assessment on product level - european...

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Annex

Assessment on product level

0 Introduction ................................................................................................... 3

1 Durability........................................................................................................ 41.1 Options..................................................................................................................... 41.2 National furniture eco-labels and other EU Eco-labels ............................................ 41.3 Proposal for draft criteria.......................................................................................... 5

2 Fitness for use............................................................................................... 72.1 Options..................................................................................................................... 72.2 National eco-labels and other EU Eco-labels .......................................................... 72.3 Proposal for draft criteria.......................................................................................... 7

3 Reparability.................................................................................................... 83.1 Options..................................................................................................................... 83.2 National eco-labels and other EU Eco-labels .......................................................... 83.3 Proposal for draft criteria.......................................................................................... 9

4 Maintenance ................................................................................................ 104.1 Options................................................................................................................... 104.2 National eco-labels and EU Eco-labels.................................................................. 104.3 Proposal for draft criteria........................................................................................ 11

5 Recycling ..................................................................................................... 115.1 Options................................................................................................................... 115.2 National eco-labels and EU Eco-labels.................................................................. 125.3 Proposal for draft criteria........................................................................................ 12

6 Reuse ........................................................................................................... 136.1 Options................................................................................................................... 136.2 National eco-labels and EU Eco-labels.................................................................. 146.3 Proposal for draft criteria........................................................................................ 14

7 Waste management hazardous substances ............................................. 147.1 Options................................................................................................................... 147.2 Proposed criteria .................................................................................................... 14

8 Transport ..................................................................................................... 148.1 Options................................................................................................................... 148.2 National eco-labels and EU Eco-labels.................................................................. 148.3 Proposal for draft criteria........................................................................................ 15

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9 Ergonomics.................................................................................................. 159.1 Options ................................................................................................................... 159.2 National eco-labels and EU Eco-labels.................................................................. 159.3 Proposal for draft criteria........................................................................................ 16

10 Safety............................................................................................................ 1610.1 Options ................................................................................................................... 1610.2 National eco-labels and EU Eco-labels.................................................................. 165.3 Proposal for criteria ................................................................................................ 17

11 Packaging..................................................................................................... 1711.1 Options ................................................................................................................... 1711.2 National eco-labels and EU Eco-labels.................................................................. 1811.3 Proposal for draft criteria........................................................................................ 18

12 Consumer information ................................................................................ 1912.1 Options ................................................................................................................... 1912.2 National eco-labels and EU Eco-labels.................................................................. 1912.3 Proposed draft criteria ............................................................................................ 20

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0 ____ Introduction

In Annex B, the analysis is presented of environmental, health and safety related andperformance issues on a product level. There seems to be no common approach of thenational eco-labels on which categories of issues should be distinguished. An attempt ismade to bring all relevant issues together which are addressed by national eco-labels forfurniture or have been raised in the first meeting of the Ad Hoc Working Group. Anexplanation of what is understood by the different issues is given in the main report. Thefollowing issues can be distinguished:

Performance• Durability• Fitness for use

Environmental• Reparability• Maintenance• Recycling• Reuse• Waste management hazardous substances

Health and safety• Ergonomics• Safety

Other• Packaging• Consumer information• Transport

It does not necessarily mean that all these issues need to be addressed by the EU Eco-label. This depends on the findings of the analysis and on the discussions in the AHWG.

For each issue the following aspects will be described:

• Options for formulating criteria• The approaches adopted by the national eco-labels for furniture and relevant EU

Eco-labels• Proposal for draft criteria

The following labels have been included in the analysis:

• Milieukeur meubelen (Stichting Milieukeur, The Netherlands);• RAL-UZ 38, Grundlage für Umweltzeichenvergabe/Blauer Engel,

(Umweltbundesamt, Germany);• ÖkoControl für Möbel (Gesellschaft für Qualitätsstandards ökologischer

Einrichtungshäuser mbH. Germany);• RAL-RG 430 Allgemeine Güte- und Prüfbestimmungen für Möbel/Goldene M

(Deutsche Gütegemeinschaft Möbel e.V., Germany);• Ecolabelling of Furniture and Fitments and of Wooden outdoor furniture, Nordic Swan

(Nordic Ecolabelling, Nordic countries);• Marque NF Environnement (France);

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• Richtlinie UZ 06 and UZ 34, (Österreichisches Umweltzeichen, Austria).

