Report from the Commission to the European Parliament and the Council pursuant to Article 16 of Regulation (EC) No 648/2004 of the European Parliament and of the Councilof 31 March 2004 on detergents, concerning anaerobic biodegradation (Text with EEA relevance)
Date: 2009-05-26
Institutions: European Commission
Subjects: activity report, biodegradability, market approval, marketing, physical environment, polishing and scouring preparations

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 26.5.2009 
COM(2009) 230 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

Pursuant to Article 16 of Regulation (EC) No 648/2004 of the European Parliament and 
of the Council of 31 March 2004 on detergents, concerning anaerobic biodegradation 

(Text with EEA relevance)  

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REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

Pursuant to Article 16 of Regulation (EC) No 648/2004 of the European Parliament and 
of the Council of 31 March 2004 on detergents, concerning anaerobic biodegradation 

(Text with EEA relevance)  

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INTRODUCTION 

1. 
Article 16(2) of Regulation (EC) No 648/2004 on detergents1 lays down that:  

“by  8  April  2009,  the  Commission  shall  carry  out  a  review  of  the  application  of  this 
Regulation,  paying  particular  regard  to  the  biodegradability  of  surfactants,  and  shall 
evaluate, submit a report on, and, where justified, present legislative proposals relating to  

anaerobic biodegradation; 

the biodegradation of main non-surfactant organic detergent ingredients”. 

This  report  concerns  the  anaerobic  biodegradation  of  detergent  surfactants  with  a  focus  on 
linear alkylbenzene sulphonate (LAS) which is a widely-used surfactant (see table 1) that is 
reported  to  be  poorly  biodegradable  under  anaerobic  conditions.  The  report  covers  the 
properties of LAS obtained from the scientific literature, risk assessment reports on the risks 
associated with the use of LAS in detergents, and a review of anaerobic testing methodology. 

Anaerobic conditions occur both in nature, for example in surface water sediments, and in the 
sludge of waste water treatment plants. Anaerobic biodegradation of surfactants in sludge and 
sediment produces methane in contrast to the carbon dioxide that results from biodegradation 
under aerobic conditions found in waste and surface water. 

As  most  waste-water  streams  and  surface  waters  are  aerobic,  surfactants  that  are  fully 
biodegradable  under  aerobic  conditions  should  be  rapidly  degraded,  and  in  principle  should 
not  enter  the  compartment  where  anaerobic  conditions  prevail.  That  is  why  the  Detergents 
Regulation  sets  ultimate  biodegradability  as  the  main  criterion  for  use  of  surfactants  in 
detergents. Surfactants that do not meet the criterion of ultimate biodegradability can only be 
used in exceptional circumstances and only when it can be demonstrated by means of a risk 
assessment that such uses do not pose a risk. One such derogation will be granted in the near 
future2.  

Although no reports have been received from Member States of any environmental concerns 
due to surfactants since the introduction of the Detergents Regulation, it has been noted that 
some  surfactants  do  accumulate  in  sewage  sludge  where  they  remain  until  the  sludge  is 
disposed of, for example as a fertiliser in agriculture, where re-exposure to aerobic conditions 
allows aerobic biodegradation to proceed to completion. 

The environmental fate and behaviour and the toxicity of surfactants should all be considered 
for  evaluating  the  effectiveness  of  the  existing legislation  in  managing  the  overall  risk.  The 
Commission approached this task in two stages: first to establish the existing knowledge base 
and identify gaps, second, to fill those gaps. The first stage was completed in 2005, the second 
has taken from 2006 to 2009. 

2. 

ESTABLISHING THE KNOWLEDGE BASE 

2.1. 

The Fraunhofer study 

In 2000, the Commission (DG Enterprise and Industry) contracted a study to the Fraunhofer 
Institute  (UMSICHT)  to  assess  the  environmental  impact  in  the  EU  resulting  from  the 

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OJ L104, 8.4.2004, p.1 
The  derogation  refers  to  surfactant  Dehypon  G  2084  for  use  in  three  industrial  applications  (bottle 
washing, cleaning in place, and metal surface cleaning)  

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incomplete  biodegradation  of  detergent  surfactants  under  anaerobic  conditions.  The  report 
was  completed  in  20033  and  covered  among  other  things  a  survey  of  statistical  data  on 
detergent production and consumption in Europe as well as a set of recommendations for test 
methods and cost/effective measures on the anaerobic biodegradability of surfactants.  

