REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Pursuant to Article 9 of Commission Recommendation 98/480/EC of 22 July 1998 concerning Good Environmental Practice for Household Laundry Detergents

1. Introduction

1.1. Since the early 1970s the Community has operated a policy in the detergent sector aimed at solving the problems caused by surfactant foam in water systems. All existing Community detergent legislation [1] is therefore intended principally to reduce environmental problems such as foaming in rivers and is based on biodegradability tests.

[1] Council Directive 73/404/EEC, OJ L 347, 17.12.1973. Council Directive 73/405/EEC, OJ L 347, 17.12.1973. Council Directive 82/242/EEC, OJ L 109, 22.4.1982. Council Directive 82/243/EEC, OJ L 109, 22.4.1982. Council Directive 86/94/EEC, OJ L 080, 25.3.1986.

1.2. The existing detergent legislation has provided a stable foundation for the Single Market and it has ensured a relatively high degree of environmental protection. Surfactants classified as "primary biodegradable" lose their surface-active properties relatively quickly. They are generally less toxic than other surface-active chemicals. Regulatory requirements for the primary biodegradability of surfactants have not only solved the foaming problem, but have also provided a comprehensive mechanism for banning non-biodegradable surface-active chemicals.

1.3. However, since the 1970s detergent and surfactant manufacturing technology has changed significantly. The old detergent production technology was based on spray tower technology which subjected the product to severe conditions that restricted the range of surfactants that could be used. New detergent manufacturing technologies allow a more concentrated product and the use of a wider range of chemicals. Some of these new surfactant chemicals cannot be adequately tested with the test methods laid down by the existing detergent Directives.

1.4. Furthermore, the detergent legislation has been supplemented by voluntary measures, such as the Commission Recommendation on the labelling of detergents and cleaning products [2], and the Commission Recommendation concerning good environmental practice for household laundry detergents [3].

[2] Commission Recommendation 89/542/EEC, OJ L 291, 10.10.1989.

[3] Commission Recommendation 98/480/EC, OJ L 215, 1.8.1998.

1.5. In 1996 AISE developed a Code of Good Environmental Practice for the Household Laundry Detergents, (hereafter "the Code"), for implementation in 18 countries [4]: the 15 EU Member States and 3 additional countries (Iceland, Norway and Switzerland). AISE [5] committed itself to undertake initiatives in order to achieve these targets and approached the Commission to request from the Commission an endorsement of the Code objectives. This request, after consultation between the Commission and Member States, lead to a Commission Recommendation.

[4] Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, Portugal, Spain, Sweden, The Netherlands, United Kingdom belonging to the EU and Iceland, Norway and Switzerland.

[5] AISE (Association Internationale de la Savonnerie, de la Détergence et des produits d'Entretien) is the official body that represents the soap, detergent and maintenance products industry within Europe and towards other international organisations. AISE's members and its National Associations are present in 28 countries (in Europe essentially); their members are companies locally placing products of the above categories on the market. AISE represents over 90 % of the detergent and cleaning product industries in the Community.

2. Aims of Commission Recommendation 98/480/EC of 22 July 1998

2.1. Commission Recommendation 98/480/EC of 22 July 1998, concerning good environmental practice for household laundry detergents, introduced for the first time at Community level an agreement between Industry and the Commission as a tool for Industry to implement its commitment to the actions envisaged in the Recommendation. It takes into account the Council and the European Parliament resolutions of 17 July 1997 and of 7 October 1997 on Environmental Agreements, which recognise that voluntary-agreements may be a valuable instrument to make optimum use of the industry's own responsibilities [6].

[6] Council and European Parliament resolution of 17 July 1997, OJ C 286, 22.9.1997, p. 254. Council and European Parliament resolution of 7 October 1997, OJ C 321, 22.10.1997, p. 6.

