Guido Bottini – Suzhou – March 18, 2010 ICE - TBD Textile Training Course 2010.

Guido Bottini – Suzhou – March 18, 2010

ICE - TBD Textile Training Course 2010ICE - TBD Textile Training Course 2010


SUMMARY

1. Mandatory environmental legislations involving textiles

2.2. (Semi) Voluntary environmental (Semi) Voluntary environmental requirementsrequirements

3.3. Future developments in the EU Future developments in the EU regulationregulation

4.4. Consumers’ awarenessConsumers’ awareness


Mandatory environmental legislations

1. REACH [Regulation (EC) 1907/2006]

2. IPPC (Directive 2008/1/EC)

3. ETS (Directive 2009/29/EC)

4. Ecodesign Directive (Directive 2009/125/EC)


REACHRegistration, Evaluation, Authorization of CHemicals

substance: means a chemical element and its compounds in thenatural state or obtained by any manufacturing process, includingany additive necessary to preserve its stability and any impurityderiving from the process used, but excluding any solvent whichmay be separated without affecting the stability of the substance orchanging its composition;

mixture (preparation): means a mixture or solution composed of two or more substances;

article: means an object which during production is given a specialshape, surface or design which determines its function to a greaterdegree than does its chemical composition;


3 deadlines for registration

November 30, 2010: substances > 1.000 t/y

May 31, 2013: substances 100 < t/y < 1.000

May 31, 2018: substances 1 < t/y < 100


Function of an article

The term “function” in the article definition should be interpreted as meaning the basic principle determining the use of the object rather than the degree of technical sophistication determining the quality of the result. In this sense, it may be helpful to look at the result of using an object and pay less attention to the quality of the result.

Shape, Surface, Design

Shape means the three-dimensional form of an object, like depth, width and height. Surface means the outermost layer of an object. Design means the ar-rangement of the “elements of design” in such a way as to best accomplish a particular purpose. For example, the design of a textile may be determined by the twist of fibres in the yarn, the weave of threads in a fabric and the treatment of the surface of the textile.


Registration and notification of substances in articles (Art. 7)


Intended release of substances from articles

A release of substances from articles is intended if it fulfils an accessory function (to be differentiated from the main function according to section 2.1) which is deliberately planned and would not be achieved if the substance were not released.e.g. in the case of scented articles, the fragrance substances need to be released in order for the article to be smelled.

Substances that are released because of ageing of articles, because of wear and tear or as an unavoidable side-effect of the functioning of the article, are generally considered not intended releases, as the release as such does not provide a function in itself.


Cases not considered as an intended release:

1. A release occurs during processing of a semi-finished article, i.e. before marketing as a finished article.

Example: a size is added to a fabric to improve its processability, whereas the size is released again during further wet processing of the textile.

2. A release occurs during use or maintenance of the article, but the released substances do not contribute to any function of the article. Example: washing of clothes by the consumer where remnants of different chemicals (dye, softener, starch, etc.) from processing are removed over some washing cycles.

3. A release of substances is an unavoidable side effect of the functioning of the article, but the release does not contribute to the functioning of the article. Examples: wear and tear of materials under conditions of high friction, e.g. break linings, tyre; leakage of lubricant used to reduce the friction between two moving parts.


4. A release of substances formed during chemical reactions of any kind. Example: ozone released from copy machines, or release of combustion products from articles catching fire.

5. A release in an accident. Example: release of substances from a thermometer that drops and breaks.

6. A release caused by a long-term, extremely intensive use of an article. Example: release from a tool, which a consumer uses in disregard of the recommendations on operating time provided in the instructions of use.


Normal conditions of use means the conditions associated with the main function of an article.

Reasonably foreseeable conditions of use mean conditions of use that can be anticipated as likely to occur because of the function and appearance of the article (even though they are not normal conditions of use).


Calculation of tonnage of a substance intended to be released

A T-shirt contains a fragrance substance intended to be released. Assumption: The fragrance substance constitutes a maximum of 5% by weight of the T-shirt, which is produced in an amount of 100 t/a. The fragrance substance is not contained in other articles of the same producer.

Conclusion: The threshold of 1 t/a is exceeded; the producer of the T-shirt must register the fragrance substance.

Not only the amounts intended to be released but the total amount in the articles needs to be considered.

If the same substance is intended to be released from different articles of one producer/importer, the volumes of this substance in all those articles have to be summed up


Substances of very high concern

Substances fulfilling the criteria defined in Article 57 of the REACH Regulation and can be put on the “candidate list for authorisation”:

• carcinogenic, mutagenic or reprotoxic (CMR) substances category 1 or 2

• persistent, bioaccumulative and toxic (PBT) substances or very persistent and very bioaccumulative (vPvB) substances

• substances for which there is evidence for similar concern, such as endocrine disruptors

Substances in “candidate list” does not mean “banned”


Notification of substances in articles

It is required when all conditions of Article 7(2) are met.