Table 1 provides an overview of the main surfactants used in detergents. 

Table 1: Consumption and production (tonnes) of main detergents surfactants in 
Western Europe for 2007 (CESIO statistics, January 2009) 

Surfactant 

Production in WE 

Sales in WE 

LAS 

Alcohol sulphates 

Alcohol ethersulphates 

Alkane sulphonates 

Alkylphenol ethoxylates 

502.200 

79.629 

449.685 

76.726 

31.602 

Fatty alcohol ethoxylates 

1.000.617 

Other ethoxylates 

Esterquats 

Betaines 

38.171 

224.315 

76.134 

403.463 

66.201 

397.448 

66.176 

24.892 

615.695 

24.921 

159.352 

67.557 

The main conclusions of Fraunhofer Report were: 

Surfactants must be ultimately and readily biodegradable under aerobic conditions in order to 
prevent adverse environmental impact. 

The  poor  biodegradability  of  some  surfactants  (e.g.  LAS)  under  anaerobic  conditions  may 
sometimes  result  in  a  significant  surfactant  content  in  sewage  sludge,  especially  after 
treatment  in  waste  water  treatment  plants  (WWTP)  employing  an  anaerobic  sludge 
stabilisation process. When the anaerobically treated sludge is used as fertiliser in agriculture, 
the  surfactant  concentration  in  the  sludge  amended  soil  is  predicted  to  decrease  rapidly 
because of the aerobic biodegradation process occurring in soil. 

With regard to sediments, no accumulation of aerobically ready biodegradable surfactants has 
been  observed,  in  particular  for  LAS  even  over  a  period  of  several  decades.  This  seems  to 
confirm that aerobic (rather than anaerobic) biodegradation plays the main role in elimination 
of organic compounds. 

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Report available at: 
http://ec.europa.eu/enterprise/chemicals/legislation/detergents/studies/anaerobic.htm 

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2.2. 

The  SCHER  opinion:  “Environmental  Risk  Assessment  of  non-Biodegradable 
Detergent Surfactants under Anaerobic Conditions”. 

The Fraunhofer study, together with related reports (e.g OECD on LAS4) were submitted in 
2004  to  the  Commission’s  Scientific  Committee  on  Health  and  Environmental  Risks 
(SCHER) for an opinion on the overall scientific quality of the Fraunhofer report and specific 
aspects of anaerobic biodegradation such as:  

(a)  The  nature  and  magnitude  of  the  risk  to  the  environment  currently  posed  by  those 
detergent  surfactants  that  are  poorly  biodegradable  under  anaerobic  conditions,  but 
that are readily and ultimately biodegradable under aerobic conditions. 

(b)  The  impact  on  the  risk  to  the  environment  from  detergent  surfactants  if  the  existing 
requirement  for  ready  and  ultimate  biodegradability  of  surfactants  under  aerobic 
conditions were to be extended to cover anaerobic conditions as well. 

In its opinion published in November 20055, SCHER found that the overall scientific quality 
of the Fraunhofer report was rather poor due to the small amount and variable quality of the 
data, as well as some flaws in the analysis and in the conclusions drawn from it in the effects 
assessment. Regarding the magnitude of the environmental risk of surfactants other than LAS, 
the Fraunhofer report did not include enough information to allow an evaluation of their risk 
to the environment.  

However,  SCHER  agreed  with  the  main  Fraunhofer  conclusion  that  “the  requirement  for 
ready and ultimate biodegradability of surfactants under anaerobic conditions is not by itself 
regarded as an effective measure for environmental protection”.  

Considering all available reports together, SCHER expressed concerns about: 

(a) a potential for risk from LAS in sludge in certain applications of worst case environmental 

conditions (PEC/PNEC values slightly above 1), 

(b)  the  relatively  high  measured  levels  (0.5-1  g/kg)  of  other  surfactants  in  sewage  sludge, 
including  some  surfactants  which  are  anaerobically  biodegradable,  such  as:  soaps, 
alcohol  ethoxylates  (AE)  and  alkyl  phenol  ethoxylates  (APE).  A  lack  of  sufficient 
information did not allow the risk to be assessed.  

(c)  the  fact  that  a  single  test  is  not  sufficient  to  evaluate  anaerobic  biodegradability.  A 

combination of several tests is more appropriate.  

3. 

FILLING THE KNOWLEDGE GAPS 

3.1. 

