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EUROPEAN COMMISSION DIRECTORATE GENERAL JRC JOINT RESEARCH CENTRE Institute for Prospective Technological Studies (Seville) Sustainable Production and Consumption Unit

2nd

Ad-Hoc Working Group (AHWG) meeting for

the revision of the EU Ecolabel and Green Public

Procurement criteria for Furniture

Thursday 15th

May 2014, 09:30 – 18:00

Albert Borschette Centre - Room AB 4C

Rue Froissart 36

B-1049 Brussels, BELGIUM

Minutes of the meeting

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Participants List

Surname Name Organisation 1 Auranmaa Kirsi Environmental advisor EU Ecolabel

2 Baumgartner Michel Europur (Polyurethane)

3 Bell James FIRA

4 Melegari Silvia European Panel Federation

5 Bulow Kjeld Denmark

6 Defranceschi Peter ICLEI

7 Degoli Omar Federlegnoarredo

8 Demarne Bertrand Industries Francaises de l 'Ameublement

9 Domer Henry Community Playthings

10 Donatello Shane European Commission – DG JRC

11 Eskeland Marianne Ecolabelling Norway

12 Fuentes Natalia LEITAT Technological Center

13 Giavon Andrea Catas

14 Godin Fabienne Belgian competent body

15 Hidalgo Carme LEITAT Technological Center

16 Hochstetler Sam Community Playthings

17 Hoff Guido DIN - Germany - consumer council

18 Hoffmann Jorg Wilkhahn, Umweltmanagement

19 Hontelez John FSC

20 Hubbard John Consultant - UK

21 Jaeger Ismene Expert nominated by BEUC

22 Kaps Renata European Commission – DG JRC

23 Kaukewitsch Robert European Commission – DG ENV

24 Kirschner Marcus Hauptverband der Deutschen Holzindustrie

25 Koppenberg Bernd CEFIC Europe

26 Kowalska Malgorzata European Commission – DG JRC

27 Livolsi Benoit French Ecolabel NF

28 Ljungar Robin Swedish Federation of Wood and Furniture

29 Machefaux Emilie ADEME

30 Minestrini Stefania European Commission – DG ENV

31 Moons Hans European Commission – DG JRC

32 Morales Blanca BEUC and EEB

33 Neto Belmira European Commission – DG JRC

34 Newson Tony Eurometaux - consultant

35 Oney Ewa European Commission - DG ENTR

36 Pinto Carla European Commission – DG ENV

37 Pohjonen Perttu Helsinki Procurement centre

38 Regtuit Hans Eurofer

39 Rinaldi Caterina LCA & Ecodesign Laboratory - ENEA

40 Salemis Philippe EFRA and PINFA

41 Scaglia Elisabetta Servizio Ambiente - IT, UNIC

42 Terwagne Simone Formacare, the Sector Group of CEFIC

43 Toma Daniela Ecolabel Romania

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Surname Name Organisation 44 Van Den Bosch Ronald PU EH&S and Sustainability - Dow

45 van der Veer Coen EFBWW

46 Van hessche Dirk Plastics Europe

47 Vaughan Paul UK Ecolabel delivery

48 Vavallo Michele AIDIMA

49 Vlot Ineke SMK (Stichting Milieukeur)

50 Waidtlow Jakob Ecolabelling Denmark

51 Wolf Oliver European Commission – DG JRC

52 Zuccaro Domenico ISPRA

Agenda

SCHEDULE

1. Opening and welcome. 09:30 – 09:45

2. Overview of process for EU Ecolabel and GPP criteria development.

Scope and definition of product group "furniture".

09:45 – 10:00

3. Topic 1: Wood and wood-based materials criteria. 10:00 – 10:45

Coffee break 10:45 – 11:00

4. Topic 2: Plastic criteria and metal criteria. 11:00 – 12:00

5. Topic 3: Leather criteria and textiles criteria. 12:00 – 13:00

Lunch break 13:00 – 14:00

6. Topic 4: Padding materials / Upholstery criteria 14:00 – 14:45

Topic 5: Hazardous substances criteria and criteria for adhesives

and surface coatings.

14:45 – 15:40

9. Topic 6: Glass criteria and packaging criteria. 15:40 – 16:00

Coffee break 16:00 – 16:15

9. Topic 7: Product description and other customer information. 16:15 – 16:30

10. Topic 8: Final product testing: Durability, reparability, VOCs. 16:35 – 17:30

11. Concluding discussion and next steps. 17:30 – 17:45

12. Close of the workshop. 17:45 – 18:00

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Contents Overview of process for EU Ecolabel and GPP criteria development. .................................................... 5

Scope and definition of product group "furniture". ............................................................................... 6

Wood and wood-based materials criteria .............................................................................................. 7

i) Origin and traceability of wood ....................................................................................................... 7

ii) Sustainable wood ............................................................................................................................ 8

iii) Free formaldehyde content in resin formulations ......................................................................... 9

iv) Formaldehyde emissions from uncoated wood-based panels and boards ................................... 9

iv) Recycled wood contaminants ...................................................................................................... 10

v) GMO wood .................................................................................................................................... 10

Plastics criteria ...................................................................................................................................... 10

i) Labelling of all plastic components >50g according to ISO 11469 ................................................. 10

ii) Hazardous substances ................................................................................................................... 11

iii) Recyclability ................................................................................................................................. 11

iv) Recycled content .......................................................................................................................... 11

Other general comments on plastic criteria ..................................................................................... 12

Metals criteria ....................................................................................................................................... 12

i) Description of metals used ............................................................................................................ 12

ii) Hazardous substances ................................................................................................................... 13

iii) Recyclability ................................................................................................................................. 13

iv) Recycled content .......................................................................................................................... 13

