The European Ecolabel is a voluntary scheme, established in 1992 to encourage businesses to manufacture and market products or services that are more environmental friendly.
Products and services awarded the European Ecolabel carry the flower logo, thereby allowing consumers - including public and private purchasers - to identify them easily.
Today the EU Ecolabel covers a wide range of products and services, with further groups being continuously added.
(See "http://ec.europa.eu/environment/ecolabel/index_en.htm"EU. DG Env. For general information on Ecolabelling)
Some Member States have established their own ecolabel
scheme. The most important 3rd party certified labels besides the EU Flower are the Blue Angel (Germany) and the Nordic Swan (Nordic countries), which have both been established before the Flower. Other well-known labels are TCO (Sweden) or the Green Label (UK). The criteria and requirements between these labels are often not harmonized which leads to challenges for the industry.
Over the last few years, the EU Flower has established or revised criteria for a number of products. Many of these products, like consumer electronics or furniture, can contain flame retardants.
Current EU Ecolabel approach to flame retardants
No EU Ecolabel criteria for any product group, bans the use of all flame retardants, nor does the EU Flower discriminate against a certain flame retardant family or technology.
The approach taken in most criteria adopted to date is to exclude those flame retardants or chemicals in general from labelled products, which have certain specific properties (risk phrases) and for which these properties are not modified once the flame retardant is incorporated into the treated product: The EU Flower must not be awarded to products with preparations/mixtures that are classified “as toxic, hazardous to the environment, carcinogenic, mutagenic or toxic for reproduction (CMR)” (Regulation (EC) No. 66/2010) In contrast to that, the Blue Angel and the Nordic Swan exclude certain types of flame retardants, in addition to certain restricted R-phrase substances.
Hazard or risk based approach
This assessment of flame retardant eligibility for use or not in ecolabelled products using “R-phrases”, is obviously preferable to blanket exclusions of certain families of products, which fail to take into account the considerable differences in chemical, health or environmental properties of substances within each flame retardant family. Therefore, EFRA believes that every substance should be treated and assessed individually and that Ecolabel criteria development should be based on sound science.
Flame Retardants should also not be singled out in EU or national Ecolabel criteria but be treated as any other chemical, regardless of their function as flame retardant, as acknowledged by the recently adopted criteria mentioned in footnote 1.
However, for EFRA the definition of ecolabel criteria using “R-phrases” is not always appropriate. These regulatory labelling phrases define hazards of chemicals as manufactured – thus many chemicals will require certain R-phrases when delivered pure, but not when in lower concentration or incorporated in a polymer matrix. In fact, the R-phrases take no account of exposure and thus risk to the environment, or to health issues through the use of the chemical in consumer products.
The long list of restricted R-phrases might also lead to issues regarding technical feasibility, common market and industry practices and limited (technology) choices.
Example of hazard statements/risk phrases excluded by Ecolabel criteria H300-R28 Fatal if swallowed
- H351-R40 Suspected of causing cancer.
- H411-R51/53 Toxic to aquatic life with long-lasting effects
- H412-R52/53 Harmful to aquatic life
- H413-R53 May cause long-lasting effects to aquatic life
These should be addressed by risk assessments, taking into account the concentrations at which flame retardants are actually used in consumer products, the fact that in all cases, they are designed to remain within the product materials (by definition, in order to provide ongoing fire protection over time), as has been done in official Risk Assessment for various flame retardant substances, conducted by European Union or Member State authorities.
1 for example: personal computers (2011/337/EU), notebook computers (2011/330/EU), television sets (2009/300/EC)