User manual : EU Ecolabel criteria for absorbent hygiene products : Commission Decision (EU) 2023/1809.
Date: 2024-08-13
Institutions: Joint Research Centre
Subjects: European standard, consumer information, eco-label, environmental impact, environmental standard, hygiene product, research report, sustainable development, user guide

ISSN 1831-9424 

User manual: EU Ecolabel criteria for 
absorbent hygiene products 

Commission Decision (EU) 2023/1809 

Faraca, G., Pérez-Camacho, M.N., Wolf, O. 

2024 

 EUR 32010 

 
  
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EUR 32010 

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ISBN 978-92-68-19567-3   ISSN 1831-9424   doi:10.2760/013211  

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How to cite this report: European Commission, Joint Research Centre, Faraca, G., Pérez-Camacho, M.N. and Wolf, O., User manual: EU Ecolabel 
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Contents 

Abstract ...................................................................................................................................................................................................... 3 

Foreword .................................................................................................................................................................................................... 4 

Acknowledgements .............................................................................................................................................................................. 5 

Executive summary .............................................................................................................................................................................. 6 

1  Introduction ....................................................................................................................................................................................... 7 

2  Before you start .............................................................................................................................................................................. 8 

3  Part A: General Information ..................................................................................................................................................... 9 

4  Part B: Product Assessment and Verification .............................................................................................................. 10 

4.1  Scope ....................................................................................................................................................................................... 10 

4.2  Definitions for Absorbent Hygiene Products ..................................................................................................... 11 

4.3  Assessment and verification of the criteria....................................................................................................... 14 

4.4  Criteria applicable to the Product Group ............................................................................................................. 15 

5  Criterion 1: Fluff pulp ................................................................................................................................................................ 16 

5.1  Criterion 1.1 Sourcing of fluff pulp ........................................................................................................................ 16 

5.2  Criterion 1.2 Bleaching of fluff pulp ...................................................................................................................... 18 

5.3  Criterion 1.3 Emissions from fluff pulp production to water (chemical oxygen demand (COD) 
and phosphorus (P)), and to air (sulphur compounds (S) and NOx) ............................................................... 20 

5.4  Criterion 1.4 Emissions of CO2 from fluff pulp production ....................................................................... 24 

5.5  Criterion 1.5  Energy consumption for fluff pulp production ................................................................... 26 

6  Criterion 2: Man-made cellulose fibres (MMCF) ........................................................................................................ 28 

6.1  Criterion 2.1 Sourcing of man-made cellulose fibres .................................................................................. 28 

6.2  Criterion 2.2  Bleaching of man-made cellulose fibres .............................................................................. 30 

6.3  Criterion 2.3  Production of man-made cellulose fibres ............................................................................ 32 

7  Criterion 3: Cotton and other natural cellulosic seed fibres ............................................................................... 34 

7.1  Criterion 3.1  Sourcing and traceability of cotton and other natural cellulosic seed fibres .. 34 

7.2  Criterion 3.2 Bleaching of cotton and other natural cellulosic seed fibres ..................................... 35 

8  Criterion 4: Production of synthetic polymers and plastic materials ............................................................. 36 

9  Criterion 5: Biobased plastic materials ........................................................................................................................... 38 

10 Criterion 6: Material efficiency in the manufacturing of the final product ................................................ 41 

11 Criterion 7: Excluded and restricted substances ....................................................................................................... 42 

11.1 Criterion 7.1  Restrictions on substances classified under Regulation (EC) No 1272/2008 .. 42 

1 

 
 
11.2 Criterion 7.2  Substances of Very High Concern (SVHCs) .......................................................................... 47 

11.3 Criterion 7.3  Other specific restrictions .............................................................................................................. 48 

11.3.1  Sub-criterion 7.3.1 Specified excluded substances ......................................................................... 48 

11.3.2  Sub-criterion 7.3.2  Fragrances .................................................................................................................. 50 

11.3.3  Sub-criterion 7.3.3  Lotions ........................................................................................................................... 50 

11.3.4  Sub-criterion 7.3.4 Inks and dyes .............................................................................................................. 50 

11.3.5  Sub-criterion 7.3.5 Further restrictions applying to adhesives ................................................. 52 

11.3.6  Sub-criterion 7.3.6 Super absorbent polymers (SAP) ..................................................................... 53 

11.3.7  Sub-criterion 7.3.7 Silicone ........................................................................................................................... 54 

11.3.8  Sub-criterion 7.3.8 Other chemicals of concern ................................................................................ 55 

12 Criterion 8: Packaging ............................................................................................................................................................... 57 

13 Criterion 9: Guidance on the use and on the disposal of the product and of the packaging .......... 60 

14 Criterion 10: Fitness for use and quality of the product ...................................................................................... 61 

15 Criterion 11: Corporate Social Responsibility with regard to labour aspects ............................................ 65 

16 Criterion 12: Information appearing on the EU Ecolabel ...................................................................................... 69 

17 Conclusions ..................................................................................................................................................................................... 70 

References ............................................................................................................................................................................................. 71 

List of abbreviations and definitions ...................................................................................................................................... 72 

List of figures ....................................................................................................................................................................................... 74 

List of tables ......................................................................................................................................................................................... 75 

2 

 
 
Abstract 

Commission Decision 2023/1809, within the scheme of the EU Ecolabel Regulation (Regulation (EC) 
No  66/2010).  This  User  Manual  guides  the  application 

ease the procedures of all the actors involved in the application stage. The manual is composed of 
the present document as well as separate files, which include the application form, data submission 
and declarations. There is only one application form (spreadsheet) to be filled out, regardless of the 
product type (baby diapers, sanitary napkins, tampons, breast pads, adult incontinence products). 

3 

 
 
Foreword  

This manual guides you through the process of applying for the EU Ecolabel, in accordance with the 
criteria requirements. The following symbols are used throughout: 

Symbol description 

Boxes with definitions or additional explanations of technical terms that could complement 
the definitions already included in Commission Decision (EU) 2023/1809. 

Notable or important information. 

Documentation on how to fill in the application form and information about documents to be 
submitted with the application. 

Website links where further information can be found. 

The manual is structured as follows: 

Part  A:  General  Information 
application process as well as frequently asked questions about the applications.  

  provides  information  about  the  EU  Ecolabel,  details  of  the 

Part B: Product Assessment and Verification   outlines the criteria for the specific product group 
set out in the Commission Decision.   

The manual is supplemented by the following elements as separate files: 

Application Form: a spreadsheet to be filled in; 

Declarations: editable pdf files to be filled in. 

the  application  form,  data  submission  and  declarations.  Additionally,  there  are  dedicated  tabs  for 

information submitted in previous tabs of the Application Form. 

The applicant may gather all the declarations from their suppliers and provide them to the assessing 
competent  body  together  with  the  application  form.  Alternatively,  these  declarations  can  also  be 
provided directly by the supplier to the competent body. 

  Please read this manual all the way through before completing and submitting 
the verification form or any other documentation. EU Ecolabel competent bodies 
can help applicants/licence holders understand the EU Ecolabel criteria and can provide 
guidance on how to assemble an application dossier. 

  All referenced legal acts are available at: https://eur-lex.europa.eu/homepage.html  

  This User Manual is for guidance only; it does not have any legal standing and 
does not, in any way, replace the  Commission Decision or any  other  relevant 
legislation. In case of doubt on specific points in the Manual, please refer directly your 
national Competent Body. 

4 

 
 
 
 
 
 
 
 
 
Acknowledgements  

Environment (DG ENV) and the Joint Research Centre (JRC). 

The authors would like to thank the competent bodies of the EU Ecolabel for their fruitful feedback. 

-General for 

Authors 

Faraca Giorgia, JRC B5   Circular economy and sustainable industry 

Pérez-Camacho Maria Natividad, JRC B5   Circular economy and sustainable industry 

Wolf Oliver, JRC B5   Circular economy and sustainable industry 

5 

 
Executive summary 

Commission Decision 2023/1809, within the scheme of the EU Ecolabel Regulation (Regulation (EC) 
No 66/2010). This User Manual (UM) guides the application 

procedures of all the actors involved in the application stage. 

This manual guides you through the process of applying for an EU Ecolabel licence, in accordance 
with the applicable criteria requirements.  

The manual is structured as follows: 

Part  A:  General  Information 
application process, and answers to frequently asked questions about applying.  

  Provides  information  about  the  EU  Ecolabel,  details  of  the 

Part B: Product Assessment and Verification   Outlines the criteria for the specific product group 
set out in the Commission Decision. 

The manual contains the following elements as separate files: 

Application Form, data submission and declarations: one spreadsheet to be filled in and several 
pdf declarations to be also filled in by the EU Ecolabel applicant 

All spreadsheet contains a fi
the  application  form,  data  submission  and  declarations.  Additionally,  there  are  dedicated  tabs  for 
 anonymous 

submitted information. 

The applicant may gather all the declarations from their suppliers and provide them to the assessing 
competent  body  together  with  the  application  form.  Alternatively,  these  declarations  can  also  be 
provided to the competent body directly by the supplier. 

6 

 
 
1 

Introduction  

This User Manual is for guidance only and is designed to support the application phase for the EU 
Ecolabel for absorbent hygiene products. It includes an outline of all data, tests and documentation 
that are required to demonstrate compliance with the criteria.  

The  basis  for  the  manual  is  the  Commission  Decision  establishing  the  EU  Ecolabel  criteria  for 
absorbent hygiene products. A copy of the criteria can be found at: 

  http://ec.europa.eu/environment/ecolabel/products-groups-and-criteria.html  

This document does not aim to duplicate the content of the criteria but is intended to  guide their 
application,  and  is  only  focused  on  helpful  explanations  and  clarifications.  Each  criterion  name 
appears as a heading under Part B with a short summary of what documents are needed for the 
verification  of  the  criterion.  The  exact  criterion  text  does  not  appear  in  this  User  Manual.  Only 
additional information, clarifications and explanations are included. 

  Please  read  the  Commission  Decision  and  this  manual  all  the  way  through  before 

completing and submitting the application form or any other documentation. 

For general questions about the EU Ecolabel and the application process please check the following 
pages: 

   http://ec.europa.eu/environment/ecolabel/faq.html    

   http://ec.europa.eu/environment/ecolabel/how-to-apply-for-eu-ecolabel.html  

7 

 
2  Before you start 

We recommend that before you start you take the following steps: 

  Read the Commission Decision and its Annex I carefully1. 

  Contact your national EU Ecolabel competent body of your choice2. 

  Make  sure  that  the  candidate  product  fulfils  all  applicable  legal  requirements  of  the 

country or countries in which the product is intended to be placed on the market. 

1  
EU Ecolabel for absorbent hygiene products. Commission Decision (EU) 2023/1809. Available at this link 
2   More information of your competent body is available at https://ec.europa.eu/environment/ecolabel/competent-

bodies.html 

8 

 
 
 
 
                                                 
 
3  Part A: General Information 

different steps of the application process in detail. It has been translated into each Member State 
language and can be found at:  

  https://environment.ec.europa.eu/publications/eu-ecolabel-translated-user-manuals-part_en  

9 

 
 
 
4  Part B: Product Assessment and Verification 

4.1  Scope 

Commission Decision (EU) 2023/1809 as follows: 

retain human fluids such as urine, faeces, sweat, menstrual fluid or milk, excluding textile products. 

use.  

EU Ecolabel absorbent hygiene products include the following products: 

(a)  baby diapers or baby nappies;  

(b)  feminine sanitary protection (sanitary pads or towels, panty liners, tampons);  

(c)  nursing pads (also known as breast pads);  

(d)  absorbing sheets 

(e)  adult incontinence products. 

  Adult incontinence products can be eligible for the EU Ecolabel only if such products are 
not registered as medical devices under the Medical Devices Regulation (EU) 2017/7453. 
The applicant is requested to state in the Application Form that the adult incontinence 
product has not been registered as medical device. 

The following products are excluded from the scope of the EU Ecolabel: 

—  Products falling under the scope of Regulation (EU) 2017/745 (the Medical Devices Regulation); 

—  Reusable products made of textiles;  

  Hybrid  products  can  contain a disposable absorbent  section  not made  of  textile.  Such 

disposable section is eligible for the EU Ecolabel. 

—  Wet  wipes,  cotton  swabs  and  make-up  remover  wipes  (as  their  function  is  not  to  absorb  and 

retain human fluids, but rather to clean parts of the human body). 

3  

Regulation (EU) 2017/745 on medical devices (OJ L 117, 5.5.2017, p. 1). 

10 

 
 
 
 
 
 
 
 
                                                 
 
4.2  Definitions for Absorbent Hygiene Products 

The following definitions shall apply throughout this User Manual: 

(1) 
improve or preserve some of its characteristics; 

(2) 
for its production. While conventional plastics are made from fossil resources (oil and natural gas), 
biobased plastics are made from biomass. The biomass currently originates mainly from plants grown 
specifically to be used as feedstock to substitute fossil resources, such as sugarcane, cereal crops, oil 
crops or non-food sources like wood. Other sources are organic waste and by-products, such as used 
cooking  oil,  bagasse  and  tall  oil.  Plastics  can  be  fully  or  partially  made  from  biobased  feedstock. 
Biobased plastics can be both biodegradable and non-biodegradable; 

(3) 
'cellulose pulp' means a fibrous material mainly composed of cellulose and obtained from 
the  treatment  of  lignocellulosic  materials  with  one  or  more  aqueous  solutions  of  pulping  and/or 
bleaching chemicals; 

(4) 
desirable function in the absorbent hygiene product, such as an absorbent core, adhesives, or an outer 
barrier film; 

(5) 
excluding materials used for labels, closures and sealing, which cannot be separated manually and 
therefore form a single integral unit;  

(6) 
to constitute a grouping of a certain number of sales units at the point of sale whether the latter is 
sold as such to the end user or it serves only as a means to replenish the shelves at the point of sale 
or create a stock-keeping or distribution unit, and which can be removed from the product without 
affecting its characteristics; 

  This  means  that  after  removing  the  grouped  packaging,  the  product  aspect  and 

functionality are not altered 

(7) 
production of raw materials, that remain in the raw material/ingredient and/or in the chemical product 
(used in the final product and any component therein) in concentrations less than 100 ppm (0,0100 
% w/w, 100 mg/kg);  

  Examples  of  impurities  are:  residues  or  reagents  including  residues  of  monomers, 
catalysts,  by-products  and  detergents  for  production  equipment  and  carry-over  from 
other or previous production lines 

  If the amount of a substance is more than 100 ppm in the chemical product, it shall be 

regarded as an ingoing substance, and not as an impurity.  

