1. Assessment of the Potential Risk, if any, of Surfactant Chemicals to the Environment
This study carried out on behalf of the EU DGIII was designed to identify if surfactant chemicals posed a risk in surface waters, and to determine whether or not a requirement to assess the ultimate biodegradability of surfactants would be beneficial for minimising the impact of future surfactants. The study focussed on the issues surrounding persistence of surfactants and their potential for oestrogenic activity.
At the time of this report (1997) of the parent surfactants which had been tested for oestrogenicity, none have been shown to be oestrogenic. Thus, it appeared that the parent surfactants themselves did not provide cause for concern regarding the potential effects of exposure to oestrogenic chemicals. A number of breakdown products of the APEs have been shown in the scientific literature to be weakly oestrogenic in a number of assays. Both the position and branching of the alkyl group were known to affect oestrogenicity. Data obtained at the time of the study from the in vivo rainbow trout vitellogenin bioassay suggested that an oestrogenic response may be seen at concentrations of around 10 and 3 g per litre of nonyl and octylphenol, respectively. However, the importance of this in terms of health and ecology of fish populations remained uncertain.
Based on data received from AISE and CESIO during the study, the total production volume of the all surfactant chemicals which would fail the screening test is less than 100,000 tonnes per year, equated to approximately 3% of the total annual production of surfactant in detergent sold in the European Community. Analysis of standardised biodegradation data revealed that alkylphenol ethoxylates (octyl- and nonyl-), which at the time of the study (1997) had a maximum Community production volume of 50,000 tonnes per year, were the sole priority candidates for risk assessment, judged on the basis of the relative persistence and oestrogenic activity of their biodegradation intermediates.
The study concluded that in view of the biodegradability data set for surfactant chemicals, it did not appear to be advantageous to change the legislation to test the small number of chemicals, which were prioritised in this report. Alternatively, the judgement of chemical persistence and fate in the environment was assumed on the basis of a voluntary agreement between industry and representatives of the Commission, whereby chemicals could be assessed on a case by case basis by an ad-hoc committee. The basis for guidance may be readily drawn from the OECD or EC strategies for biodegradability testing was outlined in this report.
2. An Assessment of the Code of Good of Good Environmental Practice for Household Laundry Detergents
An Environmental Code of Conduct was proposed in the late 1990s by the Association Internationale de la Savonnerie, de la Détergence et des Produits d’Entretien (A.I.S.E). Any manufacturer, importer or other persons within the European Detergent Industry, whether or not affiliated to A.I.S.E. national associations, which adopted the Code of Good Environmental Practice for household laundry detergents, would commit itself to striving to achieve a reduction in household laundry products, packaging, poorly-biodegradable ingredients, and energy used in the washing process.
The targets, proposed for the European Economic Area (EEA), starting in early 1998, were reductions of:
- 10% for products
- 10% for packaging
- 10% for poorly-biodegradable ingredients, and
- 5% for energy reduction
They were to be established for five years. The overall objective of this study on behalf of the EU DGIII was to identify whether the requirements for industry, as laid down in the Code, are sufficient and, if not, to suggest ways to improve them.
Data provided by A.I.S.E. showed that the average per capita consumption of all laundry detergents for Europe has reduced by approximately 12.5% over the years from 1990 to 1995. However, analysis of the following three years returns from trade members has shown a 3.5% increase in household laundry product consumption. Furthermore, the data provided by A.I.S.E. relating to energy usage from laundry products indicated that the trend had plateaued by 1998. These two factors emphasised the potential difficulty of meeting the proposed 10% reduction targets for energy and product consumption within a five year timeframe.
The trend in the Industry during the late 1990s had been a steady compaction and concentration of products over the years which has resulted in the reduction of the weight of packaging material used per wash occasion. A.I.S.E. data revealed that a 40% reduction of packaging used for an average wash was achieved on a European basis between 1991 and 1995.
It was likely that the European five year target of 10% reduction in packaging consumption would be achieved only with the continued implementation of a strategy for increasing the market share of compact powders coupled to a programme of consumer awareness for the use of refill packaging. A review of the percentage market share of household detergents within western Europe in the late 1990s illustrated that concentrated powders had a market share of 28%. In general, the Member States, which at the time of the study had very limited penetration of compact powders, were located in the southern region. Analysis of data provided by A.I.S.E. indicated that a 25% replacement of conventional powders by compact powders and liquids across Europe would provide the basis for meeting the product reduction target of 10%, whilst also maintaining the potential for washing performance. Data provided in this study indicated that the replacement of conventional powders with compact powders for heavy duty colour and light duty products would result in an increase in the poorly-biodegradable content. A possible means of reducing poorly biodegradables by 10%, without the development of suitable replacements, would be undertaken by a strategy for replacement of conventional powders with, where possible, compact liquids.
It was apparent from the data in this study in the late 1990s that considerable scope existed for Europe as a whole for an increase in the market shares of concentrated powders and liquids at the expense of conventional powders. The implementation of the Code was expected to provide a fresh dynamic to the use of compacts in favour of regular powders. Indeed, the goal of the Code was to reduce the amount of product, but not by introducing mandatory regulation of compacts in preference to conventional powders.
A.I.S.E. were keen that the Code was not seen as a command-and-control instrument and was, thus, likely to gain the positive commitment of most players in the industry. This strategy helped progress to be made quickly and cost-effectively, since it allows for industry-led innovation in the interest of sustainable development. A.I.S.E. and National Associations encouraged all members (and, even, non-members) to subscribe to the Code.
A pilot study, termed the ‘Wash Right’ programme, was initiated in Denmark and Sweden in 1998 to introduce the Code of Practice to the consumers. All of the major washing detergent suppliers in Sweden joined the trade's environmental programme. Together, the affiliated companies represented 80% of the washing detergent sold in Sweden. A positive response to the Code was given by the following stakeholders: National Chemicals Inspectorate, Swedish Environment Protection Agency, The National Swedish Board of Consumer Policies, The Ministry of Public Administration and the most important environmental lobby group in Sweden, Naturskyddsföreningen. The response from retailers was positive.