HERA reports on LAS and AEs from 2007 

In  reaction  to  the  concerns  expressed  in  the  2005  SCHER  opinion,  the  European  surfactant 
industry association (CESIO) funded additional soil toxicity studies which were performed by 
the Danish National Environmental Research Institute (NERI). The results of this work were 
included  in  an  updated  HERA  (Human  &  Environmental  Risk  Assessment) report  on  LAS6 

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Report available at: http://www.chem.unep.ch/irptc/sids/oecdsids/LAS.pdf 
SCHER opinion available at: 
http://ec.europa.eu/health/ph_risk/committees/04_scher/docs/scher_o_021.pdf 
HERA report available at: http://www.heraproject.com/RiskAssessment.cfm?SUBID=4 

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which was published in 2007 and concluded that: “the risk characterisation as expressed by 
the  PEC/PNEC  ratio  was  below  1  for  all  environmental  compartments,  considering  the 
recently  reported  PNEC  values  (~35  mg/kg  versus  4.6  mg/kg  in  previous  assessments)”. 
Therefore, the HERA report concluded that there are no adverse effects. 
Concerning AE, a HERA report was produced in May 20077, according to which: “AE usage 
in  laundry  cleaners  and  household  cleaning  products  is  not  a  cause  for  concern  for  the 
environment (in particular surface water, sediment, sewage treatment facilities, and soil)”. 

It  should  also  be  noted  that  both  HERA  reports  concluded  that  the  use  of  LAS  and  AE  in 
household laundry and cleaning poses no risk to consumer health.  

In  parallel,  additional  scientific  findings  on  LAS  and  anaerobic  biodegradation  were 
published by several researchers such as: Temnik and Klapwijk (2004)8, Krogh et al., (2007)9, 
Jensen et al., (2007)10, Schowanek (2007)11, and Berna et al. (2007)12. 

3.2. 

New SCHER opinion on anaerobic biodegradation of surfactants 

In March 2008, the Commission (DG Enterprise & Industry) requested SCHER to assess the 
overall scientific quality of the recent HERA reports on LAS and AE and comment on their 
conclusions, in particular those concerning the environmental risks.  

In addition, SCHER was invited, in the light of all available scientific evidence, to reconfirm 
the key statements mentioned in the opinion of 2005 concerning the anaerobic biodegradation 
of surfactants and  environmental protection, as well as to review the issue of anaerobic test 
methodology.  

In  November  2008,  SCHER  published  its  opinion  concerning  anaerobic  degradation  of 
surfactants  and  biodegradation  of  non  surfactant  detergents  organic  ingredients13.  The  key 
points are:  

(a) 
Alcohol ethoxylates: SCHER concluded that the PEC/PNEC ratios are sufficiently low 
(surface water: 0.041, sediment: 0.316, sewage treatment plant: 0.007 and soil: 0.103) that any 
remaining  uncertainties  (for  example,  the  potential  of  anaerobic  biodegradation  of  AE 
homologues was not considered), are not expected to invalidate the main HERA conclusion 
that there are no environmental risks.  

(b) 
LAS:  SCHER  disagreed  with  the  HERA  argument  that  soil  microbial  functions  are 
covered by the proposed PNEC and considered that a proper evaluation of the effects of LAS 
effects  on  microbial  activity  is  essential  for  the  derivation  of  a  robust  PNEC  for  soil. 

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HERA report available at: http://www.heraproject.com/RiskAssessment.cfm?SUBID=34 
Fate  of  linear  alkylbenzene  sulfonate  (LAS)  in  activated  sludge  plants,  H.  Temmink,  B.  Klapwijk, 
Water Research 38 (2004) 903–912. 
Risk assessment of linear alkylbenzene sulphonates, LAS, in agricultural soil revisited: Robust chronic 
toxicity  tests  for  Folsomia  candida  (Collembola),  Aporrectodea  caliginosa  (Oligochaeta)  and 
Enchytraeus crypticus (Enchytraeidae), P.H. Krogh et al., Chemosphere 69 (2007) 872–87.  
European risk assessment of LAS in agricultural soil revisited: Species sensitivity distribution and risk 
estimates, J. Jensen et al., Chemosphere 69 (2007) 880–892.  
Probabilistic  risk  assessment  for  linear  alkylbenzene  sulfonate  (LAS)  in  sewage  sludge  used  on 
agricultural soil, D. Schowanek, Regulatory Toxicology and Pharmacology 49 (2007) 245–259. 
Anaeobic biodegradation of surfactants-scientific review, J.L Berna et al., Tens.Surf.Deterg, (2007), 44, 
313–347. 
SCHER opinion available at: 
http://ec.europa.eu/health/ph_risk/committees/04_scher/docs/scher_o_109.pdf  

