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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.
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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
Regulatory/Digitalisation:
- 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)
Sustainability:
- 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
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Product Safety & Regulatory Affairs
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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.
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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:
- 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).
- 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.
- Labelling and refill sale
A.I.S.E. is updating the Labelling and refill sale guidance originally published in October 2020
- 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.
- 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:
- The threshold for EUH208 under CLP for preservatives that are skin sensitizers.
- 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).
- 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.
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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).
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