JRC 2025 — EU Ecolabel revision for detergents and cleaning products, TR2 stakeholder consultation deck (2nd AHWG meeting, March 2025)

A 226-page DRAFT-marked stakeholder consultation slide deck produced by the European Commission Joint Research Centre (JRC) — by named authors Alfonso Jose Lag-Brotons, Maria Grazia La Placa, and Paula Perez Lopez of the JRC’s Circular Economy and Sustainable Industry unit (Directorate B) — and presented at the 2nd Ad-hoc Working Group (AHWG) hybrid meeting (Brussels and WebEx) held 12-13 March 2025 to consult stakeholders on the second technical report (TR2) and the second draft EU Ecolabel (EUEL) criteria for the six detergent product groups regulated under the 2017 Commission Decisions named on the deck by their internal C-numbers (HDD C(2017)4227; HSC C(2017)4241; DD C(2017)4240; IIDD C(2017)4228; LD C(2017)4243; IILD C(2017)4245) and OJ citation (OJ L 180, 12.7.2017), whose criteria validity is stated on the deck as expiring 31/06/26 (reproduced verbatim from the slide; canonical reading is 30 June 2026 since June has 30 days), with final revised EUEL criteria proposals scheduled for Q2 2026 (TBC). The deck is the JRC’s mid-process consultation artefact, not an adopted programme text and not a peer-reviewed study; it is the working draft on which stakeholder feedback is being solicited through 69+ numbered consultation questions (Q18-Q69 in the sections covered, with parallel question streams in earlier sections of the deck), and it is fenced throughout as “DRAFT” on the body slides. The 2nd AHWG meeting is the consultation event between TR2 publication and the EUEB (EU Ecolabelling Board) meeting on 3 April 2025; downstream, TR3 and the final criteria proposals follow.

Heavy-metal relevance is concentrated in a single but load-bearing place: the TR2 proposed sub-criterion (a)(i) “Excluded substances” applicable to ALL six detergent product groups names “Mercury and mercury compounds as defined in Article 2 of Regulation (EU) 2017/852 on Mercury” as a class of substances that “shall not be included as ingoing substances in the final product or as ingoing substances to the ingredients used to make the final product.” This places mercury in the same outright-exclusion register as persistent organic pollutants (Annexes I/II of Regulation (EU) 2019/1021) and ozone-depleting substances (Annexes I/II of Regulation (EC) 1005/2009). The TR2 criterion has also deleted the previous “regardless of concentration, neither as part of the formulation, as part of any mixture included in the formulation, nor as impurities” clause (JRC reasons cited: consistency with Table 1 of the Commission Decisions’ “Threshold levels applicable to ingoing substances”; not all impurities will be known; analytical limits of detection), so the exclusion as written in TR2 applies to mercury as an ingoing substance rather than as a trace impurity. No other heavy metal (Pb, Cd, As, Cr, Ni, Al, Sn, Sb, U) is named anywhere in the criterion text on the slides reviewed; the criterion’s coverage of other transition metals operates indirectly through (i) REACH Annex XVII compliance (substances therein may not be used unless in full compliance and explicitly permitted via the Hazardous Substances sub-criterion’s derogations), (ii) the CLP hazard-class restrictions in sub-criterion (b) Hazardous Substances (Table 2: CMR Cat. 1A/1B/2 with H340/H350/H350i/H360/H341/H351/H361; Acute Tox. Cat. 1/2/3 with H300/H301/H310/H311/H330/H331/EUH070; Aspiration Hazard H304; Respiratory and Skin Sensitisation Cat. 1/1A/1B with H317/H334; plus aquatic hazard, ozone-layer hazard, endocrine-disruption, PBT/vPvB, and PMT/vPvM categories not enumerated in detail on the reviewed slides), and (iii) the SVHC sub-criterion (c) restriction on REACH Article 57 / Article 59(1) candidate-list substances at the 0,1 % weight-by-weight threshold (REACH Annex XVII text quoted on the deck). Sub-criterion (b) Table 3 derogated substances also names “Titanium dioxide (in a powder form containing 1% or more of particles with aerodynamic diameter ≤10μm)” with H351 (inhalation) for ALL product groups subject to worker-exposure-minimisation measures; titanium is not a heavy metal in HMI’s analyte vocabulary but is named here for completeness because pigment-grade TiO2 is a recurring co-occurrence with the heavy-metal impurity discussion in cosmetics and personal-care literature.

