Labelling of Detergents according to Regulation (EC) 648/2004: Overview of Main Requirements and Practical Examples

1. Labelling of Detergents according to Regulation (EC) 648/2004: Overview of Main Requirements and Practical Examples Dr. Dagmar Zaika A.I.S.E. / Henkel AG & Co. KGaA Workshop on the Implementation of the Regulation (EC) 648/2004 Detergents Regulation INFRA 32637 Bucharest, Sept. 21 – 22, 2009

2. Labelling of Detergents • EC No. 648/2004 (Detergents Regulation) and its amendment EC No. 907/2006 regulate the labelling of • ingredients in detergents and cleaning products. • dosage information for laundry detergents. • additional elements. • Labelling provisions are without prejudice of other regulations (DSD, DPD, CLP,..).

3. A.I.S.E. Guideline • to help industry with the implementation. • approved by the Commission and the Member States. • published on the website of the European Commission: http://ec.europa.eu/enterprise/sectors/chemicals/files/legislation/final_aise_guideline_rev_7_feb_05_22_en.pdf

4. Labelling of Ingredients • The labelling provisions for the ingredients of detergents are laid down in Article 11(3) and Annex VII A distinguishing between • ingredients to be listed when added >0,2% by weight. • ingredients to be listed irrespectively of their concentration. • allergic fragrances to be listed when added >0,01% by weight.

5. Ingredients to be Labelled >0,2 % • Ingredients to be listed when added in a concentration above 0,2%: Phosphates NTA and salts thereof Phosphonates Phenols and halogenated phenols Anionic surfactants Paradichlorobenzene Cationic surfactants Aromatic hydrocarbons Amphoteric surfactants Aliphatic hydrocarbons Non-ionic surfactants Halogenated hydrocarbons Oxygen-based bleaching agents Soap Chlorine-based bleaching agents Zeolites EDTA and salts thereof Polycarboxylates • Weight percent ranges to be applied: less than 5 % 5 % or over but less than 15 % 15 % or over but less than 30 % 30 % and more

6. Ingredients to be Labelled w/o Threshold • Classes of ingredients (if added) to be listed irrespective of their concentration: enzymes disinfectants optical brighteners perfume preservation agents • Preservation agents have to be declared using their INCI names (International Nomenclature of Cosmetic Ingredients).

7. Allergenic Fragrance Ingredients • Allergic fragrances to be listed using their INCI names when added in concentrations > 0,01%. Amyl Cinnamal Benzyl Cinnamate Benzyl Alcohol Farnesol Cinnamyl Alcohol Butylphenyl Methylpropional Eugenol Linalool Hydroxycitronellol Benzyl Benzoate Isoeugenol Citronellol Amylcinnamyl Alcohol Hexyl Cinnamal Benzyl Salicylate Limonene Cinnamal Methyl 2-Octynoate Coumarin Alpha-Isomethyl Ionene Geraniol Evernia Prunastri Extract Anise Alcohol Evernia Furfuracea Extract Hydroxyisohexyl 3-Cyclohexene-Carboxaldehyde

8. Ingredient Labelling Guidance • The labelling provisions apply to the packaging of detergents sold to the general public. • “Packaging“ refers to the individual product package purchased and handled by the consumer. • They do not imply labelling of • the outer package delivered to the retailer. • immediate packaging (flow wrap on tablets, the cage of a rimblock, etc.).

9. A.I.S.E. Recommendations • The ingredient or chemical class names as specified before must always be used. • The agreed list is intended to communicate the presence of ingredients and not their absence. • Information regarding the purpose/function of the ingredients should only be given in a distinguishably different part of the pack. • If any of the four specified concentration ranges contains no ingredient, that concentration rage can be omitted from the label. • The print size used should be as easily readable as other advisory statements on the package.

10. A.I.S.E. Recommendations • The concentration of the ingredients should be communicated referring to active matter and anhydrous form. • The ingredients ‘nominal’ concentration as specified in the product manufacturing specifications should be used to identify the weight percent range. • Phosphates should be expressed % P multiplied by 4, where P is the phosphorous derived from the inorganic phosphates present in the product. • Salts of EDTA and NTA should be expressed as the acids EDTA or NTA, as appropriate. • “Polycarboxylates” should be interpreted as referring to homo and co-polymers of acrylic acid and expressed as sodium salt.

