
product. This limit also applies to 
concentrated products that are diluted 
before use. 
 
Colouring agents are not permitted. 
 
Phosphorous: Ingredients that contain 
phosphorous must not be added to the 
product intentionally.  
 
Nitrogen: The nitrogen content of the 
product must not exceed 1.0 % by weight.  
 
Complexing agents: Organic complexing 
agents must be readily biodegradable.  
 
Solvents: Solvents must be readily 
biodegradable  
 
Solvents, preservatives, thickening 
agents/dissolving agents, bleaching agents 
must have a bioconcentration factor (BCF) 
of less than 100, or log KOW < 3. 
 
Thickening agents that are completely 
biodegradable 
according to OECD 302, may be included 
up to a maximum concentration of 0.5 % 
by weight. 
 
Enzymes are approved in products that 
bear the Good Environmental Choice label.

32 
• Substances that have been evaluated in 
the EU to be PBT (Persistent, 
bioaccumulable and toxic) or vPvB (very 
persistent and very bioaccumulable) in 
accordance with Annex XIII of REACH. 
 
Substances of very high concern listed on 
the candidate list.  
 
Allergenic substances: The product must 
not contain ≥ 0.10 % by weight per 
substance of substances that are classified 
as H334/R42 and/or H317/R43 according 
to Regulation (EC) No 1272/2008 or 
Directive 67/548/EEC. 
sodium hypochlorite or organic 
compounds of chlorine 
• quaternary ammonium salts that are not 
readily biodegradable 
• phosphates. 
 
Heavy metals: HDDs shall not be formulated 
or manufactured with compounds or 
substances that contain toxic metals, 
including arsenic (As), cadmium (Cd), 
chromium (Cr), lead (Pb), or mercury (Hg). 
 
Enzymes: The enzyme production micro-
organism shall be absent from the final 
enzyme preparation. 
In other products, enzymes must be present 
in liquid form or as a dust-free granulate. 
 
Palm oil and palm kernel oil:  the licence 
applicant must have an effective purchasing 
policy for all palm oil, palm kernel oil (or 
derivatives) or raw materials that are 
manufactured from palm kernel oil to 
maximise the use of palm oil and palm 
kernel oil from sustainable sources.  
 
Fillers must meet the requirements for 
other additives. 
 
Water content must not exceed 75 % by 
weight. No requirement is set for water 
content for products that are sold in spray 
dispensers. 
EU Ecolabel (hand dishwashing detergents) 
Nordic Swan (hand dishwashing 
detergents) 
Environmental Choice New Zealand (hand 
dishwashing detergents) 
Bra Miljöval (Good  
Environmental Choice) (chemical 
products) 
Toxicity to aquatic life 
The critical dilution volume (CDVchronic) of the 
product shall be calculated on the basis of the 
dosage in grams of the product recommended by 
the manufacturer for preparing 1 litre of 
dishwashing water for cleaning of normally soiled 
dishes. The CDVchronic of the recommended dose 
expressed for 1 litre of dishwashing water shall not 
exceed 3 800 litres. 
The products CDV is calculated at a dose 
of 0.60 g/l in-use solution if the specified 
dosage is ≥ 0,60 g/l. If the recommended 
dosage is greater than 0.60 g/l, the 
recommended dosage shall be used for 
calculations. 
 
The product’s CDV must not exceed 2500 
litres for either CDVchronic or CDVacute. 
 
Any raw ingredient that is classified as 9.1A 
(aquatic ecotoxin) must be readily 
biodegradable and not potentially bio-
accumulative. 
 
The toxicity of chemical substances to 
aquatic organisms must be specified, 
giving results for fish, daphnia and algae 
(except for preservatives for which data is 
only required for fish and daphnia). 
 
Complexing agents must not be very toxic 
to aquatic organisms (LC50, EC50 and IC50 
> 1 mg/L).

33 
 
 
Solvents must not be toxic to aquatic 
organisms (LC50, EC50 and IC50 > 10 
mg/L). 
 
Included solvents must not be harmful to 
aquatic organisms (LC50, EC50 andIC50 > 
100 mg/L). 
 
Preservatives must not be very toxic to 
aquatic organisms (LC50 and EC50 > 1 
mg/L). 
 
Thickening agents/dissolving agents must 
not be toxic to aquatic organisms (LC50, 
EC50 and IC50 > 10 mg/L). 
 
Bleaching agents must not be very toxic to 
aquatic organisms (LC50, EC50 and IC50 > 
1 mg/L). 
 
Acids must not be toxic to aquatic 
organisms (LC50, EC50 and IC50 > 10 
mg/L). 
EU Ecolabel (hand dishwashing detergents) 
Nordic Swan (hand dishwashing 
detergents) 
Environmental Choice New Zealand 
(hand dishwashing detergents) 
Bra Miljöval (Good  
Environmental Choice) (chemical products) 
Biodegradability of surfactants 
Each surfactant used in the product shall be 
readily biodegradable. 
 
Surfactants that are not biodegradable under 
anaerobic conditions may be used in the product 
provided that the surfactants are not classified 
with H400/R50 (Very toxic to aquatic life) and that 
the total weight of such anaerobically non-
biodegradable surfactants do not exceed 0.20 g of 
the recommended dose expressed for 1 litre of 
dishwashing water. 
All surfactants must be aerobically and 
anaerobically biodegradable. 
All surfactants must be readily 
biodegradable and anaerobically 
degradable. 
Surfactants must be readily biodegradable.  
 
Surfactants must be 60 % anaerobically 
biodegradable. 
Surfactants must have a very low residual 
content of organohalogen compounds 
(<100 mg/kg TOX). 
 
Surfactants must not be very toxic to aquatic 
organisms. Surfactants must not be classified 
as R50, very toxic to aquatic organisms.

34 
 
If palm oil is used as a raw material in 
surfactant production, the surfactant 
manufacturer or the palm oil supplier must be 
a member of the Roundtable on Sustainable 
Palm Oil (RSPO) or be able to show that the 
palm oil used to produce the surfactants 
comes from a plantation that is certified in 
accordance with RSPO’s sustainable 
cultivation rules. 
Information on the recommended dosage shall 
appear on the packaging in a reasonably sufficient 
size and against a visible back-ground. The 
information shall be provided in ml (and tea 
spoons) of product for 5 l of dishwashing water 
suitable for ‘dirty’ and ‘less dirty’ dishes. 
Regarding consumer products, the dosage 
shall be given as X millilitres per Y litres of 
water, or as Z teaspoons* per Y litres of 
water. 
 
*1 teaspoon = 5 ml 
The product must have information on 
the recommended dosage on the 
primary packaging. The dosage must be 
quoted in whole millilitres for 5 litres of 
dishwashing water. 
The dosage for consumer products must be 
stated in l, dl, ml or other measurement units. 
Where the dosage cannot be given in units, a 
phrase of the type “try not to use more than 
needed” should be printed on the packaging. 
There are no other specific requirements for 
HDDs. 
EU Ecolabel (hand dishwashing detergents) 
Nordic Swan (hand dishwashing 
detergents) 
Environmental Choice New Zealand 
(hand dishwashing detergents) 
Bra Miljöval (Good  
Environmental Choice) (chemical products) 
Limited and excluded substances 
The product or any part of it thereof shall not 
contain substances or mixtures meeting the 
classification with the hazard class or categories 
listed below: 
GHS Haz 
statemt 
EU Risk Phrase 
H300 
R28 
H301 
R25 
H304 
R65 
H310 
R27 
H311 
R24 
H330  
R23; R26 
H331  
R23 
H340  
R46 
H341 
R68 
H350  
R45 
H350i  
R49 
H351  
R40 
H360F  
R60 
Products must not be classified according 
to the classifications listed below: 
Classi-
fication 
Hazard 
statemt 
(CLP Reg) 
EU Risk 
Phrase 
Hazard-
ous to the 
aquatic 
environ-
ment 
H400 
H410 
H411 
H412 
H413 
N with R50 
R50/53. 
R52, 
R53 or 
R52/53 
without N. 
Very toxic 
H300 
H310 
H330 
H370 
Tx with 
R26, R27, 
R28 and/or 
R39. 
Toxic 
H330 
H331 
H311 
and/or 
H301 
T with R23, 
R24, R25, 
R39 and/or 
R48 
Hand dishwashing detergents shall not 
be formulated or manufactured with 
substances that are classified as: 
• Category 1 or Category 2 under the EC 
priority list developed under the 
Community strategy for endocrine 
disruptors 
• Under Hazardous Substances and New 
Organisms Act (HSNO) as: Class 1 
(explosive), Class 3 (flammable), Class 
5 (oxidising), 6.5 (sensitisers), 6.6 
(mutagenic), 6.7 (carcinogens), 6.8 
(reproductive/developmental toxins), 
6.9A (systemic toxicants), 8.2 (skin 
corrosive), 9.1A or 9.1B (aquatic 
ecotoxins). 
 
Ingredients or their known breakdown 
products must not be classified as: 
 
Classification 
EU Risk Phrase 
Carcinogenic 
R45, R49, R40 
Mutagenic 
R46, R68 
Toxic for 
reproduction 
R60, R61, R62, R63, 
R64 
 
Products must not be classified as: 
Classification 
EU Risk Phrase 
Toxic 
R48, R33 
Sensitising 
R42, R43 
Very toxic 
R26, R27, R28, R23, 
R24, R25, R39 
Irritant 
R35

35 
H360D  
R61 
H360FD  
R60-61 
H360Fd  
R60-63 
H360Df  
R61-62 
H361f  
R62 
H361d  
R63 
H361fd  
R62-63 
H362  
R64 
H370  
R39/23; R39/24; R39/25; 
R39/26; R39/27; R39/28 
H371  
R68/20; R68/21; R68/22 
H372  
R48/25; R48/24; R48/23 
H373  
R48/20; R48/21; R48/22 
H400  
R50 
H410  
R50-53 
H411 
R51-53   
H412  
R52-53 
H413  
R53 
EUH059  
R59 
EUH029 
R29 
EUH031  
R31 
EUH032  
R32 
EUH070  
R39-41 
H334 
R42 
H317 
R43 
 
Derogations: the following substances or mixtures 
are specifically exempted from this requirement: 
Substance 
/mixture 
GHS 
Haz 
st’mt 
EU 
Risk 
Phrase 
Surfactants 
in concs <25 
% in the 
product 
H400 
R50 
Fragrances 
H412 
R52-53 
Enzymes 
H334 
R42 
Enzymes 
H317 
R43 
NTA as an 
H351 
R40 
Aspir-ation 
hazard 
H304 
Xn with 
R20, R21, 
R22, R48, 
R65 and/or 
R68 
Sensi-tising 
H334 
H317 
Xn with 
R42 or Xi 
with R43 
Carcino-
genic 
H350, 
H350i 
H351 
Carc with 
R45, R49, 
R40. 
Muta-
genic 
H340 
H341 
R46 
R68 
Toxic for 
repro-
duction 
H360F 
H360D 
H361f 
H361d 
H362 
Repr. With 
R60, R61, 
R62, R63, 
R64. 
 
Substances in the product must not be 
classified according to the classifications in 
the table below: 
Classifi-
cation 
Haz st’mt 
(CLP Reg) 
EU Risk 
Phrase 
Carcino-
genic 
H350 
H350i 
H351 
Carc. with 
R45, R49, 
R40 
Muta-
genic 
H340 
H341 
Muta. with 
R46, R68 
Toxic for 
repro-
duction 
H360F 
H360D 
H361f 
H361d 
H362 
Repr. with 
R60, R61, 
R62, R63, 
R64

36 
 
impurity in 
MGDA and  
GLDA 
 
EU Ecolabel (hand dishwashing detergents) 
Nordic Swan (hand dishwashing 
detergents) 
Environmental Choice New Zealand 
(hand dishwashing detergents) 
Bra Miljöval (Good  
Environmental Choice) (chemical products) 
Packaging 
Plastics that are used for the main container shall 
be marked in accordance with Directive 94/62/EC 
or DIN 6120 part 1 and 2 in connection with DIN 
7728 part 1.  
 
If the primary packaging is made of recycled 
material, any indication of this on the packaging 
shall be in conformity with ISO 14021. 
 
Only phthalates that at the time of application 
have been risk assessed and have not been 
classified according to criterion 3(c) may be used 
in the plastic packaging. 
 
The weight utility ratio (WUR) of the primary 
packaging must not exceed 1.20 g packaging /l use 
solution (dish-washing water). 
Plastic packaging (including caps, lids and 
pumps) and labels containing PVC or 
plastic based on other types of chlorinated 
materials must not be used. 
 
To facilitate identification for recycling, 
plastic bottles that are used as packaging 
must be marked in accordance with DIN 
6120, section 2, ISO 11469:2000 or 
equivalent standard. Caps, lids and pumps 
are exempt from this requirement. 
 
The products weight-to-benefit ratio 
(WUR) is calculated as follows: 
WUR = Σ [(Wi + Ni)/(Di * ti)] < 0.15 
Wi = Weight of the primary packaging 
component (i) in grams including cap, 
dispenser or similar. 
Ni = weight (g) of non-recycled (virgin) 
material in packaging component (i) in 
gram. 
If the proportion of recycled material in 
the packaging component is 0 %, Ni = Wi.  
Di = Number of doses in the primary 
packaging component (i). 
ti = Reuse factor. I.e. the number of times 
that the packaging component (i) is 
reused.  
t = 1 if the packaging is not reused for the 
All plastic packaging must be made of 
plastics that are able to be recycled in 
the country where the product is sold. 
 
Primary packaging must not be 
impregnated, labelled, coated or 
otherwise treated in a manner, which 
would prevent recycling (i.e. PVC sleeves, 
metallic labels).  
 
Primary cardboard packaging shall 
consist of 80 % recycled content, 25 % of 
which must be post-consumer material  
 
The primary packaging, shall have a 
weight utility ratio (WUR) of less than or 
equal to 1.2 g/l.  
The WUR is calculated for the primary 
packaging (including caps, stoppers 
bottles and hand pumps/ spraying 
devices) using the following formula.  
WUR = weight of primary 
packaging/number of doses 
recommended for 1 litre of washing 
water.  
 
Information shall be provided to The 
Trust at application and thereafter 
reported annually on PVC and/or 
phthalates used in the packaging. This 
should include information from 
production records and/or suppliers on:  
• the percentages by weight of recycled 
Packaging must be made of components that 
are easy to take apart, and each component 
must consist of a single type of material. Refill 
packaging that weighs no more than 30 % of 
the weight of the original packaging is 
exempted from this rule.  
 
Plastic packaging must be made from 
polyethylene (PE), polypropylene (PP), poly-
ethylene terephthalate (PET) or an equivalent 
plastic. PVC is not permitted. Plastic 
packaging must be marked in accordance 
with DIN 6120 or American SPI. It is not 
necessary to mark small parts, such as 
stoppers, in this way. 
 
At least 80 % of cardboard packaging must be 
manufactured from wood fibre obtained from 
recycled raw material. If new raw material is 
used for the rest of the card-board, at least 30 
% of this must be certified by FSC. If the 
product content prevents the use of recycled 
raw materials for packaging, it is acceptable 
to use cardboard that is 100 % FSC-certified. 
Only wholly chlorine-free bleaching methods 
may be used. 
 
As far as possible, the pack-aging must 
comply with REPA’s recommendations to 
facilitate recycling. Products that are intended 
for sale to consumers must carry instructions 
on how the packaging should be sorted for 
recycling in accordance with the document

37 
 
 
same function (disposable packaging). 
 
t > 1 may only be used if supported by 
documentation demonstrating that the 
packaging is reused for the same function. 
 
Take-back system: national regulations, 
legislation and/or agreements within the 
sector regarding the recycling systems for 
products and packaging shall be met in the 
Nordic countries in which the company 
markets its dishwasher detergents. 
and virgin PVC 
• the particular production processes 
(membrane cells, non-asbestos 
diaphragms, modified diaphragms, 
graphite anodes, mercury cells, closed-
lid production etc.) used to produce 
chlorine and VCM for the PVC being 
used in the packaging for ECNZ-
licensed products (including the 
locations of the production) 
• information, where available, on 
waste disposal, wastewater treatment 
and emissions to air (occupational 
exposure, emissions from the factory 
and from the final PVC resin) 
• information on any Environmental 
Management System (EMS) for the 
production process, including 
requirements for waste, water, air and 
product-related requirements 
• the types of stabilisers used  
• the types and amounts of any 
phthalate plasticisers present in 
recycled content of the PVC (if that 
information is available) and/or added 
when manufacturing PVC 
• research and initiatives implemented 
on substitutes for phthalates 
identified as of concern by regulators  
• any product stewardship 
arrangements for the packaging.  
‘REPA’s instructions’. If the packaging consists 
of different materials, information must also 
be given on how the different components 
should be recycled. 
 
No metal may be used in the packaging. 
Exceptions to this requirement may be 
allowed for large packaging that can be 
recycled. Metal may be used in the handles of 
buckets that hold 15 litres or more if the 
handle can easily be removed when the 
packaging is recycled. Nozzles on packaging 
such as pump bottles and trigger sprays are 
exempted from this requirement. 
EU Ecolabel (hand dishwashing detergents) 
Nordic Swan (hand dishwashing 
detergents) 
Environmental Choice New Zealand 
(hand dishwashing detergents) 
Bra Miljöval (Good  
Environmental Choice) (chemical products) 
Consumer information 
The product shall bear the following information 
on the packaging:  
• “Do not use running water but immerse the 
dishes, and use the recommended dosage” (or 
 
The HDDs shall be accompanied by 
instructions for proper use so as to 
maximise product performance and 
minimise waste. These instructions shall

38 
equivalent text) 
• Information on the recommended dosage shall 
appear on the packaging in a reasonably sufficient 
size and against a visible background. The 
information shall be provided in millilitres (and 
tea spoons) of product for 5 litres of dishwashing 
water suitable for ‘dirty’ and ‘less dirty’ dishes 
• An indication of the approximate number of 
washes that the consumer can perform with one 
bottle is recommended but voluntary. 
include information on reuse, recycling 
and/or correct disposal of packaging. 
 
The product must have information on 
the recommended dosage on the 
primary packaging. The dosage must be 
quoted in whole ml for 5 l of dishwashing 
water. 
• A second well-known metric, such as 
teaspoons, shall additionally be given 
in brackets. However, if the packaging 
has an efficient and convenient dosing 
system that can provide an equally 
reliable dosage, an alternative metric 
(e.g. capfuls, squirts, or other) can be 
used. 
• The dosing instructions may be stated 
for various water hardnesses and for 
various levels of soiling or for various 
levels of washing up.  
 
All HDDs must display on the container a 
list of product ingredients that complies 
with the labelling requirements of Article 
11 of Reg (EC) No. 648/2004 of the 
European Parliament and of the Council 
of 31 March 2004 on Detergents, as 
amended by Reg (EC) No 907/2006 of 20 
June 2006. 
 
The following or equivalent words 
should be clearly displayed on the 
packaging. “All detergents have an effect 
on the environment. Always use the 
correct dose for maximum efficiency and 
minimum environmental impact.”  Any 
proposed changes/ alterations to this 
wording must be submitted to and 
approved by The Trust.

39 
All labelling shall comply with the 
requirements of HSNO legislation or the 
appropriate hazardous substance 
legislation for the country where the 
product is sold.  
 
All packaging shall include a website 
reference where a copy of the product 
data sheet can be obtained. 
The product shall be fit for use, meeting the needs 
of the consumers.  
 
The cleaning ability and the cleaning capacity must 
be equivalent to or better than that of the generic 
reference detergent specified below. 
 
Assessment and verification: the cleaning ability 
and cleaning capacity must be tested by means of 
an adequate and justifiable laboratory 
performance test carried out and reported within 
specified parameters as stated in the framework 
that can be found here: 
http://ec.europa.eu/environment/ecolabel/ecolab
elled_products/categories/hand_dishwashing_det
ergents_en.htm 
 
The generic reference detergent shall be the one 
prescribed in the IKW performance test 
‘Recommendation for the quality assessment of 
the cleaning performance of hand dishwashing 
detergents’(SÖFW-Journal, 128, 5, pp. 11-15, 
2002) with the adaptation that the dosage applied 
in the performance test is set at 2,5 millilitres of 
the reference detergent per 5 litres of water. 
 
The IKW performance test ‘Recommendation for 
the quality assessment of the cleaning 
performance of HDDs’ (SÖFW-Journal, 128, 5, pp. 
11-15, 2002) method may be applied with the 
mentioned adaptation and can be downloaded 
from: 
The performance test shall be conducted 
by a laboratory within the framework 
specified by Appendix 5. The test results 
shall be documented in accordance with 
Appendix 5. The test shall be performed 
by a laboratory complying with Appendix 
2. 
• The reference product is tested at the 
lowest recommended dosage that is 
stated on the packaging. If no dosage 
instructions are provided, the same 
dosage is used as for the test product. 
• The test product is tested at the lowest 
recommended dosage. 
• The reference product is defined as 
one of the well-established (3-4 
market-leading) HDDs in a Nordic 
country or the Nordic region. 
• The reference product shall be 
different from the product to be 
ecolabelled. The reference product 
must come from a different 
manufacturer than that of the product 
to be ecolabelled.  
• The reference product must be 
purchased in connection with the per-
formance of the test. 
• The product shall be tested against 
another consumer product. If the 
product is marketed for both 
professional and consumer use it shall 
The product shall be fit for its intended 
use and conform, as appropriate, to 
relevant product performance standards. 
 
Performance of the product with respect 
to both cleaning ability (ability to remove 
soil) and cleaning performance (the total 
amount of soil removed per dish wash) 
must be assessed.

40 
 
http://www.ikw.org/pdf/broschueren/EQ_Handge
schirr_e.pdf 
be tested against a professional 
product. 
 
 
The licence applicant/holder and product 
manufacturer must have effective waste 
management policies and procedures 
and/or a waste management 
programme. Licence holders must also 
report annually to The Trust on waste 
management. 
 
EU Ecolabel (hand dishwashing detergents) 
Nordic Swan (hand dishwashing 
detergents) 
Environmental Choice New Zealand 
(hand dishwashing detergents) 
Bra Miljöval (Good  
Environmental Choice) (chemical products) 
Information appearing in the EU Ecolabel 
 
 
The licence applicant/holder and product 
manufacturer must have effective 
energy management policies and 
procedures and/or an energy 
management programme. In addition, 
license holders must report annually to 
The Trust on energy management. 
 
Optional label with text box shall contain the 
following text:  
• reduced impact on aquatic life 
• reduced use of hazardous substances 
• reduced packaging waste 
• clear user instructions. 
 
No claim or suggestion, on the packaging 
or by any other means, shall be made 
that the product has an antimicrobial 
action.  
 
If the licence holder includes claims 
relating to the product being ‘natural’ or 
‘plant based’ the licence holder shall 
provide evidence to support the claim, 
including but not limited to: 
• the definition used by the licence 
holder to support the ‘natural’ or 
‘plant based’ claim; 
• the source of all ingredients including 
whether they are synthetic versions of 
the chemicals; and 
• evidence of chain of custody where 
synthetic versions exist and the 
ingredients are non-synthetic versions

41 
The AISE Charter for Sustainable Cleaning (household manual dishwashing detergents) has developed also criteria that aim at promoting the best environmental 
performance products. These criteria are:  
- Limited substances: Product formulation must pass successfully Environmental Safety Check (ESC) on all ingredients. 
- Dosage and dosage instructions: Dosage must not exceed 12 ml/job (preparation of 1 litre of wash water) 
- Packaging: Total (primary + secondary but excluding tertiary) packaging must be  ≤ 1.3 g/job Board packaging – recycled content requirement of ≥ 60 % OR where 100 % of 
the board used is certified made from fibre sourced from sustainable forests under an endorsed certification standard such as FSC, SFU or PEFC: no minimum.Materials 
other than board – recycled content: no minimum, but any recycled plastic content may be excluded from the calculation of total packaging weight per job 
= Consumer information: End user information on clean right and Safe Use tips must be displayed on pack. 
- Performance: Evidence has to be provided (in case of external verification organised by AISE) that the product has been performance tested and reached a level 
acceptable to consumers consistent with claims made. 
 
Table 8: Comparison of explicitly excluded substances 
Substance 
EU Ecolabel 
Nordic Swan 
Environmental Choice NZ 
Bra Miljöval (Good 
Environmental Choice) 
APEO and derivatives 
X 
X 
X 
 
EDTA and salts 
X 
X 
X 
 
5-bromo-5-nitro-1,3-dioxane 
X 
 
 
 
2-bromo-2-nitropropane-1,3-diol 
X 
 
 
 
Diazolinidylurea 
X 
 
 
 
Formaldehyde 
X 
 
 
 
Sodium hydroxyl methyl glycinate 
X 
 
 
 
Nitro-musks and polycyclic musks 
X 
X 
X 
 
Quaternary ammonium salts that 
are not readily biodegradable 
X 
X 
 
X 
Fragrances 
 
X (not permitted in 
professional products) 
 
Limitations apply  
APD and derivatives 
 
X 
 
 
Methyldibromoglutaronitrile (MG) 
 
X 
 
 
Substances on EU list of endocrine 
disruptors 
 
X 
 
 
Substances that are PBT or vPvB41 
 
X

42 
Substances of very high concern 
listed on EU candidate list41 
 
X 
 
 
Nitrotriacetic acid of any of its salts 
 
 
X 
 
Diethylene triamine pentaacetic 
acid (DTPA) 
 
 
X 
 
Reactive chlorine compounds  
 
 
 
 
Phosphates/phosphorus 
 
Limitations apply 
X 
X 
Heavy metals 
 
 
X 
X 
Chlorine containing bleach 
 
 
 
Limitations apply 
Organically bound halogens 
 
 
 
X 
Note that this does not take into account other substances which may be excluded by applicable regulations in the region for which they operate.  
 
                                                             
 
41 EU Ecolabel excludes also those substances that fall under these categories but it does not do it explicitly. But by means of the implementation of articles 6.6 and 6.7 of the EU Ecolabel regulation.

43
2.6 Summary of the findings 
Very few formal definitions or scope documents for HDDs have been developed. However, alternative 
voluntary labelling schemes such as Nordic Swan and Environmental Choice have developed definitions for the 
HDD product group. These have been considered along with feedback from the stakeholder consultation to 
help provide recommendations for the scope and definition of the EU Ecolabel HDD product category.  
 
According to the research carried out so far, for the HDD product it is recommended that the product group 
scope and definition shall remain the same. 
 
The product group ‘hand dishwashing detergents’ shall comprise all detergents which main function is manual 
washing of dishes, crockery, pots, pans, glasses, cups, kitchen utensils and other food service tools.  
 
The product group shall cover products for both private and professional use. The products shall be a mixture of 
chemical substances and must not contain microorganisms that have been deliberately added by the 
manufacturer.  
 
However, this definition can be subject of changes if further information is received during the revision process. 
Indeed the restriction of substances containing microorganism should be further investigated.

44
MARKET ANALYSIS 
2.7 Introduction 
In order to characterise the relevant European market for the product group under study, a market analysis has 
been conducted. The objective of the market analysis is to identify significant changes in the market for HDDs 
since the last development of the EU Ecolabel criteria and investigate whether any such changes need to be 
reflected in the criteria so that the 10-20 % best environmentally performing products will be selected in 
accordance with Annex 1 of the EU Ecolabel Regulation.  
 
The research in this section consists of a desktop study using a variety of available literature and statistical 
databases, such as: EUROSTAT, Datamonitor, Mintel and Euromonitor data and reports. The market analysis 
covers the period 2010-14 and includes a market forecast to 2015-16. 
 
2.7.1 
Economic indicators 
Analysis of PRODCOM data categories compared with the current EU Ecolabel criteria definition and scope 
indicates that the classifications are irreconcilable. The PRODCOM ‘cleaning product’ categories are not broken 
down in such a way that could be useful for analysis of current EU Ecolabel HDD criteria (see Table 9).  
 
Table 9: PRODCOM cleaning product categories, code and description 
Code(s) 
Description 
20.20.14.30    Disinfectants based on quaternary ammonium salts put up in forms or packing for retail sale or 
as preparations or articles 
20.20.14.50    Disinfectants based on halogenated compounds put up in forms or packing for retail sale or as 
preparations 
20.20.14.90    Disinfectants put up in forms or packing for retail sale or as preparations or articles (excluding 
those based on quaternary ammonium salts, those based on halogenated compounds) 
20.41.20.20 
Anionic surface-active agents (excluding soap) 
20.41.20.30 
Cationic surface-active agents (excluding soap) 
20.41.20.50 
Non-ionic surface-active agents (excluding soap) 
20.41.20.90 
Organic surface-active agents (excluding soap, anionic, cationic, non-ionic) 
20.41.31.20 
Soap and organic surface-active products in bars, etc, n.e.c. 
20.41.31.50 
Soap in the form of flakes, wafers, granules or powders 
20.41.31.80 
Soap in forms excluding bars, cakes or moulded shapes, paper, wadding, felt and non-wovens 
impregnated or coated with soap/detergent, flakes, granules or powders 
20.41.32.40 
Surface-active preparations, whether or not containing soap, p.r.s. (excluding those for use as 
soap) 
20.41.32.50 
Washing preparations and cleaning preparations, with or without soap, p.r.s. including 
auxiliary washing preparations excluding those for use as soap, surface-active preparations 
20.41.32.60 
Surface-active preparations, whether or not containing soap, n.p.r.s. (excluding those for use 
as soap) 
20.41.32.70 
Washing preparations and cleaning preparations, with or without soap, n.p.r.s. including 
auxiliary washing preparations excluding those for use as soap, surface-active preparations 
Source: Eurostat PRODCOM 
*not elsewhere classified (n.e.c.)     ** packaged for retail sale (p.r.s.)     *** not packaged for retail sale (n.p.r.s.) 
 