(8) 
ll substances included in the chemical product (used in the final 
product and any component therein), including additives (e.g. preservatives and stabilisers) in the raw 
materials.  Substances  known  to  be  released  from  ingoing  substances  in  stabilized  manufacturing 
conditions (e.g. formaldehyde and arylamine) are also considered as ingoing substances; 

11 

 
 
  Substances that are intentionally added in the raw materials and that are present in the 
chemical products in amounts less than 100 ppm shall be treated as ingoing substances, 
not as impurities 

(9) 
the raw material cellulose which include viscose, modal, lyocell, cupro and triacetate; 

-

(10) 
product, such as fluff pulp, cotton or polypropylene (PP); 

nstituting different components of an absorbent hygiene 

(11) 
protection, handling, delivery or presentation of products and that can be differentiated into packaging 
formats based on their function, material and design, including:  

(a) items that are necessary to contain, support or preserve the product throughout its lifetime 
without  being  an  integral  part  of  the  product  which  is  intended  to  be  used,  consumed  or 
disposed of together with the product;  

(b)  components  of,  and  ancillary  elements  to,  an  item  referred  to  in  point  (a)  that  are 
integrated into the item;  

(c) ancillary elements to an item referred to in point (a) that are hung directly on, or attached 
to, the product and that perform a packaging function without being an integral part of the 
product which is intended to be used, consumed or disposed of together with the product; etc; 

(12) 
3(5)  of  Regulation  (EC)  No  1907/2006  of  the  European  Parliament  and  of  the  Council,  to  which 
additives or other substances may have been added, and which are capable of functioning as main 
structural components of final products and/or packaging, with the exception of natural polymers that 
have not been chemically modified; 

(13) 
or  more  types  of  monomer  units.  Such  molecules  must  be  distributed  over  a  range  of  molecular 
weights wherein differences in the molecular weight are primarily attributable to differences in the 
number  of  monomer  units.  A  polymer  comprises  the  following:  (a)  a  simple  weight  majority  of 
molecules containing at least three monomer units which are covalently bound to at least one other 
monomer unit or other reactant; (b) less than a simple weight majority of molecules of the same 
molecular weight. In the context of th
monomer substance in a polymer, as defined in Regulation (EC) No 1907/2006; 

(14) 

(15) 

(16) 
sourced from post-consumer and/or post-industrial recycled material. 
product or to the packaging in this case;   

(17) 
Parliament and of the Council , any recovery operation by which waste materials are reprocessed into 
products,  materials  or  substances  whether  for  the  original  or  other  purposes.  It  includes  the 
reprocessing  of  organic  material  but  does  not  include  energy  recovery  and  the  reprocessing  into 
materials that are to be used as fuels or for backfilling operations; 

12 

 
 
 
(18) 
constitute a sales unit consisting of products and packaging to the final user or consumer at the point 
of sale; 

 known as additional component, means a packaging component 
(19) 
that is distinct from the main body of the packaging unit, which may be of a different material, that 
needs  to  be  disassembled  completely  and  permanently  from  the  main  packaging  unit  in  order  to 
access the product, and that is typically discarded prior to and separately from the packaging unit. In 
the case of absorbent hygiene products, it is any component with protective or hygienic function that 
is removed before the use of the product, e.g. the individual wrapping or film where some absorbent 
hygiene products are contained within the sales packaging (mainly for tampons and sanitary pads), 
the release liner and paper in baby diapers and sanitary pads, or the applicator for tampons; 

(20) 
disruptors,  means  substances  which  have  been  identified  to  have  endocrine  disrupting  properties 
(human  health  and/or  environment)  according  to  Article  57(f)  of  Regulation  (EC)  No  1907/2006 
(candidate list of substances of very high concern for authorisation), or Regulation (EU) No 528/2012 
of the European Parliament and of the Council  or Regulation (EC) No 1107/2009 of the European 
Parliament and of the Council , or Regulation (EC) No 1272/2008 of the European Parliament and of 
the Council; 

(21) 
large amounts of liquid compared to their own mass; 

(22) 
intentionally obtained either by: 

ecular  substances  other  than  cellulose  pulp 

a polymerisation process such as poly-addition or poly-condensation or by any other 

(a) 
similar process of combination of monomers and other starting substances; 

(b) 

(c) 

chemical modification of natural or synthetic macromolecules; 

microbial fermentation. 

handling  and  transport  of  a  number  of  sales  units  or  grouped  packages,  including  e-commerce 
packaging but excluding road, rail, ship and air containers, in order to prevent physical handling and 
transport damage. 

13 

 
 
 
 
4.3  Assessment and verification of the criteria 

For the EU Ecolabel to be awarded to a specific product, the product shall comply with all requirements 
set in the Commission Decision (unless otherwise specified by the criterion legal text). The applicant 
shall provide a written confirmation stating that all the criteria are fulfilled. 

Specific assessment and verification requirements are indicated within each criterion. 

  Where the applicant is required to provide declarations, documentation, analyses, test 
reports, or other evidence to show compliance with the criteria, these may originate from 
the applicant and/or their supplier(s) as appropriate. 

Competent bodies shall preferentially recognise attestations that are issued by bodies accredited in 
accordance  with  the  relevant  harmonised  standard  for  testing  and  calibration  laboratories,  and 
verifications by bodies that are accredited in accordance with the relevant harmonised standard for 
bodies certifying products, processes, and services.  

Where appropriate, test methods other than those indicated for each criterion may be used if the 
competent body assessing the application accepts their equivalence. 

Where  appropriate,  competent  bodies  may  require  supporting  documentation  and  may  carry  out 
independent verifications. 

Changes in suppliers and production sites pertaining to products to which the EU Ecolabel has been 
awarded  shall  be  notified  to  competent  bodies,  together  with  supporting  information  to  enable 
verification of continued compliance with the criteria. 

As pre-requisite, the product shall meet all respective legal requirements of the country or countries 
in which the product is intended to be placed on the market. The applicant shall declare the product's 
compliance with this requirement. 

The following information shall be provided together with the application for the EU Ecolabel: 

(a)  a description of the product, together with the weight of the individual product units 

and the total weight of the product; 

 

 

one tampon, including the separate component (in case there is separate component). 

package  (e.g.  20  x  individual  product  units),  including  the  separate  component  (if 
relevant). 

(b)  a  description  of  the  sales  packaging  (empty),  together  with  its  total  weight,  if 

applicable;  

(c)  a  description  of  the  grouped  packaging  (empty),  together  with  its  total  weight,  if 

applicable; 

(d)  a description of the separate components, together with their individual weight; 

(e)  the  components,  materials  and  all  substances  used  in  the  product  with  their 

respective weights and, whenever applicable, their respective CAS numbers. 

14 

 
 
 
4.4  Criteria applicable to the Product Group 

The list of EU Ecolabel criteria for AHP is presented below. All criteria have to be fulfilled in order for 
the product to be awarded the EU Ecolabel. 

No. 

Criterion 

1 

1.1 

1.2 

1.3 

1.4 

2 

2.1 

2.2 

2.3 

3 

3.1 

3.2 

4 

5 

6 

7 

7.1 

7.2 

7.3 

8 

9 

10 

11 

12 

Fluff Pulp 

Sourcing of fluff pulp 

Bleaching of fluff pulp 

Emissions from fluff pulp production to water (COD and P) and to air (S and NOx) 

Emissions of CO2 from production of fluff pulp 

Man-made cellulose fibres (including viscose, modal, lyocell, cupro, triacetate) 

Sourcing of man-made cellulose fibres 

Bleaching of man-made cellulose fibres 

Production of man-made cellulose fibres 

Cotton and other natural cellulosic seed fibres 

Sourcing and traceability of cotton and other natural cellulosic seed fibres 

Bleaching of cotton and other natural cellulosic seed fibres 

Production of synthetic polymers and plastic materials 

Biobased plastic materials 

Material efficiency in the manufacturing of the final product 

Excluded and restricted substances 

Restrictions on substances classified under Regulation (EC) No 1272/2008 of the 
European Parliament and of the Council  

Substances of Very High Concern (SVHCs) 

Other specific restrictions 

Packaging 

Guidance on the use and on the disposal of the product and of the packaging 

Fitness for use and quality of the product 

Corporate Social Responsibility with regard to Labour Aspects 

Information appearing on the EU Ecolabel 

15 

 
 
 
 
5  Criterion 1: Fluff pulp 

Criterion 1 focuses on the sourcing and production of fluff pulp and must be fulfilled whenever the 
fluff pulp material (wet weight) represents more than 1% of the weight of the final absorbent hygiene 
product. 

5.1  Criterion 1.1 Sourcing of fluff pulp 

All  the  companies  supplying  fluff  pulp  shall  hold  valid  chain  of  custody  certificates  issued  by  an 
independent third party certification scheme. Accepted schemes are the Forestry Stewardship Council 
(FSC) and the Programme for the Endorsement of Forest Certification (PEFC). Equivalent schemes can 
also be accepted if deemed appropriate by the Competent Body in charge of the verification process.  

A minimum of 70% of the wood raw materials used for the production of fluff pulp shall be covered 
by valid Sustainable Forestry Management (SFM) certificates issued by an independent third party 
certification scheme. Accepted schemes are FSC and PEFC. Equivalent schemes can also be accepted 
if deemed appropriate by the Competent Body in charge of the verification process.  

The remaining proportion (<30%) of the wood raw material used for the production of fluff pulp that 
is not covered by SFM certificates shall be covered by a verification system which ensures that it is 
legally  sourced  and  meets  any  other  requirement  of  the  certification  scheme  with  respect  to 
uncertified material. 

 

The FSC scheme 

The FSC certification can be at the forest management level and the supply chain level. In both cases, there 
are three possible control systems: the transfer system, the percentage system and the credit system. The 
transfer system is not relevant for absorbent hygiene products. Within the percentage system, companies 
have to monitor the inputs and outputs of certified fibres in their production line to be able to declare the % 
of certified fibres in the final product. Within the credit system, a proportion of fibres output in a product 
group is allowed to be sold with a credit claim corresponding to the quantity of claim-contributing inputs and 
the applicable conversion factor(s). 

Both percentage system and credit system are allowed for the EU Ecolabel. 

  More information can be found at: https://us.fsc.org/preview.fsc-coc-faq.a-446.pdf   

  The certification bodies issuing the chain of custody and/or the SFM certificates shall be 

accredited/recognised by that certification scheme.  

16 

 
 
 
 
 
 
 
 
 
Required documentation:  

  Declaration  of  compliance  with  this  sub-criterion  from  the  applicant  (template  available 

separately). 

  Declaration of compliance and valid, independently-certified chain of custody certificate(s) 

from all the supplier(s) of the pulp(s). 

 

wood raw materials used for the production of the fluff pulp. 

-certified 

  The  audited  accounting  documents  shall  be  valid  for  the  whole  duration  of  the  EU 

Ecolabel license. 

  Competent bodies will check the accounting documents again twelve months after the 

awarding of the EU Ecolabel license. 

  Proof  that  the  remaining  proportion  of  wood  raw  materials  is  below  30  %  and  that  it  is 
controlled wood covered by a verification system that ensures that it is legally sourced and 
meets any other requirement of the certification scheme with respect to uncertified material.  

  In case the certification scheme does not specifically require that all virgin material is 
sourced  from  non-GMO  species, additional  evidence shall  be  provided  to demonstrate 
this. 

  If the fluff pulp is used in air-laid material, invoices should be provided supporting the 

number of credits allocated to the air-laid material included in the product. 

17 

 
 
 
5.2  Criterion 1.2 Bleaching of fluff pulp 

The  pulp  used  in  the  absorbent  hygiene  product  shall  not  be  bleached  with  the  use  of  elemental 
chlorine (Cl2) gas.  

The following requirements apply only to elemental chlorine free (ECF) pulp. Totally chlorine free (TCF) 
pulp is automatically considered as complying with this sub-criterion. 

The  average  annual  adsorbable  organically  bound  halogens  (AOX)  emissions  from  fluff  pulp 
production shall not exceed 0.140 kg/ADt (air dried tonne, i.e. a tonne with 90% dry matter).  

AOX 

rs to the sum of all Adsorbable Organically Bound Halogens in the wastewater. It is 
the measure of the total amount of halogens (chlorine, bromine and iodine) bound to dissolved or suspended 
organic matter in a wastewater sample. For pulp, paper and paperboard wastewaters, essentially all of the 
organic substances measured as AOX are chlorinated compounds that result from the bleaching of pulps 
with  chlorine  and chlorinated  compounds such  as chlorine  dioxide  and hypochlorite.  AOX  emissions  occur 
when chlorine compounds are added during bleaching. The vast majority of AOX emission comes from the 
first ClO2 bleaching stage in the ECF bleaching process, while TCF bleaching does not produce AOX emissions.  

AOX  provides  information  about  the  quantity  of  chlorinated  organic  compounds  in  wastewater,  and  thus 
contains a broad mix of compounds that have different chemical properties. Minimizing AOX emissions will 
usually  have  the  effect  of  also  reducing  the  generation  of  chloroform,  2,3,7,8-TCDD,  2,3,7,8-TCDF,  and 
chlorinated phenolic compounds . 

The AOX emissions shall be measured using the ISO 9562:2004 test method and expressed in kg 
AOX/ADt.  

  Other test methods may be accepted if considered equivalent by a third-party. 

Measurements of AOX emissions shall be taken on unfiltered and unsettled samples at the effluent 
discharge point of the mills' wastewater treatment plants. In cases where the mill effluent is sent to 
a municipal or other third-party wastewater treatment plant, unfiltered and unsettled samples from 
the mill effluent sewer discharge point shall be analysed and the results multiplied by a standard 
removal efficiency factor for the municipal or third-party wastewater treatment plant. The removal 
efficiency factor shall be based on information provided by the operator of the municipal or other 
third-party wastewater treatment plant. 

AOX shall only be measured in processes where chlorine compounds are used for bleaching the pulp 
(ECF  bleaching).  AOX does  not  need  to  be  measured  in the effluent  from pulp  production  without 
bleaching or where bleaching is performed with chlorine-free substances. 

  In case different pulp grades are used, the AOX emissions should be measured for each 

pulp. 

The annual AOX average shall be calculated from at least 12 measurements taken at least every 
month. Measurements shall be taken on a monthly basis from representative composite samples (24 
hours composite). 

18 

 
 
 
  In case of a new or rebuilt production plant, measurements shall be based on at least 45 

subsequent days of stable running of the plant. 

Required documentation: 

For ECF-bleached pulp: 

  Declaration  of  compliance  with  this  sub-criterion  from  the  supplier(s)  (template  available 

separately). 

  A test report including the results of the measurement and any detailed calculation needed 

for showing compliance with this sub-criterion. 

  Relevant  supporting  documentation  related  to  the  measurement  of  the  AOX,  indicating  at 

least the measurement frequency. 

  Declaration that elemental chlorine (Cl2) gas was not used. 

For TCF-bleached pulp: 

  Declaration that ECF bleaching was not used for bleaching the fluff pulp. 

19 

 
 
 
 
 
 
 
 
 
 
5.3  Criterion 1.3 Emissions from fluff pulp production to water (chemical 

oxygen demand (COD) and phosphorus (P)), and to air (sulphur 
compounds (S) and NOx) 

This sub-criterion restricts the emissions from fluff pulp to water and to air via a point system for 
each  parameter:  PCOD  for  chemical  oxygen  demand  (COD),  PP  for  phosphorus  (P),  PS  for  sulphur 
compounds (S) and PNOx for nitrogen oxides (NOx). 

Points  are  calculated  dividing  the measurement value  of  the  parameter by  its  reference  value  as 
reported in Table 1 of Annex I to the Commission Decision (also reported below for simplicity) 

acc
shall then be divided by the total reference value as shown in the following formula for the example 
of PCOD: 

𝑃𝐶𝑂𝐷 =

𝐶𝑂𝐷𝑡𝑜𝑡𝑎𝑙
𝐶𝑂𝐷𝑟𝑒𝑓,𝑡𝑜𝑡𝑎𝑙

=

𝑛
𝑖=1

∑ [𝑝𝑢𝑙𝑝𝑖 × 𝐶𝑂𝐷𝑝𝑢𝑙𝑝,𝑖
𝑛
∑ [𝑝𝑢𝑙𝑝𝑖 × 𝐶𝑂𝐷𝑟𝑒𝑓,𝑝𝑢𝑙𝑝,𝑖]
𝑖=1

]

  None of the individual points PCOD, PP, PS, PNOx, shall exceed 1.5.  

  The sum of points (Ptotal = PCOD + PP + PS + PNOx) shall not exceed 4.0.  

Table 1: Reference values for emissions from different pulp types 

Pulp grade 

Integrated mills 

Reference values (kg/ADt) 

CODref  Pref 

Sref  NOxref 

Bleached chemical pulp (other than sulphite) 

16.0 

0.030 (1) 
0.05 (2) 

0.6 

1.5 

Bleached chemical pulp (sulphite) 

24.0 

0.03 

0.6 

1.5 

Unbleached chemical pulp 

6.5 

0.02 

0.6 

1.5 

Unbleached chemical pulp (UKP-E quality only)  6.5 

0.035 

CTMP (

) 

15.0 

0.01 

-chemical 

11 

0.02 

0.6 

0.2 

0.4 

1.5 

0.3 

1.5 

Non-integrated mills (3) 

Converting process 

1 

0.001 

0.15  0.6 

(1) Net emissions of P are considered in the calculation. The P naturally contained in wood raw materials and in water can 

be subtracted from the total emissions of P. Reductions up to 0.010 kg/ADt shall be accepted. 

