November 2006

RECOMMENDATIONS FOR THE REDUCTION OF
PHOSPHORUS IN DETERGENTS

FINAL REPORT
















AUTHORS

PREPARED BY:
WRc plc
(Project number 14092-0)

AUTHORS:
Helene Horth (WRc, UK)
Edward Glennie (WRc)
Lacey-Jane Davis (WRc)
Pauline Jones (WRc)
Oana Tortolea (Cesep, Romania)






















WRc
plc
Frankland Road, Swindon, UK SN5 8YF
Phone Number 0044 1793 865000

email solutions@wrcplc.co.uk




Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 1
TABLE OF CONTENTS

Executive Summary...........................................................................................................................................5
1.
Introduction ...................................................................................................... 9
2.
The Danube River Basin .....................................................................................10
2.1.
Countries in the Danube River Basin District ......................................................10
2.2.
The need to reduce phosphorus emissions in the Danube River Basin ....................12
3.
Task 1 - Review existing legislation, policies and voluntary commitments on
the reduction of phosphorus in laundry detergents across the EU and DRB.................13
3.1.
Mechanisms for the reduction of detergent phosphates .......................................13
3.2.
EU and international legislation and agreements restricting the use of
phosphates in detergents ...............................................................................14
3.2.1.
Overview of EU and other international legislation relevant to DRB
countries .................................................................................................14
3.2.2.
EU voluntary agreements ...........................................................................20
3.2.3.
Other measures for limiting phosphates in detergents ....................................20
3.3.
Overview of existing and planned legislation, policies and voluntary
agreements in DRB countries ..........................................................................21
3.3.1.
Brief case studies......................................................................................21
3.3.2.
Advantages, limitations and costs involved in implementation of
voluntary agreements in DRB countries........................................................26
4.
Task 2 ­ compile and evaluate data on phosphorus containing detergents and
associated production structures across the DRB....................................................27
4.1.
Production and use of phosphorus-based and alternative detergent builders
in DRB countries ...........................................................................................27
4.1.1.
Overview of production structures, washing techniques and regional
differences in detergent formulations ...........................................................27
4.1.2.
Overview of the current production and use of phosphate-based
detergents (including import and export)......................................................32
4.1.3.
Summary of the current use of alternative (e.g. zeolite-based)
detergents in DRB countries .......................................................................35
4.2.
Industry and country costs and benefits associated with switching from
phosphate-based to more environmentally friendly detergent builders ..................37
4.2.1.
Comparison of production costs for phosphate-based and alternative
(e.g. zeolite-based) detergents ...................................................................37
4.2.2.
Comparison of wastewater treatment costs for phosphate-based and
alternative (e.g. zeolite-based) detergents ...................................................39
4.2.3.
Estimation of costs/benefits of using alternative detergent builders in
DRB countries (country specific) .................................................................40
5.
Task 3 ­ European experience of voluntary agreements ..........................................47
5.1.
Types of voluntary agreement .........................................................................47
5.2.
Benefits and risks of voluntary agreements .......................................................48
UNDP/GEF DANUBE REGIONAL PROJECT


page 2

5.3.
Setting up a voluntary agreement ....................................................................48
5.4.
Content of a voluntary agreement....................................................................51
5.5.
Strategy for implementing the agreements........................................................51
6.
Conclusions and recommendations.......................................................................54
References.........................................................................................................................................................56

ANNEXES

ANNEX 1 Individual country detergent policy ­ results from questionnaire ...........................63
ANNEX 2 Template for Individual Country Detergent Policy and Use Questionnaire..............103
ANNEX 3 Examples of voluntary agreements ­ Czech Republic and Republic of Ireland..........113
ANNEX 4 AISE Membership in Danube countries................................................................................127

LIST OF TABLES

Table 1 Countries in the Danube River Basin District........................................................10
Table 2 Change in consumption of poorly biodegradable organic (PBO) ingredients in
household laundry detergents between 1996 and 2001 in the 15 EU Member
States (taken from COM(2004)134) ...................................................................17
Table 3 Voluntary agreements: information from the questionnaire - Relating to P
reduction in detergents ....................................................................................22
Table 4 Voluntary agreements: information from the questionnaire - Relating to other
environmental issues .......................................................................................23
Table 5 Detergent suppliers by country (information from questionnaires) ..........................30
Table 6
Data on household laundry detergent use (information from questionnaires) ..........31
Table 7 Industrial, & domestic dishwasher, detergent use (information from
questionnaires) ...............................................................................................32
Table 8 The use of phosphate-free detergents in the Danube countries ..............................33
Table 9 Detergent usage, populations & phosphate-free detergents by country....................36
Table 10 Laundry detergent manufacturers, brands, types & prices - Hungary (2005) ............41
Table 11 Laundry detergent manufacturers, brands, types & prices - Moldova (2005) ............42
Table 12 Laundry detergent manufacturers, brands, types & prices ­ Romania......................43
Table 13 Laundry detergent manufacturers, brands, types & prices - Serbia-
Montenegro ....................................................................................................44
Table 14 Laundry detergent manufacturers, brands, types & prices - Ukraine (2004) .............46
Table 15 Types of voluntary initiative ..............................................................................47
Table 16 Comments and observations .............................................................................49
Table 17 Incentives for companies to enter voluntary agreements.......................................50
Table 18 Steps to achieve a voluntary agreement .............................................................52
Table 19 AISE member associations in Danube countries ...................................................52
Table 20 Summary of AISE membership information .........................................................53
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 3

LIST OF FIGURES

Figure 1 Phosphate-free detergents in the Czech Republic (source: Doubravka
Nedvedova, Ministry of Environment, Czech Republic) ..........................................25
Figure 2 Detergents production, use and trade in Romania, 2000-2004 (source:
Romanian national statistics) ............................................................................29
Figure 3 Market shares of phosphate-free powder detergents in Europe in 1998
(Source: E.J. Smulders as provided by CESEP) ....................................................38
Figure 4 Negotiating and implementing a voluntary agreement ..........................................49





UNDP/GEF DANUBE REGIONAL PROJECT


page 4

ABBREVIATIONS

AISE
Association internationale de la savonnerie, de la détergence et des produits
d'entretien (the official body that represents the soap, detergent and
maintenance products industry within Europe)
CEE
Central and Eastern Europe
DRB
Danube River Basin
DRP
Danube Regional Project
EG Expert
Group
EU European
Union
EU15
15 pre 2004 European Union Member States
EU WFD
EU Water Framework Directive
GEF
Global Environment Facility
ICPDR
International Commission for the Protection of the Danube River
STPP Sodium
tripolyphosphate
UNDP
United Nations Development Programme
EMIS EG
Emissions Expert Group of the ICPDR
P & M EG
Pressures and Measures Expert Group of the ICPDR (formerly the EMIS EG)











WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 5
EXECUTIVE SUMMARY

WRc plc has been appointed by the United Nations Office for Project Services (UNOPS) (Reference
00036337, RER/03/G31) to develop recommendations for the reduction of phosphorus in
detergents, which were intended to be used as a basis for the negotiation of a voluntary agreement
between the International Commission for the Protection of the Danube River (ICPDR) signatory
countries and the Detergent Industry.
The project was based on the previously established need to reduce phosphorus input to the
Danube and its tributaries (ICPDR DABLAS, 20041, Danubs, 20052), and targets for phosphorus
input reductions are included in the ICPDR Joint Action Programme (ICPDR JAP 2001-20053).
The project Terms of Reference of November 2004 (ToR) divided the project into three tasks:
> Task 1 ­ Review existing legislation, policies and voluntary commitments on the reduction
of phosphorus in laundry detergents across the EU and the Danube River Basin (DRB);
> Task 2 ­ Compile and evaluate data on phosphorus containing detergents across the DRB,
as well as associated production structures, in discussion with the Detergent Industry;
and
> Task 3 ­ Develop proposals for accomplishing a voluntary agreement between ICPDR /
contracting parties (DRB countries) and the Detergent Industry.
This report documents the approach and outcome of the project. It must be noted that, due to the
outcome of Tasks 1 and 2 (Sections 3 and 4 of this report), Task 3 no longer seemed highly
relevant, although it is addressed in Section 5 to provide background information relating to
voluntary agreements.
The overall findings are summarised below.
Table A summarises the available information on the use of phosphate-free laundry detergents in
the Danube River Basin (DRB) countries, including population figures (total and those in the DRB).
It has been difficult to obtain information and the information on the use of phosphate-free
detergents must be considered approximate.
In many cases the information is incomplete and problems with the definition of `phosphate-free'
and different approaches to product labeling have given rise to uncertainties. We have attempted
to use the definition of `phosphate-free' as <0.2% phosphate in line with the EU Regulation on
detergents (EC/648/2004) according to which a phosphate content of 0.2% or higher has to be
declared on the label. However, in some cases, the `phosphate-free' component may include `low
phosphate' products, e.g. up to 5% phosphate content. The Czech voluntary agreement, for
example, allowed up to about 2% phosphate in `phosphate-free' detergents. Another difficulty was
the contradictory information at times between product labels (as examined on supermarket
shelves) and manufacturers' information (e.g. Hungary); this could have been due to a variety of
factors, for example changes in product formulations or differences in products with the same
name but produced in different countries. Overall, large multinational detergent manufacturers
were not particularly co-operative but on near completion of the project, we managed to make
contact with an AISE representative for Central and Eastern European (CEE) countries, who is
interested in dialogue at least.

1 http://www.icpdr.org/icpdr-pages/dablas.htm
2 http://danubs.tuwien.ac.at/
3 http://www.icpdr.org/icpdr-pages/pub_programmes.htm
UNDP/GEF DANUBE REGIONAL PROJECT

Executive Summary
page 6
Table A
Detergent usage, populations & phosphate-free detergents by country
Percentage Country
Total laundry
Total
Total
detergent

detergent usage
population
population in
that is
(tonnes/year)
(million) 1
Danube Basin
phosphate-
(million) 2
free

Austria 55,197
8.1
7.7
>98%
Germany 643,000
82.0
9.1





Czech Republic

9.9
2.7
Hungary 126,300
10.3

10.3
>~50%
Slovenia

2.0
1.7

Serbia-Montenegro 3 89,057
9.3 9.1





Bosnia-Herzegovina 7,485
4.4
2.5
Bulgaria

7.9
4.4
<10%
Croatia 16,516
4.7
3.2

Moldova
4.3
1.1

Slovak Republic

5.4
5.2

Ukraine 219,873
49.1
3.1





Not known 4 Romania
154,584
22.4
21.8





Total


219.8 81.9
Notes:
1. Information from Whitaker's Almanack 2005
2. From Joint Action Programme, 2000-2005
3. Data for `phosphate-free' in Serbia-Montenegro may include low phosphate detergents (i.e. up to
5% phosphate)
4. Data for products indicates `no phosphate-free detergents' on the market in 2005

Nevertheless, the situation can be broadly summarized as follows.
Austria and Germany have virtually no phosphate containing laundry detergents and need not be
considered for further action. Austria has achieved this through a voluntary agreement, whilst
Germany has used a combination of legislative and voluntary measures with the full co-operation
of the detergent industry and involvement of the public.
Slovenia has a high proportion of phosphate-free laundry detergents (>75%). However, it seems
that there has been an increase in the use of phosphate detergents in recent years (it was virtually
phosphate-free in 2000), and it may still be rising. Consequently, whilst it should not receive
priority for action, the situation may need to be monitored.
The Czech Republic has recently replaced a voluntary agreement to reduce phosphorus in laundry
detergents, which was a partial success, with legislation; it will therefore not need to be considered
for further action either.
The above four countries together account for about 26% of the total population in the DRB.
Of the remaining countries, only Hungary and Serbia-Montenegro use significant proportions of
phosphate-free laundry detergents and together account for another 24% of the DRB population.
In both cases there are some uncertainties in the data, for example some conflicting information
from Hungary; moreover, the data for phosphate-free detergents in Serbia-Montenegro may
include `low phosphate' products (up to 5% phosphate) and, particularly in view of the significant
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 7
proportion of the DRB population, we recommend consideration of these countries for further
action.
The other seven countries use little or no phosphate-free detergents and make up about half the
DRB population; of these Romania is the most significant in terms of DRB population (about 27%
of total). No figure was given for phosphate-free detergents in Romania, although the available
product data (incomplete) indicated an absence of phosphate-free detergents.
To conclude therefore, the countries requiring reductions in phosphate-based detergents are as
follows (see Table B), together representing about three quarters (74%) of the DRB population:
Table B
Countries requiring action to reduce phosphate in detergents and
percentage of DRB population

DRB Country
Percentage of DRB population
Romania 26.6
Hungary 12.6
Serbia-Montenegro 11.1
Slovak Republic
6.4
Bulgaria 5.4
Croatia
3.9
Ukraine
3.8
Bosnia-Herzegovina
3.1
Moldova
1.3

Among these countries, Romania should receive priority because it currently has virtually no
phosphate-free detergents on the market and yet constitutes the biggest single contribution to the
DRB in terms of its population (almost 27%). In contrast, Hungary and Serbia-Montenegro already
have a significant proportion of P-free detergents (>50%) and will require lower priority. In
addition to the above countries, developments in Slovenia should be monitored.
Unilever in Romania has recently announced it will start producing phosphate-free detergents in
Romania. This could be a significant development, since Unilever is one of two major players in the
Romanian market (the other is Proctor & Gamble), although it seems to be aimed at automatic
washing machines only, probably representing a relatively small proportion of the total detergent
usage.
It is also worth noting that Moldova intends to legislate and to use a combination of subsidies, tax
incentives and public involvement to promote the use of phosphate-free detergents. More
information should be sought concerning the details and progress of these plans. However, it must
be noted that Moldova relies mainly on imports of detergents.
It was not possible to obtain any information on production costs of phosphate-free detergents,
because the industry was not prepared to reveal any such information. However, Zeolite A has
previously been shown to be a viable alternative to phosphate and is used successfully in many
countries, including the DRB countries, Germany and Austria. The main adverse effect of
abandoning the use of phosphates in detergents is expected to be on the phosphate industry, but
not on the detergent industry, which should be able to adjust detergent formulation and
production.
UNDP/GEF DANUBE REGIONAL PROJECT

Executive Summary
page 8
Similarly, the information gathered on costs to consumers was inadequate for a thorough statistical
assessment, but has not indicated any evidence of higher costs of phosphate-free detergents.
The Czech example has demonstrated the difficulties in maintaining a successful voluntary
agreement with the detergent industry without legislative back-up. In the Czech case, the
agreement was between government and the industry association, and the initial success was
eroded because of increasing sales of phosphate detergents by non-members of the association.
Similarly, it would be difficult to control imports or the emergence of other manufacturers/suppliers
outside any agreements. The latter has been experienced in Slovenia, where there is a trend
towards increasing use of phosphate detergents (although no voluntary agreement has been in
place, the market was virtually phosphate-free in 2000).
Few RBD countries outside the EU have experience with voluntary agreements, but they are
generally following EU legislation. Moreover, there is an indication that manufacturers prefer to
await legislation. For these reasons, EU legislation to ban or reduce phosphates in detergents
would be far more effective in dealing with the problem. In any case we already have the curious
situation, where several EU Member States have legislation to reduce or ban phosphates in
detergents, whereas others have not (legislation is in place in Germany, the Czech Republic, Italy
and the Netherlands; and soon to follow are Sweden and France; with voluntary agreements in
Austria and Ireland being effectively equivalent to `bans').
Current EU legislation (Regulation on detergents EC/648/2004, Article 16) requires the situation to
be reviewed by April 2007 and, if appropriate, a legislative proposal to be prepared to phase out or
restrict phosphates in detergents. To this end, a report (funded by the detergent phosphate
industry) has just been completed and should be published shortly by the Directorate General on
Enterprise and Industry, the EC Department with responsibility for the Regulation. Any
developments will need to be observed.
The above requirement provides a timely opportunity to review the situation and to harmonise it
across Europe by introducing a ban or restrictions on phosphate detergents across the Community.
Nevertheless, unless EU legislation can be expected in the near future, it may still be worth
attempting to negotiate voluntary agreements, since even a partial success could usefully
contribute to reductions in phosphate in the Danube river basin. Alternatively, and probably a more
promising option, would be to persuade DRB country governments of the need for national
legislation.
It may be beneficial to hold a workshop, for example in Romania, to inform stakeholders of the
situation and to explore a way forward.
In any case it will be important to liaise closely with the appropriate government department in
each country concerned and to maintain a dialogue with the industry and relevant trade
associations. In addition, it will be important to promote public debate and involvement, and to
monitor compliance with any agreements or legislation, possibly with assistance from NGOs.
Whilst it is recognised that other actions, such as improved urban waste water collection and
treatment, as well as `good agricultural practices' are necessary complementary actions, the study
has shown clearly that there is ample scope for contributing to a successful resolution of the
problem of eutrophication, by replacing phosphate detergents with phosphate-free detergents,
thereby reducing the total phosphate burden.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 9
1. INTRODUCTION

WRc plc has been appointed by the United Nations Office for Project Services (UNOPS) (Reference
00036337, RER/03/G31) to develop recommendations for the reduction of phosphorus in
detergents, which will be used as a basis for the negotiation of a voluntary agreement between the
International Commission for the Protection of the Danube River (ICPDR) signatory countries and
the Detergent Industry.
The project is part of the UNDP / GEF Danube Regional Project (DRP).
Objective 1 of the DRP is: the creation of sustainable ecological conditions for land use and water
management. This project contributes to output 1.8 of this objective, i.e. recommendations for the
reduction of phosphorus in detergents.
The objective of this project described in the Terms of Reference of November 2004 (ToR) can be
summarised as follows:
To develop proposals for the introduction of voluntary agreement schemes leading to a reduction in
the level of phosphates used in (laundry) detergents across the Danube River Basin.
The specific objectives as stated in the ToR are to:
> Assess the current use of phosphate builders in laundry detergents used within the
Danube River Basin; and
> To develop proposals for the introduction of voluntary agreements for phosphate
reduction to be negotiated by the ICPDR / contracting parties and the Detergent Industry.
The ToR divides the project into three tasks:
> Task 1 ­ Review existing legislation, policies and voluntary commitments on the reduction
of phosphorus in laundry detergents across the EU and the Danube River Basin (DRB);
> Task 2 ­ Compile and evaluate data on phosphorus containing detergents across the DRB,
as well as associated production structures, in discussion with the Detergent Industry;
and
> Task 3 ­ Develop proposals for accomplishing a voluntary agreement between ICPDR /
contracting parties (DRB countries) and the Detergent Industry.
The project is based on the previously established need to reduce phosphorus input to the Danube
and its tributaries.
Whilst the study focuses on domestic use of laundry detergents, reviews of current practice include
industrial and domestic laundry detergent uses, where data was readily available. A review of
production structures in all Danube River Basin (DRB) countries forms an important part of the
study.
The recommendations are based on experiences of DRB and other countries, in the context of
related developments (policy and legislative) at the European Union level and take account of the
institutional and economic capability of the DRB countries.
This final report documents the outcome of the study (Tasks 1-3). More detailed information is
provided in Annexes.

