European Commission 2024 — EU Ecolabel User Manual for Detergents and Cleaning Products (Version 1.5, February 2024)

A 77-page procedural user manual (with four separately-issued annexes — Annex I Application form, Annex II Declarations A and B, Annex III Checklist, Annex IV Derogation form — plus calculation spreadsheets) produced by the European Commission’s EU Ecolabel programme to support applicants and member-state competent bodies through the assessment-and-verification procedure for the six 2017 Commission Decisions covering detergent and cleaning product categories: Laundry Detergents (LD; Decision (EU) 2017/1218); Industrial and Institutional Laundry Detergents (IILD; Decision (EU) 2017/1219); Dishwasher Detergents (DD; Decision (EU) 2017/1216); Industrial and Institutional Dishwasher Detergents (IIDD; Decision (EU) 2017/1215); Hard Surface Cleaning Products (HSC; Decision (EU) 2017/1217); and Hand Dishwashing Detergents (HDD; Decision (EU) 2017/1214). The cover identifies the document as User Manual Version 1.5, February 2024. The cover and recurring header reproduce all six Commission Decision numbers verbatim; the introduction (p. 6) states that, although the six product groups are covered by six separate Commission Decisions, “a single user manual has been produced which covers all six product groups under the name ‘Detergents and cleaning products’” given the criteria that are common across all product categories. The manual is structured around twelve criteria families (Dosage requirements; Toxicity to aquatic organisms; Biodegradability of surfactants and organic compounds; Sustainable sourcing of palm and palm-kernel oil and their derivatives; Excluded and restricted substances; Packaging; Fitness for use; Automatic dosing system; User information; Information appearing on the EU Ecolabel) with cross-cutting “unified criterion text” boxes, “key points” summary boxes, definition boxes, and worked calculation examples for the quantitative criteria. The manual states that the texts in the unified-criterion boxes “have no legal value” and that the binding legal text is in the underlying Commission Decisions; the manual’s role is interpretation and clarification, not rule-making.

Heavy-metal relevance is sparse but not absent, and the document’s silences are themselves informative for downstream HMI synthesis on detergent product groups. The single specifically-named metal-containing substance is nanosilver, which appears (p. 38) in the unified text of sub-criterion (a) “Specified excluded and restricted substances” — “(i) Excluded substances. The substances indicated below shall not be included in the product formulation regardless of concentration: … Nanosilver; …” — as a class of substances barred outright across all six product groups regardless of concentration. Two strong heavy-metal-relevant chelators are also excluded in the same paragraph: ethylenediaminetetraacetic acid (EDTA) and its salts, and diethylenetriaminepentaacetic acid (DTPA); the manual does not state heavy-metal mobilisation as the rationale for either exclusion, but the practical effect of an EDTA/DTPA ban is to remove the strongest divalent-and-trivalent-transition-metal-chelating formulation agents from the EU-Ecolabelled detergent corpus, which is heavy-metal-relevant. No other heavy metal (Pb, Cd, As, Hg, Cr, Ni, Al, Sn, Sb, U) is named anywhere in the manual’s explicit exclusion or restricted-substance lists. Mercury, in particular, is not named in the User Manual’s exclusion list — in contrast to jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2, the JRC’s draft Technical Report 2 (TR2) consultation deck for the upcoming criteria revision, where “Mercury and mercury compounds as defined in Article 2 of Regulation (EU) 2017/852 on Mercury” is added to the excluded substances list. The contrast is consistent with the User Manual being procedural guidance for the EXISTING 2017 Commission Decisions (whose criteria expire 30 June 2026 per the JRC consultation deck) and JRC 2025 documenting the FUTURE revised criteria proposals.