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Concerning  the  toxicity  data  for  effects  of  LAS  on  plants,  SCHER  considered  that  the 
information provided was not sufficient for justifying the newly proposed PNEC value of 35 
mg/kg. Thus, whereas SCHER agreed with the proposed PNEC values for aquatic organisms 
and sediments, it underlined that the new proposed PNEC for soil (PNECsoil) was not properly 
substantiated, and unless additional justification can be provided, the previous PNEC for soil 
of 4.6 mg/kg should be retained. SCHER noted that although most studies show that LAS is 
poorly  biodegradable  in  anaerobic  laboratory  tests  and  in  the  anaerobic  digesters  of  sewage 
sludge treatment plant, recent environmental monitoring data (Lara-Martin et al., 2007) seem 
to show significant degradation of LAS under anaerobic conditions in the environment. 

SCHER concludes that the use of AEs and LAS in household laundry and cleaning products 
poses no risk to human health. 

Furthermore, due to lack of new evidence, SCHER did not change the conclusions of its 2005 
opinion that: (a) poor biodegradability under anaerobic conditions is not expected to produce 
substantial modifications in the risk for freshwater ecosystems as the surfactant removal in the 
WWTP seems to be determined by its aerobic biodegradability; (b) the requirement for ready 
and  ultimate  biodegradability  under  anaerobic  conditions  is  not  by  itself  regarded  as  an 
effective measure for environmental protection. 

3.3. 

Review of anaerobic testing methodology  

In  its  2008  opinion,  SCHER  also  reviewed  the  screening  and  simulation  test  methods 
currently  available  to  determine  ultimate  anaerobic  biodegradability  of  organic  substances. 
The potential biodegradability of organic compounds under anoxic conditions can be assessed 
in  a  standardised  screening  test  for  anaerobic  biodegradability  (OECD  311).  However,  to 
assess  the  biodegradation  rate  in  anoxic  environmental  compartments,  specific  simulation 
tests should be applied, such as: TG 307 (transformation in soil) and TG 308 (transformation 
in  aquatic  sediment  systems).  In  recent  years,  the  OECD  has  revised  and  adopted  different 
anaerobic  test  methods  to  fill  the  gap  on  anaerobic  biodegradability  testing.  The  need  for 
screening methods for assessing the anaerobic biodegradability in anaerobic digesters and for 
determining  inhibition  of  biogas  production  by  chemicals,  which  are  insoluble  and/or  are 
adsorbed  onto  sludge  and  sediments,  has  been  covered  by  the  OECD  311  and  OECD  224 
methods adopted in 2006 and 2007, respectively.  

TEGEWA,  a  trade  association  of  the  German  chemical  industry,  has  recently  carried  out  a 
study on the suitability of the OECD 311 method to study the anaerobic biodegradability of 
surfactants  (Schwarz  et  al.,  2008)14.  To  address  the  observed  limitations  of  the  screening 
methodology for assessing anaerobic biodegradability and its poor reproducibility for testing 
surfactants,  a  modified  approach  for  the  assessment  of  anaerobic  biodegradation  was 
proposed  by  Willing  et  al.  in  200815.  Its  main  differences  compared  to  the  standard  OECD 
311  method  are  the  use  of  undiluted  sludge  as  the  test  medium  and  the  presence  of  an 
additional non-surfactant  source of carbon. SCHER notes that the amount of data generated 
using the modified method is rather limited, and believes that further work should be done in 
order to validate this modified test method. 

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Schwarz  et  al.  (2008).  Methodology  of  Anaerobic  Biodegradability  of  Surfactants.  7thWorld 
Surfactants. Congress CESIO, Paris, June 2008. 
Willing A. (2008) A new approach for the assessment of the anaerobic biodegradability of surfactants. 
7th World Surfactant Congress CESIO, Paris, June 2008.  

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Overall,  SCHER  believes  that  the  existing  OECD  methods  for  anaerobic  biodegradation 
together with the simulation test currently under revision provide an appropriate methodology 
for the assessment of the anaerobic biodegradability of organic compounds. However, due to 
stringent (methanogenic) conditions used in the laboratory tests, inhibitory effects cannot be 
excluded and it is therefore accepted that a poor result may not be a final proof of anaerobic 
recalcitrance. 