 
Furthermore, the composition of the various ‘cleaning product’ categories is not clearly outlined, and therefore 
it is not possible to break these down to the category of ‘dishwashing detergent’, to provide data which are 
wholly applicable to the requirements of EU Ecolabel. Table 10 shows a comparison of the categorisation.

45
Table 10: Comparison of the categorisation criteria for PRODCOM and EU Ecolabel for HDD 
PRODCOM categories  
(cleaning product type) 
EU Ecolabel for HDD product classification 
(cleaning product application) 
• Disinfectants based on quaternary ammonium salts put up in 
forms or packing's for retail sale or as preparations or articles 
• Disinfectants based on halogenated compounds put up in 
forms or packings for retail sale or as preparations 
• Disinfectants put up in forms or packings for retail sale or as 
preparations or articles (excluding those based on 
quaternary ammonium salts, those based on halogenated 
compounds) 
• Anionic surface-active agents (excluding soap) 
• Cationic surface-active agents (excluding soap) 
• Non-ionic surface-active agents (excluding soap) 
• Organic surface-active agents (excluding soap, anionic, 
cationic, non-ionic) 
• Soap and organic surface-active products in bars, etc., n.e.c. 
• Soap in the form of flakes, wafers, granules or powders 
• Soap in forms excluding bars, cakes or moulded shapes, 
paper, wadding, felt and non-wovens impregnated or coated 
with soap/detergent, flakes, granules or powders 
• Surface-active preparations, whether or not containing soap, 
p.r.s. (excluding those for use as soap) 
• Washing preparations and cleaning preparations, with or 
without soap, p.r.s. including auxiliary washing preparations 
excluding those for use as soap, surface-active preparations 
• Surface-active preparations, whether or not containing soap, 
n.p.r.s. (excluding those for use as soap) 
• Washing preparations and cleaning preparations, with or 
without soap, n.p.r.s. including auxiliary washing 
preparations excluding those for use as soap, surface-active 
preparations. 
The product group comprises: 
• All detergents intended to be used to 
wash by hand dishes, crockery, cutlery, 
pots, pans, kitchen utensils etc. 
 
 
EUROSTAT data (PRODCOM) will therefore be used only to provide cumulative data on the overall cleaning 
products market in Europe (including dishwashing, soaps and other washing and cleaning preparations), broken 
down by Member State. This analysis will include all HDDs, but will not allow for specific analysis of this product 
category.  
 
2.7.1.1 
Trade and production data, cleaning products market 
The table below provides the PRODCOM production data (value and volume) for all cleaning products in 2013, 
including dishwashing, soaps and other washing and cleaning preparations. The total EU-28 production in 2013 
of cleaning products was €19 billion with 17 million tonnes produced. Germany has the highest production 
value (€5 billion) and the Italy the highest production volume (3.004 million tonnes). NB countries marked with 
an asterisk exclude some data which is anonymous. Figures may therefore be higher than indicated in Table 11.  
 
Table 11: Production of manufactured cleaning products in EU-28, value and tonnes, 2013 
EU-28 
Value (€m) 
Sold volume 
(tonnes) 
EU-28 
Value (€m) 
Sold volume 
(tonnes) 
Austria* 
372,619 
421,327 
Italy 
2,673,495 
3,003,591 
Belgium* 
547,217 
557,297 
Latvia* 
0 
0 
Bulgaria* 
63,052 
74,552 
Lithuania 
10,116 
12,507 
Croatia 
102,119 
116,239 
Luxemburg 
0 
0 
Cyprus 
0 
0 
Malta 
0 
0 
Czech Republic* 
110,486 
123,683 
Poland* 
816,017 
923,134 
Denmark 
205,600 
167,633 
Portugal* 
149,367 
246,307

46
EU-28 
Value (€m) 
Sold volume 
(tonnes) 
EU-28 
Value (€m) 
Sold volume 
(tonnes) 
Estonia 
17,229 
24,074 
Romania* 
159,284 
233,224 
Finland 
41,481 
22,225 
Slovakia* 
5,656 
6,608 
France 
872,608 
1,656,392 
Slovenia 
5,719 
4,732 
Germany* 
4,601,831 
3,232,793 
Spain 
2,168,032 
2,413,072 
Greece* 
117,792 
91,311 
Sweden 
57,148 
35,372 
Hungary 
228,066 
230,961 
The Netherlands 
36,625 
21,202 
Ireland 
18,784 
20,474 
UK 
1,953,162 
1,438,265 
 
 
 
EU-28 
19,265,686 
16,592,287 
* Estimates only – excludes some data which is anonymous. ‘Value EU27’ includes all data.  
Source: PRODCOM 
 
In the same way that PRODCOM data is irreconcilable with current EU Ecolabel definitions for HDDs, COMEXT42 
data (international trade data) also consists of different categories which do not correspond to the EU Ecolabel 
HDD product category. Table 12 shows the COMEXT codes and descriptions for categories which include 
detergents. Neither do these directly relate to the PRODCOM categories indicated above. Even so, these data 
can be used to give an overall indication of both intra- and extra-EU trade for cleaning products.43   
 
Table 12: COMEXT detergent code and description 
Product code 
Description 
34012090 
Soap in paste form ‘soft soap’ or in aqueous solution ‘liquid soap’ 
34012010 
Soap in the form of flakes, granules or powders 
34011100 
Soap and organic surface-active products and preparations, in the form of bars, cakes, 
moulded pieces or shapes, and paper, wadding, felt and nonwovens, impregnated, coated or 
covered with soap or detergent, for toilet use, incl. medicated products 
34011900 
Soap and organic surface-active products and preparations, in the form of bars, cakes, 
moulded pieces or shapes, and paper, wadding, felt and nonwovens, impregnated, coated or 
covered with soap or detergent (excl. those for toilet use, incl. medicated products) 
 
Table 13 shows the value and volume of intra-EU trade of cleaning products for 2013. Overall, this totals: 
• 
imports of 623,793 tonnes (€1,090 million) 
• 
exports of 690,659 tonnes (€1,150 million). 
 
Table 13: Intra-EU trade of cleaning products, import and exports, 2013 
 
Imports 
Exports 
EU-28 
Value (million euros) 
Quantity (100kg) 
Value (million euros) 
Quantity (100kg) 
Austria* 
43 
194,848 
8 
17,343 
Belgium* 
71 
348,454 
65 
400,996 
Bulgaria* 
9 
42,852 
4 
29,439 
Croatia 
8 
47,416 
0 
692 
Cyprus 
3 
14,960 
0 
633 
Czech Republic* 
32 
178,434 
26 
146,934 
Denmark 
21 
139,862 
16 
79,277 
Estonia 
4 
14,542 
1 
2,248 
Finland 
21 
80,538 
1 
2,107 
France 
167 
966,219 
66 
274,158 
Germany* 
133 
758,634 
304 
1,899,952 
                                                             
 
42 COMEXT = statistical database on trade of goods managed by Eurostat. 
43 Intra-EU trade refers to the trade between the Member States of the European Union, while Extra-EU trade refers to the trade between 
Member States and partner countries that are not members of the European Union.

47
 
Imports 
Exports 
EU-28 
Value (million euros) 
Quantity (100kg) 
Value (million euros) 
Quantity (100kg) 
Greece* 
17 
94,548 
9 
49,206 
Hungary 
28 
168,663 
10 
43,066 
Ireland 
54 
211,946 
8 
24,810 
Italy 
49 
299,228 
205 
1,377,243 
Latvia* 
5 
23,092 
1 
3,753 
Lithuania 
6 
29,207 
2 
8,094 
Luxemburg 
7 
23,359 
1 
4,391 
Malta 
2 
9,415 
0 
0 
The Netherlands 
72 
420,593 
77 
362,389 
Poland* 
56 
385,558 
120 
805,672 
Portugal* 
49 
382,657 
9 
41,269 
Romania* 
24 
158,425 
3 
12,126 
Slovakia* 
13 
83,864 
4 
27,713 
Slovenia 
10 
49,120 
4 
14,808 
Spain  
52 
323,535 
47 
340,615 
Sweden 
33 
195,601 
24 
132,164 
UK 
100 
592,369 
136 
765,500 
EU-28 
1,090 
6,237,939 
1.150 
6,906,598 
Source: COMEXT trade data; see Annex II for original data 
 
Table 14 shows the value and volume of extra-EU trade of cleaning products for 2013. Overall, this totals: 
• 
imports of 215,796 tonnes (€302 million) 
• 
exports of 219,224 tonnes (€487 million). 
 
Table 14: Extra-EU trade of cleaning products, imports and exports, 2013 
 
Imports 
Exports 
EU-28 
Value (million euros) 
Quantity (100kg) 
Value (million euros) 
Quantity (100kg) 
Austria* 
6 
25,106 
2 
6,326 
Belgium* 
22 
157,013 
7 
20,365 
Bulgaria* 
10 
100,764 
4 
29,543 
Croatia 
2 
15,546 
2 
8,804 
Cyprus 
1 
3,805 
0 
126 
Czech Republic* 
9 
66,150 
6 
30,143 
Denmark 
4 
22,912 
11 
42,636 
Estonia 
0 
1,835 
0 
858 
Finland 
0 
1,166 
1 
3,434 
France 
32 
276,851 
52 
153,958 
Germany* 
44 
350,637 
117 
587,966 
Greece* 
2 
17,530 
2 
12,174 
Hungary 
2 
13,344 
3 
17,159 
Ireland 
0 
2,457 
0 
118 
Italy 
13 
113,920 
37 
189,006 
Latvia* 
1 
5,787 
3 
10,013 
Lithuania 
1 
6,756 
5 
26,754 
Luxemburg 
0 
1 
0 
1 
Malta 
0 
2,141 
0 
768 
The Netherlands 
29 
186,073 
44 
178,489 
Poland* 
19 
141,489 
30 
140,824 
Portugal* 
2 
19,172 
12 
97,462 
Romania* 
9 
73,520 
3 
11,029 
Slovakia* 
2 
11,646 
0 
1,766

48
 
Imports 
Exports 
EU-28 
Value (million euros) 
Quantity (100kg) 
Value (million euros) 
Quantity (100kg) 
Slovenia 
1 
3,913 
2 
11,956 
Spain  
12 
82,408 
19 
108,681 
Sweden 
5 
33,695 
20 
75,432 
UK 
73 
422,331 
104 
426,456 
EU-28 
302 
2,157,968 
487 
2,192,247 
Source: COMEXT trade data. See Annex II for original data 
 
As seen, there are some countries that play the main roles in all the categories: importers and exporters in both 
the intra- and extra-EU market. These countries are (order is not considered): Germany, France and UK. They 
are also three of the mostly populated countries in EU and this fact can be somehow related to their market 
activity.  Table 15 summarises the value of intra- and extra EU-trade. It shows that the majority of both import 
and export is domestic (i.e. detergents are produced and consumed within the EU boundary). There is, 
however, a degree of both import and export between the EU and the rest of the world.   
 
Table 15: Summary of intra- and extra-EU trade 
 
Import value (million euros) 
Export value (million euros) 
Intra-EU trade 
6,237,939 
6,906,598 
Extra-EU trade 
2,157,968 
2,192,247 
Source: COMEXT trade data. 
2.7.1.2 
Date sources and split 
In place of the PRODCOM and COMEXT data, a number of more relevant sources will be used to better analyse 
the EU market for HDDs.  
 
EU Market 
For Europe as a whole, Euromonitor (Passport) country reports are available for HDD for several European 
countries, including estimates up to 2018. The countries analysed in this report are the UK, Germany, Italy, 
France, Poland and Denmark. This data will be used to provide an overall view of the European market for 
HDDs. Apart from this data, there is no comprehensive dataset for HDDs only, as other data incorporates both 
hand and automatic dishwashing detergents.  
 
International Association for Soaps, Detergents and Maintenance Products (AISE) data has been used to 
provide a total figure for the value of the HDD market in Europe. 2013 AISE data puts the total market value of 
the HDD market at € 1,808 million44 (EU-27 + Switzerland (CH) + Norway (NO) in 2012). 
  
The sales value of all products for the six countries outlined in the section above is €1,089 million – it can be 
assumed that these represent 60 % of the European market for HDDs. 
 
Supply chain 
The data informing the analysis of the supply chain (including raw materials) is primarily from the 2009 Frost & 
Sullivan report, ‘Strategic analysis of the home and fabric care speciality ingredients market in Europe’. This 
report provides an overview of the supply chain of products in the home and fabric care market, which includes 
specialty surfactants, functional polymers, fabric enhancers, active ingredients and rheology modifiers in home 
and fabric care as well as hard dishwashing products, surface cleaners, car interior and upholstery cleaners, 
fabric care, furniture and shoe and leather polishes. 
 
Dishwashing detergents are included in this report, but cannot be further segregated from the information 
presented. Therefore, this report will be used to provide an overview of the cleaning product market as a 
whole, but it should not be considered as an overview of the hand dishwasher detergents in Europe.  
                                                             
 
44 AISE (2013) Market and Economic data [online] Available at: http://www.aise.eu/our-industry/market-and-economic-data.aspx

49
 
 
2.8 Market structure 
2.8.1 
Global overview, market size  
The global market for household products (including household cleaners & bleach products, air fresheners and 
textile washing products) is valued at an estimated $170 billion (or € 123 billion – 2010 data). Overall, the EU is 
estimated to account for about 35 % of this market in terms of value – a total of $60 billion (or €45 billion – 
2010 data). This market is growing with a growth of more than 19 % between the years of 2006-2011.45 It is 
estimated that the global household products market will grow between 2013 and 2016 at a compound annual 
growth rate (CAGR)46 of 3.5 %.47 Current and future global growth rates can be partially explained by a large 
increase in consumer demand for detergents in the Asia-Pacific region, with growth being predominantly 
underpinned by China, whose market for household detergents is projected to grow by 6 % per year between 
2014 and 2017.48 
 
2.8.2 
EU overview, market size 
As well as HDDs for domestic use, there is a market for Industrial & Institutional (I&I) HDDs. The market values 
of these sectors in Europe are outlined in Table 16.  
 
Table 16: Market value of dishwashing detergents (EU-27 + CH + NO), 2012  
Type of dishwashing detergents 
€ million 
Hand dishwashing detergents* 
€ 1,808 
I&I (all kitchen and catering detergents*) 
€ 1,518  
Source: Euromonitor International, cited on AISE website http://www.aise.eu/our-industry/market-and-economic-data.aspx 
 products for domestic use only.  
** including dishwasher detergents, hand dishwashing detergents, kitchen surface disinfectants, hand hygiene and care for I&I use (non-
domestic). 
 
The data for the industrial and institutional market includes a variety of kitchen and catering detergents, but it 
is unknown what proportion of this relates to HDD only.  
 
2.8.3 
EU market structure, national level 
Source: Adapted from Passport data, Market Sizes, Dishwashing (2008-2018) 
Figure 1 shows the sales value of HDDs across six countries from different European regions. Combined, the 
sales value for these countries represents 60 % of the HDD market in Europe (assuming a total market size of 
€1,808 million). Importantly, countries across Europe have very different population sizes and GDP. The larger 
countries with a higher GDP (such as the UK or Germany) will be expected to have higher sales values than 
those countries with a lower population or GDP (such as Poland or Denmark) – briefly, a larger population and 
greater GDP per capita will result in higher sales of products and a higher total sales value.   
 
Across these six countries, sales of dishwashing detergents (both hand and automatic detergents) are highest 
in Italy, followed by the UK and France.  
 
                                                             
 
45 MarketLine Industry Guide (2014) Household products. [online] Available at: http://www.reportlinker.com/ci02166/Household-
Products.html 
46 compound annual growth rate, the year-over-year growth rate over a specified period of time.  
47 Datamonitor (2014) Datamonitor’s Market Data Analysis 
48 Chemical Week, Soaps and Detergents: Consumers Remain Cautious, 17 January 2014, available at 
http://www.chemweek.com/sections/cover_story/Soaps-and-detergents-Consumers-remain-cautious_58079.html

50
 
Source: Adapted from Passport data, Market Sizes, Dishwashing (2008-2018) 
Figure 1: Sales value (€ m) of HDDs in six European countries, 2013 
 
 
2.8.4 
Manufacturers and market share 
Both the automatic and hand dishwashing detergents market across Europe (as with the detergents and 
cleaning market in general) are heavily dominated by a few well-known and globally recognised manufacturers. 
The top five organisations by retail value across Europe are listed in Table 17. Overall, the top five organisations 
in the European market for surface care have an estimated 66 % of the market share in 2013. As well as the 
companies listed below, there are an estimated 92 other organisations (in addition to private label 
manufacturers) in the dishwashing detergent market, all of which have a market share of 1 % or below.  
 
Table 17: Largest manufacturers in European* DD** market, % breakdown by retail value, 2013 
Manufacturers name 
 % share of dishwashing detergent market, by retail value 
Reckitt Benckiser Plc 
24 % 
Procter & Gamble Co 
13 % 
Henkel AG & Co KGaA 
13 % 
Unilever Group 
12 % 
Colgate-Palmolive Co 
4 % 
Private label 
22 % 
Other (circa 92 organisation) 
12 % 
* EU-28 excluding Cyprus, Estonia and Malta due to lack of data 
** Dishwashing detergent includes both hand dishwashing and machine dishwashing detergents.  
Source: Euromonitor International, Data used in Passport report, Brand share by global brand name (2013) 
 
The structure of the dishwashing detergents market has changed little over the past five years. Market 
dominance by a small number of large manufacturers is typical, and the manufacturers outlined in Table 17 
have historically represented a large portion of the market. 
 
2.8.4.1 
Brand data 
Table 18 identifies the top 10 dishwashing detergent brands by % brand share. Not only are there a small 
number of organisations dominating the market, but a small number of brands within these organisations hold 
the greatest market share. Table 18 includes both hand and automatic dishwashing detergents. Reckitt 
Benckiser (the top company by brand) is generally considered to be the market leader in the European market 
for automated dishwashing products, with its product line Finish.49 However, Reckitt Benckiser also produces 
HDDs. In the HDD market, Fairy (Proctor & Gamble) is widely recognised as the brand with the biggest share.  
                                                             
 
49 Frost & Sullivan (2009) Strategic analysis of the home and fabric care speciality ingredients market in Europe

51
 
Table 18: Dishwashing detergents*, top 10 brands (brand share, %), Europe**, 2013 
Brand 
Manufacturer 
Brand share (%) 
Finish 
Reckitt Benckiser Plc 
22 % 
Fairy 
Procter & Gamble Co 
11 % 
Sun 
Unilever Group 
8 % 
Somat 
Henkel AG & Co KGaA 
6 % 
Pril 
Henkel AG & Co KGaA 
2 % 
Svelto 
Unilever Group 
2 % 
Pur 
Henkel AG & Co KGaA 
2 % 
Paic 
Colgate-Palmolive Co 
2 % 
Palmolive 
Colgate-Palmolive Co 
1 % 
Dreft 
Procter & Gamble Co 
1 % 
 
 
 
Private label 
- 
22 % 
 
 
 
Ecover 
Ecover Belgium NV 
0.8 % 
* Dishwashing detergent includes both hand dishwashing and machine dishwashing detergents. 
** EU-28 excluding Cyprus, Estonia and Malta due to lack of data 
 
Ecover is the largest ‘green’ manufacturer of dishwashing detergents, with an estimated 8 % of the market. 
This ranks as a significant 17th of over 71 brands, and shows a high presence of Ecover products in the European 
market.  
 
The proportion of private label manufacturers in the dishwashing detergent market is relatively high (22 % of 
the market by retail value). These manufacturers typically produce for supermarkets that sell own brand 
products. There are a large number of supermarket brands across Europe, and competition between them is 
intense. Often supermarket brands compete on a low price basis and sell via discounted prices and offers in 
store.  
 
2.8.4.2 
The industrial and institutional dishwashing detergent market 
The global industrial and institutional market for cleaning products is dominated by two major players; 
together, these companies account for about 24 % of the global market for industrial and institutional cleaning 
products.50 These organisations are: 
1. Ecolab – a US-based global company, providing hygiene and food safety services and products to 
industrial and hospitality markets.  
2. Diversey – also US-based, operating globally, providing cleaning and hygiene products to a variety of 
markets including food service and food and beverage companies.  
 
The remainder of the market is made up of a large number of small local  and national companies, each with no 
more than $50 million in annual industrial and institutional cleaner sales – in many cases much less. However, 
these smaller companies are beginning to increase their market visibility as a result of recent consolidations.48 
Even so, the market remains fragmented.  
 
Some of the typical household brands also produce industrial products – including Procter & Gamble (P&G) 
Professional’s Deepio washing up liquid launched in 2013, which is designed for use on heavily soiled items51, 
                                                             
 
50 IHS(2010) Industrial and Institutional Cleaners 
51 BigHospitality (2013) P&G Professional launches Deepio washing-up liquid. [online] Available at: http://www.bighospitality.co.uk/New-
Products/P-G-Professional-launches-Deepio-washing-up-liquid

52
and the extra tough Fairy washing up liquid (also P&G) which is designed to help operators save time in the 
kitchen by reducing soaking times.52  
 
The global market for I&I cleaning products is expected to grow at an average annual rate of about 3 % by 
weight.48 No specific figures are available for industrial HDDs, although the industrial and institutional market 
for all kitchen and catering detergents53 is valued at €1,518 million.54 If the market for these products increases 
in line with global expectations for volume growth it will increase by €141 million in the next three years (see 
Table 19).  
 
Table 19: Expected growth in the I&I market for kitchen and catering detergents (€ m), 2013–16 estimate 
 
2013 
2014 
2015 
2016 
Market value*  
€1,518m 
€1,564m 
€1,610m 
€1,659m 
* 3 % average annual growth (2013 base year) 
Source: own calculation, based on BigHospitality 2013 estimate
48  
 
2.8.5 
Supply chain and raw materials 
As shown in Table 20, most household products (including dishwashing products) in Western Europe are sold 
through supermarkets. Supermarkets are able to control the amount of product on shelves and often price 
promotions in store. They are, therefore, an important part of the supply chain for the dishwashing detergent 
manufacturers. The presence of private labels is also significant for HDDs, and supermarket own-branded 
products are prevalent on the market.  
 
Table 20: Western Europe, distribution channels by value (%), 2009 
Channel 
 % 
Supermarkets / hypermarkets 
62.4 % 
Independent retailers 
19.6 % 
Pharmacies / drugstores 
8.2 % 
Convenience stores 
4.5 % 
Cash & carry and Warehouse clubs 
1.8 % 
Department stores (incl. Duty-free shops) 
1.2 % 
Others 
2.4 % 
Source: Datamonitor (2011) Household products market in Western Europe to 2014 
 
2.8.5.1 
Raw materials 
Any changes in availability of raw materials impact on the price of products which use those materials. The 
dishwashing detergent market relies on a number of ingredients, including: 
• 
surfactants 
• 
preservatives/biocides 
• 
enzymes 
• 
dyestuffs 
• 
complexing agents 
• 
bleaching agents 
• 
anti-corrosion agents 
• 
anti-foaming agents. 
 
Annex II provides more detail about each of these ingredients.  
 
                                                             
 
52 Morning Advertiser (2013) P&G Professional launches extra tough Fairy washing-up liquid. [online] Available at: 
http://www.morningadvertiser.co.uk/Pub-Food/P-G-Professional-launches-extra-tough-Fairy-washing-up-liquid 
53 includes hand dishwashing detergents, dishwasher detergents, kitchen surface disinfectants, hand hygiene and care 
54 Euromonitor International, cited on A.I.S.E website http://www.aise.eu/our-industry/market-and-economic-data.aspx

53
In the home and fabric care speciality ingredient market55 there are an estimated 40-50 companies, with the 
dominant players mainly being speciality surfactants companies. However, the market is also characterised by 
an increasing degree of consolidation, which alters the number of competing organisations.  
 
Table 21 shows the percentage revenues for each of the key ingredients in the home and fabric care speciality 
ingredients market.53. In 2008 the largest market share in terms of revenue was speciality surfactants with 
34.4 % of the market, followed by fabric enhancing chemicals (23.2 %), functional polymers (22.6 %) and 
rheology modifiers (14.1 %). Active ingredients – comprised of disinfectants, bactericides and preservatives - 
held the smallest market share amongst the speciality chemicals with only 6.1 % of the market.56  
 
Table 21: Total home and fabric care speciality ingredients market53: % of revenues by chemical type, Europe, 
2008 
Speciality 
surfactants 
Functional polymers 
Fabric enhancing 
chemicals 
Active ingredients 
Rheology 
modifiers 
34 % 
23 % 
23 % 
6 % 
14 % 
Source: Adapted from Frost & Sullivan (2009) Strategic analysis of the home and fabric care speciality ingredients market in Europe. 
 
The speciality chemical market for home and fabric care is facing a number of challenges over the next decade 
which may alter current business practices. Table 22 ranks the top eight challenges which the industry is 
expected to face, along with an indication of the impact that this may have on organisations. The top challenge 
(volatility in oil prices) relates directly to the manufacture of raw materials. This is something which many 
organisations are now adapting to, helping to drive increased innovation and research in the use of plant-based 
chemicals.  
 
Table 22: Home and fabric care speciality ingredients market53: impact of top eight industry challenges 
ranked in order of impact, Europe 
Rank 
Challenge 
Expected impact 
5-7 years 
1 
Volatility in crude oil prices affects costs across the supply chain 
High 
2 
REACH creates scepticism in the home and fabric care speciality chemicals market 
High 
3 
The trend for concentrates lowers the amount of chemicals used 
High 
4 
The largest buyers exert pressure backwards in the supply chain 
High 
5 
Consolidation in the industry alters the market dynamics (e.g. larger supplier may 
have greater control over the market) 
High 
6 
Product switching due to price shortens the life cycle of products 
High 
7 
Increase in multifunctional products that cater for more than one ‘job’ 
Medium 
8 
Increase in the use of natural proteins as fabric enhancers 
Medium 
Source: Adapted from Frost & Sullivan (2009) Strategic analysis of the home and fabric care speciality ingredients market in Europe. 
Note, this table was produced in 2009 
 
Overall, there is potential for growth in the dishwashing detergent market, which translates to growth in the 
raw materials market. However, innovation in raw materials is being rapidly driven by a push from consumers 
who are increasingly demanding more from detergents and pushing for the use of more natural products in 
HDDs.57 
 
 
                                                             
 
55 This includes: dishwashing products; hard surface cleaners; car interior and upholstery cleaners; furniture, shoe and leather polishes; and 
fabric washing and care. 
56 Frost & Sullivan (2009) Strategic analysis of the home and fabric care speciality ingredients market in Europe. 
57 Frost & Sullivan (2009) Strategic analysis of the home and fabric care speciality ingredients market in Europe.

54
2.9 Trends and innovations 
2.9.1 
Market trends 
Figure 2 shows the trends in retail value for the dishwashing detergents market (including hand and automatic 
dishwashing detergents) across Europe. There is a clear upward trend in the product category, showing an 
expected increase from €3,800 million in 2008 to €4,732 million in 2018, a CAGR of 2.01 %. 
 
For HDDs only, data are available for the six Member States analysed in this report (France, Poland, Italy, 
Denmark, UK and Germany). Figure 3 shows the actual and projected retail sales values for each of these six 
countries, to 2016. Sales of HDDs are projected to increase in all with the exception of Italy, which shows a 
downward trend from 2012. By 2016, sales values in Italy are projected to decrease from 2007 values by almost 
€38 million. However, it should be noted that this downward trend is based on projections of activity between 
2007 and 2012. In Italy between 2012 and 2013, sales values actually remained the same, rather than 
continuing in a downward trajectory. This suggests that the clear decrease in sales values since 2007 may be 
slowing and the projection to 2016 may be more positive than outlined in Figure 3.  
 
The value increase between 2007 and 2016 is an estimated €23 million in the UK, an estimated €78 million in 
France, €30 million in Germany, €22 million in Poland and €4 million in Denmark.  
 
 
* Includes HDDs and detergents for dishwashers 
** Europe excludes Cyprus, Estonia and Malta due to lack of data 
Source: Adapted from Passport data, Market Sizes (2008-2018) 
Figure 2: Actual and projected total retail value (€ m) of dishwashing detergents* in Europe**, 2008-18

55
 
Source: Adapted from Passport data, Market Sizes, Dishwashing (2008-2018) 
Figure 3: Actual and projected sales value (€ m) for countries with top five market share in dishwashing 
detergent value across Europe, 2008-18  
 
Table 23 provides more information about the change in sales value, in terms of percentage, between 2007 
and 2016.  
Table 23: Percentage change in the EU market (sales value) for HDDs 
 
% change 2007 - 2016 
CAGR 2008 - 2016 
France 
38 % 
3.7 % 
Poland 
30 % 
3.0 % 
Italy 
-13 % 
-1.5 % 
Denmark 
18 % 
1.5 % 
UK 
10 % 
1.0 % 
Germany 
16 % 
1.6 % 
 
• 
France is expected to have the highest increase in sales value between 2007 and 2016 with an 
increase of 38 %; a CAGR of 3.7 %.  
• 
Sales in Poland are expected to increase by 30 %, in Denmark by 18 %, in Germany by 16 %, and in the 
UK by 10 %.  
• 
Only Italy shows a projected decrease in sales value from 2007 to 2016; a decrease of 7 % and a CAGR 
of 1.4 %. Although this may only be a small decrease in terms of percentage, this is significant in value 
and quantity terms as Italy consistently has the highest total sales value in comparison to the other 
countries analysed. There are many likely reasons for this decrease, the most obvious being the 
possible links to the automatic dishwasher detergent market – i.e. does the sale of automatic 
dishwasher detergents directly replace purchase of HDDs? This is analysed in section 3.3.1.1.  
 