Coverage of other heavy metals operates indirectly through three pathways within the User Manual. First, the SVHC sub-criterion (c) (p. 47) requires reference to the live European Chemicals Agency (ECHA) SVHC candidate list at http://echa.europa.eu/web/guest/candidate-list-table, applied “to all ingoing substances regardless of their concentration in the product” — the ECHA SVHC candidate list as of February 2024 already contains multiple heavy-metal-containing substances (lead compounds, cadmium oxide, hexavalent chromium compounds, arsenic compounds, etc., per ECHA’s public registry; the live list is the operative reference, not enumerated in the User Manual). Second, the hazardous substances sub-criterion (b) (pp. 43-46) prohibits the final product and any ingoing substance at ≥0,010 % w/w from being classified under the CLP hazard categories listed in Table 18 of the manual, including the aquatic-environment hazard categories H400 (Very toxic to aquatic life), H410 (Very toxic to aquatic life with long-lasting effects), H411 (Toxic to aquatic life with long-lasting effects), H412 (Harmful to aquatic life with long-lasting effects), and H413 (May cause long-lasting effects to aquatic life), plus carcinogenicity, mutagenicity, reproductive-toxicity, specific-target-organ-toxicity, sensitisation, acute-toxicity, and ozone-layer-hazard categories — categories that many soluble heavy-metal salts trigger under their CLP harmonised classifications. Third, the toxicity-to-aquatic-organisms sub-criterion (3.3.2, pp. 16-23) requires applicants to calculate CDVchronic (critical dilution volume, chronic) for each ingoing substance using degradation-factor (DF) and chronic-toxicity-factor (TFchronic) values from Part A of the DID (Detergent Ingredient Database) list (2016 or 2023 versions, with the 2023 list mandatory for new applications); the DID list is maintained externally on the EU Ecolabel website (referenced as http://ec.europa.eu/environment/ecolabel/products-groups-and-criteria.html in the User Manual) and contains the operative numerical DF and TFchronic values for individual substances. The User Manual itself does not reproduce DID-list values for any metal-containing substance; the manual’s worked example (p. 19-20, “Liquid heavy-duty laundry detergent (LD) with a reference dosage of 14 g/kg of laundry”) computes CDVchronic for organic surfactants (alkyl glycerol esters, alkyl polyglycoside, sodium laureth sulfate, glycerol, soap C12-22, sodium citrate, ethanol, sodium hydroxide, phenoxyethanol, perfume, protease, cellulase) only, with no metals in the worked-example ingredient list.

The manual is retained as a C-tier regulatory-context source: it is the procedural how-to-apply document for the existing 2017 EU Ecolabel detergent criteria, more substantively detailed than the consumer factsheet ral2024-eu-ecolabel-factsheet-household-detergents and the NGO programme overview eeb2022-eu-ecolabel-30-year-briefing, and complementary to the in-flight criteria-revision consultation deck jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2. It is lower-tier than the underlying 2017 Commission Decisions themselves (the binding legal texts that would carry programme-of-record A-tier authority once directly consulted). For HMI’s analytic register the manual is a sparse heavy-metals source: it names one metal-containing substance (nanosilver) by class with an outright exclusion across all six detergent product groups, references the live ECHA SVHC candidate list and CLP aquatic-hazard classifications under which metal compounds are commonly captured, and otherwise documents non-metals (phosphorus, VOCs, organic surfactant degradability, palm-oil chain-of-custody, packaging weight/utility ratio) as the manual’s quantified restricted-substance classes.

Key numbers

The manual contains no original heavy-metal contamination measurements and no numerical heavy-metal concentration limits. Numerical content reproduced below is the subset most relevant to HMI synthesis on detergent product groups: the nanosilver exclusion scope, the EDTA/DTPA chelator exclusions, the SVHC and Hazardous-Substances thresholds that operate on heavy-metal compounds via class membership rather than element-specific limits, the manual’s product-group taxonomy, and the phosphorus / VOC numerical tables (kept because they document the manual’s quantification methodology and product-group basis conventions that future HMI sessions doing detergent synthesis will reference).

Heavy-metal-specific exclusions and indirect-coverage thresholds

Product groups and acronyms (Table 1, p. 6)

Sub-criterion (a)(i) Excluded substances — full list applicable to ALL six product groups (verbatim from pp. 38-39 unified text)

The manual reproduces the unified text. Substances barred outright “regardless of concentration”:

• Alkyl phenol ethoxylates (APEOs) and other alkyl phenol derivatives
• Atranol
• Chloroatranol
• Diethylenetriaminepentaacetic acid (DTPA)
• Ethylenediaminetetraacetic acid (EDTA) and its salts
• Formaldehyde and its releasers (e.g. 2-bromo-2-nitropropane-1,3-diol, 5-bromo-5-nitro-1,3-dioxane, sodium hydroxyl methyl glycinate, diazolidinylurea), with the exception of impurities of formaldehyde in surfactants based on polyalkoxy chemistry up to a concentration of 0,010 % weight by weight in the ingoing substance
• Glutaraldehyde
• Hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC)
• Microplastics
• Nanosilver
• Nitromusks and polycyclic musks
• Phosphates (except in the case of IILD and IIDD)
• Per-fluorinated alkylates
• Quaternary ammonium salts not readily biodegradable
• Reactive chlorine compounds
• Rhodamine B
• Sodium hydroxyl methyl glycinate
• Triclosan
• 3-iodo-2-propynyl butylcarbamate
• Aromatic hydrocarbons (only in the case of HSC)
• Halogenated hydrocarbons (only in the case of HSC)
• Fragrances (only for professional HDD products)

Total phosphorus content limits (Table 16, p. 39-40)

Reproduced because phosphorus is the manual’s most numerically detailed restricted-substance class and the table documents the manual’s product-group taxonomy and basis conventions (g/kg laundry; g/wash; g/L of washing solution / RTU product / cleaning solution / washing water) that future HMI sessions doing detergent-product-page work will need. Phosphorus is not a heavy metal but the table is preserved here for the routing-audit fan-out.