The obligation to notify substances in articles also applies to packaging materials, which may be produced or imported separately as packaging of imported goods. Packaging is to be assessed sepa-rately from any object it contains.

A notification of substances in articles shall be made at the latest 6 months after it has been included on the candidate list of substances for authorisation, but only starting from 1 June 2011.


Information to be notified:

• the identity and contact details of the producer or importer of the articles

• the registration number for the substance, if available

• the identity of the SVHC (this information is available from the candidate list and the support-ing documentation)

• the classification of the substance (this information is available from the candidate list and the supporting documentation)

• a brief description of the use(s) of the substance in the article(s) as specified in section 3.5 of Annex VI and of the uses of the article(s)

• the tonnage range of the substance contained in the articles, i.e. 1-10 tonnes, 10-100 tonnes, 100-1000 tonnes or ≥1000 tonnes


Obligations according to Article 33

The information is to be provided to the recipients automatically, i.e. as soon as the substance has been included on the candidate list for authorisation. Note that the term “recipients” refers to industrial or professional users and distributors, but not to consumers.

Information available to the article supplier necessary to ensure safe use of an article has to be provided also to consumers upon request (Article 33(2)). Consumers have to be provided with this information within 45 days of the request, free of charge.


Obligations according to Article 33 (follows)

There is no tonnage trigger for these obligations (i.e. they also apply below 1 tonne per year).

A packaging is always to be treated as an article separate from the contents of the packaging. Therefore, the obligations to communicate information on substances in articles also apply to packaging materials.

The substance concentration threshold of 0.1% (w/w) applies to the article as supplied. Like in the context of substance notification, it does not relate to the homogeneous materials or parts of an article, but to the article as such.

The obligations also apply to articles which were produced or imported before the substance was included in the candidate list and are supplied after the inclusion. Thus, the date of supply of the article is the relevant date here.


Calculation of the average concentration of a SVHC in an article

A chair consists of a wooden part and a plastic part. The weight of the chair is 2.001 kg. The wooden part of the chair contains 10 mg of an SVHC. The weight of the wooden part is 2 kg. The plastic part of the chair contains 1 mg of the same SVHC and weighs 1 g. The concentration of the SVHC in the chair is calculated using the formula above.

Conclusion: The average concentration of the SVHC in the chair does not exceed 0.1% (w/w). Obligations according to Article 7(2) and 33 do not apply.


Calculation of the total amount of a SVHC in different articles

A company imports 20000 pairs of shoes, 3000 belts, and 60000 bags per year into the EEA. A pair of shoes contains 0.05% (w/w) of a SVHC on the candidate list, a belt contains 0.15% (w/w), and a bag contains 2% (w/w) of the same SVHC. The weights of these articles are 0.7 kg per pair of shoes, 700 g per belt and 1 kg per bag.The concentration of the SVHC in the belts and bags is above 0.1% (w/w). The total amount of the SVHC in each article type produced and/or imported per year with a concentration of the SVHC above 0.1% (w/w) is calculated using the formula above.


Summing up the values obtained for each article type, the total amount of the SVHC in all articles produced and/or imported, which contain more than 0.1% (w/w) of the substance, is obtained.

Conclusion: The total amount of the SVHC in all articles produced and/or imported, which contain more than 0.1% (w/w) of the substance is over one tonne per year. Hence, the company has to submit a notification for the SVHC in the bags and the belts. Furthermore, the company has to provide information for both the belts and the bags according to Article 33 of the REACH Regulation.


Information to be supplied

As a minimum, the name of the SVHC shall be provided. Article 33(2) requires the same type of information to be forwarded to consumers upon request.

What other information shall be provided?

• what the downstream life-cycle stages of the article are up to final disposal (transport, storage, uses)

• what the potential routes of exposure are during each of these life-cycle stages

• what the hazards of the SVHC are for human health and the environment

• what types of exposure control / personal protection measures are likely to be appropriate during each of the life-cycle stages in order for the handling of the article to be considered safe.


Format for provision of information

REACH does not specify a format

Possible formats:

• existing documents, such as instructions for use and packaging;

• information on labels;

• link to a website with up-to-date information (such a link alone would not be sufficient since the information would then not be readily available);

• standard communication formats developed by industry sector associations.


Illustration of the decision process

Example: Cloth with lemon scent (D-limonene)

Are you the first EU producer or importer of the object? YES.

Is your object an article?YES. The company imports cloths which are articles, because the shape determines their function.

Is there an intended release of substances from the article?Substances are released during the use of the article. The release is an additional quality of the cloth and the release is therefore intended, otherwise the article would not smell.


Does the article contain a SVHC included in the candidate list?

As the importer has no information except the results from the chemical analysis he could do the following:

1) Collect information on sector knowledge and typical content of substances in this type of article, e.g. standards. He would compare that information with the candidate list for authorisation and may have doubts whether he can exclude the presence of SVHC. He does not find information on the fragrances intended to be released.