Leather criteria ...................................................................................................................................... 13

i) animal origin .................................................................................................................................. 14

ii) Final effluent from the tannery .................................................................................................... 14

iii) Final product testing .................................................................................................................... 14

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iv) Hazardous substances .................................................................................................................. 15

v) General comment ......................................................................................................................... 15

Textiles criteria ...................................................................................................................................... 15

i) General comments ......................................................................................................................... 15

ii) Fibre materials (specifically cotton, elastane, polyamide and polyester) .................................... 16

iii) Hazardous substances .................................................................................................................. 16

iv) Final product testing .................................................................................................................... 16

Padding materials ................................................................................................................................. 17

Hazardous substances ........................................................................................................................... 17

Surface treatment and adhesives ......................................................................................................... 18

Glass criteria .......................................................................................................................................... 19

Packaging criteria .................................................................................................................................. 19

Product description criteria and Consumer information criteria ......................................................... 20

Final product criteria ............................................................................................................................. 21

Overview of process for EU Ecolabel and GPP criteria

development. After welcoming the stakeholders and a round of introductions, the process for criteria revision and

development was presented for both the Ecolabel and GPP schemes. After the presentation it was

commented that it would be better if there could be a 3rd Ad-Hoc Working Group (AHWG) meeting

to ensure that enough time and interaction is allowed to develop mature criteria.

It was responded that this is not normally the case but that all stakeholders have already have had

around one month to read the proposals and that they will have a further 4 weeks to finalise any

comments after the meeting for GPP criteria and 6-7 weeks to comment on Ecolabel criteria, so

there is still the possibility to contribute to criteria development. Furthermore, if the criteria are not

deemed acceptable by Member State representatives then they would not be voted on and there

would be scope for further dialogue and perhaps another meeting, but that the original plan for 2

meetings is already part of longer series of events which have their own deadlines.

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Scope and definition of product group "furniture". The text on the scope and definition was presented and included a question to stakeholders

regarding their opinions on the possible inclusion of second-hand or refurbished furniture in the

scope, either for Ecolabel of GPP.

The general opinion was that even though second-hand furniture is an interesting option from an

environmental perspective, it would entail significant extra work for an already complex product

group with the Ecolabel. Although there was more support for the inclusion of second-hand or

refurbished furniture in GPP. One major issue to consider would be how to deal with any criteria

that refer to technical standards or to hazardous substances when evaluating second-

hand/refurbished furniture. Another issue is how to prove that furniture is indeed second-hand or

refurbished. The example of a Belgian company that offers this service was cited where they offer a

closed-loop service, taking the old furniture from businesses and returning it to them as new, often

redesigned furniture as per their specifications.

Other comments on the scope and definition included concerns over the precise wording of the text

and that certain furniture that has high fire safety requirements should perhaps be excluded, such as

seats in cars, aeroplanes and cinemas. It was responded that this could indeed be excluded or be

addressed by looking at possible derogations based on certain uses of furniture or with reference to

relevant national legislation in force. Another stakeholder asked about furniture in hospitals and if

this was included and if so, then the surface finish would have to be very strong to deal frequent

cleaning with alcohol based solvents, and maybe an exemption for such furniture for surface

treatment criteria could be applied. It was responded that hospital furniture is not specifically

excluded and that we can discuss in further detail surface finishes when we reach that criterion.

It was asked if street furniture was also included in the scope with the response that if the primary

function of the street furniture was to act as "furniture" as per the definition included then yes. So

this would extend to benches, seats and tables used outdoors. It was reiterated that the wording

could be improved to clarify this point to avoid the possible inclusion of other street furniture such

as bollards, which would be undesirable.

Another question was how the scope deals with beds, which consist of a bed frame, legs and a

mattress. It was responded that the Ecolabel criteria deal specifically already with padding materials,

in particular PU and latex foam, which cover the vast majority of the market, and that any mattress

should at least meet these criteria, which are aligned with the criteria for bed mattresses.

One comment asked for a clarification on what was meant by wall panels since these are considered

as construction materials, not furniture. It was responded that this is not the correct term and

perhaps "cladding" would be more appropriate since this is often used for decorative purposes in

commercial establishments.

A question was asked about whether criteria were going to be introduced for stone-like materials –

with kitchen worktops in mind. This was not intended to be included but it was suggested to look at

criteria for the "hard-floor coverings" product group to consider this further.

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Concern was expressed about the exemption for materials that make-up less than 3% of the final

product weight and how the wording potentially offers a route for hazardous substances into the

product. Other concerns about the precise wording were raised and this will be revised, taking into

account feedback from stakeholders, in an attempt to clarify any doubts.

Wood and wood-based materials criteria The 5 sub-criteria for wood and wood based materials were presented and discussions on each of

these are given below.

i) Origin and traceability of wood

The inclusion of this criterion was justified because of existing loopholes in the EU Timber Regulation

No.995/2010 (herein referred to as EUTR) that permit the import of bamboo furniture and seats

without the need for due diligence certification stating the origin of the timber. It also helps

reinforce the regulation if furniture manufacturers begin to ask about the origin of the timber, which

ultimately reaches the Operator who originally placed the timber on the EU market. The wording is

slightly different from the recently voted EU Ecolabel criteria for other products that involve wood-

based materials and opinions about this were asked.

The first comment about the text was the desire to remove any reference to particular schemes such

as FSC and PEFC from the criterion, since these should only appear in the assessment and

verification portion of the text. Other comments expressed the desire to reintroduce the term

"legal" into the text, which was removed in the new version. In fact some stakeholders stated that

there was no reason to propose text that is any different to that voted for in previous products.