4. 

STAKEHOLDER CONSULTATION 

The findings of the Fraunhofer and HERA reports as well as their evaluations in the various 
SCHER opinions have been discussed at several meetings of the Detergents Working Group 
responsible  for  the  implementation  of  the  Detergents  Regulation  (February  and  November 
2006,  November  2007,  July  2008,  and  February  2009).  Those  meetings  were  attended  by 
representatives of the competent authorities of Member States and industry associations such 
as AISE (Association de la Savonnerie, de la Détergence et des Produits d’Entretien), CESIO 
(Comité  Européen  des  Agents  de  Surface  et  de  leurs  Intermédiares  Organiques)  and  their 
research partnership ERASM (European Risk Assessment and Management).  

In  February  2006,  the  Detergents  Working  Group  concluded  that  it  would  not  be 
proportionate to take legislative action on the  basis  of the 2005 SCHER opinion, given  that 
the environmental impact of anaerobic biodegradation has not yet been fully clarified. Instead, 
the  issue  should  be  re-examined  in  the  light  of  any  new  information  nearer  to  the  reporting 
date of April 2009. In November 2006, Industry (CESIO/ERASM) communicated to the WG, 
their  ongoing  efforts  to  improve  the  current  knowledge  on  the  risk  assessment  of  LAS  in 
anaerobic sludge and soils through the performance of new soil toxicity studies, the outcome 
of which would be reflected in updated reports by ERASM (2006) and HERA (2007).  

In  the  Working  Group  meeting  of  November  2007,  ERASM/CESIO  presented  recently 
conducted  studies  on  the  anaerobic  biodegradability  of  surfactants.  New  information, 
published  in  international  journals,  was  provided  on  the  soil  ecotoxicity  and  sludge  risk 
assessment for LAS, which significantly affected the risk assessment. ERASM stressed that as 
the PNECsoil for LAS had been revised from 4.6 to 35 mg/kg due to new ecotoxicity data, the 
new  PEC/PNEC  ratio  (decreased  by  a  factor  of  7)  would  indicate  a  significantly  lower 
environmental  risk  for  LAS  in  anaerobic  sludge.  ERASM  underlined  that  as  the  revised 
deterministic and probabilistic risk assessment showed no risk for LAS at all observed sludge 
levels, soil types and typical disposal scenarios, regulatory limit values for LAS in sludge are 
not required. 

ERASM also concluded that: 

– 

– 

According to the new Risk Assessment Reports, environmental protection is ensured 
provided that readily biodegradable surfactants, as required by Regulation (EC) No 
648/2004,  are  treated  under  aerobic  conditions  in  WWTP.  The  detergent  and 
surfactant  industry  agrees  with  the  statement  by  SCHER  that  “the  requirement  for 
ready  ultimate  biodegradability  under  anaerobic  conditions  is  not  by  itself 
considered an effective measure for environmental protection.” 

No  correlation  between  (lack  of)  anaerobic  biodegradability  and  environmental 
problems  has  been  reported.  Rapid  aerobic  biodegradation  is  what  is  important  to 
ensure no risk to the environment.  

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In  January  2009,  CESIO/ERASM  communicated  their  position16  on  the  SCHER  opinion  of 
2008.  ERASM  emphasizes  the  need  to  improve  the  quality  of  existing  screening  tests  for 
anaerobic biodegradation to improve their reproducibility and to reduce the incidence of false 
negative results. ERASM announced that the TEGEWA project (funded by German surfactant 
industry  association)  is  working  in  that  direction,  aiming  to  optimize  the  experimental 
conditions of the ECETOC/OECD 311 screening method and that results will be available in 
about 2 years. 

ERASM disagrees with SCHER conclusions concerning the LAS risk assessment results for 
the soil compartments. ERASM is still of the opinion that the PNEC value of 35 mg/kg in the 
HERA report is the correct one for the impact of LAS on the soil environmental compartment. 
Nevertheless, ERASM recognises that the issue raised by SCHER as to whether LAS in soil 
affects the reduction of iron in soil should be further investigated by studies extending over 
longer periods of time. 

In February 2009, CESIO/ERASM informed the Commission of their initiative to undertake 
further research in order: 

- to develop an improved method for measuring the anaerobic biodegradability under sludge 
digester condition, and 

- to evaluate the LAS degradation in sediments and review any scientific evidence in order to 
precisely estimate the PEC value for LAS.  