2) Check the supply chain requesting if any of the substances on the candidate list is included in the article or the substances/mixtures used to produce the article or receive confirmation that SVHC are not present in the article. Check the supply chain and ask if the supplier of the fragrance substances can be identified. If yes, the importer of cloths may try to obtain a safety data sheet.


4) Check if identified substances are listed on the candidate list (The emission test revealed the presence of compounds classified with R50/53 and R51/53. These compounds may potentially fulfil the criteria as PBT/vPvB substances, and thus be identified as SVHC).

5) Calculate the amount of substances identified in the screening analysis and assess whether the tonnage threshold for registration could be exceeded.

Work process for calculating the amount:

Is the total volume of articles > 1 t/a (all articles should be considered and summed up)?YES. 1 million cloths, each cloth with 2 g of parts containing fragrance makes a total volume of articles of at least 2 t/a.


Is the total amount of the fragrance mixture > 1 t/a (all such articles in a company should be considered)?YES. The total volume of fragrance is approx. 2 t/a.

Identify each substance intended to be released from the article.A total of 11 fragrance compounds were identified to be contained in the cloth. During the emission test various compounds were detected and some of the detected compounds were identified with a CAS number and classification.

The output from the analysis was the substance name only. The C&L inventory to be established should be consulted in order to obtain a CAS number and classification.

Further steps in this case are focused on D-limonene, which was identified in the chemical analysis.


Substances exempted from registration? NO.

Check for existing registration for that use. The substance has not been registered.

Determine the amount of each substance intended to be released (all such articles in a company should be considered and summed up) Based on the chemical analysis, the content of D-limonene intended to be released is determined to be 800 mg/kg in the inner part of the cloth. The content of D-limonene in the cloth is 1.6 mg as the weight of the inner part was 2 g.

Total amount > 1 t/a? It is assumed that this cloth is the only article containing D-limonene and imported by the company. The annual amount of D-limonene is calculated to be 1.6 kg/a, which is below 1 t/a.

Registration of D-limonene in the cloths is not required.


Example: DEHP in bath mattresses

Are you the first EU producer or importer of the object? YES.

Is your object an article?YES, the bath mattress is an article.

Is there an intended release of substances from the article?NO.

Conclusion on registration: No need for registration.


Does the article contain a SVHC included in the candidate list?YES. DEHP has been included on the candidate list.

Determine the concentration of the SVHC, which in this example is DEHP. To determine the concentration limit the company asked its supplier for information. The supplier informed that the concentration of DEHP was 30% (w/w) in the mattresses. No test protocols were available from the supplier to confirm concentration levels and the company did not find any reason to question the information given by the supplier.

Concentration above 0.1% (w/w)? YES. The concentration of DEHP in the bath mattresses exceeds the threshold limit of 0.1%


Conclusion after this step: communicate information according to Art. 33.

As the bath mattress contains more than 0.1% DEHP and is distributed to retailers within the EEA. The company has to give information to allow safe use of the article. Information to be considered as important is the following:

• Substance name: di(ethylhexyl)phthalate • CAS. No: 117-81-7 • Registration No: not available for the time being • Classification: R 60-R61, the substance is classified as toxic and toxic to reproduction, i.e. the substance causes reduced ability to reproduce and damage to the unborn child • Exposure control: Avoid long term dermal contact by children or pregnant women


Is the SVHC intended to be released? NO.

Has the substance already been registered for that use? NO. It is assumed that DEHP is not registered for that use.

Determine the amount of the SVHC (DEHP) present in all articles?

The DEHP concentration in the mattresses is > 0.1% and therefore, the total amount of DEHP brought into the EEA in the mattresses has to be considered. The total amount of DEHP per year in all imported mattresses is: The import of mattresses the year before: 150,000 items The weight of one mattress: 900 g The maximum DEHP concentration in a mattress: 30% (w/w) The total amount of DEHP:(30 0.1) (900 10⋅ ⋅ ⋅ -6) 150,000 = 40.5 t/a ⋅


Is the total amount of the DEHP > 1 t/a?YES. The total imported amount of DEHP is 40.5 t/a. This amount exceeds the threshold limit of 1 t/a.

Can exposure be excluded during normal or reasonable foreseeable conditions of use?

The function of the substance in the articles: Plasticisers are not permanently bound to the PVC polymer, and phthalates are therefore released from plastic products throughout their lifetimes.

The use(s) of the article: Normal use(s): In bath mattresses for adults. Reasonably foreseeable use(s): It is very likely that the mattresses also will be used by children or fertile women.


Potential for emission during use(s) and disposal – Looking at the routes of exposure: Dermal exposure could be considered to be the most likely way of exposure. It could be assumed that naked skin often would be in direct contact with the article during use. Exposure through inhalation may occur if the article is used in-doors. Exposure through ingestion is also possible as it could be considered to be reasonably foreseeable that children might suck on the mattress, although due to the size and shape of the product exposure through ingestion is regarded as limited. Furthermore as the product is mainly used in direct sunshine at temperatures above 20 degrees the temperature of the material could be 50 degrees, which could contribute to a considerable emission of DEHP.