(2) The higher value refers to mills using eucalyptus and loblolly southern U.S. pine species from regions with higher levels 
of phosphorus and applies only until 31 December 2026. From 1 January 2027, the limit of 0.03 kg P/ADt applies also 
to mills using eucalyptus and southern US pine species from regions with higher levels of phosphorus. 

(3) For non-integrated mills, the raw material pulp(s) must comply with the values listed for integrated mills, to which the 

emissions resulting from the conversion process should be added. 

20 

 
 
 
 
 
Loblolly southern U.S. pine species 

Loblolly southern U.S. pine species typically used are: slash pine (Pinus elliottii Engelm.), longleaf pine (Pinus 
palustris Mill.), shortleaf pine (Pinus echinate Mill.), pond pine (Pinus serotine), Virginia pine (Pinus virginiana), 
sand pine (Pinus clausa), spruce pine (Pinus glabra), and white pine (Pinus strobes) 

Non-integrated processes 

In a non-integrated process, the mill buys market pulps as raw materials from one or more supplier(s). The 
market pulp(s) are then dissolved, mixed (in case more pulps are used), and dried to obtain the fluff pulp 

The  configuration  of  this  process  implies  that  emissions  occur  twice:  one  time  when  the  market  pulp  is 
produced (i.e. from the wood raw material to the market pulp), and a second time when the fluff pulp is 
produced (i.e. the conversion process, from the market pulp to the fluff pulp).  

The reference values for the emissions of COD, P, S compounds and NOx in Table 1 apply to the conversion 
process only (from market pulp to fluff pulp). Market pulps have to comply with the reference values in place 
for integrated mills. 

Measurement results shall be representative of the respective campaign and a sufficient number of 
measurements shall have been taken place for each emission parameter.  

Data shall be reported as annual averages except in cases where:  

—  the production campaign is for a limited time period only;  

—  the production plant is new or has been rebuilt, in which case the measurements shall be based 

on at least 45 subsequent days of stable running of the plant. 

Measurements of emissions to water (COD and P) shall be taken on unfiltered and unsettled samples 
at  the  effluent  discharge  point  of  the  mills'  wastewater  treatment  plant.  In  cases  where  the  mill 
effluent  is  sent  to  a  municipal  or  other  third-party  wastewater  treatment  plant,  unfiltered  and 
unsettled samples  from the mill effluent sewer discharge point shall be analysed and the results 
multiplied  by  a  standard  removal  efficiency  factor  for  the  municipal  or  third-party  wastewater 
treatment plant. The removal efficiency factor shall be based on information provided by the operator 
of the municipal or other third- party wastewater treatment plant.  

  The minimum measurement frequency for COD measurements and for total P emissions 

shall be weekly. 

Emissions  to  air  (S  and  NOx)  shall  include  all  emissions  that  occur  during the  production  of  pulp, 
including  steam  generated  outside  the  production  site,  minus  any  emissions  allocated  to  the 
production of electricity. In cases where co-generation of heat and electricity occur at the same plant, 
the  emissions  of  S  compounds  and  NOx  resulting  from  on-site  electricity  generation  shall  be 
subtracted from the total amount. The following equation shall be used to calculate the proportion of 
the emissions resulting from electricity generation: 

21 

 
 
 
 
 
 
2 × (MWh(electricity))/[2 × MWh(electricity) + MWh(heat)] 

Where: 

—  MWh(electricity) is the electricity produced at the co-generation plant;  

—  MWh(heat) is the net heat delivered from the co-generation plant to the pulp production; 

  Emissions of S and NOx shall be measured at least twice per calendar year (separated 

by four to six months). 

Measured emission values for S compounds shall include both oxidised and reduced S emissions (SO2 
and TRS   measured as S). The S emissions related to the heat energy generation from oil, coal and 
other external fuels with known S content may be calculated instead of being measured, and shall be 
taken into account. 

Measurements of S compounds and NOx shall include recovery boilers, lime kilns, steam boilers and 
destructor furnaces for strong smelling gases. Diffuse emissions shall also be taken into account. 

  The following diffuse sources should at least be considered:  

For  concentrated  non-condensable  gases  (CNCG):  Batch  cook  blowing,  batch  cook 
gassing,  continuous  cooking,  stripper,  evaporation  plant,  methanol  processing,  black 
liquor heat treatment, super concentrator; 

For  dilute  non-condensable  gases  (DNCG):  Vent  gases  from  continuous  cooking,  vent 
gases from superbatch cooking (evacuation air, vents from non-pressurised tanks), pulp 
washing plant vent gases, tall oil cooking plant vent gases, tank vent gases, evaporation 
plant (atmospheric pressure tanks), causticising plant lime kiln area. 

  The  following  streams  should  not  be  considered:  ventilation  air  from  buildings,  moist 
water vapour from pulp or paper machines, moist air from cooling towers, water vapour 
from the surface of effluent treatment ponds, ventilation from drains, and vapour from 
vacuum pumps. 

The following continuous or periodical monitoring standard test methods are accepted:  

  COD: ISO 15705 or ISO 6060; 

  Total P: EN ISO 6878;  

  S (sulphur oxides): EN 14791, EPA no 8 or EPA Method 6c;  

  S (reduced sulphur): EPA no 15A, 16A, 16B or 16c;  

  S content in oil: ISO 8754; 

  S content in coal: ISO 19579; 

  S content in biomass: EN 15289; 

  NOx: EN 14792, ISO 11564, or EPA Method 7e. 

22 

 
 
 
  Test methods whose scope and requirement standards are considered equivalent to the 
ones mentioned above and whose equivalency has been confirmed by an independent 
third-party shall be accepted.  

  Rapid tests can also be used to monitor emissions as long as they are performed regularly 
(e.g. monthly) against the relevant aforementioned standards or suitable equivalents. 

  For COD measurements (expressed in mg/l), continuous monitoring based on analysis of 
total organic carbon (TOC) shall be accepted as long as a correlation between TOC and 
COD results has been established for the industrial site concerned. 

Required documentation: 

  Declaration(s)  of  compliance  with  this  criterion  from  the  supplier(s)  (template  available 

separately). 

  Detailed calculations and test data showing compliance with this sub-criterion. 

  Supporting  documentation, 

including  test  reports.  Test  reports  must 

indicate  the 

measurement frequency and the calculation of the PCOD, PP, PS and PNOx. 

23 

 
 
 
 
 
 
 
 
 
5.4  Criterion 1.4 Emissions of CO2 from fluff pulp production 

CO2 emissions from the production of fluff pulp shall not exceed the values presented in Table 2 of 
Annex I to Commission Decision 2023/1809 (also reported below). 

The emissions shall be expressed as kg CO2 per air-dried tonne of fluff pulp. The CO2 emission value 
shall be calculated for each fluff pulp used in the AHP.  

The calculation of CO2 emissions shall include all sources of energy used during the production of 
fluff pulp, and shall include also the emissions from the production of electricity (whether on-site or 
off-site).  

Table 2: Limit values for different types of pulp 

Pulp grade 

Integrated mills 

CO2 emissions 

Chemical and semi-chemical pulp 

400 kg CO2/ADt 

CTMP ('chemithe

) 

900 kg CO2/ADt 

Non-integrated mills (1) 

Converting process 

95 kg CO2/ADt 

(1) The raw material pulp(s) for non-integrated mills shall comply with the values listed for integrated mills. See also 

relevant box in sub-criterion 1.3 

For  the  calculation  of  CO2  emissions  from  fuels  and  electricity,  the  reference  emission  values 
according to Table 3 of Annex I to Commission Decision 2023/1809 (also reported below) shall be 
used. 

  If needed, CO2 emission factors for energy sources other than those listed in Table 3 can 

be found in Annex VI to Regulation (EU) 2018/2066. 

  For the grid electricity, it is possible to use a specific value for the electricity used instead 
of the one reported in Table 3, but appropriate documentation shall be provided (e.g. copy 
of a contract). 

Table 3: Reference values for CO2 emissions from different energy sources 

Fuel 

Coal 

Crude oil 

Fuel oil 1 

Fuel oil 2-5 

LPG 

Natural Gas 

Grid Electricity 

CO2 emissions  Unit 

g CO2 fossil/MJ 

g CO2 fossil/MJ 

g CO2 fossil/MJ 

g CO2 fossil/MJ 

g CO2 fossil/MJ 

g CO2 fossil/MJ 

g CO2 fossil/kWh 

94.6 

73.3 

74.1 

77.4 

63.1 

56.1 

376 

24 

 
 
 
 
 
Renewable energy 

promotion  of  the  use  of  energy  from 
-fossil  sources, 
namely wind, solar (solar thermal and solar photovoltaic) and geothermal energy, ambient energy, tide, wave 
and other ocean energy, hydropower, biomass, landfill gas, sewage treatment plant 

Energy from renewable sources count as zero CO2 emissions for all the above except for biomass energy.  

For  biomass  energy  to  be  counted  as  zero  CO2  emissions,  the  biomass  needs  to  fulfil  the  relevant 
sustainability and greenhouse gas savings criteria as specified in Article 29 of Directive (EU) 2018/2001. 

The measurement period shall be 12 months of production. The measurement shall be representative 
of the respective campaign. 

For a new or re-built plant or a change of process at the production plant, measurements shall be 
done on a weekly basis for a total of 8 consecutive weeks following steady running of the plant.  

  Results have to be shown also after 12 months of production.  

Required documentation:  

  Declaration of compliance with the sub-criterion (template available separately) 

  Data  and  detailed  calculations  on  the  CO2  emissions  showing  compliance  with  this 
requirement, together with related supporting documentation. An excel tab is available in the 
electronic Application Form. 

  If  renewable  energy  is  used,  documentation  shall  be  provided  that  renewable  energy  is 
actually  used  at  the mill  or  that  it  has  been  externally  purchased (e.g.  copy of  an  energy 
contract).  

  If  a  different  reference  value  for  electricity  used  instead  of  the  one  reported  in  Table  3, 
documentation  shall  be  provided  that  include  technical  specifications  that  indicate  the 
average value for the electricity used (e.g. copy of a contract). 

25 

 
 
 
 
 
 
 
 
5.5  Criterion 1.5  Energy consumption for fluff pulp production  

This sub-criterion restricts the energy consumption during fluff pulp production via a point system for 
electricity and fuel consumption: Pelectricity for electricity and Pfuel for fuel. 

Points are calculated dividing the energy use by its reference value as reported in Table 4 of Annex I 
to Commission Decision 2023/1809 (also reported below for simplicity). 

The energy input during the production of the pulp shall be divided into heat/fuels and electricity. 

If  a  mix  of  pulps  is  used,  the  energy  must  be  calculated  using  values  for  single  pulps  and  their 

together.  This  factor  shall  then be  divided by the total  reference  value  as  shown  in  the  following 
formulas for Pelectricity and Pfuel. 

  The energy used in the transportation of the raw materials should not be accounted for. 

Calculation of electricity consumption points: 

𝑃𝑒𝑙𝑒𝑐𝑡𝑟𝑖𝑐𝑖𝑡𝑦 =

Where: 

𝑛
𝑖=1

∑ [𝑝𝑢𝑙𝑝𝑖 × 𝐸𝑝𝑢𝑙𝑝,𝑖
𝑛
∑ [𝑝𝑢𝑙𝑝𝑖 × 𝐸𝑟𝑒𝑓,𝑝𝑢𝑙𝑝,𝑖]
𝑖=1

]

Epulp,i = internally produced electricity + purchased electricity   sold electricity; 

Eref,pulp,i as in Table 4 of Annex I to the Commission Decision 

Total electricity consumption Epulp includes the net imported electricity coming from the grid and the 
internal generation of electricity, measured as electric power.  

  Electricity used for wastewater treatment shall not be included. 

Calculation of fuel consumption points: 

𝑃𝑓𝑢𝑒𝑙 =

Where: 

𝑛
𝑖=1

∑ [𝑝𝑢𝑙𝑝𝑖 × 𝐹𝑝𝑢𝑙𝑝,𝑖
𝑛
∑ [𝑝𝑢𝑙𝑝𝑖 × 𝐹𝑟𝑒𝑓,𝑝𝑢𝑙𝑝,𝑖]
𝑖=1

]

Fpulp,i = internally produced fuel + purchased fuel   sold fuel   1,25 × internally produced electricity; 

Fref,pulp,i as in Table 4 of Annex I to the Commission Decision. 

Total fuel consumption Fpulp includes all purchased fuels, the heat energy recovered by incinerating 
liquors and waste from on-site processes (e.g. wood waste, sawdust, liquors, etc.), as well as the heat 
recovered from the internal generation of electricity. However, when calculating the total heat energy, 
the applicant only needs to count 80 % of the heat energy from internally generated sources.  

above. 

26 

 
 
 
 
 
Where steam is generated using electricity as the heat source, the heat value of the steam shall be 
calculated, then divided by 0,8 and added to the total fuel consumption. 

  None of the individual points Pelectricity, Pfuel shall exceed 1.5. 

  The sum of points (Ptotal = Pelectricity + Pfuel) shall not exceed 2.5. 

Table 4: Reference values for electricity and fuel from different pulp types 

Pulp grade 

Integrated mills 

Reference values (kWh/ADt) 

Eref,pulp 

Fref,pulp 

Chemical and semi-chemical pulp 

800 

CTMP (

)  1800 

Non-integrated mills (1) 

Converting process 

250 

5400 

900 

1800 

(1) The raw material pulp(s) for non-integrated mills shall comply with the values listed for integrated mills. See also 

relevant box in sub-criterion 1.3 

The period for the calculations or mass balances shall be based on the production over 12 months. 
The calculations shall be repeated on a yearly basis. In case of a new or a rebuilt production plant, 
the calculations shall be based on at least 45 subsequent days of stable running of the plant. The 
calculations shall be representative of the respective campaign. 

  Energy  used  in  the  transportation  of  the  raw  materials  is  not  included  in  the  energy 

consumption calculations. 

Required documentation:  

  Declaration of compliance with the sub-criterion (template available separately). 

  Data and detailed calculations on the electricity and fuel consumption showing compliance 
with  this  requirement,  together  with  related  supporting  documentation.  An  excel  tab  is 
available in the electronic Application Form. 

27 

 
 
 
 
 
 
 
 
 
6  Criterion 2: Man-made cellulose fibres (MMCF)  

Criterion 2 focuses on the sourcing and production of man-made cellulose fibres and must be fulfilled 
whenever the man-made cellulose fibres in the product (wet weight) represents more than 1% of the 
weight of the final absorbent hygiene product. 

Man-made cellulose fibres 

Man-made cellulose fibres are obtained from the production of dissolving  pulp which  uses raw materials 
such as wood, bamboo or cotton. Sub-criterion 2.1 applies to all dissolving pulps except dissolving pulp made 
from cotton linters. Sub-criteria 2.2 and 2.3 apply to all dissolving pulps. 

  The  suppliers  of  man-made  cellulose  fibres  can  provide  the  information  to  show 

compliance with this criterion directly to the Competent Body. 

6.1  Criterion 2.1 Sourcing of man-made cellulose fibres 

All the companies supplying dissolving pulp shall hold valid chain of custody certificates issued by an 
independent third party certification scheme. Accepted schemes are the Forestry Stewardship Council 
(FSC) and the Programme for the Endorsement of Forest Certification (PEFC). Equivalent schemes can 
also be accepted if deemed appropriate by the Competent Body in charge of the verification process.  

