Background report to the guide for the use of the EU Ecolabel criteria in the green public procurement of absorbent hygiene products.
Date: 2024-08-29
Institutions: Joint Research Centre
Subjects: European standard, circular economy, consumer information, eco-label, environmental impact, environmental standard, reproductive health, research report, woman

ISSN 1831-9424 

Background report to the guide for the use 
of the EU Ecolabel criteria in the green 
public procurement of absorbent hygiene 
products 

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

2024 

EUR 32033  

 
 
  
  
 
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JRC138563 
EUR 32033 

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ISBN 978-92-68-20101-5   ISSN 1831-9424   doi:10.2760/293234  

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How to cite this report: European Commission, Joint Research Centre, Kowalska, M.A., Pérez-Camacho, M.N., Faraca, G. and Wolf, O., 
Background report to the guide for the use of the EU Ecolabel criteria in the green public procurement of absorbent hygiene products, 
Publications Office of the European Union, Luxembourg, 2024, https://data.europa.eu/doi/10.2760/293234, JRC138563. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Contents  

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

Acknowledgements .......................................................................................................................................................................................................................................... 4 

Executive summary .......................................................................................................................................................................................................................................... 5 

1 

Introduction..................................................................................................................................................................................................................................................... 7 

1.1  The procurement process and types of procedure...................................................................................................................................... 9 

1.2  Types of procurement criteria ...................................................................................................................................................................................... 10 

1.3  Use of EU Ecolabel criteria in public procurement ................................................................................................................................... 11 

2  Product-specific information ...................................................................................................................................................................................................... 13 

2.1  Scope and definition .............................................................................................................................................................................................................. 13 

2.2  Market analysis .......................................................................................................................................................................................................................... 16 

2.3  Environmental hotspots ..................................................................................................................................................................................................... 26 

3 

Identification of EU Ecolabel-based criteria for the public procurement of absorbent hygiene products....... 32 

3.1  Screening exercise: part 1   EU Ecolabel .......................................................................................................................................................... 32 

3.2  Screening exercise: part 2   other ISO 14024 Type I ecolabels ................................................................................................. 33 

3.3  General considerations about verification via ecolabels .................................................................................................................... 35 

3.4  Recommended EU GPP criteria for the public procurement of absorbent hygiene products. ........................ 36 

Fluff Pulp .............................................................................................................................................................................................................................................. 37 

TS 1.1. Sourcing of fluff pulp ................................................................................................................................................................................... 37 

TS 1.2. and AC 1.1. Bleaching of fluff pulp ................................................................................................................................................. 39 

AC 1.2. Chemical oxygen demand (COD) sulphur (S), NOx, and phosphorous (P) emissions ...................... 40 

AC 1.3. Emissions of CO2 from fluff pulp production ........................................................................................................................ 42 

AC 1.4. Energy consumption ...................................................................................................................................................................................... 45 

Man-made cellulose fibre ..................................................................................................................................................................................................... 47 

TS 2.1. Sourcing of man-made cellulose fibres ..................................................................................................................................... 47 

TS 2.2 and AC 2.1. Bleaching of man-made cellulose fibre ....................................................................................................... 48 

AC 2.2. Production of man-made cellulose fibre................................................................................................................................... 49 

Cotton and other natural cellulosic seed fibres ............................................................................................................................................... 51 

TS 3.1. and TS 3.2. Sourcing and bleaching of cotton and other natural cellulosic seed fibre................. 51 

Production process ...................................................................................................................................................................................................................... 53 

TS 4.1. Material efficiency in the manufacturing of the final product. ............................................................................ 53 

Packaging ............................................................................................................................................................................................................................................. 54 

4  Conclusions .................................................................................................................................................................................................................................................. 59 

References ............................................................................................................................................................................................................................................................. 60 

List of abbreviations and definitions ........................................................................................................................................................................................... 63 

List of figures ..................................................................................................................................................................................................................................................... 64 

List of tables ........................................................................................................................................................................................................................................................ 65 

Annexes .................................................................................................................................................................................................................................................................... 66 

1 

 
 
 
 
Annex 1. Explanations of screening of EU Ecolabel criteria for suitability of use in EU GPP criteria ................... 66 

Annex 2. Indicative information on verifying the EU GPP recommendation for absorbent hygiene products 
using selected ISO 14024 type I ecolabels .................................................................................................................................................................. 70 

2 

 
 
 
Abstract  

Green  public  procurement  (GPP)  is  a  powerful  tool  to  achieve  environmental  objectives  by  means  of  the 
incorporation of green requirements into public sector purchasing contracts. Public authorities, by promoting 

the transformation towards a sustainable economy model.  

ducers to be able to make certifiable and credible green 
claims  about  their  products  and  for  customers  to  know  what  to  ask  for.  While  the  EU  Ecolabel  policy  can 
provide environmental references or standards for the former, the EU GPP policy can provide for the latter.  

The  EU  GPP  recommendations  placed  in  this  document  are  based  on  the  EU  Ecolabel  criteria  and intend to 
provide  authorities  with  guidance  on  how  to  use  ecolabels,  and  in  particular  the  EU  Ecolabel,  in  the 
procurement process. This report aims to bring these two policies together in order to find synergies between 
 specifically for the procurement of 
the supply-side EU Ecolabel policy and the demand-side EU GPP policy 
absorbent  hygiene  products  such  as  baby  diapers,  sanitary  towels,  panty  liners,  tampons,  nursing  pads,  or 
incontinence products.  

In  addition  to  a  brief  introduction  to  the  EU  Ecolabel  policy,  to  the  EU  GPP  policy  and  to  procurement 
procedures  as  a  whole,  research  is  presented  to  support  JRC  recommendations  to  public  procurers  about 
exactly what green criteria to set when trying to procure environmentally friendly absorbent hygiene products.  

The recommended environmental criteria are categorised into the five most appropriate areas (addressed in 
detail  in  9  technical  specifications  and  10  award  criteria)  based  on  their  link  to  the  subject  matter  of  the 
procurement, ease of verification (in cases where there is no EU Ecolabel) and relevance to the environmental 
impact., as follows: 

1. 

Fluff pulp sourcing and manufacturing (referring to the impacts associated with upstream processes 
for cellulose fibre sourcing and processing, i.e., emissions and energy consumption); 

2.  Man-made  cellulose  fibre  sourcing  and  manufacturing  (referring  to  impacts  associated  with 
upstream  processes  for  cellulose  fibre  sourcing  and  processing  i.e.,  emissions  and  viscose  process 
efficiency); 

3. 

Cotton  and  other  cellulose  seed  fibre  sourcing  and  manufacturing  (referring  to  the  impacts 
associated with upstream processes for cotton fibre sourcing and processing i.e., bleaching); 

4.  Material  efficiency  in  the  production  of  the  final  product  (in  terms  of  the  impact  associated  with 

material recovery in the core process); 

5. 

Packaging (referring to the impact associated with materials circularity and resource efficiency in the 
downstream processes i.e., packaging recyclability and minimum content of recycled material).  

Where relevant, further information about the why the criteria are relevant and what other ISO 14024 type I 
ecolabels may be considered as equivalent is provided. 

3 

 
 
Acknowledgements  

The authors wish to thank corresponding policy officers from DG Environment for their support and feedback 
during  the  production  of  this  report.  Likewise,  the  authors  wish  to  thank  members  of  the  EU  Ecolabelling 
Board, the GPP Advisory Group and the JRC Editorial Board for their input and comments. 

Authors 

Malgorzata Agata Kowalska, Seville, Spain. 

María  Natividad  Pérez-Camacho,  JRC,  Directorate  B 
Sustainable Industry. 

  Fair  and  Sustainable  Economy,  Circular  Economy  and 

Giorgia  Faraca,  JRC,  Directorate  B 
Industry. 

  Fair  and  Sustainable  Economy,  Circular  Economy  and  Sustainable 

Oliver Wolf, JRC, Directorate B   Fair and Sustainable Economy, Circular Economy and Sustainable Industry. 

4 

 
Executive summary  

In accordance with the provisions of Article 7(1)(f) of the EU Ecolabel Regulation (EC) No 66/2010, the aim of 
this report is to present and justify the selection of certain EU Ecolabel criteria that are considered to be the 
most  relevant  and  appropriate  for  use  by  public  authorities  as  Green  Public  Procurement  (GPP)  criteria  in 
tenders for the procurement of absorbent hygiene products with good environmental performance.  

Consequently, this report primarily targets public authorities seeking to procure such products, but is also of 
interest  to  suppliers  and  manufacturers  of  these  products,  since  it  provides  a  clear  indication  of  relevant 
-to-peer sharing 
of procurement initiatives by providing practical guidance that can be used as reference on how to formulate 
and verify green claims under the procurement contracts. 

Altogether, the document provides 1) a general guidance on the key environmental considerations that should 
be incorporated into the public purchase (when defining life cycle-based environmental criteria), and 2) ready-
to-use EU GPP criteria (and corresponding means of verification). 

The report consists of a general introduction to EU GPP and EU Ecolabel policies and how they can and should 

is provided, with a focus on the following points: 

 

The  scope  and  definition  of  products  that  criteria  apply  to,  including  reference  to  Common 
Procurement Vocabulary codes that should be used in calls for competition. 

  Market considerations, including real examples of how the procurers purchase these products. 

 

The main environmental hotspots associated with absorbent hygiene products.  

Based  on  the  random  review  of  tenders  available  on  the  Tenders  Electronic  Daily  (TED)  platform,  the 
procurement  of  absorbent  hygiene  products  primarily  covers  the  needs  of  healthcare  providers  or  related 
public administrations, including public home care services. Absorbent hygiene products are also purchased by 

such  products.  The  distribution  of  the  free  absorbent  period  products  might  also  form  part  of  a  dedicated 
governmental campaign to take action against period poverty.  

In the period 2015   October 2023, the number of public tenders for baby care products (disposable nappies) 
is the highest among absorbent hygiene products, followed by sanitary paper products. The type of contract is 
mainly  focused  on  the  supply  of  products,  while  service  contracts  account  for  less  than  1%  of  all  notices. 
Service-related activities include 34% of contracts for the home delivery of incontinence products.  

The main environmental hotspots were found to be associated with the upstream processes of sourcing and 
processing the materials for subsequent use in the manufacture of the final product. This is due to the high 
consumption of natural resources, electricity and chemicals.  

Policy context 

The report is a comprehensive introduction to EU GPP and EU Ecolabel policies, as well as how they can be 
integrated to ´green' the market for certain product groups. 

Key conclusions 

The following EU Ecolabel criteria are recommended to be used by procurers in calls for competition 

1. 

2. 

3. 

4. 

5. 

Fluff pulp sourcing and manufacturing; 

Man-made cellulose fibre sourcing and manufacturing; 

Cotton and other cellulose seed fibre sourcing and manufacturing; 

Material efficiency in the production of the final product; 

Packaging.  

After  each  suggested  criterion,  further  information  is  provided  to  better  inform  procurers  about  why  the 
criterion is relevant, if there are equivalent labels and how they diverge, in case of non-equivalency. 

Brief  justifications  of  why  these  EU  Ecolabel  criteria  were  considered  as  relevant  and  suitable  for  EU  GPP 
criteria (based on relevance to the subject matter, ease of verifiability and environmental relevance) can be 

5 

 
found  in  Annex  1.  For  each  selected  criteria  area,  Annex  2  lays  out  an  equivalency  check,  between  the  EU 
Ecolabel and selected ISO 14024 type I ecolabels.  

Related and future JRC work 

This background report is complementary to a more concise (10 page) Science for Policy Brief for the same 
subject. Readers of the Brief who wish to find more information are directed to this background report. It is 
planned to prepare similar background report + Brief combinations for several different products groups in the 
near future.  

Quick guide 

The  core  of  this  report  is  in  sections  2.1  and  3.3,  where  the  scope  is  defined  and  where  EU  GPP  criteria 
recommendations  are  made.  After  each  criterion,  further  information  is provided  to  better inform  procurers 
about  the  criterion  and  why  it  is  important,  if  there  are  equivalent  labels  and  what  results  from  any  tests 
generally mean. 

Brief  justifications  of  why  these  EU  Ecolabel  criteria  were  considered  as  relevant  and  suitable  for  EU  GPP 
criteria (based on relevance to the subject matter, ease of verifiability and environmental relevance) can be 
found in Annex 1 to this report.  

Any absorbent hygiene product carrying the EU Ecolabel can be automatically assumed to comply with all of 
the  EU  GPP  criteria  recommended  in  this  report.  Other  ISO  14024  type  I  ecolabels  may  also  demonstrate 
proof of compliance with some or all of the recommended EU GPP criteria in this report, but these need to be 
carefully checked. For reference, a side-by-side comparison of the recommended criteria in relevant ecolabels 
for similar products is presented in Annex 2 to this report. 

6 

 
1 

Introduction  

Every year, over 250 000 public authorities in the EU spend around 14% of EU Gross Domestic Product (GDP) 
on the purchase of services, works and supplies1, accounting for roughly EUR 1.8 trillion annually (EC, 2016). 
Across  the  Organisation  for  Economic  Co-operation  and  Development  (OECD)  countries,  public  procurement 
purchasing  power  makes  up  an  average  of  12%  GDP,  and  up  to  30%  in  many  developing  countries, 
worldwide2. 

Green Public Procurement (GPP) is 

COM(2008)  400)  as  "a  process  whereby  public  authorities  seek  to  procure 
goods, services and works with a reduced environmental impact throughout their life cycle when 
compared to  goods, services and  works  with the same  primary  function that  would otherwise be procured." 
Training toolkits3 for public authorities are available to help understand the  strategic thinking, legal aspects 
and needs assessment associated with procurement as well as how to engage with the market.  

The new EU circular economy action plan (CEAP) recognizes public procurement as a driving force, capable of 
incentivising  the  demand  for  sustainable  products  and  of  steering  the  market  transition  towards  circular 
economy principles. The CEAP also stresses the need to improve the coherence between public procurement 
and  any  other  complementary  regulatory  or  voluntary  approaches  of  new  and  existing  instruments  that 
regulate products along various phases of their life cycle.  

GPP is one of the pillars of Sustainable Product Procurement (SPP)4. Worldwide, governments (especially those 
in OECD-countries) initially implemented sustainable procurement by focusing on reducing the environmental 
impacts of purchasing, but now they are progressively leveraging their procurement in support of social equity 
and economic development (UNEP, 2022). Indeed, the public sector can use procurement to boost jobs, growth 
and investment, and to create an economy that is more innovative, more energy efficient5 and more circular 
(ICLEI, 2017).  

The  EU  Ecolabel  is  the  official  EU  Ecolabel  for  environmental  excellence  of  products  (goods  and  services). 
According to Regulation (EC) No 66/2010 (EC, 2010), is to promote products (goods and services) with a 
reduced environmental impact during their entire life cycle. The EU Ecolabel criteria target the top 10 
to  20 %  of  products  on  the  market  within  a  defined  product  group  The  development  of  a  Manual  for 
authorities  awarding  public  contracts  is  foreseen  in  Article  7(1)  point  (f)  of  the  EU  Ecolabel  Regulation  (EC, 
2010), which states the following:  

The party which initiates and leads the  development or revision of EU Ecolabel  criteria shall, in accordance 
with the procedure set out in Part A of Annex I, produce the following documents: 

(a)  a preliminary report; 

(b)  a proposal for draft criteria; 

(c)  a technical report in support of the proposal for draft criteria; 

(d)  a final report; 

(e)  a manual for potential users of the EU Ecolabel and competent bodies; 

(f)  a manual for authorities awarding public contracts  

1 See: https://ec.europa.eu/info/policies/public-procurement_en  

2 See: https://www.unep.org/explore-topics/resource-efficiency/what-we-do/sustainable-public-procurement 

3 See the GPP Training toolkits here: https://ec.europa.eu/environment/gpp/toolkit_en.htm  

4 Sustainable principle is based on environmental, social and economic considerations. Sustainable procurement strategy considers the 
life  cycle  value  of  the  project,  social  impact  and  the  economic  benefits.,  for  more  information  about  sustainable  public  procurement, 
please see: SPP (UNEP)  

5  For  example,  Annex  III  to  the  Energy  Efficiency  Directive  obliges  central  governments  to  play  an  exemplary  role  in  the  purchase  of 
products,  services  or  buildings  with  the  highest  energy  efficiency  class  possible  (without  compromising  cost-effectiveness,  economic 
feasibility, technical suitability or the availability of competition).. 

7 

 
 
                                                        
 
EU Ecolabel criteria on the supply side can work in combination with EU GPP criteria on the demand side to 
drive  the  market  towards  better  products  in  terms  of  environmental  performance.  As  shown  in  Figure  1 
below,  the  EU  Ecolabel  enables suppliers  to  market  their  products with  an  ecolabel  that  can  be  used  as an 
accurate, non-deceptive and science-based proof of the excellent environmental performance of their product. 
Public authorities can then directly specify some or all EU Ecolabel criteria in calls for competition, depending 
on how ambitious they want to be. The combined effect of both supply push with EU Ecolabel and demand 
pull from EU GPP, is to shift the market distribution towards greener products as shown below.  

Figure 1. Intended effect of voluntary EU GPP and EU Ecolabel criteria on overall environmental performance of defined 
product groups and services on greening of the market 

Source: JRC own elaboration. 

This report promotes synergies between EU Ecolabel and EU GPP policies for  absorbent hygiene products by 
recommending  selected  EU  Ecolabel  criteria  for  public  authorities  to  specify  in  calls  for  competition.  This 
document provides:  

1)  A  general  guidance  on  the  key  environmental  considerations  that  should  be  incorporated  into  public 
purchasing specifications (when defining life cycle-based environmental criteria; 

2) Ready-to-use EU GPP criteria (and their verification).  

At the same time, the report informs relevant producers and suppliers of key environmental criteria that could 
make their products and services more suitable for upcoming tendering processes that will look to incorporate 
green criteria.  

This  identifies  EU  Ecolabel  criteria  that  are  most  suitable  for  inclusion  in  a  public  procurement  process, 
considering three main principles: 

1.  Compliance with the existing public procurement rules, in particular regarding the link to the subject 

matter of the contract being awarded; 

2.  Verifiability of the criteria by public authorities, beyond the reliance on products having been 

awarded the EU Ecolabel; 

3.  Highest environmental relevance as per life cycle impacts and circular economy objectives (EC, 

2020). 

8 

 
 
The recommendations proposed within this report consider the most dominant environmental impacts of the 
product group as suggested by the life cycle assessment. Where relevant, findings from background research 
undertaken when revising the EU Ecolabel criteria for absorbent hygiene products, or the final technical report 
which presents the current EU Ecolabel criteria, have been referred to for the proposed recommendations. 

1.1  The procurement process and types of procedure 

In general, procurement processes follow the sequence of:  

2.  Needs identification;  

3.  Choice of procurement method; 

4.  Allocation of financial resources/budget; 

5.  Preparation of procurement documentation; 

6.  Market engagement (optional) 

7.  Publication of documents for call for competition; 

8.  Receipt of and opening of offers; 

9.  Evaluation and verification of offers; 

10.  Announcement of winning offer; 

11.  Award and signing of contract. 

There are a number of different procurement procedures that can be applied depending on the nature of the 
goods, works or services being procured and also different types of contracting techniques depending on the 
needs of the procuring authority. The main types of process are summarised below. 

Figure 2. Broad overview of different procurement procedures that are used in the EU 

Source: JRC own elaboration. 

9 

 
 
 
 
 
The  introduction  of  environmental  requirements  to  the  procurement  of  absorbent  hygiene  products  merits 

Engaging  with  the  market  or  trying  to  prepare  the  market 

stage 0

procedures, but is already incorporated in the other types  of 
the procurement process that include negotiation stages.  

The benefits of market preparation are: 

Economic  operators  who  are  better  prepared  for 

1. 
environmental issues are more likely to become bidders; 

More  bidders  prepared  on  environmental  issues 

2. 
means more competition; 

More 

3. 
environmentally friendly products; 

competition  means  more  options 

for 

More  environmentally  friendly  products  mean  a 

4. 
greener consumption. 

1.2  Types of procurement criteria 

Engaging with the market: 

  Consulting with internal or external experts 
with  a  good  knowledge  of  the  market  for 
the  products  to  be  procured  and  the 
current state of the art with green criteria 
in these products.  
Establishing 
potential 
bidders  and  possibly  holding  information 
sessions  to  discuss  the  feasibility  of 
applying  certain  green  criteria  in  calls  for 
tender. 

dialogue  with 

 

Publishing a Prior Information Notice (PIN) about 
the environmental criteria you intend to apply in 
order to  give  potential  bidders sufficient time to 
prepare (may also include producers applying for 
the EU Ecolabel) 

Criteria differ in terms of when they apply in the evaluation process, in terms of being mandatory or voluntary 
in  nature  and  in  terms  of  who  or  what  they  apply  to.  The  relative  importance  of  each  type  of  criteria  will 
ultimately depend on how the call for competition is worded and structured by the contracting authorities. An 
illustration of how these criteria potentially apply in a procurement process is provided in Figure 3. 

Exclusion criteria (ECs): These are mandatory criteria set in European and national procurement law that 
apply to the economic operators who are bidding (the bidders). Such criteria will relate to non-compliance 
with applicable laws, grave professional misconduct that could render the integrity of the economic operator 
as questionable, or significant/persistent deficiencies in performance of substantive requirements under prior 
contracts that led to termination or comparable sanctions. Additional mandatory exclusion criteria may also 
be defined. Any bids from bidders failing the ECs are not evaluated. 

Selection  criteria  (SCs):  These  are  optional  criteria  in  terms  of  whether  they  are  used  or  not,  but  when 
used, they take on a mandatory character. It is common that SCs are used to set requirements relating to 
the experience, capacity and professional ability of the  bidders. In all cases, SCs must be proportionate, 
linked to the subject matter of the contract and not end up unnecessarily restricting competition (for example 
by presenting a barrier to SMEs). 

Technical specifications (TSs): This is the mandatory core of public procurement criteria and defines the 
minimum requirements that all offers must meet. All TSs therefore relate directly to the subject matter of 
the contract. Care must be taken when setting TSs to be sure that there are sufficient products or services on 
the market that can meet these requirements. If not, then there is a risk that no/few offers will be received, 
which results in less competition. 