The deck is retained as a C-tier regulatory-context source: it is the JRC’s draft-stage working summary of the in-flight EU Ecolabel revision, more substantively detailed than the consumer factsheet ral2024-eu-ecolabel-factsheet-household-detergents and the NGO programme briefing eeb2022-eu-ecolabel-30-year-briefing (both of which Heavy Metal Index already holds for the same scheme), but lower tier than (a) the existing 2017 Commission Decisions themselves (which carry programme-of-record A-tier authority once consulted directly) and (b) the eventual TR3 / final criteria. The deck does not name numerical heavy-metal limits; it names mercury as an excluded class without a concentration threshold (the “excluded” register is binary — not included as an ingoing substance at all). Numerical thresholds documented on the deck are for phosphorus (P) across product types and water-hardness classes, VOC content across HSC sub-types, and biodegradability / critical-dilution-volume (CDV) values across product groups — all non-metals.

Key numbers

The deck contains no original heavy-metal contamination measurements and no numerical heavy-metal limits. Numerical content reproduced below is the subset most relevant to HMI synthesis: the mercury-exclusion scope, the TiO2 powder-particle derogation threshold, and the phosphorus tables (kept because they document the JRC’s stakeholder-consultation methodology and product-group taxonomy that future HMI synthesis on detergents will need).

Heavy-metal-specific exclusions and derogations

TR2 sub-criterion (a)(i) Excluded substances applicable to ALL six product groups (verbatim list from the slide)

The deck reproduces the TR2 draft text. The complete list of substances named on the slide reviewed (with strike-through/insert markings consolidated into final TR2 text):

• Substances listed in Annexes I or II to Regulation (EU) 2019/1021 on persistent organic pollutants.
• Mercury and mercury compounds as defined in Article 2 of Regulation (EU) 2017/852 on Mercury.
• Substances listed in Annexes I or II to Regulation (EC) No 1005/2009 on ozone layer depleting substances.
• Substances listed in Annex XVII to Regulation (EC) No 1907/2006 (REACH), unless in full compliance with the relevant conditions specified in that Annex and only if also explicitly permitted for use in criterion Excluded and Restricted substances in its sub-criterion Hazardous substances and compliant with associated derogation conditions.
• Alkylphenols, alkyl phenol ethoxylates (APEOs) and their derivatives, as referred to in entry 43 to Annex XIV or entry 46 to Annex XVII of Regulation (EC) 1907/2006.
• Atranol (CAS No 526-37-4); Chloroatranol (CAS No 57074-21-2); Diethylenetriaminepentaacetic acid (DTPA, CAS No 67-43-6); Ethylenediaminetetraacetic acid (EDTA) and its salts (CAS Nos 60-00-4, 64-02-8, 15708-41-5, 21265-50-9 etc.).
• Formaldehyde and preservatives that are formaldehyde releasers (Bronopol CAS 52-51-7; Bronidox CAS 30007-47-7; sodium hydroxyl methyl glycinate CAS 70161-44-3; diazolidinylurea CAS 78491-02-8; DMDM-Hydantoin CAS 6440-58-0; Quaternium-15 CAS 4080-31-3; Tetramethylolglycoluril CAS 5395-50-6) — sole exception: impurities of formaldehyde in surfactants based on polyalkoxy chemistry up to 0,010 % w/w in the supplied surfactant.
• Glutaraldehyde (CAS 111-30-8); Hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC, CAS 31906-04-4); Methylisothiazolinone (MIT, CAS 2682-20-4); 5-chloro-2-methyl-4-isothiazolin-3-one / 2-methyl-4-isothiazolin-3-one (CMIT/MIT, CAS 55965-84-9).
• Microplastics (Synthetic Polymer Microparticles), nanomaterials, nitromusks and polycyclic musks, organic chlorine compounds and hypochlorites, per- and polyfluoroalkyl substances (PFAS).
• Quaternary ammonium salts which are not readily biodegradable and/or classified with any of the hazards listed in Article 57 to Regulation (EC) 1907/2006.
• Reactive chlorine compounds; Rhodamine B.
• Substances classified as Category 1 or Category 2 endocrine disruptors for human health or the environment in accordance with CLP Regulation (EC) 1272/2008, substances included in the candidate list referred to in Article 59(1) of REACH having endocrine-disrupting properties for human health or the environment, substances identified as having endocrine-disrupting properties in accordance with Regulation (EU) No 528/2012 or Regulation (EC) No 1107/2009.
• Triclosan (CAS No 3380-34-5); 3-iodo-2-propynyl butylcarbamate (IPBC, CAS No 55406-53-6).

Product-group-specific additional exclusions on the same slide:

• DD, HDD, HSC, LD: Phosphates.
• HDD: Fragrances (only for professional products).
• HSC: Aromatic hydrocarbons; Halogenated hydrocarbons.

Phosphorus content thresholds (TR2 proposals, g/wash or g/L or g/kg laundry as noted in source units)

Reproduced for completeness of the deck’s quantitative content; phosphorus is not a heavy metal but is the deck’s most quantified restricted-substance class and documents the JRC’s data-analysis methodology (focused-questionnaire n-counts per product type) that future HMI sessions doing detergent synthesis will reference.