Can exposure to humans or the environment be excluded? NO

Conclusion: Notification is required


Why is important to supply information on substances?

Chemical analysis of substances in articles• theoretically, substances contained in articles can be identified and their concentrations quantified by applying analytical methods.

• chemical analysis may thus be a “last resort”

• chemical analyses may yield ambiguous results and/or be very costly and are thus not recommended as the preferred instrument for obtaining information.

• articles may be very complex and composed of different parts and materials. It is therefore dif-ficult to create a sample for the analysis that represents the whole article

• substances that are included in the article matrix may have to be extracted from it

• various analytical methods are available to screen for the existence and identification of differ-ent substances in a sample


But mainly because:

• obligations to register or notify substances in articles identified as described in chapters 3 and 4 do not apply in certain cases

• a registration or notification of a substance in articles is not required, if the substance has already been registered for that use (i.e. the use by which the substance is included in the articles)

A substance is considered to have already been registered for a particular use, if two conditions are fulfilled:

• the substance in question is the same as a substance that has already been registered

• the use in question is the same as one of the uses described in a registration of this substance that was already made

and doing so will not stop your own business!!!


Notification is not required if the producer or importer of articles can exclude exposure to humans or the environment during normal or reasonably foreseeable conditions of use, including disposal.

We are working on it but it is not simple!


EXPOSURE SCENARIOS

USE DESCRIPTOR SYSTEM

Based on 4 elements:

- Sector of Use (SU)

- chemical Product Category (PC)

- PROcess Category (PROC)

- Article Category (AC)

The list of Article Categories cover both article with intended release of substances and article with not intended release.


PARTS OF THE REACH REGULATION OF PARTICULAR RELEVANCE

Article 3(3) provides the definition of an article for the purpose of the REACH Regulation

Article 7 defines under which circumstances article producers and importers have to register or notify substances in articles

Articles 23 and 28 specify the deadlines for pre-registration and registration of phase-in substances

Articles 29 and 30 create the data sharing obligations of registrants and the obligation to participate in Substance Information Exchange Fora (SIEF)

Articles 57 and 59 contain the criteria for substances of very high concern (SVHC) and the procedure for inclusion of substances in the candidate list of SVHC for authorisation

Article 33 defines the duty of article suppliers to communicate information on SVHC in their articles to recipients and consumers

Annex XVII lists conditions of restrictions, which may pertain to certain substances in articles


Link for ECHA

http://www.echa.europa.eu/reach/legislation_en.asp


IPPC - Directive 2008/1/EC

- a set of common rules for permitting and controlling industrial installations

- minimising pollution from various industrial sources

- operators of industrial installations covered by Annex I obtain an authorisation (environmental permit) from the authorities in the EU countries


Based on several principles, namely:

1. an integrated approach: take into account the whole environmental performance of the plant, covering e.g. emissions to air, water and land, generation of waste, use of raw materials, energy efficiency, noise, prevention of accidents, and restoration of the site upon closure ensure a high level of protection of the environment taken as a whole

2. best available techniques (BAT): after an exchange of information between experts from the EU Member States, industry and environmental organisations BREF (BAT Reference documents)


3. flexibility: allowing the licensing authorities, in determining permit conditions, to take into account:

(a) the technical characteristics of the installation, (b) its geographical location and (c) the local environmental conditions.

4. public participation: the public has a right to participate in the decision making process, and to be informed of its consequences, by having access to

(a) permit applications in order to give opinions, (b) permits, (c) results of the monitoring of releases and (d) the European Pollutant Release and Transfer Register

(E-PRTR)


Basic obligations:

- use all appropriate pollution-prevention measures, namely the best available techniques (which produce the least waste, use less hazardous substances, enable the substances generated to be recovered and recycled, etc.);

- prevent all large-scale pollution;

- prevent, recycle or dispose of waste in the least polluting way possible;

- use energy efficiently;

- ensure accident prevention and damage limitation;

- return sites to their original state when the activity is over.


The decision to issue a permit must contain a number of specific requirements:

-emission limit values for polluting substances (with the exception of greenhouse gases if the emission trading scheme applies - see below);

- any soil, water and air protection measures required;

- waste management measures;

- measures to be taken in exceptional circumstances (leaks, malfunctions, temporary or permanent stoppages, etc.);

- minimisation of long-distance or transboundary pollution;

- release monitoring;

- all other appropriate measures.


BREF on Textiles

- covers the industrial activities specified in section 6.2 of Annex I of the IPPC Directive 96/61/EC = “Plants for pretreatment (operations such as washing, bleaching, mercerisation) or dyeing of fibres or textiles where the treatment capacity exceeds 10 tonnes per day”

- contains a number of annexes, which provide supplementary information about textile auxiliaries, dyes and pigments, textile machinery, typical recipes, etc.