Award criteria (ACs): These criteria are always present in one form or another. The most basic AC is that 
the winning bid will be the one with the lowest cost (i.e. 100 % weighting on price). But ACs also provide the 
opportunity to insert a number of additional optional requirements that are related to quality and that can 
be independent of TSs or complimentary to them. Like TSs, they also apply directly to the subject matter of 
the contract, and thus to offers received.  The combination of less ambitious TSs with more ambitious 
ACs  allows  calls  for  competition  to  be  published  that  reward  the  best  products  on  the  market  without 
unnecessarily  restricting  the  potential  number  of  bidders.  Awarding  extra  points  for  quality  or 
environmental  performance  in  ACs  is  a  way  for  contracting  authorities  to  make  better  quality  or  more 
environmentally  friendly  products  more  competitive  with  cheaper  and  less  environmentally  friendly 
alternatives. 

Contract Performance Clauses (CPCs): CPCs defined in the call for competition aim to inform bidders of 
what  conditions  would  apply  to  the  winning  bidder  (i.e.,  the  contractor).  They  are  essentially  mandatory 
requirements that would be incorporated into a formal contract signed with the eventual contractor.  

10 

 
 
 
Figure 3. Illustration of how the main different types of procurement criteria can apply 

Source: JRC own elaboration. 

1.3  Use of EU Ecolabel criteria in public procurement 

The  EU  public  procurement  Directives  2014/24/EU  and  2014/25/EU  (EC,  2014a  and  EC,  2014b)  define  the 
possibilities of using labels (e.g., ecolabels) in public procurement. Labels can be used at different stages of 
the procurement process. At the verification stage, ecolabels provide a means of third-
can considerably help procurers to save time and effort while ensuring that high environmental standards are 

The United Nations´s Sustainable Public Procurement and Ecolabelling (SPPEL) project combines ecolabelling 
with  sustainable  public  procurement  measures  and  encourages  the  supply  and  demand  of  sustainable 
products  all  over  the  world.  The  following  figure  shows  an  estimate  derived  from  the  SPP  Global  Review 
Stakeholders  Survey  2021  on  the  use  of  ecolabels  by  procuring  organisations  worldwide  (N=257)  6  (UNEP, 
2022).  

Figure 4. Global use of Ecolabels by procurement entities 

Source: JRC own elaboration based on UNEP, 2022. 

In general, labels can be required as means of proof in public procurement, provided that all of the following 
conditions are fulfilled (taken from Article 43 of Directive 2014/24/EU and Article 61 of Directive 2014/25/EU, 
with some additional text added in square brackets [] for clarity): 

a) 

the label requirements [set in GPP criteria] only concern [proof of compliance with] criteria which are 
linked  to  the  subject  matter  of  the  contract  and  are  appropriate  to  define  characteristics  of  the 
supplies or services that are the subject matter of the contract; 

6        In Europe, 35% organisations used ecolabels as a verification means (UNEP, 2022) 

11 

 
 
 
                                                        
 
b) 

c) 

d) 

e) 

the label requirements are based on objectively verifiable and non-discriminatory criteria; 

the  labels  are  established  in  an  open  and  transparent  procedure  in  which  all  relevant  stakeholders, 
including  government  bodies,  consumers,  social  partners,  manufacturers,  distributors  and  non-
governmental organisations, may participate;  

the labels are accessible to all interested parties [i.e., manufacturers or service providers can apply for 
the label and contracting authorities can access the underlying label criteria];  

the  label  requirements  are  set  by  a  third-party  over  which  the  economic  operator  applying  for  the 
label cannot exercise a decisive influence. 

Contracting  authorities  setting  requirements  that  can  be  met  by  works,  supplies  or  services  bearing  a 
specifically  cited  label  (e.g.,  the  EU  Ecolabel)  shall  accept  any  other labels  (e.g.,  Nordic  Ecolabel,  Blue  Angel 
etc.)  as  proof  of  compliance  as  long  as  points  a),  b),  c),  d)  and  e)  above  are  valid,  and  works,  supplies  or 
services  with  these  other  labels  are  proven  to  meet  the  relevant  specified  requirements  of  that  specified 
label. 

The EU Ecolabel scheme fulfils the above points from b) to e). As regards point a), it is possible that some EU 
Ecolabel  criteria  relate  to  broader  aspects  of  the  organisation  (e.g.,  training  of  staff)  that  might  only  be 
indirectly linked to the subject matter of the contract. While all GPP criteria for AHP presented in this report 
could be considered as fulfilling the requirements of point a) on the link to the subject matter of the contract, 
this  also  depends  on  precisely  how  contracting  authorities  define  the  subject  matter  of  their  own  calls  for 
competition. Consequently, compliance of GPP criteria with point a) above must be checked on a case-by-case 
basis. 

For  more  detailed  guidance,  please  refer  to  resources  such  as  the 
EU  public  procurement  directive  (EC,  2014a),  the  Buying  Green 
Handbook  (EC,  2016),  and  the  Public  Procurement  Guidance  for 
Practitioners (EC, 2018) published by the European Commission.   

Contact us if you have any comments or 
experiences to share about the public 
procurement of absorbent hygiene 
products.  

12 

 
 
2  Product-specific information 

The research for  developing  EU Ecolabel criteria for  Absorbent  Hygiene Products (Preliminary Report:  Pérez-
Camacho et al., 2023 and Technical Report: Faraca et al., 2023) is also relevant to this EU GPP report because 
it addresses the same product group and scope. 

2.1  Scope and definition 

This GPP report applies to absorbent hygiene products (AHPs) falling within the scope and definition described 
under Article 1(1) of the Commission Decision 2023/1809

sweat, mens

. 

Reusable  hygiene  products  made  of  textiles  do  not  fall  within  the  scope  of  the  AHPs,  as  they  are  to  be 
regarded  as  textile  products.  As  per  Article  1,  the  product  group  is  not  meant  to  contain  products  that  fall 
under  Medical  Devices  Regulation  (EU)  2017/7457.  If  the  manufacturer  has an  intention  to  cover  a  medical 
purpose, incontinence products may fall under the Regulation. 

In addition, products whose purpose is not to absorb and store human fluids but rather to clean certain parts 
of the human body [such as wet wipes, cotton swabs and make-up remover wipes] are not covered by the EU 
Ecolabel  scope  for  AHP.  As far as tissue  products  are  concerned, although  they  are  often  grouped  together 
with  AHPs  under  a  general  category  of  hygiene  (or sanitary)  products, they  are  not  included  in  this  product 
group  due  to  their  different  purpose  use  (functionality).  EU  Ecolabel  criteria  for  tissue  paper  products  fall 
under the scope of Commission Decision (EU) 2019/708. The procurer can find the EU GPP recommendation 
based on EU Ecolabel criteria for tissue paper and tissue paper products in the dedicated report.9 

The  scope  of  the  product  group  is  determined  by  product  functionality  and  includes  five  key  product 
categories. 

1.  Diapers/nappies; 

2.  Sanitary Pads or Towels;  

3.  Panty liners; 

4.  Tampons,  

5.  Nursing Pads (breast pads), and 

6.  Adult incontinence products 

Main definitions 

To comprehend terminology used throughout the document, it's important to consider several definitions that 
describe the main materials or components of the final product. The complete list of applicable definitions can 
be found in Annex I of Commission Decision (EU) 2023/11809. 

  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; 

7  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/EE, 
OJ L 117, 5.5.2017, p. 1 175 
8  Commission  Decision  (EU)  2019/70  of  11  January  2019  establishing  the  EU  Ecolabel  criteria  for  graphic  paper  and  the  EU  Ecolabel 
criteria for tissue paper and tissue products, OJ L 15, 17.1.2019, p. 27 57 

9 Kowalska M, Delre A, Donatello S., and Wolf. O, 2023, Background report for authorities awarding public contracts, based on EU Ecolabel 
criteria. For the green public procurement of graphic paper, tissue paper and tissue paper product. EUR xxx EN, Publications Office of the 
European Union, Luxembourg, 2023, ISBN xxx, doi:xxx JRCxxx. 

13 

 
                                                        
 
  Component  means  one  or  several  materials  and  chemical  products  that  together  fulfil  a 
desirable  function  in  the  absorbent  hygiene  product,  such  as  an  absorbent  core,  adhesives,  or  an 
outer barrier film; 

  Composite packaging means a unit of packaging made of two or more different materials, 
excluding  materials used  for labels,  closures and sealing, which cannot be separated  manually and 
therefore form a single integral unit;  

  Grouped  packaging,  also  known  as  secondary  packaging,  means  packaging  conceived  so 
as 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; 

  Man-made  cellulose  fibres,  also  known  as  regenerated  fibres,  means  fibres  produced 

from the raw material cellulose which include viscose, modal, lyocell, cupro and triacetate;  

  Packaging means items of any materials that are intended to be used for the containment, 
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.;  

  Sales packaging, also known as primary packaging, means packaging conceived  so as to 
constitute a sales unit consisting of products and packaging to the final user or consumer at the point 
of sale;  

  Separate  component,  also  known  as  additional  component,  means  a  packaging 
component  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 
hygiene 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; 

  Super absorbent polymers mean synthetic polymers designed for absorbing and retaining 

large amounts of liquid compared to their own mass. 

Common Procurement Vocabulary (CPV) codes 

When procurers publish a call for competition, a CPV code should be used when describing the subject matter 
of  the  call.  Other  CPV  codes  may  also  be  used  at  a  secondary  level.  For  the  digital  public  procurement 
communication, the use of CPVs is an efficient and user-friendly way to identify and describe work, goods or 
service  that  are  being  a  subject  of  the  acquisition.  Consequently,  it  is  worthwhile  to  check  how  products 
included in the scope of EU Ecolabel criteria sit within the hierarchy of CPV codes as established by Regulation 
(EC) No 213/200810.  

The CPV codes consist of a main vocabulary and a supplementary vocabulary. The main vocabulary is based 
on  a  tree  structure  comprising  codes  of  up  to  nine  digits  associated  with  a  wording  that  describes  the 

10  See:  Commission  Regulation  (EC)  No  213/2008  of  28  November  2007  amending  Regulation  (EC)  No  2195/2002  of  the  European 
Parliament  and  of  the  Council  on  the  Common  Procurement  Vocabulary  (CPV)  and  Directives  2004/17/EC  and  2004/18/EC  of  the 
European Parliament and of the Council on public procurement procedures, as regards the revision of the CPV. OJ L 74, 15.3.2008, p. 1
375 

14 

 
                                                        
 
supplies, works or services forming the subject matter of the contract. Furthermore, the numerical code has 8 
digits, subdivided as follows: 

 
 
 
 

the first two digits identify the divisions (XX000000-Y), 
the first three digits identify the groups (XXX00000-Y), 
the first four digits identify the classes (XXXX0000-Y), 
the first five digits identify the categories (XXXXX000-Y). 

Each  of  the  last  three  digits  gives  a  greater  degree  of  precision  within  each  category,  while  a  ninth  digit 
serves to verify the previous digits. The goods codes contain parts or combinations of information, such as the 
main name of a product and its type, and sometimes other details. 

the 

identification 

The  higher-level  codes  encompass  a  broad  range  of  products  and  therefore  the  use  of  more  detailed  CPV 
codes  could  streamline  the  product  identification.  The 
supplementary vocabulary may be used as an aid to further 
detail  the  contract  subject  matter.  For  supplementary 
vocabulary, 
is  made  up  of  an 
alphanumeric  code  with  a  corresponding  wording  allowing 
further details to be added regarding the specific nature or 
destination of the goods to be purchased. This comprehends 
two  letters  (the  first  defines  the  section  such  as  products,  the  second  defines  the  group),  followed  by  two 
digits  that  define  attributes,  and  a  check  digit,  for  example,  the  procurement  entity  interested  in  buying 
ecolabelled  disposable  diapers  for  babies  will  choose:  33751000-9  Disposable  nappies,  CA57-1  Ecolabel, 
EA01-5 For babies (EC, 2008). Table 1 outlines a selection of CPV codes that are considered as particularly 
relevant to absorbent hygiene products. 

For more information on how to appropriately use 
the standard codes, see: Guide to the Common 
Procurement Vocabulary 

The  use  of  the  CPV  is  mandatory  in  the  European 
Union as from 1 February 2006. 

Table 1. Relevant CPV codes that could involve EU Ecolabel absorbent hygiene products 

High level 

Medium level 

Detailed level 

Division 33: CVP 33000000-0 Medical equipment, pharmaceuticals and personal care products 

CVP 
33700000-7 
Personal  care 
products 

CVP 33750000-2 Baby care products 

CVP 33751000-9 Disposable nappies 

CVP 33752000-6 Nursing pads 

CVP 33771000-5 Sanitary paper products 

CVP 33770000-8 Paper sanitary 

           CVP 33771100-6 Sanitary towels or tampons 

           CVP 33771200-7 Paper napkin liners  

CVP 33772000-2 Disposable paper products* 

Division 85: 85000000-9 Health and social work services  

85100000-0 
Health 
services 

CVP 85142000-6 Paramedical 
services 

CVP 85142400-0 Home delivery of incontinence 
products 

*Not considered for the further analysis as representing a miscellaneous group of disposable paper products for sanitary or hygiene use. 

Source: EC, 2008. 

Table  1  shows  that  the  absorbent  hygiene  products  belong  to  Division  33  (CVP  33000000-0)  Medical 
equipment,  pharmaceuticals  and  personal  care  products,  sub-divisions  of  personal  care  products,  further 
segmented into baby care products and paper sanitary. The Division 33 does not acknowledge a specific sub-
category for the incontinence product.  A  home delivery service of incontinence  products pertains to Division 
85: Health and social work services, sub-division CVP 85142000-6 Paramedical services, further segmented 
into CVP 85142400-0 Home delivery of incontinence products. 

The disposable paper products [of paper sanitary sub-division] will represent a miscellaneous group of paper 
products  for  sanitary  or  hygiene  use  such  as  paper  cups,  disposable  paper  plates,  paper  bad  linings,  tissue 
paper  products,  etc.  Indeed,  some  AHPs  might  theoretically  be  allocated  to  this  group.  However,  due  to  the 

15 

 
 
 
       
 
abundance of products that can be classified as disposable paper products, this product category is not taken 
into account for further analysis.  

All in all, the list of CPV codes above (Table 1) is not an exhaustive and only includes the most relevant ones 
or these found on the Tenders Electronic Daily (TED) Platform to be commonly used for the procurement of 
the AHPs acquisition.  

2.2  Market analysis 

This section provides an overview of the European market for absorbent hygiene products and its trends on a 
quantitative and qualitative level for the  different categories of absorbent  hygiene products. The PRODCOM 
categories describing AHPs provide highly aggregated information. Unless otherwise stated, the Euromonitor 
International  data  (Euromonitor  International,  2021)  was  primarily  used  to  gain  insight  into  AHPs  market 
segmentation and product distribution across Europe.   

The  PRODCOM  codes  do  not  correspond  directly  to  the  CPV  codes  described  in  Table  2.  The  correlation 
between CPV and product-related PRODCOM codes is shown below in an approximate manner.  

Table 2. Comparison of CPV and PRODCOM codes and a description of absorbent hygiene products that have relevance to 
the EU Ecolabel 

CPV 

PRODCOM 

33750000-2 Baby care products 

17.22 Manufacture of household and sanitary goods and of toilet requisites 

  33751000-9  Disposable 

nappies 

  33752000-6 Nursing pad 

17.22.12 Sanitary towels and tampons, napkins and napkin liners for babies 
and similar sanitary articles and articles of apparel and clothing accessories, 
of paper pulp, paper, cellulose wadding or webs of cellulose fibres  

33770000-8 Paper sanitary 

  33771000-5 

Sanitary 

paper products 

  33771100-6 

Sanitary 

towels or tampons 

  33771200-7 
napkin liners  

Paper 

85142000-6 Paramedical services 

  85142400-0 
delivery  of 
products 

Home 
incontinence 

  17.22.12.10  Sanitary  towels  (pads)  and  tampons,  napkins 
(diapers),  napkin  liners  and  similar  sanitary  articles,  of 
wadding 

  17.22.12.20  Sanitary  towels  (pads),  tampons  and  similar 
articles  of  paper  pulp,  paper,  cellulose  wadding  or  webs  of 
cellulose fibres 

  17.22.12.30  Napkins  (diapers)  and  napkin  liners  and  similar 
sanitary  articles  of  paper  pulp,  paper,  cellulose  wadding  or 
webs  of  cellulose  fibres,  (excluding  toilet  paper,  sanitary 
towels, tampons and similar articles)  

  17.22.12.90 Household, sanitary or hospital articles of paper, 

etc., n.e.c. 

Source: EUROSTAT and EC, 2008. 

PRODCOM  Code  17.22.12.90  (Household,  sanitary  or  hospital  articles  of  paper,  etc.,  n.e.c.)  may  or  may  not 
include  AHPs,  and  due  to  the  high  degree  of  aggregation,  a  large  number  of  products  may  fall  under  this 
category. As a result, it is not included in the market analysis in this section. 

Total sold production value and volume in the EU in 2022 

The data for selected PRODCOM codes (Table 2) were extracted from EUROSTAT and analysed using various 
indicators  to  provide  a  comprehensive  overview  of  the  AHP's  European  market  performance.  To  this  end, 
Table 3 includes estimations of production, export, import, and apparent consumption in monetary and unit 
values for selected absorbent hygiene product categories in 2022 [Numbers in bracket informs about %share].   

Based  on  PRODCOM's  statistical  data,  the  total  production  value  of  absorbent  hygiene  products  for  the 
selected categories in 2022 is about 7 billion euros, which corresponds to about 3 billion kg (2.3 EUR per kg 
mass unit). According to Euromonitor International's disaggregated market data, the total EU market share for 
absorbent hygiene products under the EU Ecolabel in 2020 amounts to EUR 6 billion in the EU-27 and the UK 

16 

 
 
 
(EUR  3.5  billion  for  baby  diapers  and  EUR  2.5  billion  for  feminine  hygiene  products)  (Euromonitor 
International, 2021). 

Among  the  selected  product  categories,  napkins  and  similar  products  made  of  cellulose  fibres  (PRODCOM 
17.22.12.30)  dominate  the  market  share  for  production  (76%  for  value  and  83.8%  for  volume)  and  for an 
apparent consumption (80%). The product also has the highest share of import and export value and quantity. 
Sanitary  towels,  tampons  and  the  like  (PRODCOM  17.22.12.20)  accounted  for  around  18,4%  of  the  total 
production value and 12.4% of the total production volume, which corresponds to a share of around 12% of 
apparent  consumption  and  a  price  of  EUR  3.4  per  mass  unit.  For  all  product  categories,  exports  exceed 
imports. 

Table 3. Estimation of production, export, import and apparent consumption in monetary and unit value for absorbent 
hygiene products in 2022 

PRODCOM codes 

17.22.12.10 

17.22.12.20 

17.22.12.30 

Short 
description 

Sanitary towels, 
tampons, napkins and 
the like 

Sanitary towels, tampons 
and the like made of 
cellulose fibres 

Napkins and napkin 
liners for babies and the 
like 

PRODVAL 
[m EURO] 

PRODQNT 
[MT] 

IMPVAL 
[m EURO] 

IMPQNT 
[MT] 

EXPVAL 
[m EURO] 

EXPQNT 
[MT] 

404.56 
(5.7%) 

120.33 
(3.9%) 

11.06 
(3.3%) 

1.58 
(2.1%) 

86.23 
(3.5%) 

9.38 
(1.7%) 

1314.37 
(18.4%) 

385.49 
(12.4%) 

118.16 
(35.6%) 

20.07 
(26.8%) 

789.94 
(32.1%) 

82.19 
(15.3%) 

329.39 
(6.6%) 

642.58 
(12.8%) 

Apparent 
consumption 
[m EURO] 
Apparent 
consumption 
[MT] 
Where:  
PRODVAL means the value of sold 
production 
PRODQNT means the quantity of sold 
production 
Apparent consumption means a value of (sold production + imports)   export 

EXPVAL means the value of export 
EXPQNT means the quantity of 
export 

323.37 
(12.2%) 

112.54 
(4.2%) 

5432.36 
(76.0%) 

2609.41 
(83.8%) 

203.02 
(61.1%) 

53.11 
(71.0%) 

1582.25 
(64.4%) 

447.36 
(83.0%) 

4053.12 
(80.7%) 

2215.17 
(83.6%) 

Total 

7151.28 
(100,0%) 

3115.24 
(100.0%) 

332.24 
(100.0%) 

74.77 
(100.0%) 

2458.43 
(100.0%) 

538.93 
(100.0%) 

5025.10 
(100.0%) 

2651.07 
(100.0%) 

IMPVAL means the value of import 
IMPQNT means the quantity of 
import 

Source: EUROSTAT 

Historical trends in sold production and apparent consumption value in the EU from 2010 to 2022. 

Figure 5 shows the development of the market trends between 2010 and 2022, when the production value 
sold  for  sanitary  towels  and  the  like  increased  by  25%  and  sanitary  towels,  tampons  and  the  like  by  77% 
(both PRODCOM categories counted together).  

The AHPs market share is dominated by baby diapers, but it is also possible to observe the steady growth in 
the sales production value of the feminine care products (PRODCOM code 17.22.12.10 and 17.22.12.20). The 
apparent consumption of napkins closely follows the fluctuation of sold production value, which may indicate 
the dominant intra-European consumption of the stock. Due to an increase in production value and apparent 
consumption during the same period, this correlation becomes particularly noticeable in 2017 and 2022.    

17 

 
 
 
 
According to AHPs suppliers, most imported AHPs comes from North Africa or the Middle East. The Middle East 
is most likely also the recipient of exported AHPs. Pérez-Camacho (2023) indicates that the European region is 
a net exporter of menstrual products such as sanitary towels and the majority of baby nappies used in the EU 
are  manufactured  in  Europe.  However,  it  must  be  taken  into  account  that  some  of  the  resources  used  to 
manufacture  these  products  come  from  outside  Europe  (Cabrera  and  Garcia,  2019,  Faraca  et  al.,  2023). 
According  to  the  manufacturers  of  fluff  pulp,  90%  of  the  production  of  this  material  takes  place  in  North 
America, with an average transport distance of 2 000 km from Europe (Mendoza et al., 2019). 

Figure 5. Sold production value and apparent consumption per PRODCOM product code between 2010 and 2022 

Source: JRC own elaboration based on EUROSTAT. 

Sales volume in Europe per product type and country  

Pérez-Camacho  (2023)  provides  an  overview  of  the  sales  volume  of  absorbent  hygiene  products  on  the 
European market, based on the product segment and country. 

Figure 6. Countries with the highest share of sales of selected absorbent hygiene products   Top 5 

Source: JRC own elaboration based on Euromonitor International: Tissue and Hygiene industry edition 2021. 