2.9.1.1 
Hand dishwashing versus automatic dishwashing 
Figure 4 provides a comparative overview of the size of the market for HDDs (€1,783 million) and automatic 
dishwasher detergents (€2,480 million). This equates to a market value of over €4 billion in 2012 for the entire 
household dishwashing product category.

56
 
Source: Euromonitor International, data cited in Passport (2014) Market sizes Europe, Dishwashing 
Figure 4: Market value and % share of all household dishwashing detergents, Europe, 2012 
 
Figure 5 summarises the predicted trends in total sales of both automatic and hand dishwasher detergents, 
across the six countries analysed throughout this report. These products are often seen as direct competitors, 
although many householders who own a dishwasher will also purchase HDDs. Even so, it is predicted that sales 
of HDDs will slow, while still increasing, alongside a more dramatic rise in sales of automatic dishwashing 
detergent products.  
 
 
Source: Adapted from Passport data, Market Sizes Europe, Dishwashing (2008-2018) 
Figure 5: Total actual and projected sales (€ m) of dishwasher detergents, 2007-16, (FR,PL,IT,UK,DE,DK) 
 
Figure 6 outlines the percentage of households which owned dishwashers in 2012. This number is expected to 
increase by over 1 million more dishwashers in use – in the UK for example, the market penetration of 
dishwashers increased from 34 % in 2006 to 40 % in 2012.58 In turn, this is expected to lead to an increase in 
sales of automatic dishwasher detergents.  
 
                                                             
 
58 Mintel (2011) Dishwashing Detergents UK

57
 
Source: Euromonitor International, Data used in Passport report, Possession rates (2013) 
Figure 6: Dishwasher possession rates (%), EU-28, 2013  
 
Although there has been growth in the number of households with a dishwasher, and this growth is likely to 
continue, there are still significant opportunities for HDDs. It is estimated that in 2020, more than 90 million 
households in Western Europe will still wash up by hand.59 For example, it is estimated than in Italy, 95 % of 
households still do some hand washing (2012 data).60 This is partly due to households still washing up many 
items by hand even if they own a dishwasher, but could also be a result of consumers trying to save money and 
reverting to dishwashing by hand.58  
 
This widespread use of hand dishwashing is also shown in Table 24, which estimates the share of items being 
washed up manually in households in four Member States: Germany, Italy, Sweden and the UK.  
 
Table 24: Share of items being washed up manually (%) 
 
Germany 
Italy 
Sweden 
UK 
Dinner plates 
7 % 
31 % 
9 % 
19 % 
Soup plates 
23 % 
27 % 
14 % 
17 % 
Cups 
12 % 
43 % 
26 % 
26 % 
Saucers 
17 % 
62 % 
11 % 
26 % 
Bowls 
25 % 
42 % 
29 % 
27 % 
Casseroles 
25 % 
62 % 
33 % 
43 % 
Plastic items 
39 % 
47 % 
45 % 
40 % 
Plastic items 
64 % 
49 % 
28 % 
73 % 
Pots 
51 % 
62 % 
71 % 
58 % 
Pans 
71 % 
54 % 
91 % 
65 % 
Other Items 
65 % 
78 % 
80 % 
77 % 
Source: Richter (2010), cited in Novozymes (n.d.) Manual dishwashing, Household care 
                                                             
 
59 Novozymes (n.d.) Manual dishwashing, household care  
60 Passport (2012) Dishwashing in Italy

58
To conclude, it is expected that the HDD market will continue to grow, although this will likely be at a slower 
rate than the automatic dishwashing detergent market. Importantly, there is only a partial trade-off between 
these two products as even households with a dishwasher are likely to continue to wash some items by hand. 
However, as dishwasher ownership increases, there will likely be some negative impact on sales of HDDs.  
 
2.9.2 
Sustainable cleaning product innovations 
Consumers of household care and industrial cleaning are placing a higher emphasis on sustainability when 
purchasing products. This is reflected by the increasing number of product innovations and launches which 
focus on environmental claims. It is no longer just niche brands, but global brands now also advertise the green 
credentials of their cleaning products to encourage sales.  
 
As a response to this increasing focus on environmental issues, a number of companies with ‘pitches’ centred 
on sustainability have joined the market, including brands such as Ecover and Method which can now be 
commonly found in supermarkets across Western Europe. Private label manufactures are also increasingly 
developing cleaning products with ‘green credentials’.61 
 
Among the multinational ‘green cleaning’ brands, Ecover is the most prominent, with significant sales across 
main Western European markets. Figure 7 shows the scale of this growth between 2004 and 2008 in the UK, 
one of the largest markets for Ecover in Europe – Ecover saw an increased share of 1.1 % of the total household 
care market in this period.   
 
 
Source: Adapted from Euromonitor International (2009) Global Household Case: Green Cleaning – Still an Oxymoron? September 2009 
Figure 7: Ecover’s Share Increase (% of total household care) in the UK 2004-08  
 
Typically, innovation in the household cleaning market is driven by larger brands, with occasional innovative 
product launches from smaller, niche brands. Where these brands are successful, private labels (such as own-
branded supermarket products) typically move into the market with a similar product offering. ‘Green’ cleaning 
products have been a success across the cleaning products market, which has led to private labels launching 
similar offerings and establishing a significant presence in the environmentally-friendly cleaning market.   
 
These private label green cleaning products include: 
• 
UK: Tesco’s Naturally range of household care products - made from plant-based ingredients, not tested 
on animals and free from synthetic colours.  
• 
UK: Asda’s Eco-Friendly brand includes HDDs.  
• 
UK: Co-operative own brand products include the Ecological Concentrated HDDs. 
                                                             
 
61 Euromonitor International (2009) Global Household Case: Green Cleaning – Still an Oxymoron? September 2009

59
• 
Switzerland: the Migros supermarket chain has launched a range of environmentally-friendly products 
under the brand M-Plus.  
 
Private labels can often be found at lower prices than their branded equivalents – this drives the purchase of 
private label ‘green’ products by consumers who are both eco-conscious and price-sensitive. However, 
although private labels are maintaining the balance between green benefits and price, these eco-products can 
often be considered as less efficient than the standard products.62  
 
Overall, the trend for environmentally aware ‘green cleaning’, including dishwashing, remains strong. Several of 
these environmental trends are outlined below.  
 
2.9.2.1 
Green ingredients 
The use of green or natural ingredients in HDDs has become relatively widespread and a number of the larger 
supermarket chains stock products which are marketed as having eco-friendly ingredients. These products 
include: 
• 
Orientea Enterprise Co Ltd HK launched Orientea in Japan. The product is made from organic tea 
leaves and contains no ingredients derived from petrochemicals.  
• 
Ecover, the largest brand of eco-friendly cleaning products, uses plant based and mineral ingredients 
in its HDDs.  
• 
Like Ecover, the Method HDD uses a number of plant based ingredients and the product is 
biodegradable. 
• 
The Bio D Concentrated low foam washing up liquid contains a number of eco-friendly ingredients 
such as vegetable oil, citric acid and vegetable glycerine. 
 
2.9.2.2 
Packaging minimisation 
Packaging minimisation is becoming standard for a variety of products, not just HDDs. Minimising packaging 
not only helps reduce the amounts of plastics, etc. which needs to be produced and sent to landfill, but also 
reduces the cost of manufacture. The majority of the larger HDD manufacturers have recently focused on light-
weighting packaging for a number of products in the household care market.  
 
Some manufacturers (primarily those with an environmental focus) have developed re-usable/refillable bottles 
for their HDDs. For example, both Method and Ecover sell a refillable bottle and washing up liquid refills, all in 
recyclable packaging.63   
 
2.9.2.3 
Other considerations 
Concentrated detergents: The idea of concentrating HDDs to ensure that less is used in a typical wash is not 
new – the original 1960s Fairy liquid campaigns were focused on this. Many products also market this to prove 
efficacy, rather than for environmental reasons. However, this is a widespread theme in the dishwashing 
detergents market, aimed at reducing the amount of product used, packaging needed and transportation 
required per item. For example, Henkel launched Pur 3xAction in 2012 which is marketed as 50 % thicker than 
comparable HDDs. The manufacturers of this product claim that a small amount is enough for a large amount 
of washing up, and so the product lasts longer imparting to it all the properties listed above.  
 
Water saving: Although not a trend (this is a very new concept which only one product is advertising), a 
washing-up liquid has been developed in Japan which claims to reduce the amount of water used in washing 
up. The Terra Eco Clean hand dishwashing detergent was introduced in 2012 by Natural Terra. The detergent 
contains an extra palm oil surfactant which is claimed to break down grease more easily, requiring less water to 
rinse dishes.64  
                                                             
 
62 Euromonitor International (2009) Global Household Case: Green Cleaning – Still an Oxymoron? September 2009 
63 Available at: http://methodproducts.co.uk/ind_wash_refill_cle.html 
64 Datamonitor (2009) New household goods review: Ethical lines grow in an array of categories. [online] Available at: 
http://www.datamonitor.com/store/News/new_household_goods_review_ethical_lines_grow_in_an_array_of_categories?productid=7D6
70248-A50E-459E-A546-A30748497F98

60
 
2.9.3 
Eco-labelling 
Environmental labelling schemes are becoming widely used for a number of consumer products, including for 
dishwashing detergent and other cleaning and household care items. These labelling schemes can be 
particularly useful to private labels in the cleaning market as they can be used to persuade consumers of the 
benefits of own-brand products, without the need for costly marketing strategies akin to the larger brands. For 
example, in the UK, Sainsbury’s Cleanhome product range (launched in December 2007) has been certified by 
both the EU Ecolabel and the Swedish Falcon Good Environmental Choice label. 
 
Table 25 provides an estimate of the number of EU Ecolabel HDD products manufactured and sold in Europe. 
The first column (country) indicates the country which awarded the EU Ecolabel to various manufacturers and 
products; this is also the country in which the product is manufactured. 42 manufacturers have been awarded 
the EU Ecolabel for a total of 85 products. 
 
There is reasonable availability of EU Ecolabel HDDs across Europe. However, only 11 of 28 European countries 
manufacture any products which have been awarded the EU Ecolabel; all other countries rely on the import of 
Ecolabel products. Table 26 indicates how many Ecolabel products are available in each EU country. France has 
the highest number of products available (37), followed by Spain (35). Croatia is the only country which has no 
EU Ecolabel products available on the market, although availability is also low in Bulgaria, Cyprus, Estonia, 
Malta, Slovakia and Slovenia (each with only one product).  
 
Table 25: EU Ecolabel HDD products manufactured and sold, by country (EU-28 + Norway) 
Country 
No. of 
manufacturers 
awarded the 
EU Ecolabel 
No. of products 
awarded the 
EU Ecolabel 
Countries where products are sold (Europe only) 
Austria 
1 
1 
Austria 
Belgium 
6 
35 
Austria, Belgium, Czech Republic, Denmark, Finland, 
France, Germany, Ireland, Italy, Luxembourg, 
Netherlands, Poland, Portugal, Spain, Sweden, UK 
Cyprus 
1 
1 
Cyprus 
Czech 
Republic 
1 
1 
Czech Republic 
Denmark 
1 
1 
Austria, Belgium, Bulgaria, Czech Republic, Denmark, 
France, Germany, Greece, Hungary, Ireland, Italy, 
Lithuania, Netherlands, Poland, Portugal, Romania, 
Slovakia, Spain, Sweden 
Germany 
6 
11 
Austria, France, Germany, Hungary, Italy, Poland, 
Portugal, Romania, Slovenia 
Spain 
18 
27 
France, Germany, Greece, Hungary, Ireland, Italy, Malta, 
Netherlands, Portugal, Spain 
Latvia 
2 
2 
Denmark, Estonia, Finland, Latvia, Poland, Sweden 
Netherlands 
1 
2 
Netherlands, Sweden 
Poland 
1 
1 
Poland 
UK 
4 
3 
UK 
TOTAL 
42 
85 
 
Source: EU Ecolabel E-Cat (last viewed on 07/08/2014) - http://ec.europa.eu/ecat/

61
 
Table 26: EU Ecolabel HDD products on the European market (EU-28) 
EU Member 
State 
No. of EU Ecolabel HDD products on 
the market* 
EU Member 
State 
No. of EU Ecolabel HDD products on 
the market*  
Austria 
4 
Italy 
14 
Belgium 
18 
Latvia 
3 
Bulgaria 
1 
Lithuania 
2 
Croatia 
0 
Luxembourg 
5 
Cyprus 
1 
Malta 
1 
Czech 
Republic 
5 
Netherlands 
9 
Denmark 
5 
Poland 
7 
Estonia 
1 
Portugal 
13 
Finland 
4 
Romania 
2 
France 
37 
Slovakia 
1 
Germany 
16 
Slovenia 
1 
Greece 
2 
Spain 
35 
Hungary 
3 
Sweden 
6 
Ireland 
5 
United 
Kingdom 
8 
* Note, this may include the same product in different size packaging – e.g. 500ml and 1L varieties, and so does not give an indication of 
the number of brands or product types available in each country.  
Source: EU Ecolabel E-Cat (last viewed on 20/08/2014) - http://ec.europa.eu/ecat/ 
 
In addition to the EU Ecolabel which operates across the EU-28, the Nordic Council has a set of Nordic Swan 
ecolabel criteria for HDDs. The Nordic Swan can be awarded to these items which are produced and marketed 
in its five Member States, i.e. Sweden, Denmark, Finland, Norway and Iceland. Due to the similarities between 
the EU Ecolabel criteria and the Nordic Swan criteria sets for HDDs65, it is worthwhile to identify the number of 
such products which carry this label on the European market (Table 27). 
 
Table 27: Number of Nordic Swan labelled HDDs on the EU-28 market 
Nordic Swan 
Country 
No. of Nordic Swan-labelled HDDs on the 
market 
Denmark 
70 
Norway 
8 
Sweden 
42 
Finland 
11 
Iceland 
0 
Total 
131 
Source: Danish Ecolabelling website/product catalogue, Norwegian Ecolabelling website/product catalogue, Swedish Ecolabelling 
website/product catalogue, Norway ecolabelling website/product catalogue 
 
Across Europe, the number of Nordic Swan labelled HDDs is higher than the number of EU Ecolabel products. 
For many small Scandinavian producers of HDDs it may be that the local market is more vital than the European 
market, and so the Nordic Swan label may be more familiar and accepted by producers and consumers alike. 
This may result in a lack of incentive for smaller producers to acquire both a regional label (Nordic Swan) and 
an EU Ecolabel. 
 
                                                             
 
65 Nordic Ecolabelling of Hand dishwashing detergents, 025 Hand dishwashing detergents, version 5.0, 28 May 2012. Available from 
http://www.nordic-ecolabel.org/criteria/product-groups/

62
There are a number of other national environmental labelling programmes operating in Europe that have 
criteria for HDDs, including: Austrian Ecolabel for Hand dishwashing detergents66 (about 15 HDDs have been 
awarded this label) and the Czech Ecolabel for detergents for hand dishwashing67.  
 
A number of labels are also used throughout the rest of the world, including: 
• 
Environmental Choice (New Zealand) label for HDDs.68  
• 
Good Environmental Choice (Australia) for HDDs.69 
 
2.9.4 
Consumer trends and market innovations 
The HDD market is highly competitive and price sensitive, although it is dominated by a few large brands 
alongside private label products. The scope for innovations in this market is somewhat limited to either the 
design or functionality of the container or the formulation of the detergent product. By adding additional value 
to the product, manufacturers are able to raise unit prices and maintain profit margins. 
 
2.9.4.1 
Fragrance 
The introduction of fragrance to cleaning products is a key trend, seen across a number of household product 
categories. Cleaning product launches often focus on fragrance, and this has become a point of differentiation 
between products which are otherwise very similar (including dishwashing detergents).70 Typically, most 
dishwasher detergent brands produce a range of products with various fragrances, tailored to each market. For 
example, the Fairy aromatics range of washing up liquid includes fragrances such as apple, pomegranate and 
tangerine & ginger. Persil has also launched a fresh scents range71 which, as well as including new ‘fresh’ 
fragrances (including  Apple Fizz, Orange Crush, Pink Blush and Lemon Burst), has been given new packaging 
to “stand out on the shelf”.72  
 
A number of the larger green cleaning brands also market products with a focus on fragrance, including 
Ecover’s hand dishwashing detergent (pomegranate & lime, chamomile & marigold, lemon & aloe vera and 
grapefruit & green tea73 scented) and Method’s dishwashing detergent which can be purchased in either 
clementine, cucumber, lemon mint or pink grapefruit scents.74 
 
In the US this trend has been taken further, and a washing up liquid with an air freshener attached to the 
base has been launched by Proctor & Gamble – designed to freshen the kitchen as well as clean the 
dishes.75  
 
In response to this increase of fragranced products, several brands are introducing fragrance-free HDDs - 
many of the more niche eco-brands already included fragrance-free HDDs in their product portfolios. More 
information about this is in Section 3.3.4.4 which outlines this opposing trend. 
 
                                                             
 
66 Austrian Ecolabel, hand dishwashing detergents, Available from https://www.umweltzeichen.at/cms/home/produkte/haushalt-und-
reinigung/content.html?rl=46 
67 Technical Guidelines, Detergents for hand dishwashing, V67, 2012, Ministry of Environment available from: 
http://www.cenia.cz/web/www/web-pub2.nsf/$pid/MZPMSFHMV9DV/$FILE/672012.pdf 
68 The New Zealand Ecolabelling Trust: Licence criteria for hand dishwashing detergents, EC-01-14, January 2014. Available from: 
http://www.environmentalchoice.org.nz/docs/publishedspecifications/ec0114_hand_dishwashing_detergents.pdf 
69 The Australian Ecolabel Program: Cleaning Products, Version 2.2 November 2013. Available from: 
http://www.geca.org.au/media/medialibrary/2012/08/GECA_15-2006_Hand_Dishwashing_Detergents_May_2012.pdf 
70 Datamonitor (2014) Datamonitor’s Market Data Analysis 
71 Available at: http://www.persildishwash.co.uk/hand-dishwashing#.U86K3fldWnQ 
72 Talking Retail (2011) Unilever relaunches Persil washing up liquid. [online] Available at: http://www.talkingretail.com/products-
news/household/unilever-relaunches-persil-washing-up-liquid/ 
73 Available at: http://uk.ecover.com/en/household-cleaning/product/washing-up-liquid#var103 
74 Available at: http://www.methodproducts.co.uk/prod_washingup.html 
75 Datamonitor (2007) New household goods review: a fresh approach for toilet seats. [online] Available at: 
http://www.datamonitor.com/store/News/new_household_goods_review_a_fresh_approach_for_toilet_seats?productid=B8EA70FB-
959A-419F-9850-6F5304AFBC56

63
2.9.4.2 
Additional benefits and functionality 
Adding an extra benefit or function to HDD allows manufacturers to maintain higher unit prices. Many recent 
launches of HDDs have concentrated on multi-functional aspects of the product. In particular, the focus has 
been on cleaning the sink whilst also cleaning the dishes. Typically, the sink area can suffer from odour 
problems and requires regular cleaning. Combining dishwashing detergent with a sink freshener is seen to add 
value to the product. Examples of these products include Colgate-Palmolive’s Dish + Sink range, which 
combines washing up liquid with a sink and drain freshener.76  
A similar product was launched in the US by Procter & Gamble; Dawn platinum erasing dish foam. This product 
aims to remove odours from plastic containers (such as lunchboxes or storage boxes) which may to be used for 
foods such as onions, fish or eggs, where odours permeate into the plastic.77 The dishwashing liquid therefore 
performs two functions: cleaning and removing odours from the containers.  
 
It is also increasingly common for products to offer ‘antibacterial properties’. For example, the Fairy anti-
bacterial range of HDDs claims to kill 99 % of germs in the washing up sponge as well as clean dishes. The 
product is advertised as offering “24 hour protection for your sponge”, which can quickly become unsanitary if 
not also regularly washed or replaced.  
 
In contrast to this focus on antibacterial cleaning, several HDDs have been formulated using edible ingredients, 
with the aim of reassuring consumers that these products are safe and can be used to wash fruit and 
vegetables. For example, Safe Sprouting Brown Rice by LG Household & Health Care Ltd contains rice extract 
which is traditionally used for dishwashing in South Korea.78  
 
Several products have also been marketed as suitable for washing up purposes, even if this is not their main 
purpose. These products include: Stardrops all round cleaner, which can be used for washing up as well as 
other cleaning (hard and textile surfaces, windows, bathrooms, kitchens etc.)79, and Cillit Bang Grease & 
Sparkle, which can be used to help with tougher, baked-on dirt when washing dishes. Both of these products 
are marketed as all-purpose (including the functionality to be used when washing dishes) and so are sold to 
consumers who would rather purchase one product rather than a range for all different purposes.    
 
2.9.4.3 
Premium products 
The HDD market is fairly homogenised in that there is little difference between the format of the product (i.e. 
liquid or gel) or even the type of bottle which the product is sold in. To establish a market share, it is therefore 
important for manufacturers to try and distinguish their product in terms of functionality. Efficacy of the 
product is important and a number of manufacturers have recently launched premium products which claim to 
work faster and better than others on the market.80  
 
For example, Procter & Gamble introduced the Fairy Platinum range in 2012, which claims to reduce the time 
needed to soak dishes from overnight to just 10 minutes. Due to this additional functionality, the product can 
be sold at a price premium. This trend has also been seen in the private labels, including Tesco’s Expert washing 
up liquid.  
 
2.9.4.4 
Mild on hands  
Dishwashing detergents are one of the few cleaning product which typically come into contact with consumers' 
skin in significant doses. Many manufacturers are responding to consumer demand and integrating skin care 
into hand dishwashing products. This is not necessarily a new development; Fairy washing up liquid was 
                                                             
 
76 MarketLine Industry Guide (2014) Household products. [online] Available at: http://www.reportlinker.com/ci02166/Household-
Products.html 
77 Euromonitor International (2007) Hand dishwashing still an attractive market for trendsetters. [online] Available at: 
http://www.marketresearchworld.net/content/view/1609/77/ 
78 Euromonitor International (2009) Global Household Case: Green Cleaning – Still an Oxymoron? September 2009 
79 Available at: http://www.stardrops.co.uk/ 
80 Transworld News (2014) UK dishwashing market: £418 million industry by 2017 [online] Available at: 
http://www.linkmyfan.com/1546444/id201160/p1/uk-dishwashing-market-418-million-industry-by-2017

64
originally marketed with the tag line “now hands that do dishes can feel soft as your face”. However, a number 
of products have been launched in the past few years which contain added lotions and moisturising agents.81  
 
In the UK, for example, Fairy clean and care (in fragrances including aloe vera & cucumber, rose & satin or 
chamomile & vanilla) has been developed to include Olay moisturiser. This product combination combines 
washing up with a luxury skin care brand, and allows the product to be sold at a price premium.  
 
Products created specifically for sensitive skin are also becoming more popular in both developed and 
developing markets. As a response to the proliferation of highly scented products on the market, a number of 
brands (most commonly the ‘eco-cleaning’ brands) are developing products which typically contain no/limited 
fragrance and natural products only. These products are marketed towards consumers with sensitive skin who 
may be irritated by dishwashing detergents. Examples of this include Ecozone sensitive washing up liquid and 
Ecover ZERO washing up liquid for sensitive skin. Proctor & Gamble also manufactures a ‘sensitive’ range of 
HDD which is marketed as being dermatologically tested. 
 
2.9.4.5 
Foaming dishwashing detergents 
The US has begun to see another trend emerging in the dishwashing detergents market; foaming cleaners. 
These foaming detergents rely both on the development of new dispensing systems, and on new formulations 
for the detergents themselves. One example of this is Palmolive’s Oxy Plus Foam, launched in 2006. The 
product consists of a pump top bottle which produces foam, instead of a liquid or gel. This product aims to 
offer convenience to consumers as there is no need to pre-soak dishes. Instead, the foam can be pumped onto 
a cloth or onto the dishes in order to clean.79  
 
A similar product type has been introduced by Method with its power foam dish soap.82 Again, this product 
consists of a pump top which produces a foaming detergent. Method also markets the convenience aspects 
and aims this product at consumers who lead busy lives or who do not produce enough dishes to justify filling a 
sink with water. Instead, the foam can be directly applied to a sponge or to individual dishes.  
 
 
2.10 Summary 
• 
The total retail value of the EU market for HDDs (EU-27 + CH + NO, 2012) is €1.8 billion.  
• 
The I&I market for all kitchen and catering detergents is valued at an estimated € 1.5 billion (this 
includes, but is not exclusively, HDDs). 
• 
It is expected that the HDD market will continue to grow, although in the coming years this will likely 
be a slower growth than the automatic dishwashing detergent market. Importantly, there is only 
partial trade-off between these two products (although if a household purchases a dishwasher it is 
expected that HDD sales will decrease somewhat), and even households with a dishwasher are likely 
to continue to wash some items by hand. 
• 
Private label household cleaning products are common across Europe and represent an estimated 
22 % of all brands available. The rest of the market is dominated by a small number of large 
manufacturers, including Reckitt Benckiser Plc (24 %), Procter & Gamble (13 %), Henkel (13 %), 
Unilever (12 %) and Colgate-Palmolive Co (4 %). 
• 
The HDD market is mainly domestic, with imports and exports primarily intra-EU. There is, however, a 
degree of extra-EU trade.  
• 
Innovation in the HDD market is relatively limited, and is primarily focused on adding additional 
functionality to the product. The larger brands drive this innovation, although many private label 
manufacturers have developed a range of own-brand products including a budget variety, premium 
products and environmentally friendly versions.  
                                                             
 
81 Euromonitor International (2007) Hand dishwashing still an attractive market for trendsetters. [online] Available at: 
http://www.marketresearchworld.net/content/view/1609/77/ 
82 Further information available at: http://www.methodproducts.co.uk/ind_powerfoam_pinkgrapefruit.html

65
• 
Consumer choice of HDD is driven by ease of use of the product, price, health and safety during use of 
the product and efficacy of the product. This has led to a number of developing trends in the cleaning 
market, in particular: the use of fragrance, the development of chemical free products (or products 
which include moisturising lotions) which are gentle on hands and a focus on premium products that 
claim to reduce the time required to wash-up or soak dishes.  
• 
Sustainability in the cleaning products market is becoming important for consumers, and therefore 
manufacturers. Innovations in the sustainable offerings include an increased use of green/plant-based 
chemicals and a focus on minimising packaging, however, for the time being this tendency is not 
enough to be fully representative at European level and/or properly quantified.

66
3. TECHNICAL ANALYSIS 
3.1 Technological aspects 
3.1.1 
Supply chain for HDD production 
An overview of the supply chain for home and fabric care products, including HDDs, is shown in Figure 8. 
Manufacturers of HDDs (formulators/blenders such as Procter & Gamble, Unilever and Henkel) acquire 
ingredients such as surfactants from speciality manufacturers and then blend these to produce HDDs. 
 
 
Figure 8: Supply chain for home and fabric care products 
 
The raw materials used for the production of detergent ingredients are obtained either from oleochemical 
sources or petrochemical sources. Oleochemical raw materials are derived from plant and animal fats; these 
include coconut oil, tallow, palm kernel oil and palm oil.83 These raw materials are often referred to as 
renewable raw materials. Petrochemical raw materials are derived from crude oil or natural gas; these 
materials are often termed synthetic. According to the American Cleaning Institute, there is no inherent 
environmental advantage to using surfactants from one source over the other and there are environmental 
trade-offs associated with both oleochemical and petrochemical sources.84  
 
Companies active in the European market for detergent speciality ingredients include Clariant, Rhodia, Solvay, 
Rohm & Hass, Cognis, Croda, Dow Corning, Elementis, Alco Chemical and BASF, amongst others. Within the 
home and fabric care ingredients sector, speciality surfactants hold the largest market share in Europe.85 
 
                                                             
 
83 Palm kernel oil, coconut oil, and palm oil are three of the few highly saturated vegetable fats; these oils give the name to the 16-carbon 
saturated fatty acid palmitic acid that they contain. Splitting of oils and fats by hydrolysis, or under basic conditions saponification, yields 
fatty acids, with glycerin (glycerol) as a byproduct. The split-off fatty acids are a mixture ranging from C4 to C18, depending on the type of 
oil/fat. The palm, palm kernel and coconut cultivation has been criticized for impacts on the natural environment, including deforestation, 
loss of natural habitats. In particular, the cultivation of palm has threatened critically endangered species such as the orangutan and 
Sumatran tiger and increased GHG emissions. Many palm oil plantations are built on top of existing peat bogs, and clearing the land for 
palm oil cultivation may contribute to GHG emissions. Source: Wikipedia 
84 Sustainability resources from the American Cleaning Institute, available from: 
http://www.cleaninginstitute.org/sustainability/some_facts_about_4.aspx 
85 Henkel (2011) The world of fragrances; how washing and cleaning can affect the senses. Available at: http://www.henkel.com/henkel-
headlines/news-2011-20111024-the-world-of-fragrances-34010.htm

67
3.1.2 
Description of the HDD production processes 
The first step of HDD detergent production is to select the ingredients. This is done according to several criteria 
which will typically include cost, sustainability, human health, environmental safety and performance. 
Detergent manufacturers use different approaches to ensure that their products have the least impact on the 
environment and human health. One example of such an approach is the Greenlist™ process developed by 
SC Johnson, which scores ingredients by their impact on the environment and human health.  Using the 
process, a final product score is obtained which takes into consideration the environmental classifications of 
both chemical and packaging constituents.   
 
The manufacturing process employed for HDD products in general consists of mixing and pumping the 
ingredients into mixing vessels. The exact process employed will depend on the manufacturer and the format 
of the final product. Liquid detergents are produced either in a batch process or a continuous process. The 
batch process is the simplest: ingredients are introduced to an agitated tank, and additional mixing or heating 
can be provided through a recirculation loop.  In comparison, continuous processes are more sophisticated and 
better suited to large-scale operations. In a continuous process both dry and liquid ingredients are added and 
then blended using in-line mixers. The final manufacturing process for HDDs is packaging and typically involves 
plastic bottles. 
 