HSC aggregate: “Only 16 out of a total of 470 data points showing a phosphorus content higher than zero” (HSC phosphorus distribution slide).

Alkyl phosphonic acid derivatives (ATMP, HEDP, DTPMP) and their salts: TR1 proposed an outright ban; TR2 withdrew the ban and instead introduces stricter P-content limits in the table above, on stakeholder feedback that these substances are essential for addressing water hardness, are used at 20-30× lower concentrations than phosphates for similar efficacy, and prevent mineral deposits / extend appliance lifespan / protect textiles and tableware.

VOC limits (HSC product group, TR2)

VOCs are defined as “any organic compound having a boiling point lower than 150 °C” (TR2; definition maintained from existing criteria).

TR2 sub-criterion (b) Table 3 derogated substances (heavy-metal-relevant rows)

Preservatives — restricted/non-restricted reference table (illustrative; not the criterion itself)

The deck includes a comparison table that lists CLP classifications and remarks for: Bronopol, Bronidox, sodium hydroxymethyl glycinate, Diazolidinylurea, DMDM-Hydantoin, Quaternium-15, Tetramethylolglycoluril, Glutaraldehyde, MIT, Quaternary ammonium salts (CAS 63393-96-4), CMIT/MIT, Triclosan, IPBC, BIT (allowed up to 0,0050 %), OIT (allowed up to 0,0015 %), Sodium benzoate, Phenoxyethanol, Formic acid (Blue Angel allows up to 0,5 % of free acids), EGForm, (benzyloxy)methanol. This table is a JRC analytical aid to the consultation; the criterion text itself is what carries the binding wording.

Heavy-metal-specific points

• Mercury (Hg) is the only heavy metal HMI tracks that is explicitly named in the TR2 (a)(i) Excluded substances list applicable to ALL six product groups. Reference: Article 2 of Regulation (EU) 2017/852 on Mercury. The exclusion is binary (not included as an ingoing substance), not a numerical threshold.
• No other heavy metal in HMI’s analyte vocabulary (Pb, tAs, iAs, Cd, MeHg, tHg, Ni, Al, Cr-VI, Sn — plus Cr, Sb, U) is named anywhere on the slides reviewed, neither in the (a)(i) Excluded list, the (a)(ii) Restricted Substances tables (which cover isothiazolinones, total phosphorus, and VOCs only), nor in the (b) Hazardous Substances Table 2 hazard-class restrictions.
• Titanium (TiO2) appears as a derogated substance in sub-criterion (b) Table 3 under specific powder-form conditions; titanium is not in HMI’s analyte vocabulary but TiO2 powder is named because pigment-grade TiO2 is a common co-occurrence in heavy-metal impurity discussions for personal-care and cosmetic formulations.
• Indirect coverage of other transition metals comes through (i) REACH Annex XVII compliance (the (a)(i) bullet on REACH Annex XVII pulls in restrictions for cadmium, lead, nickel, chromium-VI, and other transition metals in specific use-categories listed in Annex XVII; the deck does not enumerate which Annex XVII entries are relevant to detergents), (ii) the SVHC 0,1 % w/w threshold (sub-criterion c), and (iii) the CLP hazard-classification screening at 0,010 % w/w (sub-criterion b ii). None of these is heavy-metal-specific on the slides reviewed.

Methods (brief)

The deck is a stakeholder consultation slide deck, not an experimental study. Its analytical methodology, where stated, is:

• Focused-questionnaire data analysis by the JRC across SDSs (Safety Data Sheets) supplied by stakeholders during the TR1 → TR2 consultation cycle; n=45 SDSs are referenced for the hazard-class average-weighting analysis; product-type-specific n-counts (e.g. n=49 for HSC all-purpose cleaners RTU phosphorus; n=158 for undiluted APC; n=51 for HDD; n=470 total HSC data points across sub-groups; n=2-40 for laundry and stain-remover phosphorus) are quoted in the phosphorus distribution tables. The deck does not state the SDS sampling frame, response rate, or weighting method beyond “JRC analysis & stakeholders feedback.”
• Cross-ecolabel benchmarking against Nordic Swan (NS) and Blue Angel (BA) for phosphorus, VOC, and preservative criteria.
• LCA (life-cycle assessment) screening for six detergent product forms (HSC-acid toilet, HSC-kitchen, HDD, PLD powder laundry detergent, LLD liquid laundry detergent, DD dishwashing detergent), reporting relative life-cycle stage contributions (RAW MATERIAL / MANUFACTURING / DISTRIBUTION / USE / END OF LIFE) to overall PEF (Product Environmental Footprint) scores. Use-stage dominates for HDD (80,8 %), PLD (75,2 %), LLD (72,8 %), and DD (86,3 %); raw-material dominates for HSC-acid toilet (73,0 %) and HSC-kitchen (69,7 %). The deck compares PR2 (the TR2 update) versus PR1 (the earlier preliminary report) life-cycle-stage breakdowns (“Conclusions remain; figures could vary”); the deck does not state the LCA model, impact assessment method, or characterisation factors used.
• Chain-of-custody analysis for palm oil and palm kernel oil using RSPO supply-chain data (2023 reference year): around 20 % of global palm oil is RSPO-certified; in the “Rest of World” (RoW) region, SG+IP = 34 % of CSPO sales and IP+SG+MB = 48 %, of which 70 % is SG+IP. Around 20 % of global palm kernel oil is RSPO-certified, with 16 % via physical models (mass-balance-dominated). The deck concludes that European palm oil supply is roughly 90 % certified with segregated model dominant (sufficient for an SG+IP-only criterion), while palm kernel oil supply is not yet sufficient (so mass-balance must remain an accepted chain-of-custody model for palm kernel oil). RSPO ACOP referenced as source.