18 

 
 
 
 
In 2020, total sales of AHPs in Europe amounts to just over EUR 6 billion, which corresponds to a volume of 
around  59  billion  units.  The  majority  of  sales  volume  is  represented  by  baby  nappies  (almost  60%),  with 
sanitary towels (almost 25%) and panty liners (almost 10%) following closely behind. Tampons account for 
less than 9% of total sales (Euromonitor International, 2021). Figure 6 displays the percentage market share 
for the selected absorbent hygiene products across the countries with the highest sales. The sales figures are 
closely related to the population of the respective Member State. Regardless of which country is analysed, the 
difference  between  the  share  of  population  in  the  EU-27  (and  the  UK)  and  the  total  share  of  AHP  sales  in 
2020 is never greater than 2%. This proves the strong correlation with the population size and therefore the 
demand for feminine hygiene products, newborns and/or incontinence in the elderly.   

Potential and real-life examples of procurement exercises 

The procurer might use the real-life good practice examples as an aid to identify the elements of tendering 

Consequently,  this  section  aims  to  review  good  practice  case  studies  available  on  the  DG  Environment 
website11, the TED platform12, and identified in the relevant literature (UNEP, 2022)  

Consistent  implementation  of  such  measures  will  reap  the  full  potential  of  public  procurement.  Embedding 
green  purchase  into  procedures  or  criteria  encourages  innovation,  supply  chain  traceability  and  resources 
management  while  shaping  a  sustainable  transformation  at  the  production  and  consumption  level.  More 
practical  information  about  the  best  practice  in  Green  Public  Procurement  might  be  found  in  dedicated 
brochure.13  

Some  real-life  examples  of  GPP  criteria  for  the  absorbent  hygiene  products  with  some  specific  details  are 
summarised  in  Table  4.  Most  of  the  case  studies  from  the  table  address  a  long-term  and  rather  generic 
strategy  for  the  implementation  of  sustainable  procurement  goals  for  city  or  region.  Only  a  very  limited 
number of relevant tenders, and fewer criteria, were focused specifically on absorbent hygiene products. 

The  limited  number  of  the  examples  is  a  natural  outcome  when  considering  that  EU  GPP  criteria  have  not 
been  specifically  developed  for  this  product  group.  The  authors  view  the  limited  number  of  specific  case 

AHPs,  2)  gain  a  better  understanding  of  sustainability  opportunities  in  the  green  acquisition  of  AHPs,  3) 
provide practical guidance for innovation practise for AHPs, and 4) stimulate further reflection on the practical 
implementation of the GPP recommendations placed in this document.  

Procuring 
authority 

Across 
Member 
States 

Paris-
Saclay 
University 

(FR) 

Table 4. Summaries of real-life procurement exercises 

Subject matter of contract 

Relevant green requirements for absorbent hygiene 
products 

EMAS and the Healthcare Sector 
149 organizations in the healthcare field have 
successfully implemented and received EMAS 
registration. 

to 

Provision  of 
reusable 
free  access 
menstrual products for students in precarious 
financial situations.   
The  Diversity  and  Equal  Opportunity  unit 
identified 5.000 potential beneficiaries among 
30.000 students. 

No direct requirements 

All  sustainable  development  and  social  responsibility 
criteria  are  weighted  at  10%  or  15%  and  composed  of 
sub-criteria: 

1-  Applied  measures  in  terms  of  professional  integration 
of people in difficulty (10 or 5 points) 

2 - Applied measures in terms of environmental protection 
(5 points). 

Government 
of Ireland 

Framework  agreement  of  EUR  814.000  to 
take action against period poverty.  

The  agreement  includes  a  number  of  key  green  and 
sustainability  elements,  re-usable  and  more  sustainable 

11 See: https://ec.europa.eu/environment/gpp/case_group_en.htm  
12 See: https://ted.europa.eu/TED/main/HomePage.do?lg=en 
13 See: https://ec.europa.eu/environment/gpp/pdf/GPP_Good_Practices_Brochure.pdf 

19 

 
 
 
 
                                                        
 
Procuring 
authority 

(Ministers of 
State 
Naughton 
and Smyth, 
2023)14 

City of 
Stavanger 
(NO) 

Subject matter of contract 

The agreement contains four lots dedicated to 
period  equality  (menstrual)  products,  which 
include: 

Relevant green requirements for absorbent hygiene 
products 

disposable  product  options  are  included  in  the  range  of 
period products available to order. 

-cost dispensers 

Personal care medical consumables are listed 
among other products.  
The  framework  agreement  contract  lasts  for 
two years and can be extended for up to four 
years. 
The  medical 
consumable  market  was 
sufficiently developed to meet both the social 
and  green  criteria  outlined  in  the  tender 
documents.  

The SPP procurement process incorporates environmental, 
social, and governance (ESG) requirements.  
Green criteria:  
To  meet  selection  criteria,  tenderers  must  possess  an 
ISO 
environmental  management  system  that  meets 
14001, EMAS, or any equivalent, like the Norwegian 'Eco-
Lighthouse' certification scheme. 
Technical specifications: 

1. Mandatory use of environmentally friendly products e.g., 
by referring to products with an environmental label. 
2. For packaging   mandatory take-back scheme [to collect 
used products or materials from consumers and reprocess 
them to manufacturing cycle] during the agreement period 
proved by a membership in a return scheme such as Grønt 
Punkt  Norge  AS  or  equivalent,  or  by  operating  the  own 
scheme for packaging processing.  

Award criteria: 
The  contract  was  given  away  based  on  both  price  (40% 
factors,  such  as 
weight)  and  other  sustainability 
social 
(30%  weight)  and 
environmental 
responsibility criteria ("ethical trade") (30% weight). 
Green award criteria focus on transport emissions:  

criteria 

   Using  vehicles  that  are  either  zero-
emission  or  fossil-free  for  the  main 
delivery (weighted 90%). 

   Urgent deliveries require vehicles that 
are both zero-emission and fossil-free 
(weighted 10%).  

Green  requirements  focused  on  the  choice  of  materials, 
logistics and waste management. 
To ensure due diligence of social aspects, it is necessary to 
have at least a basic ethical approach to track and assess 
risks  for  worker  and  human  rights  abuses  throughout  the 
supply chain.  

Province of 
Zeeland 
(NL) 

Sustainable procurement plan for 2021-2024 
from  the  Province  of  Zeeland:  Using  the 
Sustainable Development Goals as a guide. 

No direct requirements   GPP guideline 
The  guide  for  implementing  and  monitoring  Sustainable 
Development Goals (SDGs).  

Each  procurement  made  by  the  Province  of 
Zeeland  during  the  period  2021-2024  will 
contribute to the SDGs targets and be shared 
on the Sustainable Procurement Platform 

Cyprus 
University of 
Technology 
(CY) 

Environmental  Policy  Office  responsible  for 
GPP  implementation  across  the  university 
with  the  objective  to  transform  procurement 
and related procedures into more sustainable 
activities 
increased 
environmental  consciousness  amongst  the 
university community.  

cultivate 

and 

No  direct  requirements  -  example  relevant  for  the 
management of green purchases by an entity.  
The  University's  Green  Public  Procurement  Consulting 
Committee 
spectrum  of 
representatives,  from  academics  to  administration  staff. 
This  committee  is  responsible  for  providing  input  on 
environmental aspects in the highest value tenders.  

consists  of  a 

(GPPCC) 

14 See: Department of Public Expenditure, NDP Delivery and Reform, Nov, 2023, available at: https://www.gov.ie/en/press-release/adbc1-
ministers-of-state-naughton-smyth-publish-framework-agreement-that-allows-the-public-sector-to-easily-purchase-period-products/ 

20 

 
 
 
 
 
 
 
 
 
                                                        
 
Procuring 
authority 

Basque 
Government 
(ES) 

Subject matter of contract 

Relevant green requirements for absorbent hygiene 
products 

The  greening  of  public  tendering  procedures, 
which  includes  green  criteria,  will  involve  at 
least 50% public procurement of over 20% of 
tenders by 2020 for over 20 priority groups. 

No direct requirements. 

Veneto 
Region (IT) 

Ensuring  that  public  buyers  in  the  region  are 
committed to GPP 

Sardinia (IT) 

the  GPP  practice  among  all  public  entities  in 
the  region  and  achieve  the  adoption  of  GPP 
policies  by  all  provincial  governments  and 
park  authorities,  in  50%  of 
municipalities,  and  in  30%  of  all other  public 
bodies by 2013. 

No direct requirements  
GPP  training  programs  and  knowledge  sharing.  Suppliers 
are  engaged  in  the  whole  process  -  market  analysis  and 
in-depth study of the criteria to be included in tenders. 

No direct requirements 
All tenders for goods/services published for the day-to-day 
operation  of  the  regional  administration  must  include 
minimum GPP criteria. 

Source: DG Environment  

Based on the random screening of tenders available on the TED platform, the AHPs procurement foremostly 
satisfies the needs of health care providers i.e., public institutions caring of sick, frail, disable, or aged persons 
such as hospitals, clinics, care centres, or alike public administration bodies including public home care service. 
  care 
facilities, and or any other public establishment, which might require the provision of the menstrual products 

 for example - 

The  distribution  of  the  free  absorbent  period  products  might  also  form  part  of  a  dedicated  governmental 
campaign  [ethical or social procurement often in  co-operation with non-governmental  organisations] to take 
action against period poverty or/and to facilitate equal rights and ensure dignity to access menstrual products, 
or  else  in  case  of  natural  disasters  (Jaafar  et  al.  2023,  Scotland  Act  2021 15,  Paris-Saclay  University, 
Government of Ireland, UNICEF16). Indeed, public poverty is a growing concern as it is estimated that currently, 
1  in  10  menstruating  females  cannot  afford  sanitary  products.  The  French  Institute  for  Public  Opinion 
assessed  that  period  poverty  affects  1.7  million  women  in  France.  The  healthy  Ireland  Survey  2022  found 
that 24% of woman (and 35% of 15 24-year-old) have experienced at least one indicator of period poverty, 
whereas 6% reported issues with the affordability of wider hygiene products17.  

Absorbent hygiene products represent goods of a common and recurrent use. For a domestic use, these are 
purchased  individually  off  the  shelf  in  small  quantities.  By  contrast,  the  acquisition  by  state  administration 
will  most  likely  bunch  absorbent  hygiene    products  into  lots  embedded  into  extensive  framework  [or 
centralised]  contracts  that  accommodate  the  purchase  of  a  vast  range  of  products  (ofte
contracts). Based on lessons learnt from the real-life examples, the centralised procurement provides goods 
and services at more competitive prices, as well as streamlines the administrative procedures.  

-

In case of health care sector, the governing body [hospital public procurement administration] will most likely 
collect the purchase requests across the entities (or sub-entities). In practice, one centralised contract might 
procure  a  numerous  AHPs  lots  [with  different  or  equal  performance  characteristics]  as  requested  by  an 
individual  sub-entity.  Under  this  scenario,  the  quasi-decentralised  institutional  structure  specifies  demand, 
whereas  a  centralised  governance  manages  the  procurement  process  [centralised  budgeting].  While  the 
requesting  body  will  most  likely  focus  on  the  performance  criteria  [without  detailing  how  it  needs  to  be 
acquired],  the  implementation  of  green  requirements  will  rely  on  the  centralised  governance  [that  manages 
spendings and supervise the administrative procedure]. This procurement model accommodates specific needs 

products. However, the methodological organisation will require a strategic co-operation across the entity. To 
bring  expected  results,  the  planning  phase  must  be  supported  by  a  collaborative  knowledge  and  capacity 

-size-fits-

15 See: https://www.gov.scot/policies/poverty-and-social-justice/access-to-free-period-products/ 
16 See:  https://www.unicef.org/wash/menstrual-hygiene 
17See:https://www.gov.ie/en/press-release/adbc1-ministers-of-state-naughton-smyth-publish-framework-agreement-that-allows-the-
public-sector-to-easily-purchase-period-products/ 

21 

 
 
 
 
                                                        
 
sharing  across  all  involved  departments,  institute  or  any  other,  from  the  preliminary  assessment  to  the 

work together and combine forces.  

Participation  of  all  actors  involved  (supply  and  demand  side)  remains  crucial  to  ensure  comprehensive 
implementation of sustainable consumption and production patterns. As with any green criteria that are not 
widely used across the market, it is necessary to increase awareness of them amongst procurers and in turn, 
to specify and explain expectations for the product performance to potential bidders. As previously mentioned, 
market  engagement  prior  to  calls  for  tender  being  published,  and/or  active  dialogue  on  expected  criteria 
during negotiation triggers the market and enhance the efficiency of the green acquisition procedure. The best 
practice  examples  always  stress  the  need  to  engage  with  the  market  prior  to  setting  green  criteria  as 
generating more complete knowledge of the market performance will provide a  better understanding about 
potential sustainability opportunities and trade-offs.   

Search of Tender Electronic Daily (TED) for relevant procurement tenders 

TED is the online version of the 'Supplement to the Official Journal' of the EU, dedicated to European public 
procurement. TED publishes 735 000 procurement notices a year, including 258 000 calls for tenders which 
es for service and supplies that exceed the minimum 

140 000 EUR threshold must be published online on the TED platform18.  

This section displays the results of TED searches by business sector i.e., CVP codes that are associated with 
 light 
absorbent hygiene produc

codes (see: Table 1) from 01/01/2015 to 31/10/2023. 

Figure 7. Trends in relevant contract notices published on TED for absorbent hygiene products and materials (data until 
October 31, 2023) 

Source: Own elaboration based on Tenders Electronic Daily (TED). 

The robustness of the statistical analysis of data subtracted from TED is largely dependent on the procurer's 
accuracy in assigning CVP(s) to a product type. After considering the way the CPV codes are defined, it is clear 
that  any  analysis  looking  at  public  contracts  for  products  and  service  will  not  distinguish  in  detail  between 
different  types  of  the  AHPs  as addressed  by  EU  Ecolabel  scope  (and  detailed  by  Faraca  et  al.,  2023).  As  a 

18 See: https://ted.europa.eu/TED/main/HomePage.do?lg=en  

22 

 
 
 
                                                        
 
result, the authors suggest that this section should be taken as an indication or added value to describe how 
the public administration is procuring absorbent hygiene products.  

 displays  a  collection  of  different  CPV  codes  in  single  columns  for  each  year,  with  baby  care  products  in 
different  shades  of  green,  the  sanitary  paper  products  in  different  shades  of  blue,  and  home  delivery  of 
incontinence products in yellow.  

A  contract  notices  for  medium  level  CVP  e.g.,  baby  diapers,  might  aggregate  contracts  from  the  lower  CVP 
codes  levels.  To  avoid  double  counting19  Figure  8  subtracts  the  number  of  detailed  (or  lower  level)  CVPs 
notices from the total number of notices for the related medium CVP category (highlighted by the patterned 
areas).  

For the selected CVP codes, a total of 4142 contracts appeared in the search for the period 2015 to October 
2023. For all  AHPs-related CVPs, the total  number of TED  -  published notices were in the  region of  130 to 
117 per year from 2015 to 2018, and in the quasi-constant region of 260 from 2019 to 2022. The sudden 
increase  in  the  procurement  of  absorbent  hygiene  products  starting  in  2019  in  particular  for  disposable 
nappies  [incontinence  products  for  adults  are  often  ascribed  to  this  CVP  code]  might  acknowledge  the 
beginning of the COVID outbreak and ther
years 2020 - 2022. Additionally, this might also be attributed to the expected rise in birth rates [for example, 
precautionary  storage  of  products]  so  called  post-COVID  baby-boom20  coupled  by  national  measures  to 
mitigate  a  falling  number  of  newborns  across  Member  States.  The  COVID  outbreak  might  also  explain  the 
increase  in  public  purchase  of  liner  napkins,  tampons  and  sanitary  towels  [higher  number  of  hospitalised 
female patience] in 2019.  

During  2015 
  October  2023,  baby  care  products  (disposable  diapers)  notices  make  the  highest  number 
among the three main CVPs divisions, followed by sanitary paper products. The type of contract is primarily 
focused  on  product  supply,  whereas  service  contracts  make  up  less  than  1%  of  all  notices.  However,  the 
separate  calculation  for  each  CVP  indicates  that  service-related  activities  include  34%  of  contracts  for  the 
supply and  provision of  continence delivery, i.e., home  delivery of incontinence products  (CVP 85142400-0), 
and  5%  for  sanitary  paper  products  (CVP  33771000-5).  For  incontinence  products,  these  may  be  delivered 

Additionally, as already  mentioned the distribution of the  free absorbent  period product might form part of 
dedicated  governmental  campaigns.  Figure  8  illustrates  the  distribution  of  the  procurement  of  absorbent 
hygiene products across different governmental bodies between 2015 and October 2023. The contracts have 
been mainly executed by the regional authority (33%) and bodies governed by public law (30%). 

Figure 8. Procurement of the absorbent hygiene products-related CVP codes across different governmental bodies 
between 2015 and Oct 31, 2023 

Source: JRC own elaboration based on Tenders Electronic Daily (TED). 

19 The superior [medium level] CVP divisions comprises baby care products (further classified as disposable diapers and nursing  pads), 
and sanitary paper products (further structured into paper napkin liners and sanitary towels and tampons) 
20 Contrary  to  some  initial  expectations,  the  coronavirus  pandemic  did  not  bring  a  lasting  baby  bust.  The  Nordic  countries,  the 
Netherlands,  Germany,  and  the  United  States  experienced  an  improvement  in  their  birth  dynamics  in  2021  compared  with  the 
  see:  Sobotka  et  al.  2023.  Pandemic  Roller-Coaster?  Birth  Trends  in  Higher-Income  Countries  During  the COVID-19 

Pandemic. Population and Development Review. https://doi.org/10.1111/padr.12544 

23 

 
 
 
 
 
 
                                                        
 
Random checks of the contract notices consistently showed that the appearance of the CPV codes identified 
as  being  most  relevant  to  absorbent  hygiene  products  were  relatively  minor  parts  of  broader  procurement 
exercises  such  as  framework  contracts  for  the  material  supply  with  around  30-50  lots  i.e.,  a  bunch  of 
distinctive  AHPs distributed across  different lots  within the same contract notice. Some framework contract 
notices  represented  a  centralised  approach,  for  instance,  centrally  (or  regionally)  procured  framework 
contracts when the contracting authority is purchasing on behalf of other contracting authorities or when the 
purchase  proceeds  under  the  joint  tender  between  different  entities  such  as  hospitals  in  the  same  city  or 

the  Framework  during  the  defined  period  of  time  (usually  between  12  and  24  months)  without  additional 
procurement cycle(s). Unfortunately, the high aggregation of AHPs into multiple lots under one contract limits 
the possibility to perform precise monetary analysis per products-relevant lots. This would best be performed 
case-by-case for each contract notice and lots within. 

While screening the contract notices on the TED Platform, the authors observed the following chief similarities 
related to: 

-

1. 

2. 

3. 

Incontinence  products 
  The  authors  have  not  identified  any  CVP  code  which  is  specific  to  the 
incontinence  products,  these  are  usually  identified  as  personal  care  products  (CVP  33700000-7)  or 
baby  care products (33750000-2) or  disposable nappies  (CVP  33751000-9) 
  which in the authors´ 
opinion is a comprehensive assignation. However, we also noticed a considerable lack of uniformity in 
how  the  incontinence  product  is  CVP-assigned,  for  example,  as  disposable  non-chemical  medical 
consumables  and  haematological  consumables  (CVPs  33141000),  or  panties  (CVP  18313000),  or 
dressings  (CVP  33141110),  among  others.  Still,  for  the  searching  criteria  used,  the  contract  notices 
always mentioned  personal  care  products  under  additional  CVP  code.  The  supplementary  vocabulary, 
such as EA04-4 ´For men´, EA05-7 ´For elderly person´, or EA06-0 ´For women´ could bring about 
more specific description of the incontinence products (EC, 2008). 

Automatic  dispensers  of  sanitary  products  -  Public  education  bodies  or  public  administration  offices 
use  a  generic  CVP  33771000-5  (Sanitary  paper  products)  code  for  the  purchase  of  wall  mounted 
vending machines and regular servicing to maintain stock levels and address any faults.  

Award criteria 
 Price dominates the award  criteria (weighting between 40 to 100% across  screened 
contract notices), followed by quality and delivery time. We also identified several GPP criteria, such as: 
CO2 compensation, totally chlorine free (TCF) pulp, or environmental management system in place. 

Availability of EU Ecolabel products on the market 

Given that this report relies on EU Ecolabel criteria to build GPP recommendations, by outlining the availability 
of  [EU  Ecolabel]  licensed  absorbent  hygiene  products,  we  can  roughly  estimate  the  current  market 
performance.  

In  September  2023  there  were  591  EU  Ecolabel  absorbent  hygiene  products  covered  by  19  licenses.  The 
numbers of licenses will always be considerably less than the number of licensed products. One license must 
be associated with at least one licensed product, and potentially hundreds or thousands of products may be 
grouped under the same license.   

The current EU Ecolabel criteria laid down in Decision (EU) 2023/1809 of 14 September 2023 are the second 
adopted  version  of  EU  Ecolabel  criteria  for  the  absorbent  hygiene  products.  The  statistical  assessment  has 
been performed until September 2023, for this reason  Error! Reference source not found. only refers to the 
uptake  of  products  verified  against  the  former  criteria  document  i.e.,  Commission  Decision  2014/763/EU  - 
valid until 31 December 2023.  

24 

 
Figure 9. Trends in EU Ecolabel licenses and licensed absorbent hygiene products over the last 8 years 

Source: JRC own elaboration from DG Environment. 

As  of  September  2023  (Figure  10),  the  major  number  of  EU  Ecolabel  absorbent  hygiene  products  can  be 
found  in  the  Czech  Republic  (197  products  under  1  license),  followed  by  Sweden  (181  products  under  2 
licenses), Denmark (57 products under 6 licenses), and France (53 products under 1 license). More information 
about the current licenses can be found in the EU Ecolabel catalogue.  

Figure 10. Distribution of EU ecolabelled products across Member States 

Source: JRC own adaptation from DG Environment. 

25 

 
 
 
 
 
 
2.3  Environmental hotspots 

Absorbent hygiene products are designed to wick moisture away from the body and prevent potential leakage 
by using a moisture-repellent cover. All this while maintaining softness, breathability and skin-friendly (health 
and  comfort)  properties.  Absorbent  hygiene  products  are  products  for  personal  use  that  are  in  constant 
demand  worldwide  because  [probably]  everyone  uses  them  at  different  stages  of  their  life,  either  for 
incontinence as newborns or adults and/or for female menstrual hygiene.  