TECHNIQUES TO CONSIDER IN THE DETERMINATION OF BAT

Good management practises: staff education and training, definition of well-documented procedures, improved knowledge of the inputs and outputs of the process, improving the quality and quantity of chemicals used, optimising water consumption, optimising the use of energy

Quality management of incoming fibre: pesticides residues, substitutes for mineral oils, pre-wetting of the warp yarns or compact spinning, selection of sizing agents

Selection and substitution of chemicals used: surfactants, complexing agents, antifoaming agents


Wool scouring: dirt removal/ grease recovery loops combined with evaporation of the effluent and incineration of the sludge, wool scouring with organic solvents

Pretreatment: oxidative route, hydrogen peroxide, sodium hypochlorite, chlorine dioxide, mercerising

Dyeing: carriers, PES after-treatment, dispersing agents, sulphur dyestuffs, bifunctional and low-salt reactive dyes, use of detergents and complexing agents, pad-batch dyeing of cellulosic fabrics, new reactive dyestuffs, dye at iso-thermal conditions, dyeing wool with metal-complex dyes


Printing: rotary-screen, printing cleaning, digital techniques, ink-jet printing, reactive printing

Finishing: minimum application techniques, energy consumption in stenter frames, easy-care treatments, mothproofing agent softeners

Washing: batch washing, continuous washing, washing with halogenated organic solvents

Waste water treatment


A permit issued in compliance with IPPC is not obliged to contain the emission limit values for greenhouse gases if these gases are subject to an emission trading scheme (ETS), provided there is no local pollution problem.

IPPC review process is on going!

http://ec.europa.eu/environment/air/pollutants/stationary/ippc/index.htm


ETS - Directive 2009/29/EC

- the first international trading system for CO2 emissions in the world

- covers over 11.500 energy-intensive installations across the EU

- does not imply new environmental targets

- but allows for cheaper compliance with existing targets under the Kyoto Protocol


- letting participating companies buy or sell emission allowances means that the targets can be achieved at least cost

- the price of allowances is a function of supply and demand as in any other free market

- Market intermediaries quote prices for allowances offered or bid for

- the Commission will not intervene in the allowance market


- National Allocation Plans (NAPs): the total quantity of CO2 emissions that Member States grant to their companies

- the Commissione assessment of the allocation plans is based on the 12 common criteria in Annex III to the Directive on Emission Trading

- the Member State can and should also take other measures

- legal framework of the trading scheme does not regulate how and where the market in allowances takes place

- Companies with commitments may trade allowances directly with each other, or they may buy or sell via a broker, bank or other allowance market intermediary


- an electronic registry system that keeps track of the ownership of emission allowances as they change hands in the market

- the registry system is not a marketplace; the way in which allowances are traded is a decision made by the participants in the market

- the Commission closely monitores the functioning of the EU ETS

- second 2008-2012 trading period


One of the most important measures requires the Commission to determine the sectors or sub-sectors deemed to be exposed to a significant risk of carbon leakage:

sector or sub-sector is "deemed to be exposed to a significant risk of carbon leakage if:

- the extent to which the sum of direct and indirect additional costs induced by the implementation of this directive would lead to a substantial increase of production cost, calculated as a proportion of the Gross Value Added, of at least 5%; and

- the Non-EU Trade intensity defined as the ratio between total of value of exports to non EU + value of imports from non-EU and the total market size for the Community (annual turnover plus total imports) is above 10%."


Sector or sub-sector is also deemed to be exposed to a significant risk of carbon leakage:

- if the sum of direct and indirect additional costs induced by the implementation of this directive would lead to a particularly high increase of production cost, calculated as a proportion of the Gross Value Added, of at least 30%; or

- if the Non-EU Trade intensity defined as the ratio between total of value of exports to non EU + value of imports from non-EU and the total market size for the Community (annual turnover plus total imports) is above 30%.

The resulting list has been supplemented after completion of a qualitative assessment, taking into account additional criteria referred to in article 10a.


Another important measures: define fully harmonised rules for free allocation of CO2 allowances, which should be based – to the extent feasible – on ex-ante benchmarks.

- the starting point shall be the average performance of the 10% most efficient installations in a sector or sub-sector in the Community in the years 2007-2008

- also taking into account other important considerations referred to in Article 10a(1) of the amended Directive, such as the most efficient techniques, substitutes, alternative production processes, high efficiency cogeneration, efficient recovery of waste gases, use of biomass and capture and storage of CO2, where such facilities are available.