On the basis of the approaches adopted by the national labels, an analysis is made ofthe different options that are available to tackle a certain performance issue. Theseoptions are weighted against each other on their pro’s and contra’s, also taking intoconsideration the fact that the chosen option has to fit in well with the broad approach ofthe EU Eco-label Furniture. Since the scope on material and product group level of theeco-label of Nordic Swan and Stichting Milieukeur are the most comparable to theproposed scope of the EU Eco-label Furniture, these labels will be leading in settingcriteria for performance, health and safety related issues.

Reference should be made to Directive 1999/44/EC on certain aspects of the sale ofconsumer goods and associated guarantees. This Directive regulates fitness for purposeof consumer goods and liability of the seller. From 1 January 2002 this Directive had tobe implemented by the Member States. This Directive can be considered to provide abasic protection for consumers against inferior products and could therefore serve assafety net besides the quality criteria proposed in the EU Eco-label Furniture.

1 ____Durability

1.1 ____ Options

Most national eco-labels address the durability issue, but the criteria are very different.The following options can be distinguished:

1. Specified reference to national and international standards (Goldene M);2. Non specified reference to national and international standards (Nordic Swan for

indoor furniture), including specific performance levels;3. Detailed, absolute standards (Nordic Swan for outdoor furniture)4. Measure based standards (Stichting Milieukeur and Österreichisches

Umweltzeichen);5. Open requirements (ÖkoControl).

Several labels distinguish different criteria on durability for contract furniture and outdoorfurniture.• With respect to contract furniture this has to do with the intensity of use. Therefore,

contract furniture has to fulfil higher testing standards (Nordic Swan, Goldene M forschool furniture).

• With respect to outdoor furniture, the criteria have to take into account the fact thatoutdoor furniture has to endure all sorts of weather conditions. This is possible in twoways:� Formulating detailed, absolute standards (Nordic Swan, Goldene M);� Formulating less stringent standards for durability in comparison with other

(indoor) types of furniture (Stichting Milieukeur).

1.2 ____ National furniture eco-labels and other EU Eco-labels

Type of criteriaSpecified reference to(inter)nat. standards

E.g. DIN 68878 for schoolchairs, EN 581-2-9/95 for outdoor furniture(Goldene M)

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Non specifiedreference to (inter)nat.standards

Durability, strength, safety and stability requirements in nat., Eur. or other internat.standards, with specific reference to different (ISO) levels for testing. If a standardother than ISO/EN is fulfilled, proof of comparable appliance by test institute isrequired. If no standard exists, evaluation by independent test institute. (NordicSwan).

Detailed, absolutestandards

With respect to outdoor furniture:- Protection of wood that comes into contact with the ground and of end-grain timberin plywood sheets.- Design should be so that water cannot run off.- Any metal parts used in outdoor furniture must not contain material that can rust ordiscolour the furniture.Furthermore:- Requirement levels for durability, strength, safety and stability relevant to theproduct’s area of use.- As a minimum requirement, the requirement levels for domestic use according to EN581-1, 581-2 and 581-3.- If for contract use, test against requirement levels relevant to contract use.- If a standard other than ISO/EN is fulfilled, proof of comparable appliance by testinstitute.(Nordic Swan)

Measure basedstandards

Guarantee for five years (indoor), three years (outdoor). Fillings can have loss inheight and firmness of max. 20%. (Stichting Milieukeur).

Option between:- Reparability service;- Replacement warrantee for parts that wear out easily for at least 10 years,- A service telephone for customers;- A take back system(Österreichisches Umweltzeichen)

Open requirement The way wood is connected should contribute to long life-span.(ÖkoContro)l

1.3 ____ Proposal for draft criteria

Furniture is a product with a relatively long life. From the perspective of environment andresources, long life is an important parameter. For furniture, the environmental impact islimited during use and more associated with production and waste. That often means thata long durability can balance environmental impacts during production and waste. Forthis reason, criteria have to be formulated with respect to durability. This is supported bythe fact that nearly all national eco-labels contain a criterion for durability.

There seems to be overall consensus within the AHWG to make use of existingstandards as much as possible. The existing international standards in the field ofdurability do not cover all products included in the scope of the EU Eco-label scheme.Therefore, the approach used by Nordic Swan seems to be a pragmatic way to deal withdurability for several reasons:

• By referring to national and international standards in general it is not necessary tomake a complete inventory of all existing standards.

• By referring to ISO testing levels an equal minimum quality standard is assured, evenif different national testing methods are applied.

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• It is not necessary to make a comparison between standards if competing standardsexist. It is left to the company applying for the label to choose between differentexisting standards.