It was also highlighted that schemes such as FSC and PEFC did not originally provide clients with

information about the origin of certified wood and that this was not the aim of chain-of-custody

certification schemes. Instead the aim was simply to ensure that all steps in the supply chain have

been controlled by suitable bodies. However, since the introduction of the EUTR, both FSC and PEFC

have made changes to their auditing system to make this information available if a client specifically

asks for it. It was highlighted that only the information of the origin would be provided, not

intermediary traders, because this could be commercially sensitive information.

Concern was expressed about possible ambiguity with the origin of recycled wood. Would this go

back so far as to ask where the trees were grown to make the newspapers that were recycled? It

was suggested that the criteria for virgin wood and recycled wood be split to avoid this ambiguity. It

was also stated that FSC and PEFC accept recycled materials as they are, we do not require any

additional certification or proof of origin and consider them as suitable alternatives to virgin

materials. It was responded that the idea about the origin of recycled wood is simply from the point

at which it is marketed as recycled wood, for example from a 3rd party collector/processor. If a

distinction between pre-consumer and post-consumer recycled would is to be used, it should be

noted that FSC makes this distinction but PEFC does not. Another comment stated that the

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traceability of recycled wood is complicated when downstream suppliers start to introduce recycled

wood but may not keep records of its origin.

The approach taken by the Dutch government regarding the origin of wood was mentioned where

'Procurement Criteria for Timber' have been developed with Dutch stakeholders. The Dutch

government does not take FSC or PEFC as a guarantee that the wood does not come from

controversial sources, but instead asks advice from an independent panel of experts (Timber

Procurement Assessment Committee). This panel assesses, according to the Procurement standards,

certification schemes such as FSC and PEFC across the world. The panel has found that the Malaysian

PEFC scheme did not meet the Procurement standards.

Regarding the difference in text for wood origin criteria in the Ecolabel and the GPP, one stakeholder

commented that he considered the GPP text as simply a repetition of the EUTR and seemed less

ambitious than that of the Ecolabel. It was responded that due to the difficulty of agreeing on the

definition of sustainable timber even within the European Commission, the text has stayed close to

what is considered "safe territory", which in this case is the EUTR. The loopholes that exist in the

EUTR that are relevant to furniture are going to be considered in the next revision of this regulation,

which should take place by the end of 2015.

A comment about whether or not bamboo and rattan should be included as wood-based materials

was raised since they could be classified as grasses. Possible text such as "lignified material other

than wood", was suggested as an alternative. The reason for specifically mentioning bamboo and

rattan in this criterion is that often they are grouped together with wood-based materials by

customs authorities.

ii) Sustainable wood

The criteria for sustainable wood were presented with a slightly different wording to that of recently

voted criteria for other products that contain wood or wood-based materials.

One important comment from a stakeholder was that he did not see any criterion in the criterion for

sustainable wood, instead all he saw was a verification text. He stated that no reference to FSC or

PEFC or equivalent should be made in the criterion text, only in the verification. The criterion should

instead state a number of defined principles according to which a forest should be sustainably

managed.

In response it was said that this text (or a similar version of it at least) was the result of many, often

repetitive, discussions between Member States and that it had reached an agreement where at least

70% of the virgin wood should be certified and the remainder be "legal and controlled". It was

pointed out the way the text was written could suggest that the criterion was instead "70%

sustainable and up to 30% legal, but possibly unsustainable", which would not be acceptable.

Another stakeholder said that they tried to introduce a similar type of criteria based on specific

aspects of sustainable forest management (the Sustainable Timber Action) but found that no

agreement could be reached on the text since legally the definitions were very vague and instead a

more pragmatic approach was taken specifically referring to FSC and PEFC.

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When asking for an explanation of what is "controlled wood", it was answered that this differs

between PEFC and FSC. With PEFC, controlled wood is legal, does not contain GMOs and is not from

plantations that result from "conversion" (that is the direct conversion of existing primary forests

into plantations). With FSC, these same three factors apply plus there must be an assurance that

indigenous people's rights are not affected and that the wood does not come from, or cause damage

to, high conservation value forests.

The need for a horizontal discussion about sustainable wood in general was expressed as well as

concern over the less stringent requirements of PEFC compared to FSC, particularly with regard to

tackling controversial sources, and the desire to remove reference to "or equivalent", when

mentioning FSC and PEFC.

Regarding GPP, it was suggested that perhaps sustainable wood content should be an outright

award criteria rather than all wood needing to be at least 50% or 70% sustainable certified. Another

stakeholder responded that in their member state the minimum requirement was that all wood

should be sustainable already.

iii) Free formaldehyde content in resin formulations

One stakeholder asked why we focus on the free-formaldehyde content of resin formulations since

surely the main factor that is important is the formaldehyde emission from the wooden panel. It was

responded that this is important in terms of worker health and safety. It was asked if anyone has any

idea about what kind of market share the resin formulations with <0.2% free-formaldehyde content

have.

iv) Formaldehyde emissions from uncoated wood-based panels and

boards

The proposal has changed from emissions being limited to 50% of E1 at the 1st AHWG meeting to the

higher limit of E1 at the 2nd AHWG meeting. This was supported by industry stakeholders but

criticised by other stakeholders as being unambitious, since E1 panels are already a basic

requirement in some EU countries. It was also commented that since formaldehyde emission is the

most important VOC compound of concern with regards to indoor air pollution, any Ecolabel

products should have stricter requirements. Furthermore, one stakeholder expressed concerns

about worker safety without personal protective equipment when handling E1 panels. This was

questioned by industry stakeholders.