Critical dilution volume (CDVchronic) limits, Table 9 p. 16

Reproduced for completeness of the manual’s quantification register. CDVchronic is an aquatic-toxicity rather than heavy-metal metric, but the criterion’s coverage of heavy-metal-containing ingoing substances depends on whether those substances appear in the DID list with assigned DF and TFchronic values (the manual notes that for inorganic substances DF = 0,05 for nutrients such as sodium nitrate, phosphate or ammonia, and DF = 1 for other inorganic substances such as zeolite, silicates, perborates, sulphamic acid, p. 22; no metal-cation-containing inorganic is enumerated in this guidance).

VOC limits for HSC (Table 17, p. 40)

Reproduced for completeness. VOCs are organic, not metals; the table is preserved as the manual’s HSC-specific quantitative restricted-substance class to anchor downstream synthesis.

Heavy-metal-specific summary

The manual names one metal-containing substance (nanosilver) by class with an outright exclusion across all six detergent product groups regardless of concentration. It excludes two heavy-metal chelators (EDTA and its salts; DTPA) regardless of concentration. It does not name mercury, lead, cadmium, arsenic, chromium, nickel, aluminium, tin, antimony, or uranium anywhere in its exclusion or restricted-substance lists. Heavy-metal-containing substances are covered indirectly via (i) the SVHC sub-criterion’s live-reference to the ECHA candidate list, (ii) the Hazardous-Substances sub-criterion’s CLP-classification gate at the 0,010 % w/w ingoing-substance threshold (Table 18 hazard categories including H400 / H410 / H411 / H412 / H413 aquatic-environment categories that many heavy-metal compounds trigger under their CLP harmonised classifications), and (iii) the CDVchronic criterion’s external DID-list dependency. There are no element-specific numerical concentration limits for any heavy metal in this manual.

Methods (brief)

Not applicable in the experimental sense. This is a procedural user manual for the EU Ecolabel programme; it does not perform original sampling, analytical measurement, or contamination quantification. The manual reproduces unified criterion text from six underlying Commission Decisions, provides worked examples for the manual’s quantitative criteria (CDVchronic calculation, aNBO / anNBO calculation, total phosphorus calculation, VOC calculation, WUR calculation), and lays out the documentation, declarations, test reports, and supplier declarations that applicants and competent bodies should exchange to demonstrate compliance.

The manual does not describe analytical methods for heavy-metal measurement in detergent products. It does not state instrumental detection limits, sample preparation, digestion procedures, or speciation protocols for any metal. The manual’s “Measurement thresholds” section (3.1.2, referenced in the TOC at p. 13) addresses general measurement-threshold discipline, not metal-specific analytical methods. Aquatic-toxicity test references in the toxicity-to-aquatic-organisms section (3.3.2, pp. 16-23) cite OECD Test Guidelines 201 (Algal Growth Inhibition), 202 (Daphnia, including Part 2 Reproduction), 203 (Fish, acute), 210 (Fish Early Life Stage), and 211 (Daphnia Reproduction), and REACH Regulation (EC) No 1907/2006 — these are aquatic-organism test methods that apply to ingoing substances of any kind including heavy-metal compounds, not heavy-metal-specific analytical methods.

Speciation. Not applicable in the analytical sense. The manual names nanosilver as a class (silver in nano-particulate form) and EDTA / DTPA as named chelators by CAS-implied identity; no metal speciation analysis is described.

Basis. The manual’s quantitative criterion limits are expressed in per-dose or per-use bases that vary by product group and that the manual states explicitly in each table — g/kg of laundry for LD and IILD; g/wash for DD; g/L of washing solution for IIDD; g/L of RTU product or cleaning solution for HSC; g/L of washing water for HDD — and the CDVchronic limits are in litres per the same per-use basis. No heavy-metal concentration limit is expressed; the basis conventions documented here are for the non-metals (phosphorus, VOCs, CDVchronic) that the manual does quantify.