UNDP/GEF DANUBE REGIONAL PROJECT

The Danube River Basin
page 10
2. THE DANUBE RIVER BASIN
The Danube River, at 2 780 km length, is the second largest river in Europe draining an area in
excess of 800 000 km2. It flows through 18 countries including EU Member States, Accession
countries and other countries that have not applied for EU membership (ICPDR, 2005). The Danube
River discharges into the Black Sea.
The International Commission for the Protection of the Danube River (ICPDR) is the implementing
body under the "Convention on Co-operation for the Protection and Sustainable Use of the Danube
River" (Danube River Protection Convention, DRPC) and serves as the platform for co-ordination to
develop and establish the Danube River Basin Management Plan (DRBMP).
2.1. Countries in the Danube River Basin District
A total of 18 countries have territories in the Danube River Basin District (see Table 1).
Table 1
Countries in the Danube River Basin District
Country
ISO-Code
Status in the EU
Albania AL
-
Austria AT
Member
State
Bosnia ­ Herzegovina
BA
-
Bulgaria BG
Accession
Country
Croatia
HR
Applied to become an
Accession Country
Czech Republic
CZ
Member State
Germany DE
Member
State
Hungary
HU
Member State
Italy IT
Member
State
Macedonia
MK
-
Moldova MD
-
Poland PL
Member
States
Romania RO
Accession
Country
Serbia and Montenegro
CS
-
Slovak Republic
SK
Member State
Slovenia SI
Member
State
Switzerland CH
-
Ukraine UA
-


WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 11
European Union Member States include Austria, Germany and Italy, joined by five further countries
on 1 May 2004, i.e. the Czech Republic, Hungary, Poland, Slovak Republic and Slovenia.
Three other Danube countries are in the process of accession or under application. Bulgaria and
Romania will join the EU in 2007. Croatia has applied to become an Accession Country in April
2004, but negotiations have not started.
Seven countries currently are not members of the EU and have not to date initiated a formal
process to join. These are: Albania, Bosnia-Herzegovina, Macedonia, Moldova, Serbia and
Montenegro, Ukraine and Switzerland.
The territory of Hungary is totally within the Danube river basin. The rest of the basin comprises
nearly all parts of Austria, Romania, Slovenia, Slovakia, and Serbia and Montenegro, significant
parts of Bosnia­Herzegovina, Bulgaria, Croatia, Czech Republic and Moldova and small parts of
Germany and Ukraine.
Countries sharing less than 2000 km˛ of the Danube river basin are (in descending order by size)
Switzerland, Italy, Poland, Albania and Macedonia and are therefore excluded from this study.
Therefore, 13 countries are included in the study as the principle Danube River Basin (DRB)
countries:
> Austria
> Bosnia-Herzegovina
> Bulgaria
> Croatia
> Czech Republic
> Germany
> Hungary
> Moldova
> Romania
> Serbia-Montenegro
> Slovakia
> Slovenia
> Ukraine

UNDP/GEF DANUBE REGIONAL PROJECT

The Danube River Basin
page 12
2.2. The need to reduce phosphorus emissions in the Danube
River Basin
The need to reduce phosphorus emissions in the Danube River Basin has already been established
and is not the subject of this report.
Identified by the European Environment Agency (EEA) as a major environmental problem across
Europe (EEA, 2005), eutrophication is the excessive enrichment of waters with nutrients (nitrogen
and phosphorus ­ N and P) and subsequent adverse ecological consequences. The presence of
nutrients in the Danube Basin has led to severe ecological problems: the deterioration of
groundwater resources and the eutrophication of rivers, lakes and especially the Black Sea
(daNUbs, 2005).
Other projects, which have clearly shown the need for phosphate input reduction in the DRB
include the DABLAS project (ICPDR DABLAS, 2004) and targets for phosphorus input reductions
are included in the ICPDR Joint Action Programme (ICPDR JAP, 2001-2005).
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 13
3. TASK 1 - REVIEW EXISTING LEGISLATION,
POLICIES AND VOLUNTARY COMMITMENTS ON THE
REDUCTION OF PHOSPHORUS IN LAUNDRY
DETERGENTS ACROSS THE EU AND DRB

3.1. Mechanisms for the reduction of detergent phosphates
The main mechanisms for significantly reducing phosphate entry into waters of the Danube river
basin (DRB) have been described as follows (Popovici, 2003):
1.
Reduce the amount of sodium tripolyphosphate (STPP) used in detergent builders and
switch to "alternative" non-phosphate-based builders, such as Zeolite A;
2.
Improve wastewater treatment through implementation of the Urban Wastewater
Treatment Directive (UWWTD).
Legal bans on phosphate in detergents are in place in Germany, Italy (ban 1989), the Netherlands,
Switzerland (ban 1986), Japan (ban limited to areas containing sensitive lakes but in effect no
STPP-based detergents sold in Japan), Canada (ban 1973) and the USA (different dates in different
states from the 1970s onwards) (Glennie, et al., 2004). The Czech Republic has recently
introduced legislation because of failure of a voluntary agreement (see details in Section 3.3.1 ­
Case Studies). Moreover, the Swedish Government has just announced that it intends to legislate
to provide for a national ban on the use of phosphates in laundry detergents and other cleaning
agents. The move is in line with the recommendations of an earlier report by a panel of
international experts on measures to counter eutrophication in the Baltic Sea (ENDS Europe Daily,
2006). In addition, France intends to ban phosphates in detergents in the near future (2007)
(ENDS Europe Daily, 2006a).
There are several voluntary agreements between governments and industry to limit the use of
phosphates in detergents by the detergent industry. In some countries, such as Germany, Austria,
and more recently Ireland, the voluntary agreement is in effect equivalent to a "ban" of phosphates
in household laundry detergents.
The WRc study (Glennie et al., 2002) to address the current use of phosphates in detergents
throughout the EU recommends measures to reduce phosphorus concentrations in surface waters
below levels that cause eutrophication, through either improving wastewater treatment, banning
the use of phosphates as detergent builders, or a combination of the two approaches. The study
suggests that banning phosphorus from household detergents can achieve a phosphorus load
reduction of up to 40% entering surface water bodies, which is substantial but not sufficient in
isolation to result in any significant improvement. Furthermore, improvements in wastewater
treatment to fully comply with the Urban Waste Water Treatment Directive (UWWTD) (Council
Directive 91/271/EEC) would only result in typical phosphorus reductions of around 30%. This is
because centres with less than 10 000 residents would not be required to eliminate phosphorus
from their wastewater. As demonstrated by Switzerland, the USA and Italy, the greatest
improvements in lakes and rivers were observed where a combination of reduced detergent
phosphorus and improved wastewater treatment were implemented, thereby achieving the
required 70-90% reduction in external load.


UNDP/GEF DANUBE REGIONAL PROJECT

Task 1 - Review existing legislation, policies and voluntary commitments
page 14
3.2. EU and international legislation and agreements restricting
the use of phosphates in detergents
3.2.1. Overview of EU and other international legislation relevant to DRB
countries
UNEP Global Plan of Action
Danube River Protection Convention (DRPC)
The Danube River Protection Convention (DRPC) is a legally binding instrument, which provides a
substantial framework and a legal basis for co-operation between the contracting parties, including
enforcement. It came into force in October 1998. The main objective is the protection and
sustainable use of groundwater and surface waters and ecological resources, directed at basin-wide
and sub-basin-wide co-operation with trans-boundary relevance. Joint activities and actions are
focused on co-ordination and enhancement of policies and strategies, while the implementation of
measures lies mainly with the executive tools at the national level. The Strategic Action Plan
provides guidance concerning policies and strategies in developing and supporting the
implementation measures for pollution reduction and sustainable management of water resources,
enhancing the enforcement of the Danube River Protection Convention.
The Danube River Protection Convention has been ratified by all of the 13 DRB countries eligible to
join it, along with the European Commission.
International Commission for the Protection of the Danube River (ICPDR)
The Danube Countries established the International Commission for the Protection of the Danube
River (ICPDR) to strengthen co-operation and to respond to the obligations of the Danube River
Protection Convention. The Commission has created several Expert Groups to strengthen the
proactive participation of all Contracting Parties and associated countries in the design and
implementation of joint measures for pollution reduction, including nutrients and water
management.
Black Sea Convention
Co-operation between the ICPDR and the International Commission for the Protection of
the Black SEA (ICPBS) ­ Joint Ad-hoc Technical Working Group of the ICPDR and the
ICPBS

In 1998, the ICPDR and the ICPBS established a joint Working Group, which analysed the causes
and the effects of eutrophication in the Black Sea. In its findings, the Working Group indicated that
the loads entering the Black Sea from the Danube had fallen in recent years due to the collapse of
the economy of many transitional countries formally attached to the Soviet Block, the measures
undertaken to reduce nutrient discharges in the upper Danube countries, in particular Germany
and Austria, and a decline in the use of phosphate in detergent.
The Working Group concluded that in spite of the evidence of recovery in the Black Sea
ecosystems, there were still concerns that the nutrient discharges to the Black Sea, in line with the
expected economic growth, were likely to rise again unless action was taken to implement nutrient
discharge control measures as part of economic development strategies.
The Working Group went on to define the possible objectives and strategies, which are included in
the Memorandum of Understanding between the ICPDR and the ICPBS, as follows:
> The long-term goal is defined as a recovery of the Black Sea ecosystem to conditions
similar to those in the 1960s;
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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 15
> As a mid-term goal, measures should be taken to prevent discharges of nutrients and
hazardous substances from exceeding the levels of 1997; and
> Inputs of nutrients and hazardous substances should be assessed, monitored and
sampling procedures should be determined, and the results reported.
Detergent Eco-label Schemes
There are two principal pan-European schemes aimed at minimising the effect of detergents upon
the environment:
> Eco-label and
> Nordic White Swan.
The aims of both are similar and encompass encouraging business to market `greener' products.
The twin goals of the schemes are to provide producers with the necessary information to take
advantages of this strategy, and to enable consumers to make informed decisions regarding the
environmental impact of products.
Only products that satisfy strict environmental requirements on the basis of objective assessments
are allowed to display either of the labels.
The Nordic environmental label is a neutral, independent label, which guarantees a certain
environmental standard and works in close co-operation with the eco-label scheme. It is run
through the competent bodies as nominated by the members, Sweden, Finland, Denmark, Iceland
and Norway.
The label helps consumers to identify the products that cause the least damage to the environment
amongst those in the market. As a result, manufacturers are stimulated to develop products and
production processes, which are better for the environment.
The Nordic Swan criteria for `all purpose cleaners' allow:
·
0.2 g P (phosphorus) per recommended dose per litre (this means per litre after
dilution according to manufacturer's recommendation)
The Nordic Swan criteria for `sanitary' cleaners allow:
·
0.2 g P (phosphorus) per 100g of product.
The EU Eco-label scheme, laid down in Council Regulation EC/1980/2000, was established in
1992 to promote products and services with a reduced environmental impact. Manufacturers
meeting the environmental criteria established for a product group can obtain the Eco-label and
display the Flower logo on their products. At the European level the Scheme is run by the EU Eco-
labelling Board (EUEB). Each EU Member State has a competent authority, which helps companies
that want to obtain the Flower logo by providing information on how to apply, and checking
compliance. Applicants must provide a detailed dossier showing how the technical criteria have
been met.
The European Union's Eco-label scheme for laundry detergents (Council Decision 2003/200/EC)
allows:
·
25 g STPP within a maximum of 100 g total chemicals per wash = 25% STPP
·
less than or equal to 0.5 g phosphonates that are not readily biodegradable
(aerobically) per wash
A `wash' refers to the dosage per 4.5 kg load (dry textiles) for heavy-duty detergents and per 2.5
kg load (dry textiles) for low-duty detergents in the washing machine.
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Task 1 - Review existing legislation, policies and voluntary commitments
page 16
The European Union's Eco-label scheme for dishwasher detergents (Council Decision
2003/31/EC) allows:
·
less than or equal to 10 g STPP within a maximum of 22.5 g total chemicals per wash =
44% STPP
·
less than or equal to 0.2 g phosphonates that are not readily biodegradable
(aerobically) per wash
A `wash' refers to the quantity of product required to wash 12 place settings with a standard level
of soilage.
The European Union's Eco-label scheme for all purpose cleaners and cleaners for sanitary
facilities
(Council Decision 2005/344/EC) allow total quantity of elemental phosphorus (P),
calculated per functional unit (for all-purpose cleaners) or per 100g of product (cleaners for
sanitary facilities) taking into account all ingredients containing phosphorus, (e.g. phosphates and
phosphonates):
·
All-purpose cleaners: P < 0.02 g per functional unit;
·
Cleaners for sanitary facilities: P < 1.0g per 100g of product; and
· Window cleaners: no phosphorus.
For all-purpose cleaners the functional unit (used in the criteria above) is the dosage in grams of
the product recommended by the manufacturer for one litre of suds (washing water).
The European Union's Eco-label scheme for hand dishwashing detergents (Council Decision
2005/342/EC) details how to calculate the critical dilution volume toxicity (CDVtox) for each
ingredient. The CDVtox of the recommended dose expressed for one litre of dishwashing water shall
not exceed 4200 l.
The current eco-label criteria also promote consumer information about `dosage' and `low
temperature washing' only. Thus it is suggested that further use instructions are added to reduce
environmental impact, these include:
> Pre-sort laundry (by colour, degree of soiling, type of fibres);
> Treat specific soilage (ink, fruit, etc.) prior to wash;
> Wash with full loads;
> Avoid pre-washing;
> Avoid overdosing; and
> Prefer low temperature washing cycles.
The Nordic environmental label is the official eco-label in Norway, Sweden, Denmark, Finland and
Iceland.
Detergent Directives (European Union)
The Commission Recommendation (98/480/EC) concerning good environmental practice for
household laundry detergents
sets the target that all poorly biodegradable organic ingredients
(PBO) in household laundry detergents should be decreased by 10% by 2002 compared with 1996
in the EU15. Other targets concern energy, weight of detergent and packaging.
In order to monitor progress of this Recommendation, statistics are requested on the total
consumption of poorly biodegradable organic ingredients4 (in tonnes per year) associated with

4 Poorly biodegradable organic ingredients are those which fail to biodegrade by more than 70 % in SCAS or
Zahn Wellens biodegradability test as defined under C.12. and C.9. of Annex V to Directive 67/548/EEC as
amended by Directive 92/32/EEC.
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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 17
detergent consumption (solid and liquid) for each calendar year. Consumption means the tonnes of
poorly biodegradable organics in detergents sold on each national market.
AISE5 committed itself to undertake initiatives to achieve the targets set in the Recommendation
and in 1996 developed a Code of Good Environmental Practice for the Household Laundry
Detergents for implementation in 18 countries: the EU15 plus Iceland, Norway and Switzerland.
Implementation of the Code started in Denmark and Sweden in autumn 1997 as a pilot project.
Following the positive results obtained from this pilot project, and the endorsement by the
European Commission, implementation in the other participating countries started in mid-1998 /
early 1999 and has continued since.
Commitments and targets in the AISE Code are based on risk assessment and life cycle analysis.
Under the Code, manufacturers agree to provide consumers with relevant usage instructions to
guide them on how to do their laundry in an environmentally responsible manner.
AISE and some non-AISE members that sell, market or produce household laundry detergents
within the European Community and the European Economic Area therefore committed themselves
to ensure compliance with this Recommendation, in co-operation with National Associations, and to
report progress towards the targets for consumption, packaging and poorly biodegradable
ingredients in detergents at least every two years, and to report on the energy consumption at the
end of a five-year period.
The Commission's report on the implementation of the Recommendation (COM(2004)134) states
that the target to reduce all poorly biodegradable organic ingredients in household laundry
detergents by 10% by 2002 compared with 1996 in the EU15 was achieved, in fact exceeded. The
reduction reported is ­13.1% between 1996 and 1998; ­14.5% between 1996 and 2000; and ­
23.7% between 1996 and 2001. Looking at the EU15 Member States individually (see Table 2), the
recorded reduction was greatest in Italy (-39.0%), Austria (-38.5%) and the Netherlands (-34.4
%), whilst there was an increase recorded in Greece and Ireland (both 10.2%).
Table 2
Change in consumption of poorly biodegradable organic (PBO) ingredients
in household laundry detergents between 1996 and 2001 in the 15 EU Member States
(taken from COM(2004)134)

EU Member State
Change in per capita PBO consumption
Austria
- 38.5 %
Belgium
- 26.1 %
Denmark
- 25.7 %
Finland
- 1.7 %
France
- 14.9 %
Germany
- 25.6 %
Greece
+ 10.2 %
Ireland
+ 10.2 %
Italy
- 39.0 %
Luxembourg
- 26.1 %
Portugal
- 19.4 %
Spain
- 23.9 %

5 AISE (Association internationale de la savonnerie, de la détergence et des produits d'entretien) is the official
body that represents the soap, detergent and maintenance products industry within Europe and towards other
international organisations. AISE's members and its National Associations are present in 28 countries (in Europe
essentially). Their members are companies locally placing products of the above categories on the market. AISE
represents over 90 % of the detergent and cleaning product industries in the Community.
UNDP/GEF DANUBE REGIONAL PROJECT

Task 1 - Review existing legislation, policies and voluntary commitments
page 18
EU Member State
Change in per capita PBO consumption
Sweden
- 25.6 %
The Netherlands
- 34.4 %
UK
- 4.6 %
EU15 -23.7
%

Council and European Parliament Regulation EC/648/2004 on detergents, which entered into
force on 8 October 2005, replaces the five Directives and the Commission Recommendation listed
below in order to bring all EU measures on detergents under a single text.
·
Council Directive 73/404/EEC on the approximation of the laws of the Member States
relating to detergents, Official Journal L347, 17 December 1973
·
Council Directive 73/405/EEC on the approximation of the laws of the Member States
relating to methods of testing the biodegradability of anionic surfactants, Official Journal
L347, 17 December 1973
·
Council Directive 82/242/EEC on the approximation of the laws of the Member States
relating to methods of testing the biodegradability of non-ionic surfactants and amending
Directive 73/404/EEC, Official Journal L109, 22 April 1982
·
Council Directive 82/243/EEC amending Directive 73/405/EEC on the approximation of the
laws of the Member States relating to methods of testing the biodegradability of anionic
surfactants, Official Journal L109, 22 April 1982
·
Council Directive 86/94/EEC amending for the second time Directive 73/404/EEC on the
approximation of the laws of the Member States relating to detergents, Official Journal
L80, 25 March 1986.
·
Commission Recommendation 89/542/EEC for the labelling of detergents and cleaning
products, Official Journal L291, 10 December 1989
The new Regulation on detergents (EC/648/2004) is primarily concerned with the aerobic
biodegradability of surfactants within detergents. Limits for biodegradability are stipulated in the
Regulation's Annex which must be adhered to for a detergent to be placed on the market.
The only other reference to phosphates is that, if present in a concentration above 0.2% by weight,
it needs to be listed as an ingredient on the packaging label. Weight percentage ranges as detailed
in Annex VII are to be used, i.e.
·
less than 5%
·
5% or over and less than 15%
·
15% or over and less than 30%
·
30% or more.
A list of ingredients is set out, including phosphates and phosphonates, which have to be declared
in the above concentration ranges if their content is 0.2% or more by weight. Some other
ingredients are listed, which require declaration irrespective of their content.
However, Article 16 - Review, states:
"By 8 April 2007, the Commission shall evaluate, submit a report on and, where justified,
present a legislative proposal on the use of phosphates with a view to their gradual
phase-out or restriction to specific applications".