A more detailed explanation of the production process of the detergents and the chemistry involved can be 
found in Annex VIII.  
 
3.1.3 
HDD detergents ingredients 
HDDs are expected to clean all types of soil from dishware, to have copious long lasting foam, to be mild to 
hands and to have a pleasant fragrance86 and are mainly composed of surfactants, preservatives, and additives. 
More information on detergent ingredients can be found in Annex I. HDDs are primarily a mixture of 
surfactants dispersed in water and these are used to remove and emulsify fats and aid with wetting. Commonly 
used anionic surfactants include alcohol ethoxylates such as LAS, alkane sulfonates and alkypolyglycosides.83 
HDDs must be safe and not damaging to the environment and therefore environmental parameters such as 
biodegradability, aquatic toxicity and bioaccumulation need to be taken into account. Further, they should be 
non-sensitizing and non-irritating. Further detail on specific detergent ingredients and their environmental 
performance will be provided in the technical report. 
 
3.1.4 
User behaviour 
The consumer behaviour and dishwashing techniques throughout Europe have been studied among others by 
Prof. Dr. R. Stamminger and colleagues. Stamminger et al.87 found that an important reason for not having a 
dishwasher at home is that there is not enough room in the kitchen. Other reasons include the number of 
people living in a household, and the performance and consumption values of automatic dishwashing. Nearly 
everybody has their ‘own way’ of manual dishwashing. Many variations and combinations of processes can be 
observed, ranging from a series of four ‘baths’ for each item to be washed (i.e. soaking, preliminary cleaning, 
cleaning, rinsing), to the use of continuously running hot water for about 30 % of the study group. The level of 
soiling and the number of items to be cleaned also influenced dishwashing behaviour. 
 
The dishwashing behaviour of individuals was found to be surprisingly constant and not likely to be a matter of 
coincidence.87 Consumer behaviour and dishwashing techniques greatly affect the amount of resources 
needed, i.e. water, energy, time, detergent.85 Nevertheless, none of these resources showed a dominant 
influence on the cleaning performance individually. Therefore, differences in cleaning performance can be 
attributed to differences in dishwashing techniques, such as clever water management or the amount of 
mechanical power applied.  
                                                             
 
86 Handbook of Detergents, Part F: Production, Surfactant Science Series Volume 142, Uri Zoller and Paul Sosis, CRC Press, 2009. 
87 Stamminger R, A Elschenbroich, B Rummler, G Broil, 2007. Washing-up Behaviour and Techniques in Europe. Hauswirtschaft und 
Wissenschaft, 1, 31–37.

68
 
Fuss et al.88 formulated best practice tips and studied whether they can be used to save resources by affecting 
behavioural changes. The researchers focused on common household conditions, such as large amounts of 
dishes, and observed a reduction in the use of resources (around 60 % less water, 70 % less energy, and 30 % 
less detergent) when the best practice tips were applied. A study by Stamminger and colleagues89 showed that 
the average water consumption increases if the load to be cleaned is divided into smaller portions, from on 
average 103 litres for twelve place settings in one go to more than 121 litres for six times two place settings. 
 
Consumers’ attitude towards best practice tips is generally positive.86 Although some concerns exist about their 
exact application in everyday life, the tips are generally highly accepted.  
 
 
3.2 LCA review 
Prior to performing an LCA analysis on the environmental performance of HDDs along their life cycle, a detailed 
LCA screening of publicly available studies was carried out. This screening has allowed the identification of the 
main environmental hotspots and their alternatives for this product group as well as the evaluation of the need 
for performing additional studies.  
 
3.2.1 
Selection criteria 
Relevant LCA studies were identified in literature and critically reviewed for the robustness of their results. The 
criteria considered for this assessment were:  
• 
Subject of the studies: The analysed products should have representative features of the product 
group, sub-categories, technologies or specifications.  
• 
Functional unit (FU): The FU refers to a quantified performance of a product system for use as a 
reference unit in LCA studies. 
• 
Time-related coverage of data: This refers to the year the inventory data of the analysis is based on; 
studies should ideally be less than 4 years old.  
• 
Comprehensiveness and robustness: This refers to the environmental impacts considered in the 
study. Impact categories should be comprehensive, ideally reflecting the European Commission’s 
Product Environmental Footprint (PEF) methodology or other recognized LCA methodologies and 
scientifically robust when considered against the evaluation provided in the JRC’s ILCD Handbook. 
Studies should also be cradle-to-grave.  
• 
Reliability: This refers to the information and the data quality provided by the authors. Studies should 
ideally be subject to an external critical review. 
 
The different studies' compliance with the ISO standards for life cycle assessment (ISO 14040 and 14044) was 
considered as well as the information provided regarding: 
• 
Cut-off criteria: According to the ISO 14040/44:2006 and the ILCD Handbook, cut-off criteria should be 
documented in an LCA study. The reasons for assuming cut-offs should be stated and their effects on 
results should be estimated. 
• 
Allocation: Allocation rules should be documented in the description of the studies. 
• 
Data quality requirements and data sources: Data quality level and sources of primary and secondary 
data should be documented, e.g. information on the geographical and technological 
representativeness of the selected LCA studies. 
• 
Assumptions: Information and documentation of the important assumptions is crucial to ensure the 
transparency and reproducibility of the results. Therefore, information about the assumptions made 
whilst modelling, should be provided.  
                                                             
 
88 Fuss N, S Bornkessel, T Mattern, R Stamminger, 2011. Are resource savings in manual dishwashing possible? International Journal of 
Consumer Studies, 35: 194–200 
89 Stamminger R, Rummler B, Elschenbroich A, Broil G, 2007. Dishwashing under various consumer-relevant conditions. Hauswirtschaft und 
Wissenschaft, 2, 81–88.

69
It should be noted that the number of available LCA studies on HDDs is very limited; in fact only three studies 
were identified. No reports were excluded by the selection criteria described above. 
 
3.2.2 
Detailed revision and quality assessment of available studies 
The number of publicly available LCAs on HDDs is very limited. Three studies were identified which described 
the environmental impacts of HDDs from a life cycle perspective, as summarised below and in Table 28.  
 
1. Van Hoof et al.90 described in IEAM a life cycle-based water assessment of a hand dishwashing product 
using a number of water assessment methods. Their goal was to identify product improvement 
opportunities and get an understanding of the potential for underlying database and methodological 
improvements.  
2. Van Hoof et al.91 showed in IJLCA three different normalization approaches that produce very different 
ranking of indicators, and can be used to select indicators in order to simplify LCA. The approaches are 
illustrated on a hand dishwashing case study.  
3. The International Association for Soaps, Detergents and Maintenance Products (AISE) carried out a 
generic LCA on dishwashing detergents for manual dishwashing.92 
 
Table 28: Publicly available LCAs on dishwashing detergents 
Source  
Van Hoof et al, 2013 (IEAM) 
Van Hoof et al, 2013 (JLCA)
AISE. 2014  
(Charter update 2010. Version 
1 January 2014) 
Title  
Life cycle-based water 
assessment of a hand 
dishwashing product: 
opportunities and limitations
Indicator selection in life 
cycle assessment to enable 
decision making: issues and 
solutions 
ASP substantiation dossier: 
Household manual 
dishwashing (MDW) 
detergents. 
Subject of the 
study and goal 
A number of water 
assessment methods were 
applied to a hand 
dishwashing product with 
the purpose of identifying 
both product improvement 
opportunities, as well as 
understanding the potential 
for underlying database and 
methodological 
improvements.  
The use of a single formula 
with the same global supply 
chain, manufactured in one 
location was evaluated in 
two countries with different 
water scarcity conditions. 
Normalization could be a 
means to narrow the list of 
indicators by ranking 
indicators vs. a reference 
system, and thereby 
simplifying LCA. This paper 
shows three different 
normalization approaches 
that produce very different 
ranking of indicators. The 
approaches are illustrated 
on a hand dishwashing case 
study. 
Get an understanding of the 
environmental impacts of the 
various stages of the 
detergent’s life cycle of 
household manual 
dishwashing (MDW) 
detergents. 
Study type  
LCA 
LCA 
Screening LCA 
Functional Unit 
Hand dishwashing 10 plates 
Hand dishwashing 14 
plates 
5 L of wash water 
System 
boundaries  
Cradle to grave 
Cradle to grave 
Cradle to grave: 
manufacturing, formulation, 
packaging, transport, use 
                                                             
 
90 Van Hoof G, B Buyle, A Kounina, and S Humbert 2013. Life cycle-based water assessment of a hand dishwashing product: Opportunities 
and limitations. Integr Environ Assess Manag, 9: 633–644 
91 Van Hoof G, M Vieira, M Gausman, A Weisbrod 2013. Indicator selection in life cycle assessment to enable decision making: issues and 
solutions. Int. J. LCA. 18(8):1568-1580 
92 AISE. 2014. Charter update 2010. ASP substantiation dossier: Household manual dishwashing (MDW) detergents. Version 1 January 2014

70
Source  
Van Hoof et al, 2013 (IEAM) 
Van Hoof et al, 2013 (JLCA)
AISE. 2014  
(Charter update 2010. Version 
1 January 2014) 
phase, end of life 
Time related 
coverage  
Primary data source not 
specified. Study is from 
2013. Secondary data are 
from Ecoinvent v2.2 (2010). 
Primary data source not 
specified. Study is from 
2013. Secondary data are 
from Ecoinvent v2.2 (2010). 
Data collection for relevant 
LCA parameters in 2011 and 
2013 
Reliability (data 
quality, external 
critical review?) 
Peer reviewed scientific 
article 
Peer reviewed scientific 
article 
The ASPs and the 
substantiation dossier were 
subject to consultation with 
Charter member companies 
and other interested parties 
(industry/external 
stakeholders) 
Impact 
assessment  
Midpoint: 
1. Swiss ecological scarcity 
(Frischknecht et al. 2006) 
2. Blue water consumption 
(Boulay et al. 2011) 
3. Blue water consumption 
(Pfister et al. 2009) 
4. Blue and gray water 
consumption (Ridoutt and 
Pfister 2010) 
5. Method evaluating blue 
and green water 
(Milà-i-Canals et al. 2009) 
 
Endpoint: 
6. Terrestrial species 
diversity from blue water 
consumption (Pfister et al. 
2009) 
7. Terrestrial species 
diversity from renewable 
groundwater 
consumption (Van Zelm et 
al. 2011) 
8. Aquatic species diversity 
from thermally polluted 
water (Verones et al. 
2010) 
ReCiPe v1.07 
1. climate change 
2. ozone depletion 
3. photochemical oxidant 
formation 
4. particulate matter 
formation 
5. human toxicity 
6. terrestrial acidification 
7. freshwater 
eutrophication 
8. marine eutrophication 
9. terrestrial ecotoxicity 
10. freshwater ecotoxicity 
11. marine ecotoxicity 
12. agricultural land 
occupation 
13. urban land occupation 
14. natural land 
transformation 
15. water depletion 
16. metal depletion 
17. fossil depletion 
Method not specified 
1. Climate change 
2. Ozone depletion 
3. Photochemical oxidant 
formation 
4. Particulate matter 
formation 
5. Ionising radiation 
6. Terrestrial acidification 
7. Eutrophication 
8. Agricultural land occupation
9. Urban land occupation 
10. Natural land transformation 
11. Metal depletion 
12. Fossil depletion 
 
 
 
Table 29 presents an overview of the comprehensiveness based on the PEF methodology.

71
 
Table 29: Evaluation of comprehensiveness based on the PEF methodology 
EF impact 
category 
EF impact 
assessment 
method 
EF impact 
category 
indicators 
Source 
Van Hoof et al, 
2013 (IEAM) 
Van Hoof et al, 
2013 (JLCA) 
Climate change  
Bern model - 
Global Warming 
Potentials (GWP) 
over a 100 year 
time horizon 
kg CO2 equivalent  
Inter-
governmental 
Panel on Climate 
Change, 2007  
0 
+ 
Ozone depletion  
EDIP model based 
on the ODPs of the 
World 
Meteorological 
Organization 
(WMO)  
kg CFC-11 
equivalent  
WMO, 1999  
0 
0 
Ecotoxicity for 
aquatic fresh 
water  
USEtox model  
CTUe 
(Comparative 
Toxic Unit for 
ecosystems) 
Rosenbaum et al., 
2008  
0 
00 
Human toxicity - 
cancer effects  
USEtox model  
CTUe 
(Comparative 
Toxic Unit for 
humans)  
Rosenbaum et al., 
2008  
0 
0 
Human toxicity – 
non-cancer effects  
USEtox model  
CTUe 
(Comparative 
Toxic Unit for 
humans)  
Rosenbaum et al., 
2008  
0 
0 
Particulate 
matter/  
respiratory 
Inorganics  
RiskPoll model  
kg PM2.5 
equivalent  
Humbert, 2009  
0 
0 
Ionising radiation 
– human health 
effects  
Human Health 
effect model  
kg 235U equivalent 
(to air)  
Dreicer et al., 1995 
0 
0 
Photo-chemical 
ozone formation  
LOTOS-EUROS 
model  
kg NMVOC 
equivalent  
Van Zelm et al., 
2008 as applied in 
ReCiPe  
0 
0 
Acidification  
Accumulated 
Exceedance model  
mol H+ eq  
Seppälä et al., 
2006; Posch et al., 
2008  
0 
0 
Eutrophication – 
terrestrial  
Accumulated 
Exceedance model  
mol N eq  
Seppälä et 
al.,2006; Posch et 
al., 2009  
0 
0 
Eutrophication – 
aquatic  
EUTREND model  
fresh water: kg P 
equivalent marine: 
kg N equivalent  
Struijs et al., 2009 
as implemented in 
ReCiPe  
0 
0 
Resource 
depletion – water  
Swiss Ecoscarcity 
model  
m3 water use 
related to local 
scarcity of water  
Frischknecht et al., 
2008  
+ 
Frischknecht et al. 
2006 
- 
(Ecoinvent 
datasets, water 
depletion (m3) but 
no degradative 
use and depletion 
potential) 
Resource 
depletion – 
mineral fossil 
CML2002 model 
kg antimony (Sb) 
equivalent  
van Oers et al., 
2002 
0 
- 
(ReCiPe, kg oil eq. 
based on their 
heat content) 
Land trans-
formation  
Soil Organic 
Matter (SOM) 
model  
Kg (deficit)  
Milà i Canals et al., 
2007  
0 
0

72
EF impact 
category 
EF impact 
assessment 
method 
EF impact 
category 
indicators 
Source 
Van Hoof et al, 
2013 (IEAM) 
Van Hoof et al, 
2013 (JLCA) 
Energy 
consumption 
Not applied 
Decrease in energy 
available 
 
0 
0 
The number of environmental impact categories that are investigated within 
the studies  
1 
3 
The number of impact categories that are the same as PEF but don’t use the 
same methodology  
1 
2 
The number of impact categories compliant with the PEF methodology, i.e. use 
the same methodology  
1 
1 
N.B. the AISE study has been left out of this table as the exact method was not specified  
+ = compliant with the requirements of the PEF methodology 
- = not compliant with the requirements of the PEF methodology 
0 = not taken into account 
1. Although a 100 year time horizon is not explicitly mentioned, we assume that GWP100 is investigated 
2. Characterisation model not explicitly mentioned   
 
3.2.3 
LCA review: results 
Van Hoof et al.88 evaluated a single formula with the same global supply chain, manufactured in one location 
but used in either Spain or Germany – two locations with different water scarcity conditions. This study looked 
at the opportunities and limitations of life-cycle based water assessment using hand dishwashing detergents as 
a case study. They used different assessment methods to identify improvement opportunities for HDD products 
and related LCA database and methods. The study showed differences ranging up to 4 orders of magnitude for 
indicators with similar units associated with different water use types (inventory methods) and different cause–
effect chain models (midpoint and endpoint impact categories). For the inventory methods, the water 
inventory category results with turbined water use were about 4 orders of magnitude higher compared to the 
category with green water consumption. Similar differences were observed between midpoint results (4 orders 
for those with similar units) and the endpoint results (3 orders of magnitude). Without uncertainty information, 
these differences are associated with the different water use types (inventory categories) or cause–effect 
chains modelled (midpoints and endpoints). 
 
Van Hoof et al.88 concluded that the use stage was the most important life cycle stage for most of the methods 
evaluated (> 90 %). Depending on the method, either the tap water used in the cleaning process (direct use) or 
the water use in the background processes associated with electricity production (indirect use) were 
predominant.  
 
Databases covering a broad spectrum of inventory data with spatially differentiated water use information are 
notably lacking.  Furthermore, there is uncertainty in some impact methods because it is not known whether or 
not characterization factors should be spatially differentiated. Spatial differentiation may lead to very different 
results for the product used under exactly the same consumer use conditions, making the interpretation and 
communication of results difficult. 
 
Table 30: Summary of study by Van Hoof et al. 
Item 
Observation 
Title 
Life cycle-based water assessment of a hand dishwashing product: opportunities and 
limitations 
Authors 
G van Hoof, B. Buyle, A. Kounina and S. Humbert 
Reference and 
year 
Integrated Environmental Assessment and Management, 9, 4 663-644 2013 SETAC 
Scope 
Comparison of a selection of water assessment methods to be applied to two HDD 
scenarios 
Type of study 
Cradle to grave LCA  
Functional unit 
and reference flow 
FU: 10 plates 
RF: 2.4 or 4.8 g of HDD / 10 plates depending on the scenario

73
Item 
Observation 
System 
boundaries  
The production of raw materials (both for the product and the packaging), the 
formulation of raw materials into a HDD formula, the package-making operation, 
distribution of the packed product, the use of the product by consumers and the final 
disposal of the packaging as well as the wastewater treatment of the down-the-drain 
emissions 
Assumptions  
(e.g. allocation) 
Geographical scope is the production of the ingredients at eh suppliers manufacturing 
locations, the manufacturing of the product in London (UK) and the use and end-of-life 
of HDD product in Germany and Spain. 
Some assumptions were needed given that the source of some elementary water flows 
is unspecified in Ecoinvent. In those cases, a conversion factor is defined to quantify 
how much water from the unspecified source originates from groundwater, lakes, etc. 
as  
Data sources & 
quality 
Primary data: formula and packaging information and specific removal of chemicals in 
sewage treatment 
Secondary data: Ecoinvent 2.2 (2010)  
Impact 
assessment 
 
categories/metho
ds 
Three types of methods were analysed. 
-  inventory methods that classified elementary water flows according to their type 
(origin of water resource, intake water quality, etc) and their use (off-stream, in-
stream, consumptive/degradative use) into water inventory categories.  
-  midpoint methods that uses WSI are based on water withdrawal or on water 
consumption 
-  endpoint methods are focused on the ecosystem quality AoP, reflecting changes in 
species diversity, expressed as the potentially disappeared fraction of species 
integrated over space and time. Two type of end-point methods are considered in 
this study: one that models diversity impacts on aquatic species and other that 
models diversity impacts on terrestrial plant species.  
Check Error! Reference source not found. for the impact assessment categories 
considered.  
Conclusions  
(e.g. most 
important LC 
phases; drivers to 
impacts, process 
or material; 
improvement 
options) 
Two aspects were highlighted in the results as being of key importance: a) the 
availability of good data, and b) the spatial differentiation. 
Regarding spatial differentiation, the results may differ up to 25 % depending on local 
considerations. For example, in this study the differences were attributed to the 
differences in the electricity grid, the sourcing of tap-water and the differences in the 
sewage treatment infrastructure and municipal solid waste treatment.  
LCA studies show that the use stage is the most important life cycle stage for the 
majority of the methods evaluated in this study. Interestingly, depending on the 
method, either the tap-water used in the cleaning process (direct use) or the water 
used in the background processes associated with electricity production (indirect use) 
were predominant.  
Critical review 
Yes 
 
In another study by Van Hoof et al.89, three different normalization approaches that produce very different 
ranking of indicators were compared in a hand dishwashing case study. If the results are broken down by their 
key driving midpoints, the most important impact categories are: fossil depletion, climate change and, to a 
lesser extent, particulate matter formation and metal depletion. However, if the results are broken down by 
their midpoint normalisation, the most important impact categories are: freshwater eutrophication, natural 
land transformation and toxicity indicators (marine and freshwater ecotoxicity and human toxicity). For human 
toxicity, the indicator is totally independent of the product composition and relates to electricity use for 
heating water during the use stage. For freshwater toxicity, Van Hoof et al. found that waterborne emissions 
after sewage treatment are the key driver behind the indicator.  
 
The key driving endpoints (reported per midpoint impact category) are fossil depletion and climate change, 
followed by particulate matter formation, human toxicity and metal depletion. All other indicators are 2 orders 
of magnitude or more lower. The study concludes that the most relevant area of protection are resources, 
closely followed by human health and ecosystems.

74
Table 31: Summary of study by Van Hoof et al. 
Item 
Observation 
Title 
Indicator selection in life cycle assessment to enable decision making: issues and 
solutions 
Authors 
G van Hoof, M. Vieira, M Gausman, A. Weisbrod 
Reference and year 
IJLCA (2013) 18: 1568-1580 study based on data from 2000 
Scope 
Assessment of the normalization methods to narrow the list of indicators by ranking 
indicators vs a reference system. 
Type of study 
Cradle to grave LCA of a HDD product developed by P&G 
Functional unit and 
reference flow 
FU: dishwashing 14 plates 
RE; 4.5 g of HDD 
System boundaries  
The production of the raw materials (both the product and the packaging), the mixing 
of raw materials into a HDD formula, the packaging making operation, distribution of 
the packed product, the use of the product by consumers, and the final disposal of the 
packaging as well as the waste water treatment of the down-the-drain emissions 
Assumptions  
(e.g. allocation) 
All sewage is considered to undergo secondary treatment 
The geographical scope is Europe 
Data sources & 
quality 
Primary data 
Secondary data: Ecoinvent v2.2 (2010) 
Impact assessment 
 
categories/methods 
Simapro using ReCiPe v1.07 
Three approaches to apply normalization in a combined midpoint-endpoint method 
Check Error! Reference source not found. for the impact assessment categories 
considered. 
Conclusions  
(e.g. most 
important LC 
phases; drivers to 
impacts, process or 
material; 
improvement 
options) 
LCA is an important tool within a sustainability framework because it is a multi-
indicator approach and is relative in nature, allowing the comparison of different 
improvement options. On the other hand, decision making is made easier when results 
are presented in a way that is focused on environmentally relevant information using 
objective criteria to the extent possible. 
Because there are no means to scientifically define whether an LCA indicator is close to 
or exceeds a threshold, it is impossible to understand its importance and therefore the 
discussion about the important indicators becomes a value-based discussion.  
Normalizing LCA results helps to rank indicators relative to a given existing situation. 
Therefore, even when indicators are ranked, the fact that a selection is made based on 
this ranking implies a value choice (usually by assuming they are equally important). 
Nevertheless, it is judged to be preferable as it starts from the assumption that 
decision makers strive to improve vs the reference and focus on indicators with high 
contribution. 
Applying these findings to the improvement options for HDD, single footprints would 
not be considered if a multi-indicator approach is the basis for decision making. If 
decision making is based on objective criteria, weighting (single scores) is not possible. 
Normalization vs a reference system could be a solution to rank indicators and make 
decisions on the indicator with high ranking.  
If product comparison or improvement options would be selected as the basis for 
decision making, this could lead to situations where products are claimed to be 
preferable or improved on an environmental attribute which is not meaningful or 
which is largely overestimated. This is not a sound basis for making claims or 
communicating benefits/attributes to third parties. If endpoint normalization is 
selected, fossil fuel and climate change would be those with highest ranking. Fossil fuel 
and metal depletion and climate change are all related to the heating of water during 
the use stage. Innovations that lead to products with better performance at low 
temperature, or saving water use, are therefore expected to lead to meaningful 
improvements. Products that lead to changing consumer behaviour toward saving 
water or lower water temperature are a second improvement option. Sourcing HDD 
raw materials that are less dependent on fossil resources is a third improvement 
option, but with a lower improvement potential 
Critical review 
Yes

75
 
In the ASP substantiation dossier90, the LCA by the International Association for Soaps, Detergents and 
Maintenance Products (AISE) showed that the life cycle stage with the largest contribution to the 
environmental impact for household manual dishwashing detergents in Europe is the use phase, particularly 
the energy needed to heat water during manual dishwashing. Furthermore, the concentration of a HDD 
product was identified as one of the key factors to reduce the environmental impact.  
 
Table 32: Summary of study by ASP 
Item 
Observation 
Title 
ASP substantiation dossier: Household manual dishwashing (MDW) detergents. 
Authors 
Experts of nine companies: Colgate Palmolive, Dalli, Henkel, Jeyes, Luhns, McBride, 
P&G, Reckitt Benckiser and Unilever 
Reference and year 
2011-2013 
Scope 
Household manual dishwashing detergents 
Type of study 
LCA  
Functional unit and 
reference flow 
 
System boundaries  
Stage of the life cycle process considered were: manufacturing, formulation , 
packaging, transport, use phase and end-of-life 
Assumptions  
(e.g. allocation) 
 
Data sources & 
quality 
 
Impact assessment 
 
categories/methods 
The impact categories evaluated were: climate change, ozone depletion, 
photochemical oxidant formation, ionising radiation, terrestrial acidification, 
eutrophication, agricultural land occupation, urban land occupation, natural land 
transformation, metal depletion and fossil depletion.  
Conclusions  
(e.g. most 
important LC 
phases; drivers to 
impacts, process or 
material; 
improvement 
options) 
LCA shows for HDD in Europe the use phase has the largest contribution to the 
environmental impact, particularly the energy needed to heat water during manual 
dishwashing.  
Given that manual dishwashing detergents end up as water-borne waste, it is essential 
that a more sustainable product poses a significantly reduced risk environment.  
Using the LCA as a starting point, several improvement measures were identified:  
- determining a maximum dosage of ingredients per job 
- determining a maximum level of packaging materials per job 
- setting a minimum level of recycled content in primary and secondary packaging 
- providing on-pack guidance for the most sustainable product use 
Critical review 
No 
 
3.2.4 
Summary of the findings / Summary of the key environmental impacts for hand dishwasher 
detergents 
Although the scopes and goals of the reviewed LCA studies vary, most of them draw similar conclusions that 
are summarised in this section. From a life cycle perspective the major environmental impacts associated with 
hand dishwashing detergents are due to: 
• 
The energy used for heating the washing water during the use stage, which significantly contributes to 
the energy use impact category. Additionally, energy use has an impact in other categories such as 
fossil fuel depletion and global warming potential.  
• 
The extraction and processing of raw materials that causes an impact on categories such as mineral 
depletion, land use and energy use. 
• 
The emissions to the environment (water) after use. The discharge of wastewater has impacts on 
eutrophication while the impacts due to the end-of-life of packaging materials depend on their 
possible scenarios. 
 
The reviewed studies identified opportunities for product improvement that can be summarised as follows:

76
• 
Detergent compaction, by providing consumers with a maximum dosage and adjusted detergent 
formulation 
• 
Reduction in dishwashing water temperature and amount of water used by providing on-pack 
guidance for the most sustainable product use 
• 
Reduction of packaging materials by determining a maximum level of packaging materials per job 
and setting a minimum level of recycled content in primary and secondary packaging 
 
 
3.3 Non-LCA impacts 
3.3.1 
Toxicity to aquatic organisms 
Toxicity to aquatic organisms is evaluated using Critical Dilution Volume (CDV). CDV was originally 
developed as an evaluation criterion for detergent ingredients in the context of the European Eco-label 
scheme93,94. It expresses the substance-specific amount of water needed for dilution to a safe level, and is 
therefore expressed in L per functional unit (FU). The Detergent Ingredient Database (DID) List, a public 
source of agreed ecological data for detergent production ingredients, can be used to perform CDV 
calculations as well as laboratory and in silica test results. The outcomes can be considered as a product-
based relative assessments, on the basis of a functional unit – dose per wash95,96. 
 
CDV calculations are based on the dosage, degradation and toxicity of a substance using the formula 
below:  
∑
∑
⋅
⋅
=
=
)
1000
)
TF
/
)
DF
dosage
(((
CDV
CDV
i
i
i
i
 
Where dosagei is the recommended dosage expressed in g per wash, DFi is the degradation factor and TFi 
is the toxicity factor.  
 
 
3.3.1.1 
Toxicity  
Per chemical, a chronic toxicity ‘base set’ of three species should ideally be collected (fish, crustaceans 
and algae). The lowest toxicity value of these three values is then used for CDV calculations. The toxicity 
test results to be used can be expressed as the effect concentration at different percentages of effect, e.g. 
EC10 or EC50, which is the calculated effect concentration at 10 % or 50 % effect, or LC50, which is the 
concentration at 50% lethality. Measured effects may be on for example growth rate, immobility or 
mortality, depending on the test organism.  
 
As there are substances with very small amounts of chronic toxicity data or which only have been tested 
for acute toxicity, there is a need to distinguish between these and other substances where the toxicity 
factors are based on more solid grounds. TF is calculated as the lowest value of toxicity test results 
complemented by a safety factor (SF) that is based on the availability of aquatic toxicity data and ranges 
from 10 to 10000.  
 