A  minimum  of  70%  of  the  raw  materials  used  for  the  production  of  the  dissolving  pulp  shall  be 
covered by valid Sustainable Forestry Management (SFM) certificates issued by an independent third 
party  certification  scheme.  Accepted  schemes  are  FSC  and  PEFC.  Equivalent  schemes  can  also be 
accepted if deemed appropriate by the Competent Body in charge of the verification process.  

The remaining proportion (<30%) of the raw material used for the production of dissolving pulp that 
is not covered by SFM certificates shall be covered by a verification system which ensures that it is 
legally  sourced  and  meets  any  other  requirement  of  the  certification  scheme  with  respect  to 
uncertified material. 

  The certification bodies issuing the chain of custody and/or the SFM certificates shall be 

accredited/recognised by that certification scheme.  

  Dissolving pulp produced from cotton linters shall meet criterion 3.1 for cotton (sourcing 

and traceability).  

Required documentation:  

  Declaration of compliance of MMCF except cotton linters (template available separately). 

  Declaration of compliance of MMCF from cotton linters (template available).  

  Valid,  independently-certified  chain  of  custody  certificate  from  the  supplier(s)  of  the 

dissolving pulp(s). 

  Audited accounting docum

raw materials used for the production of the dissolving pulp(s). 

-certified 

28 

 
 
 
  The  audited  accounting  documents  shall  be  valid  for  the  whole  duration  of  the  EU 

Ecolabel license. 

  Competent bodies will check the accounting documents again twelve months after the 

awarding of the EU Ecolabel license. 

  Proof that the remaining proportion of raw materials is below 30% and that it is controlled 
material covered by a verification system that ensures that it is legally sourced and meets 
any other requirement of the certification scheme with respect to uncertified material. 

  In case the certification scheme does not specifically require that all virgin material is 
sourced  from  non-GMO  species, additional  evidence shall  be  provided  to demonstrate 
this. 

  If the dissolving pulp is used in air-laid material, invoices should be provided supporting the 

number of credits allocated to the air-laid material included in the product. 

29 

 
 
 
 
 
6.2  Criterion 2.2  Bleaching of man-made cellulose fibres 

This sub-criterion applies only to elemental chlorine free (ECF) pulp. Totally chlorine free (TCF) pulp is 
automatically considered as complying with this sub-criterion. 

The dissolving pulp used to manufacture man-made cellulose fibres added in the product shall not 
be bleached with the use of elemental chlorine (Cl2) gas.  

The resulting total amount of AOX and organically bound chlorine (OCl) shall not exceed the following: 

—  0,140 kg/ADt, measured in the wastewater from dissolving pulp manufacturing (AOX); and  

—  150 ppm, measured in the finished man-made cellulose fibres (OCl). 

AOX  

the measure of the total amount of halogens (chlorine, bromine and iodine) bound to dissolved or suspended 
organic matter in a wastewater sample. For pulp, paper and paperboard wastewaters, essentially all of the 
organic substances measured as AOX are chlorinated compounds that result from the bleaching of pulps 
with  chlorine  and chlorinated  compounds such  as chlorine  dioxide  and hypochlorite.  AOX  emissions  occur 
when chlorine compounds are added during bleaching. The vast majority of AOX emission comes from the 
first ClO2 bleaching stage in the ECF bleaching process, while TCF bleaching does not produce AOX emissions.  

AOX  provides  information  about  the  quantity  of  chlorinated  organic  compounds  in  wastewater,  and  thus 
contains a broad mix of compounds that have different chemical properties. Minimizing AOX emissions will 
usually  have  the  effect  of  also  reducing  the  generation  of  chloroform,  2,3,7,8-TCDD,  2,3,7,8-TCDF,  and 
chlorinated phenolic compounds. 

OCl  

or product. OCl can be decreased by improving delignification during pulping, with a proper washing of the 
pulp  before  bleaching,  using  substitutes  for  chlorine  or  avoiding  over  chlorination  (by  efficient  mixing  of 
chlorine  added  to  pulp  or  using  several  smaller  additions  of  chlorine  to  avoid  localized  high  chlorine 
concentrations). 

The AOX emissions shall be measured using the ISO 9562:2004 or the equivalent EPA 1650C and 
expressed in kg AOX/ADt.  

  Frequency of measurement for AOX shall be set in accordance with the criterion 1.2 for 
fluff pulp: measurements of AOX emissions shall be taken on unfiltered and unsettled 
samples at the effluent discharge point of the mills' wastewater treatment plant. In cases 
where the mill effluent is sent to a municipal or other third-party wastewater treatment 
plant, unfiltered and unsettled samples from the mill effluent sewer discharge point shall 
be analysed and the results multiplied by a standard removal efficiency factor for the 
municipal or third-party wastewater treatment plant. The removal efficiency factor shall 
be based on information provided by the operator of the municipal or other third-party 
wastewater treatment plant. 

30 

 
 
 
 
AOX shall only be measured in processes where chlorine compounds are used for bleaching the pulp 
(ECF  bleaching).  AOX does  not  need  to  be  measured  in the effluent  from pulp  production  without 
bleaching or where bleaching is performed with chlorine-free substances. 

  In case different pulp grades are used, the AOX emissions should be measured for each 

pulp. 

The annual AOX average shall be calculated from at least 12 measurements taken at least every 
month. Measurements shall be taken on a monthly basis from representative composite samples (24 
hours composite). 

  In case of a new or rebuilt production plant, measurements shall be based on at least 45 

subsequent days of stable running of the plant. 

  In case the applicant could not provide the actual value of AOX level measured in the 
wastewater from pulp manufacturing, a corresponding declaration of compliance signed 
by the pulp manufacturer, in accordance with the exposed requirement, shall be provided. 

The OCl level shall be measured using the ISO 11480 test method and expressed in ppm.  

  The OCl level shall be measured in the finished MMCF. 

Required documentation: 

For ECF-bleached dissolving pulp: 

  Declaration of compliance with the sub-criterion (template available separately). 

  A  test  report  including  the  results  of  the  measurement  of  AOX  and  OCl  and  any  detailed 

calculation needed for showing compliance with this sub-criterion. 

  Relevant  supporting  documentation  related  to  the  measurement  of  the  AOX,  indicating  at 

least the measurement frequency. 

  Declaration of compliance signed by the pulp manufacturer, in accordance with the exposed 

AOX requirement, shall be provided (only if applicable). 

  Relevant supporting documentation related to the measurement of the OCl. 

  Declaration that elemental chlorine (Cl2) gas was not used. 

For TCF-bleached dissolving pulp: 

  Declaration that ECF bleaching is not used for bleaching the dissolving pulp. 

31 

 
 
 
 
 
 
 
 
 
6.3  Criterion 2.3  Production of man-made cellulose fibres 

This sub-criterion:  

—  establishes circular economy measures for the MMCF production process; and 

—  restricts the emissions from the manufacturing of MMCF of sulphur to air and of zinc, COD and 

SO4

2- to water.  

(a)  More  than  50  %  of  dissolving  pulp  used  to  manufacture  man-made  cellulose  fibres  shall  be 
obtained from dissolving pulp mills that recover value from their spent process liquor either by: 

(i) generating on-site electricity and/or steam, or 

(ii) manufacturing chemical co-products. 

(b)  The  following  limit  values  for  the  emission  of  several  compounds  to  air  and  water  shall  be 
respected in the viscose and in the modal fibres production process (Table 5). 

Table 5: Viscose and modal fibres emission values 

Fibre type 

Sulphur emis-
sions to air 

Limit value 
(g/kg) 

Zinc emissions 

to water 
Limit value 
(g/kg) 

COD measurements 

in water 

 Limit 

value (g/kg) 

SO4

2- emissions 

to water 
Limit value 
(g/kg) 

Staple fibre 

20 

0,05 

Filament fibre 

- Batch wash-
ing 

- Integrated 
washing 

40 

170 

0,10 

0,50 

5 

5 

6 

300 

200 

250 

  Note: Limit values are expressed as annual averages.  

  All values are expressed as g of pollutant/kg of product. 

The following continuous or periodical monitoring standard test methods are accepted: 

  Sulphur: EN 14791, EPA no. 8, 15A, 16A or 16B or DIN 38405-D27; 

  Zinc: EN ISO 11885; 

  COD: ISO 6060, DIN ISO 15705, DIN 38409-01 or DIN 38409-44; 

  SO4

2- (sulphates): ISO 22743. 

  Test methods whose scope and requirement standards are considered equivalent to the 
one of the named national and international standards and whose equivalency has been 
confirmed by an independent third-party shall be accepted. 

  The  detailed  documentation  and  test  reports  shall  include  an  indication  of  the 

measurement frequency for S, Zn, COD and SO4 2-.  

32 

 
 
 
 
 
 
 
 
 
  The  minimum  measurement  frequency,  shall  be  weekly  for  COD,  S,  Zn  and  SO4

2-,  in 

addition to any measurements stipulated in the regulatory requirements. 

Required documentation: 

  Declaration of compliance with this sub-criterion (template available separately). 

  Supporting  documentation  and  evidence  that  the  required  proportion  of  dissolving  pulp 
suppliers  has  the  appropriate  energy  generating  equipment  or  co-product  recovery  and 
manufacturing systems installed at the related production sites. 

  List of dissolving pulp suppliers.  

  Detailed calculations, test reports and supporting documentation showing compliance with 

emission restrictions in this sub-criterion. 

33 

 
 
 
 
 
 
7  Criterion 3: Cotton and other natural cellulosic seed fibres 

Criterion 3 focuses on the sourcing and production of cotton and other natural cellulosic seed fibres 
and must be fulfilled when the cotton or other natural cellulosic fibres (wet weight) represents more 
than 1% of the weight of the final absorbent hygiene product.  

7.1  Criterion 3.1  Sourcing and traceability of cotton and other natural 

cellulosic seed fibres 

All cotton and other natural cellulosic seed fibres shall be grown according to the requirements laid 
down  in  Council  Regulation  (EC)  No  834/20074,  the  US  National  Organic  Programme  (NOP)5  or 
equivalent legal obligations set by trade partners of the European Union.  

The sourcing of the cotton and other natural cellulosic seed fibres shall be certified by an independent 
control body. 

  Organically grown cotton and transitional organic cotton are both considered as organic 

cotton. 

  Global Organic Textile Standard (GOTS)6 certifications are accepted as long as 100% of 

the fibres are organic. 

Cotton and other natural cellulosic seed fibres grown according to the above requirement and used 
to manufacture the absorbent hygiene product shall be traceable from the point of verification of the 
production standard. 

   Tampon strings are exempted from the traceability requirement. 

Required documentation:  

  Declaration  of  compliance  with  the  sub-criterion  from  the  applicant  (template  available 

separately). 

  Declaration  of  compliance  with  the  sub-criterion  from  the  supplier(s)  (template  available 

separately). 

  Certification of the sourcing of cotton/other natural cellulosic seed fibres for each country of 

origin of the material.  

4  

5  
6  

Council Regulation (EC) No 834/2007of 28 June 2007 on organic production and labelling of organic products and 
repealing Regulation (EEC) No 2092/91 (OJ L 189, 20.7.2007, p. 1). 
http://www.ams.usda.gov/AMSv1.0/nop 

https://global-standard.org/images/resource-library/documents/standard-and-manual/GOTS_7.0__SIGNED_.pdf  

34 

 
 
 
 
                                                 
 
  Verification shall be provided on an annual basis, i.e. every 12 months. The applicant shall 
demonstrate that all the cotton used in the previous 12 months is compliant with sub-
criterion 3.1. 

  Information and documentation (e.g. transaction records or invoices) on the total amount of 
cotton/other natural cellulosic seed fibres purchased to manufacture the final product and 
according to each product line, on an annual basis. The total weight of certified bales shall 
also be provided. 

7.2  Criterion 3.2 Bleaching of cotton and other natural cellulosic seed 

fibres 

Cotton and other natural cellulosic seed fibres shall be bleached only using totally chlorine free (TCF) 
technologies.  

This requirement does not apply to cotton liners used to produce dissolving pulp. 

Required documentation:  

  Declaration from the supplier of cotton (template available separately).  

35 

 
 
 
 
 
 
 
 
8  Criterion 4: Production of synthetic polymers and plastic materials 

This criterion applies 
final product and/or of the packaging. 

Criterion 4 focuses on systems for water-saving, waste management and energy management and 
optimisation that polymers and plastic materials production sites shall have in place. 

  Synthetic  polymers  and  plastic  materials  shall  also  comply  with  the  restrictions  on 

ingoing chemical substances reported in criterion 7. 

Manufacturing facilities producing synthetic polymers and plastic materials used in the final product 
shall have systems for the implementation of: 

(a) 

water-savings. The water management system shall be documented or explained 
and shall include information on at least the following aspects: monitoring of water flows; proof of 
circulating water in closed systems; and continuous improvement objectives and targets relating to 
the reduction of wastewater generation and optimisation rates (if relevant, i.e. if water is used in the 
plant); 

(b) 

integrated waste management, in form of a plan to prioritise treatment options 
other than disposal for all the waste generated at the manufacturing facilities and to follow the waste 
hierarchy in relation to prevention, reuse, recycling, recovery and final disposal of waste. The waste 
management plan shall be documented or explained and shall include information on at least the 
following aspects: separation of different waste fractions; handling, collection, separation and use of 
recyclable materials  from the  non-hazardous  waste  stream;  recovery  of materials  for  other  uses; 
handling, collection, separation and disposal of hazardous waste, as defined by the relevant local and 
national regulatory authorities; and continuous improvement objectives and targets relating to waste 
prevention,  reuse,  recycling  and,  recovery  of  waste  fractions  that  cannot  be  prevented  (including 
energy recovery); 

(c) 

optimisation  of  energy  efficiency  and  energy  management.  The  energy 
management system shall address all energy consuming devices, including machinery, lighting, air 
conditioning  and  cooling.  The  energy  management  system  shall  include  measures  for  the 
improvement of energy efficiency and shall include information on at least the following aspects: 
establishing and implementing an energy data collection plan in order to identify key energy figures; 
analysis  of  energy  consumption  that  includes  a  list  of  energy  consuming  systems,  processes  and 
facilities;  identification  of  measures  for  more  efficient  use  of  energy;  continuous  improvement 
objectives and targets relating to the reduction of energy consumption. 

  Applicants  registered  with  EU  Eco-Management  and  Audit  Scheme  (EMAS)  and/or 
ISO  50001,  EN  16247  or  an  equivalent 

certified  according  to 
standard/scheme shall be considered as having fulfilled these requirements if:  

ISO  14001, 

(a) 

the  inclusion  of  water,  waste  and  energy  management  plans  for  the 

(b) 

the  inclusion  of  water,  waste  and  energy  management  plans  for  the 
production site(s) is sufficiently addressed by the ISO 14001, ISO 50001, EN 16247 or 
an equivalent standard/scheme 

36 

 
 
 
 
 
 
 
 
Required documentation: 

  Declaration  of  compliance  with  the  criterion  from the  suppliers  of  synthetic polymers  and 

plastic materials used in the final product and/or the packaging (template available). 

  Report  describing  in  detail  the  procedures  adopted  by  the  suppliers  in  order  to  fulfil  the 
requirements  for  each  of  the  sites  concerned  in  accordance  with  standards,  such  as  ISO 
14001 and/ or ISO 50001 for water, waste and energy plans. 

  If  waste  management  is  outsourced,  the  sub-contractor  shall  provide  a  declaration  of 

compliance with this criterion as well. 

37 

 
 
 
 
 
9  Criterion 5: Biobased plastic materials 

This criterion applies only to the final product, separate components, and/or packaging that contains 
> 1% w/w of biobased plastic material. 

Criterion 5 concerns the use of synthetic polymers based on renewable materials i.e. from available 
biological resources ready to be acquired and which would avoid the dependency on fossil resources.  

  Biobased plastic materials shall also have systems for water-saving, waste management 

and energy management and optimisation as reported in criterion 4. 