2.2. The Recommendation established five targets, relative to the situation existing in the 15 EU Member States in 1996, to be achieved by the end of 2001:

- 5 % reduction in energy consumed per wash cycle for the product group (kWh/wash); base: 1,04 kWh;

- 10 % reduction in weight of household laundry detergents consumed per capita (kg/head); base: 9,94 kg;

- 10 % reduction in weight of the primary and secondary packaging of the product group consumed per capita (kg/head); base: 0,71 kg;

- 10 % reduction in weight of "poorly-biodegradable organic ingredients" (PBO) consumed per capita (kg/head); base: 0,32 kg;

- Provide information to the consumers on how to use detergents in a better way.

2.3. Implementation of the Code started in Denmark and Sweden in autumn 1997 as a pilot project. Following the positive results obtained in this pilot project, and the endorsement by the European Commission in the form of a Recommendation in July 1998, implementation in the other EC countries started mid-1998/early 1999 and has continued since.

2.4. Commitments and targets in the AISE Code are based on risk assessment and life cycle analysis. Under the Code, manufacturers agree to provide consumers with relevant usage instructions to guide them on how to do their laundry in an environmentally responsible manner.

2.5. AISE and some non-AISE members that sell, market or produce household laundry detergents within the European Community and the European Economic Area therefore committed themselves to ensure compliance with this Recommendation, in co-operation with National Associations, and to report on progress towards the targets for consumption, packaging and PBOs at least every two years, and to report on the energy consumption at the end of the 5-year period i.e. to report data for 2001.

2.6. It should be noted that Member States agreed to contribute to the implementation of this Commission Recommendation and that all stakeholders showed interest in the achievement of the targets set in the above Recommendation, and particularly:

- the use of lower washing temperatures to decrease energy consumption and thus decrease CO2 emissions;

- a decrease of the consumption of detergents and their packaging to lower the general environmental impact of detergents;

- a decrease of the poorly biodegradable ingredients in detergents (PBO's), which may reduce the effects of detergents on the environment.

3. Stages in the implementation of Recommendation 98/480/EC

3.1. As stipulated in Article 7 of the Recommendation, AISE has arranged for an independent organisation to collect and process statistics. PricewaterhouseCoopers ("PwC") was selected to monitor the progress towards targets for consumption, packaging and PBOs every 2 years, and in addition to report on energy consumption in the final report in 2002. PwC was acquired by IBM global services during 2002 with the result that the final report appears under name of IBM rather than PwC. Despite this change, the final report was produced by the same team of people who produced the two earlier interim reports.

3.2. Interim reports were produced by PwC for the periods 1996-1998 [7] and 1999-2000 [8]. Both reports were similar in structure. They describe the methodology used to collect data and give results for the three targets mentioned above, at both European and National levels, with a summary of the main trends. These reports were published on the Commission's website:

[7] "AISE Code of Good Environmental Practice: Progress report to the European Commission, 1997-1998" , PricewaterhouseCoopers, Dec 1999.

[8] "AISE Code of Good Environmental Practice: Progress report to the European Commission 1999-2000", PricewaterhouseCoopers, Oct 2001.

and were the subject of a report from the Commission to the Council and the European Parliament [9].

[9] "Report from the Commission on the results reached for the period 1996-2000 by the implementation of Commission Recommendation 98/480/EC", COM(2002)287.

3.3. AISE provided complementary reports [10], [11] to the first and second PwC interim progress reports. These complementary reports focused mainly on actions undertaken by AISE's National Associations since the adoption of the Recommendation and its official launch in all Member States for the whole of the Code project, in particular on actions concerning the provision of information designed to encourage the correct use of household laundry detergents.

[10] "Implementation of the AISE Code in Europe: complementary report from AISE to the PwC 1997-1998 Progress Report", AISE, Oct 1999.

[11] "Implementation of the AISE Code of Good Environmental Practice for household laundry detergents in Europe, AISE 1999/2000 progress report", AISE, Nov 2001.