11. A.I.S.E. Recommendations • Also preservatives added indirectly to the detergent via its ingredients (e.g. via preserved surfactants) have to be listed irrespectively of their concentration. • Preservatives at trace levels have to be labelled unless they are technically unavoidable and technologically ineffective and do not cause adverse effects to human health. • Any biocidal actives (BPD 98/8/EC) incorporated in detergent product with antibacterial or disinfecting effects must be labelled as a “disinfectant”.

12. Guidance for Institutional & Industrial Products • For detergents intended to be used in the industrial sector only labelling of ingredients on the package is not required if equivalent information is provided in technical data sheets, safety data sheets, etc. • I&I products which are sold in Cash & Carry Markets should be labelled with “For professional use only”. • Additional information to ensure appropriate consumer protection should be included on the label when the Cash & Carry Markets are open to non-professionals. • I&I products intended to reach also the general public have to be labelled fully in accordance to the “domestic” provisions.

13. Practical Examples Heavy-Duty Powder Detergent Light-Duty Liquid Detergent

14. Practical Examples Dishwashing Liquid

15. Practical ExamplesHeavy-Duty Powder Detergent Ingredients 15–30% oxygen based bleaching agents 5-15% anionic surfactants <5% non-ionic surfactants, soap, polycarboxylates, phosphates, Zeolites enzymes optical brighteners Perfume (Benzyl Salicylate, Hexyl Cinnamal, Linalool)

16. Practical ExamplesDishwashing Liquid Ingredients: 5-15% anionic surfactants, <5% amphoteric surfactants, perfume (Limonene, Linalool), preservation agents (2-Bromo-2- nitropropane-1,3-diol, Methylchloroisothiazolinone, Methylisothiazolinone)

17. The following information is required on the package of laundry detergents for domestic use: Quantities and/or dosage instructions for standard machine loads for soft, medium and hard water including instructions for one and two cycle washing processes. Capacity of any provided measuring cup and markings of the appropriate dose of detergent for a standard machine load for the 3 water hardness levels. Labelling of Dosage Information (1) Annex VII B * water hardness: soft, medium, hard ** water hardness: very hard

18. Number of standard machine loads (4,5 kg / 2,5 kg) which can be washed with the content of a package at medium water hardness (2,5 mmol CaCO3) referring to normally soiled fabrics for heavy-duty detergents. lightly soiled fabrics for light duty detergents. Labelling of Dosage Information (2) Annex VII B

19. A.I.S.E. Recommendations • The following definitions should be used to ensure consistency of interpretation concerning dosage recommendations at the different water hardness levels: Soft water: <150 ppm CaCO3 (1,5 mmol – 150 mg per litre) Medium water: 150 ppm ≤ CaCO3 ≤ 250 ppm Hard water: > 250 ppm CaCO3 • Additional recommended dosage information may be communicated to cater for particularly heavily or lightly soiled or small or large loads • “Making provision for one or two cycle washing process..” should be interpreted as referring to “main wash” and “pre-wash + main wash”.

20. A.I.S.E. Recommendations • To identify the appropriate product type (heavy-duty or light-duty detergent), the claims and the presentation of a product should normally be sufficient. In case of doubt, the product should be assumed to be ‘heavy-duty’ for the indication of the number of standard loads that can be washed. • The number of standard washes should be clearly identified, preferably prominent on the front of the package associated with an appropriate icon/logo. • Measuring cups should have a dosing scale (in ml) with sufficiently small subdivisions to allow accurate dosing for standard machine loads for the 3 water hardness levels. For powders a ml to g equivalence should be shown on the pack.

21. Labelling of additional Elements Art. 11(2) • The following information must appear legibly, visibly and indelibly on the package of detergents for the general public and for I&I: 1. Name and trade name of the product. 2. Name, full address and phone number of the party responsible for placing the product on the market 3. Address, e-mail address (where available) and phone number to obtain the ingredients datasheet for medical personnel. 4. Website where the ingredients datasheet for consumers can be obtained. 5. Instructions for use and special precautions, if required. • 1 – 4 must also appear on all documents accompanying detergents transported in bulk.

22. Practical ExamplesHeavy-Duty Powder Detergent

23. Practical ExamplesHeavy-Duty Powder Detergent Universal laundry detergent for automatic washing machines. Validity date : 3 years after the producing date, stamped on the packaging. S2: Keep away from children. Keep in dry rooms. Keep away from freezing. After wash by hand clean thoroughly the hands. Keep away from eyes. If product gets into eyes rinse thoroughly with water. People with sensitive or damaged skin should avoid prolonged contact with the product. Do not ingest. If product is ingested than seek medical advice. It is not recommended for wool and silk products.