The Regulation on detergents (EC/648/2004) is within the scope of responsibilities of Directorate
General Enterprise and Industry (Unit G.2), which has `commissioned' the review required under
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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 19
Article 16. The study is funded by CEEP (European Detergent Phosphate Industry ­ Joint Research
Association), a Cefic Sector Group, and being conducted by the Laboratory for Ecotoxicology at the
Spanish Department of Environment, National Institute for Agriculture and Food Research and
Technology (INIA) in co-operation with Green Planet Environmental Consulting S.L. (also in Spain).
The interim report of September 2005 and the final report of October 2006 have been obtained
(Madariaga, et al. 2005 and 2006) from DG Enterprise.
It is outside the scope of this project to assess the above review. However, it is worth noting that
the main focus of the work is on developing and validating a model for risk assessment, concerning
phosphorus inputs from different sources, including detergents, into European rivers and the
associated risk of eutrophication. The risk assessment seems to be based on the fact that a
considerable proportion of the EU population is already using phosphate-free detergents.
Other EU Directives
Urban Wastewater Treatment Directive (UWWTD)
The main aim of the UWWTD (Council Directive 91/271/EEC) was to ensure the treatment of
significant discharges of sewage before discharge, either to inland surface waters, groundwaters,
estuaries or coastal waters. Sewage is normally treated to secondary treatment standards,
although discharges into `Sensitive Areas' require higher standards of treatment (removal of
phosphates and/or nitrate at wastewater treatment plants above 10 000 population equivalents
(p.e.) in the catchment of a designated sensitive area) due to eutrophication of receiving waters or
a potential for eutrophication, if preventive measures are not taken.
Dates were set for the implementation of the requirements of the Directive, i.e. secondary
treatment for discharges above 15 000 p.e. (population equivalents) to be provided by
31 December 2000; and discharges between 2 000 and 15 000 p.e. into estuaries and between 10
000 and 15 000 p.e. into coastal waters must receive secondary treatment by 2005. Smaller
discharges must also receive appropriate treatment by 2005.
Water Framework Directive (WFD)
The WFD (Council Directive 2000/60/EC) was adopted in December 2000. It requires Member
States to adopt an integrated system of water management covering surface and ground waters
and to achieve "good ecological status" in all waters by 2015. The Directive requires integrated
river basin management to be achieved through river basin districts, which had to be identified by
December 2003. An initial characterisation of all water bodies within each river basin district and
an assessment of the pressures and impacts on those water bodies should have been completed by
December 2004. Following this, Member States must develop monitoring programmes, river basin
management plans and programmes of measures to ensure the achievement of good ecological
status by 2015.
The Directive also requires the Commission to identify priority substances and priority hazardous
substances. For priority substances, discharges, emissions and losses must be reduced whilst for
priority hazardous substances they must be eliminated. Substances contributing to eutrophication
(particularly phosphates and nitrate) are listed as being among the main pollutants, under Annex
VIII of the Directive.
Decision 2455/2001/EC has been adopted, identifying 33 priority and priority hazardous
substances, and will be referred to as Annex X, in Directive 2000/60/EEC. The Commission is
currently developing a proposal for a daughter Directive to the WFD, which will specify
Environmental Quality Standards (EQS) and emission controls for these substances.
UNDP/GEF DANUBE REGIONAL PROJECT

Task 1 - Review existing legislation, policies and voluntary commitments
page 20
EU legislation implementation report
The European Commission has published its sixth annual survey on the implementation and
enforcement of community environmental law, covering 2004 (European Commission, 2005). The
surveys provide information on the state of application of Community environmental law.

Proposed EU measures
REACH - Registration, Evaluation and Authorisation of Chemicals
The European Commission adopted a proposal for a new EU regulatory framework for chemicals
(COM(2003)644) on 29 October 2003.
Under the proposed new system, enterprises that manufacture or import more than one tonne of a
chemical substance per year would be required to register it in a central database. The aims of the
proposed new Regulation are to improve the protection of human health and the environment while
maintaining the competitiveness and enhancing the innovative capability of the EU chemicals
industry. REACH would furthermore give greater responsibility to industry to manage the risks from
chemicals and to provide safety information on the substances. This information would be passed
down the chain of production. The proposal has been drafted in close consultation with all
interested parties, including an internet consultation. This has allowed the Commission to propose
a streamlined and cost-effective system. The proposal is now being considered by the European
Parliament and the Council of the EU for adoption under the co-decision procedure.
3.2.2. EU voluntary agreements
The Commission Recommendation concerning good environmental practice for household laundry
detergents (98/480/EC) recommended for the first time at Community level "Environmental
Agreements" as a tool for industry to implement the actions envisaged in the Recommendation. It
takes into account the Council and European Parliament Resolutions of 17 July 1997 and 7 October
1997 on Environmental Agreements, which recognise that voluntary agreements may be a valuable
instrument to make optimum use of industry's own responsibilities (Council and European
Parliament Resolutions, 1997 and 1997a).
The effectiveness of voluntary agreements has been criticised by the European Consumers'
Association, BEUC, in a call to strengthen voluntary agreement rules (ENDS Europe Daily, 2006b).
BEUC maintained that voluntary agreements failed to deliver environmental improvements and
often simply allowed industry to avoid significant behavioural changes. Quoted shortcomings
included low participation rates, leading to free-rider problems, and lack of analysis of impact,
scope, outcomes and effectiveness. Recommendations for strengthening agreements included the
imposition of large fines against individual companies where targets were not met.
3.2.3. Other measures for limiting phosphates in detergents
WashRight campaign
The WashRight campaign, an initiative of AISE (Association internationale de la savonnerie, de la
détergence et des produits d'entretien), was launched in 1998. It presents information to
consumers in a uniform format across the EU on detergent correct dosage and washing
temperature. The information itself is tailored to the existing usage habits in each country. The
campaign actions include television advertising, a dedicated website (http://www.washright.com)
and reminder panels on packaging.
The effectiveness of the campaign towards achieving the goals set in the Recommendation
concerning good environmental practice for household detergents (98/480/EC) cannot be
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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 21
quantified because the impact of information on consumer behaviour is intrinsically difficult to
evaluate.
3.3. Overview of existing and planned legislation, policies and
voluntary agreements in DRB countries
A questionnaire was sent to representatives of DRB countries and the information received,
together with soe additional information is summarised below. More detailed summaries are
provided in Annex 1 (Tables summarising country information) and a copy of the questionnaire
template is included in Annex 2.
The information provided was very limited. In general terms it shows that the appropriate EU
legislation (Directive 73/404/EEC, Recommendations 89/542/EEC and 98/480/EEC, and Regulation
648/2004/EC all relating to detergents; the Urban Waste Water Treatment Directive - UWWT -
91/271/EEC; and the Water Framework Directive - WFD - 2000/60/EC) has been transposed in the
Member States, and in part also by the accession countries and other Danube countries, although
in some cases with considerable transition periods. For example in the case of the UWWT, Bulgaria
has a transition period until 2015.
However, it is worth noting that, even once the UWWT Directive, for example, is fully implemented,
this will not result in total phosphate removal, as phosphorus and/or nitrogen removal will only be
required in designated sensitive areas and their catchments at wastewater treatment plants
> 10 000 p.e. (or an overall reduction of 75% nutrient input), whilst smaller plants and
unconnected effluents will continue to contribute phosphorus to receiving waters.
Germany has succeeded in achieving completely phosphate-free laundry detergent use through a
combination of legislation and voluntary agreements, to a large extent industry led and encouraged
by public debate.
Voluntary agreements concerning the reduction of phosphates in detergents have been used in two
Danube countries, Austria where it is still in operation and considered very successful, and the
Czech Republic, where it was a partial success but has now been replaced with legislation (see
Error! Reference source not found.).
No other Danube countries have legislation or voluntary agreements to reduce P in detergents,
although Bulgaria has a national Eco-labelling scheme as well as voluntary participation in the EU
eco-management and audit scheme (EMAS). This at least could form a basis on which to build
other voluntary agreements. The Czech Republic also has a voluntary agreement to reduce the
environmental burden of mercury from dental health care practices (Error! Reference source not
found.).
The experiences of Germany, Austria and the Czech Republic are described briefly in
Section 3.3.1.
3.3.1. Brief case studies
Three brief case studies are included below: Germany where phosphate-free laundry detergents
are exclusively in use; Austria, which appears to have been successful in implementing a voluntary
agreement, and the Czech Republic, where partial success was achieved, but legislation has now
replaced it.
Germany
In Germany phosphorus was defended initially on the grounds that substitutes would be more
expensive than alternative ways of reducing phosphorus discharges, such as better treatment of
UNDP/GEF DANUBE REGIONAL PROJECT

Task 1 - Review existing legislation, policies and voluntary commitments
page 22
wastewater. In 1972 Henkel argued that the cost of introducing increased sewage treatment (2.50
DM/capita/year) would be far less to the consumer than changing the composition of detergents. A
joint research programme between Henkel (who had held the patent for zeolite since 1973) and
the German government resulted in production of zeolite being advocated on economic grounds,
almost a decade later.
This research led to the regulation of phosphate content of detergents by the "Phosphate-
Höchstmengenverordnung", which stipulates maximum concentrations, and which entered in to
force on 1 January 1984. The maximum permitted concentration of phosphates in detergents was
reduced by 50%. Following the regulation there was a decline in the consumption of STTP (sodium
tripolyphosphate), from 185 900 tonnes in 1984 to 13 000 tonnes in 1990, and none in 1998.
The significance of this legislation must also be viewed in a wider context. Other factors in
explaining the reduction include voluntary agreements. The use of phosphate-free detergents was
an industry led development, encouraged by public debate on the eutrophication of the aquatic
environment. Since 1986 consumers have generally decided in favour of phosphate-free products
and since then there have been virtually no phosphates in detergents in Germany. (Glennie et al.,
2002; UBA, 2004).
Table 3
Voluntary agreements: information from the questionnaire - Relating to P
reduction in detergents
Country Name
Type
(e.g. Details of agreement
Is the
If an existing agreement, please
voluntary
(i.e. who is the
agreement provide a brief overview of its
agreement, agreement between,
existing or success/failure, with reasons.
eco-labelling, what does it address
planned.
incentive
etc). See note 1.
Please give
scheme)
dates (note
2)

Austria Freiwillige Notice of
Detergent Producing
Existing Successful
Verzichtserkl abandonment Industry, not to use P in
ärung
(voluntary
household laundry
Waschmittel agreement), detergents
Eco-labelling
Czech
Agreement
Voluntary
Goal of the Agreement and Existing.
Decrease of phosphates in laundry
Republic
between the agreement
its amendment was a
Agreement
detergents from 9 000 t in 1995 to
Czech
gradual decrease in the
was
5 065 t in 2003 was the result of
Association
amount of phosphates and concluded in the Agreement. The member
of producers
other substances in water. 1995 and its companies of the Association
of Soaps,
Since 1st January 2005
amendments offered on the market compact,
Cleaning
the Association has placed in 1998 and phosphate-free, as well as
Agents and
on the market only
2001.
phosphate containing detergents. In
Detergents
phosphate-free washing
the year 2003 36.6% of the overall
(CSDPA) and
powders. Full text of
amount of detergents produced by
the Ministry
Agreement on the Ministry
the Association members sold were
of the
of the Environment
phosphate-free laundry detergents.
Environment
website
Since the 1st of January 2005
on gradual
www.env.cz/AIS/web.nsf/
members of Association do not sell
decrease in
pages/voda_ochrana (in
laundry detergents containing
environment
Czech only) (English
phosphates. From this point of view
al impact of
version see Annex 3).
the goal of the Agreement has been
detergents
met (but see comment in case
study - Section 3.3.1).

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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 23
Table 4
Voluntary agreements: information from the questionnaire - Relating to
other environmental issues
Country Name
Type (e.g.
Details of agreement Is the
If an existing
voluntary
(i.e. who is the
agreement
agreement, please
agreement,
agreement between, existing or
provide a brief
eco-labelling, what does it address planned.
overview of its
incentive
etc). See note 1.
Please give
success/failure, with
scheme)
dates (note 2) reasons.
Bulgaria National
Eco-
Voluntary
Agreement between
labelling Scheme scheme
competent authority
in accordance with awarding an
and manufacturers.
Regulation (EC)
attractive eco-
Products that meet
No 1980/2000 of label logo for
strict ecological and
the European
products, which performance criteria
Parliament and of are generally a are awarded with the
the Council of 17 better choice for ecolabel.
July 2000 on a
the
revised
environment.
Community Eco-
label Award
Scheme


Bulgaria National
Eco-
Voluntary
The agreement
environment
scheme
between competent
Auditing Scheme
authority and
in accordance with
organisation which has
Regulation (EC)
an impact on the
No 761/2001 of
environment. National
the European
Eco-environment
Parliament and of
Auditing Scheme
the Council of 19
certified organisations
March 2001
have committed
allowing voluntary
themselves to
participation by
evaluating and
organisations in a
improving their
Community eco-
environmental
management and
performance and
audit scheme
providing relevant
(EMAS)
information to the
public.


Czech
Voluntary
Voluntary
Full text of Voluntary
Existing. Signed From 2005 all dental
Republic agreement
agreement
Agreement on the
in December
workplaces are fitted with
between the
Ministry of the
2001
effective amalgam
ministry of the
Environment website
separators. This
Environment and
www.env.cz/AIS/web.n
eliminates the discharge
the Czech Dental
sf/pages/voda_ochrana
of mercury into the sewer
Chamber on
(in Czech only).
systems and prevents
reducing the
contamination of
environmental
treatment plant sludge.
burden caused by
mercury from
dental health care
facilities.

UNDP/GEF DANUBE REGIONAL PROJECT

Task 1 - Review existing legislation, policies and voluntary commitments
page 24
Austria
A voluntary agreement (Freiwillige Verzichtserklärung Waschmittel) in Austria appears to have
been very successful and further action is not considered necessary. The agreement was entered
into between the Austrian authorities and the detergent producing industry; it specified not to use
phosphates in household laundry detergents. Unfortunately we have been unable to obtain further
details but we understand that virtually all household laundry detergents used in Austria are now
phosphate-free (information from questionnaire).

Czech Republic
An environmental voluntary agreement on Washing Powders in the Czech Republic (CAVA Working
Paper no. 99/10/11) proved a partial success, but legislation is now being introduced to achieve
further improvements. A summary of the Czech experience is provided below.
A voluntary agreement on the gradual decrease in environmental impact of detergents was
concluded in 1995 between the Czech Association of producers of Soaps, Cleaning Agents and
Detergents CSDPA) and the Ministry of the Environment; amendments were accepted in 1998 and
2001.
The goal of the Agreement and its amendments was a gradual decrease in the amount of
phosphates and other substances in water. Since 1st January 2005 the Association has placed on
the market only phosphate-free washing powders (full text of Agreement on the Ministry of the
Environment website www.env.cz/AIS/web.nsf/pages/voda_ochrana - in Czech; an English
translation is provided in Annex 3).
A decrease of phosphates in laundry detergents from 9 000 tonnes in 1995 to 5 065 tonnes in
2003 was the result of the Agreement. The member companies of the Association offered on the
market compact, phosphate-free as well as phosphate containing detergents. In the year 2003
36.6% of the overall amount of detergents produced by the Association members were phosphate-
free. Since 1st of January 2005 members of the Association no longer sell laundry detergents
containing phosphates. From this point of view the goal of the Agreement has been met.
However, since the year 2000 an increase in the number of phosphate containing detergents from
producers other than Association members has been observed. For example, the company SETUZA
left the Association in 2003. The share of non-member producers on the market is not negligible at
present as it was at the time of signing the Agreement (see Figure 1). In the year 2004 their share
was estimated at about 40%, and in the year 2005 at 50% of all producers.
For this reason, and with the aim to further reduce the impact of laundry detergents on waters in
the Czech Republic, it has been decided to control the content of the phosphorus in detergents
through the Amendment of the Ministry of Environment Regulation No. 221/2004 Coll., stipulating
the list of dangerous substances, whose introduction into the market, distribution or use are
prohibited or limited. This measure is in line with the Regulation EC/684/2004 of the European
Parliament and the Council of 31 March 2004 on detergents, Art. 14. Nevertheless, the measure
does not cover the whole category of detergents in the sense of Regulation EC/684/2004, but only
laundry detergents. It seems difficult to modify the whole spectrum of detergents to phosphate-
free detergents because of missing technologies. Hence, even after the approval of the above-
mentioned Amendment to the Ministry of Environment Regulation, it will be possible to produce
industrial cleaning and dish washing agents with phosphorus, but it will not be possible to produce
laundry detergents with a phosphorus content of more than 0.5% by weight.


WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 25

Balance of phosphates released from laundry
detergents sold by Association in the CZ
14000
11600
12000
10000
9000 7850 7650
8000
6737 6295 6175 6144 5312
t/year
6000
5065
4000
2000
0
1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Oveall use of phosphates (t/year)

Figure 1
Phosphate-free detergents in the Czech Republic (source: Doubravka
Nedvedova, Ministry of Environment, Czech Republic)

UNDP/GEF DANUBE REGIONAL PROJECT

Task 1 - Review existing legislation, policies and voluntary commitments
page 26
The above information for the Czech Republic was provided by Doubravka Nedvedova of the Czech
Ministry of Environment, through the questionnaire and attachments supplied.

3.3.2. Advantages, limitations and costs involved in implementation of
voluntary agreements in DRB countries
Most of the RBD countries do not at present use voluntary agreements as a tool of co-regulation.
Some have reported on obstacles/difficulties to implementing voluntary agreements. These
include:
·
Poor economic status of the country and, consequently, the main priorities focus on
economic development, rather than environmental protection;
·
Current legislation does not promote voluntary commitments;
·
Institutional constraints and inadequate financial resources to implementing such
agreements;
·
Lack of knowledge and understanding of such instruments among producers and
governmental bodies;
·
Lack of encouraging incentives from relevant governmental institutions; and
·
Industry is waiting for EU action on the phosphate situation.
Possible measures to promote the feasibility of voluntary agreements have been proposed by RBD
countries, as follows:
·
Establishing national institutions responsible for implementing and monitoring voluntary
agreements;
·
Improving communication and establishing mutually beneficial (or at least working)
relations between producers and relevant ministries;
·
Appropriate information campaign to raise awareness, share knowledge and increasing the
understanding of the benefits from such instruments for both sides (including producers
and governmental regulating institutions).
·
Revision of appropriate regulations and legal acts in order to provide legal support of
voluntary incentives.
Concerning information campaigns, assistance from experienced institutions of EU countries (in the
form of training, workshops etc.) would be considered helpful (e.g. Ukraine).



WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 27
4. TASK 2 ­ COMPILE AND EVALUATE DATA ON
PHOSPHORUS CONTAINING DETERGENTS AND
ASSOCIATED PRODUCTION STRUCTURES ACROSS
THE DRB

4.1. Production and use of phosphorus-based and alternative
detergent builders in DRB countries
Sodium tripolyphosphate, STPP (Na5P3O10), an inorganic sodium salt, is the main phosphate
present in detergents. It is prepared from phosphoric acid by neutralisation with soda ash (sodium
oxide) forming sodium hydrogen phosphates. A powdered mixture of disodium hydrogen
phosphate, and sodium dihydrogen phosphate is then heated to 500-550°C to produce the stable
form of STPP.
Phosphates offer a number of functions in detergents. They neutralise the `hardness' of water and
dirt, allowing surfactants to function (and so reducing surfactant dosages), prevent the re-
deposition of dirt by "emulsifying" dirt particles, buffering pH, facilitating dissolving of the
detergent and so reducing dosing. They are known as builders and detergents currently contribute
25-30% of phosphates in domestic sewage, where phosphate-based detergents are used.
In sewage, water and soil, phosphates break down (hydrolyse) to a simple soluble phosphate. In
water, the phosphates can act as a fertiliser, where they stimulate the growth of water plants and
algae. The growths can be used in ecosystems or dispersed as nutrients in the water, but where
excessive fertilisation occurs (eutrophication) problems can be caused in surface waters. The
phosphates can be removed from sewage using either chemical precipitation or biological
processes, such as nutrient removal, from where they may be recycled to agricultural land as
fertiliser (provided certain criteria are met, such as the content of toxic elements/substances).
Chemical precipitation is seen as the most effective method of phosphate removal, however it does
result in an increased amount of sludge. Biological processes are less effective (40-70%), but do
not result in an increase in sludge amounts.
Phosphates can be replaced by a number of different chemicals offering the same multiple
functions provided by the phosphates. However, these chemicals usually include insoluble, non-
biodegradable and non-recyclable components and are ultimately transferred to sewage sludges
(approximately 90%), from where they will accumulate in soils.
Zeolites (Zeolite A, P and X) are examples of alternative detergent builders. After discharge to
surface water Zeolite hydrolyses to amorphous minerals, or in the presence of environmental
calcium and phosphate, to poorly soluble calcium aluminium silicate phosphates. These amorphous
materials have no ion exchange capacity, and are unable to bind metals in the environment. Thus,
after hydrolysis, Zeolites should be environmentally inert.
4.1.1. Overview of production structures, washing techniques and regional
differences in detergent formulations
There are many different types of detergents produced and imported in the Danube Basin
countries, with the market for household laundry detergents dominated by multinational groups
like Procter & Gamble (P&G), Unilever, Reckitt & Colman, and Henkel-Merima (the largest
manufacturer of detergents in the Balkan peninsula). The largest detergents producer, by volume
UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 28
sales, is the Unilever Group, which has a strong presence in all regional markets in the world. The
total European market for laundry detergents was estimated at 3-4 billion in 2000.
Below is a summary of the detergents, washing techniques and production in Danube countries, as
available. Table 5, Table 6, Table 6 summarise information from the questionnaires; additional
information has been obtained from CECEP.
Czech Republic: In 2003­2004, the growth in consumption was registered in concentrated liquid
detergents, gels and concentrated powders. Sales of standard powder detergents were eroded by
increased sales of concentrated formats, with tablets remaining among the least popular products.
Hungary: In the last few years (1999-2004) two different effects have modified the phosphates
market in Hungary. Between 1999 and 2004 consumption of the different types of detergents only
increased moderately in Hungary (maximum 10%). The market was also rearranged in this period,
with the consumption of phosphate-free detergents increasing from approximately 25% in 1999 to
40-60% in 2004. This process is proposed to continue into the future. As a result of these two
different effects, the total share of the phosphate load of the surface waters originating from
detergents remained fairly stable.
No significant difference was noted in the type or quantity of detergent used in top and front loader
machines in Hungary.
Moldova: In 2002, only 200 tonnes of synthetic detergents were produced in Moldova, compared
to 800 tonnes in 2001, showing a sharp decrease in the amount of detergents produced in the
country. From these figures it was not possible to determine the precise amount of phosphate-free
detergents, although it is known they represent a very small percentage of the country's market.
The type of detergent used is dependent on the financial abilities of consumers rather than on the
design of washing machine.
Romania is an Accession country with two major detergent manufacturers, P&G (Timisoara) and
Unilever (Ploiesta). Both produce detergents containing phosphates and discharge all wastewater
into the urban sewerage system. According to the National Institute for Statistics, the detergents
are classified as anionic, cationic and non-ionic and not as laundry, industrial and dishwasher
detergents. Therefore, the term of detergents means organic surface-active agents (others than
the soaps), tensio-active preparations, auxiliary preparations for washing and for laundry and
cleaning preparations (inclusive soap containing). Figure 2 shows the development of detergent
production, export, import and usage in Romania from 2000 - 2004; all have increased
substantially over the four-year period.
No data was available on the number of households with washing machines and their design.
Serbia and Montenegro: There is big competition on the local market between domestic and
foreign producers/suppliers. P&G is the single producer with the highest market share (brand
names: Bonux, Ariel, Tide), while the major "domestic" producer is the company Henkel-Merima
(largest manufacturer of detergents in the Balkan peninsula) who export to Romania, Bulgaria, and
former Yugoslavian republics. Products from Henkel-Merima and most other domestic producers
are phosphate-free (or <5% P), in comparison to the majority of P&G products, which are
phosphate-based. This is even though P&G are active in Germany, where phosphate is not used in
laundry detergents.

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 29
Detergents production, import, export and use in Romania (tonnes)
200000
180000
160000
140000
Production
120000
Import
100000
Export
tonnes
80000
Use
60000
40000
20000
0
2000
2001
2002
2003
2004

Figure 2
Detergents production, use and trade in Romania, 2000-2004 (source:
Romanian national statistics)

According to statistical data available in Serbia, the highest amount of detergent produced in the
country belongs to powdered laundry detergents, with liquid detergents for dish washing in second
place and followed by liquid industrial detergents.
Ukraine: Based on sales for 2001, imported products account for almost 40% of the total number
of cleaning products in the Ukraine, with the greatest trade opportunities seen in the product
categories of washing powders and detergents, all-purpose formulas, scouring powders and liquids,
and rust and lime removing formulas. Most of the competition in the Ukrainian cleaning products
market comes from German, Russian, Turkish, and Polish suppliers. Large U.S. companies, such as
P&G, SC Johnson, and Colgate Palmolive are also present and aggressively fight for market
leadership. Currently, nearly 50 large and medium Ukrainian companies import and distribute
foreign cleaning products in the market place. The current trend in the market is that the share of
imports from Turkey, Poland, and Romania has been significantly decreasing since 1998, while
imports from Russia have increased.
The Ukraine noted that all types of detergents could be used for both top and front-loading
machines. However, it is recognised that front-loading machines are more up-to-date and have
improved parameters. They also require improved quality washing powders ("automatic").
According to estimation, the consumption of "automatic" powders in the Ukraine is 2 000 t
annually.

UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 30
Table 5
Detergent suppliers by country (information from questionnaires)
Country Multi-national
suppliers
Local
suppliers
Austria

Bosnia-Herzegovina

Bulgaria

Czech Republic


Croatia

Germany

Hungary
Benckiser, Henkel, Procter & Gamble
??
Moldova
Henkel, Procter & Gamble
Agurdino Com, Aschim
Romania
Henkel, Procter & Gamble, Unilever
??
Serbia-Montenegro
Henkel, Procter & Gamble
Albus Novi Sad, Hemik Kikinda, HI Panonija Pancevo, Impuls Hemila, Novi Sad,
Sinchem Beograd, Yuco-Hemija, + ??
Slovak Republik


Slovenia

Ukraine
Benckiser, Henkel, Procter & Gamble, Unilever

Cussons (Poland), Havat Chemical Industry (Turkey),
Onvia-Beta (Turkey), Unal (Turkey)
Note: Blank boxes: no information

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 31
Table 6
Data on household laundry detergent use (information from questionnaires)
Average Average
% of
% of
% of washing Is there a difference
Total laundry
Total number
use of
use of
machines of the
Year
detergent
Total
household
between top and front
detergent
of
laundry
laundry
Country
that is
population


s with
top loading loaded machines, in terms

usage
households
detergent detergent
phosphate-
(million)
washing
design
of the type of detergent
(tonnes/year)
(million)
(g/person/ (g/househ
free
machines
used or the amount?
day)
old/day)

Austria 2001
55
197
100

8.1

19.0



Bosnia-Herzegovina

7 485
0.5
4.0 0.5





Bulgaria


53
7.5 2.5





Czech Republic
2005

50
10.0




No data No data
Croatia

16 516
<1
4.4 1.5





Germany 2005
643
000
98

9.44





Hungary 2004
126
300
40-60

10.1 3.9

34.2 89.6

71 48
No
differences
Moldova 2005
n/a
1.5

4.2 0.8

22.0 90.0

10
90 No (note 1)
Romania
2004
182 855
05
21.8 8.1

19.4 52.1

- -


Serbia-Montenegro 2004 89
057 646
7.5 2.7

33.0



Slovak Republic
(20047)
(2067) 104 (277)
4.94





Slovenia


>753
1.84





Ukraine
2004
219 873
05
47.3 14.0

4.7 40.1

81
5 No (note 2)
Note 1: Type of detergent use depends on financial abilities of consumers rather than on design of washing machine
Note 2: Any types of detergents can be used for both types of machines but front loaded machines represent modern types of machines with improved parameters and
require improved washing powders "automate" (according to estimation, consumption of "automate" powders is 2 000 t annually)
Note 3: Data from CESEP
Note 4: In Danube Basin, 2000 (from the Danube Commission Expert Group Report)
Note 5. Data on laundry detergent brands indicates that none are P-free
Note 6. May include detergents with up to 5% phosphate
Note 7: Data relates to manufactured and sold in Slovak Republic only - no information on imports
UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 32
Table 7
Industrial, & domestic dishwasher, detergent use (information from
questionnaires)

Total
% of
Total industrial % of industrial
% of
dishwasher
dishwasher
detergent
detergent that
households
Country Year

detergent
detergent that
usage
is phosphate-
with
usage
is phosphate-
(tonnes/year)
free
dishwashers
(tonnes/year)
free
Austria 2001






Bosnia-Herzegovina
32
0.2
887


Bulgaria






Czech Republic







Croatia
2063
58
4346
65

Germany 2005


147000
<10

Hungary 2004
6600

24730
25-40
5
Moldova 2005
n/a
0
n/a
0
1
Romania
-
-
-
100
-
Serbia-Montenegro 2004 2534
8038


Slovak Republic







Slovenia






Ukraine 2004
No
data
(1)





Note 1. Available data do not differentiate between detergents sold / used in the country for household and
industrial purposes
Blank boxes: no information

4.1.2. Overview of the current production and use of phosphate-based
detergents (including import and export)
The use of STTP in detergents represents a high proportion of STPP production. World wide, STPP is
used as a detergent builder more than Zeolites, 4.7 million tonnes compared to 1 million tonnes
respectively. Zeolites are used in the USA, Canada, Japan and much of the EU, while STPP is used
in a greater proportion in China and India. STPP production capacity located in the EU is relatively
small compared to the rest of the world (<10%).
As limited data was provided by Danube countries with regards to the current production and use
of phosphate-based detergents, further information was obtained from appropriate sources,
including additional information obtained by CESEP (2005) and a previous report produced by WRc
(Glennie, et al., 2002) on phosphates and detergent builders.
Table 8 shows the use of phosphate-free detergents in the Danube countries.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 33

Table 8
The use of phosphate-free detergents in the Danube countries
Country
% of phosphate-free
Imports
Exports
detergents used
Austria
100 (laundry


detergents)
Bosnia-Herzegovina 0.5


Bulgaria 53


Croatia
1.1 (laundry)


58 (industrial)
65 (dishwasher)
Czech Republic
206
EU Countries

100 (laundry)7
Germany
>98 (laundry)


<10 (dishwasher)
Hungary
40-60 (laundry)
EU Countries

0 (industrial)
25-40 (dishwasher)
Moldova 1-2
(laundry)
Romania, Turkey,

0 (dishwasher)
Russia and Ukraine
Romania
?? low (laundry)

Serbia & Montenegro,
100 (dishwasher/liquid)
Russia, Bosnia-
Herzegovina,
Bulgaria, Ukraine and
Moldova.
Serbia-Montenegro
64 (laundry)

Bosnia- Herzegovina
Croatia
Slovakia 103
EU Countries

Slovenia >75
EU
Countries

Ukraine Negligible
Russian
Russian Federation,
Federation, Jordan, Moldova, Belaruse
Poland, Hungary,
and other countries
Bulgaria and
Turkey
Note: Blank boxes: no information

Austria: Austria uses over 55 000 tonnes of laundry detergents per year, all of this is phosphate-
free. We do not have any further details concerning the production structures. However, this is not
important, as there seems to be no need for further action.
Bulgaria: 95% of the household detergents are STPP-based.
Czech Republic: In 1995 an Agreement was concluded between the Czech Association of
Producers of Soaps, Cleaning Agents and Detergents and the Ministry of Environment on a gradual
decrease in the environmental impact of detergents. The main goal of the Agreement and its
amendments, concluded in 1998 and 2001 is a gradual decrease in the amount of phosphates
contained in laundry detergents produced by members of the Association8 and their input into the
surface water. Members of the Association committed themselves from 2005 to introduce to the

