Dec 2nd Questions and Answers

1. Q) The strict criteria for CCD-146I - Cleaning Product with Low Potential for Environmental Illness and Endocrine Disruption. The category is very specific about VOCs, the use of ethylene oxide in the components of the formulation and aquatic toxicity.

A) This product sub-category has been phased out in the revised version of the standard. However, the overall requirements of the standard for the various product subcategories have been made more stringent in certain parameters. Ethylene oxide has been upgraded to Group 1 as per the IARC report, and as such is banned in product formulation as per the definition of “carcinogen” in the revised standard.


2. Q) I’m reading the definitions, there is one about ethylene glycol ethers. It mentions lots of ethylene glycols specifically that are considered toxic. We don’t use these specifics to develop products. However, we do use the diethylene glycol monobutyl ether. At the point 5d) it seems that all ethylene glycol ethers are banned. Is this related only to those mentioned before in the definitions?

A) In the standard, under 5d) it bans all.


3. Q) In appendix 2 part 2, the requirements of individual ingredients apply to ingredients present at 0,01% or more. In the old version of the standard document, it was 0.1%.

A) Indeed, the revised CCD 146 has more stringent limits, of what is now considered as an “ingredient” which is now any chemical or compound present in greater than 0.01% by weight in a product formulation.


4. Q): Does this mean that even if the general profile of product is very good, company must perform a complete formula testing because of the presence of perfume or essential oils since there is no higher limit set

A ) EcoLogo is still investigating into this request.


5. Q) Does Ecologo ban ingredients that their purpose is to change the smell of product?

A) No, but we do have criteria regarding fragrances in the CCD 146 for e.g., Section 3(j), and also in the definition section under “Volatile Organic Compound”


6. Q) The new CCD-146 requires labelling to note to dilute with “unheated tap water”.
I understand that we are trying to avoid heated water. Is the statement: “Effective in Cold Water” sufficient?

A) no we require the labels to instruct that unheated tap water be used to dilute.


7. Q)I was reading again the CCD-146 and I have a question concerning the definition of aromatic solvent. In the last edition, there was a page that was called Definition of Aromatic Solvents. However, in the new standard, there is no such document. Would propylene glycol phenyl ether be OK to work with (if we’re reporting to the definition only)? I think so but I just want to be sure.

A) Our Interpretation of the Definition of Aromatic Solvents remains the same as was written in the previous CCD-146 standard.


8. Q) We are still having trouble understanding the revised CCD-146 and Aquatic toxicity testing. For measuring Aquatic toxicity, can we use the GHS additivity formula method in part 3 of the GHS in order to calculate whole formulation toxicity?

A) Yes you may use the formula method from GHS


9. Q) Where can I find the GHS?

A) Please use the most recent version of the GHS found here: http://www.unece.org/trans/danger/publi/ghs/ghs_rev04/04files_e.html


10. Q) Reference 8 D for the revised Ecologo 146 States that whenever intended to be diluted with by the customer a clear and prominent statement saying that unheated tap water be used for dilution. We feel that this might be appropriate for products designed to work with ambient temperature- but not for products such as hand dishwashing detergents.

A) We will follow up on this.