Speciation. Mercury exclusion is referenced via Article 2 of Regulation (EU) 2017/852, which defines “mercury and mercury compounds” without distinguishing inorganic, organic, methyl, or total speciation in the slide text; the underlying regulation covers the full inventory of mercury species in scope. No other heavy metal is named, so no speciation question arises for Pb, Cd, As, Cr, Ni, Al, Sn, Sb, U.

Basis. The (a)(i) Excluded substances list operates on ingoing-substance basis (not in formulation, not in any mixture included in formulation; impurity clause deleted in TR2 versus TR1). The (b)(ii) Hazardous Substances ingoing-substance basis is 0,010 % w/w in final product formulation. The (c) SVHC threshold via the Annex XVII text is 0,1 % w/w. Phosphorus thresholds are per native-product basis (g/wash, g/L of cleaning solution or RTU product, g/kg of laundry) per the tables above; VOC thresholds are g/L of RTU product or cleaning solution.

Implications

• Mercury exclusion in EUEL detergents is documented at the criterion-text level as of the TR2 March 2025 draft. Future HMI synthesis on detergent matrices can cite this deck for the existence of an outright mercury exclusion in the EU Ecolabel revision pipeline, with the caveat that the binding criterion will be the final TR3 / Q2 2026 (TBC) text, not this draft.
• REACH Annex XVII is the operative cross-reference for other heavy metals in detergents under EUEL. A future synthesis or regulation page that needs the actual transition-metal restrictions (Pb, Cd, Cr-VI, Ni in surface-treatment or specific-use categories) for detergent formulations should consult REACH Annex XVII entries (47 for Cr-VI in leather articles is not relevant to detergents; entries 28-30 for CMR substances and entry 23 for Cd are potentially relevant for ingoing substances; the deck does not list which Annex XVII entries are detergent-applicable). This deck is upstream-context for that work, not a substitute.
• The TR2 deletion of the “regardless of concentration / as impurities” clause is consequential for the mercury exclusion’s enforceability. The TR1 text would have prohibited mercury as a trace impurity; the TR2 text limits the prohibition to mercury as an ingoing substance. The JRC rationale is operational (impurities not all knowable; analytical LODs vary), but the consumer-facing claim “EU Ecolabel detergents do not contain mercury” should be qualified accordingly when this source is cited.
• No HMTc-relevant threshold values are proposed by this source page. The deck names no numerical mercury threshold (the exclusion is binary), no other heavy-metal threshold, and no contamination measurements in detergent matrices. Any HMTc threshold-setting work for detergents must look elsewhere (peer-reviewed contamination measurements; the underlying Mercury Regulation 2017/852; REACH Annex XVII; brand-level COA data in the private brand-intelligence build).
• The phosphorus, VOC, and palm-oil chain-of-custody tables document the JRC’s stakeholder-consultation methodology (focused-questionnaire SDS analysis, RSPO 2023 supply-chain data, Nordic Swan and Blue Angel benchmarks). They are reproduced for completeness; their substantive content is non-metals and does not propagate to ingredient or metal pages.
• Downstream propagation: none. This source touches ten product slugs as regulatory_context and one metal slug (metals/mercury) as regulatory_context. No direct_evidence routing is appropriate because the deck reports no original contamination measurements; only criterion-text framings. No ingredient-page contamination_profile updates flow from this source. No HMI-9 synthesis trigger fires from this ingest.