  Biobased plastic materials shall also comply with the restrictions on ingoing chemical 

substances reported in criterion 7. 

  This criterion applies on a voluntary basis. 

  This criterion is aligned with the Communication from the European Commission on EU 
Policy Framework on biobased, biodegradable and compostable plastics, available here 

A certain percentage of the total synthetic polymers and plastic materials in relation to 
the total weight of polymers in the final product (including super absorbent polymers (SAP)), 
the separate components and/or in the packaging, may be sourced   on a voluntary basis - from 
biobased raw materials. Circular economy principles shall guide the selection of feedstocks (as an 
example, producers shall prioritise the use of organic waste and by-products as feedstock). In this 
case, two requirements to fulfil: 

(a)  The  superior  environmental  profile  of  the  biobased  raw  materials  used  to  produce 
biobased plastics in the final product, separate components, and/or packaging shall be demonstrated 
in compliance with the latest applicable methodologies to assess the impacts of biobased 
plastics compared to fossil-based plastics. 

 

C

design

Plastics  LCA  method

safe and sustainable by 

             (b) Biobased raw materials used to produce biobased plastics in the final product, separate 
components,  and/or  packaging  shall  be  covered  by  chain  of  custody  certificates  issued  by  an 
independent third-party certification scheme officially recognised by the European Commission. 

  In  line  with  the  sustainability  requirements  related  to  the  sourcing  of  biobased  raw 
material as per the review of the Renewable Energy Directive (RED III). The certification 
schemes officially recognised by the European Commission are available here. 

Once the above requirements are fulfilled, the final product, separate components, and/or packaging 
may be voluntarily labelled as containing biobased plastic by means of a claim. 

38 

 
 
 
 
 
 
 
Voluntary claim to set on the sales packaging 

and/or packaging] is biobased
content in the product [separate components, and/or packaging]). 

x  %  of  plastic  contained  in  the  product  [separate  components, 
asurable share of biobased plastic 

 

wording shall not be used. 

-

-

The claim shall specify if the percentage refers to all the biobased plastic raw materials in the sum of the 
final product, separate components and packaging (jointly) or to the biobased plastic raw materials of the 
item containing biobased plastic (in the final product, separate components and/or packaging). 

To determine the biobased carbon content of the synthetic polymers and plastic materials present in 
the  product,  separate  components,  and/or  packaging,  the  applicant  can  use  standards  based  on 
radiocarbon methods: EN 16640, EN 16785, ASTM D 6866-12 or equivalent. 

  When radiocarbon methods cannot be used, the mass balance method is allowed if a 
high  level  of  transparency  and  accountability  is  ensured  and  supported  by  agreed 
standards. 

  The  proofs  of  purchase  for  the  biobased  plastic  raw  materials  shall  be  based  on 

processes according to the segregation or mass balance systems.  

  The use of purchased certificates based on the Book & Claim system is excluded. 

The applicant shall provide detailed calculations leading to the declared percentage of biobased plastic raw 
materials used in the product, separate components, and/or packaging.  

The percentage shall refer, either, to all the biobased plastic raw materials in the sum of the final product, 
separate components and/or packaging (jointly) or to the biobased plastic raw materials in the final product, 
separate components or packaging (separately).  

Required documentation: 

  Declaration of compliance to demonstrate the superior environmental profile of the biobased 
plastic raw materials used in the product, separate components, and/or packaging (template 
available)  using  an  independently  third-party  certification  that  refers  to  the  methodology 
currently available. 

  Declaration  of  compliance  supported  by  a  valid,  independently  certified  chain  of  custody 
certificate  for  the  suppliers  of  all  biobased  plastics  raw  materials  used  in  the  product, 
separate components and/or packaging (template available).  

  The  audited  accounting  documents  shall  be  valid  for  the  whole  duration  of  the  EU 

Ecolabel license. 

39 

 
 
 
 
 
 
  Competent bodies will check the accounting documents again twelve months after the 

awarding of the EU Ecolabel license. 

  In case the certification scheme does not specifically require that all virgin material is 
sourced  from  non-GMO  species, additional  evidence shall  be  provided  to demonstrate 
this. If waste management is outsourced, the sub-contractor shall provide a declaration 
of compliance with this criterion as well. 

  High-resolution photograph of the sales packaging, where information regarding the biobased 

plastic claim appears clearly (if applicable).  

  Information  and  documentation  on  how  the  biobased  carbon  content  of  the  synthetic 
polymers  and  plastic  materials  present  in  the  product,  separate  components,  and/or 
packaging was determined (template available). 

40 

 
 
 
 
10 Criterion 6: Material efficiency in the manufacturing of the final 

product 

This  criterion  aims  to  limit  the  amount  of  waste that  is  sent to  landfill  or incinerated  in the  final 
product manufacturing assembly site. The waste recovered for reuse, recycling or energy production 
is not targeted through this criterion. 

  Requirements in this criterion shall apply to the final product assembly site. 

The quantity of waste generated during the manufacturing and packaging of the products which is 
sent to landfill or incineration without energy recovery, shall not exceed: 

(a) 8 % by weight of the end products for tampons; 
(b) 4 % by weight of the end products for all the other products. 

Information to be included in the declaration of compliance with this criterion relates to the quantity 
of waste that has not been reused within the manufacturing process or that is not converted into 
materials and/or energy. 

The applicant shall present all of the following: 

—  Weight of the product and of the packaging; 

—  All waste streams generated during the manufacturing; 

—  Respective  treatment  processing  of  the  fraction  of  recovered  waste  and  that  disposed  of  to 

landfill or incineration. 

  The quantity of waste sent to landfill or to incineration without energy recovery shall be 
calculated as the difference between the amount of waste produced and the amount of 
waste recovered (reused, recycled, etc).   

The total quantity of waste generated during manufacturing and packaging of the product must be 
reported indicating how different fractions are handled, treated and, if it is the case, reused or recovered.  

Fractions of waste that are reused or converted into useful materials and/or energy shall be subtracted 
from the total. 

Treatment processes not providing added value in terms of materials and/or energy recovery (e.g. 
incineration without energy recovery) shall not be subtracted from the total. 

Required documentation: 

  Declaration of compliance with the criterion (template available separately). 

41 

 
 
 
 
 
 
 
11 Criterion 7: Excluded and restricted substances 

11.1 Criterion 7.1  Restrictions on substances classified under Regulation 

(EC) No 1272/2008 

This  sub-criterion  applies  to  ingoing  substances  added  to  the  chemical  product  used  in  the  final 
product and in any component of it. 

This sub-criterion covers restricted and excluded substances under Regulation (EC) No 1272/2008. 

This criterion does not apply to: 

 

 

substances  not  included  in  the  scope  of  Regulation  (EC)  No  1907/2006  as  defined  in 
Article 2(2) of that Regulation; 

substances covered by Article 2(7)(b) of Regulation (EC) No 1907/2006, which sets out 
the criteria for exempting substances included in Annex V to that Regulation from the 
registration, downstream user and evaluation requirements. 

Excluded substances 

The final product and any components therein shall not contain ingoing substances (added as such 
or  in  mixtures)  that  are  assigned  any  of  the  hazard  classes,  categories  and  associated  hazard 
statement codes stated in Table 6 in Annex I to Commission Decision 2023/1809 (and also reported 
below). 

  Such ingoing substances shall thus not be intentionally added to the chemical product 

used in the final product. 

  Classified substances according to Table 6 in Annex I to Commission Decision 2023/1809 
can only occur as impurities in the raw material, and always in a concentration lower 
than  0.0100%  w/w  of  the  chemical  product  that  is added  to  the  final  product,  unless 
further restricted under criterion 7.3.8. 

  Substances known to be released or to degrade from ingoing substances are considered 

ingoing substances and not impurities and shall comply with this requirement. 

Table 6: Excluded hazard classes, categories and associated hazard statement codes. vPvB: very persistent 
and very bioaccumulative; vPvM: very persistent and very mobile 

Carcinogenic, mutagenic or toxic for reproduction 

Categories 1A and 1B 

Category 2 

H340 May cause genetic defects 

H341 Suspected of causing genetic de-
fects 

H350 May cause cancer 

H351 Suspected of causing cancer 

H350i May cause cancer by inhalation 

- 

42 

 
 
 
 
H360F May damage fertility 

H361f Suspected of damaging fertility 

H360D May damage the unborn child 

H361d Suspected of damaging the un-
born child 

H360FD May damage fertility. May dam-
age the unborn child 

H361fd Suspected of damaging fertility. 
Suspected of damaging the unborn child 

H360Fd May damage fertility. Suspected 
of damaging the unborn child 

H362 May cause harm to breast-fed 
children 

H360Df May damage the unborn child. 
Suspected of damaging fertility 

Acute toxicity 

Categories 1 and 2 

Category 3 

H300 Fatal if swallowed 

H301 Toxic if swallowed 

H310 Fatal in contact with skin 

H311 Toxic in contact with skin 

H330 Fatal if inhaled 

H331 Toxic if inhaled 

H304 May be fatal if swallowed and en-
ters airways 

EUH070 Toxic by eye contact 

Specific target organ toxicity 

Category 1 

Category 2 

H370 Causes damage to organs 

H371 May cause damage to organs 

H372 Causes damage to organs through 
prolonged or repeated exposure 

H373 May cause damage to organs 
through prolonged or repeated exposure 

Respiratory and skin sensitisation 

Category 1A 

Category 1B 

H317 May cause allergic skin reaction 

H317 May cause allergic skin reaction 

H334 May cause allergy or asthma symp-
toms or breathing difficulties if inhaled 

H334 May cause allergy or asthma 
symptoms or breathing difficulties if in-
haled 

Endocrine disruptors for human health and the environment 

Category 1 

Category 2 

EUH380: May cause endocrine disruption 
in humans 

EUH381: Suspected of causing endocrine 
disruption in humans 

EUH430: May cause endocrine disruption 
in the environment 

EUH431: Suspected of causing endocrine 
disruption in the environment 

Persistent, Bioaccumulative and Toxic (PBT) 

PBT 

vPvB 

EUH440: Accumulates in the environment 
and living organisms including in humans 

EUH441: Strongly accumulates in the en-
vironment and living organisms including 
in humans 

Persistent, Mobile and Toxic (PMT) 

PMT 

vPvM 

EUH450: Can cause long-lasting and dif-
fuse contamination of water resources 

EUH451: Can cause very long-lasting and 
diffuse contamination of water resource 

43 

 
 
The hazard statement codes generally refer to substances. However, if information on substances 
cannot be obtained, the classification rules for mixtures shall apply. 

The most recent classification rules adopted by the Union shall take precedence over the listed hazard 
classifications. Applicants shall therefore ensure that any classifications are based on the most recent 
classification rules.  

For classified impurities, the applicant (or the supplier) shall use the concentration of the restricted 
impurity and an assumed retention factor of 100% in order to estimate the quantity of the impurity 
remaining in the chemical product.  

The use of substances or mixtures that are chemically modified during the production process, so 
that any relevant hazard for which the substance or mixture has been classified under Regulation 
(EC) No 1272/2008 no longer applies, shall be exempted from the above requirement. This includes, 
for example, modified polymers and monomers or additives which become covalently bonded within 
plastics. 

  Justifications for any deviation from a retention factor of 100% (e.g. solvent evaporation) 

or for chemical modification of a restricted impurity shall be provided. 

Restricted substances 

The final product and any components therein shall not contain ingoing substances (added as such 
or in mixtures) in concentrations greater than 0,010% (weight by weight) in the chemical product that 
are assigned any of the hazard classes, categories and associated hazard statement codes stated in 
Table 7 in Annex I to Commission Decision 2023/1809 (and also reported below). 

  The  concentration  of  such  ingoing  substances  shall  be  calculated  with  respect  to  the 

chemical product that is added to the final product. 

  Substances known to be released or to degrade from ingoing substances are considered 

ingoing substances and not impurities and shall comply with this requirement. 

Table 7: Restricted hazard classes, categories and associated hazard statement codes 

Hazardous to the aquatic environment 

Categories 1 and 2 

Category 3 and 4 

H400 Very toxic to aquatic life 

H412 Harmful to aquatic life with long-
lasting effects 

H410 Very toxic to aquatic life with long-
lasting effects 

H413 May cause long-lasting effects to 
aquatic life 

H411 Toxic to aquatic life with long-last-
ing effects 

Hazardous to the ozone layer 

H420 Harms public health and the envi-
ronment by destroying ozone in the upper 
atmosphere 

- 

44 

 
 
 
  
 
The hazard statement codes generally refer to substances. However, if information on substances 
cannot be obtained, the classification rules for mixtures shall apply. 

The most recent classification rules adopted by the Union shall take precedence over the listed hazard 
classifications. Applicants shall therefore ensure that any classifications are based on the most recent 
classification rules.  

For  substances  with  a  restricted  classification,  the  applicant  (or  the  supplier)  shall  use  the 
concentration  of  the  restricted  substance  and  an  assumed  retention  factor  of  100%  in  order  to 
estimate the quantity remaining in the chemical product.  

The use of substances or mixtures that are chemically modified during the production process, so 
that any relevant hazard for which the substance or mixture has been classified under Regulation 
(EC) No 1272/2008 no longer applies, shall be exempted from the above requirement. This includes, 
for example, modified polymers and monomers or additives which become covalently bonded within 
plastics. 

  Justifications for any deviation from a retention factor of 100% (e.g. solvent evaporation) 

or for chemical modification of a restricted substance shall be provided. 

Derogated substances 

Substances with an excluded or restricted hazard class that are derogated from criterion 7.1 are listed 
in Table 8 of Commission Decision 2023/1809 (and also reported below). 

Table 8: Derogated substances and derogation conditions 

Substance type 

Derogated hazard classes 

Derogation conditions 

2-methyl-2H-isothiazol-3-
one (MIT) 

H400, H314, H301, H311, H318, 
H410, H330 and H317 

Dipropylene glycol dibenzo-
ate 

H304 substances and mix-
tures  

H412 

H304 

Titanium dioxide (nano form)  H351 

Only in water-soluble inks and in 
a concentration lower than 15 
ppm in the ink (before applica-
tion) and lower than 0.1 ppm in 
the final product. The ink shall 
also comply with sub-criterion 
7.3.4 

Only in hot melt adhesives that 
are used to indicate wetness 

Substances with a viscosity un-
der 20.5 cSt at 40°C.  

Only when used as pigment. It 
cannot be used in powder or 
spray form. 

Required documentation:  

  Declaration of compliance with this sub-criterion (template available separately). 

  A list of the restricted substances and mixtures used in the chemical products added to the 
final product, as well as their concentration. A template is available as part of the electronic 
Application Form. 

45 

 
 
 
  The information provided shall relate to the forms or physical states of the substances 

or mixtures as used in the final product. 

  Safety Data Sheets or chemical supplier declarations of all substances used in the chemical 

products added to the final product. 

  In case of deviation from a retention factor of 100% for a substance, written justification 

shall be provided. 

  For substances exempted from sub-criterion 7.1 (see Annexes IV and V to Regulation (EC) No 

1907/2006), a declaration by the applicant shall be provided. 

  The  following  technical  information  shall  be  provided  to  support  the  declaration  of 

classification or non-classification for each substance and mixture: 

--   
for substances that have not been registered under Regulation (EC) No 1907/2006 
or  which  do  not  yet  have  a  harmonised  CLP  classification:  information  meeting  the 
requirements listed in Annex VII to that Regulation; 

--   
for substances that have been registered under Regulation (EC) No 1907/2006 and 
which do not meet the requirements for CLP classification: information based on the REACH 
registration dossier confirming the non-classified status of the substance; 

--   
for  substances  that  have  a  harmonised  classification  or  are  self-classified:  safety 
data sheets where available. If these are not available or the substance is self-classified then 

with Annex II to Regulation (EC) No 1907/2006; 

in the case of mixtures: safety data sheets where available. If these are not available 
--   
then calculation of the mixture classification shall be provided according to the rules under 
Regulation  (EC)  No  1272/2008  together  with  information  relevant  to  the  mixtures  hazard 
classification in accordance with Annex II to Regulation (EC) No 1907/2006. 