• The company can choose a testing institute itself, under the condition that it isaccredited.

• Different purposes of furniture are taken into account by differing between ISOtesting levels for domestic use, normal contract and hard contract (restaurant/café)use. This means that domestic furniture has to apply with testing levels for domesticuse and contract furniture with the testing levels of normal or hard contract use.

• Other standards than EN or ISO are acceptable as long as they correspond with therequirements defined by ISO.

• If no standards exist, an independent test institution may perform an evaluation of theproduct’s safety, durability and fitness for use on the basis of the design and choiceof materials.

One comment on this proposal is that up till now the furniture industry is not very familiarwith the application of ISO, EN or other standards. In particular SME's may need someguidance in what standards exist. For this reason it is suggested to refer in the scheme tothe institutions that can provide this information, i.e. standardisation institutes and branchorganisations.

Outdoor furniture is not covered by the above-mentioned approach. Nordic Swandistinguishes a separate scheme for outdoor furniture, which contains detailed, absolutecriteria on durability. There is an EN standard under development for outdoor furniturewith respect to the durability under the influence of climatic conditions. However, thisstandard has not been accepted yet. It would be more in line with the approach for indoorfurniture to refer to this EN standard when this is accepted (this may still take a longperiod of time).

Proposed criterion:For indoor furniture the approach of Nordic Swan will be followed with respect todurability, strength, safety and stability requirements. A minimum quality standard has tobe assured by a minimum testing level (these levels still need to be established). Formore information on the applicable standards the applicant should refer to the nationalstandardisation institute or the branch organisation for furniture.

Assessment and verification:As a rule the products to be tested should be selected on the basis of the test standard.Unless otherwise specified, tests should be performed within the product family to whichthe product belongs. The weakest and most critical elements in terms of stability shouldbe selected for testing, for example drawers with the biggest dimensions and longesttravel, tables with the longest free spans, etc.

The test institution must provide an account of variations within the product grouprepresented by the tested products, and verify that the product is representative.

Furthermore, information should be provided about the standard to which the product hasbeen tested, the test institution and the test results. If applicable an account of hownational standards correspond with ISO’s requirements has to be given. If an alternativeapproach is followed information has to be provided on the test institution, the test reportand the assessment criteria.

Proposed criterion:

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For outdoor furniture the approach of Nordic Swan will be followed as well or specifiedreference will be made to the EN standard under development. In the latter case it mustbe realized that this standard is still subject to change.

Assessment and verification:Appropriate testing method, depending on which criterion is chosen.

2 ____ Fitness for use

2.1 ____ Options

Fitness for use is addressed by several of the national eco-labels with respect to differentproduct groups (domestic furniture, contract furniture and children furniture). It also formspart of the EU Eco-label for hard floor coverings. The following options can bedistinguished:

1. Specified reference to national and international standards (Goldene M,Österreichisches Umweltzeichen);

2. Non specified reference to national and international standards (Environnement NF);3. Detailed, absolute standards (Goldene M);4. Open standard (EU Eco-label for hard floor coverings).

2.2 ____ National eco-labels and other EU Eco-labels


E.g. DIN 68890 2/85 for depth of cupboards and DIN EN 747 for children furniture(Goldene M)

The quality of the materials and product have to fulfill at least quality level S (standard)of ÖNORM 1610 (Österreichisches Umweltzeichen)

Non specifiedreference to (inter)nat.standards

Contract furniture which are within the scope of the eco-label fulfil the quality regulationsof the concerning sector (Environnement NF)


Specific standards with respect to e.g. width of sliding doors, the depth of wardrobes,the way backboards have to be connected to the back of a cupboard (Goldene M)

Open requirement The product shall be fit for use. This evidence may include data from appropriate ISO,CEN or equivalent test methods, such as national or in-house test procedures. (EU Eco-label Hard floor coverings)


Considering the fact that furniture is a very broad and divers product group, there aremany different international and national standards with respect to fitness for use. Thesestandards do not cover all aspects. Wishing to cover all fitness for use aspects or asmany as possible would mean that additional absolute standards would have to beformulated, as is done by Goldene M. This does not fit in with the desire to keep the Eco-

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label practical and pragmatic. Furthermore, it would also confront manufacturers orretailers that want to apply for the label with very high testing costs.

For this reason it is proposed to follow the pragmatic approach of the EU Eco-label Hardfloor coverings.