3.4. After the submission of the PwC and AISE reports in October 2000, the Commission organised a Working Group Meeting with the Member States in order to provide information on the progress achieved for the years 1997/1998. Consultation with other stakeholders such as BEUC (European Consumers' Organisation) and EEB (European Environment Bureau) were also organised and comments were provided by them. The reports were also submitted to the Consumer Committee for an opinion on the state of implementation of the Recommendation.

3.5. The main conclusions of these Organisations for the reporting period 1996-1998 were that for the four targets which were to be considered in the intermediate evaluation, two of them were fully achieved: the reduction of the PBOs and the information to consumers, but that the 1996-1998 data suggested that much remained to be done to reduce consumption of detergents and of packaging.

3.6. IBM has now prepared a final report [12] covering the whole of the five year period. The report is similar in structure to the interim reports by PwC and describes the methods of data collection, audit procedures, planning and management. Energy data, reported in the baseline report, were gathered again for 2001 through a market survey conducted by a specialist company, Taylor Nelson Sofres (formerly Taylor Nelson AGB).

[12] "AISE Code of Good Environmental Practice: Final report to the European Commission 1996-2001", IBM, Oct 2002.

3.7. The IBM final report for the period 1996-2001 shows that the number of companies committed to the Code has increased from 119 to 168, despite a number of mergers in the industry. These companies represent approximately 90 % of the EU market. Data on the consumption of detergents, packaging and PBOs and energy for the year 2001 is compared with the baseline data.

3.8. The AISE final report [13] presents the same data as the IBM final report and also comments on the consumption trends. In addition the AISE report presents the media actions undertaken by AISE to promote sustainable consumption, in particular the "WashRight" campaign, with the objective of reducing consumption of energy and detergents through correct usage. The actions comprise television advertising campaigns, a dedicated website, and reminder panels on packaging.

[13] "Implementation of the AISE Code of Good Environmental Practice for household laundry detergents in Europe, AISE 1996/2001 final report, AISE, Dec 2002.

3.9. The Commission consulted with the Member States on 21 November 2003, with AISE on 18 March 2003 and with the Consumer Committee on 5 June 2003, on the state of implementation of the Recommendation. The Consumer Committee issued an opinion [14] in October 2003.

[14] Opinion CC 2003 045/3 available at: http://europa.eu.int/comm/consumers/ cons_org/associations/ committ/opinions/opinions_en.htm

4. Progress towards the target criteria over the period 1996 to 2001

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Figure 1: Progress towards the targets for 1996-2001 (data from section 4.1)

4.1. Progress in the 15 EU Member States towards the targets described under heading 2.2 is shown graphically in figure 1 above and in tabular form below:

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4.2. The fifth target concerned the supply of information to the consumer as a supporting measure to help achieve the four quantified targets given in the table above. Provision of appropriate information to the consumer was achieved through the "WashRight" campaign and through printing it on the packaging of the detergent. The information target can be considered to have been met.

4.3. The data in the table above suggest that the initial upward movement in detergent consumption between 1996 and 1998 was effectively reversed and further reduced during the rest of the period. The reduction in consumption did not meet the target with respect to the 1996 baseline. The reduction with respect to the 1998 peak figure was 9,9 %.

4.4. Packaging consumption showed a substantial reduction during the first reporting period, but since then no further progress was made towards the target. The target was missed by a significant margin.

4.5. The target for PBO's was already met at the end of the 1996-1998 reporting period, and the trend has continued further downward since then. The target was exceeded by a large margin.

4.6. Data on energy consumption was collected only at the end of the five year period. The target of a 5 % reduction was exceeded by a significant margin.

5. Analyzing the success of the implementation in practice

5.1. The Recommendation set four quantitative targets concerning reductions in consumption, and a further target of providing consumers with information designed to encourage the correct use of detergents. Encouragement in the correct use of detergents was seen as an essential supporting measure in those areas where the active co-operation of the consumer would be indispensable for meeting the targets i.e. reduced consumption of detergents and of energy. Success in meeting the latter two targets would therefore imply that adequate information had been supplied to the consumer, and that it had been acted upon.