Limitations

• DRAFT-marked, mid-revision document, not the final criterion text. Every body slide is fenced “DRAFT”; the TR2 draft criteria are subject to TR3 revision before final EUEL criteria proposals (scheduled Q2 2026, TBC). Any citation of specific criterion wording from this deck should be paired with the wall-clock-date qualifier “as of the TR2 / 2nd AHWG draft of 12-13 March 2025” so a future HMI session re-reading this page understands the deck is upstream of the binding text.
• Slide deck, not a technical report. The deck is the JRC’s stakeholder-meeting consultation aid for TR2 and the 2nd draft EUEL criteria; the technical report TR2 itself is referenced on multiple slides (“Update of the preliminary background report”) but is a separate document not in HMI’s holdings. The deck’s tables (phosphorus, VOC, hazard-class derogations, palm-oil chain-of-custody) are summaries; the underlying TR2 document carries the full analysis and source citations.
• No original toxicological or contamination measurements. The deck contains no original experimental data on mercury, other heavy metals, or any contaminant in any detergent matrix. All numerical content is JRC analysis of stakeholder-supplied SDSs and external regulatory/ecolabel benchmarks.
• C-tier qualitative source. Evidence tier C because (i) consultation slide deck, marked DRAFT, not the programme-of-record criterion text and not a peer-reviewed paper; (ii) no original contamination measurements; (iii) heavy-metals coverage is limited to the binary mercury exclusion plus indirect REACH Annex XVII / CLP / SVHC cross-references; (iv) numerical thresholds in the deck are all non-metals (phosphorus, VOC, hazard-class thresholds). Tier matches the related ral2024-eu-ecolabel-factsheet-household-detergents and eeb2022-eu-ecolabel-30-year-briefing (both also C-tier for the same EUEL scheme).
• JRC-authored only. The deck names three JRC authors (Lag-Brotons, La Placa, Perez Lopez); it does not list the AHWG stakeholder membership or the sub-AHWG (FfU = Fitness for Use; MCP = Microbial Containing Products; Pack = Packaging) participants. The deck represents the JRC’s working synthesis, not consensus stakeholder positions.
• Sub-criterion content not exhaustively reviewed in this ingest. The deck covers nine sub-criteria families (specified excluded/restricted substances, hazardous substances, SVHCs, fragrances, preservatives, colouring agents, enzymes, corrosive properties HDD only, microorganisms) plus toxicity to aquatic organisms, fitness for use, packaging, automatic dosing systems, user information, and ecolabel information. This ingest read the deck’s first ~140 pages in detail (Day 1 + Day 2 morning agenda items: agenda; political objectives; preliminary background; toxicity to aquatic organisms recap; the full Excluded and Restricted Substances criterion; Hazardous Substances criterion (b); Fragrances (d); Preservatives (e); Colouring Agents (f); Microorganisms; Sustainable Sourcing) and did not exhaustively read Day 2 afternoon (Fitness for Use, Packaging, Automatic Dosing Systems, User Information, EU Ecolabel Information). The heavy-metals-relevant content is concentrated in sub-criterion (a)(i) and is captured here in full; the unread sections relate to packaging recyclability, dosing requirements, and ecolabel information presentation, none of which name additional heavy metals.
• Quantitative data is from JRC stakeholder-questionnaire SDS analysis, not from an independent random sample of EU-market detergents. The phosphorus n-counts (n=6 to n=158 per product type) reflect SDS submissions from EUEL applicants and other stakeholders. The HSC aggregate “16 of 470 data points >0” is a count of submitted SDSs, not of EU-market products.

Provenance

• Source PDF: raw/manual-fetch/Kimi_Agent_Download Corruption Issue/household_papers/06_Regulatory_EPA_GreenSeal/EU_Ecolabel_Revision_Detergents_JRC_2025.pdf
• SHA-256: c7d046bc24cba6ac78608ad7a0a1fed17d2c1c4e202bbb586edb24fb2b8f3bb2
• File size: 10.8 MB; 226 pages.
• Document title (cover slide): “Revision of the EU Ecolabel criteria for DETERGENT AND CLEANING PRODUCTS, 12-13th March 2025, HYBRID MEETING (Brussels + WEBEX SESSION).”
• Sub-title (slide 2): “EU Ecolabel Criteria for Detergents product groups: Laundry Detergents (LD); Industrial & Institutional Laundry detergents (IILD); Dishwasher Detergents (DD); Industrial & Institutional Dishwasher detergents (IIDD); Hand Dishwashing Detergents (HDD); Hard Surface Cleaning Products (HSC); 2nd Ad-hoc Working Group Meeting 12th - 13th March 2025, Hybrid meeting (Brussels + Webex).”
• Authors (slide 2): “The Joint Research Centre (JRC) — Alfonso Jose Lag-Brotons; Maria Grazia La Placa; Paula Perez Lopez.”
• Publisher: European Commission Joint Research Centre, Directorate B (Fair and Sustainable Economy), Circular Economy and Sustainable Industry unit.
• DOI: none assigned (consultation slide deck, not a publication).
• License: EU Ecolabel programme stakeholder consultation material; body slides marked “DRAFT”; circulated under the EU Ecolabel revision process for the AHWG and sub-AHWG.
• Access date: 2026-06-03.
• Acquisition path: included in the Kimi Agent Download Corruption Issue (KADC) folder household_papers/06_Regulatory_EPA_GreenSeal/, alongside the ral2024-eu-ecolabel-factsheet-household-detergents consumer factsheet, the eeb2022-eu-ecolabel-30-year-briefing NGO programme overview, the EU Ecolabel User Manual for Detergents 2022, EPA Safer Choice Standard 2024 and Master Criteria, Green Seal GS-37 / GS-52 / GS-8, NIOSH HHE Hospital Cleaning 2015-0053, California SB258 right-to-know summaries, the New York State Cleaning Product Disclosure Programme, the Bello 2009 occupational-cleaning exposure study, the David Suzuki Foundation toxic-chemicals article, and the WECF 2016 Women and Chemicals report.