Proposed criterion:The product shall be fit for use. This evidence may include data from appropriate ISO,CEN or equivalent test methods, such as national or in-house test procedures.

Assessment and verification:Details of the test procedures and results shall be provided, together with a declarationthat the product is fit for use based on all information about the best application by theend-user. According to Directive 89/106/EEC a product is presumed to be fit for use if itconforms to a harmonised standard, a European technical approval or a non-harmonisedtechnical specification recognised at Community level.

3 ____Reparability

3.1 ____ Options

Several labels hold measure based requirements on reparability.

3.2 ____ National eco-labels and other EU Eco-labels

Type of criteriaMeasure basedstandards

Detachable parts should be kept in stock and/or production. These parts have to bedeliverable during the effective period of fabrication and the manufacturer has toensure that these parts stay deliverable during 5 years after ending production.(Environnement NF)

All service parts (hinges, weels, etc.) of furniture should be separately deliverable forfive years. (Stichting Milieukeur and Blauer Engel)

- Easy disassembly of all parts of the furniture.- Disassembly for more than 90% of the furniture into: metals/inertmaterials/combustible materials.1

- Separation possible of larger parts made of synthetic foam and massive plastics (>200g).- Furniture boards with a synthetic or synthetic resin layer do not need to be separablein separate materials2.- Disassembly of seating furniture: if the upholstery and/or filling are assembled to themain construction, these should be easily separable. Glued surfaces, which cannoteasily be separated, are not permitted. Connections with clamps are permitted, ifthese connections can also be used for new parts.(Stichting Milieukeur)

1 Inert materials are stony materials and glass. Combustible materials are: plastics, textile, leather, rough fibers and woody

materials.2 The reason for this is that these boards are hardly recycled in practice.

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- Materials have to be easily separated.- Adhesive bindings between wood and wood based materials is permitted.- The use of composite materials is not permitted.- Adhesive bindings are only permitted if this is necessary with respect to theergonomic construction of the back of the seat.- The individual parts, especially parts that wear out fast, have to be easily separable.- Essential parts that wear out fast have to be deliverable for at least 10 years afterending of production of the specific model.(Österreichisches Umweltzeichen)


All existing criteria in the field of reparability are based on the same principle: that serviceparts have to be deliverable during a certain number of years after purchase of theproduct. From the side of manufacturers and retailers objections have been raisedagainst this approach:

• It is very difficult to guarantee the availability of spare parts, in particular if producersare out of business.

• It poses SME's for the problem how to keep a stock of all parts for such a long periodof time. Care should be taken not to develop criteria which make it impossible forSME's to apply for the Eco-label.

• For some parts of furniture products, repair is for safety reasons not allowed.• Some furniture exists of only one part (e.g. chairs made of PVC), which makes

reparation impossible.• The producer or retailer should not be held responsible for wrong use by the

consumer. Therefore, some sort of arbitration should be incorporated in the schemeto determine if the consumer has wrongly used or treated the product.

From environmental point of view, on the other hand, one can point to the fact thatreparability ensures a longer life-span of the product. As mentioned in paragraph 1.3 along life time can balance environmental impacts of furniture during production andwaste. It is therefore an issue that should not be ignored.

To counter the above-mentioned objections some manufacturers are of the opinion that itis better to rely on technical standards with respect to durability than to set criteria forreparability. This also appears to be the approach of eco-labels that refer to internationaland national standards with respect to durability, like Nordic Swan and Goldene M.These eco-labels do not contain separate criteria on reparability. For example, NordicSwan did not set any standards for reparability since these standards would have to bevery product specific and detailed (e.g. what is considered a spare part?).

Another suggestion was made by the AHWG, namely to make reparability an extrafeature within the Eco-label, e.g. an A plus within the label. However, this is an approachwhich can not be followed by the EU Eco-label (and most of the national eco-labels)

Presuming that the criteria with respect to durability provide sufficient insurance withrespect to a long life span, and the fact that legally, consumers are given a certainwarrantee, it is proposed to set no criteria on reparability.

Proposed criterion:

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No criteria are set with respect to reparability. This issue could be taken up again in arevision of the criteria.

4 ____Maintenance

4.1 ____ Options

Few labels contain criteria with respect to maintenance. The options are:

1. Detailed, absolute standards with respect to the maintenance product (Nordic Swan);2. Measure based standards with respect to maintenance itself (Stichting Milieukeur);3. Consumer information (Goldene M and Nordic Swan).