ETS

http://ec.europa.eu/environment/climat/emission/ets_post2012_en.htm


ECO-DESIGN DIRECTIVE - DIRECTIVE 2009/125/EC

- framework for the setting of Community ecodesign requirements for energy-related products with the aim of ensuring the free movement of such products within the internal market

- ‘Energy-related product’, (a ‘product’), means any good that has an impact on energy consumption during use which is placed on the market and/or put into service, and includes parts intended to be incorporated into energy-related products covered by this Directive which are placed on the market and/or put into service as individual parts for end-users and of which the environmental performance can be assessed independently;


- ‘Environmental performance’ of a product means the results of the manufacturer’s management of the environmental aspects of the product, as reflected in its technical documentation file;

- Member States to comply by 20 November 2010

- not later than 21 October 2011 Commission establishes a working plan which shall be made publicly available

- The working plan shall set out for the following three years an indicative list of product groups which are considered as priorities for the adoption of implementing measures


Significant environmental aspects must be identified with reference to the following phases of the life cycle of the product:

(a) raw material selection and use (“substances classified as hazardous to health and/or the environment” according to the CLP Regulation);

(b) manufacturing;

(c) packaging, transport, and distribution;

(d) installation and maintenance;

(e) use; and

(f) end-of-life, meaning the state of a product having reached the end of its first use until its final disposal.


For each phase, the following environmental aspects must be assessed where relevant:

(a) predicted consumption of materials, of energy and of other resources such as fresh water;

(b) anticipated emissions to air, water or soil;

(c) anticipated pollution through physical effects such as noise, vibration, radiation, electromagnetic fields;

(d) expected generation of waste material; and

(e) possibilities for reuse, recycling and recovery of materials and/or of energy, taking into account Directive 2002/96/EC.


EC declaration of conformity

must contain the following elements:

1. the name and address of the manufacturer or of its authorised representative;

2. a description of the model sufficient for its unambiguous identification;

3. where appropriate, the references of the harmonised standards applied;

4. where appropriate, the other technical standards and specifications used;

5. where appropriate, the reference to other Community legislation providing for the affixing of the CE mark that is applied; and

6. the identification and signature of the person empowered to bind the manufacturer or its authorised representative.


CE marking


(Semi) Voluntary environmental requirements

1. Ecolabel [Regulation (EC) 66/2010 and Decision 2009/567/CE on textile products]

2. GPP (Green Public Procurement - Directive 2004/18/EC)

3. EMAS [Regulation (EC) 1221/2009]

4. EPD (Environmental Product Declaration)


EU ECOLABEL

- entered into force on February 18, 2010

- shall apply to any goods or services which are supplied for distribution, consumption or use on the Community market whether in return for payment or free of charge (hereinafter ‘products’)

- ‘environmental impact’ means any change to the environment resulting wholly or partially from a product during its life cycle;

- ‘environmental performance’ means the result of a manufacturer’s management of those characteristics of a product that cause environmental impact;


EU Ecolabel criteria:

-in particular the impact on climate change, on nature and biodiversity, energy and resource consumption, generation of waste, emissions to all environmental media, pollution through physical effects and use and release of hazardous substances;

- the substitution of hazardous substances by safer substances, as such or via the use of alternative materials or designs, wherever it is technically feasible;

- durability and reusability of products;

- where appropriate, social and ethical aspects, e.g. ILO standards and codes of conduct

- criteria established for other environmental labels, e.g. EN ISO 14024


The EU Ecolabel may not be awarded to

- goods containing substances or preparations/mixtures meeting the criteria for classification as toxic, hazardous to the environment, carcinogenic, mutagenic or toxic for reproduction (CMR), in accordance with Regulation (EC) No 1272/2008 (CLP)

- goods containing substances referred to in Article 57 of Regulation (EC) No 1907/2006 (REACH).

No derogation shall be given concerning substances that meet the criteria of Article 57 of Regulation (EC) No 1907/2006 and that are identified according to the procedure described in Article 59(1) of that Regulation, present in mixtures, in an article or in any homogeneous part of a complex article in concentrations higher than 0,1 % (weight by weight).


EU Ecolabel and Carbon footprinting

- looking into how carbon footprinting can be systematically considered within its criteria development process

- carbon footprint (CF): the overall amount GHGs emissions associated with a product, along its supply-chain and sometimes including the use phase and the end-of-life recovery and disposal. It is measured in terms of CO2 equivalent

- a small study was commissioned

http://ec.europa.eu/environment/ecolabel/about_ecolabel/carbon_footprint_en.htm


EU Ecolabel and GPP (Green Public Procurement)

- GPP is 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

- GPP could have significant benefits for the environment, as public procurement accounts for 16% of EU wide GDP

- GPP can lead to savings, in particular when a “life-cycle costing” approach is taken. It is about getting the best value for taxpayers' money!

- Green purchasing is also about setting the example and influencing the market place


GPP - COM (2008) 400

http://ec.europa.eu/environment/gpp/index_en.htm

- criteria already developed for 10 priority product groups/services that have been identified as most suitable for "greening" under Public Procurement

- Public Authorities and their policies seen as the “driver” for an awarer buying process by consumers

- by 2010 up to 50% of the public purchases


Textiles covers the following items:

Textile clothing and accessories consisting of at least 90 % by weight of textile fibres;

Interior textiles (excluding wall and floor coverings) consisting of at least 90 % by weight of textile fibres;

Fibres, yarn and fabric intended for use in textile clothing and accessories or interior textiles.