                                                             
 
93 EU Eco-label 1995. Commission decision of 25 July 1995 establishing the ecological criteria for the award of the  
community ecolabel to laundry detergents. Official J European Communities L217:0014–0030, 95/365/EC 
94 Van Hoof G., D. Schowanel, H. Franceschini, I. Muñoz, 2011. Ecotoxicity impact assessment of laundry products: a 
comparison of USEtox and critical dilution volume approaches. Int J Life Cycle Assess, 16:803–818 
95 DID list (2007) Detergent Ingredient Database (DID list) – 2007 version.  
http://ec.europa.eu/environment/ecolabel/ecolabelled_products/categories/did_list_en.htm (accessed 17/12/2010) 
96 DID list Part B (2004) Detergent ingredients database version 30 June 2004. 
http://ec.europa.eu/environment/ecolabel/ecolabelled_ products/categories/did_list_en.htm. Accessed 17 Dec 2010

77
3.3.1.2 
Degradation 
Degradation of substances in CDV calculations is taken into account through the Degradation Factor which 
considers the ready biodegradability of a substance97. It can take four discreet values ranging from 0.05, if 
an ingredient is degraded in under 5 days, to 1, if an ingredient is persistent in the environment. An 
exceptional 5th value, 0.01, was introduced in the 2014 version of the DID list that is only assigned to very 
toxic substances that degrade extremely rapidly.  
 
DF only considers biodegradation and not adsorption. This choice was made in the scope of the EU 
Ecolabel as adsorpted substances end up in sludge and the presence of harmful substances in sludge can 
cause problems when the sludge is used as a fertilizer.  
 
3.3.1.3 
DID list 
The DID-list is a public tool containing toxicity and degradation information on over 200 commonly used 
ingredients in detergents and cosmetics. The DID list is revised on regular basis to update existing entries 
and introduce new ones, based on input from industry, competent bodies and ecotoxicology 
specialists.Error! Bookmark not defined. The list is meant to facilitate the work of companies applying for EU 
Ecolabel and that of competent bodies reviewing applications. Besides listing input data for CDV 
calculations, it also provides companies, especially SMEs, with an easy way of comparing and ranking 
ingredients, making it possible for them to spot a possible substitution that would result in a less 
impacting product.  
 
Error! Reference source not found. shows an example of the information available for common detergent 
ingredients in the DID-list. 
 
Table 33: Toxicity values and degradation data for example detergent ingredients in the DID-list 98 
Acute toxicity 
Chronic toxicity 
Degradation 
 
 
DID number 
 
 
Ingredient name 
LC50 / 
EC50 
SF 
(acute) 
TF 
(acute) 
NOEC 
SF 
(chronic)
TF 
(chronic)
DF 
Aerobic 
Anaerobic
DID category: Cationic surfactants 
2301 
 
C8-16 
alkyltrimethyl or 
benzyldimethyl 
quaternary 
ammonium salts 
0,08 
1000 
0,00008 
0,0068 
10 
0,00068 
0,05 
R 
O 
DID category: Other ingredient 
                            Surfactants 
2505 
Zeolite (Insoluble 
Inorganic)  
100 
1000 
0,1 
100 
50 
2 
1 
NA 
NA 
                            Builders 
2507 
Polycarboxylates 
homopolymer of 
acrylic acid  
40 
1000 
0,04 
12 
10 
1,2 
1 
P 
N 
2508 
Polycarboxylates 
copolymer of 
acrylic/maleic acid  
100 
1000 
0,1 
5,8 
10 
0,58 
1 
P 
N 
                            Bleachers 
2525 
Perborates (as 
Boron) 
14 
1000 
0,014 
 
 
0,014 
1 
NA 
NA 
2526 
Percarbonate 
4,9 
1000 
0,0049 
0,7 
50 
0,014 
0,01 
NA 
NA 
                                                             
 
97 OECD Ready Biodegradability test - http://www.oecd-ilibrary.org/environment/test-no-301-ready-biodegradability_9789264070349-en 
98  Detergents Ingredients Database (DID-list) Part A. List of ingredients 2014

78
                            Auxiliaries 
2533 
Carboxymethylcell
ulose (CMC) 
250 
5000 
0,05 
 
 
0,05 
0,5 
I 
N 
R = Readily biodegradable according to OECD guidelines, I = Inherently biodegradable according to OECD guidelines, P = 
Persistent. The ingredient has failed the test for inherent biodegradability, 0 = The ingredient has not been tested, NA = Not 
applicable, N = Not biodegradable under anaerobic conditions 
 
 
3.3.2 
Risk assessment of chemical release 
The emissions occurring during the life cycle of HDDs may have negative health effects on humans and 
ecosystems. Air emissions occur primarily during the ingredients sourcing and use. The emissions are directly 
correlated to the energy generation from fossil fuels, and therefore proportionally related to the amount of 
energy required in the use phase. The energy source plays a role in the environmental impacts; the lower the 
fossil fuel share in the national mix, the lower the impacts of the overall life cycle.   
 
3.3.3 
Sustainable sourcing 
In order to protect nature, sourcing of ingredients for HDDs and their packaging materials should be done in a 
sustainable way i.e. one which takes into account the consequences for the environment (e.g. ensuring that 
adverse effects on biodiversity are minimised and positive contributions are made where possible).99 
 
 
3.4 In-house LCA studies 
Due to the scarcity of publicly available studies on the environmental performance of HDD, in-house LCA 
analyses were carried out in this study. This section describes the methodology followed, the sources and 
assumptions considered as well as the obtained results and their interpretation and discussion.  
 
3.4.1 
Methodology 
The technical analysis was performed using an LCA approach and taking into account the ‘Product 
Environmental Footprint. General Guide’.100 The LCA allowed assessing the relative environmental load of each 
life cycle stage to have an overall profile of the products’ performance. Moreover, several comparative 
analyses and sensitivity analyses were performed regarding: the application of detergent (full sink versus direct 
application), the amount of warm water, the origin of the surfactant, the dosage of the product, the electricity 
mix, and the impact method to assess their importance and associated improvement potentials. The LCAs were 
performed in accordance with the standard methodology of ISO 14040 and 14044 (see Figure 9). The four steps 
presented in Figure 9 were carried out in an iterative process. 
 
                                                             
 
99 http://www.unilever.com/sustainable-living-2014/reducing-environmental-impact/sustainable-sourcing/protecting-
biodiversity/index.aspx 
100 Product Environmental Footprint (PEF) Guide. Official Journal of the European Union (2013/179/EU). Commission Recommendation of 9 
April 2013 on the use of common methods to measure and communicate the life cycle environmental performance of products and 
organisations. Available from: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013H0179

79
 
Figure 9: Steps of a life cycle assessment, according to UNE-EN ISO 14040: 2006 
 
3.4.2 
Goal definition 
Goal definition is the first step of an LCA study. It defines the general context for the study. In the goal 
definition, parameters such as the intended application, the reasons for carrying out the study, the target 
audience, the limitations and assumptions have to be described. 
 
The goal of this analysis is to quantify the potential environmental impacts of products included in the category 
‘hand dishwashing detergents’ during all their life cycle phases. This analysis does not aim to do a comparison 
among different products or brands. The main objective is to analyse the impact of each life stage and its 
contribution in relation to other stages and the global environmental load of the product. Thus, even though a 
specific product is taken, the study only aims to analyse the performance of an average product manufactured 
in Europe. Consequently, a general LCA has been performed in order to have the complete environmental 
profile of the selected product.  
 
Potential environmental improvements of the product have been assessed by analysing different scenarios and 
sensitivity tests. The goal of this comparison is to quantify the potential improvement of the environmental 
performance of this product. 
 
3.4.3 
Scope of the study 
The scope of an LCA study consists of describing the system to be analysed along with the associated 
considerations and specifications. In the study proposed, an LCA from cradle to grave is considered and the 
following phases are considered, as shown in Figure 10: sourcing of the ingredients and raw material for 
packaging, manufacture of detergent, product packing, distribution to retail, use phase and disposal/end of life 
treatment. 
 
Ingredients 
sourcing
Distribution 
and retail
End of life
Paper board
Plastics
Waste water 
treatment
Use
Water 
heating
Water supply
Formulation
and 
manufacture
Production
packaging
material
Transport
Rawmaterial
sourcing
Detergent 
formulation
and packaging
 
Figure 10: Schematic representation of the life cycle of a HDD.

80
3.4.4 
Functional unit and reference flow 
The functional unit describes qualitatively and quantitatively the function(s) or the service(s) provided by the 
product analysed. The functional unit is used to define what the LCA is measuring, and provides a reference to 
which the inputs and outputs can be related. In this case the functional unit chosen is the manual washing of 
four ‘place settings’.85,87 Place setting specifications are provided in Annex VI.  
The reference flow describes the amount of the product required to fulfil the functional unit. The reference 
flows are as follows: 
• 
8 ml of manual dishwashing detergent based on a ‘Full Sink’ scenario (or 2 ml/place setting). 
• 
12 ml of manual dishwashing detergent based on ‘Direct Application’ scenario (or 3 ml/place setting). 
The full sink scenario consists in filling up the sink first with water and then washing the dishes but not rinsing.  
The direct application scenario involves letting the tap run while washing/rinsing, for at least part of the time.  
In both scenarios drying of the place settings (typically manually or air-drying) was excluded. The reference 
flow is an estimate based on the review of the existing literature and is not based on the performance of a 
specific HDD.  
 
3.4.5 
System description and boundaries 
The system boundaries were defined following general supply-chain logic including: raw materials (including 
raw materials extraction and ingredients manufacturing), manufacturing, packaging, distribution, use and final 
disposal.  
• 
Raw materials: In this sub-system raw materials and processing of ingredients are included. 
Composition and formulation of these products have been analysed taking into account are: origin of 
substances (e.g. vegetal, petroleum), production processes (energy and resources used) of substances 
and the performance of substances (toxicity properties to assess potential environmental impacts). 
Transport processes have been not considered due to lack of data. 
• 
Manufacturing: Standard processes and technologies to manufacture the studied products have been 
analysed. The use of energy and water during manufacturing is reported, together with waste 
generation and emissions to air and water. 
• 
Packaging: Primary and secondary packaging have been analysed. Some relevant aspects are: weight 
of material, origin of materials, recyclability. A common packaging has been considered for 
dishwashing detergents. 
• 
Transport/Distribution: The average distribution of products in the European market has been 
analysed, consisting of the transport from the plant to the final point of sale, including transport 
among intermediate storage points. Storage processes in the manufacturing plant and intermediary 
storage have not been included in the system. Transport from retail to consumer homes was omitted. 
Data were not available, although studies for other categories show that these impacts are generally 
minimal when compared to other activities. 
• 
Use: During use it is important to investigate whether there is a risk that the product may have 
negative health impacts exists. The potential for negative health impacts could be reduced by 
increasing the health requirements of hazardous detergents compounds. LCA results do not reflect 
these effects in the use phase (either due to generic use of data or because the inputs are ‘diluted’ 
with the inclusion of all the LCA inputs); these effects are discussed in Section 4.4. In the use phase the 
environmental impacts associated with the washing of four place settings includes the amount of 
water used for an average load and the energy to heat the water.  
• 
Disposal: Two kinds of ‘waste’ were included in the system: 
o 
Disposal of the product into water after use phase: as products studied are rinsed off, it is 
considered that the whole product is released to wastewater after washing action and 
subsequently the wastewater is purified in a wastewater treatment plant. 
o 
Disposal of the packaging: a scenario has been defined for each kind of packaging where a 
part is recycled and the other goes to disposal. Impacts from recycling have been included in 
the system boundaries but balanced with environmental benefits occurring due to avoidance 
of the use of virgin materials (LCA processes pre-defined products life cycles allocation rule). 
All impacts coming from waste disposal are included in the system.

81
3.5 Life cycle inventory 
Life cycle inventory (LCI) is a ‘cradle to grave’ accounting of the environmentally significant inputs and outputs 
of the system. The inventory involves the compilation and quantification of the inputs (materials and 
resources) and outputs for the product system throughout its life cycle (see Figure 11). The environmental 
burdens measured in this case study include material input requirements, total energy consumed, emissions 
released to air and water, and total solid wastes associated with the product’s life-cycle. LCI data is normalized 
with respect to the study’s functional unit. 
 
Unit Process
INPUTS
Product materials
Ancillary materials
Energy/resources
OUTPUTS
Primary products
Air emissions
Water effluent
Release to land
 
Figure 11: Inventory inputs and outputs 
 
For each sub-system defined, the inputs and outputs of the processes have been gathered and quantified. For 
the most important stages, primary data (information gathered from products) have been used when possible. 
For secondary data other studies and existing databases (such as Ecoinvent) have been used. For a few stages 
which are not considered of high relevance (because they do not depend on the product characteristics) such 
as distribution or use phase, generic data from other studies were also used.  
 
Table 34: Key assumptions 
 
Reference 
Full sink 
Direct application 
Functional unit 
Assumption 
4 place settings* 
Reference flow 
Based on Stamminger et al. (2007)85,87 
8 ml 
12 ml 
Raw materials and ingredients 
AISE 
Standard formulation – see Table 35 
Transport ingredients to 
product manufacturing site 
Assumption 
Renewable part in surfactants 8000 km (boat) 
Other ingredients 2000 km (lorry) 
Energy to process raw 
materials 
Koehler & Wildbolz (2009)101 
3.2 MJ per kg of chemical end product 
Packaging  
(primary / secondary) 
Van Hoof et al. (2013)89 
Primary pack: 650 ml PET bottle (36.5 g PET 
bottle, 3.8 g PP cap, 0.9g PE label) 
Transport packaging: 16 bottles per case 
(26.3 g of LDPE, 411 g of cardboard) 
Transport retail 
Frischknecht and Jungbluth (2002)104 
100 km by truck and 600 km by train 
Water consumption 
Stamminger et al. (2007)85,87 
7.5 l 
15 l 
Energy for water heating** 
Assumption based on Koehler & 
Wildbolz 
0.05 kWh 
0.11 KWh 
Energy source for water 
heating  
Assumption 
Electricity 
Waste water treatment 
Based on  EU Statistics 
100 % connection to secondary treatment 
Recycling rates solid waste 
Eurostat (2012)105 
Paper & board 83.2 %, Plastic 31.9 % 
Solid waste treatment  
Eurostat (2012)105 
Landfill 65.3 %, Incineration 34.7 % 
* One family meal 
** The water temperature is based on the maximum temperature people can stand comfortably with bare hands (40 ˚C). This value is 
higher for direct application since there is twice as much warm water used. 
                                                             
 
101 Koehler A and C Wildbolz, 2009. Comparing the Environmental Footprints of Home-Care and Personal-Hygiene Products: The Relevance 
of Different Life cycle Phases. ES&T 43(22):8643-8651

82
 
3.5.1 
Raw materials and ingredients manufacturing  
There is no ‘generic ’ HDD formulation. A large number of different ingredients can be used in a variety of 
combinations giving rise to different detergent formulations. Generally however, all HDDs contain the following 
categories of ingredients but in different concentrations: water, surfactants, builders, solvents and additives. 
Thus, given the different possible formulations, assessing the environmental impact of all varieties of 
detergents is impractical and a representative product is needed. The generic formulation of a dishwashing 
detergent as shown in Table 35 was provided by AISE.  
 
Table 35: General formula of liquid HDD102,103 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 36 shows the inventory data used to model the generic HDD. 
 
Table 36: Ecoinvent data inventory for a HDD frame formula 
* Alcohol ethoxylates (AE) with two degrees of ethoxylation AE3 and AE7, 1/6 mix of petrochemical, palm kernel oil, coconut oil 
 
Ingredients of HDDs contain very specific substances. No proxies were available for dye, perfume and 
preservatives so these were modelled as empty processes.104 
 
                                                             
 
102 Vollebregt, L., P. van Broekhuizen, 1994. Tussen wasmand en afdruiprek. Amsterdam: Chemiewinkel Universiteit van Amsterdam (UvA). 
103 Prud’homme de Lodder L.C.H., H.J. Bremmer, J.G.M. van Engelen, 2006. Cleaning Products Fact Sheet to assess the risks for the 
consumer. Bilthoven, The Netherlands: National Institute for Public Health and the Environment (RIVM). Report no.320104003 
104 There are no data available  and ‘empty process’; it is essentially an empty field, but it is modelled to keep the percentages correct. 
General formula of liquid  
HDD 
Concentration
(wt %) 
Assumption on 
concentration (wt %) 
Softened water 
83-85 % 
84 
Ethanol denaturated 
< 0.1 % 
0.05 
Phenoxyethanol 
< 1 % 
0.5 
Propylene Glycol 
< 0.1 % 
0.05 
Surfactant system (anionic – non-ionic)* 
10-17 % 
13.85  
NaOH 
< 0.2 % 
0.1 
NaCl 
< 2 % 
0.1 
Perfume 
<0.5 % 
0.25 
Dye (2 types) 
< 0.1 % 
0.05 
Preservatives 
< 0.1 % 
0.05 
Dishwashing  
product formulation 
Assumption on 
concentration (wt %) 
Ecoinvent data 
Softened Water 
84 
RER: water, completely softened, at plant  
Ethanol denaturated 
0.05 
RER: ethanol from ethylene, at plant 
Phenoxyethanol 
0.5 
RER:  ethylene glycol, at plant 
Propylene Glycol 
0.05 
RER: propylene glycol, at plant 
Surfactant system (anionic – non-ionic)* 
13.85 
RER: ethoxylated alcohols* 
NaOH 
0.1 
RER: sodium hydroxide, 50 % in H2O, 
production mix, at plant 
NaCl 
0.1 
RER: sodium chloride, powder, at plant 
Perfume 
0.25 
Empty process 
Dye (2 types) 
0.05 
Empty process 
Preservatives 
0.05 
Empty process

83
3.5.2 
Manufacturing  
This module contains energy inputs for the manufacturing of an HDD. As described in Section 4.1.2, the 
manufacturing process employed for HDD generally consists of mixing and pumping the ingredients into mixing 
vessels. The exact process employed will depend on the manufacturer and the format of the final product. For 
manufacturing HDD, the amount of energy used was set to 3.2 MJ per kg of chemical end product, based on a 
study by Koehler and Wildbolz.99 It was assumed to be all electricity.105 The average EU energy mix from 
Ecoinvent database 2.2 was used. It was also assumed that the detergent and the subsequent packaging are 
produced at the same location. In the life cycle assessment, the required ingredients, packaging and transport 
are combined under the assembly of the HDD. Production of waste and emissions for the production of a HDD 
was not included due to lack of data. Infrastructure was also included. 
 
3.5.3 
Packaging 
Packaging can be defined as the materials used for the containment, protection, handling, delivery, and 
presentation of goods. Packaging can be divided into three broad categories: 
• 
Primary packaging is the wrapping or containers handled by the consumer. 
• 
Secondary packaging is the term used to describe larger cases or boxes that are used to group 
quantities of primary packaged goods for distribution and for display in shops. 
• 
Transit packaging refers to the wooden pallets, board and plastic wrapping and containers that are 
used to collate the groups into larger loads for transport, which facilitates loading and unloading of 
goods. 
In this study, primary and secondary packaging was included, based on Van Hoof et al.89  Printing ink for the 
labels and pallets were excluded, as well as the electricity for the bottle blowing process, because this 
information is not publicly available. Table 37 shows the inventory data used for the packaging materials. 
 
Table 37: Primary & secondary packaging for a HDD 
Packaging (Primary and  Secondary) 
Ecoinvent data 
Primary pack: 650 ml PET bottle  
- 36.5 g PET bottle 
- 3.8 g PP cap 
- 0.9g PE label 
 
Polyethylene terephthalate, granulate, bottle grade, at plant/RER S 
Polypropylene, granulate, at plant/RER S 
Polyethylene, LDPE, granulate, at plant/RER S 
Transport packaging: 16 bottles per case 
- 26.3 g of LDPE 
- 411 g of cardboard 
 
Polyethylene, LDPE, granulate, at plant/RER S  
Packaging, corrugated board, mixed fibre, single wall, at plant/RER S 
*2.53E-03 kg of LDPE per kg of product and 3.95E-2 kg cardboard per kg of product, based on Koehler and WildbolzError! Bookmark 
not defined. 
 
3.5.4 
Transport/distribution 
Transport of raw materials was assumed to be 8,000 km (boat) for the renewable part in surfactants, and 
2,000 km (lorry) for other ingredients. The ingredients were assumed to come from Asia, hence the large 
distance. However, it should be noted that transport does not contribute much to the life cycle impacts. 
 
For the distribution phase, literature data has been used to estimate the transport distance. Normally in the 
European market products are distributed via lorry first to an intermediate storage, then to the storage 
facilities of direct customers (retailer) and from there to the point of sale (e.g. supermarket). Transport from 
retail to consumer homes was omitted. Data were unavailable, although studies for other categories show that 
                                                             
 
105 This study assumes that the detergent sector buys electricity of the grid, as no other information could have been collected.

84
these impacts are generally minimal when compared to other activities (based on Frischknecht & Jungbluth 
(2002)106). The distance was set to 100 km by truck (> 16 tonnes, fleet average) and 600 km by freight train. 
 
3.5.5 
Use  
Data on HDDs, including choices in study assumptions and consumer use, were based on the papers from 
Stamminger (2007).85,87  Table 34 shows the key assumptions used in the study. A sensitivity analysis was 
carried out on variables that have a large contribution on the environmental impact. 
 
3.5.6 
Disposal  
In this study the ‘recycled content method’ was applied, meaning that the benefits and burdens associated 
with recycling and energy recovery from incineration fall outside the scope of the study. The recycling rates for 
paper and board and plastic were taken from Eurostat (2012).107 The remaining waste that is sent to landfill 
and incinerated is allocated to the HDD.  
 
3.5.7 
Data quality 
For this study generic available data from the Ecoinvent database and agri-food print database were used. This 
paragraph describes the quality of the available data in these databases, assessed on criteria such as the 
geographical scale, time-related coverage of data, comprehensiveness and robustness.  
 
Data quality concerning the ingredients is fair. For some ingredients for which no information was available, 
proxies were used as a best guess. Data for electricity and production is quite good. Data for waste water 
treatment is fair, but waste water treatment does not contribute much to the life cycle impacts. Typical 
municipal waste water treatment data was used. For the use phase, which dominates the impact, data quality 
is good. 
 
3.5.8 
Life cycle impact assessment 
This section presents the life cycle impact assessment (LCIA). It is based on the data obtained in the inventory 
stage and includes the analysis of alternative substances for different products. 
 
3.5.8.1 
Impact assessment method used 
The impact assessment method used was ReCiPe.108 ReCiPe proposes a feasible implementation of a combined 
midpoint categories (expressed in units of a reference substance) and damage approach, linking all types of LCI 
results (elementary flows and other interventions) via midpoint categories to four damage categories: human 
health, ecosystem quality, climate change, and resources.  
 
Normalization can be performed either at midpoint or at damage level. Midpoints are used for a more specific 
and detailed analysis, whereas damage endpoints are useful to communicate the results obtained to a broader 
audience. The pre-defined (mathematical) weighting of the different midpoint score within the ReCiPe 
assessment method allow us to come to a single score. However, as previously mentioned, this should be used 
more for communication than for analysis, as weighting is not standardised and it is generally considered more 
relevant for the experts groups to hold discussions in greater detail – on midpoints level. 
 
                                                             
 
106 Frischknecht, R., and Jungbluth, N.(2002). Working paper: Qualitiy guidelines ecoinvent 2000 (in German: Arbeitspapier: 
Qualitätsrichtlinien ecoinvent 2000). Swiss Centre for Life Cycle Inventories, ecoinvent Center: Duebendorf, Switzerland. Retrieved 
10.12.2010, from http://www.ecoinvent.org/fileadmin/documents/en/presentation_papers/Qualitaet_5.7.pdf. 
107 Eurostat. (2012). EU Packaging recycling 2005. Retrieved  from http://epp.eurostat.ec.europa.eu 
108 Goedkoop, M., Heijungs, R., Huijbregts, M., De Schryver, A., Struijs, J., & Van Zelm, R. (2009). ReCiPe 2009. A life cycle impact 
assessment method which comprises harmonised category indicators at the midpoint and the endpoint level. The Hague, The Netherlands: 
VROM.

85
3.5.8.2 
Contribution analysis by life cycle stage 
The life cycle stages with the highest contribution to the environmental impacts were identified using 
characterised midpoint results from ReCiPe. The list of the impact categories, their abbreviations and the 
results for a HDD are shown in Table 38 and Figure 12. For more information please see Annex V. Please refer 
to Table 38 below for the abbreviations. 
 
Ingredients: The ingredients are quite an important contributor for the characterised midpoint results, 
particularly for the categories Terrestrial Ecotoxicity (92 %), Agricultural Land Occupation (51 %) and Natural 
Land Transformation (80 %). Of all ingredients, the major part of the environmental impact is caused by the 
surfactant ethoxylated alcohol. The surfactant is of a mixed origin, i.e. both oleo chemical origin (palm and 
coconut resources) and petrochemical. The oleo chemical origin components in particular contribute to 
Terrestrial Acidification, Natural Land Transformation and Agricultural Land Occupation.  
 
Manufacturing: The environmental impact of manufacturing relates to the use of electricity to process the raw 
materials. Manufacturing is quite an important contributor, particularly for Freshwater (35 %) Terrestrial (35 %) 
and Marine Ecotoxicity (25 %), and Climate Change (23 %). 
 
 
Figure 12: Impact contribution of different life cycle stages of a HDD (See abbreviations in Table 38) 
 
Table 38: Aggregate midpoint results for an HDD 
Impact category 
Abbreviation 
Unit 
HDD 
Climate Change 
CC 
kg CO2 eq 
5,74E-02 
Ozone Depletion 
OD 
kg CFC-11 eq 
2.99E-09 
Terrestrial Acidification 
TA 
kg SO2 eq 
2,52E-04 
Freshwater Eutrophication 
FE 
kg P eq 
5.58E-05 
Marine Eutrophication 
ME 
kg N eq 
1.72E-04 
Human Toxicity 
HTox 
kg 1,4-DB eq 
3,38E-02 
Photochemical Oxidant formation 
POF 
kg NMVOC 
1,53E-04 
Particulate Matter Formation 
PMF 
kg PM10 eq 
8,41E-05 
Terrestrial Ecotoxicity 
TTox 
kg 1,4-DB eq 
4,43E-05 
Freshwater Ecotoxicity 
FTox 
kg 1,4-DB eq 
5,00E-04 
Marine Ecotoxicity 
MTox 
kg 1,4-DB eq 
4.89E-04 
Ionising Radiation 
IR 
kg 235U eq 
3,95E-02 
Agricultural Land Occupation 
ALO 
m2a 
5,09E-03 
Urban Land Occupation 
ULO 
m2a 
4,21E-04

86
Natural Land Transformation 
NLT 
m2 
3,62E-05 
Water Depletion 
WD 
m3 
9,06E-03 
Metal Depletion 
MD 
kg Fe eq 
1,73E-03 
Fossil Depletion 
FD 
kg oil eq 
1,63E-02 
 
 
Packaging: This life cycle phase contributes relatively little to the overall environmental impact. The only 
significant contribution is to Agricultural Land Occupation (24 %). This can be explained by the use of 
corrugated board for the transport packaging. 
 
Transport: The contribution of transport to the overall environmental impact is the smallest of all the life cycle 
stages. 
 
Use phase: The use phase is by far the most dominant for most impact categories: Water Depletion (97 %), 
Human Toxicity (67 %), Ionising Radiation (67 %), Freshwater Eutrophication (63 %), Climate Change (60 %), 
Ozone Depletion (57 %), Terrestrial Acidification (58 %), Fossil Depletion (56 %), Particulate Matter Formation 
(56 %), Urban Land Occupation (52 %), Photochemical Oxidant Formation (49 %), Marine Ecotoxicity (44 %), 
Freshwater Ecotoxicity (44 %). The dominance of the use phase can be attributed to the energy required to 
heat the water. 
 
End of life:  For Marine Eutrophication, the end of life is important and contributes to 90 % of the characterised 
midpoint results. In particular, waste water sent to the waste water treatment plant (89 %) contributed much 
to the impact. The end of life is also important for metal depletion (52 %), mainly due to the treatment of 
waste water. 
 
3.5.8.3 
Identification of significant impacts 
The magnitude of different environmental impacts cannot be compared to each other because each impact 
category is expressed in a different unit. It is possible, however, to identify how significant an impact is when 
compared to a reference - in this case, the average impacts of a European citizen in the year 2000. This step in 
life cycle impact assessment (LCIA) is known as normalization. The results were calculated based on ReCiPe 
endpoint109, using the hierarchist perspective with European normalisation data from the year 2000.110 The 
normalised values of the different life cycle stages of an HDD are shown in Figure 13. 
                                                             
 
109 Goedkoop, M., Heijungs, R., Huijbregts, M., De Schryver, A., Struijs, J., & Van Zelm, R. (2009). ReCiPe 2009. A life cycle impact assessment 
method which comprises harmonised category indicators at the midpoint and the endpoint level. The Hague, The Netherlands: VROM. 
110 Sleeswijk AW, et al, Normalization in product life cycle assessment: An LCA of the global and European economic systems in the year 
2000, Sci Total Environ (2007), doi:10.1016/j.scitotenv.2007.09.040

87
 
Figure 13: Normalised endpoint results for an HDD (see abbreviations in Table 38) 
 
For an HDD, the most relevant impact category relative to the reference (average impacts of a European citizen 
in the year 2000) was Natural Land Transformation, followed by Fossil Depletion. The impact for Natural Land 
Transformation is mainly due to the surfactant: the ethoxylated alcohols.  The impacts for Fossil Depletion can 
mainly be attributed to use of electricity for water heating, manufacturing, blow moulding etc.  Climate Change 
(both for human health and ecosystems), Human Toxicity and Particulate Matter Formation are significant and 
are also mainly due to the use of electricity.  
 
 
3.6 Sensitivity analysis 
In this section the consequences of the assumptions on the overall results are explored. The following variables 
were selected for analysis because the contribution analysis showed they had a significant contribution on a 
particular life cycle phase: 
• 
the application of detergent (full sink versus direct application) 
• 
the amount of warm water 
• 
the temperature of the water 
• 
the origin of the surfactant 
• 
the dosage of the product 
• 
the electricity mix  
• 
the impact method.  
 
