Labelling of Detergents according to Regulation (EC) 648/2004: Overview of Main Requirements and Practical Examples

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Labelling of Detergents according to Regulation
(EC) 648/2004 Overview of Main Requirements and
Practical Examples

• Dr. Dagmar Zaika A.I.S.E. / Henkel AG Co.
  KGaA
• Workshop on the Implementation of the
• Regulation (EC) 648/2004 Detergents Regulation
• INFRA 32637
• Bucharest, Sept. 21 22, 2009

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Labelling of Detergents

• EC No. 648/2004 (Detergents Regulation) and its
  amendment EC No. 907/2006 regulate the labelling
  of
• ingredients in detergents and cleaning products.
• dosage information for laundry detergents.
• additional elements.
• Labelling provisions are without prejudice of
  other regulations (DSD, DPD, CLP,..).

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A.I.S.E. Guideline

• to help industry with the implementation.
• approved by the Commission and the Member States.
• published on the website of the European
  Commission
• http//ec.europa.eu/enterprise/sectors/chemicals/
  files/legislation/final_aise_guideline_rev_7_feb_0
  5_22_en.pdf

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Labelling of Ingredients

• The labelling provisions for the ingredients of
  detergents are laid down in Article 11(3) and
  Annex VII A distinguishing between
• ingredients to be listed when added gt0,2 by
  weight.
• ingredients to be listed irrespectively of their
  concentration.
• allergic fragrances to be listed when added
  gt0,01 by weight.

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Ingredients to be Labelled gt0,2

• Ingredients to be listed when added in a
  concentration above 0,2
• Phosphates NTA and salts thereof
• Phosphonates Phenols and halogenated phenols
• Anionic surfactants Paradichlorobenzene
• Cationic surfactants Aromatic hydrocarbons
• Amphoteric surfactants Aliphatic hydrocarbons
• Non-ionic surfactants Halogenated hydrocarbons
• Oxygen-based bleaching agents Soap
• Chlorine-based bleaching agents Zeolites
• EDTA and salts thereof Polycarboxylates
• Weight percent ranges to be applied
• less than 5
• 5 or over but less than 15
• 15 or over but less than 30
• 30 and more

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Ingredients to be Labelled w/o Threshold

• Classes of ingredients (if added) to be listed
  irrespective of their concentration
• enzymes
• disinfectants
• optical brighteners
• perfume
• preservation agents
• Preservation agents have to be declared using
  their INCI names (International Nomenclature of
  Cosmetic Ingredients).

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Allergenic Fragrance Ingredients

• Allergic fragrances to be listed using their INCI
  names when added in concentrations gt 0,01.
• Amyl Cinnamal Benzyl Cinnamate
• Benzyl Alcohol Farnesol
• Cinnamyl Alcohol Butylphenyl Methylpropional
• Eugenol Linalool
• Hydroxycitronellol Benzyl Benzoate
• Isoeugenol Citronellol
• Amylcinnamyl Alcohol Hexyl Cinnamal
• Benzyl Salicylate Limonene
• Cinnamal Methyl 2-Octynoate
• Coumarin Alpha-Isomethyl Ionene
• Geraniol Evernia Prunastri Extract
• Anise Alcohol Evernia Furfuracea Extract
• Hydroxyisohexyl 3-Cyclohexene-Carboxaldehyde

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Ingredient Labelling Guidance

• The labelling provisions apply to the packaging
  of detergents sold to the general public.
• Packaging refers to the individual product
  package purchased and handled by the consumer.
• They do not imply labelling of
• the outer package delivered to the retailer.
• immediate packaging (flow wrap on tablets, the
  cage of a rimblock, etc.).

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A.I.S.E. Recommendations

• The ingredient or chemical class names as
  specified before must always be used.
• The agreed list is intended to communicate the
  presence of ingredients and not their absence.
• Information regarding the purpose/function of the
  ingredients should only be given in a
  distinguishably different part of the pack.
• If any of the four specified concentration ranges
  contains no ingredient, that concentration rage
  can be omitted from the label.
• The print size used should be as easily readable
  as other advisory statements on the package.

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A.I.S.E. Recommendations

• The concentration of the ingredients should be
  communicated referring to active matter and
  anhydrous form.
• The ingredients nominal concentration as
  specified in the product manufacturing
  specifications should be used to identify the
  weight percent range.
• Phosphates should be expressed P multiplied by
  4, where P is the phosphorous derived from the
  inorganic phosphates present in the product.
• Salts of EDTA and NTA should be expressed as the
  acids EDTA or NTA, as appropriate.
• Polycarboxylates should be interpreted as
  referring to homo and co-polymers of acrylic acid
  and expressed as sodium salt.