Product Layer 

Upper layer  
(top sheet) 

Acquisition and 
optional 
distribution layer 

Absorbent core 
layer 

Bottom layer 

Table 5. Raw materials for possible use in multi-layered absorbent hygiene products 

Material 

Function 

 

 
 

 
 

 
 

 

 
 
 
 
 

 
 

 
 

 
 
 
 

polymers 
such  as 

Propylene  (PP),  Polyethylene  (PE), 
Polystyrene (PS), PP/PE 
Biobased polymers 
Cellulose-based fibre e.g., viscose 
(rayon) 
Cotton 
Propylene  (PP),  Polyethylene  (PE), 
Polystyrene (PS),  
Fluff pulp   cellulose fibre 
Petroleum  or  biobased  super 
(SAPs) 
absorbent 
granulates 
sodium 
polyacrylate  
Nonwoven e.g., PE (for an optional 
distribution layer) 
Cotton 
Fluff pulp  
Cotton 
Protein fibres 
Petroleum  or  biobased  super 
absorbent 
(SAPs) 
granulates  
PP and/or PE, PS and copolymers 
PLA  combined  with  polyolefin 
resins  
Biobased PE and/or PP 
Waterproof 
or 
polypropylene film laminated with 
polypropylene non-woven 
Biobased polymers 
Adhesives (for feminine pads) 
Silicone paper  
Velcro straps 

polyethylene 

polymers 

Skin contact and comfort 
Hydrophilic layer used to keep skin dry 
and quickly transfer fluids to the 
absorbent core with a minimal rewet. 

To temporarily retain the body fluids 
and help to move it away from the 
body contact while evenly distributing 
the liquid in the area. 

To absorb and retain fluids. Generally, 
it consists of cellulose fibres blended 
with super absorbent polymer (SAP).  

External layer. A microporous barrier 
that prevents leakage. 
Adhesives help to attach sanitary 
towels to underwear or use of touch 
fasteners (e.g. Velcro scraps) helps to 
fix it (stay-in place) around the body.  

Source: JRC own elaboration. 

Tampons  are  usually  made  of  a  limited  number  of  materials  such  as  rayon  blended  with  cotton  fibres  or 
exclusively cotton (organic or non-organic (AHPMA, 2021)) covered with a thin layer of non-woven fabric or 
perforated film to reduce the loss of fibres and makes the tampon easy to insert and remove once used. The 
retrieval string necessary to remove the tampon is typically composed of cotton or other fibres and may be 
coloured (Ajmeri and Ajmeri, 2011).  

Disposable  AHPs  other  than  tampons  are  complex  multi-layer  products  where  each  layer  serves  a  distinct 
purpose.  The  incontinence  products  for  babies  and  the  elderly,  as  well  as  the  sanitary  towels,  have  many 
 mainly a combination of synthetic 
similarities in terms of functional design and the type of materials used 

26 

 
 
 
materials (petroleum or biobased) and natural-based fibres such as cotton or wood. The final product consists 
of a top layer, an absorbent core layer (including an absorption and distribution layer) and a bottom layer.  

Nursing  pads  are  also  multi-layered  products  consisting  of  an  inner,  liquid-permeable  layer,  followed  by  a 
normal absorbent layer of fluff pulp. This is followed by a layer consisting partly of a superabsorbent. Outside 
this layer there may be another layer of cellulose, and the outermost layer is a layer of liquid-impermeable 
material21.   

Table 5 presents the indicative range of raw materials that could be found in absorbent hygiene products.  

Pérez-Camacho et al. (2023), using the Product Environmental Footprint (PEF)22 methodology, conducted an 
LCA  study  to  evaluate  the  environmental  impacts  of  average  disposable  baby  diapers  and  sanitary  towels. 
Furthermore,  the  authors  conducted  a  comprehensive  review  of  the  available  LCA  literature,  material 
innovations and best practices that were relevant to the absorbent hygiene products.  

Various authors (Pérez-Camacho et al. 2023, Plotka-Wasylka et al. 2022, UNEP 2021, Nealis 2021, Mendoza 
et al. 2019, and Cordella et al. 2015) recognise the raw material acquisition (sourcing and production) as the 
main  contributor  to  the  life  cycle  impact  of  hygiene  products.  This  is  due  to  the  extensive  use  of  natural 
resources, electricity and chemicals. The elementary flow relies on energy and material resources as inputs, 
and  waste  and  emissions  as  outputs.  Figure  11  highlights  the  most  important  impact  categories  for 
producing baby diapers and feminine pads. Procures that wish to learn more about life cycle assessment of 
absorbent  hygiene  products  should  refer  to  Preliminary  report  for  the  revision  of  EU  Ecolabel  criteria  for 
absorbent hygiene products.  

Figure 11. The most relevant impact categories of baby diapers and feminine pads 

Source: Adapted from Pérez-Camacho et al., 2023. 

As already mentioned, the multi-layer absorbent hygiene products, i.e., incontinence care products for adults, 
baby  nappies,  breast  pads,  panty  liners  and  feminine  pads  (i.e.,  sanitary  towels)  share  some  similarities  in 
terms  of  material  supply  chains,  properties  and  production  processes  -  therefore  environmental  hotspots. 
Figure 12 provides a schematic overview of the raw material flows and life cycle phases in the production of 
absorbent hygiene products, including tampons. Processing of input materials is divided into 3 key categories 

21 See: Larson, L. Hansen, G., Marcussen, J., Bo Madsen, L.,1998. Breast Pads. EP0840582A1. European Patent Office (1998) available at:  
https://patents.google.com/patent/EP0840582A1/en 
22  The  Product  Environmental  Footprint  (PEF)  is  a  LCA-based  method  to  quantify  the  environmental  impacts  of  products  (goods  or 
services)  that  are  more  reproducible,  comparable  and  verifiable,  compared  to  existing  alternative  approaches.  For  the  details  of  the 
methodology, see: https://eplca.jrc.ec.europa.eu/permalink/PEF_method.pdf 

27 

 
 
                                                        
 
i.e., natural origin materials (marked by the yellow arrow), extracted materials: fossil and minerals (marked by 
the orange arrow), and packaging (marked by the green arrow).  

Figure 12 is to be read vertically for the manufacture of certain materials (components of an end product), 
with the life cycle running from top to bottom. The most environmentally relevant inputs at each stage (either 
electricity, fuel or transport) come in at the left, pass through the relevant production process and come out 
as environmental impacts on the right-hand side. The manufacturing process of absorbent hygiene products is 
schematically separated into life cycle phases i.e., upstream process, core process, and downstream process. 

Upstream processes  

The  upstream  process  comprises  the  acquisition,  processing  and  distribution  of  raw  materials  for  the 
production of input materials (feedstock) that are transferred (supplied) to the core process. This also includes 
the  production  and  distribution  of  packaging  i.e.,  polyethylene  packaging  and  bags  as  well  as  cardboard 
packaging. The weight of raw material sourcing is between 76% (climate change) and 102% (resource use  - 
fossils) for baby diapers and between 91% (eutrophication, terrestrial) and 100% (resource use 
 fossils and 
resource use - minerals and metals) for sanitary napkins. Resource use   fossils exceed 100% due to negative 
values in the EoL. 

For  baby  nappies,  the  key  environmental  impact  of  raw  materials  sourcing  includes  the  production  of 
superabsorbent  polymers  (SAPs),  fluff  pulp  and  polypropylene  (PP),  low-density  polyethylene  (LDPE)  and 
polyethylene  terephthalate  (PET)  granules.  In  particular,  SAPs  generate  the  greatest  impact,  accounting  for 
40% of all raw materials, mainly due to its high energy consumption.  

The production of viscose, fluff pulp, PET, LDPE and PP granulates is the most significant processes involved 
in  obtaining  raw  materials  for  sanitary  towels.  In  particular,  production  of  LDPE 23  granulates  and  film 
extrusion  of  LDPE  for  packaging  are  the  most  relevant  processes  in  some  impact  categories,  mainly  in 
Resource Use 
 freshwater 
 fossils (17%), Climate Change (11% granulates, 6% extrusion) and Ecotoxicity 
(14%). 

The information in Figure 12 illustrates the upstream processes for making the raw materials that end up in 
absorbent hygiene products. In terms of mass, fluff pulp is the most significant material component. 

Core process 

The core process i.e., final product manufacturing stage, comprises a series of industrial operations in which 
the raw materials from the upstream stage are processed and then assembled (combined) into an absorbent 
hygiene product.  

For incontinence products and sanitary towels, each layer is made of functional raw material bonded together 
to  work  complementary  to  each  other  and  guarantee  the  serviceability  of  the  final  products.  The  process 
starts with building of an absorbent core layer - typically mixing fluff pulp in air-laid process (air-jets blowing) 
with  SAPs  powder  in  a  core  former,  which  also  shapes  the  layer.  Then  the  absorbent  core  is  attached  to  a 
permeable  (hydrophilic)  top  layer  that  comes  with  a  direct  skin  contact.  This  is  mainly  made  from 
polypropylene, polyethylene and/or polyester-based nonwoven fabrics produced through a process known as 
meltblown (e.g., using high-velocity hot air to convert polymers into a nonwoven web of very fine fibre). The 
top layer is usually perforated to facilitate the pass off to the absorbent core. The second layer of nonwoven 
fabric sheets of polypropylene might be added to act as a wicking material and distribute fluid throughout the 
pad (distribution layer), which might also contain superabsorbent polymers (SAPs) 

Currently, thermal bonding is widely used to seal the layers as it offers high production rates, lower energy 
utilisation, and is more environmentally friendly since there are no residues to be disposed of. The last step 
consists in lamination with an impermeable synthetic bottom layer with the added fastening system, straps 
with  adhesives  for  sanitary  pads  to  stick  the  product  to  the  underwear,  and  tapes  or  fasteners  for 

Tampons  consist  of  nonwoven  fibres  that  are  rolled  up  or  folded  into  the  desired  shape  to  ensure  even 
distribution of the liquid. A sheath of nonwoven fabric or a perforated sheath can be added to the non-woven 

23  LDPE  packaging  has  a  higher  contribution  in  the  most  relevant  processes  compared to  baby  diapers  because  of  the  higher  share  of 
packaging materials compared to the product mass in sanitary towels. 

28 

 
 
                                                        
 
and the string is also added to ensure removal from the body. The product can also be secured in plastic or 
cardboard applicators. 

For  all  single-use  AHPs,  the  final  production  step  is  the  packaging  (wrapping)  of  each  individual  product  to 
prevent  contamination  of  the  product  (usually  plastic  or  paper  film)  and  is  then  packaged  in  secondary 
packaging - paper boxes or plastic bags.  

The manufacturing phase requires the use of energy, chemicals, water and minerals and accounts for only a 
small part of the impact in almost all impact categories. 

During the production process, some material scraps are discarded on the manufacturing line due to errors in 
the process (pre-consumer waste). Cordella et al. (2015) quantified that 4% scrapped product is used back in 
the process. The pre-consumer waste24 from the production of absorbent hygiene products are considered as 
high-
-Wasylka et al., 2022) and the minimum purity of such materials is in excess of 
95% (Wille, 2018).  

Downstream processes  

The  downstream process includes  product  distribution (from the  manufacturing site to the retail stores and 
from there to the final client), use phase and end-of-life (EoL) of product and packaging.  

Products distribution typically has contributions around 5%, but in Acidification and Eutrophication   terrestrial 
it is around 10%- mainly due to the truck transport of products.  

Retail is assumed to have negligible impacts in the AHPs lifecycle, equally the use phase has zero burdens as 
the product is ready to be used and disposed of after use.  

In general, used AHPs are treated with household waste and landfilled or incinerated without further recycling. 
It is technically possible to correctly collect, shred, separate, and sterilize the diaper material but the process 
is complex, expensive and uncommon (Nealis, C. 2021). Therefore, at the moment, the recovery of resources 
from  post-consumer  AHPs  waste  is  negligible  and  lies  within  research  and  innovation  to  develop  new 
techniques (or improve existent) and offset health and safety concerns, while converting waste into valuable 
feedstock. As of 2023, the authors have not identified any comprehensive, national long-term strategy for the 
management of post-consumer AHPs waste  besides landfills and incineration. Khoo et al. (2019) mentioned 
the recycling processes from Knowaste company (UK), Fater company (Italy) or Super Faiths Inc. (Japan). The 
European project from the BBI JU25 studied the possibility of recycling the cellulosic fraction of post-consumer 
AHPs waste for producing biobased building blocks, polymers and fertilisers26 (EMBRACED project, 2021).  

Despite  the  AHPs  being  a  predominately  single-use  product  the  EoL  stage  shows  only  a  small  share  of  an 
overall  life  cycle  impact  in  almost  all  impact  categories.  The  end-of-life  contributes  19%  to  the  climate 
change impact of baby nappies, as the emissions come from landfilling the product. This may not be the case 
for sanitary towels as long as the packaging material is recovered in the end-of-life phase (the mass of the 
packaging  is  relatively  high  compared  to  the  mass  of  the  product  itself).  Packaging  recycling  can  therefore 
partially offset the impact of landfilling.  

24  Rework,  regrind  or  scrap  generated  in  a  process  and  capable  of  being  reclaimed  within  the  same  process  that  generated  it,  is  not 
considered recycled material. 
25 See: Biobased Industries Joint Undertaking (BBI JU), available at: https://www.bbi.europa.eu/  
26 See: EMBRACED project, 2021, available at https://www.embraced.eu/project (accessed 10/11/2023). 

29 

 
 
 
                                                        
 
Figure 12. Overview of the main processes and life cycle stages for the manufacturing of absorbent hygiene products 

Source: JRC own elaboration 

30 

 
 
 
All in all, the disposable AHPs contribute to the release of the greenhouse gases (GHG) during their 
entire lifecycle. In the upstream process, since the use of non-renewable fossil resources, whereas in 
the  core  phase,  due  to  the  energy  required  for  the  production  and  fuels  for  transport,  and  at  the 
end-of-life phase due to landfilling or incineration.  

Theoretically,  single-use  diapers  could  benefit  from  the  use  of  post-consumer  secondary  material, 
mainly  recycled  nonwoven.  However,  due  to  the  health  and  safety  concerns  it  is  not  a  common 
-Wasylka et al., 2022, Wille, D. 2018). In 
fact, Nordic Ecolabelling for  Sanitary Products (v.6.9.) specifies that, with the exception of recycled 
plastic, the  use  of  recycled  material  (e.g.,  in  cotton,  paper and fluff) is  not  allowed  in  the  sanitary 
product (Nordic Ecolabelling, 2016). In the EU Ecolabel criteria, recycled materials inside the AHP are 
not explicitly prohibited, however their inclusion is not common market practice. 

Pérez  Camacho  et  al.  (2023)  analysed  the  environmental  surplus  of  substituting  disposable  AHPs 
with  their  reusable  alternatives and  conclude  that  this  often  represents  a  compromise  in  different 
impact categories.   

The limited (if any)  recovery of materials in the EoL phase,  coupled with extensive use of primary 
materials places a single-use AHP in line with an outdated linear economy model with high resource 
consumption.  Reducing  the  overall  environmental  impact  of  the  AHP  should  therefore,  in  the  first 
place, focus on the environmental hotspots, improving process efficiency and circularity of the raw 
materials  supply,  while  maximising  waste  recovery  in  the  pre-consumer  phase  (both  upper 
  and 
core processes), and reuse/recycling of packaging material in the EoL phase. Further enforcement of 
ecodesign measures, particularly in the upstream process where most environmental impacts occur, 
could serve as a roadmap for steering the AHP value chain towards circular economy goals. In this 
sense, the EU Ecolabel criteria could serve as a well-established and industry-verified guidance.  

31 

 
3 

Identification of EU Ecolabel-based criteria for the public 
procurement of absorbent hygiene products. 

A  twofold  screening  exercise  was  undertaken  to  identify  criteria  that  are  most  suitable  for 
recommendation as EU GPP criteria: first the screening of the existing EU Ecolabel criteria for AHPs 
(valid until 31 December 2029) against their suitability to be used in EU GPP criteria; and secondly, 
the screening of other relevant ISO 14024 type I ecolabels to verify if they have equivalent criteria 
to be used as an alternative means of verification. 

Figure 13. Illustration of two-part screening exercise conducted during the development of this EU GPP report 

Source: JRC own elaboration. 

3.1  Screening exercise: part 1   EU Ecolabel 

The  suitability  of  each  EU  Ecolabel  criterion  set  out  in  Annex  I  to  Commission  Decision  (EU) 
2023/180927 to be used in the EU GPP recommendations .was analysed and screened against these 
the three following parameters: 

  Be clearly linked to the subject matter of the procurement contract being awarded; 
  Be  verifiable  by  public  authorities  (in  cases  when  products  do  not  carry  the  EU 

Ecolabel); 

  Be of high environmental relevance from the perspective of LCA analysis and/or fit 

with circular economy objectives. 

Screening of each of the EU Ecolabel criteria has been carried out and results and recommendations 
are summarised in Annex 1.  

To this end, the selection of the proposed GPP recommendations is the result of (1) a cross-analysis 
of the environmental hotspots and improvement potentials identified within the EU Ecolabel revision 
and  (2)  an  assessment  of  the  suitability  of  the  EU  Ecolabel  criteria  for  use  in  the  procurement 
contracts.  

27 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, p. 142).  

32 

 
 
                                                        
 
The  EU  Ecolabel  criteria  are  then  compared  with  the  baseline  assessment  such  as  (a)  highly 

 EU GPP recommendations.  

Overall, the  screening  exercise  led  to  the  consideration  of  19  EU  Ecolabel  criteria  and  sub-criteria, 
which  were  transformed  into  a  total  of  10  technical  specifications  (TS)  and  9  award  criteria  (AC) 
(see: Table 6). Overall, the criteria cover the most important environmental hotspots and facilitate 
the methodology for assessment and verification by an independent third-party. 

3.2  Screening exercise: part 2   other ISO 14024 Type I ecolabels 

In  general,  ISO  14024  type  I  ecolabels  try  to  set  criteria  based  on  life  cycle  considerations  of 
products or services. These ecolabels are voluntary, multiple criteria-based schemes that are third-
party  verified.  The  ISO  14024  standard  also  addresses  procedures,  governance  and  transparency 
regarding how pre-defined environmental criteria should be set in the first place. The EU Ecolabel is 
an example of an ISO 14024 type I ecolabel28. 

The  non-exhaustive  global  examples  of  other  ISO  14024  Type  I  ecolabels,  which  fully  or  partially 
addressee absorbent hygiene products included in the scope of the EU Ecolabel are: 

  Nordic Ecolabelling ; 
  Blue Angel  
  GECA  (Good  Environmental  Choice  Australia)  -  The  GECA  Sanitary  Products  (SPv1.0-2019) 

ry Products (V6.4: 2016) 

These  ecolabels  guarantee  that  products  bearing  them  have  been  verified  by  third  parties  for 
compliance  with  pre-defined  environmental  criteria.  However,  none  of  the  ISO  14024  type  I 
ecolabels,  which  were  analysed  (Nordic  Ecolabelling  and  Blue  Angel)  are  fully  equivalent  to  theEU 
Ecolabel criteria that were selected for EU GPP criteria.   

Nordic  Ecolabeling  for  paper  products  has  brought  about  a  modular  system  that  comprises  three 
modules:  the  basic,  chemical,  and  supplemental  module.  For  this  reason,  the  product-specific 
(supplementary module) should be read together with the basic module. The requirements' levels in 
a Supplementary Module are tailored to the specific product performance and therefore prevail over 
those set in the basic module. 

The compliance check between EU Ecolabel, Nordic Ecolabeling, and Blue Angel summarized in Table 
6 is based on the following criteria documents: 

1. 
2. 

3. 

EU Ecolabel: Annex I to Commission Decision (EU) 2023/1809; 
Blue Angel DE-UZ 208 - Nappies, feminine hygiene and incontinence products (absorbent 
hygiene products, AHP), Edition January 2021, Version 3 
Nordic Ecolabelling for Sanitary Products Version 
2025, read together Paper Products   Basic Modules, (Version 3.0, 05 October 2020   31 
December 2025), or with Paper Products   Basic Module (Version 2.7 
- 31 
December 2025). 

- 31 December 

28   A  list  of  further  ecolabelling  schemes  can  also  be  obtained  at  the  web  site  of  the  Global  Ecolabelling  Network  (GEN) 

www.gen.gr.jp/product.html  

33 

 
 
 
 
 
 
 
 
 
 
 
                                                        
 
Table 6. EU GPP criteria recommendations for the public procurement of absorbent hygiene products in relation 
to selected ISO 14024 type I ecolabels 

29 

30 31 32 

33 

-

-

-

-

Source: JRC based on EC 2023, Nordic Ecolabelling 2016, Blue Angel 2021. 

1) 

2) 

If the fluff  pulp is  manufactured with only one type of  pulp (without pulp mix), otherwise 
not equivalent 
If the pulp is verified against with Nordic Ecolabelling for Paper Products 
3.0), otherwise not equivalent 

 Basic Module (v 

3)  Only if the sum of points for energy and fuel does not exceed 2.5, otherwise not equivalent 

29 Commission Decision (EU) 2023/1809 of 14 September 2023 establishing the EU Ecolabel criteria for absorbent hygiene 
products and for reusable menstrual cups 
30  See:  Nordic  Ecolabel  criteria  for  Paper  Products 
available at: https://www.nordic-ecolabel.org/globalassets/ai001_3.0_basic_module_cd.pdf 
31 See: Nordic Ecolabelling for Paper products 
https://www.nordic-swan-ecolabel.org/4ac252/contentassets/956d503409fb4a6bb1bb38762bb78da5/basic-module-for-
paper-products-2.7_041_printing-companies-and-printed-matter-041_english.pdf 
32  See:  Nordic  Ecolabelling  for  Sanitary  Products,  Version  6.9.  14  June  2016  -  31  December  2025,  available  at: 
https://api.svanemaerket.dk/api/docs/CriteriaDocumentFiles/7444 
33 See: Nappies,  feminine  hygiene  and incontinence  products  (absorbent hygiene  products,  AHP)  -  DE-UZ  208,  Basic  award 
criteria,  January  2021,  version  3,  available  at:  https://www.blauer-engel.de/en/productworld/nappies-feminine-hygiene-and-
incontinence-products 

- 31 December 2025, available at: 

  31  December  2025, 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                        
 
 
 
 = covered; 

 = exceeded; 

 = partially or potentially covered/further assessment required; X = not covered  

Annex 2 contains details of part 2 of the screening exercise summarised in Table 6. It describes the 
reasoning  for  the  equivalence  or  non-equivalence  between  selected  EU  Ecolabel  requirements  for 
absorbent  hygiene  products  and  corresponding  Nordic  Ecolabeling  and  Blue  Angel  criteria.  In 
summary,  none  of  the  ISO  14024  type  I  ecolabelling  standards  are  entirely  equivalent  to  the  EU 
Ecolabel criteria that were selected for EU GPP criteria´s recommendations. 