The sensitivity analysis focuses on the impact categories which have shown to have the most significant 
contribution in the normalised endpoint results namely: Natural Land Transformation, Fossil Depletion, Climate 
Change, Human Toxicity and Particulate Matter Formation.  
 
3.6.1 
Full sink versus direct application 
As deducted from Stamminger et al., roughly 70 % of consumers wash their dishes in a water bath (sink or 
bowl) the so-called ‘full sink’ approach. The remaining 30 % do their washing-up under continuously running 
tap water – the so-called ‘direct application’ approach. This sensitivity analysis tested the differences in impact 
of the ‘full sink’ and ‘direct application’ approaches, using the assumptions as shown in Table 39.

88
Table 39: Assumptions ‘full sink’ vs ‘direct application’  
 
Full sink 
Direct application 
Amount HDD 
8 ml 
12 ml 
Water consumption 
7.5 l 
15 l 
Energy for water heating 
0.05 kWh 
0.11 KWh 
 
As expected, the direct application scenario scores significantly higher on all impact categories (see Figure 14).  
From this analysis it can be deducted that reducing the amount of detergent, water and energy will lower the 
environmental impact. The other sensitivity analyses will focus on these elements separately.  
 
 
Figure 14: Sensitivity full sink versus direct application (see abbreviations in Table 38) 
 
3.6.2 
Amount of warm water 
In the use phase, warm water is commonly used to wash and rinse the dishes. In the baseline and in this 
section, the temperature of the water is assumed to be 40 °C. In the sensitivity analysis, the impact of the 
amount of warm water for the full sink scenario with 7.5 litres of water (baseline) is compared to twice the 
baseline amount (15 l), or half the baseline amount (3 l). This latter was kept to check the influence of the 
amount of warm water in the environmental impacts, but it does not mean that the washing could be done 
using such a small amount of water.  
 
A change of amount influences all the impact categories as shown in Figure 15. for Fossil Depletion, Climate 
Change, Human Toxicity and Particulate Matter Formation, a proportional change in the impact was observed. 
Natural Land Transformation was the only impact category which stayed relatively consistent for the three 
amounts. This matches expectations, as most of the impact on Natural Land Transformation relates to the use 
of the ingredient ethoxylated alcohols.

89
 
Figure 15: sensitivity to amount of water (See abbreviations in Table 38) 
 
3.6.3 
Temperature of the water 
In the use phase, warm water is used to wash and rinse the dishes. In the sensitivity analysis, we compared the 
impact of the temperature of the water for the full sink scenario with 7.5 litres of water of 40 °C (baseline) to 
cold water 15 °C,  water with a temperature of 30 °C and water with a temperature of 60 °C.  A higher 
temperature of the washing water contributes to a proportional increase of all impact categories, as shown 
inError! Reference source not found.Figure 16. A decrease in the temperature of the washing water therefore 
results in a proportional decrease in all impact categories. This matches expectations, as heating of the water in 
the use phase is an important contributor to the overall environmental impact.  
 
 
Figure 16: Sensitivity to temperature of water (See abbreviations in Table 38) 
 
3.6.4 
Surfactant origin 
The surfactant used in detergent can be petroleum-derived or plant-derived from palm oil, palm kernel oil, or 
coconut oil. In the formulation of HDD, ethoxylated alcohol (AE) with two degrees of ethoxylation AE3 and AE7, 
1/6 was used. Here the impact of the origin of the surfactant on the overall environmental impact is analysed.

90
 
Figure 17: Sensitivity to formulation (See abbreviations in Table 38) 
 
The results show that if a purely plant-derived AE is used for the detergent formulation, the natural land 
transformation drastically rises. When purely petroleum-derived AE is used for the detergent, the impact on 
fossil depletion rises. However, the impact is smaller than that of the plant derived AE on natural land 
transformation. This can be explained by the fact that the impact on Natural Land Transformation comes 
mainly from the surfactants, whereas for Fossil Depletion electricity is the main contributor.  
 
The LCIs for surfactants, whilst the best available, are over 15 years old and they do not contain adequate data 
relating to direct land use change. For compliance with WRI GHG protocol, ILCD and ISO 14040/44, any direct 
land use change occurring in the previous 20 years should be considered for above- and below-ground biomass 
and for soil organic matter (differentiated for peat and mineral soil).  
 
Consequently the results for impact categories relating to direct land use change and the associated GHG 
emissions are compromised and hence must be interpreted with caution. The available outdated LCI datasets 
have been included for completeness and for future comparison with the updated and improved surfactant 
inventories which have not been published at the time of this revision. 
 
3.6.5 
Product dosage 
In the ‘full sink’ baseline scenario, the reference flow is 8 ml of HDD per functional unit. In the sensitivity 
analysis, we tested the influence of using half a dose or a double dose of HDD. As can be seen in Figure 18, the 
amount of HDD proportionally relates to all five impact categories. This shows that the amount of HDD 
influences the environmental performance.

91
 
Figure 18: Sensitivity dose HDD (see abbreviations in Table 38) 
 
3.6.6 
Electricity mix 
In the baseline scenario we used the energy mix for Continental Europe (the Union for the Coordination of the 
Transmission of Electricity (UCTE)) from Ecoinvent. This represents the electricity net production shares by the 
member countries based on annual averages from the year 2000. For the sensitivity analysis we used the 
dataset for electricity production in France (approximately 50 % is derived from nuclear energy), electricity 
production in Switzerland (approximately 50 % derived from hydropower), and electricity production in the 
Netherlands (approximately 50 % is derived from natural gas). The results are shown in Figure 19. 
 
 
Figure 19: Sensitivity to electricity mix (See abbreviations in Table 38) 
 
The results show that switching to an energy mix based mostly on nuclear energy significantly reduces the 
environmental impacts in nearly all impact categories, as does switching to an energy mix based mostly on 
hydro power. This is because these sources are a cleaner source of energy compared to the electricity mix used 
in the study, which includes coal, crude oil, lignite, etc, which have higher GHG emissions.  
 
Trade-offs occur between other impact categories. Switching to an energy mix based on mostly gas would 
result in higher environmental impacts for nearly all categories. However, the impact on Particulate Matter 
Formation and Human Toxicity would be reduced significantly.

92
 
The comparison between the four different electricity mixes shows that switching to an electricity mix with 
higher renewable energy sources share is beneficial from the environmental point of view. Switching towards 
an electricity mix based on nuclear energy significantly decreases the impact on the selected categories. 
However, we cannot draw the conclusion that this is environmentally beneficial from a holistic point of view, as 
it can heavily impact on other non-studied categories.  
 
There is a significant increase in most of the categories under study when the electricity mix is mainly produced 
from natural gas. Switching to an energy mix based mostly on gas would result in higher environmental impacts 
for nearly all categories. However, the impact on ionising radiation would be reduced significantly, and the 
impact on Freshwater Eutrophication and Human Toxicity would also be reduced a little. This fact can be 
attributed to the larger use of fossil fuel resources  
 
3.6.7 
Impact method 
Differences in characterization models and their substance coverage for individual impact categories have 
earlier been identified as influential on the results of LCAs, sometimes able to change the conclusions of 
comparative LCA studies and often leading to different ranking of substances in terms of their contribution to 
the environmental impact.111 
 
In 2012, following work involving evidence from domain experts and stakeholders, the JRC identified best 
practice and launched a recommended set of characterization models and factors for application in LCIA.112 The 
recommended method, referred to as ILCD 2009, was compiled by assessing a total of 156 different 
characterization models belonging to 12 different LCIA methodologies and choosing the most appropriate, 
based on a predefined set of assessment criteria.113 The ILCD 2009 is now being introduced into LCA modelling 
tools, but it is not known yet whether there can be differences in impact scores between the ILCD 2009 and 
other frequently used LCIA methodologies and whether the choices of the ILCD 2009 matter for the 
implementation of LCA results. 
 
In this study, the results were analysed with the ReCiPe midpoint hierarchist perspective. Here we test the 
influence of this method choice, by comparing the outcomes to the outcomes of another method: ILCD 
midpoint (see Figure 20). 
 
According to ILCD, ingredients are less relevant for the overall environmental impact. In ReCiPe ingredients 
scored highly on categories Terrestrial Ecotoxicity (92 %), Agricultural Land Occupation (51 %) and Natural Land 
Transformation (80 %); these three impact categories are not included in the ILCD method. For manufacturing, 
both methods give similar results. Packaging contributes less than 10 % for all impact categories. Agricultural 
Land Occupation contributed for 24 % in ReCiPe and is not assessed in ILCD. For transport, both methods 
provided similar scores. In line with ReCiPe, the ILCD method shows that the use phase is the most important 
contributor for all the characterised midpoint results. The use phase is dominant in all categories, except for 
Human Toxicity non-cancer effects, Marine Eutrophication and Freshwater Ecotoxicity. Only Freshwater 
Ecotoxicity (28 %) in ILCD does not score as highly as Freshwater Ecotoxicity (44 %) in ReCiPe. In ReCiPe, impact 
categories which are less relevant for the use phase are Natural Land Transformation, Metal Depletion and 
Agricultural Land Occupation, but these are not assessed in ILCD. The end of life contributed to the 
characterised midpoint results for Marine Eutrophication, Human Toxicity non-cancer, and Mineral, Fossil & 
Renewable Resource Depletion, according to ILCD. Freshwater Ecotoxicity and Human Toxicity non-cancer are 
noteworthy, since they scored particularly high in ReCiPe. Metal depletion, which was important in ReCiPe, is 
not included in ILCD.   
 
                                                             
 
111 M. Owsianiak, A. Laurent, A. Bjorn, M. Z. Hauschild, IMPACT 2002+, ReCiPe 2008 and ILCDs recommended practice for characterization 
modelling in LCA: a case study-based comparison. Int J LCA, DOI 10.1007/s11367-014-0708-3 
112 Energy roadmap 2050. ISBN 978-92-79-21798-2 
113 Recommendations based on existing environmental impact assessment models and factors for LCA methods. Databases and supporting 
information. EUR 25167 http:/let.jrc.ec.europa.eu

93
Overall both methods show that the use phase is the most important hotspot. It should be noted that 
ingredients are not indicated as an environmental hotspot in the ILCD method because Terrestrial Ecotoxicity, 
Agricultural Land Occupation, and Natural Land Transformation are not taken into account in the ILCD. Another 
point to consider is the relevance of Human Toxicity - non-carcinogenic, which scored high in the end of life 
according to ILCD and scored relatively low in ReCiPe. 
 
Figure 20: Impact contribution of different life cycle stages of HDD according to the ILCD method 
 
3.6.8 
Sensitivity of the surfactant to the database 
In the present screening LCA we chose the widely used Ecoinvent database version 2.2 as a reference for the 
ingredients data. Recently, another LCI database containing data on palm and coconut oil production became 
available: the Agri-footprint® database.114 It is important to note that the differences in data collection 
methods between these databases result in differences in environmental impact of coconut and palm oil when 
using the ReCiPe endpoint method. Here we compare the results of the two databases on two renewable 
surfactants: coconut oil and palm kernel oil, which have shown to have a significant contribution to the 
environmental impact of detergents (see paragraph 4.6.44.6.8), which is to a large extent due to land 
transformation. 
 
In general, the Agri-footprint database based land transformation data on observed changes of palm fruit or 
coconut cropland for the past in 20 years in the countries where they are grown. Ecoinvent based its inventory 
data on permanent transformation of primary forest into agricultural land, and subsequently transformation 
into forest (planted forest) when the palm trees are not productive anymore, as reported by the farmers. 
  
3.6.8.1 
Coconut oil  
The Ecoinvent database assumes that for coconut trees, primary forest is permanently transferred into 
agricultural land. In Agri-footprint it is assumed that coconut area has not increased in the Philippines for the 
past 20 years, based on observed data. As a result, 1 kg of ethoxylated alcohols from coconut oil in Ecoinvent 
scores higher on natural land transformation (see Figure 21115). Furthermore, the total environmental impact 
at endpoint level of 1 kg of ethoxylated alcohols from coconut oil is slightly higher in Ecoinvent. This is because 
the impact from other categories is much higher in case of Agri-footprint, due to different assumptions on yield 
per hectare and fossil fuel use. As the difference between the total impact of this ingredient is small, Agri-
footprint will lead to the same overall conclusion regarding the importance of the surfactants in the life cycle of 
detergents. 
 
                                                             
 
114 http://www.agri-footprint.com/ 
115 Impact categories that are not shown contribute less than 1 %

94
 
Figure 21: Comparison between the environmental impact at endpoint of 1 kg of ethoxylated alcohols from 
coconut oil in Ecoinvent and in Agri-Footprint 
 
3.6.8.2 
Palm kernel oil 
In the Ecoinvent database, the amounts of transformation for of palm kernel oil are based on numbers for 
tropical forest transformed into palm kernel oil cropland and transformation to forest (planted forest), as 
reported by the farmers. Conversely, in Agri-footprint the amounts for palm kernel oil are based on data that 
indicate there was an increase in palm kernel oil cropland in Malaysia in the past 20 years. In Ecoinvent there is 
more transformation of tropical forest into palm kernel oil cropland, but there is also transformation to forest 
(not specified as being tropical forest). In Agri-footprint there is less transformation of tropical forest 
transformed into palm kernel oil cropland, but there is no planting of new forest.116 This is because the 
developers of Agri-footprint calculated the net transformation to palm fruit area. 
 
As the characterisation factor for damage at the end point level for transformation from tropical forest is about 
30 times higher than the characterisation factor for transformation from forest (and the negative factor for 
transformation to tropical rain forest is about 30 times higher than for transformation to forest), the higher 
number for transformation from tropical forest in Ecoinvent leads to a higher impact on Natural Land 
Transformation for 1 kg of ethoxylated alcohols from palm kernel oil in Ecoinvent (see Figure 22).  
 
Furthermore, the total environmental impact at endpoint level of 1 kg of ethoxylated alcohols from palm kernel 
oil is higher in Ecoinvent.  
The information that is currently available does not give insights in which of the methods lead to more realistic 
results. However, as natural land transformation is also the most important impact category in our study when 
using coconut or palm oil from Agri-footprint, just like it is when using Ecoinvent, from the use of Agri-footprint 
can also be concluded that the surfactants are an important contributor to the life cycle impact of detergents. 
The magnitude of the impact, however, is variable. 
 
                                                             
 
116 A bug correction in the current version of Agri-Footprint was made for the process oil palm fruit bunch: “Tranformation, from forest” 
changed into “Transformation, from tropical rain forest”.

95
 
Figure 22: Comparison between the environmental impact at endpoint level of 1 kg of ethoxylated alcohols 
from palm kernel oil in Ecoinvent and in Agri-Footprint 
 
 
3.1 Summary of findings 
The following conclusions can be derived from the screening LCA: 
I. 
The life cycle stage with the largest contribution to the environmental impact profile of an HDD is, by 
far, the use phase followed by the sourcing of raw materials (ingredients) and the end of life.  
II. 
Based on the normalisation assessment, the most significant impact categories for HDDs in Europe are 
Natural Land Transformation and Fossil Depletion.117  
 
Based on the results of this study, the key environmental performance indicators (KPIs - i.e. those variables that 
drive the results) for HDDs in Europe are:  
• 
Amount of product used. 
• 
Formulation, to be specific: the choice and amount of surfactant. 
• 
Energy needed to heat the water. 
• 
Energy source used to heat the water. 
 
The following conclusions can be made about the key environmental considerations that should be linked to 
the Ecolabel criteria of HDDs, as presented in Table 40: 
 
Table 40: Overall summary of the key environmental considerations linked to the Ecolabel criteria 
Conclusion 
Significance 
Addressable in the EU Ecolabel 
The formulation is an important contributor to 
environmental impact. Surfactants are responsible 
for most of the impact. 
High 
Yes, directly by restricting the use of the 
worst performing surfactants 
The use phase is the most significant contributor to 
the environmental impact, driven by energy needed 
High 
Somewhat, but indirectly through 
consumer information criteria 
                                                             
 
117 The impact on natural land transformation is due to the use of palm and coconut based surfactants. This is the case for all detergents 
(laundry, APC, dishwasher etc).

96
to heat water.  
Therefore, consumer information on the packaging 
can be used to tell consumers to use cold water for 
rinsing to reduce the amount of energy consumed 
to heat the water. 
An important environmental impact arises from the 
end of life, specifically related to municipal 
wastewater treatment. 
Medium 
Yes, through the toxicity to aquatic 
organisms criterion 
Impacts of detergent packaging are of medium 
importance.  
Medium 
Yes, through the packaging 
requirements criteria 
The impacts of distribution and transport are low 
Low 
No, would require specification for local 
sourcing

97
4. PRODUCT INNOVATIONS AND IMPROVEMENT POTENTIAL 
4.1 Introduction and approach 
The aim of this section of the report is to assess the potential improvement that might be delivered by 
adopting the revised criteria for the EU Ecolabel for all HDDs. 
 
In order to assess the potential improvement of HDDs the following have been undertaken: a sensitivity 
analysis using the results from the LCA study; identification of recent product innovations; an estimate of the 
potential benefits associated and identification of the possible measures to be undertaken in the EU Ecolabel.  
 
The sensitivity analysis conducted using results from the LCA study is presented in Section 4.6 and covers the 
attributes which showed significant contribution to the environmental impact. These are: the application of 
detergent (full sink versus direct application), the amount of warm water, surfactant origin, product dosage, 
the electricity mix, and the impact method. 
 
 
4.2 HDD product innovations 
In order to understand the scope of improvement options for HDD, recent product innovations which led to 
enhanced performance have been identified. These product innovations are: compaction, low-temperature 
cleaning performance, low/no harmful chemicals content, natural/renewable ingredients.118 Each of these 
innovations and their improvement potential is discussed below. Product innovations have been introduced 
throughout this report; the focus in this section is on innovations which offer improvement in terms of 
environmental performance.  
 
4.2.1 
Compaction 
Compaction is now common amongst the large brands in HDDs, with brands such as Unilever and Procter & 
Gamble offering products which are at least 2X and often 3X concentrated. However, further innovation in 
compaction technology has led to the development of 8X concentrated HDD.119 Compaction of HDDs brings 
several environmental benefits, through reductions in the amount of ingredients and packaging raw materials 
used, savings in water, energy and resources are made.  
 
4.2.2 
Natural/renewable ingredients 
The use of ingredients from natural or renewable sources instead of petrochemical sources is increasing in the 
HDD market. For most of the bulk ingredients this is not an option as they are inorganic and therefore cannot 
be easily replaced by renewable raw materials. However, for surfactants it is possible to use raw materials from 
renewable origins as their lipophilic compound is usually organic. Historically, vegetable and animal oils and 
fats were used as raw materials for soaps and detergents. Consequently, the use of renewable raw materials in 
this product group is not a recent innovation.  
 
4.3 Conclusions 
A summary of the results from the sensitivity analysis and the LCA analysis for HDD, along with the feedback 
provided after consultation to the stakeholders and their suggestions for how these issues can be addressed by 
the EU Ecolabel and an estimate of the potential benefits associated are presented in Table 41. The outcomes 
are presented by life cycle stage.  
                                                             
 
118 Global Household Care: Green Cleaning – Still an Oxymoron, Euromonitor International, September 2009.  
119 How laundry detergent became a catalyst for green innovation, Yale Environment 360, June 2013. Available from: 
http://e360.yale.edu/feature/adam_lowry_how_laundry_detergent_became_green_innovation_catalyst/2662/

98
 
As the results of the LCA and sensitivity analysis have shown that the highest environmental impacts are 
associated with the use phase and the ingredients used, the focus for improvement should be for these phases. 
The high environmental impact of the use phase can be addressed by encouraging consumers to wash at lower 
temperatures and promoting products which are effective at low temperatures. Moreover, impacts of the use 
phase could be further reduced with product compaction and the restriction on the content of harmful 
substances. The sensitivity analysis also showed that dosage is an important aspect, as an increase in product 
dosage leads to a proportional increase in the overall environmental impact. Overdosing can be addressed by 
improved consumer awareness through user instructions on the packaging.

99 
Table 41: Outcomes of sensitivity analysis and actions in Ecolabel criteria 
Stage 
Environmental impact 
Potential 
environmental 
gain 
Good environmental 
practices/restrictions 
Area of improvement 
For each functional group in the 
product composition, select 
substances which are less harmful in 
terms of ecotoxicity, aquatic toxicity 
and biodegradability 
Improvement of the environmental performance of ingredients 
used. The sensitivity analysis has shown that for terrestrial 
ecotoxicity the ethoxylated alcohols have the highest impact. For 
Human Toxicity, freshwater toxicity and marine ecotoxicity 
ethoxylated alcohols and ethylene glycol diethyl ether have the 
highest impacts.  
IInngredients 
1-92 % impact contribution,  
the highest indicator score goes 
for terrestrial ecotoxicity. Also 
it is important the score for 
natural land transformation, 
and agricultural land 
occupation. 
High 
Restrict the use of surfactants which 
have a significant impact on natural 
land transformation and agricultural 
land occupation. 
The sensitivity analysis showed that impact can be reduced by 
excluding surfactants from coconut oil   
Manufac-
turing 
0-35 % impact contribution, the 
highest score goes for 
freshwater and terrestrial 
eutrophication, marine 
ecotoxicity and climate change. 
Low 
Choose a clean source of energy 
The sensitivity analysis showed that switching to an energy mix 
based mostly on hydro power significantly reduces the 
environmental impacts in nearly all impact categories, except for 
ozone depletion, ionising radiation, water depletion, and metal 
depletion. 
Packaging 
0-24 % impact contribution,  
0-6 %contribution of all the 
indicators except for 
agricultural land lccupation 
which accounts for 24 %. 
Moderate 
Reduce the use of packaging 
materials from virgin sources by 
encouraging post-consumer 
materials for packaging. 
As the majority of the environmental impact from packaging is due 
to the material a decrease in the use of virgin materials will result 
in direct decrease of environmental impact.  
Transport 
 0-13 % impact contribution, 
the highest indicator score for 
photochemical oxidant 
formation and urban land 
occupation.  
Overall the impact is minor 
compared to the other stages.  
Low 
Decrease packaging weight and 
improve transport efficiency and 
logistics. 
Saving of fossil fuel used in transport.

100 
Stage 
Environmental impact 
Potential 
environmental 
gain 
Good environmental 
practices/restrictions 
Area of improvement 
Clean at lower temperatures. 
Encourage the use of detergents 
effective at 30 °C and below. 
The sensitivity analysis has shown that reducing the amount of 
warm water used, or the temperature of the water, would lead to 
reduced environmental impact, particularly for Fresh Water 
Eutrophication, Human Toxicity, Freshwater Toxicity Marine 
Ecotoxicity, Ionising Radiation, Urban Land Occupation, and Water 
Depletion. 
Use phase 
1-97 % impact contribution, 
Water Depletion, Human 
Toxicity, Ionising Radiation, 
Freshwater Eutrophication, 
Climate Change, Ozone 
Depletion, Terrestrial 
Acidification, Fossil Depletion, 
Particulate Matter Formation, 
Urban Land Occupation, 
Photochemical Oxidant 
Formation, Marine Ecotoxicity, 
Freshwater Ecotoxicity. The 
energy used to heat the water 
is the highest contributor to 
this.  
Moderate – can 
only be addressed 
indirectly through 
recommendations 
on use.  
Do not overdose the product as this 
increases the overall chemical load. 
The sensitivity analysis has shown that by reducing the dose, the 
environmental impact in all impact categories can be reduced 
proportionally. 
Treatment of 
packaging waste 
0-90 % impact contribution, 
highest for marine 
Eutrophication, <52 % for the 
rest of the impact categories. 
Impacts are 
dependent on the 
packaging stage 
Encourage the use of packaging 
which is recyclable and easy to 
disassemble  
Recycling or packaging waste is generally environmentally 
preferable than other waste treatment options.

101
5. CONCLUSIONS AND FURTHER STEPS 
This report presents the research carried out, through stakeholder surveys, market analysis, legal review and 
an environmental performance investigation, on areas related to the product group covered by the EU Ecolabel 
on hand dishwashing detergents. The report provides background information that underpins to the revision of 
the EU Ecolabel criteria and the proposed changes. The rationale behind the changes is included in the 
accompanying document: "Technical Report" 
 
The main findings of the Preliminary Report are: 
- The market analysis reported that the total retail value of the EU market for hand dishwashing detergents is 
€1.8 bn. Innovation in the hand dishwashing detergents market is relatively limited, and is primarily driven by 
adding functionality to the product. The range of hand dishwashing detergent products available includes 
budget variety, premium products and environmentally friendly versions.  
- The technical analysis found that the key environmental impacts of hand dishwashing detergents can be 
summarised as follows: 
 
The life cycle stage with the largest contribution to the environmental impact profile of hand 
dishwashing detergents is - by far - the use phase, particularly the energy needed to heat the water.  For 
some impact categories, the sourcing of raw materials and the end of life are also important. 
 
Based on the normalisation assessment, by far the most important impact categories for hand 
dishwashing detergents in Europe are natural land transformation and fossil depletion.  
The results of the LCA for a hand dishwashing detergent conducted as part of the technical analysis are shown 
in Figure 23. The ingredients represent an important contribution to characterised midpoint results, in 
particular for terrestrial ecotoxicity, agricultural land occupation and natural land transformation. Of all the 
ingredients, the surfactant ethoxylated alcohol accounts for the largest contribution to these impact 
categories. However, the use phase is by far the most dominant for the impact categories. The manufacturing 
and disposal phases are also important contributors to the freshwater, terrestrial and marine ecotoxicity 
impact categories.  
 
Figure 23: Impact contribution of different life cycle stages of a hand dishwashing detergent

102
The key environmental performance indicators (KPIs), i.e. those variables that mainly drive the results for 
hand dishwasher detergents in Europe, based on the results of this study, are:  
 
Amount of product used, 
 
Formulation; specifically the choice and amount of surfactants, 
 
Energy consumed to heat the water (if warm water is used), 
 
Energy source used to heat the water (if warm water is used). 
Finally the sensitivity analysis gives the ranges of environmental impacts due to the identified hotspots. This 
analysis highlight the importance of selecting environmentally-friendlier ingredients (e.g. biodegradable 
surfactants, less harmful substances in terms of ecotoxicity, aquatic toxicity and biodegradability), advising 
consumers on the environmental benefits of using cold water, the correct dosage and the correct management 
of the packaging materials at the end of the life of the product.  
As introduced, further research and their implications on the revision of the EU Ecolabel criteria are included in 
the accompanying "technical report" document.  It will summarize the rationale behind each of the EU Ecolabel 
criteria changes proposed and will be presented as the first working document before the first AHWG meeting.

103
 
Annex I: Hand dishwashing detergent ingredients 
Surfactants 
Surfactants (surface active agents) are the active cleaning ingredients found in detergent products. They 
function by changing the surface tension of water to assist with cleansing, wetting surfaces, foaming and 
emulsifying. In HDDs they help to remove food and soils. Anionic surfactants are the primary surfactants used 
in HDDs, as they tend to be high sudsing. These surfactants can accumulate and may be toxic and harmful in 
the environment. Therefore, to reduce the environmental impacts, surfactants which are readily biodegradable 
or environmentally innocuous should be chosen.  
 
Preservatives/biocides 
Preservatives are used to prevent the product from spoiling during storage by preventing the growth of 
microorganisms. Biocides are often used for preservation purposes, however, they can present significant risk 
to the environment and human health when used for purposes beyond preserving the product. 
 
Enzymes 
Enzymes are used in dishwasher detergents to improve washing performance. They function by targeting 
specific food deposits, which they break down into smaller parts so that they can then be removed by other 
ingredients in the detergent. As enzymes do not lose functionality after use, they can replace large quantities of 
other chemicals with the same function. Amylase and protease are commonly used in dishwasher detergent 
formulations.  
 
Dyestuffs 
Dyestuffs are added to the detergent formulations in order to give the detergents colour and for marketing 
purposes. They do not necessarily serve a purpose in the wash process.  
 
Solubility enhancers 
Solubility enhancers aid with formulation of the product and ensure that the desired physical characteristics 
are present. They ensure that the final product is uniform in nature and that all active ingredients are soluble in 
the product.   
 
Fragrances 
Fragrances are used to neutralise the inherent odour of detergent chemicals and give the laundry a pleasant 
smell. There are many different fragrance substances used by the detergent industry of which several are of 
environmental concern. For example, nitro-musks and polycyclic musk compounds are suspected of being 
carcinogenic and they show a tendency to accumulate in a mother’s milk. As a consequence all nitro-musks are 
banned from EU Ecolabel laundry detergent products. 
 
Opacifiers 
Opacifiers are additives that render the product, of which it is part of, impervious to light rays. They are 
commonly added to liquid detergents for aesthetic appeal. Opacifiers are usually water insoluble metal 
compounds, such as titanium dioxide. They may be used alone to reduce translucence or with a dye to give the 
product a desired colour.  
 
ANNEXES

104
Annex II: Stakeholder survey 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
QUESTIONNAIRE TO ANALYSE THE EXISTING SCOPE, MARKET 
SEGMENTATION AND ENVIRONMENTAL PERFORMANCE FOR 
HAND DISHWASHING DETERGENTS 
 
Stakeholders Consultation Document

105
 
1. INTRODUCTION 
 
Objectives 
The EU Ecolabel is a key policy instrument in promoting environmentally friendly products and services. The 
EU Ecolabel criteria for hand dishwashing detergents (HDDs) were adopted on 23 March 2005 (2005/342/EC) 
and revised and replaced on 24 June 2011 (2011/382/EU). Their aim was to promote cleaning detergents that 
represent the best 10-20 % of the products available on the EC market in terms of environmental performance 
considering the whole life cycle (from production, through use, and until disposal). These criteria are forseen to 
expire in December 2016. 
 