If 50% of E1 is too ambitious, with concerns about market availability and quality, then perhaps a

middle ground could be reached such as that used by the Nordic Swan, which provides different

limits (some 50% of E1 and some slightly higher) depending on the type of board used. It seems that

some panel types are easier to produce at 50% E1 than others.

It was suggested to change the text from "preferably carry out tests in laboratories that are

accredited under ISO 17025", to "only laboratories that are accredited under ISO 17025", because

there are already many such facilities available and it would ensure a certain level of quality control.

It must be stated that this wording cannot be changed since the text comes directly from the

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Ecolabel Regulation (No. 66/2010 itself). A key industry stakeholder stated that they would be willing

to co-operate into looking into possible improvements on E1 although it must be technically feasible

for industry.

The other main comments were that any specific reference to non-EN and non-ISO standards should

be removed from the document (but perhaps included in the user manual) and that perhaps a better

approach would be to only focus on formaldehyde emissions from the final (coated) furniture

product via an ISO 16000 type test as outlined in the French label.

iv) Recycled wood contaminants

No change from the original values used in the old version of the EU Ecolabel for wooden furniture

was proposed. One stakeholder suggested we look at the German AltholzVerordnung, although this

is only available in German.

v) GMO wood

It was proposed to ban this although it seems such a ban is already covered under sustainable and

controlled wood definitions. One stakeholder highlighted that this "double counting" of GMO

criteria highlights why it would be better to have a sustainable wood criteria that is not simply a

reference to FSC and PEFC.

Plastics criteria

i) Labelling of all plastic components >50g according to ISO 11469

A more ambitious labelling scheme (according to ISO 1043) was proposed that not only identifies the

polymer (like ISO 11469) but also any fillers, flame retardants and plasticisers used. ISO 1043

provides polymer resin codes for all commercially produced polymers whereas ISO 11469 labels the

6 most widely used polymers plus a catch-all number 7 for "other polymers". It was also asked if

anyone could provide information on possible standard methods that could be used to confirm that

a polymer is indeed the same as the label says in cases or dispute.

One industry stakeholder stated that since most furniture is incinerated and the metal recovered,

plastic marking has no beneficial effect and in no way helps furniture to be recycled. Another

stakeholder proposed to raise the minimum weight above which components should be labelled,

citing possible conflicts with designers over aesthetics. Support for labelling was expressed in the

sense that it facilitates recycling at the end-of-life if the user decides to do that. It was added that

labelling for PVC is especially important if trying to avoid this going to incineration, which most

furniture apparently does. The problem with PVC in incinerators is the potential formation of very

hazardous dioxin compounds and many incinerators are not well equipped to deal with PVC

combustion.

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ii) Hazardous substances

The following possible hazardous substance criteria specifically relating to plastics were presented:

a ban on any polymers containing 50% chlorine/chloride content,

Any PVC must contain less than 1ppm vinyl chloride monomer (VCM) impurities.

Any polycarbonate (PC) must contain less than 100ppm BisPhenol-A (BPA) impurities.

One industry stakeholder strongly criticised the criterion proposed for 50% chlorine/chloride content

limits as being very unscientific and it was unreasonable to exclude whole families of compounds like

this. It was responded that this criteria is linked to potential dioxin formation if the material is to be

incinerated, and dioxin formation is directly linked to chlorine/chloride content, but that indeed, the

choice of 50% is not based on any solid science, perhaps a much lower limit is reasonable.

Regarding the limits for the VCM monomer, it was said that this is a non-criterion in the EU since it is

already standard practice in EU manufacturers. In response it was stated that this cannot be

extending to other countries outside the EU, where furniture components can easily be supplied

from and that this criteria effectively ensures that any PVC comes from modern plants operated with

good process control.

Some other stakeholders supported an outright exclusion of PVC, based on its adverse

environmental impacts over the whole lifecycle, citing that the Ecolabel Regulation itself is set up to

consider products and their component materials in this way. However, it was also mentioned that

this has been discussed many times in the past and in fact the failure to agree over an approach to

take over PVC was one of the main reasons for the old criteria being limited to wooden furniture.

Other concerns regarding PVC included the risk to the environment and workers from VCM during its

manufacture and it was undesirable that, under the current scope, up to 3% of the furniture product

could in fact consist of PVC. One Member State representative stated that this could be right at the

very limits of what could be acceptable with the EUEB. Further work on this issue was requested.

iii) Recyclability

This sub-criterion attracted a lot of criticism with many industry stakeholders regarding it as very

difficult to implement and possibly presenting a barrier to the sale of Ecolabel furniture in certain

geographical areas and as an unnecessary additional burden for both manufacturers and Competent

Bodies. Providing this information should be the responsibility of someone else, like local authorities.

It was also asked how this was to be verified in the future, although it was stated that this

verification would only take place at the point of application for the Ecolabel license.

iv) Recycled content

It was communicated that experience with the Nordic ecolabel has shown that the requirement for

recycled plastic content on products containing more than 10% plastic by weight has been very

difficult to comply with and so it is suggested to raise the threshold. A concern was expressed about

the wording since it appears to follow the Nordic Swan but is slightly different and it was not clear if

both pre- and post-consumer recycled plastic was acceptable.

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Doubt was expressed if it was possible to manufacture white plastic furniture (which is popular) with

recycled plastic contents above a certain level and left as an open question. Another comment

stated that there is not enough plastic recyclate on the market and that plastic resins are produced

in huge batches, where it would be impossible to ensure such a high recycled content. In response, it

was stated that the criteria are set up to encourage the market to ask for recycled plastic. In addition

to this (after the meeting itself) it can be commented that when manufacturing final plastic

components the resin flakes are mixed with highly specific mixtures of fillers and other additives and

it is at this stage, which is on a much smaller scale and on a batch basis, that recycled plastic flakes

could be introduced. One potential way around white furniture with recycled plastic is to use co-

extrusion equipment where a core plastic with high recycled content extrudes along with a virgin

plastic capping layer.