46 

 
 
 
  
  
 
 
 
11.2 Criterion 7.2  Substances of Very High Concern (SVHCs) 

This  sub-criterion  applies  to  ingoing  substances  added  to  the  chemical  product  used  in  the  final 
product and in any component of it. 

The final product and any components therein shall not contain ingoing substances (added as such 
or in mixtures) that meet the criteria referred to in Article 57 of Regulation (EC) No 1907/2006 of the 
European  Parliament  and  of  the  Council  that  have  been  identified  according  to  the  procedure 
described in Article 59 of that Regulation and included in the candidate list for substances of very 
high concern for authorisation. 

  SVHCs shall  thus not be intentionally added to the chemical  product used in the final 

product. 

  SVHCs can only occur as impurities in the raw material, and always in a concentration 
lower  than  0.0100%  w/w  of  the  chemical  product  that  is  added  to  the  final  product, 
unless further restricted under criterion 7.3.8. 

  Substances known to be released or to degrade from ingoing substances are considered 

ingoing substances and not impurities and shall comply with this requirement. 

As the SVHCs list is dynamic and in continuous update, attention should be paid to check the latest 
list available on the submission date of the EU Ecolabel application. 

  The 

latest 

list 

can 

always 

be 

found 

at: 

http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp   

For SVHCs occurring as impurities, the applicant (or the supplier) shall use the concentration of the 
impurity and an assumed retention factor of 100% in order to estimate the quantity of the impurity 
remaining in the chemical product.  

The use of substances or mixtures that are chemically modified during the production process, so 
that any relevant hazard for which the substance or mixture has been classified under Regulation 
(EC) No 1272/2008 no longer applies, shall be exempted from the above requirement. This includes, 
for example, modified polymers and monomers or additives which become covalently bonded within 
plastics. 

  Justifications for any deviation from a retention factor of 100% (e.g. solvent evaporation) 

shall be provided. 

Required documentation:  

  Declaration of compliance with this sub-criterion (template available separately). 

  A list of all known SVHC impurities in the chemical products added to the final product, as 
well as their concentration. A template is available as part of the electronic Application Form. 

  Safety Data Sheets or chemical supplier declarations of all SVHC impurities occurring in the 

chemical product added to the final product. 

  In case of deviation from a retention factor of 100% for a SVHC impurity, written justification 

shall be provided. 

47 

 
 
 
 
11.3 Criterion 7.3  Other specific restrictions 

11.3.1 Sub-criterion 7.3.1  Specified excluded substances 

This  sub-criterion  applies  to  ingoing  substances  added  to  the  chemical  product  used  in  the  final 
product and in any component of it. 

The following substances shall not be added (alone or in mixtures) to the final product, nor in any 
components therein: 

  The  substances  listed  in  this  sub-criterion  are  thus  only  allowed  as  impurities,  and 
nevertheless in concentrations lower than 0.0100% w/w in the chemical product, unless 
further restricted under criterion 7.3.8.  

  Substances known to be released or to degrade from ingoing substances are considered 

ingoing substances and not impurities. 

  5-chloro-2-methyl-4-isothiazoline-3-one (CMIT); 

  Acrylamide in superabsorbent polymers; 

  Alkyl phenol ethoxylates (APEOs) and other alkyl phenol derivatives; 

  Sterically hindered phenolic antioxidants with molecular weight (MW) >600 g/mole are 

allowed.  

 

chemicals  

-search-for-

  Antibacterial agents (e.g. Nanosilver and triclosan);  

  Antibacterial agent are chemicals/products that inhibit or stop growth of microorganisms 

such as bacteria, fungi or protozoa (single-celled organisms). 

  Formaldehyde and formaldehyde releasers; 

  The use of formaldehyde and formaldehyde releasers in adhesives is regulated according 

to sub-criterion 7.3.5. 

  Nitromusks and Polycyclic musks; 

  Organotin compounds used as a catalysts in the production of silicon; 

  Parabens; 

  Phthalates; 

48 

 
 
 
 
 
 
  DINP used in adhesive formulations is allowed at a maximum concentration of 0.010% 

weight by weight of the adhesive formulation. 

  Substances identified to have endocrine disrupting properties; 

Substances identified to have endocrine disrupting properties means substances which have been identified 
to  have  endocrine  disrupting  properties  (human  health  and  or/environment)  according  to  Article  57(f)  of 
Regulation (EC) No 1907/2006 of the European Parliament and of the Council (candidate list of substances 
of very high concern for authorisation) or according to Regulations (EU) No 528/2012 or (EC) No 1107/2009 
of the European Parliament and of the Council. 

  The National Authorities List I can be consulted, as it includes the substances that have 
undergone an  evaluation of  endocrine  disrupting  properties, as  regulated  in  the  EU  in 
PPPR, BPR or REACH, and which are identified as endocrine disruptors. 

  https://edlists.org/  

  It  is  recommended  to  check  the  National  Authority  Lists  to  have  an  overview  of  all 
identified  endocrine  disrupting  substances  evaluated  in  the  context  of  different  EU 
Regulations (list I).  

  It is advised to avoid as far as possible the substances in the list II (substances under 
evaluation  for  endocrine  disruption  under  an  EU  legislation),  as  these  are  likely  to  be 
banned in future EU Ecolabel criteria revisions and/or EU Regulations. 

 

priority  list  of  substances  that  are  to  be  investigated  further  for  endocrine  disruptive 
effects. 

  The  list  of  such  substances  can  be  found  in  Annex  13,  retrievable  at  this  link: 

https://ec.europa.eu/environment/chemicals/endocrine/strategy/substances_en.htm   

Required documentation:  

  Declaration  of  compliance  with  this  sub-criterion  from  the  supplier(s)  (template  available 

separately). 

49 

 
 
 
 
 
 
 
 
11.3.2 Sub-criterion 7.3.2  Fragrances 

Fragrances  shall  not  be  added  to  the  final  product,  to  any  component  of  it,  to  the  separate 
components nor to the packaging. 

Required documentation:  

  Declaration  of  compliance  with  this  sub-criterion  from  the  supplier(s)  (template  available 

separately). 

11.3.3 Sub-criterion 7.3.3  Lotions 

Lotions shall not be used in the product, nor in any component of it. 

Required documentation:  

  Declaration  of  compliance  with  this  sub-criterion  from  the  supplier(s)  (template  available 

separately). 

11.3.4 Sub-criterion 7.3.4  Inks and dyes 

This sub-criterion applies to the final product and any components therein. This sub-criterion does not 
apply to the separate components, the sales packaging and the information sheets. 

The final product and any components therein shall not be dyed or printed on, except for:  

 

 

tampon strings; 

closing systems; 

  materials that are not directly in contact with the skin, if the dye or ink fulfils specific 

functions or decorative purposes. 

  Examples of this last exemption include dying to reduce visibility of the product through 
white or light coloured clothes, to show landing zones of tapes, to indicate the wetness 
and to indicate the back part of a product. 

The parts that are dyed or printed on should comply with the following requirements: 

50 

 
 
 
 
 
 
 
 
 
—  the content of antimony, arsenic, barium, cadmium, chromium, lead, mercury, selenium, primary 
aromatic amines and polychlorinated biphenyl occurring as impurity in the dying colorants and 

colorants in plastic materials coming into contact with food; 

  The Council of Europe Resolution AP(89)1 on the use of colorants in plastic materials coming 

into contact with food is available at: https://rm.coe.int/16804f8648. 

—  dying colorants used in pla

for Plastics and other Polymers Used in Commodities, or with the Swiss Ordinance 817.023.21 
Annex 2 and Annex 10; 

sed  in 
Commodities  is  available at:  https://www.bfr.bund.de/cm/349/IX-Colorants-for-Plastics-and-
other-Polymers-Used-in-Commodities.pdf   

  The 

Swiss 

Ordinance 

817.023.21 

Annex 

2 

is 

available 

at: 

https://www.blv.admin.ch/dam/blv/fr/dokumente/lebensmittel-und-ernaehrung/rechts-und-
vollzugsgrundlagen/lebensmittelrecht2017/anhang2-verordnung-materialien-kontakt-lm-
gg.pdf.download.pdf/Annexe_2.pdf  

  The 

Swiss 

Ordinance 

817.023.21 

Annex 

10 

is 

available 

at: 

https://www.blv.admin.ch/dam/blv/en/dokumente/lebensmittel-und-ernaehrung/rechts-und-
vollzugsgrundlagen/lebensmittelrecht2017/anhang10-verordnung-materialien-kontakt-lm-
gg.pdf.download.pdf/Annex-10-ordinance-fdha-materials-and-articles-intended-to-come-
into-contact-with-food-stuffs.pdf   

— 

and board for food contact. 

https://www.dssmith.com/contentassets/1bbf9877253f458aa0eed26b76f2d705/360-
english.pdf   

aper  and  board  for  food  contact  is  available  at: 

  The dying colorants and inks used shall also comply with sub-criteria 7.1, 7.2 and 7.3. 

Required documentation:  

  Declaration of compliance with this sub-criterion (template available separately). 

  Chemical supplier declarations, if relevant. 

  If dyes and/or inks are used, the following shall be provided: 

written justification of the specific function provided by dying or printing certain parts 

 -- 
of the product; 

-- 

documentation showing that impurities in the dying colorant or ink comply with the 

esolution AP (89) 1; 

51 

 
 
 
 
 
 
  
 -- 
recommendations IX. Colorants for Plastics and other Polymers Used in Commodities, Swiss 
Ordinance 817.023.21 Annex 2 and Annex 10 (if used in plastic materials); 

 -- 
recommendation XXXVI. Paper and board for food contact (if used in cellulosic materials). 

11.3.5 Sub-criterion 7.3.5  Further restrictions applying to adhesives 

This sub-criterion applies to the adhesives used in the final product and any component of it.  

The content of free formaldehyde in hardened adhesive (glue) shall not exceed 10 ppm. 

The maximum limit for the content of formaldehyde generated during adhesive production shall be 
250 ppm, measured in newly produced polymer dispersion. 

  Hotmelt adhesives are exempted from this requirement. 

The content of formaldehyde in adhesives can be determined using derivatisation and analysis with 
GC-MSD 
liquid 
chromatography) with UV detection.  

(Gas  chromatography-mass  spectrometry)  or  HPLC 

(high  performance 

The recommended test method for the measurement of formaldehyde emissions is the ISO 14184-
1:2011. Equivalent test methods will also be accepted. 

  The adhesives used shall also comply with sub-criteria 7.1, 7.2 and 7.3.1. 

Required documentation:  

  Declaration  of  compliance  with  this  sub-criterion  from  the  supplier(s)  (template  available 

separately). 

  Safety data sheets (SDS) of any substance/mixture in the adhesive and information on their 

concentration in the adhesive. 

  Test results for the content of formaldehyde. 

52 

 
  
  
  
 
 
 
 
 
 
 
 
11.3.6 Sub-criterion 7.3.6  Super absorbent polymers (SAP) 

This sub-criterion applies to the super absorbent polymers (SAP) used in the final product and any 
component of it.  

The maximum content of residual monomers that are classified with the H-codes reported in sub-
criterion 7.1 in SAP is 1 000 ppm.  

  Residual monomers are intended as the total of unreacted acrylic acid and cross linkers  

  For sodium polyacrylate this limit applies to the sum of unreacted acrylic acid and cross 

linking agents. 

The tested quantities for residual monomers and soluble extracts shall be averages from repeated 
measures over a certain period of time. Recommended test methods are ISO 17190 and WSP 210.  

The maximum content of water soluble extracts in SAP is 10% weight by weight. 

ISO 17190 is recommended as a test method. 

  Water-soluble extracts in SAP are intended as monomers and oligomers of acrylic acid 

with a lower molecular weight than the one of SAP, and salts. 

  For  sodium  polyacrilate  these  represent monomers and  oligomers  of  acrylic acid  with 

lower molecular weight than the superabsorbent polymer. 

Acrylamide shall not be included in superabsorbent polymers. 

  The SAP and its ingredients (including water soluble extracts) shall also comply with sub-

criteria 7.1, 7.2 and 7.3.1. 

Required documentation:  

  Declaration  of  compliance  with  this  sub-criterion  from  the  supplier(s)  (template  available 

separately). 

  Safety data sheets (SDS) of any substance/mixture in the chemical product and information 

on their concentration in the final product. 

  SDS  or  test  results  specifying  the  presence  and  concentration  of  the  residual  monomers 

contained in the SAP.  

  The test report shall describe the information on  the methods used, the measurement 

frequency for the analyses, and the laboratories carrying out the analysis. 

53 

 
 
 
 
 
 
 
11.3.7 Sub-criterion 7.3.7  Silicone 

This sub-criterion applies to the release liner used in the final product. 

Solvent-based silicone coatings shall not be used. 

The maximum concentration of octamethyl cyclotetrasiloxane (D4   CAS no.: 556-67-2), decamethyl 
cyclopentasiloxane (D5   CAS no.: 541-02-6) and dodecamethylcyclohexasiloxane (D6   CAS no.: 540-
97-6) in the silicone mixture is 800 ppm (0.08 % w/w).  

  Silicone mixture

raw materials that is used as a coating on the protective paper or the  protective film 
used  for  the  release  liner  on  some  feminine  hygiene  products  (e.g.  panty  liners  and 
sanitary towels) or on nappy tapes. 

  The 800 ppm limit is to be applied to each substance (D4, D5 and D6) separately. 

  The silicone mixture and its ingredients shall also comply with sub-criteria 7.1, 7.2 and 

7.3. 

Silicones 

Silicones (or polysiloxanes) are used in general to protect the adhesive and to achieve a grease- or water-
repellent effect as well as a release effect. When they are used in release liners, silicone coating adheres to 
the material to be treated in the form of a thin layer, especially to low-porosity and smooth paper substrates. 
There  are  release  liners  which  use  different  types  of  substrates (papers,  films,  and  combinations),  many 
different types of silicone coatings, and at a wide range of weights/amounts. 

Required documentation:  

  Declaration of compliance with this sub-criterion signed by the manufacturer of the release 

liner (template available separately). 

  Safety data sheets (SDS) of the substances constituting the silicone mixture. 

54 

 
 
 
 
 
 
  
 
11.3.8 Sub-criterion 7.3.8  Other chemicals of concern 

This sub-criterion applies to the final product. 

The chemicals in the following table shall not be present in the final product in a concentration higher 
than what indicated in Table 9 of Annex I to Commission Decision 2023/1809 (also reported below). 