The framework that sets out the EU Ecolabel criteria for HDDs defines the aims of the criteria as promoting 
products that have a reduced impact on aquatic ecosystems, contain a limited amount of hazardous 
substances, and whose performance has been tested.  
 
There are currently criteria for each of the following aspects of HDDs: 
1. Toxicity to aquatic organisms 
2. Biodegradability of surfactants 
3. Excluded or limited substances and mixtures 
4. Fragrances 
5. Corrosive properties 
6. Packaging requirements 
7. Fitness for use 
8. User instructions 
9. Information appearing on the EU Ecolabel 
 
This questionnaire is the first stage in the process of revising the criteria for the award of the EU Ecolabel for 
HDDs. Its aim is to find out whether the current scope definition is still appropriate regarding the current 
market conditions and state of the art of the technology, and which criteria need to be amended, prolonged or 
withdrawn. One of the goals of the revision is to obtain simplified criteria addressing the most important 
environmental impacts of HDDs from a life cycle perspective. 
 
The views of relevant stakeholders are of utmost importance. 
 
 Confidentiality and contact details 
All responses received through this questionnaire will be treated as confidential. Where data is published, it 
will be in an aggregated format only. Comments will not be attributed to an individual person or organisation 
unless this is specifically requested. 
 
We rely heavily on stakeholder consultation, so your time and expertise are greatly appreciated and valued. 
 
For further information regarding this questionnaire, please contact us by writing to Josie Arendorf at the 
following e-mail address: josie.arendorf@oakdenehollins.co.uk. 
 
Once you have completed this survey, please email it to: JRC-IPTS-Hand-Dishwashing@ec.europa.eu  
 
Thank you for taking part!

106
 
2. QUESTIONNAIRE 
2.1 Your contact details 
First name: 
 
Family name: 
 
Email:   
 
Company/ Organisation:   
 
Position held:   
 
 
Organisation type: 
☐ Industry                                                               ☐ Government  
☐ Environmental Agency                                     ☐ Trade Association 
☐ Competent body                                            
☐ Other (please specify)  
 
Company/Organisation details: 
 
Website              
 
Country                         
 
Telephone Number

107
 
2.2 Scope and definition 
The product group ‘Hand Dishwashing Detergents’ comprises all detergents intended to be used to wash by 
hand dishes, crockery, cutlery, pots, pans, kitchen utensils and so on. 
The product group shall cover products for both private and professional use. The products shall be mixtures of 
chemical substances and must not contain micro-organisms that have been deliberately added by the 
manufacturer. 
 
1. Do you find the existing product 
group definition easy to understand? 
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification. 
 
2. Is the current definition appropriate 
and suitable for this product? 
 
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification. 
 
3. Is the current definition of hand 
dishwashing detergents excluding any 
type of product that should be 
included? 
☐ Yes          
☐ No 
 
If yes, please indicate.

108
These questions are specifically addressed to the EUEB members and Competent Bodies:  
 
4. Please can you provide anonymised CDV values for EU Ecolabel products. This is required for the analysis of 
CDV limits.  
Please send this information by email to Josie.arendorf@oakdenehollins.co.uk 
 
5. Have producers or any other interested party had difficulty in understanding the scope of the product 
group, or encountered difficulties because the product was not covered within the current scope and 
definition? 
☐ Yes          ☐ No 
 
If yes, please specify: 
 
 
 
6. Have you ever denied the EU Ecolabel licence for APCs because of a product not being covered by the 
current scope and definition?  
☐ Yes          ☐ No 
 
If yes, please specify: 
 
 
 
These questions are specifically addressed to the stakeholders/licence holders: 
 
7. Do you have any difficulty in understanding the scope of the product group? 
 
☐ Yes          ☐ No 
If yes, please specify:  
 
 
 
8. Have you ever been denied the EU Ecolabel licence for HDDs because of a product not being covered by the 
current scope and definition?  
☐ Yes          ☐ No 
If yes, please specify:

109
 
2.3 Questionnaire on currently valid criteria  
 
Criterion 1: Toxicity to aquatic organisms: Critical Dilution Volume (CDV) 
 
The current criteria specify that the critical dilution volume of the product must not exceed the following 
limits (CDVchronic): 
Product type 
CDVchronic 
Hand dishwashing detergents (diluted in water at manufacturers recommended 
dose for normally soiled items to create a litre of dishwashing water) 
3800 L/1 L of solution 
 
9. Is the CDV limit strict enough?  
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification. 
 
10.  Is CDV the most appropriate 
method for assessing aquatic 
toxicity? If not, which assessment 
method should be considered. 
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification. 
 
 
 
Criterion 2: Biodegradability of surfactants 
 
The current criteria specify that the content of surfactants in the product that are aerobically non-
biodegradable (not readily biodegradable aNBO) and/or anaerobically non-biodegradable (anNBO) shall not 
exceed the following limits.  
 
The current criteria specify that each surfactant in the product shall be readily biodegradable (aerobically) 
 
For anaerobic biodegradability of surfactants the following requirements apply: 
Feature 
Criterion 
Surfactants classified as H400/R50 
None permitted 
Total weight of anaerobically non-biodegradable 
surfactants that are not classified as H400/R50 
< 0.20 g/1 L of dishwashing water 
 
11. Are requirements for anaerobic 
biodegradability necessary for this 
product group? Which other 
parameters could be considered? 
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification.

110
12. Are the current limits effective in 
distinguishing between the state-
of-the-art and the best 
environmentally performing 
products in the HDD product 
group? 
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification. 
 
13. Are the current limits set for 
anaerobic biodegradability of 
surfactants strict enough? 
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification.

111
Criterion 3: Excluded or limited substances and mixtures 
 
Under the existing criteria, the following ingredients must not be included in the product: 
Substance 
APEO (alkyl phenol ethoxylates) and derivatives thereof 
EDTA (ethylenediamine tetraacetic acid) and its salts 
5-bromo-5-nitro-1,3-dioxane 
2-bromo-2-nitropropane-1,3-diol 
Diazolinidylurea 
Formaldehyde 
Sodium hydroxyl methyl glycinate 
Nitromusks and polycyclic musks 
 
There are restrictions on the use of quaternary ammonium salts: 
Substance 
Quaternary ammonium salts that are not readily biodegradable shall not be used, either as part of the 
formulation or as part of any mixture included in the formulation. 
There are restrictions on the use of biocides 
Substance 
i) 
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. 
ii) It is prohibited to claim or suggest on the packaging or by any other communication that the product 
has an antimicrobial action. 
iii) Biocides, either as part of the formulation or as part of any mixture included in the formulation, that 
are used to preserve the product and that are classified H410/R50-53 or H411/R51-53 in 
accordance with Directive 67/548/EEC, Directive 1999/45/EC of the European Parliament and of 
the Council ( 1 ) or Regulation (EC) No 1272/2008, are permitted but only if their bioaccumulation 
potentials are characterised by log Pow (log octanol/water partition coefficient) < 3,0 or an 
experimentally determined bioconcentration factor (BCF) ≤ 100. 
 
In addition, the most critical substances regarding human health and environment must also not be included in 
the product. This is a standard requirement for ecolabelled washing and cleaning products. However, there are 
certain substances which are specifically exempted from this requirement: 
Substance 
Hazard statement 
Risk phrase 
Surfactants (in concentrations <25 % in the product) 
H400 and H412 
R50 and R52-53 
Fragrances 
H412 
R52-53 
Enzymes 
H334 and H317 
R42 and R43 
NTA as in impurity in MGDA and GLDA 
H351 
R40 
 
The criteria also impose restrictions on the use of substances listed in accordance with Article 59(1) of 
Regulation EC No 1907/2006. 
 
14. Are there any additional ingredients 
which should be specifically 
excluded or limited from EU 
Ecolabelled HDDs? 
☐ Yes          
☐ No 
 
If yes, please specify and provide rationale or 
supporting information. 
 
15. Are any additional derogations 
required? 
☐ Yes          
☐ No 
 
If yes, please explain why and/or propose modification 
and provide rationale or supporting information.

112
16. Are there any substances or 
mixtures which no longer need to 
be excluded? 
☐ Yes          
☐ No 
 
If yes, please explain why and/or propose modification 
and provide rationale or supporting information. 
 
17. Are further requirements needed 
for the use of biocides in the 
product? 
☐ Yes          
☐ No 
 
If yes, please explain why and/or propose modification 
and provide rationale or supporting information. 
 
 
 
Criterion 4: Fragrances 
 
Under the current criteria the following requirements on fragrances apply: 
 
a) Nitro- and polycyclic musk-based fragrances are prohibited as in Criterion 3.  
 
b) Any substance added to the product as a fragrance must have been manufactured and/or handled in 
accordance with the code of practice of the International Fragrance Association. The code can be 
found on IFRA’s website: http://www. ifraorg.org 
 
c) Other fragrances may be limited to < 100 ppm (g/g) by the requirements of Regulation (EC) No 
648/200 (Annex VII) or where they are classified H317/R43 may cause allergic skin reaction and/or 
H334/R32 may cause allergy or asthma symptoms or breathing difficulties if inhaled.  
 
d) Fragrances are not permitted in HDDs for professional use. 
 
 
 
18. Are there any additional fragrance 
ingredients which should be 
specifically excluded or limited 
from EU Ecolabel HDDs? 
☐ Yes          
☐ No 
 
If yes, please specify and provide rationale or 
supporting information. 
 
19. Are there any further requirements 
needed for fragrances? 
☐ Yes          
☐ No 
 
If yes, please specify and provide rationale or 
supporting information. 
 
 
 
Criterion 5: Corrosive properties 
 
The current criteria state that the product shall not be classified as a ‘Corrosive’ (C) mixture with R34 or R35 in 
accordance with Directive 1999/45/EC, or as a ‘Skin Category 1’ mixture in accordance with Regulation (EC) No 
1272/2008.

113
 
20. Are the requirements on corrosive 
properties sufficient?  
☐ Yes          
☐ No 
 
If no, please explain why and/or propose modification. 
 
 
 
Criterion 6: Packaging requirements 
 
The existing criteria specify the following requirements on packaging: 
  
a) Plastics that are used for the main container must be marked in accordance with EC Directive 
94/62/EC or DIN 6120 part 1 and 2 in connection with DIN 7728 part 1. 
 
b) If the primary packaging is made of recycled material, any indication of this on the packaging shall 
be in conformity with the ISO 14021 standard 
 
c) Only phthalates that at the time of application have been risk assessed and have not been classified 
according to criterion 3c may be used in the plastic packaging 
 
d) The weight utility ratio (for primary packaging) must not exceed the following values: 
 
Product type 
WUR 
HDDs that are diluted in water prior to use 
1.2 g/ L use solution (dishwashing water) 
 
21. Do you think that is it necessary 
to have a criterion on packaging 
requirements for this product 
group? 
☐ Yes    
☐ No 
 
If no, please explain why and/or propose 
modification.
 
22. Are the WUR limits acceptable 
for HDDs currently on the 
market? 
☐ Yes    
☐ No 
 
If no, please explain why and/or propose modification. 
 
23. Should additional criteria be set 
to further promote the use of 
recycled materials in packaging? 
☐ Yes    
☐ No 
 
If yes, please explain why and/or propose modification. 
 
24. Should there be restrictions on 
combinations of materials used 
for packaging? For instance to 
encourage design for recycling 
(like the new proposed criterion 
for rinse-off cosmetics). 
☐ Yes    
☐ No 
 
If yes, please explain why and/or propose modification.

114
 
 
Criterion 7: Washing performance (fitness for use) 
 
The existing criteria state that the product shall be fit for use, meeting the needs of the consumer. 
The criteria state that the product shall comply with the performance requirements as specified in the latest 
version 
of 
the 
EU Ecolabel 
HDD 
performance 
test 
which 
can 
be 
found 
here: 
http://ec.europa.eu/environment/ecolabel/documents/performance_test.pdf   
 
25. Please provide us with your comments on the washing performance test and, if appropriate proposals 
for modification 
 
 
 
 
Criterion 8: User instructions 
 
Under the existing criteria, the product shall bear the following information on the packaging: 
 
a) ‘Do not use running water but immerse the dishes, and use the recommended dosage’ (or equivalent 
text) 
 
b) Information on the recommended dosage shall appear on the packaging in a reasonably sufficient size 
and against a visible background. The information shall be provided in millilitres (and tea spoons) of 
product for 5 litres of dishwashing water suitable for ‘dirty’ and ‘less dirty’ dishes. 
 
c) An indication of the approximate number of washes that the consumer can perform with one bottle is 
recommended but voluntary. 
 
 
26. Are additional requirements and 
instructions for dosage needed? 
☐ Yes          
☐ No 
 
If yes, please explain why you think so. 
 
 
 
Criterion 9: Information appearing on the EU Ecolabel 
 
An optional label with text box shall contain the following text: 
• 
Reduced impact on aquatic life 
• 
Reduced use of hazardous substances 
• 
Reduced packaging waste 
• 
Clear user instructions

115
27. Is there any other information 
which should be included on the EU 
Ecolabel claims text? 
☐ Yes          
☐ No 
 
If yes, please specify. 
 
 
2.3 Further issues or hot spots for HDDs 
The current criteria are set for 9 different aspects of HDDs, with the aim of promoting products which have a 
reduced impact on aquatic ecosystems, contain a limited amount of hazardous substances, and whose 
performance has been tested.  
 
28. Should further criterion be developed, either because all the issues are not already covered or because 
of recent developments which affect the environmental performance of HDDs? 
 
 
29. Do you consider it feasible to link the CDV and performance criteria? If yes, please explain your 
approach. 
 
 
30. Do you know of any examples of the use of nanomaterials in HDDs? Should their use be banned from 
this product group and why? 
 
 
 
 
 
2.4 Market data  
The market analysis forms an integral part of the criteria revision process, as it identifies important drivers, 
trends and innovations in the market for HDDs.  
 
If you have any information on market statistics for the HDD product group, please mention it here so that we 
can get in touch with you and collect the details needed for the project. Thank you in advance for your 
cooperation. 
 
 
 
 
2.5 Commission statement

116
Please find below the Commission statement accompanying the criteria revision to see the issues which should 
particularly be taken into account.

DRAFT
 
 
117

DRAFT
 
 
118
Annex III: Life cycle impact assessment 
For each substance, a schematic cause and effect pathway needs to be developed that describes the 
environmental mechanism of the substance emitted. Along this environmental mechanism an impact 
category indicator result can be chosen either at the midpoint or endpoint level. Endpoint results have a 
higher level of uncertainty compared to midpoint results but are easier to understand by decision makers. 
• 
Midpoint impact category, or problem-oriented approach, translates impacts into environmental 
themes such as climate change, acidification, human toxicity, etc. 
• 
Endpoint impact category, also known as the damage-oriented approach, translates 
environmental impacts into issues of concern such as human health, natural environment, and 
natural resources. 
 
LCI result
CO2
VOS 
P 
SO2
NOx
CFC
Cd
PAH
DDT
Land use
Oil
Raw mat.
Single score
Decr. Ozone P.
Ozone Conc.
Hazard. W. Dose
Absorbed Dose
PM10 Conc.
Infra-red Forcing
Climate Change
Ozone depletion
Radiation
Hum tox
Particulate Form.
P. C. Ozone Form.
Resources 
Surpus cost
Damage
Human health
DALY
Damage
Damage
Damage
Damage
Damage
Minerals Cons.
Fossil fuel Cons.
Energy Content
Decrease Conc.
Hazard W. Conc.
Marine Ecotox.
Marine Eutr.
Fresh water Eutr.
Fresh W. Ecotox
Algae Growth
Algae Growth
.
Hazard W. Conc
Nat. Land Transf.
Urban Land Occ.
Terr.Ecotox
Agr. Land Occ.
Terr. Acidif.
Hazard W. Conc.
Occupied Area
Base Saturation
Transformed area
Ecosystems
PDF.m2..yr
Terr. 
Damage
Fresh. 
Damage
Marine
Damage
 
Figure 23: Relationship between LCI parameters (left), midpoint (middle) and endpoint indicator (right) in 
ReCiPe 2009

DRAFT
 
 
119
 
Annex IV: Contribution analysis of different life cycle stages 
Table 42: Life cycle impact contribution of an HDD 
Impact 
category 
Unit 
Ingredients 
Manufacturing 
Packaging 
Transport 
Use phase 
Disposal 
CC 
kg CO2 eq 
2,91E-03 
1,34E-02
1,65E-03
1,45E-03
3,45E-02 
3,52E-03
OD 
kg CFC-11 eq 
1,48E-10 
6,33E-10
8,19E-11
1,77E-10
1,70E-09 
2,54E-10
TA 
kg SO2 eq 
1,24E-05 
5,32E-05
5,72E-06
9,30E-06
1,46E-04 
2,48E-05
FE 
kg P eq 
7,14E-07 
1,14E-05
5,04E-07
2,64E-07
3,50E-05 
7,94E-06
ME 
kg N eq 
2,96E-06 
3,43E-06
5,74E-07
5,65E-07
9,75E-06 
1,55E-04
Htox 
kg 1,4-DB eq 
7,49E-04 
7,50E-03
4,33E-04
2,47E-04
2,28E-02 
2,09E-03
POF 
kg NMVOC 
1,63E-05 
2,81E-05
5,26E-06
1,48E-05
7,44E-05 
1,40E-05
PMF 
kg PM10 eq 
5,40E-06 
1,72E-05
2,10E-06
4,00E-06
4,72E-05 
8,22E-06
Ttox 
kg 1,4-DB eq 
4,07E-05 
3,23E-07
3,08E-07
1,09E-07
1,55E-06 
1,24E-06
Ftox 
kg 1,4-DB eq 
2,14E-05 
1,74E-04
4,64E-06
5,73E-06
2,18E-04 
7,63E-05
Mtox 
kg 1,4-DB eq 
1,64E-05 
1,71E-04
5,56E-06
6,43E-06
2,17E-04 
7,21E-05
IR 
kg U235 eq 
4,46E-04 
1,02E-02
3,67E-04
2,43E-04
2,66E-02 
1,55E-03
ALO 
m2a 
2,62E-03 
5,92E-04
1,21E-03
9,09E-06
6,26E-04 
3,63E-05
ULO 
m2a 
1,32E-05 
5,15E-05
2,50E-05
5,62E-05
2,18E-04 
5,75E-05
NLT 
m2 
2,89E-05 
1,67E-06
3,96E-07
9,04E-07
4,24E-06 
7,36E-08
WD 
m3 
1,25E-04 
1,10E-04
1,04E-05
6,52E-06
8,75E-03 
6,14E-05
MD 
kg Fe eq 
1,60E-04 
1,64E-04
4,57E-05
8,20E-05
3,75E-04 
9,02E-04
FD 
kg oil eq 
1,43E-03 
3,67E-03
9,12E-04
4,59E-04
9,31E-03 
5,43E-04
 
Table 43: Life cycle impact contribution of a HDD (in percentages) 
Impact 
category 
Unit 
Ingredients 
Manufacturing 
Packaging 
Transport 
Use 
phase 
Disposal 
CC 
 % 
5 
23 
3 
3 
60 
6 
OD 
 % 
5 
21 
3 
6 
57 
8 
TA 
 % 
5 
21 
2 
4 
58 
10 
FE 
 % 
1 
20 
1 
0 
63 
14 
ME 
 % 
2 
2 
0 
0 
6 
90 
Htox 
 % 
2 
22 
1 
1 
67 
6 
POF 
 % 
11 
18 
3 
10 
49 
9 
PMF 
 % 
6 
20 
2 
5 
56 
10 
Ttox 
 % 
92 
1 
1 
0 
4 
3 
Ftox 
 % 
4 
35 
1 
1 
44 
15 
Mtox 
 % 
3 
35 
1 
1 
44 
15 
IR 
 % 
1 
26 
1 
1 
67 
4 
ALO 
 % 
51 
12 
24 
0 
12 
1 
ULO 
 % 
3 
12 
6 
13 
52 
14 
NLT 
 % 
80 
5 
1 
2 
12 
0 
WD 
 % 
1 
1 
0 
0 
97 
1 
MD 
 % 
9 
9 
3 
5 
22 
52 
FD 
 % 
9 
22 
6 
3 
57 
3

DRAFT
 
 
120
 
Annex V: Sensitivity analysis 
Product formulation sensitivity 
Table 44 shows the results of the ‘Full sink’versus ‘Direct application’. 
Table 44: Impact contribution of the ‘full sink’ versus ‘direct application’ scenario 
Impact category 
Unit 
Full sink 
Direct 
application  
Climate change 
kg CO2 eq 
5,76E-02 
1,05E-01 
Ozone depletion 
kg CFC-11 eq 
3,01E-09 
5,49E-09 
Terrestrial acidification 
kg SO2 eq 
2,52E-04 
4,64E-04 
Freshwater eutrophication 
kg P eq 
5,59E-05 
1,05E-04 
Marine eutrophication 
kg N eq 
1,72E-04 
3,40E-04 
Human toxicity 
kg 1,4-DB eq 
3,38E-02 
6,31E-02 
Photochemical oxidant formation 
kg NMVOC 
1,53E-04 
2,74E-04 
Particulate matter formation 
kg PM10 eq 
8,42E-05 
1,54E-04 
Terrestrial ecotoxicity 
kg 1,4-DB eq 
4,41E-05 
6,76E-05 
Freshwater ecotoxicity 
kg 1,4-DB eq 
5,00E-04 
8,96E-04 
Marine ecotoxicity 
kg 1,4-DB eq 
4,89E-04 
8,77E-04 
Ionising radiation 
kg U235 eq 
3,95E-02 
7,33E-02 
Agricultural land occupation 
m2a 
4,66E-03 
7,33E-03 
Urban land occupation 
m2a 
4,15E-04 
7,60E-04 
Natural land transformation 
m2 
3,61E-05 
5,63E-05 
Water depletion 
m3 
9,07E-03 
1,80E-02 
Metal depletion 
kg Fe eq 
1,73E-03 
3,23E-03 
Fossil depletion 
kg oil eq 
1,64E-02 
2,95E-02 
 
Sensitivity to warm water use  
Table 45 shows the results for the sensitivity to the amount warm water used. 
Table 45: sensitivity to the amount of heated water 
Impact category 
Unit 
7,5 L 
3 L 
15 L 
Climate change 
kg CO2 eq 
5,76E-02 
3,52E-02 
9,50E-02 
Ozone depletion 
kg CFC-11 eq 
3,01E-09 
1,84E-09 
4,96E-09 
Terrestrial acidification 
kg SO2 eq 
2,52E-04 
1,50E-04 
4,23E-04 
Freshwater eutrophication 
kg P eq 
5,59E-05 
3,02E-05 
9,89E-05 
Marine eutrophication 
kg N eq 
1,72E-04 
7,41E-05 
3,36E-04 
Human toxicity 
kg 1,4-DB eq 
3,38E-02 
1,90E-02 
5,85E-02 
Photochemical oxidant formation 
kg NMVOC 
1,53E-04 
1,00E-04 
2,41E-04 
Particulate matter formation 
kg PM10 eq 
8,42E-05 
5,10E-05 
1,40E-04 
Terrestrial ecotoxicity 
kg 1,4-DB eq 
4,41E-05 
4,24E-05 
4,69E-05 
Freshwater ecotoxicity 
kg 1,4-DB eq 
5,00E-04 
3,24E-04 
7,92E-04 
Marine ecotoxicity 
kg 1,4-DB eq 
4,89E-04 
3,16E-04 
7,77E-04 
Ionising radiation 
kg U235 eq 
3,95E-02 
2,26E-02 
6,76E-02 
Agricultural land occupation 
m2a 
4,66E-03 
4,27E-03 
5,33E-03 
Urban land occupation 
m2a 
4,15E-04 
2,51E-04 
6,89E-04 
Natural land transformation 
m2 
3,61E-05 
3,35E-05 
4,04E-05

DRAFT
 
 
121
Water depletion 
m3 
9,07E-03 
3,78E-03 
1,79E-02 
Metal depletion 
kg Fe eq 
1,73E-03 
9,61E-04 
3,00E-03 
Fossil depletion 
kg oil eq 
1,64E-02 
1,05E-02 
2,63E-02 
 
 
Surfactant origin  
Table 46 shows the results for sensitivity to surfactant origin. 
Table 46: Impact contribution of surfactant origin 
Impact category 
Unit 
1/6 mix 
plant/petro 
Only 
petro-
chem-
ical 
derived 
Only 
plant 
derived 
Climate change 
kg CO2 eq 
5,76E-02 
5,75E-02 
5,77E-02 
Ozone depletion 
kg CFC-11 eq 
3,01E-09 
3,01E-09 
3,02E-09 
Terrestrial acidification 
kg SO2 eq 
2,52E-04 
2,50E-04 
2,53E-04 
Freshwater eutrophication 
kg P eq 
5,59E-05 
5,59E-05 
5,60E-05 
Marine eutrophication 
kg N eq 
1,72E-04 
1,70E-04 
1,74E-04 
Human toxicity 
kg 1,4-DB eq 
3,38E-02 
3,37E-02 
3,39E-02 
Photochemical oxidant formation 
kg NMVOC 
1,53E-04 
1,52E-04 
1,54E-04 
Particulate matter formation 
kg PM10 eq 
8,42E-05 
8,22E-05 
8,52E-05 
Terrestrial ecotoxicity 
kg 1,4-DB eq 
4,41E-05 
3,48E-06 
6,44E-05 
Freshwater ecotoxicity 
kg 1,4-DB eq 
5,00E-04 
4,89E-04 
5,05E-04 
Marine ecotoxicity 
kg 1,4-DB eq 
4,89E-04 
4,84E-04 
4,91E-04 
Ionising radiation 
kg U235 eq 
3,95E-02 
3,94E-02 
3,95E-02 
Agricultural land occupation 
m2a 
4,66E-03 
2,09E-03 
5,95E-03 
Urban land occupation 
m2a 
4,15E-04 
4,12E-04 
4,17E-04 
Natural land transformation 
m2 
3,61E-05 
7,57E-06 
5,04E-05 
Water depletion 
m3 
9,07E-03 
8,96E-03 
9,12E-03 
Metal depletion 
kg Fe eq 
1,73E-03 
1,69E-03 
1,75E-03 
Fossil depletion 
kg oil eq 
1,64E-02 
1,69E-02 
1,62E-02 
 
Product dosage sensitivity 
Table 47 shows the results of the product dosage sensitivity analysis. 
Table 47: Impact contribution of the product dosage sensitivity 
Impact category 
Unit 
half dose 
(4ml) 
Baseline 
(8ml) 
double 
dose 
(16ml) 
Climate change 
kg CO2 eq 
4,75E-02 
5,76E-02 
7,79E-02 
Ozone depletion 
kg CFC-11 eq 
2,48E-09 
3,01E-09 
4,08E-09 
Terrestrial acidification 
kg SO2 eq 
2,12E-04 
2,52E-04 
3,33E-04 
Freshwater eutrophication 
kg P eq 
4,95E-05 
5,59E-05 
6,89E-05 
Marine eutrophication 
kg N eq 
1,68E-04 
1,72E-04 
1,81E-04 
Human toxicity 
kg 1,4-DB eq 
2,93E-02 
3,38E-02 
4,29E-02 
Photochemical oxidant formation 
kg NMVOC 
1,21E-04 
1,53E-04 
2,19E-04 
Particulate matter formation 
kg PM10 eq 
6,98E-05 
8,42E-05 
1,13E-04 
Terrestrial ecotoxicity 
kg 1,4-DB eq 
2,34E-05 
4,41E-05 
8,54E-05

DRAFT
 
 
122
Freshwater ecotoxicity 
kg 1,4-DB eq 
3,96E-04 
5,00E-04 
7,07E-04 
Marine ecotoxicity 
kg 1,4-DB eq 
3,88E-04 
4,89E-04 
6,89E-04 
Ionising radiation 
kg U235 eq 
3,38E-02 
3,95E-02 
5,07E-02 
Agricultural land occupation 
m2a 
2,66E-03 
4,66E-03 
8,67E-03 
Urban land occupation 
m2a 
3,44E-04 
4,15E-04 
5,57E-04 
Natural land transformation 
m2 
2,02E-05 
3,61E-05 
6,79E-05 
Water depletion 
m3 
8,94E-03 
9,07E-03 
9,32E-03 
Metal depletion 
kg Fe eq 
1,50E-03 
1,73E-03 
2,18E-03 
Fossil depletion 
kg oil eq 
1,31E-02 
1,64E-02 
2,30E-02 
 
 
Energy source sensitivity 
Table 48 shows the results for the energy source sensitivity analysis 
Table 48: Impact contribution of energy source sensitivity  
Impact category 
Unit 
UCTE  
FR 
CH 
NL 
Climate change 
kg CO2 eq 
5,76E-02 
3,12E-02 
2,71E-02 
6,56E-02 
Ozone depletion 
kg CFC-11 eq 
3,01E-09 
1,72E-09 
2,34E-09 
2,94E-09 
Terrestrial 
acidification 
kg SO2 eq 
2,52E-04 
1,48E-04 
1,23E-04 
1,74E-04 
Freshwater 
eutrophication 
kg P eq 
5,59E-05 
2,71E-05 
2,49E-05 
3,45E-05 
Marine eutrophication 
kg N eq 
1,72E-04 
1,65E-04 
1,64E-04 
1,68E-04 
Human toxicity 
kg 1,4-DB eq 
3,38E-02 
2,00E-02 
1,77E-02 
2,30E-02 
Photochemical 
oxidant formation 
kg NMVOC 
1,53E-04 
1,04E-04 
9,05E-05 
1,47E-04 
Particulate matter 
formation 
kg PM10 eq 
8,42E-05 
5,35E-05 
4,53E-05 
6,32E-05 
Terrestrial ecotoxicity 
kg 1,4-DB eq 
4,41E-05 
4,37E-05 
4,35E-05 
4,36E-05 
Freshwater ecotoxicity 
kg 1,4-DB eq 
5,00E-04 
4,58E-04 
4,14E-04 
5,51E-04 
Marine ecotoxicity 
kg 1,4-DB eq 
4,89E-04 
4,41E-04 
3,96E-04 
5,39E-04 
Ionising radiation 
kg U235 eq 
3,95E-02 
8,14E-02 
4,66E-02 
1,73E-02 
Agricultural land 
occupation 
m2a 
4,66E-03 
4,36E-03 
4,29E-03 
4,81E-03 
Urban land occupation 
m2a 
4,15E-04 
3,51E-04 
3,26E-04 
4,42E-04 
Natural land 
transformation 
m2 
3,61E-05 
3,35E-05 
3,31E-05 
4,11E-05 
Water depletion 
m3 
9,07E-03 
9,15E-03 
9,03E-03 
8,94E-03 
Metal depletion 
kg Fe eq 
1,73E-03 
2,99E-03 
2,89E-03 
2,81E-03 
Fossil depletion 
kg oil eq 
1,64E-02 
9,11E-03 
8,12E-03 
2,04E-02 
 