Other general comments on plastic criteria

One stakeholder proposed to have a separate criterion for plastic labelling only and then another

one for specific plastics commonly used in furniture but not for PVC

Some confusion arose due to the text stating that the plastic criteria only related to thermoplastics,

which would effectively ban plastic laminate surface coatings for example. It was responded that

such coatings should instead be addressed in surface coating criteria but that , since not specific text

is available on laminates in that criterion, more information on this would be welcome.

Metals criteria The following sub-criteria were presented:

Description of metals used

Hazardous substances

Recyclability

Recycled content

i) Description of metals used

No specific comments were raised on this criteria except that it may be obsolete since the

information will be provided to the Competent Bodies via the Product Description criterion and

possibly also under Consumer Information criterion.

One stakeholder objected to the need for verification methods because this information does not

need to be made available to public authorities. It was responded that the idea behind these

methods was mainly considered in terms of GPP, where an abnormally low bid may arise due to the

use of a low quality steel, which may then impact on product durability and lifetime. It is believed

there is a mechanism to reject abnormally low bids in the GPP process but requiring possible final

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product testing of the alloy composition was one possible option. However, this is probably more

relevant to engineering applications than furniture.

ii) Hazardous substances

A derogation request for Ni in stainless steel was accepted but not extended to Ni-plated stainless

steel. It was pointed out that stainless steel is not Ni-plated but rather carbon steel.

One comment arose regarding Chrome plating and it was mentioned that this is banned under the

Nordic Ecolabel except under limited circumstances, and then only with Cr(III), not Cr(VI). This

information could be provided. In general it would be simpler if the criteria for metal also had a sub-

criteria for metal coatings (and likewise for wood). This was generally agreed.

iii) Recyclability

The recyclability criterion was widely criticised in a similar manner as that presented for plastics.

iv) Recycled content

Industry stakeholders did not support any criteria regarding recycled content for metals, citing the

example of steel and how two different production routes exist (Basic Oxygen Furnace with up to a

25% recycled content and the Electric Arc furnace with up to a 100% recycled content) and how this

criteria essentially discriminates against one facility when in reality both are complimentary. They

argued that the already high recycling rates of metal make the potential impact of this criterion very

small.

It was also commented that it would be more important that the criteria ensure that the furniture

product can be disassembled into different material components to facilitate recycling rather than

possessing a certain recycled content.

Another comment was that the threshold of 30% (above which recycled content must be stated) was

lower than that of the Nordic Ecolabel (50%). This was not recommended because already the

Nordic Ecolabel is experiencing problems, in particular with recycled Aluminium contents, due to the

way in which the industry operates. Because demand keeps growing, it is difficult for industry to

keep recycled contents high. A possible alternative way of looking at recycled content is available in

the newest version of the Nordic Ecolabel.

A representative of furniture manufacturers added that they have a lot of difficulty in finding

accurate data about recycled metal content and instead often simply quote EU average recycled

contents because the furniture industry is not a dominant sector for metal manufacturers and so has

little influence on the specifications of what metals are produced.

Leather criteria The following criteria were presented:

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Animal origin

Final effluent from tannery

Final product testing

Hazardous substances in leather production

Furthermore opinions on the exclusion of faux leather from the scope were asked and other criteria

that have been excluded on the grounds of potential difficulties in verification (i.e. total water

consumption and total COD discharge per tonne of hides processed).

i) animal origin

It was commented that this criteria is not very relevant for furniture because furniture leather is

almost exclusively made from bovine hides due to the large size of pieces used. In fact even leather

from bovine calves is generally excluded for this practical reason. One possible exception is with

cushions however. It was advised against any verification using DNA analysis due to the high costs

involved and the very fine differences that exist between some species. Traditionally, the distinction

between animal origin has been carried out be visual and textural observation by experts.

Also it was requested that the use of "or equivalent" be deleted when referring to any test methods

since this can lead to ambiguity and disparities in results if two different methods that analyse the

same component are used but have been designed to handle samples that have different matrices

(for example freshwater and seawater). This is attributed to leather especially because of the

hundreds of different compounds it contains that could potentially interfere with methods not

especially designed with leather analysis in mind. A general comment was made that the same logic

should apply to all other test methods mentioned for other materials in the criteria as well.

ii) Final effluent from the tannery

The limits of 1ppm for total Cr and 250ppm for COD were generally accepted although it was

suggested to also include some sort of requirement for water consumption because compliance

could simply be achieved by diluting the effluent stream with clean water. Chemical tests in Italy are

weekly or even daily.

Interest in additional effluent criteria was expressed, for sulphide and for an ecotoxicological assay

based on fish egg survival (the same as mentioned in the Blue Angel criteria for leather). Some

written feedback can be provided regarding more details of this method and the frequency with

which it should be carried out.

iii) Final product testing

It was commented that the test parameter "tear strength", should in fact be "tear load", the

document should refer specifically to "ISO 3377-1" rather than simply "ISO 3377", to avoid confusion

with the different method in ISO 3377-2, and that the final limits for both footwear and furniture

products should be the same in the final versions.

