August 7, 2017 by Olivia Tran

Since the Ecolabel criteria for rinse-off cosmetics were updated in December 2014, wca have prepared and submitted a number of new applications for clients. Our experience with the UK Delivery Body has been very positive and we have worked together to identify the right information to meet the criteria and improve the dossiers. Here we highlight some tips and nuances to consider in preparing a robust application.

1. Toxicity to aquatic organisms
   The DID list was revised in 2016 and is available here. The calculation sheet integrates the 2014 version of the DID List, however you can check the 2016 version to see if there are new data available for your ingredient.
2. Biodegradability
   There are options to exempt non-surfactant ingredients from the requirement for anaerobic degradability. Exemption can be applied if the non-surfactant ingredient is readily degradable and has either low adsorption (A< 25%), high desorption (C>75%) or is non-bioaccumulating. Adsorption/desorption and bioaccumulation data are usually easier to find than anaerobic degradation data.
3. Excluded or limited substances and mixtures
   We recently came across a point of disagreement with the UK Delivery Body in the interpretation of the classification derogation criterion. A survey was consequently submitted to the EU Competent Body Forum to gain consensus from other national Delivery Bodies on how the criteria should be interpreted. It is best to clarify with the assessor before submission on how they will assess the Ecolabel criteria, but the criteria can be challenged if they are open to interpretation.
4. Packaging
   There is a discrepancy between the calculation sheet and criteria guidelines in the user manual with regards to the residue test. “m3” is calculated using the virgin packaging weights in the calculation sheet, whereas the user manual defines “m3” as “primary packaging emptied and cleaned”. Residue results from both calculation methods can be reported, however this will need to be flagged to the Ecolabel assessors.
5. Sustainable sourcing of palm oil, palm kernel oil and their derivatives
   In addition to the criteria declarations, the assessors will want to see evidence of third-party certification (e.g. RSPO certification number) from the supplier and/or applicant.
6. Fitness for use
   An in-house consumer test is the easiest way to fulfil this criterion. Each national Delivery Body will have different market-leading products, therefore it is best to ask the Delivery Body in the country you are applying in. The guidance for the design and reporting of efficacy tests can be found here.
7. Information appearing on the EU Ecolabel
   If your product is marketed under different names or packaging, you will have to provide the artwork for all the different labels. Keep in mind there are specific logo guidelines (e.g. colour, size) to be met. The guidance for use of the EU Ecolabel logo can be found here.

The current criteria are set to expire in December 2018, however they are likely to be extended. If you would like help in preparing any type of EU Ecolabel application, please contact Olivia at olivia.tran@wca-consulting.com