4.2 ____ National eco-labels and EU Eco-labels

Type of criteriaDetailed, absolutestandards

Specific requirements with respect to maintenance products for outdoorfurniture:- Not classified as hazardous to health in Nordic countries.- Maximum of 2% by weight of substances that fulfil the criteria forenvironmental harmfulness according to the relevant regulations in Nordiccountries, or according to the EU classification system Directive 67/548/EECwith specific conditions and changes.- Biocides contained in maintenance products must not be bio accumulative.- Surface treatment agents may contain a maximum of 5% by weight oforganic solvents.- No halogenated organic compounds, halogenated organic flame retardants,phthalates, aziridine and polyaziridines, along with pigments and additivesbased on lead, tin, cadmium, chromium VI, mercury and their compounds.(Nordic Swan)


Cleaning of products should be possible without organic based solvents.(Stichting Milieukeur)

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Consumer information Information on cleaning and care has to be provided. (Goldene M)

The manufacturer/supplier should recommend specified requirements (seeabove) regarding maintenance products and should specify therecommended product’s trade name. (Nordic Swan)


There are two environmental aspects relevant to maintenance. Maintenance and caresafeguard the furniture’s life-span. However, maintenance can also constitute extensiveenvironmental impact. Many of the maintenance products available to consumers on themarket today contain environmentally hazardous substances and organic solvents. TheEco-label cannot impose requirements on the consumer’s choice of maintenanceproduct, but demands can be placed on the producer to recommend less environmentallyharmful maintenance products.

The Nordic Swan eco-label for outdoor furniture contains very detailed information onwhich products to use and even requires the producer to mention the brand’s name ofthe most appropriate cleansing product. This would not work in the European marketsince so many different products are on the market. Therefore, the criteria should be keptmore pragmatic.

Proposed criterion:Cleaning of products should be possible without organic based solvents. Information oncleaning and care has to be provided.

Assessment and verificationThe applicant and/or his supplier shall provide a declaration completed with documents tosupport this declaration that this criterion is met. A maintenance instruction has to beincluded with the product.

5 ____ Recycling

5.1 ____ Options

Recycling requirements on product level are very limited in existing schemes. Mostrecycling requirements are on a material level (see also annex A). Several options areavailable to deal with recycling on product level:

1. Non specified reference to international and national legislation (Nordic Swan and NFEnvironnement);

2. Measure based standards (Ökocontrol, Nordic Swan, EU Eco-label Hard floorcoverings, NF Environnement, Österreichisches Umweltzeichen);

3. Consumer information (Stichting Milieukeur, EU Eco-label Mattresses).

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Type of criteriaNon specifiedreference to (inter)nat.standards

The producer or importer of ecolabelled products ensures that nationallegislation governing recycling schemes for products and packaging arefulfilled in the Nordic countries in which the ecolabelled product is sold.(Nordic Swan)

Waste during production which cannot be reused at location and containingmore than 5% of organic materials has to be disposed of in authorizedinstallations according to national legislation. (NF Environnement)


Products have to be recyclable or fit for reuse. Materials have to beseparable. (Ökocontrol)

Waste generated during furniture production has to be reduced and recycledas far as possible. Waste deriving from renewable resources may beexploited for energy purposes. (Nordic Swan)

At least 70 % (by weight) of the total waste generated by the process or theprocesses shall be recovered according to the general terms and definitionsestablished by Council Directive 91/156/EEC of 18 March 1991 amendingDirective 75/442/EEC on waste. (EU Eco-label Hard floor coverings)

Possibility of disassembly at end of life of each element heavier than 50 gram.(NF Environnement)

The producer or retailer has a take back obligation. (ÖsterreichischesUmweltzeichen)

Consumer information Consumer information on the best way of discarding the furniture has to beprovided. (Stichting Milieukeur)

“Please consult your local authority on the best way to dispose of your oldmattress.” (EU Eco-label Mattresses)


The environmental impact of furniture is to a large extent associated with waste.According to information of UEA, it is likely that most furniture waste is dumped althoughno detailed official statistics are available. An increase in consumption of furniturecontributes to a rise in the amount of waste associated with furniture and vice-versa.Increased recycling and re-use of furniture has the opposite effect.(www.ueanet.com/furniturewaste).

Therefore, recycling of the materials used in furniture after end of life should beencouraged. It goes without saying that national legislation in the field of recycling has tobe fulfilled, but this is an obligation for all manufacturers and does not need specialmentioning in the Eco-labelling scheme.