Other documents: Product Sheet on Textiles, containing a slightly expanded

version of the information in these slides Background Product Report on Textiles, providing more detailed

background information on how these purchasing recommendations have been developed

full GPP Training Toolkit: http://ec.europa.eu/environment/gpp/toolkit_en.htm


Core GPP criteria: products meeting the listed criteria which are based on the European Ecolabel for textiles will comply with the specifications. Additionally award criteria have been included relating to the use of organically produced cotton and recycled fibres.

Comprehensive GPP criteria: include production process and fibre-specific criteria taken from the European Ecolabel in the specifications, with the use of organically produced cotton, recycled fibres and products meeting some additional European Ecolabel criteria being encouraged in the award phase.


GPP and Environmental Management Systems (EMS)

- EMS are tools for any organisation – enterprise or public authority – to manage the impact of its activities on the environment;

- an EMS integrates environmental management into an organisation’s daily operations, long-term planning and other quality control mechanisms.

- EMAS (Eco-management and Audit Scheme) is the EU environmental management tool, originally restricted to companies in industrial sectors, since 2001 extended to all economic sectors

- voluntary and open to public or private organisations operating in the European Union and the European Economic Area (Iceland, Liechtenstein, Norway)


EMAS addresses five key issues:

- as a first step, the establishment and implementation of an environmental management system according to the requirements of EN/ISO 14001 (international standard on environmental management);

- the systematic, objective and periodic evaluation of the performance of this system;

- the provision of information on environmental performance and an open dialogue with the public and other stakeholders, among other things through use of the EMAS logo;

- the active involvement of employees in the organisation and appropriate training that makes active participation in the tasks referred to under the environmental management system possible;

- Companies and organisations subscribing to EMAS are required to comply with environmental legislation


Organisationally, EMAS means:

Quality environmental management due to the application of a highly developed scheme

Contribution to an organisation’s environmental risk management

Incentives to eco-innovate production processes

Compliance check with environmental legislation by an EMAS verifier

Sharing of best practice with other companies and organisations

Added credibility and confidence with public authorities, other businesses and customers/citizens

Improved relations with the local community

Better quality workplaces, employee morale and incentives to team building

Marketplace advantage and improved company image by improving stakeholder relations


Economically, EMAS means:

Resource savings and therefore lower costs

Reduction of financial burdens caused by reactive management strategies such as remediation, clean-ups and the paying of penalties for breach of legislation

Financial benefits through better control of operations

New business opportunities in markets where green production processes are important


The link between EMAS and GPP

Key factor to ensure successful implementation of green procurement policies is the communication between and within concerned departments of public or private organisations and Environmental Management Systems such as EMAS provide:

• clear guidelines for internal communication and reporting structures;

• a useful framework for coordinating environmental improvements. An EMS foresees all necessary elements to involve and coordinate the concerned parties within the organisation;

• for the supplier, EMAS can be used as a way of demonstrating compliance with an environmental selection criterion related to the capacity of bidders to take environmental management measures during the performance of the contract


EMAS and Public Authorities

- a group of 11 cities throughout Europe have started the LEAP project (Local Environmental Management System and Procurement)

- supported by the European Commission’s LIFE programme (the Financial Instrument for the Environment)

- the aim is examining how management and implementation of green purchasing can be improved through integration of environmental management systems

- developing practical approaches aimed at realising the environmental and financial benefits of joint procurement

- developing a number of tools aimed at supporting local authorities in implementing green procurement.


EMAS II1 logo 2 versions


EMAS goes further than ISO 14001

ISO/EN ISO 14001(2004)

+ Public Reporting

+ Legal Compliance

+ Employees Participation

+ Performance improvement


If the organisation has already ISO 14001?

The organization needs: Environmental Legal compliance Verification Environmental Management System Validation Environmental Statement Continuous improvement of environmental

performance Information to Public Employees participation Public participation

The ISO 14001 has been considered as a previous stage to reach EMAS certification


Management review

EMAS is a systematic approach

Environmental policy

Planification

Implementation

Monitoring and measurement

Continuous improvement

Initial env

review

PLAN

DO

CHECK

ACT


EMAS website

http://ec.europa.eu/environment/emas/index_en.htm

LEAP project website

http://www.iclei-europe.org/index.php?id=LEAP


The International EPD® System

- member of the Global Type III Environmental Product Declarations Network (GEDnet)

- increased demand for science-based, verified and comparable information about environmental performance of products and services

- raw material supply-chain, product development and green procurement

- main objective: to help and support organisations to communicate the environmental performance of their products (goods and services) in a credible and understandable way


How?