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The limit of 200ppm for extractable Cr was generally accepted although the final result will depend

to a large extent of whether or not the leather was coated or not. Reference to EN 13336 was made

by another stakeholder where the correct definitions for furniture leather can be found. The main

final product quality issues for consumers tend to be surface adhesion and light fastness rather than

tear strength (or load).

iv) Hazardous substances

It was asked why the international method for chlorophenols was not mentioned in the document

and an EN-ISO standard for APEO (Alkyl-Phenol EthOxylates) analysis was offered. Regarding flame

retardants, although leather in itself is not flammable (it is self-extinguishing) other risks can arise

when it is combined with other flammable materials. The need for flame retardants in leather seats

in aircraft was cited.

Some stakeholders pressed for a specific exclusion of halogenated flame retardants while industry

representatives were against the banning of whole families of compounds, citing the REACH

registration process which tackles substances individually.

Some doubt over the wording regarding the inclusion or exclusion of polyfluorinated treatments was

expressed, which will be looked into in the criteria revision.

v) General comment

One stakeholder stated that he would not like to see faux leather included in the same criteria as

leather because it has a completely different nature (is basically a plastic with or without a textile

backing).

Textiles criteria The discussion on textiles was quite general with some specific points directly related to the criteria

which will be mentioned.

i) General comments

Concern was expressed that too much focus was going to components such as textiles which may

not be the most important aspect of furniture from an LCA perspective, especially if criteria is copied

from the EU Ecolabel for textiles which is far more relevant to that product group. In particular, it

was deemed unacceptable that some of the criteria for textiles in furniture, the way it was worded,

was less flexible than that for EU Ecolabel textiles. If any text is to be carried over, it should be word

for word then same, so that extra work is avoided for the Competent Bodies and that possible errors

are introduced in both wording and interpretation. This was agreed upon and shall be addressed in

the criteria revision. A cut-off limit of 1% of furniture product weight, below which textile criteria

would not apply, was suggested (in line with the Nordic Ecolabel).

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ii) Fibre materials (specifically cotton, elastane, polyamide and

polyester)

Criteria for wool were requested by some stakeholders. With regards to cotton, it was stated that if

IPM cotton was to be allowed, the minimum content should be raised from 20% to 60%. Another

stakeholder expressed strong support for a requirement for 100% organic cotton. It was responded

that these points regarding cotton will need to checked for compatibility with the EU Ecolabel

criteria for textiles so that we avoid the situation where an Ecolabel textile product cannot be used

in Ecolabel furniture.

With elastane, the relevance of the workplace emission limits for isocyanates was raised since they

don’t seem related to the process. This will be looked into in the criteria revision.

iii) Hazardous substances

An objection to the derogation of Antimony Trioxide (ATO) for use as a flame retardant was raised

by one stakeholder due to the fact that this substance is a suspect human carcinogen (H351). The

ENFIRO project, funded by the European Commission, was cited where many alternative and less

hazardous, or even non-hazardous, flame retardants have been shown to be able to be used. One

industry stakeholder urged caution when referring to the potential of non-hazardous flame

retardants, stating that the outcomes of the project were not "black and white", and that such

alternatives do not offer a 1 for 1 replacement and may be difficult to incorporate into certain

material manufacturing processes. They stated that some freedom should be left to the

manufacturer to choose their flame retardant and a lack of choice may affect product cost. With

regards to ATO, we will need to ensure that the revised criteria are such that we avoid possible

scenarios where Ecolabel textiles are not permitted in Ecolabel furniture.

The political dimension of the debate over flame retardants was mentioned and the desire to see a

list of specific chemicals that are permitted was expressed. This would aid Competent Bodies more

in their job rather than a non-exclusive list of flame retardants that are not allowed. Some specific

reference to fire safety standards was requested. This latter point may be complicated since these

standards vary between Member States. It was suggested to look at the criteria for WCs and urinals

for text that is suitable for covering different Member State legislation.

iv) Final product testing

It was stated that an element of final product testing related to physical properties of the textile

fabric should be introduced, since this is the main area of customer concern - the main properties of

interest were said to be wear resistance, colour fastness and pilling.

For the extractable heavy metal and formaldehyde tests, it was stated that the 5g sample mentioned

was very small and may miss certain heterogeneous properties of the textile fabric, for example

fibres of different colours. It was responded that this could be remedied by asked for a

representative larger sample to be homogenised prior to taking a 5g sample from the homogenised

bundle.

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Padding materials It was asked if the use of recycled PU foam in padding materials had been considered. In response, it

was said that post-consumer waste is not recycled due to its long lifetime (typically >10 years) which

leads to concerns with hazardous substances that could be present that would today be banned in

new PU foam. For the same reason there are also concerns about dust mites and mould, which could

be exacerbated if the old foam had been stored outside during its disposal. For pre-consumer waste

PU, it was commented that this can be recycled into carpet underlay.

Regarding other materials, it was stated that any polyester fibres should simply meet the same

requirements as stated for textiles and that regarding the use of down feathers, ethical issues such

as whether the feathers had been plucked from live animals would be relevant, which is a particular

concern in some countries.

Hazardous substances A restructuring of the hazardous substance criteria would be welcome by several stakeholders, with

a general text referring to Article 6(6) of the Ecolabel Regulation (66/2010) and specific test for each

material to improve readability. This was deemed as okay although text must also be included for

Artcile 6(7) so long as derogations are used.

Regarding deorgations, concern was expressed about the large number of H-statements/R-phrases

derogated for glues and adhesives and that this should be far more restrictive to focus on those less

hazardous products available on the market. It is also confusing to the reader to mention the

derogation text in criterion 2b) and then in Annex I. It was responded that the restructured criteria

will hopefully be much more readable in general. One stakeholder asked that this criterion should

simply follow REACH but it was responded that this would not meet the requirements of Article 6(6)

of the Ecolabel regulation.

