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Internal A.I.S.E. Newsletter for members, December 2021
In this newsletter you will find: 
🔵 Special Highlights
🔵 Product Safety & Regulatory Affairs 
🔵 Sustainability & End-user Engagement
🔵 Communications, Advocacy & Stakeholder Engagement
A.I.S.E. Annual Cleaning & Hygiene Forum focuses on driving circularity and the European Green Deal

At the 2021 edition of its annual Cleaning & Hygiene Forum, A.I.S.E. reiterated its commitment to contribute constructively to the European Commission’s Green Deal’s and the Circular Economy Action Plan (CEAP).
The annual event, combined this year with a symposium on the Charter for Sustainable Cleaning, gathered some 250 participants to hear from high-level speakers from the Commission, the upcoming French Presidency of the EU, industry, and external experts on the theme of "Cleaning and circularity: working together to meet the Green Deal’s objectives”.

Read the whole article with main key takeaways from each speaker. If you missed it and still want to catch up watch forum video here and you can download all the speaker presentations here.

This year has again been marked by a very dense workload that has been managed with a lot of energy and fortitude by the whole A.I.S.E. team. Please find below an overview of A.I.S.E.'s main achievements:

Cleanliness & Hygiene/ Advocacy & Communication:

  • New Activity & Sustainability report launched incl. KPI reporting (June)
  • Joint A.I.S.E./IFH Targeted Hygiene Report launched during World Health Day and successfully presented to various policy contacts (April onwards)
  • Joint Unique Formula Identifier (UFI) campaign with ECHA (November onwards)
  • MEP outreach programme with 20+ contacts (November/December)
  • Stakeholder engagement with consumer NGOs (CLEAN/NordQual)
  • A.I.S.E. led Joint Industry Letter on Better Regulation
  • Input to CLP revision consultation submitted (November)
  • Input submitted to studies on Detergent Regulation and Digitalisation of Hazard Info
  • Pilot project with qualitative and quantitative research on provision of online information presented externally (December)
  • Green Deal / Chemicals Strategy for Sustainability (CSS) – input to 2 High Level Round Table meetings and reports, on SSbD criteria, and on strategic dependencies
  • REACH revision – input submitted on polymers, restrictions, Eds, PFAS
  • Use Map Package – completion of 4th and final A.I.S.E. SPERC
  • Biocides: RAC opinion on BIT, with 360 ppm limit allowing continued consumer product use
  • Zero Pollution – input to consultation on urban wastewater treatment
  • DUCC Communication for the 20 Years anniversary launched (October)
  • Meeting with DG ENV re Charter “bridging” (November)
  • Vision and recommendations to deliver on the EU Green Deal CEAP objectives & Charter evolution: several workstreams initiated  3rd party recognition: Charter meets new more stringent Siegelklarheit criteria and continues to be recognised as a 'good choice’
  • Climate mitigation: progress on A.I.S.E. activities (quantification + comms campaign)
  • Packaging: contribution to EU Circular Plastics Alliance activities on Design for Recycling & Recyclability
Product Safety & Regulatory Affairs

Chemicals Strategy for Sustainability

A.I.S.E. participated in the 2nd High Level Round Table meeting on 25 November, at which the Rules of Procedure were adopted.  The Round Table adopted a report on enforcement and compliance, which includes ten key recommendations for the Commission.  The Round Table will hold a third meeting in May 2022 focusing on the strategic R&I agenda and Safe & Sustainable by Design; work will begin soon on developing the report for adoption at the meeting (press release). 
 In January, the Sherpas (including Jan Robinson A.I.S.E. Director) will begin developing the report on the strategic Research & Innovation agenda and the role of Safe and Sustainable by Design.  This will be important for a transition pathway that leaves no-one behind.
On 2 Dec. 2021, CEFIC released their Economic Analysis of the Impacts of the Chemicals Strategy for Sustainability Repor (undertaken by Ricardo). CEFIC DG Marco Mensink joined A.I.S.E.’s  December board to present the report, its release and the consequences for downstream users like the detergent industry. A.I.S.E. is currently reviewing our first draft report on the CSS Impact Assessment for release beginning of 2022 with a communication plan.