5.2. The WashRight campaign: Information to the consumer on correct dosage and washing temperature was prominent in the WashRight campaign which presented the information to the consumer in a uniform format across the EU. The information itself was tailored to the existing usage habits in each country. By the end of the reporting period, the target for reduced energy consumption was met, whereas that for detergent consumption was not. At first sight, this might seem to imply that information was getting through to the consumer, who acted on it appropriately in the case of energy consumption, but who was less receptive to it in the case of detergent consumption. Indeed, a survey conducted on behalf of AISE reported that 79 % of consumers followed WashRight recommendations on energy (washing temperature) and 64 % on detergent dosage.

5.3. However, changes in consumer washing habits, combined with the fact that the energy target was set on a per-wash basis whereas the detergent consumption target was set on a per-capita basis, also contribute substantially to the divergent performance on targets for energy and detergent consumption. The influence of these additional factors is examine in more detail in Annex A. The correlations show that the reduction in detergent consumption is attributable to consumers following the dosage instructions rather than to the use of more compact forms of laundry detergent. While this result is fully consistent with the objectives of the WashRight campaign, it does not prove that there was a causal link between the campaign and the reduced consumption.

5.4. The four quantitative targets: None of the four quantitative targets set in the Recommendation was met exactly. The results are a mixture of under-performance in some cases and over-performance in others. Whereas the additional benefits to the environment from overshoot on the targets for energy and PBOs are welcome as such, the shortfall in the benefit to the environment from the undershoot on consumption of detergents and packaging is not.

5.5. Evaluation of the overall degree of success achieved by the implementation depends on to what extent the overshoot on some targets can be shown to compensate for the undershoot on others i.e. whether the benefit to the environment due to the results obtained is of lesser or greater value than that of the targets set. The method used to quantify this comparison of benefits is described in Annex B. This quantitative analysis shows that the over-performance on the target for PBOs was more than sufficient to compensate for the under-performance on the other targets.

6. Conclusions

6.1. The WashRight campaign did meet its stated target of providing appropriate information to consumers throughout the EU. It was not possible to quantify the contribution of the campaign towards achieving the four quantitative goals, however, because the impact of information on consumer behaviour is intrinsically difficult to evaluate.

6.2. The analysis of the results achieved for the four quantitative targets shows that the net benefit to the environment resulting from the reductions achieved in practice by industry in the implementation of the Recommendation, taken together with the contribution of the consumer, is significantly greater than it would have been if the targets had been met exactly. The Commission therefore concludes that overall the implementation of the Recommendation was a success.

6.3. With this report the Commission provides the information on the results achieved by the implementation of Recommendation 98/480/EC, as required by Article 9 of the Recommendation.

7. Future developments

AISE is developing a "Charter on Sustainable Development" to expand on the approach adopted in the Code of Good Environmental Practice. The Charter covers professional cleaning as well as laundry detergents and foresees a central role for health and environmental risk assessments on detergent ingredients [15] in the formulation of detergents. More recently, the Commission has adopted a proposal for new legislation on chemicals, the REACH system, which also makes risk assessment a key criterion for the access of chemical products to the market. In addition, the existing legislation concerning the biodegradation of surfactants in detergents is being modernised to provide a higher level of protection of the environment.

[15] http://www.heraproject.com/ RiskAssessment.cfm

Annex A

Analysis of the WashRight campaign

1. Although the provision of information to the consumer is clearly only one factor affecting consumer behaviour, the considerable variations in the results recorded across the EU underline the importance of the other factors. For example, the change in detergent consumption varied from - 18,8 % in Denmark to + 13,7 % in Finland. Similarly, the change in energy consumption varied widely, from - 13,5 % in Greece, to 0 % in Germany, Ireland, Spain and the UK. These variations occurred despite the provision of the same information to consumers in all Member States. At first sight, the wide variations in the consumption data seem difficult to reconcile with the data from the WashRight survey that shows that 64 % and 79 % of consumers respectively followed the recommendations on detergent and energy consumption.