6 From: ICPDR Issue Paper on the rationale for a phosphate ban in detergents (Popovici, 2003).
7 As from 1st January 2005, Producers of Soaps, Cleaning Agents and Detergents no longer able to sell
phosphate-based laundry detergents.
8 UNILEVER CR, spol. s.r.o., PROCTER and GAMBLE, v.o.s., HENKEL CR, spol. s.r.o., BENCKISER, spol. s.r.o.,
SETUZA a.s.
UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 34
market only laundry detergents with a maximum content 0.1% (weight) of inorganic phosphorus
and 1.0% of phosphorus bound in phosphonates. As of the 1st of January 2005 members of
Association were no longer able to sell phosphate-based laundry detergents. The Agreement
resulted in a decrease of phosphates in laundry detergents from 9 000 t in 1995 to 5 065 t in 2003.
However, this was accompanied by a sharp increase in the sale of phosphate containing detergents
by non-members of the association from 2002 - 2004, resulting in about 40-50% by 2003 - 2004
(see case study in Section 3.3.1).
Germany: Similar to Austria, about 98% of laundry detergents used are phosphate-free (about
643 000 tonnes per year) and therefore no further action is necessary. Only 10% of dishwater
detergents are phosphate-free and the usage is considerable (147 000 tonnes per year compared
with 643 000 tonnes per year of laundry detergents.
Hungary: The consumption of phosphate-free detergents has been increasing from approximately
25% in 1999 to 40-60% in 2004, and the trend is expected to continue.
Moldova: More than 90% of the detergents used are imported, with the levels of detergents and
soaps increasing by 11.2% in 2004. The majority of imports are from Romania, Turkey, Russia and
the Ukraine. On a small share of imported powder detergents the phosphate content was not
indicated. Among the 20 kinds of detergents inspected, only one was found to contain a lower
phosphate content (5-15%), compared to 15-30% indicated on other detergents. There were no
phosphate-free detergents found on the market.
To improve this situation new legal acts are intended to be implemented to limit phosphate-content
in detergents; financial support from donors will be provided to subsidize phosphate-free
detergents prices; tax policy in relation to phosphate-free detergents will be changed and public
involvement increased.
Romania: In 2000 the National Research Institute for Environmental Protection carried out a study
named "Experimental researches in order to establish the effect of the detergents concentration on
biological treatment process". One of the conclusions of this study was that the phosphate
concentrations identified in the commercial detergents were, on average, between 0 and10%. The
same study also drew the conclusion that, in the case of Cluj city, a maximum 27.6% of the
phosphates quantity contained in the non-treated wastewaters was coming from household
washing/laundry.
However, all products surveyed on the market in 2005 (for this project) contained phosphate
concentrations ranging from about 10-20%. No phosphate-free detergents were found, but
Unilever has recently announced that it will soon provide phosphate-free detergents, initially those
for automatic machines.
Serbia: There is much competition on the local market between domestic and foreign
producers/suppliers, with P&G being the single producer with highest market share (brand names:
Bonux, Ariel, Tide). Most of the P&G products are phosphate-based even though they are based on
German technology, where phosphate is not used in laundry detergents. The major "domestic"
producer is Henkel-Merima (Krusevac), which, like most other domestic producers, is phosphate-
free. The major export of detergents is to neighbouring countries such as Bosnia-Herzegovina and
Croatia.
Slovenia: Less than 25% of the detergents used in Slovenia are reported to contain phosphates.
Discussions with Jaroslav Slunecko of Proctor & Gamble in Slovenia (AISE representative for
Central and Eastern Europe) revealed that prior to 2000, almost 100% of detergents in Slovenia
were phosphate-free, not because of any legislation or voluntary agreements, but merely the
particular market structure. This has gradually changed and is still changing because of an increase
in the market share of a variety of small companies supplying phosphate-based detergents.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 35
Ukraine: The production and selling of detergents for domestic and industrial purposes is growing
by 15-20% annually and represents one of the most rapidly developing business sectors (legally
and illegally) in the Ukraine. Most products comprise surface-active substances and phosphate
compounds. In 2004 the Ukraine produced 155 217 t packed and 1 852 t non-packed detergents
and cleansers, with 70-75% of them as washing powders. The detergents produced in the Ukraine
cover 65% of the Ukrainian market. 14 852 t of detergents produced in the Ukraine (14 460 t
packed and 392 t non-packed) were exported to the Russian Federation, Moldova, Belarus and
other countries. During the same period in 2004, the Ukraine imported 77 656 t detergents and
cleansers (71 424 t packed and 6 232 t non-packed). These products were supplied by the Russian
Federation (54 000 t or 69% of imported products), Jordan (4 800 t), Poland (3 500 t), Hungary
(3 400 t), Bulgaria (3 300 t), and Turkey (1 300 t).
National Statistics in the Ukraine do not provide reliable data concerning phosphate containing
detergents production and use in household and industrial sector. No market data was available on
the amount of phosphate-free detergent used in the Ukraine, however from an assessment of the
available information, it was concluded that the proportion of phosphate-free detergents was
negligible.
DRB: Recent calculations from the `Significant pressures for the WFD Roof report' (ICPDR, 2004)
indicate that the catchments with the highest specific phosphate discharges were found for the
Sava, Banat-Eastern Serbia, Velika Morava and Mizia-Dobrudzha. The specific phosphate emissions
are above 2 g/(Inh.·d) for Slovenia, Croatia and Serbia and Montenegro. The medium level
phosphate emissions between 1 and 2 g/(Inh.·d) were found for the Slovak Republic, Hungary,
Bosnia, Herzegovina, Romania and Bulgaria. Specific point phosphate discharges below 1 g/(Inh.·d)
were recorded for Austria, Germany, the Czech Republic, Moldova and Ukraine. For the Czech
Republic this is due to the fact that some WWTPs have additional phosphate elimination. The
Ukraine and Moldova also have relatively low specific phosphate emissions. Specific phosphate
point discharges reflect, not only the state of the phosphate elimination in waste water treatment
plants, but also the existing use of phosphorus in detergents, and discharges from direct industrial
sources.
The annual specific per capita consumption of detergents in this period varies from about 1.0 -
11.6 kg in the Danube Basin countries. This represents approximately 85-90% of the total
household consumption of phosphate containing detergents and only 10-15% of the total industrial
consumption, especially in commercial laundries.

4.1.3. Summary of the current use of alternative (e.g. zeolite-based)
detergents in DRB countries
Table 9 summarises the available information on the use of phosphate-free laundry detergents in
the Danube River Basin (DRB) countries, including population figures (total and those in DRB). It
has been difficult to obtain information and the information on the use of phosphate-free
detergents must be considered approximate.
UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 36

Table 9
Detergent usage, populations & phosphate-free detergents by country
% Detergent Country
Total laundry detergent Total population Total population
that is

usage (tonnes/year)
(million)1
in Danube Basin
Phosphate-
(million)2
free
Austria
55
197 8.1 7.7
>98%
Germany 643
000
82.0
9.1
Czech Republic

9.9
2.7
Hungary
126 300
10.3
10.3
Slovenia

2.0
1.7
>~50%

Serbia-Montenegro 3 89
057 9.3 9.1
Bosnia-Herzegovina
7
485 4.4 2.5
Bulgaria

7.9
4.4
Croatia
16
516 4.7 3.2
<10%
Moldova
4.3 1.1

Slovak Republic

5.4
5.2


Ukraine 219
873
49.1
3.1
Not known 4
Romania
154
584 22.4 21.8
Note 1. Information from Whitaker's Almanack 2005
Note 2. From Joint Action Programme, 2000-2005
Note 3. Data for `phosphate-free' in Serbia-Montenegro may include low phosphate detergents (i.e. up to 5%
phosphate)
Note 4. Data for products indicates no phosphate-free detergents on the market in 2005

In many cases the information is incomplete and problems with the definition of `phosphate-free'
and different approaches to product labeling have given rise to uncertainties. We have attempted
to use the definition of `phosphate-free' as <0.2% phosphate according to the EU Regulation on
detergents (EC/648/2004) according to which a phosphate content of 0.2% or higher has to be
declared on the label. However, in some cases, the `phosphate-free' component may include `low
phosphate' products, e.g. up to 5% phosphate content. The Czech voluntary agreement, for
example, allowed up to about 2% phosphate in `phosphate-free' detergents. Another difficulty was
the contradictory information at times between product labels (as examined on supermarket
shelves) and manufacturers' information (e.g. Hungary): whilst manufacturers claimed their
products were phosphate-free, information from the survey of products on the market was unclear
or contradictory (see Section 4.2.3, Table 10). this could have been due to a variety of factors, for
example changes in product formulations or differences in products with the same name but
produced in different countries, such as Germany and Hungary.
Nevertheless, the situation can be broadly summarized as follows.
Austria and Germany have virtually no phosphate containing laundry detergents and need not be
considered for voluntary agreements or other measures. Austria has achieved this through a
voluntary agreement, whilst Germany has used a combination of legislative and voluntary
measures with the full co-operation of the detergent industry and involvement of the public.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 37
Slovenia has a high proportion of phosphate-free laundry detergents (about 75%). However, it
seems that there has been an increase in the use of phosphate detergents in recent years (it was
virtually phosphate-free in 2000), and it may still be rising. Consequently, whilst it should not
receive priority for action, the situation may need to be monitored.
The Czech Republic has recently replaced a voluntary agreement to reduce phosphorus in laundry
detergents, which was a partial success, with legislation; it will therefore not need to be considered
for further action either.
The above four countries together account for about a quarter, or 26%, of the total population in
the DRB.
Of the remaining countries, only Hungary and Serbia-Montenegro use significant proportions of
phosphate-free laundry detergents and together account for about another quarter (24%) of the
DRB population. In both cases there are some uncertainties in the data, for example some
conflicting information from Hungary; moreover, the data for phosphate-free detergents in Serbia-
Montenegro may include `low phosphate' products (up to 5% phosphate) and, particularly in view
of the significant proportion of the DRB population, we recommend consideration of these countries
for further action.
The other seven countries use little or no phosphate-free detergents and make up almost half the
population; of these Romania is the most significant in terms of DRB population (about 27% of
total). No figure was given for phosphate-free detergents in Romania, although the available
product data (incomplete) indicated an absence of phosphate-free detergents.
It is worth noting that Moldova intends to legislate and to use a combination of subsidies (from
donors) and tax incentives to promote the use of phosphate-free detergents. More information
should be sought concerning the details and progress of these plans.
4.2. Industry and country costs and benefits associated with
switching from phosphate-based to more environmentally
friendly detergent builders

4.2.1. Comparison of production costs for phosphate-based and alternative
(e.g. zeolite-based) detergents
There are many different types of detergents produced and imported in the Danube Basin
countries, resulting in trade flows of detergents between EU countries and Central European
Countries, as well as other neighbouring countries, and within the Central European Countries
themselves, having significantly expanded over the last years.
Figure 3 shows the market shares of phosphate-free powder detergents in Europe in 1998.

UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 38

Figure 3
Market shares of phosphate-free powder detergents in Europe in 1998
(Source: E.J. Smulders as provided by CESEP)
Among those countries indicated in Figure 3, the 1998 figures for Austria and Germany (100% P-
free) are in line with our current findings. Similarly, the data for the Czech/Slovak republics
(combined 30% P-free compared with our findings: ~50% for CZ and <10% for SK), as well as the
low percentages of P-free in Bulgaria and Romania. However, it is interesting to note that the P-
free share has increased from about 30% in 1998 to 40-60% current usage (2005) in Hungary, but
has decreased significantly in Slovenia (from 95% to about 75%) and in Croatia (from abot 60% to
less than 10%).
An analysis of the volume of trade shows that the Czech Republic, Slovakia, Slovenia and Hungary
import detergent products mainly from the EU countries, whilst imports by Romania, the Ukraine
and Moldova from EU countries are very limited in terms of volume and value. The amount of
detergents imported by Slovakia, Hungary, Romania, the Ukraine, Moldova and Bulgaria has played
a significant part in the decrease of the domestic production of detergents over the last five years
in Croatia, Hungary, Romania, Ukraine and Bulgaria. The production and use of detergents has
dropped mainly because of the economic crisis and detergent imports.
The EU currently contributes to less than 10% of the world's STPP production, and employs
approximately 1000 people. Therefore, while an EU-wide ban on STPP use would direct STPP
manufacturing to other large centres, such as China and India, the economic loss of this would not
be considered great in overall EU terms.
Zeolite-A is the most commonly used substance for replacing phosphates in detergents.
Approximately 50% of the zeolites are produced in Europe, where the capacity for production
exceeds the current rate of production. Zeolite A has been shown to be a cost effective alternative,
both in terms of socio-economic and environmental impacts to STPP as a detergent builder.
Therefore, as the EU capacity for Zeolite A production exceeds the actual production, it could be
expected that increased production in this area would result in substantial employment and
economic opportunities, with only a small requirement for additional capital expenditure on
infrastructure.
Unilever in Romania indicated that, in order to obtain the same washing performances as
phosphate-based detergents, the production of phosphate-free detergents implied higher
production costs. However, no details were forthcoming from Unilever or any other manufacturers.
Such information is regarded as trade secrets (Jaroslav Slunecko, Procter & Gamble in Slovenia
and AISE representative for CEE countries, personal communication).
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 39

4.2.2. Comparison of wastewater treatment costs for phosphate-based and
alternative (e.g. zeolite-based) detergents
The overall economic balance between wastewater treatment operating costs for phosphate-based
or phosphate-free detergents is dependent on sludge generation, on the choice between biological
or chemical phosphorus removal and on the proportion of sewage works in which phosphate
removal is not necessary (but where substitutes, on the other hand, will nonetheless be transferred
to sludge). This makes the main obstacle to implementing the EU sewage treatment legislation
(Urban Wastewater Treatment Directive) to be plant investment cost.
Sewage sludge disposal is now the biggest single operating expense for most European water
companies, with costs usually averaging 150 Euros per tonne dry matter, and rising. Sludge
volumes will become an even more important sewage works management issue with application of
the EU Landfill Directive, which imposes over a 15-19 year horizon, a 65% reduction in
biodegradable waste going to landfill.
Phosphates can be removed in sewage works either by chemical precipitation or by biological
techniques (which also allow nitrogen removal). Chemical precipitation is easy to operate and
involves little investment. However, there is a cost for purchasing precipitant chemicals (often iron)
and the sewage sludge volumes are increased by contributions from both the suspended solids
removed and from the chemicals added to induce precipitation. Biological phosphate removal is
potentially more sustainable than chemical precipitation systems, but it requires a higher initial
investment and is more complex to operate. It also typically removes only 40 to 70%
(exceptionally, up to 85%) of the phosphate present and thus may not be able to meet some of the
strictest phosphate consent levels found in the EU. For these reasons and other considerations
(financially, biological phosphate removal has higher capital costs, but lower running costs than
chemical phosphate removal), chemical phosphate removal is currently more prevalent in EU
countries.
Where phosphate-free detergents are used, a deposition of 0.7 g of phosphates (STPP) is
equivalent to a deposition approximately 0.9 g zeolite plus 0.2 g polycarboxylates. Both these
products will be transferred in sewage treatment to the sewage sludge in all sewage works,
implying a significant increase in sludge volumes. Approximately 90% of the Zeolite entering the
sewage treatment facility is incorporated into the sewage sludge. Although this typically causes an
increase of approximately 10% in the dry weight of the sludge produced the sludge volume has
been shown not to increase, as Zeolites aid sludge settling. Thus sludge transport costs will not be
increased by the use of Zeolite in washing products. In treated wastewater effluents the amount of
suspended solids is regulated, therefore the use of Zeolites will not increase the emissions of
suspended solids in surface waters over those values accepted for the receiving waters.
According to the previous experience of western European States, where phosphate-free
detergents are already widely used, the cost of the introduction of phosphate-free detergents is
much less than the additional cost of the improvement of sewage treatment to deal with phosphate
elimination. Therefore, it will not involve any additional direct costs to either the consumer or
national budgets. However, it is generally estimated that, where phosphates are used in
detergents, this contributes less than one third of the total phosphates in sewage, the remainder
coming from human and food wastes and other material (e.g. natural bed-rock erosion and
agricultural run-off). This means that even where sewage phosphate is contributing to
eutrophication problems, moving to phosphate-free detergents will not totally resolve the
problems, irrespective of detergent formulation. It will still be necessary to install phosphate
removal in sewage works to remove the phosphates in human wastes.
UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 40
In the long-term, it is deemed that the cost and environmental balance of phosphate removal from
sewage may be significantly improved in the future with the development of phosphate recovery
for recycling, which will effectively convert sludge production into a valuable re-usable resource.
The substitutes used in phosphate-free detergents themselves are not feasibly recyclable at
present.
4.2.3. Estimation of costs/benefits of using alternative detergent builders in
DRB countries (country specific)
The data supplied as part of this study was inadequate for an assessment of the costs and benefits
of replacing phosphate detergents with phosphate-free detergents. For example, detergent
producers were not prepared to provide information on production costs and we have no
information on the investment costs (if any) for switching from the production of phosphate
detergents to non-phosphate containing detergents.
However, the previous study (Glennie, et al., 2002) found that Zeolite A was a cost-effective
alternative, both in terms of socio-economic and environmental impacts. Moreover, only minor
differences were observed between the production costs in terms of energy used and sludge
produced.
In terms of environmental benefits, it has also been established previously (Glennie, et al., 2002)
that a combined approach is needed to combat eutrophication problems, that is the use of
phosphate-free detergents, effective wastewater treatment to remove nutrients and `good
agricultural practice'.
At present, the use of chemical and biological phosphate removal from wastewater can require
initial investment costs and regular costs for purchasing the precipitation chemicals. Therefore, it is
understood that in the long-term the introduction of phosphate-free detergents will be a cost-
effective and necessary measure.
Some information has been obtained in the present survey on costs of detergents to the consumer;
this information is summarised in Table 10 for Hungary, Table 11 for Moldova, Table 12 for
Romania, Table 13 for Serbia-Montenegro and Table 14 for the the Ukraine, as available. From this
data it is not possible to draw any firm conclusions, concerning the cost of phosphate detergents
compared with phosphate-free detergents. This is mainly due to the uneven distribution of
samples; in all except Serbia-Montenegro where most samples were phosphate-free, there were
few or no phosphate-free detergents. In addition, the prices varied a great deal according to many
factors, such as product, manufacturer, packet size etc. Some phosphate-free detergents (or low
phosphate, i.e. <5%) were in the lowest price bracket, others in the higher range, providing no
evidence of phosphate-free (or low phosphate) detergents consistently being more expensive.




WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 41
Table 10
Laundry detergent manufacturers, brands, types & prices - Hungary (2005)

Phosphate-
Amount
Name of
Country of
Phosphate-
based (%
Price range
used
manufacturer/supplier
manufacture Brand
name free
Phosphate)
Type / purpose
Euro/kg
(t/year)
Procter & Gamble
EU
ARIEL
No
15-30
Several types, usually universal
2.5-4.5 *
No data
Procter & Gamble
EU
BONUX
No
15-30 (5-15)
Several types, usually universal
1.5-2
No data
Procter & Gamble
EU
TIDE
No
15-30
Several types, usually universal
2 to 4
No data
Henkel
Germany, Hungary
PERSIL, Matik
Yes / No 1
<5 / 15-30
For each washing machine type
2.5-3.5
No data
Henkel
Germany, Hungary
PERSIL, Other types
Yes 1
<5
Several types, usually universal
2.5-3.5
No data
Henkel Germany,
Hungary
TOMI Yes
1
<5
Several types, usually universal
1.5-2
No data
Henkel
Germany, Hungary
BIOPON Colour
Yes / No 1
<5 / 5-15
Several types, usually universal
1.5-2
No data
Henkel
Germany, Hungary
BIOPON white
Yes / No 1
<5 / 15-30


No data
EVM Hungary
ÁSZ
Yes
1 <5
Universal
1
No
data
Benckiser
EU
DOSIA
No
15-30
Several types, usually universal
1.5
No data

EU
BIP
No
5-15
Several types, usually universal
1.5-2
No data
Note 1: Whilst manufacturers Henkel and EVM confirmed that their products were P-free (<0.2% phosphate), the package information was unclear, sometimes indicating
merely <5% phosphate, or even contradictory (see BIOPON and PERSIL Matik)
UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 42
Table 11
Laundry detergent manufacturers, brands, types & prices - Moldova (2005)

Phosphate-
Name of
Country of
based (%
Price range
manufacturer/supplier
manufacture Brand
name
Phosphate-free
Phosphate)
Type / purpose
Euro/kg
Amount used (t/year)
Agurdino Com
Moldova
Unidet
No
15-30
Hand wash
0.6
15 (in the Danube basin)
Aschim
Moldova
Planeta/Moldova
No
15-30
Hand wash
0.6
17 (in the Danube basin)
Henkel
Czech Republic
Tide
No
15-30


No data
Henkel
Poland
E
No
15-30


No data
Henkel Romania
Omo
No
15-30
90O wash
1.8
No data
Henkel Romania
Dero
No
15-30
90O wash
1.5
No data
Henkel
Russia
Sorti,Bimax
No
15-30


No data
Henkel
Turkey
Fax
No
15-30
All types
1.2
No data
Henkel
Turkey
Bingo, Test, Joly,
No
15-30


No data
Henkel
Turkey
Nit (dishwasher)
No
15-30

2.2
No data
Henkel
Ukraine
Persil
No
15-30
Coloured wash
2.0
No data
Henkel
Ukraine
Rex,Perwall
No
15-30


No data
Procter & Gamble
Romania
Bonux
No
15-30
All types
1.2
No data
Procter & Gamble
Romania
Ariel
No
15-30
90O wash
1.6
No data
Procter & Gamble
Romania, Russia
Tide
No
15-30


No data


Other
Yes


2-3.5
No data

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 43
Table 12
Laundry detergent manufacturers, brands, types & prices ­ Romania

Phosphate-
Amount
Name of
Country of
Phosphate- based (%
used
manufacturer/supplier
manufacture
Brand name
free
Phosphate) Type / purpose
Price range Euro/kg
(t/year)
Unilever
Romania
Dero Surf Automat2 in 1 AV
No
21.3
90oC wash
1.67 (package 1.5 kg)
No data
Unilever
Romania
Dero Surf2 in 1 AV
No
15.2
Hand wash
1.49 (6kg), 1.70 (0.45 kg)
No data
Unilever
Romania
Dero Surf Automat
No
21.3
90oC wash
1.25 (6 kg), 1.35 (3 kg)
No data
Unilever
Romania
Dero Surf
No
15.2
Hand wash
1.55 (0.45 kg)
No data
Unilever
Romania
Bona Automat 3 in 1
No
15.6
90oC wash

No data
Unilever
Romania
Bona 3 in 1
No
15.2
Hand wash
2.40 (0.45 kg)
No data
Unilever Romania
Bona
Automat
No
15.6
90oC wash

No data
Unilever Romania
Bona manual
No
15.2
Hand wash

No data
Unilever Romania
Omo
Automat
No
20.3
90oC wash
2.38 (3kg), 2.14 (6 kg), 2.06 (9 kg) No data
Unilever
Romania
Omo color
No
18.3
Coloured wash

No data
Unilever
Romania
Floraszept, Biopon chloride1 No
8.8
Soaking

No
data
Unilever Romania
Biopon
Automat1 No
14.4
90oC wash

No data
Unilever Romania
Pollena No
11.9
90oC wash

No data
Unilever
Romania
Total all brands
No



43421
Procter & Gamble
Romania
No data




Henkel
No
data




Note 1: also exported to Hungary
UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 44
Table 13
Laundry detergent manufacturers, brands, types & prices - Serbia-Montenegro

Phosphate-
Name of
Country of
Phosphate-
based (%
Price range Amount used
manufacturer/supplier manufacture Brand
name
free
Phosphate)
Type / purpose
Euro/kg
(t/year)
Albus Novi Sad
Serbia
Albus Automat (Albus)
Yes

0.3 - 1.13
Albus Novi Sad
Serbia
Max Duo (Albus)
Yes

Laundry machine powder
0.30 - 1.87
288
Albus Novi Sad
Serbia
Gong
Yes



Albus Novi Sad
Serbia
Industrial det.
Yes



226
Hemik Kikinda
Serbia
Pjaf ekonomik
Yes



102
Henkel
Serbia
Industrial det.
Yes



1457
Henkel
Serbia
Mer
Yes



Henkel
Serbia
Meril (Henkel-Merima)
Yes


1.6
Henkel Serbia
Merix
(Henkel-Merima)
Yes


1.0 ­ 1.5
33328
Henkel
Serbia
Persil (Henkel)
Yes

Laundry machine powder
2.0
Henkel
Serbia
Rex
Yes



Henkel
Serbia
Sudomil
Yes



HI Panonija Pancevo
Serbia
Industrial det.
Yes



60
HI Panonija Pancevo
Serbia
Lana, Fino-Per
Yes



130
Impuls hemija Novi sad Serbia
Impuls, Impuls multiaktiv
Yes



54
Impuls hemija Novi sad Serbia
Industrial det
Yes



370
Procter & Gamble

Ariel (P&G)
No
15-30
Laundry machine powder
1.6 ­ 2.2

Procter & Gamble

Bonux (P&G)
No
5 - 15

0.8 ­ 1.0

Procter & Gamble

Tide (P&G)
No
15-30

1.4 ­ 1.8

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 45
Phosphate-
Name of
Country of
Phosphate-
based (%
Price range Amount used
manufacturer/supplier manufacture Brand
name
free
Phosphate) Type
/
purpose Euro/kg
(t/year)
Simchem Beograd
Serbia
Axel Matic (Sinchem)
Yes

Dishwasher machine powder
3.4
74
Yuco-hemija
Serbia
Azur D
No
11


36
Yuco-hemija Serbia
Industrial detergent
Yes



40
Yuco-hemija
Serbia
Star, Aktiv, Atomic, Ox etc
Yes



605


Talas Clean forest (Delta in)
Yes

1.0 ­ 1.2

Laundry machine powder


Talas economic plus (Delta In) No
15-30

1.0 ­ 1.2

UNDP/GEF DANUBE REGIONAL PROJECT

Task 2 ­ Compile and evaluate data
page 46
Table 14
Laundry detergent manufacturers, brands, types & prices - Ukraine (2004)

Name of
Country of
Phosphate-based
Price range
Amount used
manufacturer/supplier
manufacture Brand
name Phosphate-free
(% Phosphate) Type / purpose Euro/kg
(t/year)
Benckiser
International
Dosia
No
>12


No data
Benckiser
International
Lanza
No
>12


No data
Cussons
Poland
E
No
15 - 30
Universal1
1.5 - 1.6
No data
Havat Chemical Industry Co
Ukraine, Turkey
TEST
No
12 - 17
Universal1
0.9 - 1.7
No data
Henkel Ukraine,
Austria
Losk
No
>12
Universal1
1.3 - 1. 8 *
No data
Henkel Ukraine,
Austria
Persil
No
>12
Universal1
1.5 - 2.0
No data
Henkel Ukraine,
Austria
REX
No
>12
Universal1
0.9 - 1.3
No data
Olvia-Beta
Ukraine, Turkey
Gala
No
>12


No data
Procter & Gamble

Ariel
No
>12
Universal1
1.7 - 1.9
No data
Procter & Gamble

Tide
No
>12
Universal1
1.3 - 1.7
No data
Procter & Gamble

Gala
No
>12
Universal1
1.0 - 2.3
No data
Procter & Gamble

DAX
No
>12
Universal1
0.7 - 0.9
No data
Procter & Gamble

Bonux
No
>12
Universal1
1.0 - 1.3
No data
Unal - ABC Chemical Industry
Ukraine, Turkey
Test
No
12 - 17


No data
Unilever
International
OMO
No
>12


No data
Unilever
International
Surf
No
>12


No data
Note 1. All types of fabric. There are different types for hand and machine washing
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 47
5. TASK 3 ­ EUROPEAN EXPERIENCE OF VOLUNTARY
AGREEMENTS
5.1. Types of voluntary agreement
There are many examples of voluntary initiatives by industries to reduce pollution and improve the
environment. These have been reviewed by the Wuppertal Institute (Dalkmann et al, 2005), in
order to identify success factors and risks. Their report is recommended reading for those who may
play a role in setting up voluntary agreements in Danube basin countries. Here a brief summary of
their findings is given, with supporting material from earlier documents (Higley et al., 2001; Ijjas,
undated; UNEP, 2000).
For industries, both `command and control' regulation, and `market instruments' such as taxes, can
impose costs and reduce their ability to compete. For governments and their environmental
agencies, regulation can be technically difficult and costly. These perceptions have encouraged the
emergence of more flexible voluntary approaches to achieving environmental objectives (Higley et
al.,
2001).
The UNEP identifies five types of voluntary initiative (UNEP 2000, summarised in Table 15). The
proposed voluntary agreements considered in this report are of type 3.
Table 15
Types of voluntary initiative
1
Industry initiatives
The decisions on goals, how to achieve them, monitoring &
reporting are taken unilaterally by the company or industry.
2
Government initiatives
The goals are defined by governments, usually in consultation
with industry. Companies volunteer to take part.
3
Joint government /
Negotiated agreements, either sector specific or cross-sector
industry initiatives
(e.g. on packaging or energy efficiency).
4
Third party initiatives
Standards such as ISO14000, which are set up and
monitored by non-government non-business organisations.
5
UN and other
These use the moral authority of international commitments.
international &
voluntary initiatives

Differences exist between countries in legal systems, and in relationships between government,
business and the voluntary sector. These have been important influences on the use of voluntary
agreements.
In addition to the options identified in Table 15 above, other characteristics of an agreement need
to be considered:
> Product based versus process oriented:
> An agreement on detergents would be product based, i.e. define standards for products.
> Target based versus implementation based:
> Voluntary agreements can set targets, or define ways of meeting targets set elsewhere.
> Binding versus non-binding:
> A binding agreement would include sanctions for non-compliance and be enforceable.
> Individual versus collective liability:
UNDP/GEF DANUBE REGIONAL PROJECT

Task 3 ­ European experience of voluntary agreements
page 48
> Either individual companies, or the sector association collectively, may be liable to pay
sanctions for not complying with the agreement. Or there may be no sanctions.
> Open versus closed access to third parties:
Community organisations, independent experts and environmental groups provide a
useful independent view.

5.2. Benefits and risks of voluntary agreements
Benefits:
A flexible approach to complex and incompletely understood environmental problems
Voluntary agreements are one part of a mix of policies, alongside `command and control'
regulation, taxes and emissions trading. The most important environmental issues for voluntary
agreements have been waste management and climate change mitigation, where there was a high
degree of technological uncertainty when the issues were first addressed, and voluntary
agreements have offered flexibility.
Wider awareness of the issues and sharing of information
Voluntary agreements have resulted in increased awareness of environmental damage on the part
of industry staff, and in the sharing of clean or energy saving technology.
Risks:
The biggest concern is `regulatory capture', when the industry influences the terms of the
agreement in its own immediate interest. The result is a weak agreement, as for example that
between the EU and the European Automobile Manufacturers Association on CO2 emissions from
passenger cars.
The credibility of an agreement can be undermined, if it is negotiated between government and
industry without the involvement of independent third parties, such as voluntary organisations,
parliaments or research institutes.
Free riding occurs when one or more parties to the agreement does not take the action agreed on.
This can easily occur when there are many participating companies, and liability is collective rather
than individual.
A variation of free riding seems to have occurred in the case of the Czech voluntary agreement on
detergents, when one member left the industry association in order to be free to sell detergents
containing >5.5% P, and increased its market share significantly (see Section 3.3.1).
5.3. Setting up a voluntary agreement
Dalkmann et al. (2005) define a process for creating and implementing a voluntary agreement (
Figure 4). Table 16 provides comments and observations and Table 17 lists possible incentives for
entering voluntary agreements (UNEP, 2000).

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 49
Figure 4
Negotiating and implementing a voluntary agreement
Define targets
Establish cooperation
Offer incentives
Negotiate on targets,
measures and monitoring
Conclude and implement
the agreement
Monitor action
Promote information
dissemination
Communicate information
reports
Apply sanctions if needed


Table 16
Comments and observations
Step
General comments
Czech agreement on detergents
Define targets
The targets need to be clearly
In 1995, no timetable for achieving the
defined and sufficient to meet the objectives was set.
environmental objectives.
Establish
It is important to build confidence The CSDPA9 was created to show
cooperation
between the involved parties and corporate responsibility and to limit
seek agreement on the basic
negative impacts on business
elements
Offer incentives
See Table 17
The main motive of the companies was
to avoid potentially costly regulation?
Negotiate on

Negotiations were between industry and
targets, measures
the Ministry of the Environment ­ better
and monitoring
than the Ministry of Economic Affairs!
Conclude and


implement
agreement
Monitor action

Annual reports are obligatory. Two
NGOs and the Prague Chemical and
Technology College are involved in
monitoring as independent experts

9 The Czech Soap and Detergent Products Association was set up by 5 companies covering >90% of the Czech
market
UNDP/GEF DANUBE REGIONAL PROJECT

Task 3 ­ European experience of voluntary agreements
page 50
Step
General comments
Czech agreement on detergents
Promote information

dissemination
Communicate


information reports
Apply sanctions if

Since 2001 a collective fine of 1 million
needed
CZK (33 000 Euro) has been in force,
but never tested.
The main sanction has been the threat
of regulation, which is now being
introduced.
Based on Dalkmann et al., 2005

Table 17
Incentives for companies to enter voluntary agreements
Incentives to reduce costs, especially by cutting resource use and waste generation
Desires to avoid or at least delay additional regulatory action that would impose undesirable
administrative and compliance costs
Fear of damage to public image and associated customer and investor confidence, or desire to
enhance public reputation and associated customer and investor confidence
Desire to minimise risk of costly surprises
Expectation of competitive advantage through exclusion of new competitors and access to new
markets
Requirements imposed by banks and/or insurers that do not wish to inherit environmental liabilities
Demands of suppliers and customers who wish to avoid environmental costs and liabilities
Pressure from staff or fellow industry members
Personal commitment of corporate leaders
Source: Robert Gibson, UNEP 2000
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 51
5.4. Content of a voluntary agreement
The texts of the Czech and Irish agreements are attached as Annex 3. These are examples, and
should not be followed word for word.
A list of suggested headings for an agreement is shown below.
Title
Subject
Objective
Defines the overall objective and the target date for achieving it
Parties to the agreement and their roles
Government, industry association and independent expert / community representatives
The association / its members
Targets and timetable for achieving them
Specific and measurable, and consistent with the objective
Monitoring and evaluation
What and by whom
Reporting and dissemination of information
What information, prepared by whom and made available to whom
Sanctions
When they would apply, individual or collective, amount
Changing or terminating the agreement
End date of the agreement
Circumstances and period of notice for terminating the agreement
Provision for changing the agreement
Provision for a member of the association to leave?
5.5. Strategy for implementing the agreements
Ijjas (undated) recommends voluntary agreements between the producers of detergents and the
responsible government agencies for the removal of P from detergents, as part of a programme
that includes:
> Harmonisation with the EU standards for detergents;
> Introduction of the European eco-labelling system for detergents;
> Market oriented measures, such as taxes or fines. This could be a product charge: `tax
differentiation seems to be one of the more successful economic instruments and its
application' (Ijjas, undated);
> Increased public awareness and involvement. Ijjas comments that public awareness of
environmental problems related to detergents has been growing, but is still poor, and that
where people are under pressure because of unemployment, inflation or low salaries,
willingness to pay for solving water pollution problems is reduced;
> Introduction of environmentally friendly substitutes for P in detergents;
> Enhancement of wastewater treatment.
Table 18 shows the steps to be taken to achieve a voluntary agreement and Table 19 lists whether
DRB countries have members of AISE.
UNDP/GEF DANUBE REGIONAL PROJECT

Task 3 ­ European experience of voluntary agreements
page 52

Table 18
Steps to achieve a voluntary agreement
Step
Implementation in the Danube basin
1. Define targets
What limit on the P content of detergents should be set? For which
types of detergent? Who will raise public awareness, in what ways?
2. Establish cooperation
The first step will be to encourage the formation of an association,
where one does not exist. Of the 9 Danube countries of interest
(see Section 4.1.3), 3 have an association that is a member of
AISE10 (Table 19).
3. Offer incentives
See Table 17. A clear understanding is needed of any increased
production costs with P-free detergents, and whether they will be
passed on to consumers.
4. Negotiate on targets,
NGOs / independent experts should be involved.
measures and monitoring
5. Conclude and implement

agreement
1


6. Monitor action
NGOs / independent experts should be involved.
7. Promote
information

dissemination
8. Communicate
information
reports
9. Apply sanctions if needed What sanctions will be included? Individual or collective? What
would prevent a company leaving the association and selling
detergents containing P? How to deal with imports of phosphate
detergents?

Table 19
AISE member associations in Danube countries
Country
AISE member association?
Austria Yes
Bosnia-Herzegovina No
Bulgaria No
Croatia No
Czech Republic
Yes
Germany Yes
Hungary Yes
Moldova No
Romania Yes
Serbia-Montenegro No
Slovakia Yes
Slovenia Yes
Ukraine No
Note: The countries, where phosphate reductions in detergents are needed (see Section 4.1.3) are marked in
bold

10 There may be industry associations in some of the other 6 countries, but the authors are not
aware of any.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 53

A summary of AISE membership information is provided in Table 20, including number of member
companies, small and medium size enterprises and number active in consumer product domain.
Bosnia-Herzegovina, Bulgaria, Croatia, Moldova, Serbia-Montenegro and the Ukraine have no
members of AISE. As AISE is a European trade association, companies in these countries may
belong to other (national) associations. AISE contact details in the different countries are presented
in Annex 4.