Detergent Regulation 

The work of the Detergent Regulation review can be divided into different topics, a summary and update are provided below:

High level Update - General Revision of the Detergent Regulation 
Public consultation and targeted stakeholder consultations expected to take place in Jan 2022 and A.I.S.E. will be involved in both. 
Some topics that the Commission is considering in the consultation revision are: 
  • How microbial cleaning products are regulated 
  • Phosphate/ P use in our sector 
  • Biodegradability of non-surfactant ingredients 
  • Labelling and refill sale 
  • Detergent labels, simplification and digitalisation of information, removing discrepancy and duplication
Update on Sub-points: 
  1. Phosphates (P) in our sector 
Following a meeting between A.I.S.E. and the Commission in November, it became clear that one of the Commission’s priorities, as part of the Detergent Regulation Review, is to reduce phosphates in professional cleaning products, in a similar way that they were restricted in household products. While the meeting with the Commission was constructive, they have requested data on phosphate use in our sector, including on the market size, possible economically viable alternatives to P, examples/ market categories where it is crucial for P to be used and Life Cycle Analysis information.  A.I.S.E. has distributed a survey to the membership and the support of companies will be crucial.

Despite the Commission’s acknowledgement that our industry is responsible for only 1% of total discharge into the environment, we urgently need to ensure there is not a blanket ban for the sector. In 2014 when a restriction on P in household products took place, the industry took a proactive stance, showing how a reduction in the use of P was already underway. The Commission will consider options, so ideally, we would come forward with proposals, for example showing the impact of reducing P in certain applications (e.g. difficult to remove tea/coffee stains in catering textiles without P, leading to higher rate of replacement of textiles) and show how the use of P has been reduced in recent years (due to high cost).
  1. Microbial cleaning products 

An A.I.S.E. expert subgroup is working on guidance for microbial cleaning products and is aligning with the American Cleaning Institute (ACI) microbial cleaning product Task Force.

  1. Labelling and refill sale
A.I.S.E. is updating the Labelling and refill sale guidance originally published in October 2020
  1. Labelling of fragrance allergens 
The proposal under the Cosmetics Regulation to expand the fragrance allergen list is ongoing and will have a direct impact on Detergents. Commission has confirmed they will align with  the   Cosmetics Regulation and companies will have 3 years for placing on the market and 5 years for product withdrawal. A.I.S.E. is following this topic closely.
  1. Labelling of preservatives 
There is an ongoing discussion on labelling of preservatives, and especially the labelling of carry-over preservatives, under the Detergent Regulation.  The Commission and some member states want all carry-over preservatives to be labelled irrespective of concentration. 
A.I.S.E. is proposing an minimum threshold that carry-over preservatives are labelled based on the most conservative value among the following: 
  1. The threshold for EUH208 under CLP for preservatives that are skin sensitizers. 
  1. A general fall-back margin for all non-sensitizing preservative set at 100 ppm (this is a conservative value. To be treated as a default, and assumes the value for skin sensitizer Cat. 1A, although the ingredient may have no data identifying it as a skin sensitizer). 
  1. The value below which studies demonstrate that the ingredient no longer has preservation effect on a final formulation (based on literature Minimum Inhibitory Concentration (MIC) values and expert input of A.I.S.E. members). 
This proposal was discussed at the Commission Detergent WG on the 15th December and member states have until the 28th February to comment.

