UNION EUROPEENNE DE L’ARTISANAT ET DES PETITES ET MOYENNES ENTREPRISES
EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE
EUROPEAN ASSOCIATON OF CRAFT, SMALL AND MEDIUM-SIZED ENTERPRISES
UNIONE EUROPEA DELL’ ARTIGIANATO E DELLE PICCOLE E MEDIE IMPRESE
UEAPME's comments on 8th July 2003
draft Eco-Label criteria on furniture
I. GENERAL OVERVIEW
UEAPME believes that these draft criteria, if approved as such, will not be able to raise the
interest of SME manufacturers in the new Eco-Label for furniture. As a matter of fact, most
of the procedures and requirements set by these draft criteria (such as, for instance, the ones
on sustainable forest management and on coating for wood and wood-based materials) are not
suitable for SMEs, and particularly for micro and small businesses, since they do not consider
their structures, their ways of operating and their position in the supply chain. These criteria
are, therefore, likely to be so burdensome and costly that they outweigh the market and image
advantages SMEs get from eco-labelled products. Furthermore, the underlying idea of
banning plastics will strongly limit the number of small and big companies able to apply for
the new Eco-label criteria. This in turn will act against a wide uptake of these new criteria,
contradicting the marketing efforts undertaken so far at EU and national level in order to
disseminate the EU Flower.
II. COMMENTS ON SPECIFIC DRAFT CRITERIA
1.4
Hazardous substances
Last sentence before “assessment and verification” does not make sense:
“…and where less than 0.1% remains in the form as before application”
2.1 & 2.2
Certified wood / sustainable forest management
As mentioned previously, although the wording does not specifically state that chain-ofcustody certification will be required by the furniture manufacturer, it will in fact be required
by the majority of sites. This is because timber of a specific type is often purchased from a
number of sources. If one or more of these is not certified, the furniture manufacturer will
require an internal system to prove that the required amount of certified timber has entered
the eco-labelled product.
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In the case where certified timber is not available, no clarification is given to the amount of
proof required. Also, what if certified timber is available but only at a significant cost
premium?
Furthermore, there are an infinite number of timber producer certificates which state that their
product comes from a sustainable source. In reality, the vast majority are meaningless.
Therefore, what type of proof could be used to show that the wood comes from sustainable
managed forests other than certification by a third party – i.e. FSC, PEFC etc?
UEAPME has underlined several times that small companies will always struggle most with
certification due to the relative scale of the cost and man-power implications, coupled with
the fact they are unlikely to have the purchasing power to influence their suppliers if the latter
are not tempted by the certification process.
2.5. Plastics
The level of plastic allowed for surface coating applications is too low and does not
correspond to the current application by furniture manufacturers (for instance, kitchen
manufacturers can use a percentage up to 17%). The percentage proposed by the draft criteria
is, therefore, totally unrealistic and correspond to an indicrect ban of plastic for surface
coating applications.
2.5.1. Hazardous additives
UEAPME does not agree with the mere exclusion of phtalates from the final Eco-label
criteria. This exclusion is not based on scientific evidence, since the risk assessment has
shown that most phtalates are not dangerous. This case shows again the attempt to make the
use of plastic directly or indirectly impossible in the new Eco-label criteria on furniture
simply on the basis of emotional reactions or suppositions, which UEAPME cannot support..
2.5.3. Input recycled material
25% recycling target for all plastics not used as surface coating application is too high. Since
there is no legislation obliging to recycle furniture and the plastics used in furniture, this
target is quite unrealistic. There might be the risk that furniture might be refused just because
the minimum amount of recycled plastics prescribed by the criteria might not be available at
all or at reasonable costs on the market.
2.7.3 & 2.7.4 Leather
There seems to be an unnecessary number of requirements on the use of leather – which after
all, is a renewable resource. There are also two requirements (2.7.3 COD and 2.7.4 chrome)
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which relate to the environmental performance of the supplier rather than the furniture
manufacturer site. Neither COD emissions from waste water or chrome in waste water will
affect the content of the leather at the furniture site and the control of such emissions is the
responsibility of the leather producer and its regulators. Therefore, these requirements are
largely irrelevant to the furniture site. In addition, smaller furniture manufacturers would have
difficulty obtaining such information due to their lack of buying power. They would have
even less chance of influencing the supplier behaviour other than buying elsewhere – which
may increase costs.