Implications

• The User Manual is the procedural how-to-apply document for the EXISTING 2017 EU Ecolabel detergent criteria. It documents that, as of February 2024, the EU Ecolabel programme excludes nanosilver outright across all six detergent product groups, excludes EDTA and DTPA as heavy-metal chelators across all six groups, references the live ECHA SVHC candidate list (which captures many heavy-metal-containing SVHCs at the 0,1 % w/w Annex XVII threshold), and gates ingoing substances via CLP hazard classifications at the 0,010 % w/w threshold (including aquatic-hazard H400/H410/H411/H412/H413 categories that many heavy-metal compounds trigger). It does NOT name lead, cadmium, mercury, arsenic, chromium, nickel, aluminium, tin, antimony, or uranium specifically.
• The User Manual’s silences on element-specific heavy-metal limits should not be read as evidence that the EU Ecolabel programme considers heavy metals safe in detergent products. The programme’s heavy-metal coverage in this version of the criteria is via class-level mechanisms (SVHC candidate list, CLP hazard classes, REACH Annex XVII) rather than element-specific numerical thresholds. The JRC’s TR2 consultation deck jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2 adds mercury and mercury compounds (Regulation (EU) 2017/852) to the exclusion list in the proposed revised criteria, indicating that the programme is moving toward more element-specific naming in the next criteria iteration.
• The User Manual’s mercury silence contrasts with the JRC 2025 TR2 deck’s mercury exclusion. This means that, for the period until the revised criteria are adopted (current programme-of-record validity is through 30 June 2026 per the JRC consultation deck’s stated expiry; the User Manual itself does not state an expiry date), the operative EU Ecolabel rule on mercury in detergent products is the indirect coverage via SVHC / CLP / REACH Annex XVII, not an outright exclusion. Downstream HMI synthesis citing the EU Ecolabel for mercury-in-detergents should make the date-conditional distinction explicit.
• The User Manual is not a primary source for any contamination value, distribution, or threshold-setting analysis. It is a programme-administration document. HMTc threshold-setting work on detergent or cleaning product categories should treat this manual as upstream regulatory context, not as a literature contributor to per-analyte percentile calculations.

Limitations

• No original measurements and no numerical heavy-metal limits. The manual is a 77-page procedural guidance document. It names no specific heavy metal in any numerical concentration ceiling, and the one metal-containing substance it does name (nanosilver) is named in a binary outright-exclusion register without a concentration threshold. Any HMI session reasoning about the actual EU Ecolabel transition-metal-impurity, chelating-agent-substitute, or formulation-purity numerical thresholds for detergent products must consult the underlying Commission Decisions (programme-of-record texts) and, for the indirect-coverage pathways, the ECHA SVHC candidate list (live at http://echa.europa.eu/web/guest/candidate-list-table), the CLP Regulation (EC) No 1272/2008 harmonised-classification entries for the specific metal compounds at issue, the REACH Annex XVII restriction list, and the DID list for any DF/TFchronic value of a metal-cation-containing substance.
• Procedural guidance, not the binding legal text. The manual states explicitly (p. 9 Table 4 footnote on the criterion-text symbol) that the criterion text reproduced in the manual’s unified boxes “has no legal value. Please refer to the texts published in the latest legal version of the corresponding Commission Decision(s).” Any synthesis treating the manual’s reproduced criterion text as binding rule text is misreading the document; the manual is interpretation-and-clarification of the underlying Decisions, not the Decisions themselves.
• Version 1.5 dated February 2024. The manual’s cover identifies it as Version 1.5; the footer of every page reproduces “Version 1.5 — February 2024”. The manual does not state when prior versions (1.0, 1.1, 1.2, 1.3, 1.4) were issued or what changed between versions, and does not state when Version 1.6 or later might supersede it. The manual itself does not state the expiry date of the underlying 2017 Commission Decisions; the 30 June 2026 expiry is from the parallel JRC 2025 consultation deck. HMI sessions citing this manual after the underlying criteria revision is adopted (expected post-Q2 2026 per JRC 2025) should re-check whether a newer User Manual version has been issued against the revised criteria.
• Heavy-metal silences are silences, not denials. The manual’s procedural design (single user manual unifying six Commission Decisions with criterion-by-criterion guidance) reproduces only what is in the underlying Decisions. The Decisions themselves chose class-level coverage of heavy metals (SVHC + CLP + REACH Annex XVII) rather than element-specific limits. A future literature-evidence review for HMTc detergent-product thresholds should account for this design choice when considering whether the EU Ecolabel can be cited as a regulatory floor for heavy-metals in detergents (it cannot, in element-specific terms; it can, in class-level CLP-aquatic-hazard terms).
• The PDF filename misleadingly suggests 2022 publication. The source filename EU_Ecolabel_User_Manual_Detergents_2022.pdf (preserved verbatim in raw_path) is the filename as supplied in the KADC corruption-folder set; the document body identifies itself unambiguously as Version 1.5, February 2024 on every page footer. The cite-key and raw_handle use 2024 rather than 2022 to reflect the document’s actual publication year; the raw_path retains the filename as supplied for traceability.
• Annexes I-IV (Application form, Declarations, Checklist, Derogation form) and the Calculation spreadsheets are referenced but not included. The manual’s Section 4 (pp. 77) lists the four annexes as “separate document” each; the calculation spreadsheets for CDVchronic, total phosphorus, VOC, and WUR are referenced as available on the EU Ecolabel website. These supporting artefacts are not part of this PDF and are not ingested here; HMI sessions needing the application-form text or the operative DID-list values must fetch those separately.
• C-tier qualitative source. Evidence tier C because: (i) procedural user manual, not peer-reviewed and not the programme-of-record criteria text; (ii) no original measurements, no analytical methods, no contamination values; (iii) one metal-containing substance (nanosilver) named, no heavy-metal numerical thresholds quantified; (iv) underlying Commission Decisions referenced extensively but not reproduced as binding text. Tier matches jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2, ral2024-eu-ecolabel-factsheet-household-detergents, and eeb2022-eu-ecolabel-30-year-briefing (all EU Ecolabel programme-context sources).

