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
Date: 2004-02-27
Institutions: European Commission
Subjects: code of conduct, energy consumption, environmental protection, organic chemical, packaging, polishing and scouring preparations

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 27.02.2004 
COM(2004) 134 final 

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 

EN 

   EN 

 
 
 
  
1. 

Introduction 

1.1. 

1.2. 

1.3. 

1.4. 

1.5. 

1 

2 
3 
4 

5 

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 legislation1 is therefore intended principally to reduce 
environmental problems such as foaming in rivers and is based on biodegradability 
tests. 

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. 

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. 

Furthermore, the detergent legislation has been supplemented by voluntary measures, 
such as the Commission Recommendation on the labelling of detergents and cleaning 
products2,  and  the  Commission  Recommendation  concerning  good  environmental 
practice for household laundry detergents3. 

In 1996 AISE developed a Code of Good Environmental Practice for the Household 
Laundry Detergents, (hereafter “the Code”), for implementation in 18 countries4: the 
15 EU Member States and 3 additional countries (Iceland, Norway and Switzerland). 
AISE5 committed itself to undertake initiatives in order to achieve these targets and 
approached the Commission to request from the Commission an endorsement of the 

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. 
Commission Recommendation 89/542/EEC, OJ L 291, 10.10.1989. 
Commission Recommendation 98/480/EC, OJ L 215, 1.8.1998. 
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. 
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 

 
 
  
 
                                                 
 
 
Code  objectives.  This  request,  after  consultation  between  the  Commission  and 
Member States, lead to a Commission Recommendation. 

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 
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 responsibilities6. 

the  actions  envisaged 

its  commitment 

implement 

to 

to 

in 

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. 

2.4. 

2.5. 

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. 

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. 

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 

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.  

3 

 
 
  
 
                                                 
 
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. 

3.2. 

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. 

Interim reports were produced by PwC for the periods 1996-19987 and 1999-20008. 
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: 

http://europa.eu.int/comm/enterprise/chemicals/legislation/detergents/index.htm 

and  were  the  subject  of  a  report  from  the  Commission  to  the  Council  and  the 
European Parliament9. 

3.3. 

AISE  provided  complementary  reports10,11  to  the  first  and  second  PwC  interim 
progress reports. These complementary reports focused mainly on actions undertaken 

7 

8 

9 

10 

11 

“AISE  Code  of  Good  Environmental  Practice:  Progress  report  to  the  European  Commission, 
1997-1998” , PricewaterhouseCoopers, Dec 1999. 
“AISE  Code  of  Good  Environmental  Practice:  Progress  report  to  the  European  Commission 
1999-2000”, PricewaterhouseCoopers, Oct 2001. 
“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. 
“Implementation of the AISE Code in Europe: complementary report from AISE to the PwC 1997-1998 
Progress Report”, AISE, Oct 1999. 
“Implementation of the AISE Code of Good Environmental Practice for household laundry detergents 
in Europe, AISE 1999/2000 progress report”, AISE, Nov 2001. 

4 

 
 
  
 
                                                 
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. 

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. 

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. 

IBM  has  now  prepared  a  final  report12  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). 

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. 

The  AISE  final  report13  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. 

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 opinion14 in October 2003. 

“AISE Code of Good Environmental Practice: Final report to the European Commission 1996-2001”, 
IBM, Oct 2002. 
“Implementation of the AISE Code of Good Environmental Practice for household laundry detergents 
in Europe, AISE 1996/2001 final report, AISE, Dec 2002. 
Opinion  CC  2003  045/3  available  at:  http://europa.eu.int/comm/consumers/cons_org/associations/ 
committ/opinions/opinions_en.htm 

5 

3.4. 

3.5. 

3.6. 

3.7. 

3.8. 

3.9. 

12 

13 

14 

 
 
  
 
                                                 
4. 

Progress towards the target criteria over the period 1996 to 2001 

D e t e r g e n t   c o n s u m p t io n  
( k g  p e r   c a p ita   p e r   a n n u m )

B a s e lin e   c o n s u m p t io n

T a r g e t   c o n s u m p t io n   ( - 1 0 % )

1 9 9 6

1 9 9 7

1 9 9 8

1 9 9 9

2 0 0 0

2 0 0 1

P a c k a g i n g   c o n s u m p t i o n  
( k g   p e r   c a p it a   p e r   a n n u m )

B a s e lin e   c o n s u m p t io n

T a r g e t   c o n s u m p t io n   ( - 1 0 % )

1 9 9 6

1 9 9 7

1 9 9 8

1 9 9 9

2 0 0 0

2 0 0 1

P o o r l y   b i o d e g r a d a b l e   o r g a n i c s   ( P B O )   c o n s u m p t i o n  
( k g   p e r   c a p ita   p e r   a n n u m )

B a s e lin e   c o n s u m p tio n

T a r g e t   c o n s u m p t io n   ( - 1 0 % )

1 0 , 5 0

1 0 , 0 0

9 , 5 0

9 , 0 0

8 , 5 0

0 , 7 4

0 , 7 2

0 , 7 0

0 , 6 8

0 , 6 6

0 , 6 4

0 , 6 2

0 , 6 0

0 , 3 4

0 , 3 2

0 , 3 0

0 , 2 8

0 , 2 6

0 , 2 4

0 , 2 2

1 9 9 6

1 9 9 7

1 9 9 8

1 9 9 9

2 0 0 0

2 0 0 1

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: 