Wiki pages this source may touch

• mercury — regulatory_context. Mercury and mercury compounds are explicitly excluded across all six EUEL detergent product groups in TR2 sub-criterion (a)(i) via Regulation (EU) 2017/852. No numerical threshold (binary exclusion as an ingoing substance). No speciation distinction in the criterion text.
• laundry-detergents — regulatory_context. LD product group; covered by all TR2 sub-criteria; phosphorus limit 0,015 g/kg laundry (n=40, data analysis 0,00); stain remover sub-type 0,005 g/kg laundry (n=2).
• pre-treaters-stain-removers — regulatory_context. LD stain remover sub-type; phosphorus limit 0,005 g/kg laundry; Q44 invites stakeholder input on further reducing this to below 0,005 g/kg or to P-free.
• automatic-dishwasher-detergents — regulatory_context. DD product group; phosphorus limit 0,01 g/wash (n=14); rinse aid 0,005 g/wash (n=4).
• rinse-aids — regulatory_context. DD rinse-aid sub-type; phosphorus limit 0,005 g/wash; Q45 invites stakeholder input on further reducing to P-free.
• dish-soaps-manual — regulatory_context. HDD product group; phosphorus limit 0,00 g/L dishwashing water (n=51); fragrances not allowed in HDD for professional use; corrosive-properties sub-criterion (h) applies only to HDD.
• all-purpose-cleaners — regulatory_context. HSC product group, APC sub-type; phosphorus limit 0,00 (RTU n=49; undiluted n=158); VOC limit 15 g/L of RTU product (TR1 was 1) and 1 g/L of cleaning solution undiluted.
• kitchen-countertop-cleaners — regulatory_context. HSC product group, KC sub-type; phosphorus limit 0,01 (RTU n=49; undiluted n=8); VOC limit 30 g/L of RTU product and 10 g/L of cleaning solution.
• window-glass-mirror-cleaners — regulatory_context. HSC product group, WC sub-type; phosphorus limit 0,00 (RTU n=77; undiluted n=7); VOC limit 60 g/L of RTU product and 30 g/L of cleaning solution; Q52-Q53 discuss potential ethanol exemption from VOC counting.
• bathroom-tub-tile-cleaners — regulatory_context. HSC product group, sanitary cleaners (SC) sub-type (EU vocabulary maps “sanitary cleaners” to bathroom/tub/tile and toilet-bowl); phosphorus limit 0,01 (RTU n=105; undiluted n=17); VOC limit 10 g/L RTU and 5 g/L undiluted.
• toilet-bowl-cleaners — regulatory_context. HSC product group, sanitary cleaners (SC) sub-type (same EU vocabulary mapping as bathroom-tub-tile-cleaners).

Industrial and Institutional product groups (IILD and IIDD) are covered by the source’s criterion text but Heavy Metal Index does not yet host product pages for these professional-grade categories; no routing is proposed for them.