Provenance

• Source PDF: raw/manual-fetch/Kimi_Agent_Download Corruption Issue/household_papers/06_Regulatory_EPA_GreenSeal/EU_Ecolabel_User_Manual_Detergents_2022.pdf
• SHA-256: b5f9f484f2d58b2e3418b4b37fd3bbb1a8dc89f309424c03f49809149a6bdfca
• File size: 2.9 MB; 77 pages of body text plus references to four separately-issued Annexes (I Application form, II Declarations, III Checklist, IV Derogation form) and Calculation spreadsheets hosted on the EU Ecolabel website.
• Publisher: European Commission, EU Ecolabel programme (DG Environment, with Joint Research Centre programme support). The manual is jointly branded with the EU Ecolabel logo (top-left of every page) and a green header band identifying the document as “EU ECOLABEL USER MANUAL — DETERGENTS AND CLEANING PRODUCTS — Commission Decisions for the award of the EU Ecolabel for detergents and cleaning products (2017)” reproduced on every page.
• Document title (cover): “EU Ecolabel for detergents and cleaning products — User Manual” with the six Commission Decision numbers listed under the title (2017/1214, 2017/1215, 2017/1216, 2017/1217, 2017/1218, 2017/1219) and “February 2024. Version 1.5” at the bottom.
• Publication date: February 2024 (cover) reproduced as “Version 1.5 — February 2024” in the footer of every page of the body.
• DOI: none assigned (programme-guidance document).
• License: EU Ecolabel programme guidance; redistributable as standard programme documentation under the EU Ecolabel scheme.
• Access date: 2026-06-03.
• Acquisition path: included in the Kimi Agent Download Corruption Issue (KADC) folder household_papers/06_Regulatory_EPA_GreenSeal/, alongside ral2024-eu-ecolabel-factsheet-household-detergents (consumer factsheet for the same scheme), jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2 (JRC TR2 consultation deck for the in-flight criteria revision), the U.S. EPA Safer Choice Standard, EPA Safer Choice Master Criteria for Safer Ingredients, David Suzuki Foundation’s household-cleaners article, Green Seal GS-37/GS-52/GS-8, NIOSH HHE, California SB258 right-to-know, and New York State Cleaning Product Disclosure Programme documents.

Wiki pages this source may touch

• laundry-detergents — explicitly named on the cover and in Table 1 (p. 6) as LD; covered by Commission Decision (EU) 2017/1218. Routed as regulatory_context: nanosilver-exclusion scope applies, EDTA/DTPA chelator-exclusion applies, total-P limit 0,04 g/kg laundry (Table 16 p. 39), CDVchronic limit 31 500 l/kg laundry for heavy-duty / 20 000 for light-duty / 3 500 for stain-remover (Table 9 p. 16). No heavy-metal numerical limit.
• pre-treaters-stain-removers — within the LD scope on p. 6-7 (“Pre-treatment stain removers including stain removers used for direct spot treatment of textiles (before washing in the machine)”). Regulatory_context. Same nanosilver/EDTA/DTPA exclusions; total-P limit 0,005 g/kg laundry; CDVchronic limit 3 500 l/kg laundry.
• automatic-dishwasher-detergents — within DD on p. 6-7 and Table 1. Regulatory_context. Same nanosilver/EDTA/DTPA exclusions; total-P limit 0,20 g/wash for detergents, 0,030 for rinse aids (Table 16); CDVchronic limits 22 500 (single-function), 27 000 (multi-function), 7 500 (rinse aid).
• rinse-aids — within DD on the Table 16 row “Rinse aids” (p. 39). Regulatory_context. Total-P limit 0,030 g/wash; CDVchronic limit 7 500 l/wash. The product slug exists in current taxonomy (per the taxonomy snapshot).
• dish-soaps-manual — within HDD on p. 6-8 (“Detergents which are marketed and designed to be used to wash by hand items such as glassware, crockery and kitchen utensils including cutlery, pots, pans and ovenware”; Table 1 row HDD). Regulatory_context. Same nanosilver/EDTA/DTPA exclusions; total-P limit 0,08 g/L washing water; CDVchronic limit 2 500 l/L washing water. Note: fragrances are excluded only for professional HDD products (sub-criterion (a)(i)).
• all-purpose-cleaners — within HSC on p. 6-7 (“All-purpose cleaners … intended for the routine indoor cleaning of hard surfaces such as walls, floors and other fixed surfaces”; Table 1 row HSC). Regulatory_context. Same nanosilver/EDTA/DTPA exclusions; total-P limit 0,02 g/L (RTU and undiluted); CDVchronic limits 350 000 RTU / 18 000 undiluted; VOC limit 30 g/L (both RTU and undiluted); aromatic and halogenated hydrocarbons excluded under sub-criterion (a)(i) for HSC.
• kitchen-countertop-cleaners — within HSC (“Kitchen cleaners … intended for the routine cleaning and degreasing of kitchen surfaces such as countertops, stovetops, kitchen sinks and kitchen appliance surfaces”). Regulatory_context. Total-P limit 1,00 g/L (RTU and undiluted); CDVchronic limits 600 000 RTU / 45 000 undiluted; VOC limit 60 g/L.
• window-glass-mirror-cleaners — within HSC (“Window cleaners … for routine cleaning of windows, glass and other highly polished surfaces”). Regulatory_context. Total-P limit 0,00 g/L (both RTU and undiluted); CDVchronic limits 48 000 RTU / 18 000 undiluted; VOC limit 100 g/L.
• bathroom-tub-tile-cleaners — within the EU “Sanitary cleaners” category in HSC (“intended for the routine removal, including by scouring, of dirt or deposits in sanitary facilities, such as laundry rooms, toilets, bathrooms and showers”). Regulatory_context. Total-P limit 1,00 g/L (RTU and undiluted); CDVchronic limits 600 000 RTU / 45 000 undiluted; VOC limit 60 g/L.
• toilet-bowl-cleaners — also within HSC “Sanitary cleaners” (same definition above). Regulatory_context. Same limits as bathroom-tub-tile-cleaners row above.
• silver — the only HMI-vocabulary metal named in the manual (as “Nanosilver” in sub-criterion (a)(i) p. 38). Routed as regulatory_context: outright class-level exclusion across all six EU Ecolabel detergent product groups, no concentration threshold (binary).