Digitalisation: Pilot project and consumer habits survey

Initial  findings from A.I.S.E. funded qualitative and quantitative consumer research held in FR, POL, SP and SWE on simpler label options and the provision of hazard and sustainability information online are available.  
The findings still need to be analysed by the relevant A.I.S.E. groups (SSG, Digitalisation WG, Detergent Regulation WG, CLP WG). key sustainability information results were shared during A.I.S.E.’s Cleaning & Hygiene Forum, and the hazard information and use of e-labels results were presented to the Commission Detergent WG meeting on 15 December with all EU Members States, demonstrating A.I.S.E.’s commitment to the Commission's work on Hazard Information simplification and use of IT Tool.
In a nutshell: The data confirmed that the simpler label proposed by A.I.S.E. is the one favoured by consumers, and that the value of information provided on a website (via QR code) is greatly appreciated by consumers.  It also indicates that allergen information is wished to be labelled in an exhaustive way (50% of the sample). And that the alternative label with all ingredients listed is not the one favoured by consumers.  Providing online more details on how a brand meets the Charter criteria is also very much appreciated. These findings are therefore supportive to the A.I.S.E. strategy.
A.I.S.E. will organise its input to the current public consultation (open untill 16 Feb 2022) during  early  January, and will continue to collaborate with the Commission consultant VVA/Conpolicy as they finalise their report (due in March 2022).

CLP Update

A.I.S.E. submitted its response to the CLP open public consultation on 10 November, along with support from INCPA colleagues who answered the consultation as well.

The Commission launched an Impact Assessment in August and expects it to close in March 2022. This Impact Assessment is meant to evaluate and quantify the impact of the CLP revision on the industry and national authorities. To this end, a ‘Targeted Stakeholder Survey’ due for 22 December has been shared with A.I.S.E. and our experts are currently preparing our response.

In parallel to the various surveys, the Commission is organising meetings with Competent Authorities for REACH and CLP or relevant sub-groups to focus on specific topics.

A draft CLP revision proposal is expected in mid-2022 and the Commission is committed to maintain this official timeline.
Sustainability & End-User Engagement

A.I.S.E. Charter for Sustainable Cleaning / meeting DG ENV

On 30 Nov. A.I.S.E. met with DG Environment's Sustainable Production, Products and Consumption unit, to receive feedback on our technical proposal to develop and integrate PEF criteria into the A.I.S.E. Charter and avoid the Commission proposing a completely new scheme for our sector.
In summary, A.I.S.E. is on the right track with the current Charter 2020+ and the planned technical revisions; however, further alignment will be needed (such as product comparison/differentiation, full life-cycle approach, and on ingredients’ assessment i.e. risk-based vs. USETox).

Communications, Advocacy & Stakeholder Engagement

MEP Outreach

In November, A.I.S.E. organised a very successful outreach programme towards Members of the European Parliament (MEPs). The Secretariat and Members met more than 20 MEPs’ offices to introduce A.I.S.E. and our policy priorities for this legislative mandate, as well to start establishing contacts with their offices ahead of future collaboration. The Advocacy Steering Group will be looking to build upon our relationships in the European Parliament and undertake an outreach programme towards Member States in early 2022.

New Product Stewardship Programme (PSP) 21 and updated safe use icon

On 17 Dec. 21, A.I.S.E. released  the  new version of the Product Stewardship Programme (PSP) for liquid detergent capsules. A.I.S.E. produced an updated consolidated Project description in 2021 ("the 2021 PSP") which aims to improve transparency and clarity to existing and potential signatories. The limited changes introduced by the 2021 PSP mainly concern the mandatory safety message (e.g. further precision concerning social media channels) and safe use patch design. Companies who have previously signed the PSP are kindly invited to re-sign based on this new version.
New companies interested in joining the PSP can do so by using this letter. NAC members are requested to promote this initiative to local companies to further increase the list of signatories.
In addition, A.I.S.E. released a slightly updated version of the  safe use icon entitled ‘Do not tear apart stuck capsules” (initially launched in July 21), to enhance consumer understanding. This icon, available for voluntary use, can be retrieved from this page on the A.I.S.E. artwork page on the public site.

Unique Formula Identifier “UFI” campaign 

A.I.S.E. has launched a campaign to promote the Unique Formula Identifier (UFI) to EU citizens in support of ECHA, via our social media accounts, on and via the NAC Network. We have received very good feedback from stakeholders, including the Commission. A.I.S.E. was pleased to take this  opportunity to further promote  its Keep Out of Reach of Children icon.
All members of A.I.S.E. – including corporate members – are invited to promote this campaign via their social media account; please access the ECHA toolkit here.
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