Table 20
Summary of AISE membership information
Association /
Number of
Number of
Number active in
AISE member
members
SMEs1
consumer product
domain
Czech Republic
7
1
4
Hungary 19
11
13
Romania 16
1
15
Slovenia 21
13
20
Slovak Republic
?
?
?
Austria 17
10
8
Germany 128
99
75
Note 1. SME = small / medium sized enterprise
Source: http://www.aise-net.org/downloads/members2006.pdf

UNDP/GEF DANUBE REGIONAL PROJECT

Conclusions and recommendations
page 54
6. CONCLUSIONS AND RECOMMENDATIONS

The work undertaken has demonstrated that a high proportion of phosphate-based detergents is
used in Danube River Basin (DRB) countries, except in Germany and Austria, where virtually all
domestic laundry detergents are phosphate-free. The proportion of phosphate-free detergents used
in the remainder varies from negligible to about 75%, with the majority of countries using less
than 10% P-free.
Consequently there is considerable scope for reducing phosphate inputs into DRB waters by
reducing the amount used in detergents in DRB countries.
Austria has achieved P-free detergent use through a voluntary agreement, whilst Germany has
used a combination of legislative and voluntary measures with the full co-operation of the
detergent industry and involvement of the public.
The Czech Republic has recently introduced legislation and does not need to be considered for
further action.
Although Slovenia uses a significant proportion of P-free detergents (about 75%), it has recently
experienced a significant increase in the use of phosphate-based detergents; therefore it should be
monitored and further action considered if appropriate.
The following, remaining countries, together accounting for about three quarters of the DRB
population, must be considered for action to achieve reductions in phosphate-based detergents:
>
Bosnia-Herzegovina
>
Bulgaria
>
Croatia
>
Hungary
>
Moldova
>
Romania
>
Serbia-Montenegro
>
Slovakia
>
Ukraine
Among these countries, Romania should receive priority because it currently has virtually no
phosphate-free detergents on the market and yet constitutes the biggest single contribution to the
DRB in terms of its population (about 26%). In contrast, Hungary and Serbia-Montenegro already
have a significant proportion of P-free detergents (>50%), but they are significant in terms of their
population and, hence, detergent usage.
It may be worthwhile to follow developments in Moldova, where a combination of measures
(legislation, incentives and public involvement) are planned to promote reductions in the use of P-
based detergents.
It must be noted that in many cases the information is incomplete and problems with the definition
of `phosphate-free' and different approaches to product labeling have given rise to uncertainties.
Another difficulty was the contradictory information at times between product labels (as examined
on supermarket shelves) and manufacturers' information. Overall, large multinational detergent
manufacturers were not particularly co-operative.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 55
It was not possible to obtain any information on production costs of phosphate-free detergents,
because the industry was not prepared to reveal any such information. However, Zeolite A has
previously been shown to be a viable alternative to phosphate and is used successfully in many
countries, including the DRB countries, Germany and Austria. The main adverse effect of
abandoning the use of phosphates in detergents is expected to be on the phosphate industry, but
not on the detergent industry, which should be able to adjust detergent formulation and
production.
Similarly, the information gathered on costs to consumers was inadequate for a thorough statistical
assessment, but has not indicated any evidence of higher costs of phosphate-free detergents.
Voluntary agreements without legislative backing are unlikely to be successfully established, and in
particular, to be maintained in the Danube River Basin (RBD) countries where action is needed.
This is partly because these countries have little experience in the field of voluntary agreements,
but would be likely to follow EU legislation, if this were to be put in place. Large multinational
detergent manufacturers also seem to prefer to wait for legislation, rather than enter into voluntary
agreements. Moreover, there is a considerable risk of other manufacturers or suppliers, not having
signed up to the agreement, expanding their market position with P-based detergents, either
through production or imports.
These difficulties have been exemplified by the Czech experience, where a voluntary agreement
has recently been replaced by legislation, because of failure of the voluntary agreement due to the
emergence of `free-riders'. Similarly, Slovenia has recently seen significant increases in P-based
detergents (the market was virtually P-free in 2000, although no voluntary agreement was in
place).
It is therefore quite clear that the best way forward would be to introduce a ban or restrictions on
phosphate in detergents through EU legislation. The current Regulation on detergents
(EC/648/2004) provides an opportunity through Article 16, to review the need and to propose
legislation if considered appropriate. The review is under the responsibility of EC Directorate
General Enterprise and Industry and a report (funded by the phosphate industry) has recently been
published. Developments will need to be monitored.
Nevertheless, if appropriate EU legislation is not forthcoming in the near future, it may still be
worth attempting to enter into voluntary agreements, since even partial success could usefully
contribute to reductions in phosphate in the DRB. Probably a more promising option would be to
persuade national governments to introduce national legislation.
It may be beneficial to hold a workshop, for example in the high priority country Romania, to
inform stakeholders and to explore the best way forward.
In any case it will be important to liaise closely with the appropriate government department in
each country concerned and to maintain a dialogue with the industry and relevant trade
associations. In addition, it will be important to promote public debate and involvement, and to
monitor compliance with any agreements or legislation, possibly with assistance from NGOs.
Whilst it is recognised that other actions, such as improved urban waste water collection and
treatment, as well as `good agricultural practices' are necessary complementary actions, the study
has shown clearly that there is ample scope for contributing to a successful resolution of the
problem of eutrophication, by replacing phosphate detergents with phosphate-free detergents,
thereby reducing the total phosphate burden in the DRB.
UNDP/GEF DANUBE REGIONAL PROJECT

References
page 56
REFERENCES

COM(2004)134 Report from the Commission to the European Parliament and the Council pursuant
to Article 9 of Commission Recommendation 98/480/EC of 22 July 1998 concerning good
environmental practice for household laundry detergents.
http://europa.eu.int/eur-lex/en/com/cnc/2004/com2004_0134en01.pdf

COM(2003)644 Proposal for a Regulation of the European Parliament and of the Council concerning
the Registration, Evaluation, Authorisation and Restriction of Chemicals (Reach), establishing a
European Chemicals Agency and amending Directive 1999/45/EC and Regulation (EC) {on
Persistent Organic Pollutants}
http://europa.eu.int/eur-lex/en/com/pdf/2003/com2003_0644en.html

Commission Decision 2003/200/EC establishing revised ecological criteria for the award of the
Community Eco-label to laundry detergents and amending Decision 1999/476/EC, Official Journal
L76 22 March 2003.
http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_076/l_07620030322en00250039.pdf

Commission Decision 2003/31/EC establishing the ecological criteria for the award of the
Community Eco-label to detergents for dishwashers and amending Decision 1999/427/EC, Official
Journal
L9 15 January 2003.
http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_009/l_00920030115en00110025.pdf

Commission Recommendation 98/480/EC concerning good environmental practice for household
laundry detergents, Official Journal L215, 1 August 1998
http://europa.eu.int/eur-lex/pri/en/oj/dat/1998/l_215/l_21519980801en00730075.pdf

Commission Recommendation 89/542/EEC for the labelling of detergents and cleaning products,
Official Journal L291, 10 December 1989
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc
=31989H0542&model=guichett

Council Decision 2005/342/EC establishing revised ecological criteria for the award of the
Community Eco-label to hand dishwashing detergents, Official Journal L115 4 May 2005.
http://europa.eu.int/eur-lex/lex/LexUriServ/site/en/oj/2005/l_115/l_11520050504en00090034.pdf

Council Decision 2005/344/EC establishing ecological criteria for the award of the Community eco-
label to all-purpose cleaners and cleaners for sanitary facilities, Official Journal L115 4 May 2005.
http://europa.eu.int/eur-lex/lex/LexUriServ/site/en/oj/2005/l_115/l_11520050504en00420068.pdf

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 57
Council Directive 73/404/EEC on the approximation of the laws of the Member States relating to
detergents, Official Journal L347, 17 December 1973
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc
=31973L0404&model=guichett

Council Directive 73/405/EEC on the approximation of the laws of the Member States relating to
methods of testing the biodegradability of anionic surfactants, Official Journal L347, 17 December
1973
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc
=31973L0405&model=guichett

Council Directive 82/242/EEC on the approximation of the laws of the Member States relating to
methods of testing the biodegradability of non-ionic surfactants and amending Directive
73/404/EEC, Official Journal L109, 22 April 1982
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc
=31982L0242&model=guichett

Council Directive 82/243/EEC amending Directive 73/405/EEC on the approximation of the laws of
the Member States relating to methods of testing the biodegradability of anionic surfactants,
Official Journal L109, 22 April 1982
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc
=31982L0243&model=guichett

Council Directive 86/94/EEC amending for the second time Directive 73/404/EEC on the
approximation of the laws of the Member States relating to detergents, Official Journal L80,
25 March 1986.
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc
=31986L0094&model=guichett

Council Directive 91/271/EEC concerning urban waste-water treatment, Official Journal L135,
21
May
1991.


http://europa.eu.int/eur-lex/lex/LexUriServ/LexUriServ.do?uri=CELEX:31991L0271:EN:HTML.

Council Directive 2000/60/EC establishing a framework for Community action in the field of water
policy, Official Journal L327, 22 December 2000.


http://europa.eu.int/eur-
lex/pri/en/oj/dat/2000/l_327/l_32720001222en00010072.pdf.

Council and European Parliament Regulation EC/648/2004 of 31 March 2004 on detergents, Official
Journal of the European Union
, L 104/1-35.

Council and European Parliament Resolution (1997) of 17 July 1997. Official Journal C286,
22 September 1997.
UNDP/GEF DANUBE REGIONAL PROJECT

References
page 58

Council and European Parliament Resolution (1997a) of 7 October 1997, Official Journal C321,
22 October 1997.

Council Regulation EC/1980/2000 on a revised Community eco-label award scheme, Official Journal
L237 21 September 2000
http://europa.eu.int/eur-lex/pri/en/oj/dat/2000/l_237/l_23720000921en00010012.pdf

Dalkmann H, Bongardt D, Rottman K and Hutfilter S, 2005: Review of Voluntary Approaches in the
European Union, Wuppertal Institute for Climate, Environment and Energy, Report 2, December
2005, ISSN 1862-1953.

DaNUbs (March 2005) Nutrient Management in the Danube Basin and its Impact on the Black Sea,
Report No: EVK1-CT-2000-00051, Project Duration: 01.02.2001 ­ 31.1.2005
http://danubs.tuwien.ac.at/

Decision No. 2455/2001/EC of the European Parliament and of the Council of 20 November 2001
establishing a list of priority substances in the field of water policy and amending Directive
2000/60/EC, Official Journal of the European Union, L 331/1-5.

ENDS Europe Daily (2006) Sweden tightens up with phosphates ban, issue no. 2135, 11/07/2006,
www.endseuropedaily.com

ENDS Europe Daily (2006a) France wants beefed-up EU detergent ecolabel, issue no. 2193,
26/10/2006, www.endseuropedaily.com

ENDS Europe Daily (2006b) Voluntary agreement rules "need strengthening", issue no. 2206,
16/11/2006, www.endseuropedaily.com

European Commission (2005) Sixth Annual Survey on the Implementation and Enforcement of
Community Environmental Law 2004.
http://europa.eu.int/comm/environment/law/pdf/6th_en.pdf


European Environment Agency (EEA) (2005) Source apportionment of nitrogen and phosphorus
inputs into the aquatic environment.

Glennie, EB., Littlejohn, C., Gendebien, A., Hayes, A., Palfrey, R., Sivil, D. and Wright K. (2002)
Phosphates and alternative detergent builders, Final Report for EU Environment Directorate, Ref.
UC 4011, WRc plc, Frankland Road, Blagrove, Swindon, Swindon SN5 8YF, UK .

Higley et al, 2001: Higley C J, Convery F and Lévęque, F, Voluntary Approaches: An Introduction,
in CAVA International Policy Workshop on the Use of Voluntary Approaches, Brussels, 2001.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 59

ICPDR DABLAS (2004) Evaluation of Policies,, Regulation and Investment Projects in the Danube
River Basin Countries in line with EU Directives and Regulation, DABLAS Final Project Report
http://www.icpdr.org/icpdr-pages/dablas.htm

ICPDR (International Commission for the protection of the Danube River) JAP (Joint Action
Programme) (2001-2005) for the Danube River Basin, January 2001 to December 2005)
http://www.icpdr.org/icpdr-pages/pub_programmes.htm

ICPDR (International Commission for the protection of the Danube River) (2004) The Danube River
Basin District River basin characteristics, impact of human activities and economic analysis required
under Article 5, Annex II and Annex III, and inventory of protected areas required under Article 6,
Annex IV of the EU Water Framework Directive (2000/60/EC) Part A ­ Basin-wide overview Short:
"Danube Basin Analysis (WFD Roof Report 2004)".

ICPDR (International Commission for the protection of the Danube River) (2005) The Danube River
Basin District. River basin characteristics, impact of human activities and economic analysis
required under Article 5, Annex II and Annex III, and inventory of protected areas required under
Article 6, Annex IV of the EU Water Framework Directive (2000/60/EC).

Ijjas, Istvan Professor, (no date) Reducing Phosphorus in the Danube Basin. Department of Water
Resources Engineering, Budapest University of Technology, Hungary.

Madariaga, B. M. de, Ramos, M. J., and Tarazona, J. V. (2006) Model implementation and
quantification of the eutrophication risk associated to the use of phosphates in detergents, Phase I:
Development of a generic river basin model for quantifying the eutrophication risk associated
phosphors emissions, INIA and Green Planet Consulting, Spain, September 2005 (kindly provided
by Stephen Pickering of Directorate General Enterprise and Industry, Unit G.2).

Madariaga, B. M. de, Ramos, M. J., Mateos, M. and Tarazona, J. V. (2005) Development of an
European quantitative eutrophication assessment of polyphosphates in detergents, Final Study
Report, INIA (Spain) and Green Planet Research, Green Planet Research Report GPR-CEEP-06-02-
Final, October, 2006.

Popovici, M. (2003) Issue paper on the rationale for a phosphate ban in detergents, International
Commission for the Protection of the Danube River (ICPDR) (Draft ­1, IC/WD/173, 24-Oct-2003).

Umweltbundesamt (UBA) (2004) Informationen rund um Wasch- und Reinigungsmittel,
www.umweltbundesamt.de/uba-info-daten/daten/wasch/trends.htm (last updated, 20.12.2004).
UNEP, 2000: Voluntary Initiatives: Current Status, Lessons Learnt and Next Steps ­ UNEP
Discussion Paper, Paris September 2000.


UNDP/GEF DANUBE REGIONAL PROJECT


Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 61
ANNEXES

ANNEX 1
INDIVIDUAL COUNTRY DETERGENT POLICY ­
RESULTS FROM QUESTIONNAIRE

ANNEX 2
TEMPLATE FOR INDIVIDUAL COUNTRY
DETERGENT POLICY AND USE QUESTIONNAIRE

ANNEX 3
EXAMPLES OF VOLUNTARY AGREEMENTS ­
CZECH REPUBLIC AND REPUBLIC OF IRELAND

ANNEX 4
AISE MEMBER ASSOCIATIONS IN DANUBE
COUNTRIES




UNDP/GEF DANUBE REGIONAL PROJECT


Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 63

ANNEX 1

INDIVIDUAL COUNTRY DETERGENT POLICY ­ RESULTS FROM
QUESTIONNAIRE

















UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 64
INFORMATION FROM QUESTIONNAIRES
Austria
Status of EU Legislation
Ref. Nr.
Title
Body
Status in
Present status Comments
responsible for 20002
implementation
Directive
Biodegradability



73/404/EEC as of detergents
amended
Recommendation Labelling of




89/542/EEC
detergents
Regulation
On detergents Federal



648/2004/EC
(degradability Ministry for
and labelling)1 Agriculture,
Forestry,
Environment
and Water
Recommendation Good




98/480/EC
environmental
practice for
household
detergents
Directive
Urban Waste




91/271/EEC
Water
Treatment
Directive
Directive
Water




2000/60/EC
Framework
Directive
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)

Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Is a Additional information
review planned?
/ comments





Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 65
Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates
Freiwillige
Notice of
Detergent Producing Existing Successful
Verzichtserklä abandonment Industry, not to use P
rung
(voluntary
in household laundry
Waschmittel agreement), detergents
Eco-labelling
Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1 Details
of
Is the agreement
Overview of its
agreement2
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
If no voluntary agreement has been made ­ What has prevented this?
What do you think is needed in your country for an effective voluntary agreement to
be established?

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 66
Bosnia-Herzegovina
Status of EU Legislation
Ref. Nr.
Title
Body
Status in
Present status Comments
responsible for 20002
implementation
Directive
Biodegradability



73/404/EEC as of detergents
amended
Recommendation Labelling of




89/542/EEC
detergents
Regulation
On detergents



648/2004/EC
(degradability
and labelling)1
Recommendation Good




98/480/EC
environmental
practice for
household
detergents
Directive
Urban Waste


Transposed in
91/271/EEC
Water
the draft Law
Treatment
on water, that
Directive
is to be
Directive
Water


adopted by

2000/60/EC
Framework
responsible
Directive
bodies soon
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC -
enters into force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)

Existing legislation and policies
Name Main
aims/issues
Is this still in force? Is a Additional information
addressed
review planned?
/ comments
Water Laws
To achieve good status 1998 Water Laws of
It has to be
of water bodies and
FBiH and RS are
emphasized that a vast
improve in that sense
currently in force. Laws majority of the
water management. The are different for both
decrees, regulations
Water Law deals with
entities and not efficient and instructions which
use and protection of
with regard to water
could ensure operative
water and contains
protection.
functioning of the 1998
provisions on permits,
Therefore, the new
Water Laws have not
legal procedures,
entity Laws on
yet been adopted.
international standards, protection of waters
It was envisaged that
and conditions for water were passed (in 2002 in the new law on water
use.
RS and in 2003 in FBiH). come in effect by the
But, these laws are not end of June 2005, but
harmonized particularly it was not happened.
with regard to
Namely, the
implementing
government refused to
institutions. Coming into adopt the law.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 67
Name Main
aims/issues
Is this still in force? Is a Additional information
addressed
review planned?
/ comments
effect for both of these Drafting of bylaws that
laws has been
shall accompany the
postponed, until
new law on water will
adoption of the new
take a long time, and
entity laws on water.
in the meantime there
The draft new law on
is no regulation such
water is to be adopted as Regulation of
soon. The draft law has Threshold
been developed in scope Concentrations of
of the EU funded "River Harmful and
Basin Management
Dangerous Materials
Programme". The new
that may be found in
law follows the
Processed Waters, etc.
guidelines of the EU

Water Framework
Directive.
Regulation on
Threshold values for
Currently in force
No binding provisions
Harmful Substances harmful substances not
on phasing-out P-
not to be Discharged to be discharged
containing detergents?
into Waters
Law on physical
Urban planning,
Not in force any more.
planning
environmental
There is new law on
protection and land,
physical planning that
water and air protection covers only urban
planning maters.
Regulations on
Wastewater quality
Currently in force
Effective since 1998
Types, Manner and
standards, method for
Scope of
analysis and taxation
Measurement,
mechanisms
Investigation of Used
and Discharged
Polluted Waters
Regulations of



Threshold
Concentrations of
Harmful and
Dangerous Materials
that may be found in
Processed Waters
Regulations of



Threshold
Concentrations of
Harmful and
Dangerous Materials
that may be
Discharged to the
Recipient after
Treatment
Regulations of



Threshold
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 68
Name Main
aims/issues
Is this still in force? Is a Additional information
addressed
review planned?
/ comments
Concentrations of
Harmful and
Dangerous Materials
that may be
Discharged onto
Agricultural Land
Framework
Integrated

Effective since 2002 in
Environmental Law environmental permits
RS and since 2003 in
FBiH

Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1 Details
of
Is the agreement
Overview of its
agreement2
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
If no voluntary agreement has been made ­ What has prevented this?
Bosnia and Herzegovina presents special difficulties concerning the establishment of
international agreements. Acceptance of international agreements is exclusively under
competence of state level authorities, but implementation is under competence of entity level
bodies.
There is ongoing activity on establishing of state level EPA, as well as state level "umbrella law".
This activity is supported by international community, which gives good chances to succeed in
practice.
From practical point of the view, a lot of problems will be solved by establishing state level
authority, including those related to voluntary agreements establishing.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 69
What do you think is needed in your country for an effective voluntary agreement to
be established?
Both of ministries engaged in environmental protection are faced with two main
problems:
- Lack of human resources
- Lack of financial means.
Ministries have been established in 1997 on entity level, as departments in spatial planning
ministries, with only few employees.
One of the most repeated statements in B&H is desperately needed institutional strengthening,
which understands increasing of employees and also their additional education.
Regular financing of environmental sector is insufficient, based on the budget.
Concerning effective voluntary agreement to be established practice and experience of other
countries, especially those from the region, could be very useful.
Organising of training courses, for employees in environmental institutions will be useful.
Active co-operation with international bodies, at first line ICPDR in order to prepare conditions
for implementation of international rules in the country.
Developing of relations with neighbouring countries, especially with SEE countries.