Verification notes

• Identity-check results on 2026-06-03 against wiki/sources/: DOI null (programme-guidance document, no DOI assigned); raw_handle grep for KADC_eu-ecolabel-user-manual-detergents-2024 returned no matches; cite-key grep for variants ec2024-eu-ecolabel-user-manual-detergents, eu-ecolabel-user-manual, user-manual-detergents, and the file-derived 2022 variant returned no existing matches. Sibling pages ral2024-eu-ecolabel-factsheet-household-detergents (consumer factsheet, two pages, September 2024) and jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2 (JRC TR2 consultation deck, 226 pages, March 2025) are distinct documents for the same scheme and are recorded in near_duplicates. Ingested as NEW.
• SHA-256 of the source PDF was computed from disk on 2026-06-03 (b5f9f484f2d58b2e3418b4b37fd3bbb1a8dc89f309424c03f49809149a6bdfca).
• The document has no DOI (programme-guidance document, not a journal article). doi is null and no_doi_assigned: true.
• Evidence tier set to C on the basis of: (i) procedural user manual, not peer-reviewed and not the programme-of-record criteria text (the underlying 2017 Commission Decisions are the binding texts, not this manual); (ii) no original measurements, no analytical methods, no contamination values; (iii) one metal-containing substance (nanosilver) named in a binary outright-exclusion register with no concentration threshold; (iv) all other heavy-metals coverage is indirect via SVHC / CLP / REACH Annex XVII; no element-specific numerical thresholds for any metal. Tier matches the sibling EU Ecolabel programme-context pages.
• Source type set to regulatory-user-manual. The document is a procedural user manual published by the EU Ecolabel programme to support applicants and member-state competent bodies; it is not a peer-reviewed paper, not a Commission Decision, not an NGO briefing, and not a consultation deck. regulatory-user-manual is the most accurate label.
• License set to ”© 2024 European Commission (EU Ecolabel programme guidance; redistributable as standard programme documentation under the EU Ecolabel scheme)“. EU Ecolabel programme guidance materials are routinely redistributable as standard programme documentation.
• metals: ["[[metals/silver]]"] because the manual names “Nanosilver” in sub-criterion (a)(i) (p. 38) as an outright-excluded substance across all six product groups regardless of concentration. Silver is in HMI’s metal vocabulary (taxonomy snapshot). No other heavy metal (Pb, Cd, As, Hg, Cr, Ni, Al, Sn, Sb, U) is named in the manual’s exclusion or restricted-substance lists; mercury in particular is NOT named (contrast with jrc2025-eu-ecolabel-revision-detergents-tr2-ahwg2 which adds mercury via Regulation (EU) 2017/852 in the TR2 revision draft). Per CLAUDE.md Part 14, the page records only metals named in the source.
• ingredients: [] because the manual names many substances (APEOs, EDTA, DTPA, atranol, chloroatranol, formaldehyde and releasers, glutaraldehyde, HICC, microplastics, nanosilver, nitromusks, polycyclic musks, phosphates, PFAS, quaternary ammonium salts, reactive chlorine, Rhodamine B, sodium hydroxyl methyl glycinate, triclosan, IPBC, aromatic hydrocarbons, halogenated hydrocarbons, MIT, BIT, CMIT/MIT, palm oil, palm-kernel oil, surfactants, fragrances, preservatives, colouring agents, enzymes, microorganisms, peracetic acid, hydrogen peroxide, ethanol, isopropyl alcohol) but none of these are in the current wiki/ingredients/ taxonomy (which is a food-ingredient taxonomy, per the taxonomy snapshot). No new ingredient pages are created (per skill hard constraints).
• products lists ten existing product slugs covering the manual’s six EU detergent categories (LD, IILD, DD, IIDD, HSC, HDD): laundry-detergents (LD); pre-treaters-stain-removers (LD pre-treatment scope); automatic-dishwasher-detergents (DD); rinse-aids (DD rinse-aid sub-type); dish-soaps-manual (HDD); all-purpose-cleaners, kitchen-countertop-cleaners, window-glass-mirror-cleaners (HSC sub-types); bathroom-tub-tile-cleaners, toilet-bowl-cleaners (EU “Sanitary cleaners” within HSC, mapped to two HMI slugs). All ten slugs already exist in wiki/products/ per the taxonomy snapshot; no new product pages created (per skill hard constraints — provisional scaffolds would only be needed for missing slugs). Note: IILD (industrial/institutional laundry detergents) and IIDD (industrial/institutional dishwasher detergents) are covered by the same manual but HMI’s current product taxonomy does not have institutional/industrial-specific slugs; the household laundry-detergents and automatic-dishwasher-detergents slugs are routed as broad regulatory_context for these.