2. AISE explain the undershoot on the target for detergent consumption in terms of three factors. First, there was a trend in consumer preference away from compact products and refill bags. Second, there was a demographic shift to more single-person households. Third, there was a trend by consumers to wash clothes more often. The AISE report gives figures for the period 1996-2001 of a 4,1 % increase in the number of households and an 11 % increase in the total number of washes. To put these numbers in context, the population of the EU increased by 1,3 % during the same period. AISE also point out that the overall detergent consumption per wash has decreased by 16 %, whereas the per capita reduction was 7,9 %. Likewise, the reduction in packaging consumption per wash was 14,9 %, compared with the per capita reduction of 6,7 %.

3. Nevertheless, these overall figures for detergent consumption do not address the question of how much of the reduction that was achieved was due to the consumer following the dosage information in line with the WashRight recommendations, and how much was due, for example, to the use of more compact products. Establishing cause and effect on these questions, particularly concerning consumer behaviour, is not possible given the nature of the data available. It is possible, however, to distinguish and quantify the separate contributions of reduced dosage and of the use of different detergent product forms to the overall reduction in detergent consumption.

4. The value of the latter contribution is deduced from the statistical correlation between overall detergent consumption and overall packaging consumption. Detailed data for the 15 EU Member States for the changes recorded between 1996 and 2001 is tabulated below. As shown in figure 2, the data has a correlation coefficient of R2 = 0,48. This correlation value means that just under half of the change in detergent consumption and packaging consumption can be attributed to a common underlying cause.

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Figure 2: Correlation between changes in detergent consumption and packaging consumption in the 15 EU Member States for the period 1996-2001 (data from the IBM report).

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Change in consumption of PBOs, detergent, energy and packaging between 1996 and 2001 in the 15 EU Member States (data from IBM report).

5. By considering figure 2 as a deviation from a scenario in which no consumer switches to a different detergent [16], the correlation coefficient of R2 = 0,48 can be interpreted as indicating that about half of the reduction in the overall detergent consumption per capita is due to continued use by the consumer of the same detergent product in the same packaging, but with a reduced consumption of that product. The remaining half of the overall per capita reduction in consumption of detergent can be attributed to the use of differently packaged products. This might be the result of a major change by the consumer, such as the use of compact products instead of regular powders, for example, but even a minor change by the consumer, such as using the same brand in a different packet size would also produce a similar statistical effect because the ratio of packaging to detergent would change.

[16] The case in which each consumer continues to use the same detergent product in the same packaging and, for whatever reason, changes only the level of consumption of the product is, in fact, the scenario that corresponds to the normal use pattern in many households. In this case, the consumption of packaging and detergent are in a fixed ratio, irrespective of the level of consumption, and the corresponding correlation diagram would have the following characteristics compared with figure 2. First, the slope of the correlation line has a value of exactly 1,00, i.e. an x % change in detergent consumption automatically leads to an x % change in packaging consumption. Second, the correlation line passes through the origin, i.e. for no change in detergent consumption there is no change in packaging consumption. Third, the correlation coefficient is R2 = 1,00, i.e. all points would fall exactly on the correlation line, reflecting the fact that all the changes in detergent and packaging consumption have the same underlying cause, namely, a change in the amount - but not in the type - of detergent product consumed.