Regarding biocides, it was stated that these are permitted in the preservation of outdoor wood and

logs that are stored prior to processing but we would like to see so specific limits and verification

tests mentioned since this can end up in the final product. This comment was also extended to other

materials such as leather and textiles. It was responded that we can try to look into this but would

welcome any input directly from stakeholders. The limits for biocides allowed as in-can preservatives

corresponded only to indoor paints, the limits for outdoor paints (and paint film preservatives)

should also be mentioned in the derogation table since these are higher.

Some concern was expressed about possible confusion that could arise from different wording when

referring to the non-exclusive list of excluded flame retardants and that for plasticisers. This can be

addressed quite simply in the revised text.

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Finally one stakeholder expressed the desire to see an emphasis on Occupational Health and Safety

(OHS) standards which are standardised across the EU when dealing with hazardous substance

criteria. This process starts with looking the Safety Data Sheet (SDS) and then, depending on the risk

phrases present, you workplace has to be planned appropriately as well as any necessary personal

protective equipment and so on. A possible requirement would be certification under the 3rd party

OHSAS scheme and possible EMAS certificate of production companies. Industry would like to see

more focus on the proper handling of hazardous substances rather than their simple exclusion.

Surface treatment and adhesives It was commented that points ii) and iii) in criterion 4a) should be clearly stated as alternatives,

which is not the case in the current text. This will be addressed in the revised criteria. It was also

stated that the specific VOC limits mentioned (of 10, 30 and 60g/m2) are linked to quality

requirements, which should be mentioned in the report. It was commented if these limits are linked

to any data on final product VOC emissions via chamber tests and if any study has been published in

this respect. Also the choice of a limit for 5% VOC content (below which a calculation is not required)

was based on mathematical reasons rather than market availability. It was also commented that

some water-based lacquers have VOC contents >5%. Regarding the calculation method, it was

commented that the figure of 70% coating efficiency for spraying devices with recycling can in fact

exceed 90% when excesses are scraped off the feed belt.

With regards to UV curing lacquers, these are low VOC (around 2%) coating substances and can

prove to be more durable than high VOC coatings. UV lacquers may require a derogation for the

R50/53 risk phrase or perhaps not because they change their properties after curing. It was later

commented that the relevant risk phrase is actually R52/53 (H412).

With regards to chrome plating, it was clarified that only Cr(III) should be permitted and not Cr(VI).

Also these substances should only be allowed to be used in closed systems, due to lower workplace

and environmental emissions. The allowance of electroplating on parts subject to heavy wear was

considered as a loose definition because manufacturers will argue that this applies to many parts of

furniture and the Competent Bodies may be required to have many discussions with applicants

about this - more specific examples of these types of parts should be mentioned.

It was reiterated that a specific criteria for melamine coatings is requested by stakeholders and that

possible extra coating requirements for hospital furniture should be considered. A query was raised

if the 3% exemption in the product scope meant that laminates would thus be exempt. It was

responded that this was not the intention and will be more clearly worded in the revised criteria.

One point was raised about the table containing the list of banned risk phrases and that if this is

applied to substances, it would mean that a huge amount of mixtures, which may not be so

hazardous in themselves, would be banned. It was responded that the CLP (Classification, Labelling

and Packaging) Regulation has specific rules for the classification of mixtures.

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Glass criteria It was suggested that the Nordic label text could be followed if mirrors are to be included although

perhaps they should simply be excluded for clarity to applicants. It was commented that criterion

10b) would read better if it was simply split into 4 bullet points. Another comment queried if there

should be an allowable limit for lead glazing in furniture since it would be strange for a big piece of

furniture to be rejected based on it containing a small piece of leaded glass. It was responded that

lead glass is banned because it can contain very high percentages of Pb (in the region of 20% as PbO)

and asked if anyone was aware of low Pb content leaded glass.

The recycled content criterion was not generally supported due to doubts over what is achievable or

in fact current industry practice for all the different types of glass that can be used in furniture. It

was commented that it was more important that the glass is "replaceable" rather than "recyclable"

and that consumers should be informed that this type of glass should not be disposed of in recycling

bins for post-consumer glass bottles because this would contaminate the batch since it has a

different melting point than post-consumer glass. As with metal and plastic, it was seen that the

recycling (or downcycling to aggregates in concrete) of glass waste should be considered as the

responsibility of other parties such as local authorities rather than producers or consumers.

Packaging criteria Specific criteria for cardboard and plastic were described as well as a general criterion for other

materials. It was asked what was meant exactly by other materials and responded that this was not

clear exactly but generally textiles.

The typical overall contribution of furniture packaging to the environmental impact of the product

was requested. It was responded that this can vary considerably depending on the individual

product in question, which is difficult to determine due to the very broad scope of furniture

products. In support of packaging criteria was the high impact this has on customers during first

impressions and even if packaging is not a dominant factor on environmental impacts, it can be on

consumer opinion and that there is a clear conflict in sustainable products being stored in

unsustainable packaging.

The requirement for "being recyclable" was criticised as being too vague and a concern about

recycled content was expressed if this should in anyway undermine the ability of the packaging to

carry out its main function, which is to protect the furniture product from damage during storage

and transport.

The proposed recycled content of 80% was supported by one stakeholder, adding that this was

deemed acceptable to TV manufacturers, although another commented that in the UK the average

recycled content was 64% and that higher recycled content requirements may make compliance

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more complicated for small companies who have difficulties in negotiating with their suppliers for

higher recycled content cardboard. Another stakeholder expressed doubt about the availability of

information on recycled contents.

It was also commented that the packaging criteria can vary significantly from EU Ecolabel criteria

from one product to another. A horizontal approach by the JRC to harmonise packaging criteria was

encouraged.

