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Understanding the European Commission's Regulation on Detergents

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As we approach the 2023 SEPAWA Congress that will take place on October 25th-27th, it's only appropriate we take time to look at the European Commission's regulation on detergents: EC No 648/2004. In this blog, we will provide an overview of the regulation, guidance on implementation, and examine the specific biodegradability requirements in depth.

Overview of EC No. 648/2004

The Detergents Regulation (EC) No. 648/2004 is a piece of legislation that was enacted by the European Union in 2004. The purpose of the regulation is to control the adverse effects of detergents on the environment and human health. The regulation applies to all detergents that are placed on the market in the EU, including laundry detergents, dishwashing detergents, and household cleaners.

The regulation sets out a number of requirements for detergents, including:

  • Biodegradability: All surfactants in detergents must be readily biodegradable, meaning that they must be broken down by microorganisms in the environment. This is important to prevent the accumulation of detergents in water bodies, which can harm aquatic life.
  • Labelling: Detergents must be labelled with information about their ingredients and how to use them safely. This includes information about any hazardous ingredients in the detergent, as well as any precautions that should be taken when using it.
  • Restrictions on certain ingredients: The regulation bans the use of certain ingredients in detergents, such as phosphates and certain fragrances. These ingredients have been linked to environmental problems, such as eutrophication (excessive algae growth) in water bodies. The Detergents Regulation has been successful in reducing the environmental impact of detergents in the EU. For example, a study by the European Commission found that the regulation has led to a 60% reduction in the use of phosphates in detergents since it came into force.

The regulation has also helped to protect human health. For example, the ban on certain fragrances has actually reduced the risk of allergic reactions to detergents.

This regulation is an important piece of legislation that helps to protect the environment and human health. It is important to note that the regulation applies to all detergents that are placed on the market in the EU, regardless of where they are manufactured. This means that consumers can be confident that the detergents they are using are safe for the environment and for their health.

Guidance on Implementation

While translating this regulation into reality may seem difficult, here are several resources that can be utilized for guidance on the implementation of this legislation:

Surfactant Biodegradability Requirements

The regulation specifically calls out that surfactants in detergents need to meet an ultimate aerobic biodegradability requirement. The surfactants need to meet 60% biodegradability within 28 days from one of the following recommended tests:

  • EN ISO Standard 14593: 1999 (Evaluation of ultimate aerobic biodegradability of organic compounds in aqueous medium) Method by analysis of inorganic carbon in sealed vessels (CO2 headspace test). Pre-adaptation is not to be used. The 10-day window principle is not applied (reference method).
  • Directive 67/548/EEC method, Annex V.C.4-C (carbon dioxide (CO2) Eeolution modified Sturm test): pre-adaptation is not to be used. The 10-day window principle is not applied.
  • Directive 67/548/EEC method, Annex V.C.4-E (closed Bottle): pre-adaptation is not to be used. The 10-day window principle is not applied.
  • Directive 67/548/EEC method, Annex V.C.4-D (manometric respirometry): pre-adaptation is not to be used. The 10-day window principle is not applied.
  • Directive 67/548/EEC method, Annex V.C.4-F (MITI: Ministry of International Trade and Industry, Japan): pre-adaptation is not to be used. The 10-day window principle is not applied.
  • ISO 10708:1997 (Evaluation in an aqueous medium of the ultimate aerobic biodegradability of organic compounds) Determination of biochemical oxygen demand in a two-phase closed bottle test. Pre-adaptation is not to be used. The 10-day window principle is not applied.

If appropriately justified due to the physical characteristics of the surfactant, one of these additional test methods can be used. It should be noted for this list, the surfactant will need to achieve 70% biodegradability:

  • Directive 67/548/EEC method, Annex V.C.4-A (dissolved organic carbon DOC die-away): pre-adaptation is not to be used. The 10-day window principle is not applied.
  • Directive 67/548/EEC method, Annex V.C.4-B (modified OECD screening-DOC die-away): pre-adaptation is not to be used. The 10-day window principle is not applied.

References
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