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A.I.S.E. Recommendations

• Also preservatives added indirectly to the
  detergent via its ingredients (e.g. via preserved
  surfactants) have to be listed irrespectively of
  their concentration.
• Preservatives at trace levels have to be labelled
  unless they are technically unavoidable and
  technologically ineffective and do not cause
  adverse effects to human health.
• Any biocidal actives (BPD 98/8/EC) incorporated
  in detergent product with antibacterial or
  disinfecting effects must be labelled as a
  disinfectant.

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Guidance for Institutional Industrial Products

• For detergents intended to be used in the
  industrial sector only labelling of ingredients
  on the package is not required if equivalent
  information is provided in technical data sheets,
  safety data sheets, etc.
• II products which are sold in Cash Carry
  Markets should be labelled with For professional
  use only.
• Additional information to ensure appropriate
  consumer protection should be included on the
  label when the Cash Carry Markets are open to
  non-professionals.
• II products intended to reach also the general
  public have to be labelled fully in accordance to
  the domestic provisions.

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Practical Examples
Heavy-Duty Powder Detergent
Light-Duty Liquid Detergent
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Practical Examples
Dishwashing Liquid
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Practical ExamplesHeavy-Duty Powder Detergent
Ingredients 1530 oxygen based bleaching
agents 5-15 anionic surfactants lt5 non-ionic
surfactants, soap, polycarboxylates,
phosphates, Zeolites enzymes optical
brighteners Perfume (Benzyl Salicylate, Hexyl
Cinnamal, Linalool)
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Practical ExamplesDishwashing Liquid
Ingredients 5-15 anionic surfactants, lt5
amphoteric surfactants, perfume (Limonene,
Linalool), preservation agents (2-Bromo-2- nitropr
opane-1,3-diol, Methylchloroisothiazolinone,
Methylisothiazolinone)
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Labelling of Dosage Information (1) Annex VII B

• The following information is required on the
  package of laundry detergents for domestic use
• Quantities and/or dosage instructions for
  standard machine loads for soft, medium and hard
  water including instructions for one and two
  cycle washing processes.
• Capacity of any provided measuring cup and
  markings of the appropriate dose of detergent for
  a standard machine load for the 3 water hardness
  levels.

water hardness soft, medium, hard water
hardness very hard
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Labelling of Dosage Information (2) Annex VII B

• Number of standard machine loads (4,5 kg / 2,5
  kg) which can be washed with the content of a
  package at medium water hardness (2,5 mmol CaCO3)
  referring to
• normally soiled fabrics for heavy-duty
  detergents.
• lightly soiled fabrics for light duty detergents.

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A.I.S.E. Recommendations

• The following definitions should be used to
  ensure consistency of interpretation concerning
  dosage recommendations at the different water
  hardness levels
• Soft water lt150 ppm CaCO3 (1,5 mmol 150 mg
  per litre)
• Medium water 150 ppm CaCO3 250 ppm
• Hard water gt 250 ppm CaCO3
• Additional recommended dosage information may be
  communicated to cater for particularly heavily or
  lightly soiled or small or large loads
• Making provision for one or two cycle washing
  process.. should be interpreted as referring to
  main wash and pre-wash main wash.

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A.I.S.E. Recommendations

• To identify the appropriate product type
  (heavy-duty or light-duty detergent), the claims
  and the presentation of a product should normally
  be sufficient.
• In case of doubt, the product should be assumed
  to be heavy-duty for the indication of the
  number of standard loads that can be washed.
• The number of standard washes should be clearly
  identified, preferably prominent on the front of
  the package associated with an appropriate
  icon/logo.
• Measuring cups should have a dosing scale (in ml)
  with sufficiently small subdivisions to allow
  accurate dosing for standard machine loads for
  the 3 water hardness levels. For powders a ml to
  g equivalence should be shown on the pack.

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Labelling of additional Elements Art. 11(2)

• The following information must appear legibly,
  visibly and indelibly on the package of
  detergents for the general public and for II
• 1. Name and trade name of the product.
• 2. Name, full address and phone number of the
  party responsible for placing the product on the
  market
• 3. Address, e-mail address (where available) and
  phone number to obtain the ingredients datasheet
  for medical personnel.
• 4. Website where the ingredients datasheet for
  consumers can be obtained.
• 5. Instructions for use and special
  precautions, if required.
• 1 4 must also appear on all documents
  accompanying detergents transported in bulk.

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Practical ExamplesHeavy-Duty Powder Detergent
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Practical ExamplesHeavy-Duty Powder Detergent
Universal laundry detergent for automatic washing
machines. Validity date 3 years after the
producing date, stamped on the packaging. S2
Keep away from children. Keep in dry rooms. Keep
away from freezing. After wash by hand clean
thoroughly the hands. Keep away from eyes. If
product gets into eyes rinse thoroughly with
water. People with sensitive or damaged skin
should avoid prolonged contact with the product.
Do not ingest. If product is ingested than seek
medical advice. It is not recommended for wool
and silk products.
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