Product description criteria and Consumer information

criteria It was generally accepted that the product description criterion should be solely intended for the

Competent Bodies, to aid them in their task. Another stakeholder questioned the need for the list of

materials by weight and suggested that simply drawings should be sufficient.

The most relevant consumer information was generally considered to be whether the furniture is

suitable for indoor or outdoor use, any assembly instructions (and disassembly), how to

clean/maintain the product, compliance with technical standards and information about hazardous

substances. It was asked if this information represents any extra information beyond what is

normally given. Even to Competent Bodies the need for criteria on consumer information was

doubted since all this information would be generated already by compliance with other criteria.

It was stated that information about hazardous substances should come at the point of sale, and not

only after the customer has opened the packaging and read the instruction manual. Some debate

arose about hazardous substances, with some saying that any text accompanying the EU Flower

should say if flame retardants or biocides had been used whereas others stated that this could

create a conflict in the consumers impression, and that any text should be positively worded along

the lines of "free from biocides" or "restricted/reduced use of hazardous substances" and so on.

Others opined that the simple presence of the EU Flower was enough to inform the customer that

they had made a good choice.

Another comment touched on the subject of outdoor furniture and suggested that information

should be provided saying something like "this furniture is for outdoor use only because it may

contain biocides". Information on flame retardants was also supported by some stakeholders while

another wanted information on fire safety to be specifically included.

It was generally agreed that too much consumer information would not be beneficial and that it was

unlikely the consumer would read all of this anyway. Nonetheless, consumer information could be

especially useful to procurers for evaluating different products when applying award criteria.

Another query was raised about the web-link to be provided with the Ecolabel, it was stated that this

link was too generic and did not give any specific information about the furniture Ecolabel. It was

responded that a more appropriate link would be used as soon as a page for the new furniture

criteria has been created.

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Final product criteria With regards to ergonomic requirements, it was requested that this be restricted specifically to

school and office furniture, for which specific standards exist (EN 1729, EN 1335 and EN 527). Doubts

were raised about the usefulness of durability criteria, instead stating that an extended product

warranty would be a better approach to take, both for Ecolabel and GPP. It was asked if durability

standards have different levels of compliance and it was responded that this is based on "fitness for

use" - with levels for "normal" furniture and levels for "extreme" furniture, examples of the latter

being in airports and police stations. Regarding the reference to standards in general, it was said that

no reference to CEN TC work should be made (when no current standards exist) since this would be

very difficult to justify and would refer to methods have not yet been adopted. It was requested that

the years for each standard listed in the Annex be removed since this could become outdated as

new versions are drafted.

Regarding possible criteria for lighting, it was suggested that no criteria be used because most

furniture is not produced with the light-bulbs themselves but instead this is the choice of the

consumer. Another opinion was that the requirement for Class A rating light bulbs is not ambitious

since a report by "Lighting Europe", stated that all lightbulbs sold in the EU now meet the Class A

requirements. It was also doubted how many CFLs (Compact Fluorescent Lightbulbs) were actually

used in furniture and whether a derogation for them would be necessary. If the criterion is to be

maintained then a better energy rating should be used (A+). Another comment about electrical

energy consumption referred to electrical actuators in height adjustable desks being a larger

potential impact than light-bulbs since they continually draw energy during their lifetime, this is

apparently included in the Danish GPP criteria.

It was proposed that the last two sentences of criterion 11c) be deleted since they have no place in

the criteria document – this will be addressed in the criteria revision. Possible complications with the

disassembly of glued components was also mentioned.

The majority of the discussion on this criterion focussed on possible VOC testing of final products.

Concerns about the cost of chamber tests were expressed. Costs from 3000 to 5000 Euros were

quoted for large chamber tests (for 28 days, which is the standard test duration). The limited

availability of facilities with large test chambers was also communicated.

Although not all stakeholders agreed on the need for final product VOC emission testing, all

stakeholders agreed that the use of small chambers to test furniture components should be allowed

as an alternative to large chamber tests. The small chamber test costs are at least 90% cheaper in

general. The possibility to use accelerated tests (at elevated temperatures/flow rates) was queried

and it was responded that this is used in tests for furniture in automobiles but may not translate into

cost reductions for testing due to the need for carefully controlled heating of the chamber. The issue

of excess testing costs for small furniture companies and for custom-made and low production

volume furniture was raised. In response it was said that where finished wood-based panels are

mass produced, for example by Kronospan, it would be more sensible, and cheaper overall, for the

supplier to test these finished boards regularly rather than have downstream furniture

manufacturers testing them. Another issue is whether or not all products should be tested or, if the

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"worst-case scenario" products in a given range from a given supplier meet the criteria then could

testing for better products be avoided.

One possible flexible approach was suggested was that any E1 panels would have to be chamber

tested for VOC emissions once coated and as part of the final product. It was not sure what the

approach would be for any 50% of E1 panels but this can be discussed after the meeting. It was

asked if there are any Member State regulations specifically about indoor air quality. Some

information about indoor air testing will be provided later by one stakeholder.

Regarding the VOC limits proposed for the final product criteria, it was said that the values for TVOC

were considerably higher (1500) than those in the Blue Angel RAL UZ 148 (450). A doubt about

whether ISO 16000 should be used was raised, because this was designed for construction materials,

which are generally quite uniform – but furniture products are far more complex and varied.

With regards to GPP, the potential of this policy instrument to help move the market forward was

underlined if criteria for final product VOC testing should be introduced. It was stated that when

procurers ask about VOCs. It was added that procurers often look for the VOC content of coating

compounds used and this should be considered as the main factor related to final product emissions

where solid wood or metal has been used at least.