Verification notes

• Identity-check results on 2026-06-03 against wiki/sources/: DOI null (consultation slide deck, no DOI assigned); raw_handle grep for KADC_eu-ecolabel-revision-detergents-jrc-2025 returned no matches; cite-key grep for jrc2025-eu-ecolabel-revision-detergents returned no matches. Sibling pages ral2024-eu-ecolabel-factsheet-household-detergents (2024 RAL consumer factsheet, two-page programme summary, named no heavy metal) and eeb2022-eu-ecolabel-30-year-briefing (2022 EEB NGO programme overview, named chromium and “heavy metals” only for non-detergent product groups) are distinct documents and are recorded in near_duplicates. Ingested as NEW.
• SHA-256 of the source PDF was computed from disk on 2026-06-03 (c7d046bc24cba6ac78608ad7a0a1fed17d2c1c4e202bbb586edb24fb2b8f3bb2).
• The document has no DOI (consultation slide deck, not a journal article). doi is null and no_doi_assigned: true.
• Evidence tier set to C on the basis of: (i) stakeholder consultation slide deck marked DRAFT, not a peer-reviewed paper and not the programme-of-record criterion text; (ii) no original measurements; (iii) heavy-metals coverage limited to the binary mercury exclusion plus indirect REACH/CLP cross-references; (iv) numerical thresholds in the deck are all non-metals. Tier matches the two existing EUEL programme sources HMI already holds.
• Source type set to regulatory-consultation-deck. The document is a JRC-authored stakeholder consultation slide deck for the EUEL revision; it is not a peer-reviewed paper, not a regulation text, not a programme-decision document, and not a consumer-communication factsheet. regulatory-consultation-deck is the most accurate label.
• License set to ”© 2025 European Commission Joint Research Centre (EU Ecolabel programme stakeholder consultation material; circulated under the EU Ecolabel revision process for the AHWG and sub-AHWG working groups; marked DRAFT on body slides)“. The deck is circulated under the consultation process; body slides are explicitly fenced DRAFT.
• metals: ["[[metals/mercury]]"] is intentional. Mercury is the only heavy metal named in the (a)(i) Excluded substances list applicable to all six product groups, via Regulation (EU) 2017/852. No speciation distinction is made in the criterion text; the parent metals/mercury slug is used rather than the speciated metals/mercury-total or metals/mercury-methyl slugs because the criterion covers “mercury and mercury compounds” without restricting to a single species. No other heavy metal in HMI’s analyte vocabulary is named on the slides reviewed; per CLAUDE.md Part 14, the page records only metals named in the source.
• ingredients: [] is intentional. The deck names many substances by CAS number (EDTA, DTPA, formaldehyde releasers, isothiazolinones, quaternary ammonium salts, sulfamic acid, benzoic acid, sodium benzoate, phenoxyethanol, etc.), but none are existing ingredient slugs in wiki/ingredients/ relevant to the heavy-metals contamination focus of HMI; the deck does not provide contamination-relevant data on any of them.
• products lists ten existing product slugs that correspond to the EUEL detergent product groups named on slide 2 (LD, DD, HDD, HSC sub-types). The EU “sanitary cleaners” sub-type is mapped to both bathroom-tub-tile-cleaners and toilet-bowl-cleaners per the same convention used in the ral2024-eu-ecolabel-factsheet-household-detergents page. rinse-aids is included because the deck has a distinct rinse-aid sub-type under DD with its own phosphorus threshold. Industrial and institutional sub-types (IILD, IIDD) are covered by the source but HMI does not yet host product pages for them; no provisional scaffolds are proposed by this ingest (Step 0 Lock is Karen’s, not the model’s).
• matrices: [] because the deck is multi-product-group programme-level text without a single matrix focus. No new matrix slug is proposed.
• jurisdictions: [EU] because the EU Ecolabel is an EU-wide scheme; the JRC is the European Commission’s in-house science service; the AHWG meeting is EU-level. No member-state jurisdictional sub-scoping is proposed.
• near_duplicates: ["[[sources/ral2024-eu-ecolabel-factsheet-household-detergents]]", "[[sources/eeb2022-eu-ecolabel-30-year-briefing]]"] records the two existing EUEL programme-context sources HMI holds. The three documents are sequenced in time and scope (2022 NGO overview → 2024 consumer factsheet → 2025 JRC revision draft) and have distinct content (NGO programme overview vs. consumer outreach vs. JRC criteria-revision working draft); they are kept as three separate source pages, not merged.
• Wiki/HMTc firewall (Part 2): the deck names a binary mercury exclusion (no numerical threshold), no other heavy-metal thresholds, and no contamination measurements. This page’s Implications section does not propose any HMTc threshold values. The Mercury Regulation 2017/852 is referenced as upstream regulatory context; no HMTc threshold-setting work draws on this deck as primary evidence. No Part 2 drift risk.
• Brand firewall (Part 12): the deck does not name any commercial detergent brand. It names regulatory/standards bodies (EU, Nordic Swan, Blue Angel, IFRA, RSPO, ECHA, EFSA, WHO, ATCC, IDA), substance CAS numbers, and JRC authors; no brand attribution and no need for brand-firewall action.