- offering a complete programme for any interested organisation in any country to develop and communicate EPDs according to ISO 14025, and

- to support other EPD programmes (i.e. national, sectorial etc.) in seeking cooperation and harmonisation and helping organisations to broaden the use of their EPDS on an international market

- based on a hierarchic approach following the international standards ISO 9001 (Quality management systems), ISO 14001 (Environmental management systems), ISO 14040 (LCA - Principles and procedures), ISO 14044 (LCA - Requirements and guidelines), ISO 14025 (Type III environmental declarations) and ISO 21930 (Environmental declaration of building products)

- developing so-called Product Category Rules (PCR)


Ten of the most prominent key programme elements:

Purpose Element identification and principal approach

Complying with principles set in ISO 14025 on modularity and comparability

1. "Book-keeping LCA approach"2. A Polluter-Pays (PP) allocation method

Simplifying work to develop Product Category Rules (PCR)

3. PCR Module Initiative (PMI) for structurising PCR into modules according to international classification4. PCR moderator for leadership and support on the PCR work5. Pre-certification of EPDs


Secure international participation in PCR work

6. Global PCR Forum for open and transparent EPD stakeholder consultation

Facilitating identification and collection of LCA-based information

7. Selective data quality approach for specific and generic data

Broaden market applications of EPDs

8. Introducing Sector EPDs9. Introducing "Single-issue EPDs"

Expand possibilities for organisations to issue EPDs in a cost-effective way

10. Introducing "EPD process certification"


DIVISION: 27: TEXTILE ARTICLES OTHER THAN APPAREL

271 Natural textile fibres prepared for spinning2711 Blankets and travelling rugs (except electric blankets)2712 Bed linen, table linen, toilet linen and kitchen linen2713 Curtains (including drapes) and interior blinds; curtain or bed valances2714 Other furnishing articles n.e.c.; sets of woven fabric and yarn for

making up into rugs, tapestries, embroidered table cloths or serviettes, or similar textile articles, put up in packings for retail sale2715 Sacks and bags, of a kind used for the packing of goods2716 Tarpaulins, sails for boats etc., awnings, sunblinds, tents and camping goods (including pneumatic mattresses)2717 Parachutes2718 Quilts, eiderdowns, cushions, pouffes, pillows, sleeping bags and

the like, fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics2719 Other made-up textile articles (including floor-cloths, dish-cloths,

dusters and similar cleaning cloths, life-jackets and life-belts)


272 Carpets and other textile floor coverings2721 Carpets and other textile floor coverings, knotted2722 Carpets and other textile floor coverings, woven, not tufted or

flocked2723 Carpets and other textile floor coverings, tufted2729 Other carpets and textile floor coverings (including those of

felt)

273 Twine, cordage, ropes and cables and articles thereof (including netting)

2731 Twine, cordage, rope and cables2732 Knotted netting of twine, cordage or rope; made up nets of

textile materials; articles of yarn, strip, twine, cordage, rope or cables n.e.c.

279 Textiles n.e.c.2791 Tulles, lace, narrow woven fabrics, trimmings and

embroidery2792 Felt and nonwovens2799 Other textile articles


FUTURE DEVELOPMENTSIN THE EU REGULATIONS

SUSTAINABILITY

COM (2009) 400 FINAL


Main issues

- Climate change and clean energy

- Sustainable transport

- Sustainable consumption and production

- Conservation and management of natural resources

- Public health

- Social inclusion, demography and migration

- Global poverty and sustainable development challenges

- Education and training

- Research and development

- Financing and economic instruments


SensitivEcoSystem® www.sensitivecosystem.it

- a captivating project: spread beyond the boundaries of the Company Eurojersey

- ethical behaviour: build a network and promote a mindful and responsible attitude

- save the rainforest: support the World Land Trust


How they do this

- Total Quality Control: technology innovation and training

- product traceability: integrated management system

- ethical quality label: tag with the SensitivEcoSystem® logo

- the SensitivEcoSystem® website


Results

- energy efficiency and energy saving

- clean energy provided by nature

- completely integrated manufacturing control

- “HRS” water purification system

- “HRS” fume purification system

- ISO 14001 certification

- less waste and more recycling

- eliminate manufacturing waste


Certifications

- ISO 14001 certification

- EPD environmental certification

- OEKOTEX certification

- LCA (Lyfe Cycle Assessment) certification

- compliance with REACH


Partners

- awareness raising campaign to consumers

- taylor-made tools

- informed consumers

- care instructions


EUROPEAN TECHNOLOGY PLATFORMfor the Future of Textiles and Clothing


CONSUMERS’ AWARENESS


THANK YOU

FOR YOUR ATTENTION

Guido Bottini – Suzhou – March 18, 2010 ICE - TBD Textile Training Course 2010.

Documents

Transcript of Guido Bottini – Suzhou – March 18, 2010 ICE - TBD Textile Training Course 2010.