Unlike the above listed type I ecolabels, the Forest Stewardship Council (FSC) and Programme for the 
Endorsement  of  Forest  Certification  (PEFCS)  certificates  are  exclusively  sustainable  forestry 
certificates that never address industrial production process. The limited scope of FSC and PEFC (to 
fibre sourcing), is the only reason of non-inclusion in the above equivalency cross-check with other 
type I Ecolabels. The schemes are accordingly addressed  under  criteria that  verifies cellulose fibre 
sourcing i.e., Criterion T.S. 1.1., T.S. 2.1., and T.S. 5.1.  

checked in relation to the actual subject matter and requirements used in a tender.  

When  conducting  the  cross-checking  exercise  of  EU 
Ecolabel  criteria  with  those  of  other  ISO  14024  Type  I 
ecolabels  for  the  same  or  similar  product  groups,  it  is 
important to specify the exact version of the other ecolabel 
criteria,  since  it  can  be  updated  or  completely  changed  in 
later versions and the comparison summarised above may 
become  inaccurate  or  invalid  over  time.  In  order  to  ensure  that  comparisons  remain  valid,  the 
screening exercise should be repeated every few years. Updated  versions of  Table 6 and Annex 2 
could  be  made  available  on  the  DG  ENV  website,  on  the  same  link  where  this  report  is  made 
available. 

Other Type I ecolabels may undergo 
regular updates which make them 
more or less similar to EU Ecolabel 
criteria compared to today.  

3.3  General considerations about verification via ecolabels 

According to Article 43 of Directive 2014/24/EU (EC, 2014a) third-party environmental labels can be 
stipulated in technical specifications, award criteria, or contract performance conditions as means of 
proof.  However,  their  applicability  always  needs  to  be  checked  in  relation  to  the  actual  subject 
matter  and  criteria  used  in  the  tender,  and  equivalent  means  of  verification  for  products  without 
labels must be permitted. 

When using criteria based on the EU Ecolabel in calls for competition, products awarded with the EU 
Ecolabel automatically comply with the set requirements and no further verification is required.. 

35 

 
Figure 14. Verification hierarchy for GPP criteria based on EU Ecolabel criteria 

Source: JRC own elaboration. 

Products with the EU Ecolabel are associated with the least verification effort. However, in cases of 
doubt  about  the  validity  of  the  EU  Ecolabel,  procurers  can  consult  the  online  catalogue  (ECAT)34 
where  searches  can  be  made  by  product  name,  company  name  or  license  number.  In  case  the 
product  or  license  number  cannot  be  found  in  the  EU  Ecolabel  catalogue,  the  relevant  national 
Competent Body35 should be consulted.  

The  criteria  arrangement  into  technical  specifications  and  award  criteria  suggests  how  the 
procurement sequence could be managed in order to distinguish levels of ambition and achieve the 
best results. The award EU GPP criteria recommendations are to encourage manufacturers to steer 
innovation  and  become  more  competitive  in  invitations  to  tender  in  a  number  of  areas  that  are 
strongly related to the environmental impact of absorbent hygiene products, and which are already 
addressed  by  ISO  14024  Type  I  ecolabels.  The  combination  of  less  ambitious  TSs  with  more 
ambitious  ACs  allows  calls  for  competition  rewarding  the  best  products  on  the  market  while 
accommodating market features (i.e., availability of sustainable products).  

If the products are currently undergoing the application process 
to  obtain  the  EU  Ecolabel  (or  a  relevant  type  I  ecolabel),  this 
cannot be accepted as proof of compliance. Instead, compliance 
with  individual  requirements  would  be  necessary  just  like  for 
any other product without a relevant ecolabel. 

Wherever equivalent third-party 
operated labelling scheme are 
not applicable, a full assessment 
and verification process is 
needed. 

Where environmental labels or certificates are not available or 
applicable, a full assessment and verification process needs to be conducted. Each EU GPP criterion 
indicates information about, for example, relevant standards, test methods or other documentation 
that could be required to demonstrate compliance. 

3.4  Recommended  EU  GPP  criteria  for  the  public  procurement  of 

absorbent hygiene products. 

34 http://ec.europa.eu/ecat/  
35 More details can be found here: https://ec.europa.eu/environment/ecolabel/competent-bodies.html  

36 

 
 
 
 
                                                        
 
In  this  Section,  we  outline  a  total  of  19  green  criteria  (nine  technical  specifications  (TS),  and  ten 
award  criteria  (AC))  for  procuring  absorbent  hygiene  products.  The  recommendations  are  broken 
down into sections that cover essential improvement areas from the life cycle perspective,  such as 
materials, core production process, and packaging.  

Annex I to Commission Decision 2023/1809 serves as the basis for the recommendations. Each EU 
GPP  criterion is accompanied by summarized  rationales,  which may be considered  valuable  by the 
procurer when designing the tender. 

If  you  would  like  to  further  explore  the  technical  and  policy  arguments  that  supported 
each EU Ecolabel criterion, please refer to the respective Technical Report (Faraca et al., 
2023) and Preliminary Report (Pérez-Camacho et al., 2023). 

Where the procurement exercise is to procure future products or customised products that do not yet 
exist,  the  technical  specifications  could  be  converted  into  contract  performance  clauses  with  clear 
penalties and consequences for any non-compliance. 

In  case  of  doubt  about  the  market  availability  of  compliant  products,  technical 
specifications could be changed to the award criteria.  

Based on market analysis, the procurer may also opt to raise the level of ambition of the 
criteria. This can be accomplished by adjusting limit values or assigning a higher number 
of points to products that perform better than the limit value.  

However,  raising  the  ambition  level  of  a  specific  criterion  should  not  allow  for  the 
reduction in the ambition level of another criterion.  

The criteria are narrowed down to materials that are typically used in the production of AHPs, 
such as fluff pulp, cotton, and man-made cellulose fibre. Therefore, it is crucial to  view 
criteria 1 to 3 as complementary instead of alternative. The final number of points awarded 
to a product should not be decreased if any of the materials discussed in this report is not present.  

The  materials  produced  in  an  upstream  process,  particularly  cellulose  pulp,  are  highly  traded 
commodities. The authors advise the procurer to ensure that feedstock comes from legally operating 
site(s),  under  conditions  stated  in  the  operating  permit  as  specified  by  the  competent  regional  or 
national  authority  -  the  introduction  of  respective  safeguard(s)  can  be  executed  via  e.g.,  exclusion 

requirement.  Therefore,  unless  being  relevant  to  the  criterion´s  explanation,  it  is  not  specifically 
addressed.  

If  you  wish  to  find  more  background  information  on  the  compliance  check  for  the  selected  type  I 
ecolabels, please refer to Annex 2.  

Fluff Pulp 

TS 1.1. Sourcing of fluff pulp 

Based on EU Ecolabel Criterion 1.1 
Decision (EU) 2023/1809. 

 Sourcing of fluff pulp laid down in the Annex I to Commission 

-

-

37 

 
 
 
 
 
-

-

-

Further information 

-

The fluff  pulp is characterised by its high absorbency and is commonly  used in absorbent hygiene 
products  (see:  Table  5).  Mainly  long  softwood  fibres  such  as  spruce  or  pine  are  used  for  its 
production,  which  is  concentrated  in  the  United  States  (85%  of  global  capacity  in  2022)  (Nelson, 
2022).  The  production  volume  in  the  EU  is  estimated  at  5%  of  global  production  (Schlusaz  et  al., 
2019), mainly in Sweden and Finland.  

The  main  environmental  impacts  that  most  people  immediately  associate  with  the  cellulose  pulp 
production  are  deforestation  and  land  use.  In  order  to  enforce  a  continuation  of  existing  good 
procurement  practise  in  the  sourcing  of  forestry  products,  it  seems  essential  to  ensure  the 
sustainable use of forest resources throughout the supply chain. In this context, compliance with (1) 
the  principles  of  sustainable  forest  management  (SFM)  and  (2)  the  traceability  and  attribution  of 
materials from SFM-certified forests through the supply chain to the final product is essential. In this 
respect, the EU GPP recommendation for fibre sourcing ensures that these areas are  covered. The 
requirement is also structured to verify that all fibre is legally sourced and covered by a valid chain 
of  custody  certificates.  The  criterion  requires  a  minimum  of  70%  w/w  content  of  fibres  from 
sustainably managed forests. 

Referring  to  forest  management  schemes  established  in  the  market  such  as  Forest  Stewardship 
Council (FSC), Programme for the Endorsement of Forest Certification (PEFC) or equivalent schemes, 
provides a procurer with a straightforward verification of compliance.  

The  voluntary  certification  schemes  for  sustainable  forest  management  have  been  designed  to 
incorporate  relevant  SFM  practises  (which  help  to  mitigate  the  impacts  of  land  use  and  protect 
biodiversity). Their implementation has been verified by an  accredited independent third-party. FSC 
and PEFC have come to prominence precisely because they aim to allay potential consumer concerns 
about deforestation by ensuring that forests and plantations are managed sustainably. These labels 
have  become  established  for  many  different  types  of  wood  products  and  are  often  required  in 
tenders. 

Verification of compliance with other Type I ecolabels   

The  verification  of  EU  Ecolabel  requirement  for  fibre  sourcing  relies  on  CoC  and  SFM  certification 
schemes such as FSC and PEFC labels - thereof suitable proof of compliance.  

The Blue Angel requires 100% SFM-certified fibres. By being more ambitious than EU Ecolabel, the 
scheme provides adequate evidence of compliance with the proposed EU GPP requirements for fibre 
sourcing.  

The  criterion  for  fibre  sourcing  in  Nordic  Ecolabelling  for  Sanitary  Products  (v.6.9.,  June,  2016) 
requires  at  least  30% w/w  of  wood  raw  material  used  in  the  fluff  pulp  to  be  SFM-certified, which 
does not fulfil EU Ecolabel criterion 1.1.  

38 

 
 
 
 
 
 
 
 
TS 1.2. and AC 1.1. Bleaching of fluff pulp 

Based on EU Ecolabel Criterion 1.2 Bleaching of fluff pulp  laid down in the Annex I to Commission 
Decision (EU) 2023/1809. 

Technical specification 

Award criterion 

TS 1.2. Fluff pulp bleaching 

AC 1.1. Absorbable organic halogens (AOX) 

Fluff pulp used in the absorbent hygiene product shall 
be  elemental  chlorine  free  (ECF)  or  totally  chlorine 
free (TCF) bleached. 

Chlorine gas shall not be used as a bleaching agent.  

Note:  This  criterion  refers  to  elemental  chlorine  free 
(ECF)  pulp.  Totally 
(TCF)  pulp 
automatically fulfils this requirement. 

chlorine 

free 

X points will be awarded when ECF pulp bleaching for 
each  pulp  used  in  a  product  demonstrated  to  comply 
with maximum AOX emission value in accordance with 
criterion  1.2  of  Annex  I  to  Commission  Decision  (EU) 
2023/1809.    

Verification: 

Absorbent  hygiene  product,  which  have  been  awarded  the  EU  Ecolabel  EU  Ecolabel  according  to  Annex  I  of 
Commission Decision (EU) 2023/1809 will be deemed to comply with the requirement.  

Alternatively, the tenderer shall declare that the absorbent hygiene product has been certified by another third-
party operated labelling scheme confirming that equivalent EU Ecolabel requirements are met (1). 

If  the  absorbent  hygiene  product  does  not  carry  a  required  label  or  an  equivalent  label,  another  equivalent 
means of proof must be provided. 

(1) Equivalency here means compliance check and demonstrating that fluff pulp used in manufacturing of the non-EU Ecolabel 
absorbent hygiene product meets or exceeds the requirements as stated in criterion 1.2 of Annex I to Commission Decision 
(EU) 22023/1809.  

For TS1.2 at the time of writing (as of January 2024), suitably equivalent third-party certification schemes identified include 
Nordic Ecolabelling for Sanitary Products (v.6.9, June 2016) and Blue Angel DE-UZ 208 (v.3, Jan 2021).  

For AC1.1 at the time of writing (as of January 2024), there are no labels that are suitable equivalents. However,  Blue Angel 
DE-UZ 208 (v.3., Jan 2021) could be accepted as suitably equivalent third-party schemes under condition that only one type 
of pulp is used in the manufacturing of fluff pulp.  

Further information: 

The  above  EU  GPP  recommendations  target  reduction  of  industrial  wastewater  toxicity  such  as 
absorbable organic halogens (AOX) discharges into the wastewater.  

The bleaching of pulp is mainly carried out to improve the optical properties of the end product (i.e., 
fluff  pulp).  Traditionally,  chlorine  gas  was  used  as  the  main  bleaching  agent.  Due  to  its  strong 
association  with  the  emission  of  chlorinated  organic  pollutants,  bleaching  with  elemental  chlorine 
was replaced by bleaching with elemental chlorine free (ECF) sequences (with chlorine dioxide as the 
main bleaching agent) and later on by totally chlorine free (TCF) bleaching sequences (with peroxide, 
ozone,  oxygen,  etc.).  The  distinguishing  factor  between  the  two  processes  is  the  use  of  chlorine 
dioxide in the ECF method. ECF and TCF are both considered best available techniques (EC, 2014c). 

Absorbable  organic  halogens  (AOXs)  are  associated  with  acute  toxicity,  chronic  toxicity  and 
mutagenic effects in living organisms. The main source of AOX emissions from bleaching processes 
is  the  use  of  free  chlorine  or  chlorine  compounds.  As  TCF  bleaching  does  not  require  any  form  of 
chlorine, the award criterion should only apply to the ECF pulps.  

In  general,  AOX  monitoring  calculates the  total  amount  of  halogens  (chlorine, bromine  and  iodine) 
bound to dissolved or suspended organic matter in a wastewater sample. Verification of compliance 
is simplified by checking the results of the standardised test method ISO 9562:2004.  

Monitoring  and  reporting  of  AOX  emission  are  mandatory  for  the  plants  that  are  covered  by  the 
Industrial Emission Directive (2010/75/EU) and Commission Implementing Decision 2014/687/EU on 
the BAT conclusions for the production of pulp, paper, and board (EC, 2014c). Also, for the fluff pulp 
manufactured in the United States, the US EPA requires to monitor emission parameters under the 

39 

 
 
guidelines incorporated into the National Pollutants  Discharge Elimination System (NPDES)  permits 
and other control mechanisms for from pulp and paper manufacturing.   

Hence, the verification of requirement should not cause additional burden for the procurer.  

Verification of compliance with other Type I ecolabels   

All  listed  schemes  can  be  used  as  an  appropriate  proof  of  compliance  for  the  verification  of 
technical specification (TS1.2.). 

For absorbable organic halogens, the EU Ecolabel sets the maximum emission threshold at 0.14 kg 
AOX/ADt  for  each  individual  pulp  used  in  a  final  product,  whereas  for  Nordic  Ecolabelling:  AOX 
emission from the individual pulp must be equal or lower than 0.17kg/tonne, and for Blue Angel: AOX 
emissions must not exceed a value of 0.12 kg AOX/ADt.  

While the ambitious level set by Blue Angel is apparently higher than that of EU Ecolabel, the Blue 
Angel does not specify that the verification refers to each individual pulp in a pulp mix. This, in case 
of  pulp  blend,  means  that  the  reference  value  represents  an  average  for  a  pulp  mix  whereas 
emission from each individual pulp might be (virtually) higher than 0.14 kg AOX/ADt. The equivalency 
can be accepted as long as fluff pulp is made from only one type of pulp.  

AC 1.2. Chemical oxygen demand (COD) sulphur (S), NOx, and phosphorous (P) emissions  

Based on EU Ecolabel criterion 1.3  Emissions from fluff pulp production to water (chemical oxygen 
  COD  and  phosphorus  (P)),  and  to  air  (sulphur  compounds  (S)  and  NOx  laid  down  in  the 
demand 
Annex I to Commission Decision (EU) 2019/70. 

Award criterion 

AC 1.2. Chemical oxygen demand (COD) sulphur (S), NOx, and phosphorous (P) emissions 

X points will be awarded when fluff pulp making process demonstrated to comply with maximum COD, S, NOx, 
and P emission limits to air and water in accordance with criterion 1.3 of Annex I to Commission Decision (EU) 
2023/1809.  

Verification: 

Absorbent  hygiene  product,  which  have  been  awarded  the  EU  Ecolabel  EU  Ecolabel  according  to  Annex  I  of 
Commission Decision (EU) 2023/1809 will be deemed to comply with the requirement.  

Alternatively, the tenderer shall declare that the absorbent hygiene product has been certified by another third-
party operated labelling scheme confirming that equivalent EU Ecolabel requirements are met (1). 

If  the  absorbent  hygiene  product  does  not  carry  a  required  label  or  an  equivalent  label,  another  equivalent 
means of proof must be provided. 

(1) Equivalency here means compliance check and demonstrating that emission to water and air from manufacturing of the 
non-EU  Ecolabel  absorbent  hygiene  products  meets  or  exceeds  the  requirements  as  stated  in  criterion  1.3  of  Annex  I  to 
Commission Decision (EU) 2023/1809. Compliance check shall include pulp and fluff pulp manufacturing, process i.e., for non 
  integrated  pulp  and  paper  production  the  verification  should  separately  address  pulping  process  and  fluff  pulp  making 

process. For integrated production process, a combined verification shall suffice.   

At the time of writing (as of January 2024), the suitably equivalent third-party scheme identified includes Nordic Ecolabel for 
Sanitary Products (v.6.9, June 2016)) but only if read together with Nordic Ecolabelling for Paper Products 
 Basic Module (v 
3.0). The equivalency of Blue Angel DE-UZ 208 (v.3) should be accepted based on a case-by-case analysis. 

Further information: 

Fluff pulp is a product of the pulp and paper industry. After producing cellulose pulp, it undergoes a 
series of operations (air-laid process)36 to create cellulose fluff that has high absorbency and bulk. 
The fluffing process involves using a hammer mill to defibrillate cellulose pulp and break the fibre-

36 When fibre is dispersed in the air 

40 

 
 
                                                        
 
fibre bonds. The air carries the individual fibres and arranges them into a web of fluff pulp. The air-
laid  process  permits  the  incorporation  of  fluff  into  the  intended  product,  such  as  an  absorbent 
hygiene product, and facilitates the mixing with other fibres in a nonwoven process. 

Fluff pulp can be obtained in integrated and not integrated processes. A non-integrated pulp mill is a 
standalone  factory  that  produces  market  pulp  for  further  processing  elsewhere,  and  a  non-
integrated  paper  mill  uses  externally  purchased  market  pulp  for  fluff  pulp  production.  In  the 
integrated  system,  pulp  and  fluff  pulp  processing  are  interlinked  as  to  the  site  and  process 
continuity.  

Emissions to water and air are among the most significant environmental impacts of pulp and paper 
production.  The  type  and  extent  of  emissions  can  vary  depending  on  the  technique  used,  fuel 
sources,  and  the  novelty  of  abatement  equipment.  In  the  European  Economic  Area  (EEA),  as 
previously  mentioned,  the  environmental  performance  of  pulp  and  paper  industrial  activities  is 
covered by the Industrial Emissions Directive (IED) and the BAT conclusions (EC, 2014c). Similarly, in 
the United States pulp and paper sector is covered by the National Pollutants Discharge Elimination 
System (NPDES) and National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Source 
Categories  managed  by  the  United  States  Environmental  Protection  Agency  (US  EPA).  Therefore, 
monitoring  selected  emission  parameters  is  a  well-established  practice  worldwide  and  should  not 
cause additional burden for the procurer. 

As  a  general  rule,  the  EU  Ecolabel  reference  values  for  emission  into  the  water  and  air  set  by 
Criterion  1.3  accommodate  differences  between  pulping  techniques  and  production  scenarios.  The 
emission thresholds are expressed as specific emission loads per tonne of product i.e., air dried pulp 
(ADt).  For  non-integrated  mills,  the  raw  material  pulp(s)  shall  comply  with  the  values  listed  for 
integrated  mills,  to  which  the  emissions  resulting  from the  conversion  (fluffing)  process  should  be 
added (Table 7). 

Table 7 EUEL reference values for emissions from different pulp types and from paper production 

Pulp grade/paper 

Emissions (kg/ADt) 

COD reference 

P reference 

S reference 

NOx reference 

Bleached chemical pulp (other than sulphite) 

Bleached chemical pulp (sulphite) 

Unbleached chemical pulp 

Unbleached chemical pulp (UKP-E quality) 

CTMP  

NSSC 

Integrated mills 

16.00 

24.00 

6.50 

6.50 

15.00 

11.00 

0.03(1)/0.05(2) 

0.03 

0.02 

0.035 

0.01 

0.02 

Non-integrated mills 

0.60 

0.60 

0.60 

0.60 

0.20 

0.40 

1.50 

1.50 

1.50 

1.50 

0.3 

1.50 

Paper mill (kg/tonne) 

1.00 

0.001 

0.15 

0.60 

(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  southern  U.S.  pine  species  from  regions  with  higher  levels  of 
phosphorus  and  applies  until  31  December  2026.  From  1  January 2027,  the  limit  of  0.03  kg P/ADt  shall  apply  also  to 
mills using eucalyptus and southern U.S. pine species from regions with higher levels of phosphorus 

Source: EC, 2023. 

The verification of COD, P, S and NOx emission represents a holistic approach that is translated into 
the  emission  scoring  (points  system),  which  evaluates  the  performance  of  a  plant.  The  applicable 

41 

 
 
methodology requires to divide the monitored emissions from pulp and fluff pulp making process by 
the applicable reference values, while the resulting score must meet the following requirements37: 

1.  The score for any individual emission parameter shall not exceed 1.5., and 
2.  The total number of points (Ptotal = PCOD + PS + PNOx + PP) shall not exceed 4.0. 

The  use  of  emission  points  grants  flexibility  at  the  site  level  and  accommodates  the  trade-off 
between emission parameters. 