2.10.1 Feathers waste water treatment
Same argument as above.
3.3.1) Coatings for wood and wood-based materials (other than plastics and metals)
 A title of “wood coatings” would be more comprehendible to manufacturers.
 Why are flame retardants mentioned in this section – they are applied to fabric not wood?
 The distinction between flat and 3D furniture has been removed. Research by BFM Ltd1
shows that there are significant differences in the levels of solvent reduction which can be
achieved by the two groups.
Manufacturers are given two options:
1. Reduction of VOC content to 5%. This is even less workable than the previous situation.
Even the majority of water based coatings will fail to meet this level – leaving UV cured
coatings as the sole compliance option which is of course impractical especially for
smaller operations.
2. <35g/m2 of VOC. This is a new measure which is meaningless to myself and to UK
furniture manufacturers as we have no figures on what is currently achieved given average
solvent contents and film weights.
UEAPME does not support making up new measurements and inventing new reduction
targets in this sector. The EU Solvent Emissions Directive contains a perfectly logical
measure of performance in the form of the mass balance. If the scheme wants to impose
requirements which are tighter than relevant legislation, why does it not just replicate the
requirement on leather (2.7.8 total VOC emissions will be 7% below the emission limit of
Directive 1999/13/EC) and say that the Eco label requires the achievement of a level of
solvent reduction 7% greater than the SED, i.e.:
1
Benchmarking solvent use in the UK furniture manufacturing sector
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 15 to 25 tonne users must achieve a ratio of 1:1.5 (as opposed to 1:1.6 under SED)
 >25 tonne users must achieve a ratio of 1:0.9 (as opposed to 1:1)
This would provide sites with a requirement based upon measurements that they are already
making rather than forcing them to make another set of calculations purely for Eco-label
compliance purposes. It would also give them a measurement which is meaningful.
Other points on wood coating
The following paragraph has been included. This is presumably setting a requirement on the
level of transfer efficiency which must be achieved – however:
 The term “transfer efficiency” is not mentioned
 Actual transfer efficiencies will differ greatly from the spray equipment manufacturers
claims. It is unlikely that 50% efficiency could be achieved with the 3 D coating of
objects such as chairs using air assisted airless or high volume low pressure systems.
However, it could be achieved by those spraying large flat surfaces
 There is a mention of spraying with no percentage after it.
“The following degrees of effectiveness (which are fixed values and must not be deviated
from) are used for the purpose of calculating discharges:Spraying device without recycling
50%, spraying device with recycling 70%, electrostatic spraying 65%, spraying, bell/disk
80%, roller varnishing 95%, blanket varnishing 95%, vacuum varnishing 95%, dipping 95%,
rinsing 95%”
3.4. Coatings for metals (other than plastics and metals)
3.4.3. Degreasing
“Halogenated organic compounds shall not be used for degreasing in the surface treatment of
metals.”
Compounds such as trichloroethylene are in widespread use and are allowed under the
Solvent Emissions Directive. A degreaser which meets the emission limits of SED will have
minimal emissions and many would argue that its environmental impact is less than that of an
aqueous based system.
3.4.4. Loss of coating
“Loss of the product (coating) should not exceed 10% (w/w) for powder coatings and 30%
(w/w) for wet paint, for surfaces larger than 25 cm2.”
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Loss of coating is not defined. Presumably this allows recapture for later reuse as most
modern powder coating facilities recycle the overspray (rather than eliminating its production
in the first place).
7.b) Appendix 1
A limit for chlorine at 600 ppm would mean in practice an indirect ban of PVC from the
criteria. As a matter of fact, chlorine represents 57% of PVC. Therefore its restriction to the
above-mentioned amount would result in PVC not being allowed over 0,1%. UEAPME
cannot support this criterion, which would lead to an exclusion of PVC on the basis of
presumptions without any scientific evidence.
8 Consumer information
A heavy information burden is provided on the smaller manufacturer in terms of the details
which must be provided with the product.
Brussels, 5TH August 2003