3 Legislation and regulations

Survey of chemical substances in cleaning products for ovens, cookers and ceramic cooktops

Cleaning products for ovens, cookers and ceramic cooktops are covered by the Danish EPA’s regulation on classification and labelling, regulation on detergents and cleaning agents, regulation on the use of propellants and solvents in aerosol dispensers /2, 3, 4, 5/ and the EC regulation on detergents, which came into force on 8 October 2005, i.e. after the period during which the products assessed in this report were purchased /6/. Below the effect of the above regulations on the labelling of the products is briefly described^[1].

3.1 Regulations for classification and labelling of products

Products, which contain hazardous substances and which must be classified as dangerous, must carry a label in Danish stating the trade name of the substance or product, the volume of the product, chemical names of hazardous substance, hazard class designation, hazard symbols and related R- and S-phrases. Furthermore, the products must be labelled with company name and address of the manufacturer or the company responsible for the marketing of the product.

For products, which must be classified as very toxic, toxic, harmful, corrosive, carcinogenic, mutagenic or reproduction toxic (CMR) in categories 1, 2 or 3, or sensitising, the constituents causing this classification must be stated if they occur in concentrations higher than or similar to the lower concentration limit for classification. Products labelled very toxic or toxic (including CMR substances in cat. 1 and 2) must not be sold to private consumers.

Products not classified as sensitising, but containing a sensitising substance in a concentration above 0.1 %, must be labelled with the name of the substance and information that it may produce an allergic reaction.

If the products are for industrial use, there are further demands to the preparation of safety data sheets/supplier’s instructions for the products (Danish Executive Order No. 559 issued by the National Working Environment Authority on 4 July 2002 on Special Duties of Manufacturers, Suppliers and Importers, etc. of Substances and Materials pursuant to the Danish Working Environment Act). Classified products for industrial use sold in volumes of more than 100 kg per year must be registered in the Danish Product Register by the manufacturer/importer/distributor before the product is released on the market.

3.2 Regulations for detergents and cleaning agents

According to the statutory order on detergents and cleaning agents, which applied during the period of the purchase of the products (Danish Statutory Order No. 884, 2002), the packaging of a product should be labelled in Danish with the aim of application together with name/company name and address or registered trade mark belonging to the company responsible for the marketing. The primary biodegradation of the surface-active substances (surfactants) in the products must be at least 90 % (measured as the removal of surface-active properties). Furthermore, the EU Commission has made a recommendation of 13 September 1989 on labelling of detergents and cleaning products /7/), that the contents expressed in percentages of a number of constituents, including a.o. surfactants, are declared on the packaging within fixed ranges. Preservatives/disinfectants must be stated irrespective of concentration.

The Danish Statutory Order No. 884 and the EU Recommendation were as from 8 October 2005 replaced by the Regulation of the European Parliament and of the Council No. 648/2004 on washing and cleaning products (the detergent regulation) /6/), in which it is specified that the contents of selected substances must be stated in weight percentage ranges. The contents of aromatic/aliphatic hydrocarbons, which are some of the substances identified in this survey, must be stated on the packaging if the contents exceed 0.2 weight percentages of the product. Enzymes, disinfectants, optical brighteners and fragrance must be stated irrespective of their concentration. Furthermore, preservatives must be stated using their INCI names (International Nomenclature Cosmetic Ingredient: common nomenclature for cosmetics), if possible. Furthermore, there is a demand for supplementary labelling of the products regarding 26 named allergenic fragrances. If they are used in concentrations larger than 0.01 weight percentage, it must be stated on the packaging. For surfactants used in the products, requirements are made to complete aerobic biodegradability.

3.3 Regulations for propellants and solvents in aerosol dispensers

Oven cleaners as sprays (aerosols) are comprised by the statutory order on the use of propellants and solvents in aerosol dispensers (Danish Statutory Order No. 571, 1984). In annex 1 of the order, the propellants and solvents that can be used in aerosol dispensers are specified together with the limitations and conditions for their use. The list contains 36 different substances. In addition, the products are comprised by the executive order on aerosols issued by the National Working Environment Authority (Danish Executive Order No. 844, 1994), which gives the rules for correct labelling of aerosol dispensers.

3.4 Assessment of purchased products according to labelling rules

An assessment of the information available in the listings of ingredients and safety data sheets of the products and chemical analyses indicates that 4 of the 21 purchased products were not correctly labelled and classified in accordance with the regulations of classification and labelling of chemical substances and products /3/. According to the chemical analysis, product no. 1 contained solvents in a concentration causing the product to be labelled ‘Irritant’, while for products 6, 18 and 20 there was no obvious consistency between risk phrases and labelling. The products 18 and 20 were labelled with risk phrases showing that the products contained solvents in concentrations that caused the products to be labelled ‘Harmful’ and ‘Dangerous for the Environment’, respectively. For the remaining products, no violation of the regulations on classification and labelling was observed.

Based on the available data, two of the products (products nos. 4 and 6) were assessed to comply with the labelling regulations in the EC regulation on detergents, which came into force on 8 October 2005, at the time of their purchase (May - July 2005).

[1] Please note that the regulations mentioned were in force in 2006. The existing regulation may be found at www.retsinfo.dk or www.mst.dk