Verification of compliance with other Type I ecolabels   

EU  Ecolabel,  Nordic  Ecolabelling  and  Blue  Angel  share  a  comparable  methodological  approach  for 
verifying  emissions  i.e.,  translating  the  actual  emission  values  into  emission  points  for  each 
monitored parameter.  

To  examine  the  differences  between  EU  Ecolabel  and  Nordic  Ecolabelling,  the  Nordic  criteria  for 
Sanitary Products should be read along with the Basic Module for paper products version 2.0 or later. 
 Basic Module, Version 
The authors refer to the most recent Nordic Ecolabelling for Paper Products 
  basic  module  v 2.7 (22 Jun 
  31  Dec  2025)  as  their  reference  points.  The  EU  Ecolabel  and  Nordic  Ecolabelling 
2011 
accommodate integrated and non-integrated processing and consider the situation when fluff  pulp 
might be made of more than one type of pulp (often the case) - emissions from different sites are 
allocated to the weight of each individual pulp in the pulp mix: 

 31 December  2025 and/or Paper products 

  The Paper products   basic module v 3.0 establishes the emission reference values that are 
comparable  to  those  from  EU  Ecolabel.  In  some  cases,  the  Nordics  reference  values  are 
stricter, particularly for COD and S emissions. The equivalent methodological approach with 
comparable  or  stricter  reference  values  can  guarantee  the  equivalent  or  better 
performance.  

  The  Paper  products 

  basic  module  v  2.7  (22  Jun  2011 

  31  Dec  2025)  establishes  the 
emission  reference  that,  in  particular  for  COD  are  somewhat  less  strict  than  the 
requirements set by EU Ecolabel. The use of an analogous calculation methodology cannot 
guarantee  equivalent  results  due  to  the  differences  in  reference  values.  A  case-by-case 
analysis could lead to acceptance of equivalence. 

The Blue Angel DE-UZ 208 (v. 3) determines an additional parameter for nitrogen (N) emission into 
the  water,  and  then  sets  the  maximum  allowed  score  of  five  for  the  sum  total  of  the  five 
parameters.  The  emission  reference  values  for  each  pollutant  are  generic  i.e.,  without  being 
associated  with  the  pulping  technique.  Furthermore,  the  criteria  have  been  comprehended  to  only 
encompass  the  integrated  production  process.  All  of  these  render  the  comparison  between  the 
schemes  almost  impossible,  and therefore  equivalence  can  only  be  recognized  through  a  case-by-
case analysis.  

AC 1.3. Emissions of CO2 from fluff pulp production  

Based  on  EU  Ecolabel  criterion  1.4  Emissions  of  CO2  from  fluff  pulp  production  laid  down  in  the 
Annex I to Commission Decision (EU) 2019/70. 

Award criterion 

AC 1.3. Emissions of CO2 from fluff pulp production 

X Points will be awarded when fluff pulp manufacturing process demonstrated to comply with maximum  CO2 
emission values in accordance with criterion 1.4 of Annex I to Commission Decision (EU) 2023/1809. 

Verification: 

Absorbent  hygiene  product,  which  have  been  awarded  the  EU  Ecolabel  EU  Ecolabel  according  to  Annex  I  of 
Commission Decision (EU) 2023/1809 will be deemed to comply with the requirement.  

37 If you wish to learn more about the calculation methodology please check:  EU Ecolabel criteria for Graphic Paper, Tissue 
Paper and Tissue Products. Final Technical Report, 

42 

 
                                                        
 
Alternatively, the tenderer shall declare that the absorbent hygiene product has been certified by another third-
party operated labelling scheme confirming that equivalent EU Ecolabel requirements are met (1). 

If  the  absorbent  hygiene  product  does  not  carry  a  required  label  or  an  equivalent  label,  another  equivalent 
means of proof must be provided. 

(1)  Equivalency  here  means  compliance  check  and  demonstrating  that  CO2  emission  from  manufacturing  of  the  non-EU 
Ecolabel absorbent hygiene product meets or exceeds the requirements as stated in criterion 1.4 of Annex I to Commission 
Decision (EU) 2023/1809. Compliance check shall include pulp and paper manufacturing, process i.e., for non   integrated pulp 
and  fluff  pulp  production  the  verification  should  separately  address  pulping  process  and  fluff  pulp  making  process.  For 
integrated production process, a combined verification shall suffice.   

At the time of writing (as of January 2024), no suitably equivalent labels have been identified.  

Further information: 

The CO2 emission from pulp and paper manufacturing occurs due to the energy requirements in the 
production  process,  which  are  fulfilled  by  on-site  fuel  burning  and  consumption  of  externally 
purchased electricity e.g., originating from the national grid. However, high energy consumption 
does not always indicate a high CO2 emission, just like low CO2 emission is not always a 
sign of low energy consumption.  

The  authors  suggest  that  the  procurer  always  considers  a  joint  verification  of  energy 
consumption and CO2 emission 
for the market to switch to a less carbon-intensive economy.  

Direct  and  indirect  emissions  across  the  supply  chain  will  determine  the  carbon  footprint  of  the 
product.  For  fluff  pulp  manufacturing,  on-site  combustion  of  fossil  fuels  is  the  source  of  direct 
CO2emissions - as detailed under scope 138 of GHG Protocol39, whereas the use of grid (purchased) 
electricity sums up to indirect emissions (scope 2 of the GHG Protocol). In 2021, the European pulp 
and  paper  industry  relied  on  biomass  for  60,5%  of  their  fuel  needs  (CEPI,  2023).  A  substantial 
amount of biomass resulted from the process residues, particularly black (or brown) liquor40. Modern 
kraft  pulp  plants  (sulfate  process)  already  have  chemical  recovery  units,  which  generate  on-site 
electricity through a combined heat and power (CHP) unit that utilises biomass.  

In 2021, the specific direct CO2 emission from pulp and paper industry in Europe, was 0.27 kt CO2/kt 
of  product,  which  was  7,4%  lower  than  in  2020.  The  overall  implemented  energy  efficiency 
measures reduced the absolute direct CO2 emissions of the sector by 2.7% between 2020 and 2021 
and by 27.9% since 1991 (CEPI, 2023).  

38 See: Scope 1 and 2 GHG Inventory Guidance f 
39 Greenhouse gases emission (GHG) Protocol supplies the world's most widely used greenhouse gas accounting standards for 
measuring and managing greenhouse gas (GHG) emissions. It addresses private and public sector activities, value chains and 
mitigation actions. 
40 By product of chemical pulping process with a high biomass content  

43 

 
 
 
                                                        
 
Figure 15. Reference values for CO2 emissions from different energy sources 

Source: EC, 2018c 

When calculating CO2 emissions, the amount of energy from renewable sources purchased and used 
for  the  production  processes  shall  count  as  zero  CO2  emissions.  For  biomass  combustion,  the 
relevant  sustainability  and  greenhouse  gas  savings  criteria  are  specified  in  the  Directive  (EU) 
2018/200141 

The above recommended EU GPP award criterion AC. address both direct and indirect CO2 emissions 
and  encourages  the  optimisation  of  energy  sourcing,  for  instance,  the  substitution  of  carbon-
intensive fossil fuels for energy from renewable sources42.  

The EU Ecolabel Criterion 1.4 refers to the emission factors for fuels43 established by Commission 
Regulation (EU) No 2018/206644 (Figure 15), except for grid electricity with the reference value of 
376  g  CO2  fossil/kWh  that  is  in  line  with  Regulation  2019/33145.  The  following  CO2  emission  limit 
values apply: 

For integrated mills  

Chemical and semi-chemical pulp: 400 kg CO2/ADt 
CTMP 900 kg CO2/ADt 

For non-integrated mills  

Converting process 95 kg CO2/ADt 

The  CO2  emission  estimation  from  mills  that  are  not  integrated  should  use  the  reference  values 
established for integrated production and include the CO2 emitted  during pulp fluffing (converting) 
process.  

The  EU  Emissions  Trading  System  (EU  ETS)  covers  the  pulp  and  paper  industry,  therefore  CO2 
monitoring is already a standard industry practice and should not proportionate additional barrier for 
the criteria verification by the procurement.  Note: The ETS scope for CO2 reporting differs from the 

41 See: Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of 
the use of energy from renewable sources (recast) (OJ L 328, 21.12.2018, p. 82) 
42  The  amount  of  energy  from  renewable  sources  purchased  and  used  for  the  production  processes  counts  as  zero  CO2 
emission for the calculation 
43 Fuel emission factors relate CO2 emission with net calorific value (NCV) and mass of fuel  
44  See:  Commission  Implementing  Regulation  (EU)  2018/2066  of  19  December  2018  on  the  monitoring  and  reporting  of 
greenhouse  gas  emissions  pursuant  to  Directive  2003/87/EC of  the  European Parliament  and of  the  Council  and  amending 
Commission Regulation (EU) No 601/2012 , OJ L 334, 31.12.2018, p. 1 93 
45 See: Commission Delegated Regulation (EU) 2019/331 of 19 December 2018 determining transitional Union-wide rules for 
harmonised  free  allocation  of  emission  allowances  pursuant  to  Article  10a  of  Directive  2003/87/EC  of  the  European 
Parliament and of the Council, OJ L 59, 27.2.2019, p. 8 69 

44 

 
 
 
 
 
 
 
 
                                                        
 
Verification of compliance with other Type I ecolabels   

To  examine  the  methodology  for  the  calculation  established  by  Nordic  Ecolabelling,  the  Nordic 
criteria for Sanitary Products v.6.9. should be read along with the Basic Module for paper products 
version 2.0 or later. The authors use the most recent Nordic Ecolabelling for Paper Products 
 Basic 
 basic module 
Module, 
v 2.7 (22 Jun 2011   31 Dec 2025) as their reference points. Both reference documents show some 
methodological differences with the EU Ecolabel.  

 31 December 2025  and/or Paper products 

The  Nordic  Ecolabelling  reference  values  for  Sanitary  products  are  in  comparable  value  ranges [to 
those  established by EU Ecolabel],  which  may reproduce  comparable results, in  particular, for non-
integrated  production  and  for  CTMP  integrated  production.  However,  the  comparison  of  the 
equivalence  of  the  possible  scenarios  for  the  CO2  emission  becomes  complicated  due  to  the 
differences in methodology. This means that equivalence can be accepted based on a case-by-case 
analysis (for more details see: Annex II). 

Blue  Angel  DE-UZ  208  v.3  for  Nappies,  feminine  hygiene  and  incontinence  products  (absorbent 
hygiene products, AHP) does not set requirement on CO2 emission.  

AC 1.4. Energy consumption 

Based  on  EU  Ecolabel  criterion  1.5  Energy  consumption  for  fluff  pulp  production  laid  down  in  the 
Annex I to Commission Decision (EU) 2019/70. 

Award criterion 

AC 1.4. Energy consumption during fluff pulp production 

X  points  will  be  awarded  if  the  energy  used  for  the  fluff  pulp  production  demonstrated  to  comply  with  the 
maximum energy (electricity and fuel) consumption in accordance with criterion 1.5 of Annex I to Commission 
Decision (EU) 2023/1809 

Verification: 

Absorbent  hygiene  product,  which  have  been  awarded  the  EU  Ecolabel  will  be  deemed  to  comply  with  the 
requirements.  

Alternatively, the tenderer shall declare that the absorbent hygiene product has been certified by another third-
party operated labelling scheme, confirming that equivalent EU Ecolabel requirements are met (1). 

If  the  absorbent  hygiene  product  does  not  carry  a  required  label  or  an  equivalent  label,  another  equivalent 
means of proof must be provided. 

(1) Equivalency here means compliance check and demonstrating that energy consumption for manufacturing of the non-EU 
Ecolabel absorbent hygiene product meets or exceeds the requirements as stated in criterion 1.5 of Annex I to Commission 
Decision (EU) 2023/1809. Compliance check shall include pulp and paper manufacturing, process i.e., for non   integrated pulp 
and paper production the verification should separately address pulping process and fluff pulp making process. For integrated 
production process, a combined verification shall suffice.   

At  the  time  of  writing  (as  of  January  2024),  the  equivalent  third-party  scheme  includes  Nordic  Ecolabelling  for  Sanitary 
products  (v.6.9.  June  2016)  but  only  if  the  sum  of  points  for  energy  and  fuel  does  not  exceed  2.5  (in  line  with  the  EUEL 
criterion 1.5). The equivalency of Blue Angel DE-UZ 208 (v.3) should be accepted based on a case-by-case analysis. 

Further information 

Fuel  and  energy  sourcing  are  the  main  contributors  to  the  environmental  impact  of  the  pulp  and 
paper sector. Either primary energy in the form of fuel or secondary energy in the form of electricity 
and  steam  or  both  energy  sources  are  used.  Hence,  by  encouraging  industry  best  practice  the 
recommended  EU  GPP  criterion  stimulates  the  optimisation  of  energy  consumption  (and  therefore 
triggers environmental and monetary benefits).  

Energy costs largely adds to total production costs, so there is an inherent incentive for the pulp and 
paper  (including  fluff  pulp)  sector  to  improve  energy  efficiency  when  beginning  new  investment 
cycles.  In  general,  the  pulp  and  paper  industry  relies  on  a  long-term  investment  plan  (e.g.,  to 
modernise  installation),  therefore  any  radical  shift  to  technologies  that  offer  improved  energy 
efficiency is unlikely to occur on an industry-wide scale overnight, thus sequential improvements via 

45 

 
upgrades  are  more  likely.  Incorporating  energy  consumption  thresholds  into  the  tender  would 
reward  the  paper  business  sector  for  transforming  efforts  towards  energy  efficiency  and 
incentivize sustainable investment.  

Although energy optimisation is a common practise in the pulp and paper industry, the extent of the 
applicable measures depends on the pulping technique used. One aspect that distinguishes the pulp 
and  paper  industry  from  other  energy-intensive  industries  is  the  aforementioned  fact  that  the 
residual  biomass  (i.e.,  bark,  black  liquor  and,  to  a  much  lesser  extent,  wastewater  sludge)  is 
recovered from the process  and used as fuel. A faster  spread of best available techniques (BATs), 
such as combined heat and power (CHP), retrofitting existing mills with energy efficient technologies, 
and  maximising  economics  of  scale  production  (e.g.,  integrating  mills,  larger  paper  machines,  etc) 
can  further  reap  significant  energy  savings  (EC,  2014c).  Although  BAT  6  of  Decision  2014/687/EU 
doesn´t state any specific energy consumption reference values, it lays out a series of measures for 
its reduction.  

To this end, the primary energy consumption of the European pulp and paper sector in 2021 reached 
in  total  1.356.405  TJ  (88.8%  fed  by  fuels),  while  the  electricity  consumption  was  93.239  GWh 
(95.6%  of  which  produced  through  the  CHP).  In  reference  to  2020,  the  specific  primary  energy 
consumption dropped by 0.6% (13.15 TJ/kt), whereas specific electricity consumption by 2.7% (0.90 
MWh/kt) (CEPI, 2023), while 95.6% of on-site electricity was produced through CHP. 

The  EU  Ecolabel  criterion  is  based  on  monitoring  of  actual  energy  fed  into  the  different  pulping 
processes.  This  is  linked  to  specific  reference  values  for  fuel  and  electricity  consumed  to 
manufacture  1  tonne  of  product  (sum  of  the  energy  from  pulp  processes  and  the  fluff  pulp 
conversion  process).  The  EU  Ecolabel  calculates  energy  points  i.e.,  a  ratio  between  actual  energy 
consumption  and  the  reference  value  weighted  against  a  type  of  pulp  content  in  a  pulp  mix.  The 
points for energy (Penergy) and for fuel (Pfuel) should not exceed 1.5, for each parameter, whereas the 
sum of points (Ptotal = Penergy + Pfuel) should not exceed 2.5. The combined verification of a total energy 
used allows for flexibility when optimising mill(s) energy consumption. 

Table 8. EU Ecolabel reference values for energy consumption during fluff pulp manufacturing 

-

-

Source: EC, 2023. 

Verification of compliance with other Type I ecolabels   

Nordic Ecolabelling for Sanitary Products (v.6.9.) and EU Ecolabels share methodological principles to 
calculate energy consumption. Unlike EU  Ecolabel, the  Nordic Ecolabel calculates energy scores for 
each parameter without considering its sum total: the threshold for  scoring is 1.25 for energy and 
1.25  for  fuel  consumption.  The  main  distinctions  stem  from  the  reference  values,  which  are  a  bit 
more  relaxed in the Nordic Ecolabelling criteria. However, as the maximum allowed score for each 
parameter  is  16.6%  more  ambitious  than  established  by  EU  Ecolabel  [1.25  vs  1.5],  the  authors 
assume that the energy consumption calculation might be comparable under condition that the sum 
of points for fuel and electricity is less than 2.5 (for more details refer to Annex 2). 

Blue  Angel  DE-UZ  208  v.3  for  Nappies,  feminine  hygiene  and  incontinence  products  (absorbent 
hygiene  products,  AHP)  uses  a  different  methodology  for  the  energy  calculation  i.e.,  pass/fail 
approach. The authors assume that reference  values refer to an integrated  production. The use of 
generic reference  values for  heat and electricity by Blue  Angel ignores the specific pulp input (and 

46 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
pulping technique) involved. The equivalency assessment is nearly impossible due to the absence of 
an energy point and generic values for the pulp blend. This means that equivalency can be accepted 
based on a case-by-case analysis. 

Man-made cellulose fibre 

TS 2.1. Sourcing of man-made cellulose fibres 

Based on EU Ecolabel Criterion 2.1 
to Commission Decision (EU) 2023/1809. 

 Sourcing of man-made cellulose fibres laid down in the Annex I 

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46

47

48

-

-

-

Further information 

46  Council  Regulation  (EC)  No  834/2007  of  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) 
47  Regulation  (EU)  2018/848  of  the  European  Parliament  and  of  the  Council  of  30  May  2018  on  organic  production  and 
labelling of organic products and repealing Council Regulation (EC) No 834/2007, PE/62/2017/REV/1 (OJ L 150, 14.6.2018, p. 
1) 
48 National Organic Program, A Rule by the Agricultural Marketing Service on 12.21.2000, 65 FR 80547 

47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                        
 
To see further information on cellulose fibre sourcing, please refer to technical specification TS 1.1. 
within fluff pulp section. 

Dissolving  pulp  produced  from  cotton  linters  shall  meet  technical  specification  TS  3.1.  addressed 

Verification of compliance with other Type I ecolabels   

Nordic  Ecolabelling  specifies  that  a  minimum  of  30-%  w/w  of  all  wood  raw  material  used  shall 
proceed from forestry certified (SFM) under the FSC or PEFC schemes.  

Blue  Angel  DE-UZ  208  v.3  for  Nappies,  feminine  hygiene  and  incontinence  products  (absorbent 
hygiene products, AHP) does not set requirements on man-man cellulose fibres. 

FSC and PEFS are suitable equivalent third-party operated schemes to verify fibre sourcing.  

TS 2.2 and AC 2.1. Bleaching of man-made cellulose fibre 

Based on EU Ecolabel Criterion 2.2 Bleaching of man-made cellulose fibres laid down in the Annex I 
to Commission Decision (EU) 2023/1809. 

Technical specification 

Award criterion 

TS 2.2. Bleaching of man-made cellulose 
fibre  

AC 2.1. Organic halogens  

-

. 

1.  X points will be awarded when ECF pulp bleaching 
for each pulp used to manufacture man-made 
cellulose fibres demonstrated to comply with 
emission limit for absorbable organic halogens 
(AOX) in accordance with criterion 2.2 of Annex I to 
Commission Decision (EU) 2023/1809.   

2.   X points will be awarded when ECF pulp bleaching 
for each pulp used to manufacture man-made 
cellulose fibres demonstrated to comply with 
thresholds for organically bound chlorine (OCl) 
content in accordance with criterion 2.2 of Annex I 
to Commission Decision (EU) 2023/1809.    

-

(1)  Equivalency  here  means  compliance  check  and  demonstrating that  dissolving  pulp  used  in  manufacturing  of  the  non-EU 
Ecolabel absorbent hygiene product meets or exceeds the requirements as stated in criterion 2.2. of Annex I to Commission 
Decision (EU) 22023/1809.  

For TS 2.1.at the time of writing (as of January 2024), suitably equivalent third-party certification schemes identified include 
Nordic Ecolabelling for Sanitary Products (v.6.9, June 2016)  

For AC2.1.1 a

For  AC  2.1.2.  at  the  time  of  writing  (as  of  January  2024),  suitably  equivalent  third-party  certification  schemes  identified 
include Nordic Ecolabelling for Sanitary Products (v.6.9, June 2016) 

48 

 
 
 
 
 
 
 
 
 
 
 
 
 
Further information 

The criteria aim to reduce the negative environmental and health effects caused by the consumption 
of resources and emissions generated during the production of man-made cellulose fibres. 

Organically  bound  chlorine  (OBC)  or  (OCl)  indicates  the  amount  of  organochlorine  compounds that 
remain  in  the  finished  product  as  a  result  of  pulp  bleaching  and  therefore  it  is  determined  by 
bleaching chemistry.  To  decrease the OBC content in the end product, standard techniques include 
adjustment  of  process  parameters,  including  the  selection  and  concentration  of  bleaching  agents. 
For  instance,  chlorine  dioxide  is  used  in  the  delignification  stage  (D)  before  being  extracted  with 
alkaline. 

Absorbent hygiene products can contain chlorine compounds that dissolve in bodily fluids and pass 
through the skin barrier, potentially damaging human health (Sofronova et al., 2022). The ISO 1148 
has  been  developed  for  determination  of  the  total  content  of  chlorine  (TC)  and  organically  bound 
chlorine (OBC) in cellulose materials.  

To  learn  more  about  AOX  emission,  consult  technical  specification  TS  1.2.  within  the  fluff  pulp 
section.  

The  proposed  EU  GPP  criterion  establishes  threshold  values  for  organochlorines,  addressing  AOX 
emission into water and the presence of OCI in a final product for ECF bleached pulps. 
  0.140 kg AOX/ADt, measured in the wastewater from pulp manufacturing; and 
  150 ppm OCl, measured in the finished man-made cellulose fibres. 

Verification of compliance with other Type I ecolabels   

For Nordic Ecolabelling for Sanitary Products (v.6.9.), the emission reference value for AOX (0,15 kg 
AOX/ADt)  is  less  strict  than  the  EU  Ecolabel  requirement.  For  organically  bound  chlorine  (OCl),  the 
Nordic Ecolabelling and EU Ecolabel establish equivalent threshold. 

