Appendix
Detergents Ingredients Database (DID) list
The DID list (Part A) is a list containing information on the aquatic toxicity and biodegradability of ingredients typically used in detergent formulations. The list includes information on the toxicity and biodegradability of a range of substances used in washing and cleaning products. The list is not comprehensive, but guidance is given in Part B of the DID list concerning the determination of the relevant calculation parameters for substances not present on the DID list (e.g. the Toxicity Factor (TF) and degradation factor (DF), which are used for the calculation of the critical dilution volume). The list is a generic source of information and substances present on the DID list are not automatically approved for use in EU Ecolabel products.
Part A and Part B of the DID list can be found on the EU Ecolabel website at:
https://ec.europa.eu/environment/ecolabel/documents/DID%20List%20PART%20A%202016%20FINAL.pdf
https://ec.europa.eu/environment/ecolabel/documents/DID_List_PART_B_2016_FINAL.pdf
For substances with no data regarding aquatic toxicity and biodegradability, structure analogies with similar substances may be used to assess the TF and DF. Such structure analogies shall be approved by the competent body granting the EU Ecolabel license. Alternatively, a worst case approach shall be applied, using the parameters below:
Worst case approach:
|
|
Acute toxicity |
Chronic toxicity |
Degradation |
||||||
|
Ingoing added substance |
LC50/ EC50 |
SF (acute) |
TF (acute) |
NOEC (1) |
SF (chronic) (1) |
TF (chronic) |
DF |
Aerobic |
Anaerobic |
|
‘Name’ |
1mg/l |
10 000 |
0,0001 |
|
|
0,0001 |
1 |
P |
N |
|
(1)
If no acceptable chronic toxicity data is found, these columns are empty. In this case, TF (chronic) is defined as equal to TF (acute). |
|||||||||
Documentation of ready biodegradability
The following test methods for ready biodegradability shall be used:
Until 1 December 2015:
The test methods for ready biodegradability provided for in Council Directive 67/548/EEC ( 25 ), in particular the methods detailed in Annex V.C4 to that Directive, or their equivalent OECD 301 A-F test methods, or their equivalent ISO tests.
The 10-day window principle shall not apply for surfactants. The pass levels shall be 70 % for the tests referred to in Annex V.C4-A and C4-B to Directive 67/548/EEC (and their equivalent OECD 301 A and E tests and ISO equivalents), and shall be 60 % for tests C4-C, D, E and F (and their equivalent OECD 301 B, C, D and F tests and ISO equivalents).
or
The test methods provided for in Regulation (EC) No 1272/2008.
After 1 December 2015:
The test methods provided for in Regulation (EC) No 1272/2008
Documentation of anaerobic biodegradability
The reference test for anaerobic biodegradability shall be EN ISO 11734, ECETOC No 28 (June 1988), OECD 311 or an equivalent test method, with the requirement of 60 % ultimate biodegradability under anaerobic conditions. Test methods simulating the conditions in a relevant anaerobic environment may also be used to document that 60 % ultimate biodegradability has been attained under anaerobic conditions.
Extrapolation for substances not listed in the DID-list
Where the ingoing substances are not listed in the DID-list, the following approach may be used to provide the necessary documentation of anaerobic biodegradability:
Apply reasonable extrapolation. Use test results obtained with one raw material to extrapolate the ultimate anaerobic biodegradability of structurally related surfactants. Where anaerobic biodegradability has been confirmed for a surfactant (or a group of homologues) according to the DID-list, it can be assumed that a similar type of surfactant is also anaerobically biodegradable (e.g., C12-15 A 1-3 EO sulphate [DID No 8] is anaerobically biodegradable, and a similar anaerobic biodegradability may also be assumed for C12-15 A 6 EO sulphate). Where anaerobic biodegradability has been confirmed for a surfactant by use of an appropriate test method, it can be assumed that a similar type of surfactant is also anaerobically biodegradable (e.g., literature data confirming the anaerobic biodegradability of surfactants belonging to the group alkyl ester ammonium salts may be used as documentation for a similar anaerobic biodegradability of other quaternary ammonium salts containing ester-linkages in the alkyl chain(s)). Nevertheless, vice-versa if a structurally similar surfactant has been shown not to be anaerobically degradable, it can be assumed that a similar type of surfactant is also not anaerobically biodegradable.
Perform screening test for anaerobic biodegradability. If new testing is necessary, perform a screening test by use of EN ISO 11734, ECETOC No 28 (June 1988), OECD 311 or an equivalent method.
Perform low-dosage biodegradability test. If new testing is necessary, and in the case of experimental problems in the screening test (e.g. inhibition due to toxicity of test substance), repeat testing by using a low dosage of surfactant and monitor degradation by 14C measurements or chemical analyses. Testing at low dosages may be performed by use of OECD 308 (August 2000) or an equivalent method.
Documentation of bioaccumulation
The following test methods for bioaccumulation shall be used:
Until 1 March 2009:
The reference test for bioaccumulation shall be OECD 107 or 117 or equivalent. The pass levels shall be < 500 or log Kow is < 4,0.
The OECD 305 test on fish. For a BCF < 500 the substance is considered not bioaccumulative. If there is a measured BCF value, it is always the highest measured BCF that is used in assessing a substance’s bioaccumulative potential.
After 1 March 2009:
The reference test for bioaccumulation shall be OECD 107 or 117 or equivalent with the requirement of < 500 or log Kow is < 4,0
Documentation on aquatic toxicity:
The lowest available NOEC/ECx/EC/LC50 value shall be used. If chronic values are available, they shall be used instead of acute ones.
For acute aquatic toxicity test methods nos. 201, 202 and 203 ( *2 ) in the OECD Guideline for the Testing of Chemicals or equivalent test methods shall be used.
For chronic aquatic toxicity test methods nos. 210 (*2) , 211, 215 (*2) and 229 (*2) in the OECD Guideline for the Testing of Chemicals or equivalent test methods shall be used. OECD 201 may be used as chronic test if chronic endpoints are chosen.
( 25 ) Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances (OJ 196, 16.8.1967, p. 1).
( *2 ) The Commission prohibited animal testing of ingredients for cosmetic products from March 2009 onwards. To determine aquatic toxicity, however, the prohibition only concerns testing with fish (does not include invertebrates). As such, OECD test guideline no. 203 (acute toxicity – fish), 210, 215 and 229 (chronic toxicity – fish) shall not be used to document acute/chronic toxicity. The results of acute/chronic toxicity testing using fish produced before March 2009 may still be used, however.