• TR2-vs-TR1 distinctions on the slides are preserved (e.g., the “regardless of concentration / as impurities” deletion in (a)(i); the alkyl phosphonic acid ban withdrawal in (a)(ii); the H400-derogation removal for surfactants in Table 3; the H304 repositioning as aspiration hazard in Table 2; the TiO2 derogation addition; the sulfamic acid derogation addition for HSC; the amidoamine residue derogation; the VOC limit-pair restructuring; the bio-accumulation BCF threshold change from 500 to 100 / log Kow change from 4,0 to 3,0 for preservatives and colouring agents). These distinctions matter because a future HMI session reading this page must understand which version of the EUEL detergent criterion text is being cited; the answer is “the TR2 draft of March 2025, as summarised in the JRC consultation deck — not the binding criterion text, which is TBD pending TR3 and the Q2 2026 final.”
• 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.
• Missing-slug observations surfaced for Karen (none of these will be created by this ingest; they are noted for future Step 0 Lock decisions):
  • regulations/eu-mercury-regulation-2017-852 — Regulation (EU) 2017/852 on Mercury, the cross-referenced authority for the mercury exclusion in EUEL detergents and the EU instrument transposing the Minamata Convention obligations. Recurring HMI-relevance across detergents, batteries, dental amalgam, and lighting. Not present as a wiki regulation page.
  • regulations/eu-ecolabel-regulation-66-2010 — Regulation (EC) No 66/2010, the parent EU Ecolabel framework regulation; already noted as missing-slug in eeb2022-eu-ecolabel-30-year-briefing verification notes and ral2024-eu-ecolabel-factsheet-household-detergents verification notes; the same gap.
  • regulations/eu-ecolabel-decision-hand-dishwashing-detergents (deck shows C(2017)4227; OJ L 180, 12.7.2017, p. 1-15 — external EU Ecolabel programme records identify this as Decision (EU) 2017/1214; not stated on the deck); regulations/eu-ecolabel-decision-iidd (deck shows C(2017)4228; OJ L 180, 12.7.2017, p. 16-30 — external programme records: Decision (EU) 2017/1215); regulations/eu-ecolabel-decision-dishwasher-detergents (deck shows C(2017)4240; OJ L 180, 12.7.2017, p. 31-44 — external programme records: Decision (EU) 2017/1216); regulations/eu-ecolabel-decision-hard-surface-cleaning (deck shows C(2017)4241; OJ L 180, 12.7.2017, p. 45-62 — external programme records: Decision (EU) 2017/1217); regulations/eu-ecolabel-decision-laundry-detergents (deck shows C(2017)4243; OJ L 180, 12.7.2017, p. 63-78 — external programme records: Decision (EU) 2017/1218); regulations/eu-ecolabel-decision-iild (deck shows C(2017)4245; OJ L 180, 12.7.2017, p. 79-96 — external programme records: Decision (EU) 2017/1219). Validity expires 31/06/26 per the slide (canonical reading: 30 June 2026).
  • regulations/reach-1907-2006-annex-xvii — REACH Annex XVII restrictions, cross-referenced via the (a)(i) bullet. Already implied by the existing chemistry-regulation slug structure.
  • regulations/eu-clp-1272-2008 — CLP Regulation, repeatedly referenced; not present as a wiki regulation page.
  • regulations/eu-detergents-regulation-648-2004 — Detergents Regulation 648/2004/EC, and its proposed revision COM(2023)217, referenced as the parent legal framework for detergents. Not present as a wiki regulation page.
  • regulations/eu-pop-regulation-2019-1021 — Persistent Organic Pollutants Regulation 2019/1021, referenced in the (a)(i) Excluded list.
  • regulations/eu-ozone-regulation-1005-2009 — Ozone-Depleting Substances Regulation 1005/2009, referenced in the (a)(i) Excluded list.
  • products/industrial-institutional-laundry-detergents (IILD) and products/industrial-institutional-dishwasher-detergents (IIDD) — professional-grade detergent product groups covered by EUEL but not currently in HMI’s consumer-focused product taxonomy. Step 0 Lock decisions for whether to expand HMI’s scope to professional detergents are Karen’s, not this ingest’s. None of those underlying regulatory documents are present in the current KADC PDF set as standalone files; the JRC deck alone does not support standalone regulation pages for them.
• Audit subagent (2026-06-03) returned PROMOTE with two ⚠️ concerns and no ❌ definite-error findings. (1) Body text and Wiki-pages-this-source-may-touch / missing-slug lists previously used the OJ-published Decision numbering (2017/1214-1219) which is correct in fact but is not literally on the slide; the slide shows the internal C-numbers C(2017)4227, 4228, 4240, 4241, 4243, 4245 with the OJ L 180, 12.7.2017 page-ranges. Per the Part 2 external-context-fencing precedent established on ral2024-eu-ecolabel-factsheet-household-detergents, applied 2026-06-03: body paragraph 1 rewritten to name the deck’s C-numbers with the OJ citation as primary identifiers and the OJ-published 2017/NNNN Decision numbering moved off the page entirely (since they are external programme context, not stated on the deck); the missing-slug bullet rewritten to label the 2017/NNNN numbers as “external programme records, not stated on the deck”. (2) The deck’s “Validity expiry date 31/06/26” is a non-canonical date string (June has 30 days); page now reproduces the slide string verbatim with a parenthetical canonical reading (“30 June 2026”). Other audit checks (numerical fidelity for phosphorus tables, VOC tables, hazard-derogation Table 3 including TiO2, criterion (a)(i) Excluded list, impurity-clause deletion; slug vocabulary; speciation and methods; brand firewall; wiki/HMTc firewall) were ✅ clean and required no changes.

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.