Several aspects are necessary to take into account when formulating criteria for recyclingat product level:

http://www.ueanet.com/furniturewaste

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• Disassembly is a prerequisite to ensure recycling, but is difficult to test (it will comedown to expert judgement).

• Disassembly is more expensive than moulding furniture, after which the materials areseparated for recycling.

• Recycling needs a take back system of products. This brings about certain problems:o The change of materials by consumers (e.g. painting etc.) should be taken

into account when setting criteria for take back.o Take back of furniture is of no use when there is no system to handle

products that are taken back.o There is discussion on the fact if the responsibility for take back has to be

posed either on the retailer or the manufacturer.o The costs of take back of products will directly or indirectly be paid by the

consumer.

None of the approaches of existing labels provides a solution to the above-mentioneddilemma’s. It would be very ambitious to require the set up of a take back system for alltypes of furniture. For this reason it is suggested to only impose criteria with respect torecyclability, but not to require the set up of a take back system.

Proposed criterion:Products have to be recyclable or fit for reuse. Materials have to separable. In the usermanual with the product the options of recycling and reuse have to be mentioned.Furthermore, consumers have to be pointed to the fact to contact their local authorities onthe best way to dispose of old furniture.

Assessment and verification:The applicant shall provide appropriate information on the construction and compositionof the product on the basis of which the certificating institute can assess whether theproduct is separable and recyclable.

The applicant shall provide a sample of the product’s packaging and of the informationsupplied with the product.

6 ____ Reuse

6.1 ____ Options

Reuse is only covered by two schemes. The options are:

1. Measure based standards (Ökocontrol);2. Consumer information (Stichting Milieukeur).

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Products have to be recyclable or fit for reuse. (Ökocontrol)

Consumer information Reuse of materials has to be mentioned as an option to the consumer.(Stichting Milieukeur)


Proposed criterion:Reference is made to the proposed criterion for recycling.

7 ____Waste management hazardous substances

7.1 ____ Options

No requirements were found with respect to waste management of hazardoussubstances in the national eco-labels or other EU Eco-labels. The main reason for this isprobably that the management of hazardous substances is already part of nationallegislation.

7.2 ____ Proposed criteria

Proposed criterion:It is proposed not to set a criterion for waste management of hazardous substances.

8 ____Transport

8.1 ____ Options

Only one label contains a criterion with respect to transport, which can be categorised as:1. Measure based standard (NF Environnement).



Space during transport and storage has to be optimised. (NF Environnement)

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Optimised use of space during transport and storage is not only in the interest of theproducer and retailer from an environmental point of view, but is probably also aimed atfor economical reasons. For this reason it seems unnecessary to put this requirementinto the scheme. Moreover, it may be very difficult to verify compliance with thisrequirement.

Proposed criterion:It is proposed not to include a criterion on transport in the EU Eco-label Furniture.

9 ____ Ergonomics

9.1 ____ Options

Very few of the national eco-labels contain ergonomic criteria. The following options arepresented:1. Specified reference to national standards (Österreichisches Umweltzeichen);2. Detailed, absolute standards (Österreichisches Umweltzeichen);3. Open requirement (ÖkoControl).



Sizes of seats and desks for use in schools have to fulfil the criteria ofÖNORM A 1650. (Österreichisches Umweltzeichen)


With respect to office and swivel chairs:- Testing according to ÖNORM A 1675;- Seat and back have to be upholstered;- The wheels have to be light and quickly responding;- The break system has to fulfil the necessary safety requirements accordingto appropriate norms;- A spring has to intercept jerking when adjusting the seat in height;- Operation of adjustability mechanisms has to be possible without using forceand from seating position, with the exception of the back;- The back should be adjustable for large persons;- Armrests have to be present;- Upholstery has to be breathable and permeable for vapour;- The combination of upholstery, shape and seat has to prevent sliding andensure a full use of the seat;- Information on correct seating has to be provided;- Dynamic seating principle: this has to be supported by the construction ofthe seat.(Österreichisches Umweltzeichen)

Open requirement The product has to adapt to the human being and not the other way around.This applies to chairs (depth and height), beds (height) and kitchens (heightwork top). (ÖkoControl)

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It may be desirable to formulate ergonomics criteria for office chairs and school furniture,sub-groups where ergonomics play an important role. On the other hand, standards mayvary in different countries and it may be expected that the market for office chairs andschool furniture will regulate itself on this issue (producers will follow demand forergonomics certified products). This and the fact that only two of the national labels haveset criteria regarding ergonomic aspects and the fact that the requirements will probablybe very hard to verify unless certification is required, it is proposed not to set anystandards for ergonomics.

