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FOD VOLKSGEZONDHEID, VEILIGHEID VAN DE VOEDSELKETEN EN LEEFMILIEU

CB FORUM

22nd March 2017


1 Welcome

New participants?

- Tour de table

- Practical information

2


1 Welcome

Adoption of the agenda:

• Point 9 Soil improvers

• Germany: Aldi & Logo

• AOB requests?

Approve of minutes of November?

3


2 EU Ecolabel updates4


3 Cleaning5


6


9 Soil improver DK7


4 Converted paper products - logo8

CB Forum Meeting

23/03/2017

Questions raised by

French CB

Murielle GAUVAIN

10

CONVERTED PAPER PRODUCTS

(2014/256/EU)

AFNOR Certification - CB FORUM

Problems with paper components, such as stickers, labels, etc…, and

especially with the interpretation given in the User Manual, page 7:

A ‘final converted paper product’ consists of all fixed components (paper based or

not) intended to be used by the end-consumer during the use phase (e.g. rulers,

dividers, name tag, elastic, eyelet, pocket etc.). The final converted paper product

can refer to one sale unit of product. All fixed components referring to packaging

purpose but sold or provided with it (e.g. stickers for Gencod etc.) are not included

in the final product only if:

- the EU Ecolabel is not intended to be placed on them,

- it's not intended to the use of the end-consumer,

- it can easily be removed before use by the end-consumer.

All other fixed components (not intended to be removed) and intended to be used

by the end-consumer (e.g. labelling paper, back label for binder etc.) shall fulfil the

requirements of the Annex to the Decision 2014/256/EU.

Components that are not fixed to the converted paper product (such as flyers,

removable stickers, promotional materials) but sold or provided with it, shall fulfil

the requirements of the Annex to the Decision 2014/256/EU only if the EU

Ecolabel is intended to be placed on them.

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(2014/256/EU)


a. Cardboard folders

Manufacture: cutting and folding, no printing. So no marking.

Sold by 10, under plastic film, with a mobile sheet (“flyer”): not part of the

article, but presents the necessary information (name of the article, number,

image).

b. 3-flap folders

Manufacture: cutting and folding, no printing. So no marking.

A removable sticker for Gencod is affixed on the 3-flap folder.

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(2014/256/EU)


In these two cases, the best option to have the EU Ecolabel logo is to place

it on the flyer in case a, and on the sticker, in case b, in order to avoid an

unnecessary printing phase on the product.

But, according to the UM, in these cases, those elements shall fulfil the

requirements of the Annex to the Decision 2014/256/EU, and the feasibility is

very complex.

Consequently, we would like to recommend, in these cases, that the

flyer/removable sticker be considered as part of the packaging, and no

requirement should apply, even if the EU Ecolabel logo appears on it (as it is

the case, for example, for copying and graphic paper).

Do you share this recommendation?

Furthermore, applicants have also difficulties to source labels such as back

label for binder ( i.e. to be used by the end-consumer), that meet the

requirements of the Annex to the Decision 2014/256/EU. Do other CBs have

the same feedback?

13

Thank you for listening


[email protected]

00331 41 62 61 11

www.ecolabels.fr

mailto:[email protected]


5 Packaging

Italy: Packaging criterion Rinse-off cosmetics

Austria: Detergents: new packaging criterion

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The IT CB found on the

market 40 ml EU

ECOLABELLED shampoos

and shower gels

sold to hotels as courtesy

products.

5.a : RINSE OFF COSMETIC PRODUCTS

SECONDARY PACKAGING

THESE PRODUCTS would not be

assessed as compliant by the IT

CB (would not pass cr. 4.b)

Complaint by Italian producers!

Possible market distortions


SECONDARY PACKAGING

Definition Art. 2.3-4 Decision 2014/893/EU‘primary packaging’ means packaging in direct contact

with the content conceived so as to constitute the smallestsales unit of distribution to the final user or consumer at thepoint of purchase;

“secondary packaging” means packaging which can be

removed from the product without affecting its

characteristics and is conceived so as to constitute at the

point of purchase a grouping of a certain number of sales

units whether the latter is sold as such to the final user orconsumer or whether it serves only as a means to replenish

the shelves at the point of sale.


SECONDARY PACKAGING

“secondary packaging” means

packaging which can be removed

from the product without affecting

its characteristics and is conceived

so as to constitute at the point of

purchase a grouping of a certain

number of sales units whether the

latter is sold as such to the final user

or consumer or whether it serves

only as a means to replenish the

shelves at the point of sale.

POINT OF PURCHASE: HOTEL

18

Cr 4.b: Packaging Impact Ratio (PIR)

PIR in case of no refill = (W + N)/D

W —weight of packaging (primary + proportion of secondary,

including labels)(g)

N —weight of non-renewable + non-recycled packaging (primary + proportion of secondary (1), including labels) (g)

D —weight of product contained in the ‘parent’ pack (g)

PIR MUST BE <0.28

19

Cr 4.b: Packaging Impact Ratio (PIR)

PIR WITHOUT CONSIDERING SECONDARY PACKAGING

WOULD COMPLY with the criterion

PIR CONSIDERING SECONDARY PACKAGING

WOULD NOT COMPLY with the criterion

EXAMPLE

secondary packaging example.xlsx

20

Logo Guidelines not respected

Background : Brown

Less than

10.6mmx10.6mm

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QUESTIONS TO CBs:

1) DO YOU ALWAYS CONSIDER SECONDARY PACKAGING

WHEN ASSESSING PIR in ROCs?

2) DO YOU ALWAYS ASK FOR THE FULL RESPECT OF

the current LOGO GUIDELINES even for SMALL PRODUCTS?


Lunch 13h – 14h

Thank you for being back in time…

22


6 ECAT

Italy: Packaging criterion Rinse-off cosmetics

Austria: Detergents: new packaging criterion

23


7 Communication24


8 Virtual CB Forum questions25

30/11 SI (discussed today)

1/12 Buttons

8/12 Multi-component systems

9/12 AHP – SAP

20/02 Laundry detergents – duvet

28/2 Printed paper – deadline 21st March

1/3 Plant response: Water cress versus Chinese cabbage – deadline

22/3

13/3 IILD & IIDD: Hazardous substances – deadline 27/3

14/3 IILD: Neutralizer – deadline 28/3


26


10 Classification for substance evaluation


11 Any other business & Closing remarks28


Back-up slides Virtual CB Forum questions29


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