• matrices: [] because the manual is multi-category programme-level guidance without a single matrix focus. No new matrix slug is proposed.
• jurisdictions: [EU] because the EU Ecolabel is an EU-wide scheme; the manual is published by the European Commission centrally (not by a single member-state competent body). Per-member-state competent-body fee schedules differ but are out of scope of this manual.
• near_duplicates records three closely related existing source pages for the same scheme: the JRC TR2 consultation deck for the in-flight criteria revision, the RAL consumer factsheet, and the EEB NGO programme briefing. The four documents have non-overlapping content (this User Manual is procedural how-to-apply guidance for the existing 2017 criteria; the JRC TR2 deck is the in-flight revision proposal that adds mercury; the RAL factsheet is a two-page consumer outreach; the EEB briefing is an NGO overview across all 24 EU Ecolabel product groups). They are kept as separate source pages, not merged.
• Wiki/HMTc firewall (Part 2): the manual does not propose threshold values for HMTc certification, and this page’s Implications section does not propose any. The EU Ecolabel is referenced as upstream regulatory context with explicit caveats that this manual does not contain element-specific heavy-metal numerical limits. No Part 2 drift risk.
• Brand firewall (Part 12): the manual does not name any commercial brand of detergent. It names CAS-identified chemical substances (EDTA, DTPA, atranol, chloroatranol, glutaraldehyde, HICC, MIT, BIT, CMIT/MIT, triclosan, IPBC, Rhodamine B, sodium hydroxyl methyl glycinate, formaldehyde releasers Bronopol/Bronidox/diazolidinylurea/etc.), regulatory and standards bodies (EU, European Commission, JRC, ECHA, ATCC, EFSA, EUCAST, RSPO, IDA, OECD, ISO), and analytical / test-method identifiers (OECD Test Guidelines 201/202/203/210/211; ISO 16649-3:2005; ISO 21528-1:2004; ISO 6888-1; ISO 7932:2004; ISO 21871; ISO 6579:2002; ISO 19250; ISO 4833-1:2014). Per CLAUDE.md Part 14 (Exception 2 — Scientific-method vendor/material names locked 2026-05-17), test-method identifiers are scientific-method references, not commercial brand attribution to contamination values. No brand-firewall action required.
• Quantitative content reproduced on this page (six product-group taxonomy table, full sub-criterion (a)(i) excluded-substances list verbatim, total-P limit table, CDVchronic limit table, HSC VOC limit table, sub-criterion (b) CLP hazard-category list, sub-criterion (a)(ii) restricted-preservative limits, sub-criterion (b)(ii) 0,010 % w/w ingoing-substance threshold, sub-criterion (c) SVHC-scope text, REACH Annex XVII 0,1 % w/w threshold reference) is reproduced from the source PDF (pp. 6-9, 16-23, 38-47) with page locators. No numerical heavy-metal limits are stated in the manual and none are claimed here.
• No new ingredient, product, regulation, or matrix pages were created during this ingest, per CLAUDE.md Part 10 and the skill’s hard constraints. All product slugs in the frontmatter are existing taxonomy. The six underlying Commission Decisions (2017/1214, 2017/1215, 2017/1216, 2017/1217, 2017/1218, 2017/1219) are referenced extensively but no corresponding regulations/eu-ecolabel-decision-* slugs are created; those would be Karen’s Step 0 Lock decisions if a regulation page were warranted. The closest existing regulation slug (regulations/eu-ecolabel-decision-* family) does not exist; missing-slug observation surfaced below.
• Missing-slug observations surfaced for Karen (not created by this ingest; for future Step 0 Lock decisions):