Industry will present the outcome of their research at a next meeting of the Detergents WG 
and if required, a further opinion could be requested from SCHER in the future. 

5. 

SUMMARY AND CONCLUSIONS 

The  Commission  has  taken  a  number  of  steps  to  establish  a  knowledge  base  sufficient  to 
review the anaerobic biodegradation of surfactants as required by Article 16 (2) of Regulation 
648/2004. 

The  results  of  a  study  conducted  in  2003  on  anaerobic  biodegradation,  mandated  by  the 
Commission to an external consultant, together with the findings of risk assessment studies of 
major  surfactants  which  were  conducted  by  Industry  in  2007  on  a  voluntary  basis  and  the 
outcome of their evaluation by SCHER, were discussed with delegates from Member States 
and  industry  associations  in  a  number  of  meetings  of  the  Commission  Detergents  Working 
Group.  

Following  a  systematic  evaluation  of  the  risks  from  the  presence  of  non-degradable 
surfactants  in  various  anaerobic  compartments,  it  was  concluded  that,  in  contrast  to  the 
adverse  effects  observed  in  the  absence  of  aerobic  degradation,  the  lack  of  anaerobic 
degradation  does  not  seem  to  be  correlated  with  any  apparent  risk  for  these  environmental 
compartments.  It  can  therefore  be  concluded  that  anaerobic  biodegradability  should  not  be 
used as an additional pass/fail criterion for the environmental acceptability of surfactants such 
as LAS which are readily biodegradable under aerobic conditions.  

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Concerning  the  recently  produced  data  on  the  terrestrial  toxicity  of  LAS  leading  to  an 
increased PNECsoil (which reduces the PEC/PNEC ratio and thereby diminishes the predicted 
environmental risk from LAS in anaerobic sludge and soil) this should be better substantiated 
as requested by SCHER in its opinion of 2008.  

The remaining concerns therefore focus on the possible environmental toxicity of surfactants, 
rather  than  on  their  biodegradability.  At  present,  however,  there  is  no  evidence  that  would 
justify legislative measures at EU level, such as regulatory limit values for LAS in sludge. 

The  information  requirements  of  the  REACH  registration  dossiers  will  ensure  that 
comprehensive  data  on  the  health  and  environmental  effects  of  detergents  ingredients  - 
including surfactants such as LAS - will be submitted by industry to the European Chemical 
Agency  (ECHA).  In  fact,  for  substances  manufactured  or  imported  in  quantities  of  1  000 
tonnes or more per year registrations are due by December 2010 and chemical safety reports 
as part of the registration dossiers will need to demonstrate the safe use throughout their life 
cycle. The REACH registration information should therefore be sufficient to decide whether 
restrictions  on  certain  surfactants  in  detergents  formulations  are  needed  on  environmental 
grounds  in  addition  to  those  already  imposed  by  the  Detergents  Regulation.  If  so,  the 
restriction  procedure  of  REACH  would  be  the  most  appropriate  instrument  to  impose  such 
restrictions.  

6. 

LIST OF ABBREVIATIONS  

AE: 

AISE: 

APE: 

CESIO: 

Alcohol ethoxylates 

Association  Internationale  de  la  Savonnerie,  de  la  détergence  et  des 
produits d’Entretien  

Alkylphenol ethoxylates 

Comité  Européen  des  Agents  de  Surface  et  de  leurs  Intermédiares 
Organiques 

ECETOC: 

European Chemical Industry Ecology and Toxicology Centre 

ERASM: 

HERA: 

LAS: 

NERI: 

OECD: 

PEC: 

PNEC: 

European Risk Assessment and Management 

Human & Environmental Risk Assessment on ingredients of European 
household cleaning products 

Linear alkyl benzene sulphonates 

Danish National Environmental Research Institute 

Organisation for Economic Co-operation and Development  

Predicted Environmental Concentration 

Predicted No Effect Concentration 

REACH: 

Registration Evaluation Authorisation of Chemicals  

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SCHER: 

Scientific Committee on Health and Environmental Risks  

TEGEWA: 

TExtilhilfsmitteln, GErbstoffe und Waschrohstoffe  

UMSICHT: 

Institut für Umwelt-Sicherheit und Energietechnik  

WG: 

WWTP: 

Working Group 

Wastewater Treatment Plant 

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