6. Therefore, of the per capita reduction in detergent consumption of 7,9 % reported by IBM, only about half, i.e. 4 %, can be attributed to reduced consumption by consumers of their usual product. Because the reduction in detergent consumption per capita was accompanied by an increase in the number of washes per capita, this reduced detergent consumption can only be the result of using a reduced dose of detergent per wash using the usual product. AISE report that during the WashRight campaign the recommended dose for detergents was reduced by just over 25 %, i.e. from 150g to 110g per wash. The achieved reduction of 7,9 % in detergent consumption per capita translates into a reduction in consumption per wash of 17 % (92,1 % per capita consumption/111 % number of washes). However, only half of this reduction per wash, i.e. 8,5 % instead of 17 %, can be attributed to consumers reducing the dose of their usual product in line with the dosage information provided to them.

7. The dose reduction resulting from the use of other product forms contributed a further reduction of 8,5 %. At first sight, a reduction in consumption of 8,5 % associated with a switch to other product forms would imply a switch to compact product forms. In such a case, it would seem appropriate to credit at least a part of the reduction in consumption to the manufacturer for introducing a new product form, instead of attributing all the reduction to the consumers for following the reduced recommended dosage. However, AISE reports that there was in fact a slight trend away from compact product forms. Indeed, this is supported by figure 2 which shows an increase in packaging consumption of 1,1 % even when there was no change in detergent consumption.

8. Why should a trend to less compact product forms lead to a reduction in detergent dose per wash? A possible explanation is that, independently of any information campaigns, when consumers switch to a different product, whether compact or not, they are far more likely to read the dosage information carefully than they would if they continued to use their usual product. There are therefore plausible, though not conclusive, reasons for attributing the entire 17 % reduction in detergent consumption per wash, or of 7,9 % per capita, to compliance by the consumer with the dosage information.

9. Compared with the recommended reduction in detergent dosage of 25 % per wash, the reduction of 17 % per wash is therefore equivalent to about two thirds of consumers reducing their dosage in line with the new reduced dosage recommendations. This figure is consistent with the result of the AISE survey concerning the WashRight campaign which reported that 64 % of consumers followed the dosage information. It therefore appears that a majority of consumers responded appropriately to the dosage information each time the washing machine was used. The effect of the WashRight campaign on the level of compliance, however, cannot be deduced from this data.

10. The overall magnitude of the consumer response to the dosage information, i.e. the reduction in detergent dose per wash of 17 %, exceeded the target for reducing detergent consumption by 10 %. However, because the consumer now uses the washing machine more often, the overall reduction in consumption of detergent and packaging on a per capita basis are only about half of what they would otherwise have been, and consequently these two consumption targets have not been met on a per capita basis [17].

[17] In contrast to the targets for detergent and packaging consumption, the target for energy consumption was originally set on the basis of energy per wash. Given the 11 % increase in the number of washes, as reported by AISE, the change in energy consumption per wash of - 6,4 % translates into a change of energy consumption per capita of + 2,2 %. The results recorded on a per-wash basis are therefore very different from those recorded on a per capita basis for all the target criteria.

11. The differences between percentage reductions in consumption on a per wash basis, and in consumption on a per capita basis, were caused primarily by the consumer trend to more washing - a trend that was not foreseen in the Recommendation (or by the WashRight campaign) i.e. the differences were caused by an external factor. Whereas it is clear that external factors have intervened to make the challenge to industry much harder, the change in consumer wash behaviour cannot be ignored in any objective evaluation of the success of the Recommendation with respect to its stated aim of reducing the impact of laundry detergents on the environment. Moreover, such an evaluation should be made as quantitative as possible. Such an analysis is given in Annex B.

Annex B

Analysis of the four quantitative targets

1. The Recommendation foresaw that there would be a substantial and worthwhile reduction in the environmental impact resulting from the use of household detergents if the various targets were achieved. Nevertheless, it was clear that the benefits to the environment from achieving the targets could not be quantified. Judging the overall success of the implementation in the case of overshoot or undershoot of the targets therefore presents certain inherent difficulties when trying to relate the quantifiable reductions achieved by industry and the consumer to the non-quantifiable benefit of those reductions to the environment.