Proposed criterion:It is proposed not to include a criterion on ergonomics.

10 ___Safety

10.1 ___ Options

Only Österreichisches Umweltzeichen and Goldene M contain specific safetyrequirements. Nordic Swan has included safety issues together with durability, strengthand stability. The following options can be distinguished:

1. Specified reference to international and national standards (ÖsterreichischesUmweltzeichen and Goldene M);

2. Non specified reference to international and national standards, including specificlevels to comply to (Nordic Swan).

10.2 ___ National eco-labels and EU Eco-labels


- Desks have to be adjustable in height and fulfil the criteria of ÖNORM A1676 and ÖNORM EN 527-1.- Swivel chairs have to fulfil the criteria of ÖNORM A 1675 or DIN 4551regarding the seize, fundamental technical safety of shape, stability andstrength.- Desk chairs have to fulfil the criteria of ÖNORM A 1610 Part 5 concerningthe materials and their effect, stability, distortion and durability.- If a gas spring is used for the adjustment in height then this has to fulfil theprescribed safety requirements.- Textile upholstering has to fulfil ÖNORM EN ISO 12947-2.(Österreichisches Umweltzeichen)

Safety requirements of E DIN EN (Goldene M)Non specifiedreference to (inter)nat.standards

Durability, strength, safety and stability requirements in nat., Eur. or otherinternat. standards, with specific reference to different (ISO) levels for testing.If a standard other than ISO/EN is fulfilled, proof of comparable appliance bya test institute is required. If no standard exists, evaluation by independenttest institute. (Nordic Swan).

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5.3 ____ Proposal for criteria

It is suggested to follow the approach of Nordic Swan and to refer to existing internationaland national standards in the field of safety and to require that specific quality levels(according to ISO) are met. This does not need a separate criterion if the approach assuggested in paragraph 1.3 is followed.

Special attention should be paid to the fire safety of the product. The producer can makeuse of international standards to test fire behaviour. However, none of the national eco-labels or other EU Eco-labels require testing on fire behaviour. Within the first meeting ofthe Ad Hoc Working Group it was stated that in case no flame retardants are used, theconsumer should be made aware of the fact that the product is not fire safe. This ishowever not in line with the approach followed by the national labelling schemes and theEU Eco-label. Moreover, this would require further specification indicating what is meantby 'not fire safe' and further specification based on the flammability of the materials used.

Proposed criterion:It is proposed to follow the approach of Nordic Swan and to refer to existing internationaland national standards in the field of safety, with a reference to minimum testing levels.Safety can be included in the same criterion as durability. For this reason no separatecriterion is needed (see paragraph 1.3).

Proposed criterion:It is proposed not to set a criterion with respect to flammability when no flame retardantsare used.

11 ___ Packaging

11.1 ___ Options

Nearly all national eco-labels for furniture contain criteria with respect to packaging. Inother EU Eco-labels packaging is only dealt with in the label for footwear. The followingoptions are used:

1. Detailed, absolute standards (Goldene M, Österreichisches Umweltzeichen, NordicSwan, Milieukeur, EU Eco-label Footwear);

2. Measure based standards (Österreichisches Umweltzeichen, Blauer Engel, NFEnvironnement).

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Type of criteriaDetailed, absolutestandards

Used plastics have to be free of halogenated organic compounds and cannotbe based on styrol compounds. (Österreichisches Umweltzeichen)

Plastic material containing chlorine is not permitted. (Nordic Swan)

The amount of weight of package material may not exceed 40 kg, unless forsound reasons. (Goldene M)

Packaging needs to be made of one type of recyclable material (cardboard,paper, polyethene, polypropene, polystyrene). Packaging may consist of morematerials if this can be separated easily by hand in recyclable parts consistingof one material. (Stichting Milieukeur)

If packed in carton boxes, package should consist of at least 80% recycledmaterial. If in plastic bags, then it should be recycled material (EU Eco-labelfootwear)


The one who brings packaging in the market has either a take back obligationor the obligation to participate in a collecting and recycling system.(Österreichisches Umweltzeichen)

Packaging has to be breathable insofar as possible. (Blauer Engel andÖsterreichisches Umweltzeichen)

- Packaging should be made of easy recyclable materials or materials ofrenewable sources.- Complex non recyclable composites are permitted if it is used in multi-rotation packaging. This criterion applies to packaging of end products andpackaging used by suppliers.(NF Environnement)

11.3 ___ Proposal for draft criteria

Reference is made to the European Directive on packaging and packaging waste94/62/EC. The Directive contains essential requirements which all packaging introducedonto the EU market has to satisfy. The CEN has developed standards with respect to theimplementation of the essential requirements, some of which are under revision (EN13428 - EN 12432). The Directive aims at reducing packaging waste and indicatesmethods how to achieve this, one of which is recycling.