Method sensitivity 
Table 49 shows the results for the method sensitivity analysis: the comparison to ILCD. 
Table 49: Life cycle impact contribution of an APC, according to ILCD midpoint 
Impact category 
Unit 
Ingred-
ients 
Manu-
facturing 
Pack-
aging 
Trans-
port 
Use 
Phase 
Disposal 
Climate change 
kg CO2 eq 
2,91E-03 
1,28E-02 
2,41E-03 
1,45E-03 
3,45E-02 
3,52E-03 
Ozone depletion 
kg CFC-11 eq 
1,48E-10 
6,05E-10 
1,31E-10 
1,77E-10 
1,70E-09 
2,53E-10 
Human toxicity, 
kg SO2 eq 
1,25E-10 
9,22E-10 
1,54E-10 
1,10E-10 
3,32E-09 
1,24E-09

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cancer effects 
Human toxicity, non-
cancer effects 
kg P eq 
3,27E-10 
3,36E-09 
2,02E-10 
2,21E-10 
3,11E-09 
1,54E-08 
Particulate matter 
kg N eq 
2,54E-06 
6,10E-06 
1,33E-06 
6,10E-07 
1,49E-05 
2,08E-06 
Ionizing radiation HH 
kg 1,4-DB eq 
4,46E-04 
9,84E-03 
7,40E-04 
2,43E-04 
2,66E-02 
1,55E-03 
Ionizing radiation E 
(interim) 
kg NMVOC 
1,38E-09 
3,03E-08 
2,29E-09 
7,47E-10 
8,26E-08 
4,68E-09 
Photochemical ozone 
formation 
kg PM10 eq 
1,56E-05 
2,65E-05 
6,86E-06 
1,47E-05 
7,35E-05 
1,35E-05 
Acidification 
kg 1,4-DB eq 
1,61E-05 
6,67E-05 
1,11E-05 
1,23E-05 
1,92E-04 
3,20E-05 
Terrestrial 
eutrophication 
kg 1,4-DB eq 
3,97E-05 
9,35E-05 
2,03E-05 
5,48E-05 
2,55E-04 
9,09E-05 
Freshwater 
eutrophication 
kg 1,4-DB eq 
7,42E-07 
1,09E-05 
1,09E-06 
2,64E-07 
3,50E-05 
7,94E-06 
Marine eutrophication 
kg U235 eq 
4,37E-06 
1,06E-05 
2,23E-06 
5,03E-06 
2,97E-05 
1,53E-04 
Freshwater ecotoxicity 
m2a 
1,21E-02 
8,42E-02 
4,30E-03 
4,65E-03 
6,93E-02 
7,29E-02 
Land use 
m2a 
1,34E-03 
6,11E-03 
4,22E-03 
3,91E-03 
2,71E-02 
2,95E-03 
Water resource 
depletion 
m2 
2,96E-05 
7,91E-05 
1,44E-05 
2,45E-06 
1,59E-03 
1,41E-05 
Mineral, fossil & ren 
resource depletion 
m3 
4,55E-08 
5,32E-08 
5,96E-09 
1,80E-08 
1,30E-07 
1,34E-07

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Annex VI: Place settings 
According to Stamminger et al. 50 % of the respondents wash their dishes before or after each meal. Assuming 
that an 'average' family consist of 2 adults and 2 children an average washing would consist of a four persons 
place settings. According Stamminger et al. one place setting consists of a dinner plate, soup plate, dessert 
plate, a glass , tea cup and saucer, a knife, fork, soup spoon, dessert spoon, teaspoon and additional serving 
pieces. 
 
This means that the washing up with four place settings is assumed to consist of: 
• 
4 Dinner plates  
• 
4 Dessert plates  
• 
4 Glasses 
• 
4 Tea cups and saucers  
• 
4 Knives, forks, soup spoons, dessert spoons and teaspoons  
• 
1-2 Serving plates and serving spoons  
• 
4 Bowls

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Annex VII: Detailed feedback from the stakeholders to the first questionnaire 
Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
Do you find the existing product group 
definition easy to understand? 
 
 
No comments 
Is the current definition appropriate and 
suitable for this product? 
 
 
No comments 
Scope and 
definition 
Is the current definition of hand dishwashing 
detergents excluding any type of product that 
should be included? 
 
 
No comments 
Y 
Industry 
However, with a super concentrate we passed the requirement 
well. 
N 
Competent body 
2500 L/l is possible 
N 
Industry 
2500 L/1L of solution will be more restrictive 
N 
Competent body 
I think we can reduce the limits because most of the products 
have CDV values much lower and the ecolabel certification must 
remain restrictive.  
N 
Competent body 
This can be much lower, I send already data about the CDVtox of 
the current EU Ecolabel products. A lot of those products has a 
CDVtox that is much lower than 3800. 2200L/1L of solution should 
be feasable. The revision of the new didlist should be taken into 
account, I did some comparative calculations and for most of the 
products the use of the new didlist results in a lower CDVtox. 
Is the CDV limit strict enough? 
N 
Industry 
Our CDV tox values for HDD are lower than 1500L. It is possible to 
reduce the limit. 
N 
Industry 
The CDV is very much a hazard based tool, whereas environmental 
risk of each ingredient would be the most appropriate parameter, 
such as done by REACH. 
Y 
Competent body 
Regarding CDV and USEtox please refer to opinion described in 
email  
N 
Industry 
association 
CDV criteria are taking a pure hazard approach, whereas looking 
at environmental risk of each ingredient would be the most logical 
approach (which is also the approach of REACH). 
1.  Toxicity to 
aquatic 
organisms: CDV 
Is CDV the most appropriate method for 
assessing aquatic toxicity? If not, which 
assessment method should be considered? 
Y 
Competent body 
I believe we don't have enough information available about others 
methods

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Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
N/A 
Industry 
It has can be other methods there better but not knowing them it 
is difficult to answer. 
Y 
Industry 
Use tox database isn't as complete as vcdtox database. For 
example: Malic acid. 
N 
Industry 
Anaerobic biodegradability is not a relevant environmental 
parameter 
N 
Industry 
Anaerobic biodegradability is not a relevant environmental 
parameter, as concluded by the Commission (SCHER) in 2009. 
N 
Industry 
Research on availability of raw materials with anaerobic 
biodegradability should be done. 
N 
Industry 
association 
Anaerobic biodegradability is not a relevant environmental 
parameter (as concluded by SCHER in 2008) 
N 
Competent body 
The commission decision of 28 May 2014 amending Decisions 
2011/382/EU allows the using of surfactants classified H411 (2.5% 
authorized). This amendment has to be cancelled because 
alternatives are possible. 
Y 
Competent body 
Surfactants should be anaerobic biodegradable. As the EU 
Ecolabel is a volontary label and a label of excellence surfactants 
should be anaerobicaly biodegradable too, even if most of them 
are aerobically biodegraded in wastewater treatment there are 
still situations where they can end up in anaerobical 
circumstances. Second reason in the new criteria for rinse-off 
cosmetics this is also required, the EU Ecolabel should be 
consequent and it is possible to have weel performing HDD's with 
only surfactants that are aerobic and anaerobic biodegradable. 
Are requirements for anaerobic 
biodegradability necessary for this product 
group? Which other parameters could be 
considered? 
N 
Industry 
Other parameter to forbit: the using of surfactants classified H411 
(2.5% authorized from now) because alternatives no classified 
H411 are possible 
N 
Industry 
Anaerobic biodegradability is not relevant (see question 11) for 
the environmental performance of surfactants, if they are already 
readily biodegradable (aerobically) 
2. Biodegradability 
of organics 
Are the current limits effective in 
distinguishing between the state-of-the-art 
and the best environmentally performing 
products in the HDD product group? 
N 
Industry 
association 
Anaerobic biodegradability does not define the environmental 
performance of surfactants, if they are already readily 
biodegradable (aerobically)

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Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
N 
Competent body 
There are products that contain surfactants that are anaerobically 
biodegradable   
N 
Competent body 
We can reduce the threshold of anaerobically non-biodegradable 
surfactants that are not classified as H400/R50. 
N 
Industry 
0.20g/1L of anNBO surfactants is too much. In general for this 
product category, you use less than 20% of surfactants in formulas 
for a dosage of 5mL/5L of water = 0.20g of anNBO / 1L of 
diswashing water. So the current criteria allows near the total 
quantity of required surfactants in anNBO surfactants that is not 
good. 
Y 
Industry 
Actually they are too strict (see Q.11) (Anaerobic biodegradability 
is not a relevant environmental parameter) 
Y 
Industry 
Actually they are too strict 
N 
Industry 
Research on availability of raw materials with anaerobic 
biodegradability should be done. 
Y 
Industry 
association 
Actually they are too strict (see Q.11) 
N 
Competent body 
We can reduce the threshold of anaerobically non-biodegradable 
surfactants that are not classified as H400/R50 because most of 
the products (currently certified) have values << 0,2g. 
N 
Competent body 
All surfactants should be anaerobicly biodegradable. 
Are the current limits set for anaerobic 
biodegradability of surfactants strict enough? 
N 
Industry 
Forbid aNBO surfactants. 
Y 
Competent body 
Endocrine disruptors, vPvB, PBT and SVHC 
Y 
Industry 
Liberator of formaldehyde should not be used 
Y 
Competent body 
We can forbid enzymes because most products would not include 
them. We can also cancel the exemption for NTA because we 
don't see this substance in the chemicals formulations. In 
addition, quaternary ammonium salts are rarely used so we can 
forbid them. 
Y 
Industry 
Exclude Surfactants classisfied H411 (from now 2.5% authorized) . 
Exclude enzymes (not necessary for these products). 
Are there any additional ingredients which 
should be specifically excluded or limited from 
EU Ecolabel HDDs? 
Y 
Industry 
Chloromethylisothiazolinone 
Y 
Industry 
H400 for enzymes & H411 for surfactants 
3. Excluded or 
limited 
substances and 
mixtures 
Are any additional derogations required? 
N 
Industry 
Note that derogation for surfactants classified as H411 <2.5 %, is

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128 
Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
not in this document yet 
Y 
Industry 
association 
Some proteases can be classified as H400. A derogation could be 
considered, similarly to the amendment made to the I&I laundry 
and dishwashing detergents criteria. Also, please note that this 
document is not taking into account yet the derogation recently 
published for surfactants classified as H411 in total concentrations 
< 2,5 % in the final product. 
N 
Industry 
It's quite difficult to preserve Ecolabel dishwashing products so it 
will be interesting to allow the R43 (or H317) and R52 (or H412)  
for the preservatives 
Y 
Industry 
APEO: are not used due to their limited biodegradability 
Y 
Industry 
APEO: are not used due to their too low biodegradability 
Y 
Industry 
association 
APEO: are not used due to their limited biodegradability 
Are there any substances or mixtures which no 
longer need to be excluded? 
Y 
Industry 
Quaternary ammonium salts shall not be used even if there are 
readily biodegradable 
Y 
Industry 
Research on more sustainable preservatives could be useful. 
Are further requirements needed for the use 
of biocides in the product? 
Y 
Competent body 
Why does the criteria accept risk phrases H410 and H411 and 
forbid H412, is it an error? 
Are there any additional fragrance ingredients 
which should be specifically excluded or 
limited from EU Ecolabel HDDs? 
 
 
 
Y 
Industry 
There need to be a better solution for CDV calculation of 
fragrances. Now we need to use 100 % concentration for every 
perfume. CDV calculation for every ingredient (if available) should 
be better and stimulates the use of more sustainable fragrances. 
Y 
Industry 
Allow fragrance in professional product. 
Y 
Industry 
It is not logical not to authorize flavors for the professional 
products. It favors the other markets like ecocert. 
Y 
Competent body 
Criterion 4c isn't clearly written, it seems that it is already covered 
by criterion 3 unless here the perfum as a whole is meant and not 
the different substances in the perfume. 
4.  Fragrances 
Are there any further requirements needed for 
fragrances? 
Y 
Industry 
It is possible to permit fragrances in professionnal product with 
the same requirements than private products.

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129 
Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
5.  Corrosive 
properties 
Are the requirements on corrosive properties 
sufficient? 
Y 
Industry 
However industry initiatives such as Detnet should also be 
allowed. 
Y 
Industry 
Association 
Yes, the packaging of these products is ultimately part of the 
package purchases by the final consumer. 
Do you think that is it necessary to have a 
criterion on packaging requirements for this 
product group? 
N 
Industry 
In the lowest possible will of the WUR, we lose on the quality of 
packagings and we risk to create dissatisfactions of the users. 
N 
Industry 
WUR are too strict, versus a rather limited impact of packaging as 
a whole on the impact of a hand dishwashing detergent. Advice 
on recycling of the packaging could be used alternatively. 
N 
Competent body 
This limit could be more stringent, See Nordic Swan for limit 
N 
Industry 
association 
WUR are too strict, whereas the impact of packaging on the 
environmental impact of detergents does not justify this. 
N 
Competent body 
We can reduce the threshold. If it's necessary, we can send you 
our values (for currently certified products). 
Y 
Industry 
For the moment, yes, but if the WUR is too low we risk to 
decrease the quality of packagings. 
Are the WUR limits acceptable for HDDs 
currently on the market? 
N 
Competent body 
The WUR limit can be much lower. 
N 
Industry 
Any recycling criteria should not go further that what is reality in 
the market w.r.t. availability of recycled materials of sufficient 
quality. 
Y 
Industry 
Recycled materials are slowly being more available to the market; 
it would be good to stimulate this in EU Ecolabel. Perhaps 
research to bio-based plastic and other new forms of packaging 
materials could be useful. 
Y 
Industry 
association 
A criterion promoting the use of recycled material will reduce the 
environmental impact of the packaging. 
N 
Industry 
association 
Recycling criteria should not go beyond market reality. 
Should additional criteria be set to further 
promote the use of recycled materials in 
packaging? 
Y 
Competent body 
I think it is possible, there is already a lot of packaging on the 
market with at least some recycled content. The requirement 
shouldn't be too high because the quality has to stay high and a 
high % of recycled content doesn't allow a white transparent 
bottle 
6.  Packaging 
requirements 
Should there be restrictions on combinations 
N 
Industry 
But could be yes, if it can be proven that a certain kind of

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130 
Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
packaging cannot be recycled at all, and that efficient & 
economically viable alternatives with same functionality exist. 
N 
Industry 
We use quite a lot of very low weight laminated pouches, these 
packaging have many sustainable advantages: less transportation, 
less stock and less waste. However these pouches need to go to 
rest plastic waste for recycling. 
Y 
Industry 
association 
Non compatible materials are the major barrier to improve the 
recyclability of packaging (at the recycler and at the sorting 
plants). Additionally, easy-to-empty and easy-to-access concepts 
and indexes could also ease the recycling process. See 
www.recyclass.eu 
Y 
Competent body 
To ease recycling different materials should be easily separated 
N 
Industry 
association 
Unless it can be proven that a certain kind of packaging cannot be 
recycled at all. 
of materials used for packaging? For instance 
to encourage design for recycling (like the new 
proposed criterion for rinse-off cosmetics). 
N 
Industry 
Some packaging are inevitably multi-materials (doypack for 
example) and it's technicaly impossible to have a monomaterial 
packaging. 
N/A 
Industry 
The currently proposed IKW test protocol is sufficient 
N/A 
Testing institute 
Ingredients for the soil preparation should be general available (at 
least within one country). Instead of ‘local’ source or "not 
specified" some clarifications are needed because the use of 
specific ingredients can one-sidedly influence the plate numbers. 
Concerning this matter, the reference product is unfortunately 
rather robust. 
N/A 
Industry 
We are more a supporter for consumer test because the 
difference we see in lab tests are not relevant for use in practice 
and bring unnecessary high costs for certification. 
N/A 
 
Testing institute 
At least five repetitions should be increased to at least 20 
- We suggest a chemical characterization to be attached to the 
performance test to allow certain compositional characteristics of 
the product in order to strengthen the declared in composition. 
This allows a further quality control. 
7.  Washing 
performance 
(fitness for use)  
Please provide us with your comments on the 
washing performance test and, if appropriate 
proposals for modification 
N/A 
Industry 
association 
The currently proposed IKW test protocol is sufficient

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131 
Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
N/A 
Industry 
No particular comment, the test is suited. 
N/A 
Competent body 
The framework requires a too detailed report of different 
parameters e.g. how the temperature remains constant,...In the 
framework for APC less details are asked for, this is better. All the 
detergents score much better than the reference detergent, it 
seems that the reference detergent is rather weak. 
N/A 
Industry 
Ok for this criteria. Maybe it is possible to eliminate foam criteria 
from the test that is not a proof of efficacity. 
Y 
Industry 
Mentioning dosage in Teaspoons is not relevant for professional 
market. Would be better to have the choice => replacing "and" by 
‘or’. 
Y 
Industry 
For professional use a dosage per litre is better, because sinks are 
often bigger than 5 litre in professional areas. 
Y 
Industry 
Advise the customer to apply for a rinse step after the hand- 
wash. 
Y 
Industry 
association 
Mentioning the dosage in teaspoons is not relevant for the 
professional products. Item b) should read as "in millilitres (and 
teaspoons) for consumer products and in millilitres for 
professional products". 
Y 
Competent body 
We can precise in the criteria how many milliters are contained in 
a tea spoon. Furthermore, it seems to be useless to have this 
information (in tea spoons) for professional products. 
8.  User 
instructions 
Are additional requirements and instructions 
for dosage needed? 
N/A 
Competent body 
The naming of dirty should be the same as refered to in the 
reference dose. Now it is "dirty" and "normally soiled", this is 
confusing. 
Y 
Competent body 
Can claim the performance of the products. 
9.  Information 
appearing on 
the EU Ecolabel 
Is there any other information which should be 
included on the EU Ecolabel claims text? 
N/A 
Industry 
How is going to take place the labeling at the level SGH? 
N/A 
Industry 
One could consider sustainable sourcing of renewable, making use 
of existing schemes (e.g. from RSPO) 
N/A 
Industry 
For professional use training and/or product information sheets 
could also stimulate more sustainable use. 
10. Further issues 
or hot spots for 
HDDS 
Should further criterion be developed, either 
because all the issues are not already covered 
or because of recent developments which 
affect the environmental performance of 
HDDs? 
N/A 
Industry 
Yes, a criterion in regard with the use of Raw materials based on 
renewable carbon.

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132 
Criterion 
Question 
Response 
(Y/N) 
Stakeholder type 
Comment 
N/A 
Industry 
association 
Potentially sustainable sourcing of renewables could be 
considered, there where schemes are in place. 
N/A 
Industry 
No. Fragrances dominate CDV score too much, but do not 
contribute to technical performance. In other words, there is no 
clear link to technical performance and CDV. 
N/A 
Industry 
No; The performance is linked to a specific chemistry (example: 
acidic material with a good CDV is a bad degreaser...) 
N/A 
Industry 
association 
No. CDV is too much driven by fragrance, which is not linked to 
cleaning performance, but which is one of the drivers for 
consumer preference 
 
Do you consider it feasible to link the CDV and 
performance criteria? If yes, please explain 
your approach 
N/A 
Industry 
No. The CDV tox depends to raw materials used in the 
formulations. Even if you choose raw materials with low CDV tox 
values, you must be as efficient as the ecolabel reference. 
N/A 
Industry 
I do not know any example. Yes, nanomaterials should be banned 
in relation with possible health concern. 
 
Do you know of any examples of the use of 
nanomaterials in HDDs? Should their use be 
banned from this product group and why? 
N/A 
Competent body 
Our experts are checking this, probably I come back to you with an 
answer on this question next week.

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133
Annex VIII: Detergents production process and chemistry involved 
Source: Manufacturing of detergents was compiled by Heather Wansbrough from two articles, one from Ralph 
Laing and the other from Paul Milson and with reference to:  
- the enclyclopedia Britannica (15th Ed) Encyclopedia Britannica Inc 1979 
- Selinger, Ben; Chemistry in the market place (3rd Ed); Harcourt brace Jovannovich, 1986 
 
Detergents are produced industrially in four basic steps. This annex lists different steps because in the 
industrial processes described each of these is done over several process steps, but in principle it could be done 
in the three steps outlined here.  
 
Step 1 – Saponification 
A mixture of tallow (animal fat) and coconut oil is mixed with sodium hydroxide and heated. The detergent 
produced is the salt of a long chain carboxylic acid 
 
Step 2 – Glycerine removal 
Glycerine is more valuable than detergent, so most of it is removed. Some is left in the detergent to help make 
it soft and smooth. Detergent is not very soluble in salt water, whereas glycerine is, so salt is added to the wet 
detergent causing it to separate out into detergent (soap) and glycerine in salt water 
 
Step 3 – Soap purification 
Any remaining sodium hydroxide is neutralized with a weak acid such as citric acid and two thirds of the 
remaining water removed 
 
Step 4 – Finishing 
Additives such as preservatives, colour and perfume are added and mixed in with the soap/detergent and it is 
packed for sale 
 
In addition to the described process, detergents usually incorporate a variety of other ingredients that act as 
water softeners, free-flowing agents, etc. 
 
The chemistry of detergents 
All detergents contain a surfactant as their active ingredient. This is ionic species consisting of a long, linear, 
non-polar ‘tail’ with a cationic or anionic ‘head’ and a counter ion. The tail is water insoluble and the head is 
water soluble – a difference in solubility which has two important implications. Firstly, this makes the 
surfactant molecule a wetting agent: the tails migrate to align themselves with the solid: water interface, 
lowering the surface tension at that point so that it penetrates the fabric better. Secondly, it allows the oily dirt 
particles to form an emulsion with the water: the tails of may surfactant molecules surround an doily dirt 
particle, forming a micelle with a drop of oil in the centre and the ionic heads of the surfactant molecules 
pointing outwards and hence keeping the micelle in the polar solution. 
 
The detergent manufacturing process 
Detergents use a synthetic surfactant in most of the cases, instead of the metal fatty acid salts. They are made 
both in powder and liquid from, and sold as laundry powders, hard surface cleaners, dish washing liquids, fabric 
conditioners, etc. most detergents have soap in their mixture of ingredients, but it usually functions more as a 
foam depressant than as a surfactant.  
 
Detergent powder manufacture 
 
Step 1 – slurry making 
The solid and liquid raw ingredients (see table xx) are dropped into a large tank know as a slurry mixer. As the 
ingredients are added the mixture heats up as a result of two exothermic reaction: the hydration of sodium 
tripolyphosphate and the reaction between caustic soda and linear alkylbezenesulphonic acid. The mixture is 
then further heated to 85C and stirred until it forms homogenous slurry.

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Step 2 – spray drying 
The slurry is de-aerated in a vacuum chamber and the then separated by an atomiser into finely divided 
droplets. These are sprayed into a column of air at 425C, where they dry instantaneously. The resultant powder 
is known as ‘base powder’ and its extract treatment form this point on depends on the product being made.  
 
Step 3 post dosing 
Other ingredients are now added, and the air blown through the mixture in a fluidiser to mix them into a 
homogenous powder. Typical ingredients are listed in Table xx.  
 
Table 50: the ingredients of detergent base powder 
Solids 
Ingredient 
Function 
Sodium tripolyphosphate (STP) 
Water softener, ph buffer (to reduce alkalinity) 
Sodium sulphate 
Bulking and free-flowing agent 
Soap noodles 
Causes rapid foam collapse during rinsing 
Zeolite 
Water softener (adsorbs Ca2+ and Mg2+) in countries where STP is not 
used. Granulating agent for concentrated detergents 
Sodium carboxymethyl cellulose 
Increases the negative charge on cellulosic fibres such as cotton and 
rayon, causing them to repel dirt particles (which are positively 
charged) 
Liquids 
Linear alkylbenzene sulphonic acid 
(LAS) 
Surfactant – the main active ingredient 
Caustic soda solution 
Neutralises the LAS 
Coconut diethanolamide or a fatty 
alcohol ethoxylate 
Non-ionic detergent and foam former 
Fluorescer 
Absorbs UV light and emits blue light, causing ageing cotton to appear 
white rather than yellow 
Water 
Dissolves the various ingredients, causing them to mix better  
 
Liquid detergent manufacture 
 
Step 1 soap premix manufacture 
Liquid detergent contains soap as well as synthetic surfactants. This is usually made first as a premix, and then 
other ingredients are blended into it. This step simply consists of neutralising fatty acids (rather than fats 
themselves) with either caustic soda (NaOH) or potassium hydroxide.  
 
Step 2 – ingredient mixing 
All ingredients expect enzymes are added and mixed at high temperature. The ingredients used in liquid 
detergent manufacture are typically sodium tripolyphosphate, caustic soda, sulphonic acid, perfume and water. 
The function of these ingredients has been covered above.  
 
Step 3 – enzyme addition 
The mixture is cooled and milled and the enzymes added in powder form.  
 
Table 51: typical post dosing ingredients 
Ingredient 
Function 
Soda ash ( anhydrous Na2CO3)  
Keeps the pH at 9.0-9.5. This ensures optimum detergent function. Also 
forms insoluble carbonates with Ca and Mg, so acts as a water softener 
Bleach (usually sodium 
perborate) NaBO3 
Bleaches stains without damaging colour fast dyes. Sodium perborate breaks 
down at high temperatures to release H2O2, which functions this way 
Bleach activator (e.g. 
tetraacetylethylenediamine) 
Catalyses sodium perborate breakdown at low temperatures 
Enzymes 
(e.g. alkaline protease) 
Alkaline protease breaks down proteins in the alkaline conditions created by 
soda ash, helping to remove stains 
Colour and perfume 
Create a more aesthetically pleasing product.

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Environmental implications of the production process 
Soap is designed as a product to be used once then flushed down the drain, so as expected the environmental 
implications of its manufacture are not nearly so great as many other chemical processes. There are two min 
areas of concern: the safe transport and containment of the raw materials and the minimization of losses 
during manufacture.  
 
The three main components of detergents by both cost and volume are oils, caustic and perfumes. Oils and 
perfume are immiscible in water and if spilled create havoc, although the oils do solidify at room temperature. 
Transport of these products is by trained carriers and the systems for pumping from the truck to storage tanks 
are carefully designed. Perfumes are bought in lined steel drums which are quite robust and flammable 
perfumes are not used in soaps.  
 
All storage tanks are surrounded by bunds to catch the contents of a tank should it rupture or a valve fail. 
When the storage system is designed, all the safety features (such as access to tank and valves) are designed in, 
as well as procedures to deal with the product should it end up in a bunded area. Within the plant, all the 
process areas are also bunded, and the trade waste from the piped to the interception tank before draining to 
the council's trade waster system. The contents of the interception tank are continuously monitored for acidity 
or alkalinity, and are designed to settle out excess solids or light phase chemicals. If a spill is detected in the 
plant itself, a portion of the interception tank can be isolated off and the effects of the spill neutralised before 
the waste is dumped.  
 
In most cases, however, potential problems are identified and stopped before they happen. Often an off-spec 
product can be reprocessed and blended rather than dumped, and even washout water can be reprocessed to 
minimise the discharges from the plant.  
 
Finally, the manufacturing process itself is closely monitored to ensure any losses are kept to a minimum. 
Continuous measurements of key properties such as electrolyte levels and moisture both ensure that he final 
product is being made to spec, and ensures the manufacturing process is working as it was designed to. Hence 
the losses in the plant will indirectly be minimised because the process itself is being monitored.  
 
Synthetic detergent biodegradability 
There has recently been a strong move away from the environmentally hazardous biologically stable 
detergents used in the past to biodegradable ones. The sulphonic acid and non-ionic detergents used to 
produce both liquid and powder detergents are fully biodegradable (in most cases). The sulphonic acid is made 
form a highly linear alkylbenzene, mainly dodecylbenxene and the non-ioninc are ethoxylated long chain 
alcohols. The sodium lauryl ether sulphates also used in liquid detergents and shampoos are highly 
biodegradable, being made from either natural or synthetic linear C12-C15 alcohols.  
 
Detergent powder 
Detergent poweder manufacture has some specific environmental issues associated with it that are not present 
in other areas of the industry. These are dust control and VOC emissions. Dust present during delivery and 
transfer of bulk powdered detergent (and powdered raw materials) is a potential problem. Dry and wet 
cyclones are used to filter out most of the dust, and all emissions are monitored. If the dust level in these does 
exceed acceptable limits, appropriate remedial action is taken. Dust levels in emissions must be kept below 
50 mg/m3 
 
The spray drying tower also releases VOC. These emissions are minimised by having tight specifications on 
what can be added as primary detergent active material. Any potentially hazardous materials are added with 
the secondary actives after the tower so that it is not heated. Spot checks are done on the total hydrocarbon 
content of the exhausted gases using a flame ionisation detector.