1. Consultation Cosmetic products 090

Consultation concerning revised criteria

Nordic Ecolabelling gives you the opportunity to comment on the proposal for criteria for Nordic Swan Ecolabelling for Cosmetic products 090. The ecolabelling is assessed based on a life cycle perspective and fulfil high environmental and health requirements. Your comments are important and will be considered by the national Ecolabelling boards and the Nordic Ecolabelling Board.

We look forward to your comments, which should be sent to the Nordic Ecolabelling no later than 29/04-2024 to be taken into consideration.

Please find the proposed criteria for download further down on this page.

What has been changed?

  • If renewable raw materials from palm oil are used, the palm oil/palm kernel oil must be RSPO certified with trace level Mass Balance or higher (Requirement O4)
  • The new EUH hazard classes for endocrine disruptors, PBT/vPvB, and PMT/vPvM are added to the prohibited classifications (Requirements O5).
  • Updated definition on microplastics and endocrine disruptors (Requirement O6)
  • The exemption for anaerobic degradation of surfactants for emulsifiers is removed and a limit of 1,0 ppm for 1,4 dioxane impurity in surfactant active matter is introduced (Requirement O7).
  • Requirement for amount of fragrance allergens in the product is adjusted to the updated list of regulated fragrances in Annex III of the Cosmetic Regulation (Requirement O10).
  • Additional requirement for preservatives which now also must be readily aerobically degradable (Requirement O12).
  • In the requirements for environmentally hazardous substances, the general threshold limit have been tightened and the most toxic H410 substances with M-factor > 1 is now completely prohibited. Surfactants are no longer exempted, but a separate higher threshold value is introduced for liquid soap, body shampoo and shower gel (Requirement O16)
  • For rinse-off products, the threshold limits for both aNBO, anNBO, and CDV have been slightly tightened and for leave-on products, the threshold limit for biodegradability/toxicity have been slightly tightened (Requirement O17-O19)
  • Fossil-based fibres are no longer permitted in wet wipes (O24). Requirements for fibres/wipe material is updated to be in line with the latest NSE and EU Ecolabel Criteria for textiles, sanitary products, and tissue paper.
  • Medical examination lubricants are now included in the product group (Requirement O30)
  • New requirements have been introduced for primary packaging made from rigid and flexible plastic, paper-based materials, and aluminium, concerning the packaging’s recyclability and design for recycling. Glass is no longer permitted as a packaging material, and miniature bottles sold to the HoReCa sector is no longer permitted (Requirements O31-O34).
  • The WUR requirement has been tightened (Requirement O35).

In addition to the above mentioned we would also like your comments on the following matters

  • Requirement O6: For the exclusion of microplastics we introduce the definition from the REACH restriction which is now in force. Its derogation for microparticles whose “physical properties are permanently modified during intended end use in such a way that the polymer no longer falls within the scope of this entry” (e.g. film-forming) is not applied. The exemption from generation 3 for film-forming microplastics in water-resistant sunscreen is also not applied. This affects both rinse-off products and leave-on products, e.g. water-resistant sunscreen. It is important to emphasize that it is NOT our intention to rule out ecolabelled waterproof sunscreen, but we only wish to implement exemptions that are necessary. We therefore ask for comments on the consequences of not including the exemptions, particularly regarding availability of current and future test data on biodegradability and/or water solubility of polymers like filmformers and acrylates.
  • Requirement O7: The exemption for anaerobic degradation for emulsifiers is removed as we can see that there are alternatives. However, a question remains regarding if specific emulsifiers are excluded by this change which are needed for certain functions or product categories. For example, rinse-of or leave-on? Therefore, we ask for comments regarding the need for an exemption for specific emulsifiers.
  • Requirement O7: A Limit of 1,0 ppm for trace levels of 1,4 dioxane in surfactant active matter is introduced due to the concern of this substance toxic and environmental hazardous properties. We ask for comments regarding this new limit for 1,4 dioxane and specifically the technical possibilities of reaching this limit in the surfactant raw material? We also ask for information about the presence of other dioxanes or substances of similar concern?
  • Requirement O10: The additional fragrance allergens from the amendment of Annex III to the Cosmetic Products Regulation this past summer ((EU) 2023/1545), which must be declared on the label when present in products above 10 or 100 ppm, are excluded above the same levels in labelled products. There are 48 new substances added to Annex III. Taking classifications into consideration, in practise 19 of those substances haven’t been covered by the Nordic Swan cosmetics criteria before (29 substances are currently classified H317 and eight substances are classified as hazardous to the environment). We ask for comments on how this affects the fragrances for labelled products, and particularly about time frames for reformulations. In addition, we ask for comments about possible changes to the restriction limits for fragrance allergens in toothpaste. We want to assess whether it is possible from an allergy perspective to raise the limits to achieve stronger tasting products.
  • Requirement O16: Surfactants are no longer exempted from the weighted calculation of environmentally hazardous substances, so please check your products using the updated calculation sheet, and comment on the updated threshold limits. We also ask for comments on the prohibition of substances classified H410 with M-factor>1.
  • Requirement O24: Fossil-based fibres are no longer permitted in wet wipes, and the requirements for the fibre/wipe material has been updated in line with the latest NSE and EU Ecolabel Criteria. Are any of the requirements difficult to meet? We are specifically looking for comments on the requirements for cellulose pulp/fluff pulp in appendix 7.
  • Requirement O31-O34: The packaging requirements concerning recyclability of the packaging and design for recycling are extensive, but very important from a climate perspective. We ask for comments on all the requirements. Are any of them difficult to meet? We request as much details as possible.
  • Requirement O34: The calculation of the label’s coverage of PET containers could be made redundant given that thinner labels (40-70 microns) are used, which the NIR scanner can pierce through. Do you see this as possible?

Documents for download


Please let us know if you prefer a hard copy, and we will send you one by mail.

Who can provide input?

All people, companies and institutions who are interested in taking part in the development work of Nordic Ecolabelling criteria for Cosmetic products can provide us with their opinions and comments. We would appreciate if you kindly distribute information about this review to whom it may concern.

How can comments be sent in?

Your input is most valuable to our criteria development. We prefer to receive your answers via the form below, via mail or by e-mail to remiss@svanen.se

For further questions, please contact our Product Specialists Lina Harström and Sabina Risén Rimfors.

What happens next?

When the consultation period is complete, the answers will be compiled and evaluated. For this reason, a new revised proposal for criteria will be submitted to the Swedish Ecolabelling Board and the other national committees. On this basis, the Nordic Ecolabelling Board will then decide on new criteria.

Part of the decision document is the summary of all consultation responses together with answers from Nordic Ecolabelling. The summary will be public and available on the Ecolabelling Sweden’s web page in connection with the publication of the new criteria.

We look forward to receiving your comments no later than 29/04-2024.

Please leave your comments here

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