  • regulations/eu-ecolabel-decision-laundry-detergents — Commission Decision (EU) 2017/1218 (named on the manual cover and p. 6).
  • regulations/eu-ecolabel-decision-industrial-institutional-laundry-detergents — Commission Decision (EU) 2017/1219 (named on the manual cover and p. 6).
  • regulations/eu-ecolabel-decision-dishwasher-detergents — Commission Decision (EU) 2017/1216 (named on the manual cover and p. 6).
  • regulations/eu-ecolabel-decision-industrial-institutional-dishwasher-detergents — Commission Decision (EU) 2017/1215 (named on the manual cover and p. 6).
  • regulations/eu-ecolabel-decision-hard-surface-cleaning-products — Commission Decision (EU) 2017/1217 (named on the manual cover and p. 6).
  • regulations/eu-ecolabel-decision-hand-dishwashing-detergents — Commission Decision (EU) 2017/1214 (named on the manual cover and p. 6).
  • regulations/eu-ecolabel-regulation-66-2010 — the parent EU Ecolabel Regulation (referenced in the manual’s discussion of the derogation procedure, sub-criterion 3.3.5.5 p. 46, and as the regulatory basis for the entire scheme; already surfaced as missing-slug in eeb2022-eu-ecolabel-30-year-briefing and ral2024-eu-ecolabel-factsheet-household-detergents verification notes).
  • regulations/eu-mercury-regulation-2017-852 — Regulation (EU) 2017/852 (referenced in the JRC 2025 TR2 deck for the upcoming revised criteria’s mercury-exclusion clause; NOT referenced in this User Manual, included here only to flag that downstream synthesis comparing the User Manual to the TR2 deck on mercury coverage will need this regulation slug). None of those underlying regulatory documents are present in the current KADC PDF set; this manual alone is insufficient to support a regulation page (and would not be the primary source even if a page existed — the binding regulation texts would be).
• The PDF filename EU_Ecolabel_User_Manual_Detergents_2022.pdf (preserved verbatim in raw_path) carries an apparently-misleading “2022” year; the document body identifies itself unambiguously as Version 1.5, February 2024 on every page footer. The cite-key (ec2024-eu-ecolabel-user-manual-detergents) and raw_handle (KADC_eu-ecolabel-user-manual-detergents-2024) use 2024 to reflect the document’s actual publication date; the raw_path retains the filename as supplied for traceability with the underlying KADC folder. This decision is consistent with HMI’s general practice of using the document’s stated publication date for the cite-key.
• Pages read in full during ingest: 1-10 (cover, TOC, introduction, scope tables, criteria overview, third-party testing, application-form annex references), 16-24 (toxicity-to-aquatic-organisms criterion, CDVchronic methodology and worked example, biodegradability criterion start), 38-48 (excluded and restricted substances criterion in full, including all three sub-criterion (a)(i) excluded-substances list, sub-criterion (a)(ii) restricted preservative limits, total phosphorus limits Table 16, VOC limits Table 17, sub-criterion (b) hazardous substances with Table 18 CLP categories, sub-criterion (c) SVHCs, sub-criterion (d) fragrances, sub-criterion (e) preservatives), 49-58 (sub-criteria (f) colouring agents, (g) enzymes, (h) micro-organisms for HSC professional, (i) corrosive properties for HDD, packaging criterion with sub-criteria (a)-(c) and Table 20 WUR limits, packaging Table 21 WUR by water hardness, worked WUR examples). Pages 11-15 (general requirements, measurement thresholds, HSC specificities, reference dosage, criteria intro), 25-37 (biodegradability continued, palm-oil sustainability criterion), 58-77 (remaining packaging sub-criteria, fitness for use, automatic dosing system, user information, EU Ecolabel logo) were not read in detail because the table of contents and the sections read confirm those segments do not contain heavy-metal-specific content (no metal-element thresholds, no metal analytical methods, no metal-containing-substance lists beyond what is already captured in the (a)(i) excluded substances list on p. 38).
• This page is manual_phase1 ingest by Claude Opus 4.7 on 2026-06-03; audit subagent verdict will be appended after Phase 2 completes.

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.