DG Environment has a policy to encourage the use of recycled material as much aspossible. This would lead to the adoption of the requirement of the EU Eco-labelFootwear (cardboard: 80% recycled, plastics 100% recycled). Relevant branchorganisations have been consulted on the question if it is feasible to require recycledmaterial. If packaging is made of cardboard it should not be a problem.

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For plastic material however, it appears to be a very hard criterion to comply with, forseveral reasons:

• Recycled plastic is not used for packaging material on a large scale. Although plasticpackaging material is collected for recycling purposes, it is mainly used to produceother products and not for packaging material.

• Packaging material composed of recycled plastic is mainly hard plastic, like crates.This is (probably) not used by the furniture industry.

• Recycled plastic foil is of inferior quality.• Recycled plastic foil is for its dark colour less attractive from a marketing point of

view.

Since the approach of Stichting Milieukeur is less stringent but still fits in well with theobjective of encouraging recycling of packaging material, it is suggested to combine thisapproach with the one of EU Eco-label Footwear.

Proposed criterion:Packaging needs to be made of one type of recyclable material (cardboard, paper,polyethene, polypropene, polystyrene). Packaging may consist of more materials if thiscan be separated easily by hand in recyclable parts consisting of one material(cardboard, paper, polyethene, polypropene, polystyrene). Where cardboard is used forthe final packaging of furniture, it shall be made from a minimum of 80% recycledmaterial.

Assessment and verification:A sample of the product packaging shall be provided on application, together with acorresponding declaration of compliance with this criterion.

12 ___ Consumer information

12.1 ___ Options

All national eco-labels indicate what consumer information should be provided. This isdone either in a very elaborate way or kept very simple. It is done on the basis ofmeasure based standards.



An instruction for assembly and one for use have to be included. Theinstructions for use need to fulfil DIN standards (8418-2/88). (Goldene M)

Maintenance instructions have to be included with the furniture and foroutdoor furniture also instructions on durability (including weather resistance).(Stichting Milieukeur)

- Instructions for cleaning and maintaining the product with specificinstructions for the different materials;- Information regarding which standards have been applied in testing theproduct’s properties of use;

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- Illustrated assembly instructions if the item of furniture or fitment is soconstructed that it needs to be assembled;- Information about the materials used in the product and how these can berecycled or treated in an environmentally friendly manner.- With respect to outdoor furniture the consumer is informed as to the bestway to use, maintain and store it.(Nordic Swan)

- Instruction on parts subject to wear and their repair or replacement, ifapplicable repair service, and 5 years deliverance spare parts;- Type and source of wood;- Other materials;- Instruction on construction or transportation of the product;- Instruction on assembly;- Durability.(Blauer Engel)- Name and address of holder of label;- Modeldescription;- Quality of furniture according to ÖNORM A 1610-1 (S or H)- Used wood type, and other materials;- Used materials for surface treatment;- Measurements;- Maintenance instruction;- For office and school furniture information on ergonomic design of workplaceor classrooms.(Österreichisches Umweltzeichen)

The product shall be sold with relevant user information, which providesadvice on the product's proper and best general and technical use as well asits maintenance. In detail is indicated what information has to be provided onthe packaging and/or on documentation accompanying the product. (EU Eco-label Hard floor coverings)

- NF Environnement label and information;- Information on waste disposal at end of life;- Information on maintenance(Environnement NF)

12.3 ___ Proposed draft criteria

In the previous paragraphs it has already been indicated what information should beprovided on issues like maintenance, recycling, etc. In summary, the followinginformation should be supplied:

Proposed criterion:Consumer information should consist of:

• Information regarding which standards have been applied in testing the product’sdurability, safety and fitness for use;

• Information on cleaning and care;• Information on the options of recycling and reuse and the fact that local authorities

should be contacted on the best way to dispose of old furniture;• An instruction for assembly;

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• With respect to outdoor furniture the consumer is informed about the best way to use,maintain and store it.

Verification and assessment:The applicant shall provide a sample of the information material supplied with thefurniture.

assessment on product level - european...

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