2. A simple summing up of the debits and credits on the various targets can be taken as an acceptable indicator of the overall effort made by industry to meet the targets, but the complexity of environmental responses to chemical inputs would seem to preclude the use of such a simple indicator as a measure of the environmental benefit - unless it can be shown that there is good reason to attribute equal weight to each of the target parameters.

3. Clearly, an exact equivalence between the benefit to the environment obtained from reduced inputs from parameters as different as electrical energy and PBOs cannot be rigorously established. The first affects the atmosphere (global warming) through the release of CO2, whereas the second affects the aquatic environment (toxicity). What can be established, however, is that the greatest concern arising from the use of detergents relates to their impact on the aquatic environment. It is for this reason that EU legislation on detergents focuses on the aquatic compartment, and on the biodegradability of surfactants in particular.

4. It would therefore seem appropriate to rank the four quantifiable target parameters according to their relevance to the aquatic compartment. PBO and detergent consumption both impact directly on the aquatic compartment, and they are therefore ranked above packaging and energy consumption. Detergents are composed of organic and inorganic ingredients. The organic components are recognised to be generally of more concern than the inorganics, with the poorly biodegradable ones being of most concern - indeed this is why a reduction in PBO consumption was chosen as one of the targets. PBO consumption is therefore ranked above detergent consumption. The environmental impacts of packaging or energy consumption are of much lower concern. Nevertheless, because of the commitment of the EU to the Kyoto protocol, there is an argument for ranking a reduction in the consumption of energy ahead of a reduction in packaging.

5. Having established the ranking order of:

1. PBO consumption,

2. detergent consumption,

3. energy consumption,

4. packaging consumption,

it is possible to proceed rapidly to a worst-case assessment of the overall environmental benefit resulting from the implementation compared with that expected from exactly achieving the target values. To do this it is sufficient, firstly, to assign a weighting factor of 1 to the consumption of packaging and, secondly, to assume that a higher ranking target parameter is not less important than a lower ranking one.

6. This assumption establishes a limiting case in which a weighting factor of 1 is also applied to the three remaining parameters. The consequence of this assumption is to underestimate the impact on the environment of both undershoots and overshoots of the parameters to which the environment is most sensitive. If it were the case that undershoots dominated numerically over overshoots in the highest ranked parameters, this would be an unacceptably lax assumption to make. However, as overshoots dominate, and particularly because the largest overshoot is on the highest ranked target parameter, the assumption is very strict and safe as it sets the lowest possible limit on benefits to the environment due to overshooting the target values.

7. Under these assumptions, the condition for the equal weighting of target parameters as mentioned in section 2 above is fulfilled, and consequently the overall environmental benefits deriving from the implementation achieved in practice can be compared with the benefits that would have arisen from exactly achieving the target values simply on the basis of the magnitude, i.e. the percentage values, of the overshoots and undershoots on each of the targets.

8. The table below shows that under the most stringent assumptions, i.e. that the undershoot on the targets for packaging and detergent consumption is only just compensated by the same number of percentage points overshoot on PBOs, there was a net benefit to the environment equivalent to exceeding the targets by 9,7 % overall.

>TABLE POSITION>

The above data for PBOs, detergent, and packaging consumption are per capita values, whereas for energy the corresponding values are on a per wash basis. If the energy consumption per capita (+ 2,2 %) were to be considered instead of the energy consumption per wash (- 6,4 %), to take into account the 11 % increase in the number of washes, there would still be a net benefit to the environment of 1,1 %.

9. Under more realistic assumptions, where the impact of PBOs is assigned a weighting greater than 1, a much larger net benefit to the environment would be predicted than the value calculated above. It is clear that the large overshoot achieved on the target parameter to which the environment is most sensitive, i.e. PBOs, dominates over the sum of the undershoots on all other targets, even under the most stringent assumptions.