6 

 
 
  
 
 
 
 
1996-1998 

1996-2000 

1996-2001 

Target 2001 

Detergent consumption 

+ 2,2 % 

– 4,6 % 

– 7,9 % 

– 10 % 

Packaging consumption 

– 6,8 % 

– 5,9 % 

– 6,7 % 

– 10 % 

PBO consumption 

– 13,1 % 

– 14,5 % 

– 23,7 % 

– 10 % 

Energy consumption 

no data 

no data 

– 6,4 % 

– 5 % 

4.2. 

4.3. 

4.4. 

4.5. 

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. 

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 %. 

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. 

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. 

5.2. 

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. 

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 

7 

 
 
  
 
 
5.3. 

5.4. 

5.5. 

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. 

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. 

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. 

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. 

6.2. 

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. 

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. 

8 

 
 
  
 
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  ingredients15  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 

9 

 
 
  
 
                                                 
1. 

2. 

3. 

4. 

Annex A 

Analysis of the WashRight campaign 

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. 

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 %. 

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. 

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. 

10 

 
 
  
 
%

,

n
o

i
t

p
m
u
s
n
o
c

i

g
n
g
a
k
c
a
p

n

i

e
g
n
a
h
C

30

25

20

15

10

5

0

-5

-10

-15

-20

y = 0,9918x + 1,1305
R2 = 0,4809

FI

PT

DE

ES

SE

IE

AT

IT

NL

DK

FR

UK

BE/L

GR

-20

-15

-10

-5

0

5

10

15

Change in detergent consumption, %

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). 

1996-2001 

Change in per 
capita PBO 
consumption 

Change in per 
capita detergent 
consumption 

Change in per 
capita energy 
consumption 

Change in per 
capita packaging 
consumption 

Austria 
Belgium 
Denmark 
Finland 
France 
Germany 
Greece 
Ireland 
Italy 
Luxembourg 
Portugal 
Spain 
Sweden 
The Netherlands 
UK 
EU-15 

– 38,5 %
– 26,1 %
– 25,7 %
– 1,7 %
– 14,9 %
– 25,6 %
10,2 %
10,2 %
– 39,0 %
– 26,1 %
– 19,4 %
– 23,9 %
– 25,6 %
– 34,4 %
– 4,6 %
– 23,7 %

– 8,4 %
0,7 %
– 18,8 %
13,7 %
– 15,6 %
– 0,7 %
0,6 %
– 5,7 %
– 0,8 %
0,7 %
– 1,8 %
– 11,4 %
– 11,5 %
– 2,5 %
– 17,1 %
– 7,9 %

– 7,4 % 
– 10,7 % 
– 4,0 % 
– 10,1 % 
– 6,0 % 
0,0 % 
– 13,5 % 
0,0 % 
– 3,7 % 
– 10,7 % 
– 9,2 % 
0,0 % 
– 6,9 % 
– 10,2 % 
0,0 % 
– 6,4 % 

– 10,5 %
0,6 %
– 14,1 %
27,1 %
– 16,2 %
7,9 %
– 18,3 %
– 8,1 %
– 8,1 %
0,6 %
9,0 %
3,9 %
– 7,5 %
– 10,5 %
– 16,8 %
– 6,7 %

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

11 

 
 
  
 
 
 
 
 
 
5. 

6. 

7. 

8. 

16 

By  considering  figure  2  as  a  deviation  from  a  scenario  in  which  no  consumer 
switches  to  a  different  detergent16,  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. 

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. 

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. 

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, 

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. 

12 

 
 
  
 
                                                 
9. 

10. 

11. 

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 
in  detergent 
consumption per wash, or of 7,9 % per capita, to compliance by the consumer with 
the dosage information. 

the  entire  17 %  reduction 

their  dosage 

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 
the  new  reduced  dosage 
consumers  reducing 
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. 

line  with 

in 

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 basis17. 

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. 

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. 

13 

 
 
  
 
                                                 
1. 

2. 

3. 

4. 

Annex B 

Analysis of the four quantitative targets 

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. 

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. 

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. 

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. 

2. 

3. 

4. 

PBO consumption, 

detergent consumption, 

energy consumption, 

packaging consumption, 

14 

 
 
  
 
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. 

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 
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. 

in 

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. 

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.  

6. 

7. 

8. 

 Parameter  Ranking  Weighting  Target  Achieved  Difference 

PBO 

Detergent 

Energy 

Packaging 

Sum 

1 

2 

3 

4 

1 – 10 % – 23,7 %

– 13,7 % 

1 – 10 %

– 7,9 %

2,1 % 

1

– 5 %

– 6,4 %

– 1,4 % 

1 – 10 %

– 6,7 %

3,3 % 

– 35 % – 44,7 %

– 9,7 % 

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 

15 

 
 
  
 
 
sum  of  the  undershoots  on  all  other  targets,  even  under  the  most  stringent 
assumptions. 

16