Table 9: List of restricted chemicals in the final product 

Substances 

Formaldehyde 

Restrictions 

< 16 ppm 

Dibenzo-p-dioxins (PCDDs): 2,3,7,8-TCDD; 
1,2,3,7,8-PeCDD; 1,2,3,4,7,8-HxCDD; 
1,2,3,6,7,8-HxCDD; 1,2,3,7,8,9-HxCDD; 
1,2,3,4,6,7,8-HpCDD; OCDD 

Dibenzofurans (PCDFs): 2,3,7,8-TCDF; 1,2,3,7,8-
PeCDF; 2,3,4,7,8- PeCDF; 1,2,3,4,7,8-HxCDF; 
1,2,3,6,7,8-HxCDF; 1,2,3,7,8,9-HxCDF; 
2,3,4,6,7,8-HxCDF; 1,2,3,4,6,7,8-HpCDF; 
1,2,3,4,7,8,9-HpCDF; OCDF 

DLPCBs: PCB 77; PCB 81; PCB 126; PCB 169; 
PCB 105; PCB 114; PCB 118; PCB 123; PCB 
156; PCB 157; PCB 167; PCB 189 

PAHs 

Benzo[a]anthracene; Benzo[a]pyrene; 
Benzo[e]pyrene; Chrysene; Benzo[b]fluoran-
thene; Benzo[k]fluoranthene; Dibenzo[a,h]an-
thracene; Benzo[j]fluoranthene; 
Benzo[g,h,i]perylene; Indeno[1,2,3,cd]pyrene; 
Phenanthrene; Pyrene; Anthracene; Fluoran-
thene; Naphthalene 

Phenols 

Bisphenol A 

Nonylphenol-di-ethoxylate 

Nonylphenol 

Phthalates 

DINP, DEHP, DNOP, DIDP, BBP, DBP, DiBP, DIHP, 
BMEP, DPP/DIPP, DnPP, DnHP, DMP, DHNUP, 
DCHP, DHxP, DIHxP, DIOP, DPrP, DNP, 1,2-ben-
zenedicarboxylic acid, di-C6-10 alkyl esters, 
1,2-benzenedicarboxylic acid, mixed decyl and 
hexyl and octyl diesters 

Pesticides 

Glyphosate 

AMPA 

Quintozene 

Hexachlorobenzene 

55 

sum TEQ of the detected 
congeners of PCDDs, 
PCDFs and DLPCBs < 
2ng/kg 

Each PAH < 0,2 

 
mg/kg 
Sum PAHs < 1 mg/kg 

< 0,02 % 

< 10 mg/kg 

< 10 mg/kg 

< 0,01% each 

< 0,5 mg/kg 

< 0,5 mg/kg 

< 0,5 mg/kg 

< 0,5 mg/kg 

 
 
 
Organotins 

Tributyltin 

< 2 ppb 

Other organotins: Monobutyltin; Dibutyltin; Tri-
phenyltin; Dioctyltin; Monooctyltin 

Each organotin < 10ppb 

Heavy metals 

Antimony 

Cadmium 

Chromium 

Lead 

Mercury 

< 30 mg/kg 

< 0,1 mg/kg 

< 1 mg/kg 

< 0,2 mg/kg 

< 0,02 mg/kg 

The applicant shall carry out test analyses on a representative product or separately on each of the 
material composing the final (representative) product. 

  In the case of identically produced products (e.g. hygiene products of different sizes), it 

is sufficient to carry out tests on one of the product sizes. 

Recommended test methods are NWSP 360.1R0 for the sample preparation, NWSP 360.2R0 for 
the analyte extraction, and NWSP 360.3R0 for the instrumental analysis.  

     Equivalent test methods can be accepted by the Competent Bodies. 

The frequency of the measurement shall be at least once a year. 

Required documentation:  

  Declaration of compliance with this sub-criterion (template available separately). 

  Test report containing the results of the analyses performed on the final product. 

  The test report should describe the methods used, the date of the measurement for the 

analyses, and the information of the laboratories used for the analysis. 

56 

 
 
 
 
 
 
 
12 Criterion 8: Packaging 

This  criterion  aims  at  introducing  certain  percentages  of  recycled  content  and  recyclability  in  the 
packaging of absorbent hygiene products. 

  This criterion sets requirements for sales and grouped packaging.  

  Grouped packaging shall be avoided or be made of only cardboard and/or paper. 

Figure 1: Sales packaging (primary packaging) 

Figure 2: Separate component (additional component) 

     Bag for pads/ tampons               Release liner in nappies/pads 

(a) Cardboard and/or paper used for packaging  

Sales  packaging  made  of  cardboard  and/or  paper  shall  contain  a  minimum  40%  of  recycled 
material. 

Grouped packaging made of cardboard and/or paper shall contain a minimum 80%  of recycled 
material. 

The remaining share (100% minus recycled content percentage) of cardboard and/or paper used 
for the sales and grouped packaging shall be covered by valid Sustainable Forestry Management 
certificates  issued  by  an  independent  third-party  certification  scheme  such  as  FSC,  PEFC  or 
equivalent.  The  certification  bodies  issuing  Sustainable  Forestry  Management  certificates  shall  be 
accredited/recognised by that certification scheme. 

57 

 
 
    
 
 
 
 
(b) Plastic used for packaging 

Until 31 December 2026, sales packaging made of plastic shall contain a minimum 20% recycled 
material.  

From 1 January 2027, sales packaging made of plastic shall contain a minimum 35% recycled 
material.  

Recycled content shall be verified by complying with the EN 45557 or ISO 14021. 

Plastic recycled content in the packaging shall comply with chain of custody standards such as ISO 
22095 or EN 15343. 

  Equivalent methods may be accepted if considered equivalent by a third-party, and shall 
be accompanied by detailed explanations showing compliance with this requirement and 
related supporting documentation. Invoices demonstrating the purchase of the recycled 
material shall be provided. 

(c) Recyclability  

The content of the sales packaging (either cardboard and/or paper or plastic) and grouped packaging 
(cardboard and/or paper) that is available for recycling shall be a minimum of 95% by weight, 
while the remaining 5% shall be compatible with recycling.  

Recyclability shall be verified by complying with the EN 13430 or ISO 18604.  

In addition, recyclability (availability and compatibility for recycling) of the packaging shall be tested 
by  means  of  standard  testing  protocols.  Cardboard  and/or  paper  packaging  recyclability  shall  be 
assessed through repulpability testing and in this case, the applicant shall demonstrate cardboard 
and/or paper packaging repulpability supported by the result(s) of test report(s) according to the PTS 
method PTS-RH 021, the ATICELCA 501 evaluation system or equivalent standard methods that 
are accepted by the competent body as providing data of equivalent scientific quality. Segregation 
schemes or controlled blending schemes like RecyClass shall be accepted as independent third-party 
certification  for  plastic  packaging.  Equivalent  testing  methods  may  be  accepted  if  considered 
equivalent by a third-party. 

(d) Additional requirements 

Utilisation of composite packaging (sales and grouped), mixed plastics or the coating of the cardboard 
and/or paper with plastics or metals are not allowed. 

Recycled content and recyclability  of sales and grouped packaging shall be indicated on the sales 
packaging. 

58 

 
 
 
 
 
 
 
For cardboard and/or paper used for the sales and grouped packaging:  

—  The audited accounting documents shall be valid for the whole duration of the EU Ecolabel license. 

—  Competent bodies will check the accounting documents again twelve months after the awarding 

of the EU Ecolabel license. 

For sales packaging made of plastic:  

—  Competent bodies shall check the declaration of compliance specifying the percentages of plastic 

recycled content for sales packaging again after 1 January 2027. 

Required documentation: 

  Declaration  of  compliance  for  recycled  content  and  recyclability  (template  available 

separately). 

  Audited accounting documents demonstrating the percentage (100% minus recycled content 
percentage)  of  the  cardboard  and/or  paper  used  for  the  sales  and  grouped  packaging  is 
defined as certified material according to valid FSC, PEFC or equivalent schemes. 

  Related supporting documentation regarding standard methods used for recycled content and 

recyclability compliance. 

  Invoices demonstrating the purchase of the recycled material.  

  High-resolution  photograph  of  the  sales  packaging  (clearly  visible  information  regarding 

recycled content and recyclability of the sales and grouped packaging).  

59 

 
 
 
 
 
 
13 Criterion 9: Guidance on the use and on the disposal of the product 

and of the packaging 

This criterion aims at: 

—  offering guidance on the use of the product; 

—  providing the consumer with information for correct disposal of the waste product and of the 

packaging. 

To that end: 

—  Instructions for the use of the final product shall be made available on the packaging or through 

a printed and/or digital leaflet.  

—  The sales packaging shall contain guidance regarding disposal of the sales packaging, the grouped 
packaging  (if  any),  the  separate  components  and  for  the  disposal  of  the  used  product.  The 
following information shall be written or indicated through visual symbols on the sales packaging: 

 

that the sales packaging, the grouped packaging (if any), the separate components and 
the used product shall not be flushed into toilets, and; 

  how  to  correctly  dispose  of  the  sales  packaging,  the  grouped  packaging  (if  any),  the 

separate components and the used product. 

  Correct  disposal  is  determined  also  by  other  factors  than  those  purely  related  to  the 
product itself (i.e. nature of the material to be disposed [plastic, cardboard, and/or paper]). 
For example, waste collection and management systems may differ within each Member 
State  of  the  EU.  Consequently,  competent  bodies  should  account  for  this  potential 
heterogeneity at the time of interpreting 

Required documentation: 

  Declaration of compliance with the criterion (template available separately). 

  High-resolution photograph of the instructions for use of the product. 

  High-resolution  photograph  of  the  sales  packaging  (clearly  visible  information  regarding 

disposal). 

60 

 
 
 
 
 
 
 
 
 
14 Criterion 10: Fitness for use and quality of the product 

The  aim  of  this  criterion  is  to  address  the  performance  tests  that  AHP  must  undergo  to  fulfil  all 
important characteristics and functions of the product.  

The quality of products awarded with the EU Ecolabel is one of the most important aspects of the 
label, which must be considered in order to prevent creating the image that EU Ecolabel products are 
environmentally-friendly but poor in performance/inefficient.  

The effectiveness /quality of the final product shall be satisfactory and at least equivalent to that of 
products already on the market. 

Fitness  for  use  shall  be tested  with  respect  to  the  characteristics  and  the parameters  reported  in 
Table  10  in  Annex  I  to  Commission  Decision  2023/1809  (and  also  reported  below).  Performance 
thresholds shall be matched, where these have been identified.  

Table 10: Characteristics and parameters describing the fitness for use of the product to be tested. More 
details can be found in the Technical Report7. TEWL: transepidermal water loss 

Characteristic 

In-use 
tests 

U1.  Absorption  and 
leakage  protection 
(*) 

U2. Skin dryness 

Testing practice required (performance threshold) 

Baby diapers 

Feminine 
care pads 

Tampons 

Nursing pads 

uses) 

Consumer panel test (80 % of the 
consumers  testing  the  product 
shall rate the performance as sat-
isfactory) 

Not applicable 

As for baby dia-
pers  and  femi-
nine care pads 

U3. Fit and comfort 

Consumer panel test (80 % of the consumers testing the product shall 
rate the performance as satisfactory) 

U4.  Overall  perfor-
mance 

Consumer panel test (80 % of the consumers testing the product shall 
rate the performance as satisfactory) 

Technical 
tests 

T1.  Absorption  and 
leakage protection 

Absorption  rate  and  absorption 
before leakage 

Syngina 
method 

T2. Skin dryness 

TEWL,  rewet  method  or  cor-
neometric testing 

Not applicable 

As for baby dia-
pers  and  femi-
nine care pads 

As for baby dia-
pers  and  femi-
nine care pads 

(*) Panty liners intended to protect the feminine lingerie (light panty liners) are derogated from these requirements. 

7  

Faraca, G., Perez Camacho, M.N., Lag Brotons, A., Perez Arribas, Z., Kowalska, M.A. and Wolf, O., Revision of EU 
Ecolabel criteria for Absorbent Hygiene Products and Reusable Menstrual Cups (previously Absorbent Hygiene 
Products), Publications Office of the European Union, Luxembourg, 2023, doi:10.2760/209936, JRC134197 

61 

 
 
 
 
                                                 
 
In-use and technical tests guidelines 

  A test report shall be provided for in-use and technical tests. The test report shall describe, 

as a minimum, the test methods, test results and data used;  

  Tests shall be conducted for all the specific type and size of products for which the EU 
Ecolabel application is made. Nevertheless, if it can be demonstrated that products have 
the same performance, only one size or a representative mix of sizes per each product 
design shall be tested;  

  Special care shall be taken regarding sampling, transport and storage of the products to 
guarantee reproducible results. It is recommended not to blind products or repack them 
in  neutral  packaging  due  to  the  risk  of  altering  the  performance  of  products  and/or 
packaging, unless alteration can be excluded; 

 

Information on testing shall be made available to the competent bodies under the respect 
of confidentiality. Test results shall be clearly explained and presented in language, units 
and symbols that are understandable to the data user. The following elements shall be 
specified: place and date of the tests; criteria used to select the products tested and their 
representativeness;  selected  testing  characteristics and,  if  applicable, the  reasons  why 
some were not included; test methods used and their limitations if any. Clear guidelines 
on the use of test results shall be provided. 

Additional guidelines for in-use tests 

  Sampling, test design, panel recruitment and the analysis of test results shall comply with 
standard statistical practices (AFNOR Q 34-0198, ASTM E1958-07e19 or equivalent); 

  Each product shall be assessed on the basis of a questionnaire. The test is to last at least 
72 hours, a full week when possible, and shall be realised in normal conditions of use of 
the product; 

  The recommended number of testers shall be at least 30 (for both products specifically 
designed for one gender, such as feminine care products, as well as for products designed 
for both genders). All the individuals participating in the survey shall be current users of 
the specific type/size of product tested; 

  When the product is not designed specifically for a single gender, the ratio of male to 

female individuals shall be 1:1; 

  A  mixture  of  individuals  proportionally  representing  different  groups  of  consumers 
available on the market shall take part to the survey. Age, countries and genders shall be 
clearly stated; 

8  

9  

https://www.boutique.afnor.org/en-gb/standard/q34019/sanitary-and-domestic-articles-test-method-under-
conditions-of-use-for-chil/fa039217/11448  

https://www.astm.org/e1958-07e01.html  

62 

 
                                                 
 
  Sick individuals and those with a chronic skin condition shall not participate in the test. In 
cases  where  individuals become ill during the  user trial, this is to  be  indicated  on  the 
questionnaire and the answers shall not be taken into consideration for the assessment; 

  For all in-use tests (absorption and leakage protection, skin dryness, fit and comfort and 
overall  performance),  80%  of  the  consumers  testing  the  product  shall  rate  the 
performance  as  satisfactory,  with  a  rate  above  60  assigned  by  the  consumer  (on  a 
quantitative  scale  from  1  to  100).  Alternatively,  80%  of  the  consumers  testing  the 
product shall rate it as good or very good (among five qualitative options: very poor, poor, 
average, good, very good); 

  The results shall be statistically evaluated after the user trial has been completed; 

  External  factors  such  as  branding,  market  shares  and  advertising  that  may  have  an 

impact on the perceived performance of the products shall be communicated. 

Additional requirements for technical tests 

  Test methods shall be based as much as possible on product-relevant, reproducible and 

rigorous methods; 

  A minimum of five samples shall be tested. Average results shall be reported together 

with indication of the standard deviation; 

  Technical tests recommended for nursing pads are the same as for baby diapers and for 

feminine care pads.  

  Weight, dimensions and design features of the product shall be described and provided 
in accordance with information provided in the general assessment and verification text. 

Examples on the testing protocols (for technical test)  

International Consumer Research & Testing (ICRT) performs technical tests such as absorption speed before 
leakage, leakage test and rewet testing conditions for baby diapers. Their methodology provides different 
thresholds  used  as  reference  for  establishing  a  rating  based  on  5  stars.  More 
information: 
https://www.international-testing.org/   

EDANA has developed guidelines for testing feminine hygiene products and baby diapers: 

(1)  Guidelines 
standards/edana-diaper-test-protocol-2-0-final.pdf?sfvrsn=213c4e0_2  (EDANA, 2016) 

testing  baby  diapers:  https://www.edana.org/docs/default-source/international-

for 

(2)  Guidelines 
source/international-standards/femcare-testing-guidelines-final.pdf?sfvrsn=b3f31df6_2  (EDANA, 2018) 

  https://www.edana.org/docs/default-

feminine  hygiene  products: 

testing 

for 

In  the  table  of  Harmonized  Nonwovens  Standard  Procedures  from  EDANA  updated  in  May  2023 
(https://www.edana.org/docs/default-source/international-standards/table-of-content-nw-standard-
procedures-20210105.pdf?sfvrsn=4ede1add_20): 

(1) Listed test methods for permeability (absorption rate/time of penetration) of baby diapers are Nonwoven 
Coverstock Liquid Strike-Through Time Using Simulated Urine NWSP 070.3.R1 (19), Repeated Liquid Strike-
Through  Time  (Simulated  Urine)  NWSP  070.7.R2  (20)  and  Wetback  After  Repeated  Strike-Through  Time 
(Simulated Urine) NWSP 070.8.R1 (19).  

