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The EU Eco-label and Health 7 Conclusion and recommendations
Analysis of the coverage of health aspects in the EU regulationThe Regulation includes a number of basic requirements regarding health aspects. It is a prerequisite for obtaining an eco-label license for substances and preparations that the substance or preparation is not classified as toxic to human health. Presently, the product groups for which eco-label criteria have been elaborated cover 5 types of preparations (various detergents, paint and lacquer) and no substances. From the text, the base line requirements relate to substances and preparations. Hazardous substances are very seldom purchased by consumers and therefore no criteria would be expected to be elaborated for such substances. The overall coverage of the Regulation could therefore be restricted to preparations alone. It could be worthwhile to try to extend the overall criteria to exclude very toxic substances, PBT, and CMR substances at all from eco-labelled products. This could be a strategic choice to position eco-labels as more stringent than the (forthcoming) REACH regulation. For goods the requirements are less specific. It is stated that the processes of manufacture “may not significantly harm man and/or environment” and the normal application of the goods may not harm the consumer. In practice, the requirements for preparations are relatively stringent while those for goods are minimum requirements, i.e. that goods shall comply with legislation. It is recommended, that
Analysis of the coverage of health aspects in 6 criteria documentsThe analysis of the criteria documents for the chemical preparations and products selected do show that the health-related criteria covered are more stringent for most parameters than the requirements of the related chemicals legislation. The analysis thus supports the conclusion from another study reported in 2004 prepared by BEUC /15/. The analysis also indicates a varying coverage of health aspects. Although not required only one of the criteria documents actually covers all requirements listed in the scope of the regulation. Some of the criteria documents, however, include other aspects than those listed in the Regulation, e.g. requirements regarding sensitization and hormone disruptive substances. The relevance of health and environmentally related limits for chemicals may vary for different product groups. It is interesting, however, to note that about three quarters of the specific limit requirements in the 6 criteria documents relate to environmental aspects, while around half of the requirements (also) relate to health aspects. Therefore, in practice there is a relative balanced coverage between health and environmental issues. Workers environment is only indirectly covered as the use of highly hazardous substances as raw materials are restricted. There are, however, no requirements regarding auxiliary substances and preparations and no requirements for other aspects related to occupational health (physical environment). It is recommended that
A more balanced focus on environment and health in the regulationThe Eco-label should take into account consumer preferences as an important part of the coverage of criteria documents to facilitate licensees’ successful marketing of labelled products. Although the analysed criteria documents indicate a relative good balance between health and environmental requirements this is not reflected in the Regulation. As a minimum, it should be considered to update the Regulation to cover the state-of-the-art regarding health coverage in the criteria documents. It is suggested that a succeeding revision of the Regulation be more progressive in order to be in line with consumer preferences and potential applicants’ focus on sustainable development. A number of amendments of the articles of the Regulation are proposed in the present report to balance the scope regarding health and environment. If this balance is to be achieved in the ongoing Regulation revision, also the methodological foundation needs revision. In addition to the guidance regarding health assessment mentioned above, also a life cycle framework for health assessments would be required in the form of a supplement to Annex 1 of the Regulation regarding an “indicative assessment matrix” for both environment and health. It is recommended that
REACH and the EU eco-labelThe new EU regulation for chemical substances (REACH) is expected to be adopted in 2007 with an 11 years’ implementation period. The new regulation aims at ensuring that chemical substances produced or imported above a certain tonnage level are not to be marketed, unless the producer or importer is able to ensure that the substance may be used without significant harmful effects to health and environment. The Eco-label Regulation and criteria documents should be positioned ahead of the implementation of REACH to facilitate those industry branches/companies implementing the regulation ahead of the implementation deadline with an information tool to signalise this proactive measure to the customers. According to REACH highly hazardous substances will require an authorisation before they may be used. The category of substances to be covered by an authorisation is carcinogenic, mutagenic and repro-toxic substances, highly toxic substances, and persistent and bioaccumulative substances. Other substances of concern may be subject to authorisation as well. The Eco-label regulation should set requirements to facilitate that such substances be gradually eliminated from eco-labelled products (preparations and goods). It is recommended that
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