Blue  Angel  DE-UZ  208  v.3  for  Nappies,  feminine  hygiene  and  incontinence  products  (absorbent 
hygiene products, AHP) does not set requirements on man-man cellulose fibres. 

AC 2.2. Production of man-made cellulose fibre 

Based on EU Ecolabel Criterion 2.3. Production of man-made cellulose fibre laid down in the Annex I 
to Commission Decision (EU) 2023/1809. 

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-

-

-

-

-

49 

 
 
 
 
 
 
 
 
 
 
 
-

Further information 

The traditional methods for producing dissolving grade pulps include acid sulfate and pre-hydrolysis 
kraft  pulping  processes.  These  methods  proportionate  cellulose  of  high  purity.  The  conventional 
viscose  process  involves  dissolving  cellulose  pulp  with  carbon  disulphide  (CS2)  in  strong  alkaline 
conditions,  i.e.,  in  the  presence  of  sodium  hydroxide  (NaOH).  The  spinning  that  follows,  transforms 
the dissolved pulp into filaments or staple yarns. For filaments, individual long fibre strands form an 
organised  structure  of  a  yarn,  whereas  for  staple  viscose,  fibre  is  cut  into  short  lengths  after 
spinning,  making  viscose  easier  to  blend  and  process  into,  for  example  textile  yarns  or  nonwoven. 
The staple fibre that is bulky and 'fuzzy to touch'  has a resemblance to  cotton.  About 85% of the 
total viscose fibre production is produced as staple fibres and about 15% as filaments49.  

The  emissions  to  water  in  dissolving  pulp  mills  can  originate  from  different  processes,  mainly 
washing losses, effluents from the bleach plant and condensates from the evaporation plant, while 
major point sources for emissions to air are the recovery boiler, the bark or biomass boiler and other 
steam blocks for steam production; however, potential releases of emissions to air from a number of 
processes  are  also  to  be  taken  into  account  (Faraca  et  al.,  2023).  Alternatively,  new  trends  in  the 
production  of  regenerated  fibres  are  related  to  the  direct  dissolution  of  cellulose  in  appropriate 
environmentally sound recyclable solvents, allowing high quality fibres (Mendes et al., 2021).  

The  award  criteria  encourage  the  retrieval  of  value,  like  by  recovering  spent  liquor  to  produce 
lignosulphonates  or  generate  steam.  In  this  sense,  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  generating  on-site  electricity  and/or  steam,  or  by 
manufacturing chemical co-products.  

EU  Ecolabel  emission  reference  values  are  extracted  from  the  Reference  Document  on  Best 
Available  Techniques  in  the  Production  of  Polymers  (BREF,  2007)  and  distinguish  the  specificity  of 
fibre  processing  into  filaments  or  staple  (Table  9)  [The  BREF  document  above  can  provide  the 
procurer  with more information about the manufacturing  process of  man-made cellulose fibre and 
its associated emission]. 

Table 9. EU Ecolabel emission limit values for viscose and modal manufacturing process 

- 

-

-
-

Source: EC, 2023. 

Verification of compliance with other Type I ecolabels   

The Nordic Ecolabel for sanitary products (v.6.9) does not specify a minimum % for the recovery of 
values from product manufacturing. In contrast to the EU Ecolabel, the Nordic scheme establishes a 
general  emission  requirement  that  does  not  take  into  account  the  type  of  fibres  used  and  the 

49 See: https://www.marketresearch.com/UnivDatos-Market-Insights-v4240/Viscose-Staple-Fiber-Current-Forecast-31627669/ 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                        
 
verification  refers  to  the  proportion  of  cellulose  fibres  that  makes  up  at  least  10%  (w/w)  of  the 
products.  The  different  emission  thresholds  in  the  Nordic  system  could  also  cause  other  non-
equivalent outcomes. 

Blue  Angel  DE-UZ  208  v.3  for  Nappies,  feminine  hygiene  and  incontinence  products  (absorbent 
hygiene products, AHP) does not set requirements on man-man cellulose fibres. 

Cotton and other natural cellulosic seed fibres 

TS 3.1. and TS 3.2. Sourcing and bleaching of cotton and other natural cellulosic seed fibre 

Based on EU  Ecolabel Criterion 3.1.  Sourcing  and traceability of cotton and other natural cellulosic 
seed fibre and Criterion 3.2. Bleaching of cotton and other natural cellulosic seed fibres laid down in 
the Annex I to Commission Decision (EU) 2023/1809. 

Technical specification 

TS 3.1. Sourcing of cotton and other natural cellulosic seed fibre 

All cotton and other natural cellulosic seed fibres shall be traceable and grown according to the requirements 
laid  down  in  Council  Regulation  (EC)  No  834/200750  and  Regulation  (EU)  2018/84851  of  the  European 
Parliament and of the Council, the US National Organic Programme (NOP52) or equivalent legal obligations set 
by trade partners of the European Union.  

The organic cotton content may include organically grown cotton and transitional organic cotton.  

TS 3.2. Bleaching of cotton and other natural cellulosic seed fibre 

Cotton and other natural cellulosic seed fibres used in a product shall be bleached using totally chlorine free 
(TCF) techniques in accordance with criterion 3.2 of Annex I to Commission Decision (EU) 2023/1809. 

Verification: 

Absorbent  hygiene  product,  which  have  been  awarded  the  EU  Ecolabel  EU  Ecolabel  according  to  Annex  I  of 
Commission Decision (EU) 2023/1809 will be deemed to comply with the requirement.  

Alternatively, the tenderer shall declare that the absorbent hygiene product has been certified by another third-
party operated labelling scheme confirming that equivalent EU Ecolabel requirements are met (1). 

If  the  absorbent  hygiene  product  does  not  carry  a  required  label  or  an  equivalent  label,  another  equivalent 
means of proof must be provided. 

(

-

-

-

-

-

-

-

50  Council  Regulation  (EC)  No  834/2007  of  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) 
51  Regulation  (EU)  2018/848  of  the  European  Parliament  and  of  the  Council  of  30  May  2018  on  organic  production  and 
labelling of organic products and repealing Council Regulation (EC) No 834/2007, PE/62/2017/REV/1 (OJ L 150, 14.6.2018, p. 
1) 
52 National Organic Program, A Rule by the Agricultural Marketing Service on 12.21.2000, 65 FR 80547 

51 

 
 
 
 
 
 
                                                        
 
Further information 

This  requirement  is  designed  to  reduce  the  negative  environmental  effects  of  growing  and 
processing of cotton and other natural cellulosic seed fibres.  

Global cotton production is expected to grow by 1.6% per year, reaching 30,6 million tonnes in 2031, 
while global trade in raw cotton is expected to exceed 12 million tonnes (up 27% from 2021), with 
India being the largest cotton producer and the  United States the largest exporter in  2022.  India's 
contribution to the global increase in cotton production is estimated to be around 25%.  

Since  2010,  the  percentage  of  cotton  fibres  produced  in  accordance  with  sustainability  or  organic 
standards  has  been  steadily  increasing,  reaching  a  25%  share  in  2018.  Among  the  existing 
standards, in 2018 the Better Cotton Initiative dominated worldwide with a share of more than 45% 
of  the  sustainable  cotton  supply, followed  by  the  Responsible  Brazilian  Cotton  Initiative  with  35%. 
The  certification  of  around  80%  of  cotton  production  under  these  two  initiatives  makes  Brazil  a 
leading player in global sustainable cotton supplier (OECD/FAO, 2022).  

The authors want to stress that the increasing market availability of sustainable and organic cotton 
justifies the  need  to  define  the  criterion  as a  technical  specification.  More  detailed  information  on 
the  organic  cotton  global  market  can  be  found  in  the  Organic  Cotton  Market  Report  2022  (Textile 
Exchange53).  

Figure 16. Global sustainable and organic cotton production  

Source: OECD/FAO, 2022 based on International Cotton Advisory Committee (ICAC) data54. 

The  main  objective  of  organic  cotton  cultivation  is  to  reduce  GHGs  emission  and  use  farming 
methods  that  minimize  or  eliminate  the  use  of  pesticides.  Organic  production  is  beneficial  for  the 
environment,  farmers,  and  local  communities,  and  it  responds  to  consumer  demand  for  organic 
products.  Organic  producers  are  verified  by  third-party  certification  bodies  to  meet  strict  national 
regulations  regarding  the  methods  and  materials  allowed  in  organic  production.  International 
Federation  of  Organic  Agriculture  Movements  (IFOAM)´s  family  of  organic  production  guidelines, 
such as the European Commission Regulations (EC) 834/2007 or the  United States Department of 
Agriculture National Organic Program (USDA NOP), among others, are used for the due diligence.  

In Europe, the production and control requirements for organic harvests are laid down by Regulation 
834/2007 on organic production and labelling of organic  products, which  harmonises the  rules for 
the production, labelling and control of organic products. It lays down general principles for specific 
production  methods,  the  use  of  natural  resources  and  strict  restrictions  on  the  use  of  synthetic 
chemicals.  It  also  lays  down  specific  principles  for  agriculture,  the  processing  of  organic  food  and 
organic feed. Organic production pursues the objectives of the common agricultural policy (CAP) 55 of 

53 See: https://textileexchange.org/ 
54 See: www.icac.org. 
55 See: CAP 2023-27 (europa.eu) 

52 

 
 
                                                        
 
the  Union  to  enforce  sustainable  agriculture  and  rural  development. Regulation  (EC)  1235/200856 
describes  how  producers  of  organic  products  from  outside  the  EU  can  conform  to  the  applicable 
European requirements. 

In the United States of America, the National Organic Program (USDA NOP) is the federal regulatory 
framework,  which  develops  and  enforces  consistent  national  standards  for  organically  produced 
agricultural products sold in the United States57. 

In addition, the term ´transitional organic cotton´, also called ´in-conversion cotton´, refers to the 
crop  that  is  in  the  process  of  certification.  The  certification  time  might  vary-  for  example,  the 
European Union requires 24 months and India and the United States36 month58. 

Regarding cotton bleaching, currently about 80-90% (Faraca et al., 2023) of cotton is bleached using 
TCF  techniques  (mainly  based  on  H2O2  sequences).  In  this  sense,  the  requirement  reinforces  the 
implementation of the current industry best practise.  

Verification of compliance with other Type I ecolabels   

All  reference  schemes  set  comparable  requirements  for  cotton  sourcing  and  traceability.  As  for 
cotton  bleaching,  unlike  EU  Ecolabel,  the  Nordic  Ecolabelling  accepts  ECF  bleaching  technique. 
Equally to EU Ecolabel, Blue Angel only accepts total chlorine free (TCF) bleaching process.  

Production process 

TS 4.1. Material efficiency in the manufacturing of the final product. 

Based on EU Ecolabel Criterion 6.  Material efficiency in the  manufacturing of  the final product  laid 
down in the Annex I to Commission Decision (EU) 2023/1809. 

Technical specification 

TS 4.1. Material efficiency in the manufacturing of the final product 

-

-

-

56 Commission Regulation (EC) No 1235/2008 of 8 December 2008 laying down detailed rules for implementation of Council 
Regulation  (EC)  No  834/2007  as  regards  the  arrangements  for  imports  of  organic  products  from  third  countries.  OJ  L 
334,12.12.2008, p. 25 52 
57See: https://www.ams.usda.gov/about-ams/programs-offices/national-organic-program 
58Textile  Exchange  2021,  see:  https://textileexchange.org/app/uploads/2021/02/In-Conversion-to-Organic-the-Basics-Final-
020821-1.pdf 

53 

 
 
 
 
 
 
 
  
 
 
                                                        
 
Further information 

The main objective of this criterion is to promote material recovery during the assembly of the final 
product and thus limit the amount of waste that ends up in a landfill or is incinerated without energy 
recovery. For this reason, process rejects e.g., scraps (pre-consumer waste) treated according to the 
principles  of  the  circular  economy  and  waste  hierarchy  such  as  recovery  for  reuse,  recycling  or 
processing for energy recovery do not fall within the scope of this requirement.  

Pre-consumer process rejects are valuable materials of high purity (Wille et al., 2028, Cordella et al. 
2015) that should, as far as technically feasible, be returned to the production process, for instance, 
by mixing with the raw materials and reprocessed. Plotka-Wasilewska et al. (2022) report that more 
and  more  component  manufacturers  are  setting  up  recycling  programmes  for  their  production 
waste, which directly benefits the process economy. To support this practice, technical specification 
TS 4.1. promotes production processes that maximise resource efficiency. 

To this end, the waste generated during the manufacture and packaging of the end products should 
not exceed 8% w/w for tampons and  4% w/w for all other products. The amount of  waste that is 
landfilled or incinerated without energy recovery should be calculated by subtracting the amount of 
waste recovered (reused, recycled, etc.) from the total amount of waste generated. 

Verification of compliance with other Type I ecolabels   

Neither  the  Nordic  Ecolabelling  for  sanitary  Products  (v.  6.9)  nor  the  Blue  Angel  DE-UZ  208  (v.  3) 
establish a threshold for the waste generated at the final product assembly site.   

Packaging 

TS. 5.1, TS 5.2., TS 5.3, AC 5.1, and AC 5.2 for packaging requirements 

Based on EU Ecolabel Criterion 8.  Packaging laid down in the Annex I to Commission Decision (EU) 
2023/1809. 

-

-

-

54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Alternatively, the tenderer shall declare that the absorbent hygiene product has been certified by another third-
party operated labelling scheme confirming that equivalent EU Ecolabel requirements are met (1). 

-

-

-

-

-

-

-

-

Further information 

The primary goal of the above requirements is to achieve advanced green procurement practices 
that  support  the  recycling  of  materials  and  contribute  to  the  creation  of  a  sustainable  value 
chain.  

The Ecodesign of packaging (sales and grouped59) that enforces a minimum content of recycled and 
recyclable  materials  will  support  material  circularity  and  hence  resource  recovery.  The  EU  GPP 
requirement encourages the  development of such measures, which aim to reduce the  depletion of 
natural resources that would otherwise be used to produce new raw materials. To this end, grouped 
packaging  must  be  made  of  paper  or  cardboard,  whereas  sales  packaging  can  be  made  of  paper, 
cardboard or plastic. Mixing of the different materials (i.e., plastic with paper) is not allowed.  Table 
10  summarises  the  EU  Ecolabel  requirements  for  plastic  and  cellulose  -based  materials  used  in 
packaging. The key elements of the requirements are divided into sections and are explained below.  

Maximised recycled material content in packaging 

The selection of paper that contains up to 100% of recycled fibre (known as paper for recycling) is a 
common  green public procurement practice for paper products. This is undoubtedly an appropriate 
way  to  allocate  life  cycle  thinking  and  reduce  the  environmental  impact  associated  with  pulp  and 
paper production. 

In 2022, the recycling rate of paper and board in Europe was 70.5%, which corresponds to 49.1% 
(47.491.000 tonnes) of the total raw material consumption of the European pulp and paper industry. 
In the same period, in total 79.5% of recycled fibre was used for the production of packaging and 
board (CEPI, 2023). Overall, the use of recycled fibres is much in demand and so it can be assumed 
that  is  being  efficiently  heightened.  The  highest  recycled  content  (70-90%  w/w60)  can  be  found  in 
corrugated board used for product  distribution, which  due to its characteristic e.g., thickness is not 
used for sales packaging.  

Technical  specification  TS  5.1.  therefore,  stipulates  a  minimum  recycled  content  of  40  %  w/w  for 
sales packaging and 80 % w/w for grouped packaging. The remaining percentage should be covered 
by a valid SFM certificate. In this way, 100% diligent material is used in product packaging.  

59 See definitions in the Introduction. 
60 GWP Group, 2022. Recyclable Packaging. Available at: https://www.gwp.co.uk/advantages/recyclable-packaging/ 

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                        
 
For plastic, the revised Packaging and Packaging Waste Directive (PPWD)61 defines a safeguard for 
the  recycled  content  (recycled  plastic  material)  in  the  contact  sensitive  packaging  such  as  medical 
applications62. The  Zero  Waste  Europe  (ZWE)  estimated  future  targets  for  the  recycled  content  of 
plastic  packaging  between  30-40%63 - combined  value  for  chemical64  and  mechanical  recycling. 
While  setting  targets  for  a  high  percentage  of  recycled  plastic  content  may  be  affected  by  its 
availability  on  the  market,  expert  consultations  suggested  that  due  to  several  limitations,  around 
30 40% w/w of recycled content would be appropriate for the plastic packaging sector (Faraca et al., 
2023).  Consequently,  the  PPWD  proposal,  depending  on  the  type  of packaging, sets  targets  for 
recycled content65  For AHPs, it is understood that the packaging should meet the targets of 35% by 
2030  and  65%  by  2040  (Faraca  et  al.,  2023).  Market  estimates  forecasts  enough  availability  of 
secondary  raw  materials  to  be  used  (based  upon  availability  of  recyclates)  and  indicate  a  current 
potential recycled content of (close to) 25% and near 49% by 203066  

Accordingly,  criterion  AC  5.1.for  a  share  of  recycled  plastic  (see:  Table  10),  while  achieving  the 
expected targets, also represents a compromise between the ambitious level and market feasibility
.e., a share of 20% w/w of recycled plastic. In the medium term (from 2027), however, the level of 
ambition will rise to 35% w/w. This harmonises the EU Ecolabel targets with the revised Packaging 
and Packaging Waste Directive ahead of time.  

The  procurer  can  play  an  important  role  in  promoting  a  circular  economy,  as  the  consistent 
application of such a criterion would help stimulate the market to reap the full potential of plastic 
recyclates. 

Recycled content shall be verified by complying with the EN 45557 or ISO 14021 while recyclability 
shall be verified by complying with the EN 13430 or ISO 18604. 

For  wood  cellulose  fibre,  the  remaining  share  (100  %  minus  recycled  content  percentage)  of  the 
cardboard and/or paper used for the sales and grouped packaging should be SFM certified material 
according to FSC, PEFC or equivalent schemes.  

No use of the composite packaging and guaranteed material recyclability 

The study of the Society for Packaging Market Research (GVM)67 has observed a recent market trend 
to substitute plastic packaging by paper composites packaging i.e., mixing paper with plastic with or 
without  aluminium  thus  creating  multi-material  and  multilayer  product.  While  this  re-designing 
might  favour  some  functional  aspects,  the  embedded  material  heterogeneity  doubtlessly 
complicates or hinders recycling (Walker et al, 2020).  

Since  traditional  single-component  recycling  technologies  are  not  suitable  for  the  composite 
packaging  (due  to  physicochemical  incompatibility  of  the  different  layers,  problems  with  the 
identification of material type, sorting and separation technique, etc) this implies the use of complex 
separation  techniques.  For  example,  for  plastic,  multilayer  waste  scraps  would  first  need  to  be 
partially  or  fully  deconstructed  into  their  constituent  resins  before  being  co-fed  into  processing 

61 See: https://environment.ec.europa.eu/publications/proposal-packaging-and-packaging-waste_en  
62 
Regulations:  (EC)  No  1831/2003  for  animal  nutrition,  (EC)  No  1935/2004  for  materials  and  articles  intended  to  come  into 
contact with food, (EC) No 767/2009 for placing on the market and use of feed, (EC) No 2009/1223 on cosmetic products, 
(EU) 2017/745 on medical devices , (EU) 2017/746 for in vitro diagnosis MD, (EU) 2019/4 for the manufacture, placing on the 
market  and  use  of  medicated  feed,  (EU)  2019/6  for  veterinary  medicinal  products,  Directive  2001/83/EC  for  medicinal 
products for human use, or Directive 2008/68/EC for inland transport of dangerous goods 
63 See: ZWE, 2022: Climate impact of pyrolysis of waste plastic packaging in comparison with reuse and mechanical recycling 
64  ´C
back  into  substances  that  can  be  used  as  raw  materials  for  the  manufacturing  of  plastics  or  other  products.  There  are 
different chemical recycling technologies, e.g. pyrolysis, gasification, hydrocracking and depolymerisation 
65 For 2030 (a) contact sensitive packaging made from polyethylene terephthalate (PET) as the major component; (b) contact 
sensitive  packaging  made  from  plastic  materials  other  than  PET,  except  single-use  plastic  beverage  bottles;  (c)  single-use 
plastic beverage bottles; (d) packaging other than those referred to in points (a), (b) and (c). For 2040  (a)  contact sensitive 
plastic  packaging,  except  single-use  plastic  beverage  bottles;  (b)  single-use  plastic  beverage  bottles;  (c)  plastic  packaging 
other than those referred to in points (a) and (b). 
66 See: Ellen MacArthur Foundation (2019) New Plastics Economy Global Commitment: June 2019 Report 
67 See: Substitution von Kunststoffverpackungen durch papierbasierte Verbunde 

56 

 
                                                        
 
equipment to produce reconstituted multilayer films (Garcia and Robertson, 2017). Furthermore, the 
recycling of fibre-based composite materials must also be processed in specialised paper mills (with 
additional equipment and adequate operating conditions) that enable to reprocess EN 643 paper for 
recycling  of  Grade  568.The  sorted  composite  packaging  frequently  ends  up  being  incinerated  with 
energy  recovery  (De  Mello  Soares,  2022).  To  this  end,  Circular  Economy  for  Flexible  Packaging 
(CEFLEX) has launched a series of voluntary guidelines - Designing for a Circular Economic (D4ACE)69 
  aiming  at  maximizing  the  content  of  recyclable  components  in  the  structures,  avoidance  of 
hazardous or non-recyclables materials, reduction of complexity, among other measures to increase 
packaging recyclability.  

The award criterion AC 5.2 on material recyclability is meant to reinforce technical specification TS 
5.2  and  ensure  that  the  packaging  material  reaches  the  quality  to  be  reintroduced  into  material 
value  chain.  The  requirement  is  verified  by  standardised  test  method  that  guarantees  product 
recyclability such as ATICELCA and PTS test methods.  

Verification of compliance with other Type I ecolabels   

Table 10 outlines the  packaging requirements for the  referenced schemes. Blue  Angel and Nordic 
Ecolabelling  set  extensive  requirements  for  product  packaging,  which  include  the  contents  of 
removable materials or the chemical profile of recycled materials. The exercise is solely focused on 
comparing  the  requirements  across  the  reference  schemes  against  EU  Ecolabel  Criterion  8  and 
therefore only includes the proposed EU GPP criteria.  