(2) Listed test method for absorption before leakage is Absorption Before Leakage Using an Adult Mannequin 
NWSP 354.0.R2 (22). 

63 

 
Also relevant to follow the developments of the Technical Committee ISO/TC 338 for menstrual products: 
https://www.iso.org/committee/8933440.html   

  Tests  shall  be  carried  out  by  laboratories  certified  to  implement  quality  management 

systems.  

Required documentation: 

  Declaration of compliance with in-use tests (template available separately). 

  Declaration of compliance with technical tests (template available separately). 

  Test report for in-use tests. 

  Test report for technical tests.  

64 

 
 
 
 
 
 
15 Criterion 11: Corporate Social Responsibility with regard to labour 

aspects 

The aim of this criterion is to set guidelines to ensure that the minimum labour standard requirements 
have been fulfilled by companies applying for the EU Ecolabel, independently from national laws.  

  The  requirements  set  in  criterion  11  apply  to  the  final  absorbent  hygiene  product 

assembly site. 

Applicants shall obtain third-party verification supported by site audit(s) that the following principles 
included in the International Labour Organisation's (ILO) Tripartite Declaration of Principles concerning 
Multinational  Enterprises  and  Social  Policy10;  the  UN  Global  Compact  (Pillar  2)11;  the  UN  Guiding 
Principles on Business and Human Rights12; and; the OECD Guidelines for Multinational Enterprises13, 
have been respected. 

(i) Child Labour:  

—  Minimum Age Convention, 1973 (No 138);  

—  Worst Forms of Child Labour Convention, 1999 (No 182).  

(ii) Forced and Compulsory Labour:  

—  Forced Labour Convention, 1930 (No 29) and 2014 Protocol to the Forced Labour Convention;  

—  Abolition of Forced Labour Convention, 1957 (No 105). 

(iii) Freedom of Association and Right to Collective Bargaining:  

—  Freedom of Association and Protection of the Right to Organise Convention, 1948 (No 87);  

—  Right to Organise and Collective Bargaining Convention, 1949 (No 98).  

(iv) Discrimination:  

—  Equal Remuneration Convention, 1951 (No 100); 

—  Discrimination (Employment and Occupation) Convention, 1958 (No 111). 

ILO NORMLEX (http://www.ilo.org/dyn/normlex/en) and supporting guidance.  

10  
11   United Nations Global Compact (Pillar 2), https://www.unglobalcompact.org/what-is-gc/participants/141550. 
12   Guiding Principles for Business and Human Rights, https://www.unglobalcompact.org/library/2. 
13   OECD Guidelines for Multinational Enterprises, https://www.oecd.org/daf/inv/mne/48004323.pdf. 

65 

 
 
 
 
 
 
                                                 
 
(v) Working Hours:  

—  ILO Hours of Work (Industry) Convention, 1919 (No 1); 

—  ILO Weekly Rest (Industry) Convention, 1921 (No 14). 

(vi) Remuneration:  

—  ILO Minimum Wage Fixing Convention, 1970 (No 131);  

—  ILO Holidays with Pay Convention (Revised), 1970 (No 132);  

—  Living wage: The applicant shall ensure that wages (excluding any taxes, bonuses, allowances, or 
overtime wages)  paid for a normal  work week (not exceeding 48 hours) shall be  sufficient to 
afford  basic  needs  (housing,  energy,  nutrition,  clothing,  health  care,  education,  potable  water, 
childcare, and transportation) of workers and of a family of four people, and to provide some 
discretionary income. Implementation shall be audited with reference to the SA8000 guidance on 

(vii) Health & Safety:  

—  ILO Safety in the use of chemicals at work Convention, 1981 (No 170);  

—  ILO Occupational Safety and Health Convention, 1990 (No 155);  

—  ILO Working Environment (Air Pollution, Noise and Vibration) Convention, 1977 (No 148). 

(viii) Social protection and inclusion: 

—  ILO Medical Care and Sickness Benefits Convention, 1969 (No 130); 

ILO Social Security (Minimum Standards) Convention, 1952 (No 102); 

—  ILO Employment Injury Benefits Convention, 1964 (No 121); 

—  ILO Equality of Treatment (Accident Compensation) Convention, 1925 (No 19); 

—  ILO Maternity Protection Convention, 2000 (No 183). 

(ix) Fair dismissal: 

—  ILO Termination of Employment Convention, 1982 (No 158). 

  In  locations  where  the  right  to  freedom  of  association  and  collective  bargaining  are 
restricted under law, the company shall not restrict workers from developing alternative 
mechanisms  to  express  their  grievances  and  protect  their  rights  regarding  working 
conditions  and  terms  of  employment,  and  shall  recognise  legitimate  employee 
associations with whom it can enter into dialogue about workplace issues. 

66 

 
 
 
 
 
 
 
  The  audit  process  shall  include  consultation  with  external  industry-independent 
organisation stakeholders in local areas around sites, including trade unions, community 
organisations, NGOs and labour experts. Meaningful consultations shall take place with 
at least two stakeholders from two different subgroups. In locations where national law 
cannot  ensure  adequacy  of  corporate  social  responsibility  with  the  aforementioned 
international  conventions,  the  audit  process  shall  include  third-party  site  audits 
composed of unannounced spot inspections by industry-independent evaluators. 

  During  the  validity  period  of  the  EU  Ecolabel  license,  the  applicant  shall  publish  the 
aggregated results and key findings from the audits (including details on (a) how many 
and  how  serious  violations  of  each  labour  rights  and  OHS  standard;  (b)  strategy  for 
remediation   where remediation includes prevention per UNGP concept; (c) assessment 
of root causes of persistent violations resulting from stakeholder consultation   who was 
consulted,  what  issues  were raised,  how  did  this influence  the  corrective  action  plan), 
online in order to provide evidence of their performance to interested consumers. 

Third  party  verification  of  factory  sites  to  the  following  standards  and  codes  of  conduct  shall  be 
recognised as their core criteria reflect the ILO standards. 

Equivalent codes of conduct 

OECD  Guidelines  for  Multi-National  Enterprises:  Recommendations  on  human  rights  and  on 

employment and industrial relations https://www.oecd.org/corporate/mne/   

The  United  Nations  Global  Compact: 
https://unglobalcompact.org/what-is-gc/mission/principles   

Principles 

on  Human 

rights 

and 

Labour 

The Joint Initiative on Corporate Accountability and Workers Rights (JO-IN): the Draft Code of Labour 

Practice https://jo-in.org/pub/about.shtml   

Equivalent standards  

ISO  26000:  Human  rights  and  Labour  practice  components  https://www.iso.org/iso-26000-social-

responsibility.html   

Social Accountability 8000 (SA8000) https://sa-intl.org/   

Ethical Trading Initiative (ETI) https://www.ethicaltrade.org/   

Fair Wear Foundation (FWF) https://www.fairwear.org/   

Business Social Compliance Initiative (BSCI) https://www.amfori.org/content/amfori-bsci   

Fair Labour Association (FLA) https://www.fairlabor.org/   

67 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  Third-party site audits shall be carried out by auditors qualified to assess the compliance 
of  the  industry  manufacturing  sites  with  social  standards  or  codes  of  conduct  or,  in 
countries where the ILO Labour Inspection Convention, 1947 (No 81) has been ratified 
and ILO supervision indicates that the national labour inspection system is effective and 
where  the  scope  of  the  inspection  systems  covers  the  areas  listed  above,  by  labour 
inspector(s) appointed by a public authority. 

  The  third-party  certifications  shall  be  not  more  than  12  months  old,  on  the  date  of 
application. The applicant shall demonstrate third party verification of compliance, using 
independent verification or documentary evidence, including site visits by auditors during 
the Ecolabel verification process for production sites in the supply chain for the licensed 
products. These shall take place upon application and subsequently during the license 
period if new production sites are introduced.  

Required documentation: 

  Declaration of compliance with the criterion (template available separately). 

  Copies of the most recent version of the code of conduct for each final product assembly 
plant for the model(s) to be awarded the EU Ecolabel (consistent with the provisions specified 
above). 

  Copies of the supporting audit reports for each final product assembly plant for the model(s) 
to be awarded the EU Ecolabel (adding a web link to where online publication of the results 
and findings can be found).  

  Valid certifications from third-party schemes or inspection processes of audit compliance for 
each final product assembly plant for the model(s) to be awarded the EU Ecolabel (consistent 
with the provisions specified above). 

68 

 
 
 
 
 
16 Criterion 12: Information appearing on the EU Ecolabel 

This  criterion  aims  to  inform  consumers  about  the  EU  Ecolabel  environmental  preference  of  the 
products and to make easier the environmentally friendly choice. In this line, the EU Ecolabel logo 
may be displayed on the sales packaging of the product.  

If the optional label with text box is used, it shall contain the following three statements: 

— 

— 

— 

  The applicant shall follow the instructions on how to use the EU Ecolabel logo as provided 
Guidelines: 

in 
http://ec.europa.eu/environment/ecolabel/documents/logo_guidelines.pdf  

Ecolabel 

Logo 

the 

EU 

Required documentation: 

  Declaration of compliance with the criterion (template available separately). 

  High-resolution photograph of the product sales packaging that clearly shows the EU Ecolabel 
logo,  the  registration/license  number  and,  where  relevant,  the  statements  that  can  be 
displayed together with the logo. 

69 

 
 
 
 
 
 
 
 
17 Conclusions 

This User Manual guides the application 
and it explains all requirements established in Commission Decision 2023/1809, in order to optimise 
the time and ease the procedures of all the actors involved in the application stage. Before starting 
the application, applicants are recommended to read Commission Decision 2023/1809 and its Annex 
I carefully; contact a national EU Ecolabel competent body; ensure that the candidate product fulfils 
all applicable legal requirements of the country or countries in which the product is intended to be 
placed on the market. The User Manual is composed of separate chapters that explain in detail each 
of the EU Ecolabel criteria and sub-criteria for absorbent hygiene products, provide useful links and 
list the documentation to be provided to the competent body responsible for the assessment of the 
applications. This User Manual is for guidance only; it does not have any legal standing and does not, 
in any way, replace the Commission Decision or any other relevant legislation. 

70 

 
 
 
 
References 

AFNOR, Standard Q34-019, Sanitary and domestic articles. Test method under conditions of use for 
child/woman  hygiene  and  incontinence  articles  (single  use  articles).  Recommendations.  December 
1994 

Commission Decision (EU) 2023/1809 of 14 September 2023 establishing the EU Ecolabel criteria 
for absorbent hygiene products and for reusable menstrual cups, OJ L 234, 22.9.2023 

COMMISSION RECOMMENDATION of 8.12.2022 establishing a European assessment framework for 

 chemicals and materials, C(2022) 8854 final 

COMMUNICATION  FROM  THE  COMMISSION  TO  THE  EUROPEAN  PARLIAMENT,  THE  COUNCIL,  THE 
EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS, EU policy 
framework on biobased, biodegradable and compostable plastics, COM/2022/682 final 

Council Regulation (EC) No 834/2007of 28 June 2007 on organic production and labelling of organic 
products and repealing Regulation (EEC) No 2092/91 (OJ L 189, 20.7.2007, p. 1) 

European Commission, Voluntary schemes (web page). Last accessed: July 2024 

Faraca, G., Perez Camacho, M.N., Lag Brotons, A., Perez Arribas, Z., Kowalska, M.A. and Wolf, O., Revision 
of  EU  Ecolabel  criteria  for  Absorbent  Hygiene  Products  and  Reusable  Menstrual  Cups  (previously 
Absorbent  Hygiene  Products),  Publications  Office  of  the  European  Union,  Luxembourg,  2023, 
doi:10.2760/209936, JRC134197 

Global Organic Textile Standard (GOTS) - Version 7.0, March 2023 

Nessi, S., Sinkko, T., Bulgheroni, C., Garcia-Gutierrez, P., Giuntoli, J., Konti, A., Sanye Mengual, E., Tonini, 
D.,  Pant,  R.,  Marelli,  L.  and  Ardente,  F.,  Life  Cycle  Assessment  (LCA)  of  alternative  feedstocks  for 
plastics production, EUR 30725 EN, Publications Office of the European Union, Luxembourg, 2021, 
ISBN 978-92-76-38144-0, doi:10.2760/693062, JRC125046 

Perez Camacho, M.N., Faraca, G., Perez Arribas, Z., Kowalska, M.A., Wolf, O., Sinkko, T. and Tosches, D., 
Revision  of  EU  Ecolabel  criteria  for  Absorbent  Hygiene  Products  and  Reusable  Menstrual  Cups 
(previously  Absorbent  Hygiene  Products),  Publications  Office  of  the  European  Union,  Luxembourg, 
2023, doi:10.2760/467041, JRC134703. 

Regulation (EU) 2017/745 of the European Parliament and of the Council of 5 April 2017 on medical 
devices,  amending  Directive  2001/83/EC,  Regulation  (EC)  No  178/2002  and  Regulation  (EC)  No 
1223/2009 and repealing Council Directives 90/385/EEC and 93/42/EEC, OJ L 117, 5.5.2017 

71 

 
 
 
 
List of abbreviations and definitions 

Abbreviations 

Definitions 

AHP 

AOX 

ASTM 

CAS 

CLP 

COD 

ECF 

EDANA 

EMAS 

EN 

EU 

FSC 

GOTS 

ISO 

JRC 

LCA 

NOx 

PAH 

PBT 

PEFC 

Absorbent Hygiene Products 

Adsorbable organic halogen compounds 

American Society for Testing and Measurement 

Chemical Abstracts Service 

Classification, labelling and packaging 

Chemical oxygen demand 

Elemental Chlorine Free 

The international association for the nonwovens and related 
industries 

Eco-Management and Audit Scheme 

European Norm 

European Union 

Forest Stewardship Council 

Global Organic Textile Standard 

International Standardisation Organisation 

Joint Research Centre 

Life Cycle Assessment 

Nitrous Oxides 

Polycyclic Aromatic Hydrocarbon 

Persistent, Bioaccumulative and Toxic 

Programme for the Endorsement of Forest Certification 

72 

 
Abbreviations 

Definitions 

PMT 

REACH 

SAP 

SO2 

SVHC 

TCF 

TEWL 

vPvB 

vPvM 

Persistent, Mobile and Toxic 

Registration, Evaluation, Authorisation and Restriction of 
Chemicals 

Superabsorbent Polymer 

Sulphur Dioxide 

Substance of Very High Concern 

Total Chlorine Free 

Transepidermal Water Loss 

Very Persistent and very Bioaccumulative 

Very Persistent and very Mobile 

73 

 
 
List of figures  

Figure 1: Sales packaging (primary packaging) ................................................................................................................. 57 

Figure 2: Separate component (additional component) ................................................................................................ 57 

74 

 
 
List of tables  

Table 1: Reference values for emissions from different pulp types ..................................................................... 20 

Table 2: Limit values for different types of pulp .............................................................................................................. 24 

Table 3: Reference values for CO2 emissions from different energy sources ................................................. 24 

Table 4: Reference values for electricity and fuel from different pulp types .................................................. 27 

Table 5: Viscose and modal fibres emission values ....................................................................................................... 32 

Table 6: Excluded hazard classes, categories and associated hazard statement codes. vPvB: very 
persistent and very bioaccumulative; vPvM: very persistent and very mobile ................................................ 42 

Table 7: Restricted hazard classes, categories and associated hazard statement codes ......................... 44 

Table 8: Derogated substances and derogation conditions ........................................................................................ 45 

Table 9: List of restricted chemicals in the final product ............................................................................................ 55 

Table 10: Characteristics and parameters describing the fitness for use of the product to be tested. 
More details can be found in the Technical Report. TEWL: transepidermal water loss .............................. 61 

75 

 
 
 
 
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