Also, the authors consider relevant to mention that Blue Angel DE-UZ 208 foresees changes in their 
requirements  for  packaging,  as  follows:  Packaging  criteria  will  be  reviewed  e.g.,  with  the  aim  of 
promoting the use of a high recycled content in the plastic and paper used for sales packaging for 
products that are also individually packaged. This requirement has only applied to repackaging up to 
now  Within  the  planned  criteria  revision,  the  general  issue  of  material  efficiency  will  also  be 
examined (Blue Angel, 2021). 

Table 10. An overview of the comparison between EU Ecolabel requirements for materials used in packaging 
and other schemes of reference 

Sales Packaging 

Grouped packaging 

Nordic Ecolabelling 

Blue  Angel  DE-UZ 
208 (v.3) 

FSC 
PEFC 

and 

Requirem
ent 

Cardboar
d 
paper  

and 

with 

content 
the 
remaining  %  w/w  of 
SFM-certified fibre 

recycled content 
Remaining  %  w/w  of 
SFM-certified fibre 

For  Sanitary  Products 
(v.6.9) 

For  primary  packaging 
-% w/w of renewable 

and/or recycled. 
Chain  of  Custody  (CoC) 
certified  by  the  FSC/PEFC 
schemes 

For  primary  packaging 
-% w/w of renewable 

and/or recycled 

80%  w/w  of  recycled 
fibre for repackaging. 
Virgin  fibres  must  not 
from 
be 
forests 
are 
particularly  worthy  of 
protection 

sourced 

that 

in repacking. 
Biodegradability 
and 
recyclability  criteria  for 
sales packaging 

Plastic 

Until 

31.12.2026 

content, 

of 

w/w 
content. 

recycled 

ial  and  remaining 

For  sales  packaging 

5 % w/w must be compatible with recycling. 

Not allowed 

and/or  recycled 
primary packaging 

in  the 

Paper/board  must  not  be 
coated 

recycling material 

Not allowed 

Recyclabi
lity 

Composit
e 
packagin
g 

Source: Adopted from EC 2023, Nordic Ecolabelling 2016, and Blue Angel 2021. 

68 See: https://www.cepi.org/the-new-en643/ 
69 See: https://guidelines.ceflex.eu/ 

57 

Certification 
body  for  the 
and 
SFM 
paper 
for 
recycling  

n.a. 

n.a. 

n.a. 

 
 
 
 
                                                        
 
FSC and PEFS are suitable equivalent third-party operated schemes to verify cellulose fibre sourcing 
(both virgin and paper for recycling).  

58 

 
 
 
 
4  Conclusions 

This report provides considerations for defining green criteria in public tenders and aims to motivate procurers 
to reflect on, evaluate and guide their innovation measures and management practises in order to realise the 
full  potential of  green  public procurement. The content of this report could also  be  useful  for evaluating or 
revising  existing  procurement  practises.  It  aims  to  encourage  the  'doers  and  makers'  to  endorse  green 
purchasing and implement procedures capable of advancing sustainable procurement practices.  

Verification  of  compliance  with  such  green  requirements  has  been  facilitated  by  harmonizing  with  the 
environmental criteria already defined and met by the relevant products bearing the EU Ecolabel and, in some 
cases, other equivalent ISO Type I ecolabels.  

The report systematises the knowledge about environmental aspects related to absorbent hygiene products, 
and informs procurers and product manufacturers about the reasons for the chosen environmentally friendly 
sourcing option(s) or recommendation(s) along the value chains of a product.  

The  exact  range  of  products  covered  by  the  EU  Ecolabel  is  explained  to  provide  a  useful  context  for 
purchasers. It provides some background market data based on Eurostat's PRODCOM database and identifies 
relevant Common Procurement Vocabulary codes that should be used when tendering.  

The  AHPs  procurement  is  likely  to  foremostly  satisfy  the  needs  of  health  care  providers  or  alike  public 
administration bodies including  public  home-care service. The labels can  be  used in different phases of the 
procurement process. At the verification stage, ecolabels provide a means of third-

applied in public procurement. Contracting authorities setting requirements that can be met by works, supplies 
or services bearing a specifically cited label (e.g., the EU Ecolabel) shall accept any other labels (e.g., Nordic 
Ecolabel, Blue Angel etc.) as proof of compliance so long as they confirm that the works, supplies or services 
with these other labels also meet the relevant specified requirements of that specified label. 

The  main  environmental  hotspots  were  found  to  be  associated  with  the  upstream  process  (sourcing  and 
manufacturing  of  input  materials).  The  key  impacts  are  linked  to  the  resource  depletion,  energy  generation 
and  consumption  as  well  as  emissions  resulting  from  the  industrial  processing.  Reducing  the  overall 
environmental impact of the AHPs should in the first place, focus on the environmental hotspots, improving 
process  efficiency  and  circularity  of  the  raw  materials  used,  while  maximising  waste  recovery  in  the  pre-
consumer  phase  (both  upper 
  and  core  processes),  and  reuse/recycling  of  packaging  material  in  the  EoL 
phase. 

The EU Ecolabel criteria considered as the most appropriate for the use in recommended EU GPP criteria were 
as follows: 

1.  Fluff pulp sourcing and manufacturing (referring to the impacts associated with upstream processes 

for fibre sourcing and processing); 

2.  Man-made  cellulose  fibre  sourcing  and  manufacturing  (referring  to  the  impacts  associated  with 

upstream processes for fibre sourcing and processing); 

3.  Cotton  and  other  cellulose  seed  fibre  sourcing  and  manufacturing  (referring  to  the  impacts 

associated with upstream processes for fibre sourcing and processing); 

4.  Material efficiency in the manufacturing of the final product Pulp bleaching (referring to the impacts 

associated with core process); 

5.  Packaging (referring to the impact associated with downstream processes. 

Each  criterion  is  followed  by  the  summarised  rationales  and  explanation  of  the  requirement  set  by  EU 
Ecolabel and other type I ecolabels. Brief justifications of why these EU Ecolabel criteria are recommended for 
EU GPP (based on relevance to the subject matter, ease of verifiability and environmental relevance) can be 
found  in  Annex  1.  Finally,  a  comparison  of  how  selected  other  ISO  14024  type  I  ecolabels  compare  to  the 
relevant EU Ecolabel criteria is presented in Annex 2. 

59 

 
 
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62 

 
 
 
 
 
 
 
 
 
 
 
 
List of abbreviations and definitions  

AC 

AHPs 

AOX  

CEPI 

CHP 

CoC 

CPV 

CTMP 

EC 

ECF 

EMAS 

EoL 

FSC 

GPP 

Award Criterion/Criteria 

Absorbent hygiene products 

Halogenated organic compounds 

The Confederation of European Paper Industries 

Combined heat and power 

Chain of custody 

Common Procurement Vocabulary 

Chemi-thermo mechanical pulp  

Exclusion Criterion/Criteria 

Elementary chlorine free 

Eco-Management and Audit Scheme 

End of life  

Forest Stewardship Council 

Green Public Procurement 

IFOAM 

International Federation of Organic Agriculture Movements (IFOAM) 

ISO 

LCA 

NOx 

PEF 

International Standards Organisation 

Life cycle assessment 

Nitrogen Oxides 

Product Environmental Footprint 

PEFC  

Programme for the Endorsement of Forest Certification  

SC 

SFM 

SOx 

TCF 

TED 

TS 

Selection Criterion/Criteria 

Sustainable Forestry Management 

Sulphur Oxides 

Totally chlorine free 

Tenders Electronic Daily 

Technical Specification 

UNEP 

The United Nations Environment Programme 

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
List of figures  

Figure 1. Intended effect of voluntary EU GPP and EU Ecolabel criteria on overall environmental performance 
of defined product groups and services on greening of the market ..................................................................................................8 

Figure 2. Broad overview of different procurement procedures that are used in the EU ...................................................9 

Figure 3. Illustration of how the main different types of procurement criteria can apply ............................................. 11 

Figure 4. Global use of Ecolabels by procurement entities ................................................................................................................ 11 

Figure 5. Sold production value and apparent consumption per PRODCOM product code between 2010 and 
2022 ........................................................................................................................................................................................................................................ 18 

Figure 6. Countries with the highest share of sales of selected absorbent hygiene products 

 Top 5 ................. 18 

Figure 7. Trends in relevant contract notices published on TED for absorbent hygiene products and materials 
(data until October 31, 2023) ................................................................................................................................................................................. 22 

Figure 8. Procurement of the absorbent hygiene products-related CVP codes across different governmental 
bodies between 2015 and Oct 31, 2023 ......................................................................................................................................................... 23 

Figure 9. Trends in EU Ecolabel licenses and licensed absorbent hygiene products over the last 8 years ......... 25 

Figure 10. Distribution of EU ecolabelled products across Member States ............................................................................ 25 

Figure 11. The most relevant impact categories of baby diapers and feminine pads ..................................................... 27 

Figure 12. Overview of the main processes and life cycle stages for the manufacturing of absorbent hygiene 
products................................................................................................................................................................................................................................. 30 

Figure 13. Illustration of two-part screening exercise conducted during the development of this EU GPP report
 .................................................................................................................................................................................................................................................... 32 

Figure 14. Verification hierarchy for GPP criteria based on EU Ecolabel criteria ................................................................. 36 

Figure 15. Reference values for CO2 emissions from different energy sources ................................................................. 44 

Figure 16. Global sustainable and organic cotton production .......................................................................................................... 52 

64 

 
 
List of tables  

Table 1. Relevant CPV codes that could involve EU Ecolabel absorbent hygiene products ........................................... 15 

Table 2. Comparison of CPV and PRODCOM codes and a description of absorbent hygiene products that have 
relevance to the EU Ecolabel ................................................................................................................................................................................... 16 

Table 3. Estimation of production, export, import and apparent consumption in monetary and unit value for 
absorbent hygiene products in 2022.................................................................................................................................................................. 17 

Table 4. Summaries of real-life procurement exercises ...................................................................................................................... 19 

Table 5. Raw materials for possible use in multi-layered absorbent hygiene products .................................................. 26 

Table 6. EU GPP criteria recommendations for the public procurement of absorbent hygiene products in 
relation to selected ISO 14024 type I ecolabels ......................................................................................................................................... 34 

Table 7 EUEL reference values for emissions from different pulp types and from paper production ................... 41 

Table 8. EU Ecolabel reference values for energy consumption during fluff pulp manufacturing ........................... 46 

Table 9. EU Ecolabel emission limit values for viscose and modal manufacturing process ......................................... 50 

Table 10. An overview of the comparison between EU Ecolabel requirements for materials used in packaging 
and other schemes of reference ........................................................................................................................................................................... 57 

65 

 
Annexes  

Annex 1. Explanations of screening of EU Ecolabel criteria for suitability of use in EU GPP criteria  

     Highly recommended       Recommended        Non-recommended 

EU Ecolabel criterion 

Relevance to the subject matter 
(SM) 

Ease of verification without EU Ecolabel 

Environmental relevance 

Recommendation for the use 
as EU GPP recommendation 

Fluff Pulp 

1.1 Sourcing of fluff pulp 

1.2 Bleaching of fluff pulp 

Directly related   cellulose fibre is the 
main raw material for fluff pulp 
manufacturing, which lies among the 
main materials used in a final AHP 
product. 

Straightforward compliance checks without EU 
Ecolabel. 
Verification relies on the common industry practice in 
using sustainable forest management (SFM) 
certification schemes such as PEFC or FSC. 

Indirectly related to the SM  criteria 
apply at the level of the industrial site 
where fluff pulp was made. 

Easy to demonstrate compliance when products do not 
have an EU Ecolabel by means of the supply chain 
verification. Standardised test methods to verify the 
compliance check.  

1.3 Emission of COD and 
phosphorous (P) to water 
and sulphur (S) compounds 
and NOx to air from 
production of fluff pulp 

Indirectly related to the (SM)   criteria 
apply at the level of the industrial site 
where fluff pulp was made. 

1.4 Emissions of CO2 from 
production of fluff pulp 

Indirectly related   criteria apply at 
the level of the industrial site where 
fluff pulp was made. 

1.5 Energy use from 
production 

Indirectly related   criteria apply at 
level of the site where fluff pulp was 
made. 

Easy to demonstrate compliance when products do not 
have an EU Ecolabel by means of the supply chain 
verification. Standardised test methods to verify the 
compliance check.  
Industrial Emissions Directive (2010/75/EU) ensures 
monitoring and reporting of the selected emission 
parameters. 

Easy to demonstrate compliance when products do not 
have an EU Ecolabel by means of the supply chain 
verification. Standardised test methods to verify the 
compliance check.  
Verification supported by the EU Emissions Trading 
System (EU ETS) that requires monitoring and reporting 
of CO2 emissions. 

Easy to demonstrate compliance with if products do 
not have an EU Ecolabel. 
Monitoring of energy consumption by the 
manufacturer- supply chain verification (energy 
consumption). 

Environmental hotspot.  
Related to the circular economy objectives. 

Highly recommended as TS. 

Environmental hotspot.  
An emission to water that occurs during the core 
process of fluff pulp manufacturing and dominates 
the environmental impact (material sourcing).   
Related to the circular economy objectives. 

Environmental hotspot.  
Emissions to water and air that occur during the core 
process of fluff pulp manufacturing dominate the 
environmental impact (material sourcing).   
Related to the circular economy objectives. 

Environmental hotspot.  
Emissions to water and air that occur during the core 
process of fluff pulp manufacturing dominate the 
environmental impact (material sourcing).   
Directly related to the circular economy objectives 
(climate change). 

Highly recommended as TS + 
AC. 

Highly recommended as AC. 

Highly recommended as AC. 

Environmental hotspot.  
Directly related to the circular economy objectives 
(climate change) 

Highly recommended as TS. 

66 

 
 
EU Ecolabel criterion 

Relevance to the subject matter 
(SM) 

Ease of verification without EU Ecolabel 

Environmental relevance 

Recommendation for the use 
as EU GPP recommendation 

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

2.1 Sourcing of man-made 
cellulose fibres 

2.2 Bleaching of man-
made cellulose fibres 

Directly related   cellulose fibre is the 
main raw material for the man-made 
cellulose fibre manufacturing, which 
lies among the main materials used 
in a final AHP product. 

Indirectly related   criteria apply at 
the level of the industrial site where 
man-made cellulose fibre was made. 

Straightforward compliance checks without EU Ecolabel 
- verified relying on a common industry practice in 
using sustainable forest management (SFM) 
certification schemes. 

Environmental hotspot.  
Related to the circular economy objectives. 

Highly recommended as TS. 

Easy to demonstrate compliance when products do not 
have an EU Ecolabel by means of the supply chain 
verification (technology and emission).  
Standardised test methods to verify the compliance 
check.  

Environmental hotspot.  
An emission to water that occurs during the core 
process of the pulp manufacturing dominates the 
environmental impact (material sourcing).   
Related to the circular economy objectives. 

Highly recommended TS+ AC. 

2.3 Production of man-
made cellulose fibres 

Indirectly related   criteria apply at 
the level of the industrial site where 
man-made cellulose fibre was made. 

Easy to demonstrate compliance when products do not 
have an EU Ecolabel by means of supply chain 
verification (technology and emission).  
Standardised test methods to verify the compliance 
check with the emission limit values 

Cotton and other natural cellulosic seed fibres 

Environmental hotspot.  
Directly related to the circular economy objectives. 

Highly recommended as AC. 

3.1 Sourcing and 
traceability of cotton and 
other natural cellulosic 
seed fibres 

3.2 Bleaching of cotton 
and other natural 
cellulosic seed fibres 

Directly related   cotton lies among 
the main materials used in a final 
AHP product. 

Straightforward compliance checks without EU Ecolabel 
by regulatory requirements concerning organic 
production and labelling of organic products 

Environmental hotspot.  
Related to the circular economy objectives 

Highly recommended as TS. 

Indirectly related   criteria apply at 
the level of the industrial site where 
cotton fibre is processed  

Easy to demonstrate compliance when products do not 
have an EU Ecolabel by means of the supply chain 
verification (notification of bleaching technique used).  

Environmental hotspot.  
An emission to water that occurs during the core 
process of fluff pulp manufacturing dominates the 
environmental impact (material sourcing).   
Related to the circular economy objectives 

Highly recommended as TS + 
AC. 

Production of polymers and plastic 

4. Production of synthetic 
polymers and plastic 
materials 

Directly related   synthetic polymers 
and plastic materials form part of a 
final AHP product (including 
packaging). 

Complex verification without EU Ecolabel due to the 
need to qualitatively verify the appropriateness of the 
measures which were used at the manufacturing site 
to reduce environmental impact from material 
processing.  

Environmental hotspot.  
Applicable measures are meant to mitigate 
environmental impact from the production site.  
The magnitude of the improvement potential that 
might be achieved cannot be assessed due to the lack 
of quantitative requirements.  

Not recommended.  

67 

 
 
 
 
Biobased plastic 

5. Biobased plastic 
materials 

Material efficiency 

6. Material efficiency in 
the manufacturing of the 
final product 

EU Ecolabel criterion 

Relevance to the subject matter 
(SM) 

Ease of verification without EU Ecolabel 

Environmental relevance 

Recommendation for the use 
as EU GPP recommendation 

Not recommended. 

Directly related   synthetic polymers 
and plastic materials form part of a 
final AHP product. 

Complex verification without EU Ecolabel due to the 
lack of a comprehensive traceability system in-place. 
Current market performance does not allow 
establishing a min. percentage content of biobased 
plastic in a product.  

Not considered as an environmental hotspot. 
The use of available bio-recourses for bio-plastic 
manufacturing might reduce dependency on fossil 
fuels, e.g. bioSAP. However, an increase use of 
biobased materials does not guarantee an overall 
greater material sustainability as a trade-off impact 
must be individually considered.   

Indirectly related   criteria apply at 
the level of the final industrial site 
where incoming materials are 
processed.  

Relatively easy to demonstrate compliance when 
products do not have an EU Ecolabel by means of the 
quantitative verification of the amount of waste 
generated during the manufacture and packaging of a 
final product.  

Environmental hotspot.  
Resource efficiency and waste reduction at 
manufacturing site directly related to the circular 
economy objectives.  

Highly recommended as TS. 

Excluded and restricted substances 

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

7.2 Substances of Very 
High Concern (SVHCs) 

7.3 Other specific 
restrictions  

Product Packaging 

8. Packaging  

User information 

9. Guidance on the use and 
on the disposal of the 
product and of the 

Directly related - as to SVHC and CLP 
classification, and non-presence or 
conditional requirements of listed 
substances that might remain on the 
final product. 

Difficult to verify the compliance check for product 
without EU Ecolabel. It would require screening of 
chemicals used in a production process followed by the 
relevant declaration of compliance issued by a final 
product manufacturer and upstream supply chain.   

Not considered as an environmental hotspot, except 
for the use of chlorine in bleaching. 

Not recommended. 

Directly related   packaging material 
forms part of a final AHP product. 

Relatively easy to demonstrate compliance when 
products do not have an EU Ecolabel.  

Environmental hotspot. 
Resource efficiency and recyclability requirement for 
packaging - directly related to the circular economy 
objectives. 

Highly recommended as a TS 
(EU Ecolabel sub-criteria 8a and 
8d) and AC (8b and 8c). 

Not relevant 

Easy to verify.  

Not considered as an environmental hotspot, however 
user behaviour determines the EoL phase.  

Not recommended. 

68 

 
 
EU Ecolabel criterion 

Relevance to the subject matter 
(SM) 

Ease of verification without EU Ecolabel 

Environmental relevance 

Recommendation for the use 
as EU GPP recommendation 

packaging 

Fitness for use 

10. Fitness for use and 
quality of the product 

Directly related.  

Easy to verify however fitness for use and product 
quality criteria are considered tenderer-specific  

Social requirements 

11. Corporate Social 
Responsibility with regard 
to Labour Aspects 

User information 

Not relevant. 

12. Information appearing 
on the EU Ecolabel 

Not relevant. 

The AHP products are predominately single-use items 
of a short life-spam. The EoL has not been identified 
as the key contributor to the life cycle impact of a 
product.  

Not recommended. 

Not relevant. 

Not recommended. 

Easy to demonstrate compliance when products do 
bear an EU Ecolabel by means of the third-party 
verification against indicated ILO principles.  

Not applicable without EU Ecolabel. 

Not relevant. 

Not recommended. 

69 

 
 
 
 
 
Annex 2. Indicative information on verifying the EU GPP recommendation for absorbent hygiene products using selected ISO 14024 type I ecolabels 

Additional explanations for the equivalency check are provide in green.  

70 

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70 Commission Decision (EU) 2023/1809 of 14 September 2023 establishing the EU Ecolabel criteria for absorbent hygiene products and for reusable menstrual cups 
71 Nordic Ecolabelling for Sanitary Products , Version 6.9. 14 June 2016 - 31 December 2025, available at: https://api.svanemaerket.dk/api/docs/CriteriaDocumentFiles/7444 
72 Nordic Ecolabelling for Paper Products   
73Nordic 
available 
ecolabel.org/4ac252/contentassets/956d503409fb4a6bb1bb38762bb78da5/basic-module-for-paper-products-2.7_041_printing-companies-and-printed-matter-041_english.pdf 
74 Nappies, feminine hygiene and incontinence products (absorbent hygiene products, AHP) - DE-UZ 208, Basic award criteria, January 2021, version 3, available at: https://www.blauer-
engel.de/en/productworld/nappies-feminine-hygiene-and-incontinence-products 

Ecolabelling 

December 

products 

2025, 

Paper 

for 

31 

- 

 31 December 2025, available at: https://www.nordic-ecolabel.org/globalassets/ai001_3.0_basic_module_cd.pdf 

at: 

https://www.nordic-swan-

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75 Commission Implementing Regulation (EU) 2018/2066 of 19 December 2018 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of 
the Council and amending Commission Regulation (EU) No 601/2012, C/2018/8588 (OJ L 334, 31.12.2018, p. 1) 
76 Commission Delegated Regulation (EU) 2019/331 of 19 December 2018 determining transitional Union-wide rules for harmonised free allocation of emission allowances pursuant to Article 10a of Directive 
2003/87/EC of the European Parliament and of the Council (OJ L 59, 27.2.2019, p. 8) 
77 Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources (OJ L 328, 21.12.2018, p. 82) 

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79 Council Regulation (EC) No 834/2007 of 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) 
80 Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production and labelling of organic products and repealing Council Regulation (EC) No 834/2007, 
PE/62/2017/REV/1 (OJ L 150, 14.6.2018, p. 1). 
81 National Organic Program, A Rule by the Agricultural Marketing Service on 12.21.2000, 65 FR 80547. 

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79 

 
 
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