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 70
Bulgaria
Status of EU Legislation
Ref. Nr.
Title
Body responsible
Status Present
Comments
for implementation in
status
20002
Directive
Biodegradability of
Ministry of



73/404/EEC as detergents
Environment and
amended
Water of Bulgaria
Recommendation Labelling of
Ministry of



89/542/EEC
detergents
Environment and
Water of Bulgaria
Regulation
On detergents
Ministry of



648/2004/EC
(degradability and
Environment and
labelling)1
Water of Bulgaria
Recommendation Good environmental Ministry of



98/480/EC
practice for
Environment and
household detergents Water of Bulgaria
Directive
Urban Waste Water Ministry of

Transitional 8 year transitional
91/271/EEC
Treatment Directive Environment and
period, until 2015
Water of Bulgaria
Directive
Water Framework
Ministry of



2000/60/EC
Directive
Environment and
Water of Bulgaria
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)
Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Additional information /
Is a review planned? comments
Environmental
Environmental management
Effective since 1991
Protection Law
Water Law
Provides activities for

Effective since 2000.
integrated water resources
Realised at National level
management and their
by the Council of Ministers
sustainable use. Includes
and MOEW; and at basin
protection of water from
level by the River Basin
pollution
Directorate
Water Users
Law will set rules for the

Act passed on 22 March
Association Act
exploitation of water and use
2001
of drainage systems by the
Water Users Association
Bulgarian Water


Act
Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments




WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 71
Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the
Overview of its
agreement success/failure
existing or
planned?
Dates
National Ecolabeling
It is voluntary
The agreement


Scheme in accordance scheme awarding an between competent
with Regulation (EC) attractive ecolabel authority and
No 1980/2000 of the logo for products,
manufacture.
European Parliament which are generally Products that meet
and of the Council of better choice for the strict ecological and
17 July 2000 on a
environment.
performance criteria
revised Community
are awarded with the
Eco-label Award
ecolabel.
Scheme
Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc
Other Voluntary Commitments
Name Type1
Details of agreement2
Is the
Overview of its
agreement
success/failure
existing or
planned?
Dates
National Eco-environment Voluntary The agreement between


Auditing Scheme in
scheme competent authority and
accordance with Regulation
organisation which has an
(EC) No 761/2001 of the
impact on the environment.
European parliament and of
National Eco-environment
the council of 19 March
Auditing Scheme certified
2001 allowing voluntary
organisations have committed
participation by
themselves to evaluating and
organisations in a
improving their environmental
Community eco-
performance and providing
management and audit
relevant information to the
scheme (EMAS)
public.
Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?

If no voluntary agreement has been made ­ What has prevented this?

What do you think is needed in your country for an effective voluntary agreement to
be established?

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 72
Czech Republic
Status of EU Legislation
Ref. Nr.
Title
Body responsible Status in
Present status Comments
for
20002
implementation
Directive
Biodegradability Ministry of the
Act No.
Act No.
Methods for
73/404/EEC as of detergents Environment
157/98 on
356/2003 on assessment of
amended
chemical
chemical
detergents
Recommendation Labelling of
substances
substances and biodegradability,
89/542/EEC
detergents
and chemical chemical
their labelling
preparations preparations as and restrictions
and related
amended and for use
regulations
related
regulations
Regulation
On detergents Ministry of the

Amendment to Methods for
648/2004/EC
(degradability Environment
the Act. No.
assessment of
and labelling)1
356/2003 is at biodegradability,
present in
of detergents,
Parliament
labelling and
restrictions for
use. Establishes
competent
authority
responsible for
reporting in line
with Regulation
648/2004/EC
Recommendation Good
Not covered
Not covered
Not covered

98/480/EC
environmental
practice for
household
detergents
Directive
Urban Waste
Ministry of

Water Act No. Full compliance
91/271/EEC
Water
Agriculture/Minis
254/2001 Coll. in 2010
Treatment
try of
and related
Directive
Environment
regulations and
Act No.
274/2001 on
water Supply
and Sewage
Systems Coll.
Directive
Water
Ministry of

Water Act No.
2000/60/EC
Framework
Agriculture/Minis
254/2001 Coll.
Directive
try of
and related
Environment
regulations
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 73
Existing legislation and policies
Name Main
aims/issues
Is this still in force? Additional information
addressed
Is a review
/ comments
planned?
Water Act 254/2001
Full transposition of
In force

Coll. and related
requirements of WFD and
regulations
basis of the Czech water
legislation
Act. 274/2001 Coll. on Covers area of drinking
In force

Water Supply and
water supply and collection
Sewerage systems and and waste water treatment
related regulations
Public Health act
Regulates rights and duties In force

258/2000 Coll. and
of physical and legal
related regulations
persons on the field of
public health support and
establishes network of
public health protection
bodies. Among others
delimits requirements for
drinking water.
Act No. 356/2003 Coll. Methods for assessment of In force

on chemical
biodegradability ,of
substances and
detergents, labelling and
chemical preparations restrictions for use.
as amended and
related regulations
Planned Legislation and Policies
Name
Main aims/issues addressed
Expected date to Additional
come into force
information /
comments
Amendment to the Act Establishes competent authority October 2005
At present in
No. 356/2003 Coll. on responsible for reporting in line
Parliament
chemical substances
with Regulation 648/2004/EC
and chemical
and covers issues emerged in
preparations as
connection with the Czech
amended
Republics EU membership.
Amendment of the
The amendment restricts the use In negotiation

Ministry of
of phosphates in washing
Environment
powders on 0,5 % by weight.
Regulation on lists of
dangerous chemical
substances and
dangerous chemical
preparations No.
221/2004 Coll.

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 74
Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its success/failure
existing or planned?
Dates
Agreement
Voluntary Goal of the
Existing. Agreement
Decrease of phosphates in
between the
agreement Agreement and its
was concluded in 1995 laundry detergents from 9,000 t
Czech
amendment was
and its amendments in in 1995 to 5,065 t in 2003 was
Association of
gradual decrease in
1998 and 2001.
the result of the Agreement.
producers of
amount of phosphates
The member companies of
Soaps,
and other substances
Association offered in the
Cleaning
in water. Since 1st
market compact, phosphate-
Agents and
January 2005 the
free as well as phosphate
Detergents and
Association has placed
containing detergents. In the
the Ministry of
on the market only
year 2003 36.6% of phosphate-
the
phosphate-free
free laundry detergents has
Environment on
washing powders. Full
been sold from the overall
gradual
text of Agreement on
amount of detergents produced
decrease in
the Ministry of the
by the Association members.
environmental
Environment website
Since the 1st of January 2005
impact of
www.env.cz/AIS/web.
members of Association do not
detergents
nsf/pages/voda_ochra
sell laundry detergents
na (only in Czech).
containing phosphates. From
this point of view the goal of
the Agreement has been met.
Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc
Other Voluntary Commitments
Name Type1
Details of agreement2
Is the agreement
Overview of its
existing or planned?
success/failure
Dates
Voluntary
Voluntary
Full text of Voluntary
Existing. Signed in
From 2005 all dental
agreement
agreement
Agreement on the Ministry of December 2001
workplaces are
between the
the Environment website
outfitted with the
ministry of the
www.env.cz/AIS/web.nsf/pag
effective amalgam
Environment and
es/voda_ochrana (only in
separators. This
the Czech Dental
Czech).
regulation eliminates
Chamber on
the discharge of
reducing the
mercury into the
environmental
sewer systems and
burden caused by
prevents
mercury from
contamination of
dental health-care
treatment plant
facilities.
sludge.
Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 75
Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
Yes, it has been successful.
From the 1st of January 2005 members of Association do not sell laundry detergents containing
phosphates. Since the year 2000 the increase of number of phosphate containing detergents
from other producers than Association members has been observed. SETUZA a.s. stepped out of
the Association in 2003. The share of non-member producers on the market is not negligible at
present as it was in time of signing of the Agreement. In the year 2004 their share was
estimated at about 40% and in the year 2005 it is 50% of all producers (see Annex 3). With the
aim to reduce the impact of laundry detergents on waters in the Czech Republic it has been
decided to control the content of the phosphorus in detergents through the Amendment of the
Ministry of Environment Regulation No. 221/2004 Coll. stipulating the list of dangerous
substances and dangerous chemical means introduction of which into the market, distribution or
use is prohibited or limited. This measure is in line with the EC Regulation No. 684/2004 of the
European Parliament and of the Council of the 31st of March 2004 on detergents, Art. 14.
Nevertheless, the measure does not cover the whole category of detergents in sense of EC
Regulation No. 684/2004, but only laundry detergents. According to our information it is not
possible to modify the whole spectrum of detergents to phosphate-free detergents because of
missing technologies. Hence, also after the approval of above mentioned Amendment to the
Ministry of Environment Regulation it will be possible to produce industrial cleaning and dish
washing agents with content of phosphorus, but it will be not possible to produce laundry
detergents with content of phosphorus of more than 0.5% of weight.

If no voluntary agreement has been made ­ What has prevented this?

What do you think is needed in your country for an effective voluntary agreement to
be established?


UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 76
Croatia
Status of EU Legislation
Ref. Nr.
Title
Body responsible for Status in Present
Comments
implementation
20002
status
Directive
Biodegradability Ministry of Econ.,


n/a
73/404/EEC as of detergents Labour and
amended
Entrepreneurship
Recommendation Labelling of
Ministry of Econ.,


n/a
89/542/EEC
detergents
Labour and
Entrepreneurship
Regulation
On detergents Ministry of Econ.,


n/a
648/2004/EC
(degradability Labour and
and labelling)1 Entrepreneurship
Recommendation Good
Ministry of Econ.,


n/a
98/480/EC
environmental Labour and
practice for
Entrepreneurship
household
detergents
Directive
Urban Waste
Ministry of


See note 3
91/271/EEC
Water
Agriculture,
Treatment
Forestry and Water
Directive
Management
Directive
Water
Ministry of


Approach basically
2000/60/EC
Framework
Agriculture,
accepted for
Directive
Forestry and Water
incorporation into
Management
national
legislation. CARDS
2003
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)
Note 3: Based on CARDS 2003 Project Preparation of Draft strategy and action plan for
approximation of Croatian legislation with EU Water Aquis which is ready for tendering draft a
Strategy and Action Plan for approximation of the Croatian water legislation with EU Water
Aquis as supporting tool that shall assist in planning of legal transposition and implementation
of the EU Water Aquis in Croatian national legislation. CARDS 2003 should be finished in 2007.

Existing legislation and policies
Name Main
aims/issues
Is this still in force? Is Additional information
addressed
a review planned?
/ comments
Water Pollution
Manages water in
Yes

Control Plan (OJ
accordance with the
8/99)
principle integrity of the
river system and principle
of sustainable development
The Water Act (OJ Provides framework for
Yes, Review in 2005
Permits must be issued
107/95)
new regulations in water
for chemicals and
pollution control, and
derivatives which get
water quality control in
into water after use.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 77
Name Main
aims/issues
Is this still in force? Is Additional information
addressed
a review planned?
/ comments
compliance with EU
Only existing
regulations and
mechanism that can be
international conventions
directly used regarding
P-containing
detergents
Water Management
Yes

Financing Act (OJ
107/95)
Ordinance on Water Defines: water quality,
Yes

Classification (OJ
methods of sampling/
77/98)
analyzing and methods of
defining/ presenting water
classification, ambient
quality standards
Ordinance on
Defines substances
Yes Includes:
biological
Hazardous
forbidden to be discharged
non-suspended
Substances in
into waters; substances
detergents, surface
Water (No. 78/98) that can be discharged but
active substances,
only at a maximum
inorganic phosphorous
permissible level
compounds,
elementary
phosphorous
Regulations on the Defines obligation of water Yes

issuing of water
management permits for
management
detergents
consents and
permits (OJ 28/96)
Regulation on the Defines the limit values of Yes

discharge of
hazardous and other
hazardous and
substances discharged in
other substances
different category of
into water (OJ
effluents.
44/99)
Environmental
Protection of natural
Yes

Protection Act (OJ sources on levels not
82/94)
harmful for human, plants
and animals

Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 78
Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?

If no voluntary agreement has been made ­ What has prevented this?

What do you think is needed in your country for an effective voluntary agreement to
be established?

-
Assistance from ICPDR
-
Training workshop
-
Capacity building of the institutions
-
Improvement in the legal system dealing with environmental issues

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 79
Germany
Status of EU Legislation
Ref. Nr.
Title
Body
Status in
Present status Comments
responsible for 20002
implementation
Directive
Biodegradability of



73/404/EEC as detergents
amended
Recommendation Labelling of




89/542/EEC
detergents
Regulation
On detergents




648/2004/EC
(degradability and
labelling)1
Recommendation Good




98/480/EC
environmental
practice for
household
detergents
Directive
Urban Waste Water



91/271/EEC
Treatment
Directive
Directive
Water Framework



2000/60/EC
Directive
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)

Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Is a Additional information
review planned?
/ comments
Washing and
To be reviewed to


Cleansing Agents implement Regulation
Act of 1975 and 648/2004/EC, which shall
1986
enter into force 8 October
2005
Ordinance on
Review planned 2007(?)


Maximum
because of Regulation
Amounts of
648/2004/EC Article 16
Phosphates in
(1)"By 8 April 2007, the
Washing and
Commission shall evaluate,
Cleansing Agents submit a report on and,
of 1980
where justified, present a
legislative proposal on the
use of phosphates with a
view to their gradual phase-
out or restriction to specific
applications."

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 80
Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1 Details
of
Is the agreement Overview of its
agreement2
existing or
success/failure
planned? Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
If no voluntary agreement has been made ­ What has prevented this?
What do you think is needed in your country for an effective voluntary agreement to
be established?



WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 81
Hungary
Status of EU Legislation
Ref. Nr.
Title
Body
Status in
Present status Comments
responsible for 20002
implementation
Directive
Biodegradability Ministry of
Processing.
Active

73/404/EEC as of detergents Environment
Transposed in
amended
and Water
2001
(KvVM)
Recommendation Labelling of
Ministry for
Adopted in
Active

89/542/EEC
detergents
Economics and 1998
(handout)
Transport
(GKM)
Regulation
On detergents Ministry of
Government
Still not in

648/2004/EC
(degradability Environment
decree only on force
and labelling)1 and Water
duties of
(KvVM)
Member states
Recommendation Good
Not applicable - - -
98/480/EC
environmental in Hungary
practice for
household
detergents
Directive
Urban Waste
Ministry of
Adopted


91/271/EEC
Water
Environment
Treatment
and Water
Directive
(KvVM)
Directive
Water
Ministry of
Adopted in


2000/60/EC
Framework
Environment
2004
Directive
and Water
(KvVM)
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)

Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Is a Additional information
review planned?
/ comments
6/2001.

Still in force. 6/2001
6/2001 has no
ministerial
ministerial decree will be restriction on the P
decree on
replaced by a
content of detergents
detergents
government decree on
(amended by
detergents on 2005. The
5/2004)
government decree will
regulate the duties of
Member states (record
keeping, notification,
information, control
measures, etc)

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 82
Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments

Currently there is no
Before 8th October
It will regulate the
regulation on P content. By 2005
duties of Member
8 April 2007, the
States according to
Commission shall evaluate,
REGULATION (EC) No
submit a report on and,
648/2004 OF THE
where justified, present a
EUROPEAN
legislative proposal on the
PARLIAMENT AND OF
use of phosphates with a
THE COUNCIL of 31
view to their gradual phase-
March 2004 on
out or restriction to specific
detergents
applications.

Voluntary Commitments relating to P reduction in detergents
Name Type1 Details
of
Is the agreement
Overview of its
agreement2
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1 Details
of
Is the agreement Overview of its
agreement2
existing or
success/failure
planned? Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
No voluntary agreements
If no voluntary agreement has been made ­ What has prevented this?
Industry waits for the report of the EU phosphate situation (opinion of the secretariat
of the Hungarian Cosmetic and Home Care Association)
What do you think is needed in your country for an effective voluntary agreement to
be established?

Improvement in the legal system: to establishment of the legal basis of the voluntary
agreements.
Further more: clear environmental target on the subject (concrete goal how the
voluntary agreement can be effective on the quality of the environment)
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 83
Moldova
Status of EU Legislation
Ref. Nr.
Title
Body
Status in Present status
Comments
responsible for 20002
implementation
Directive
Biodegradability Ministry of
Not yet
Not yet adopted
None
73/404/EEC as of detergents Ecology and
adopted
amended
Natural
Resources
Recommendation Labelling of
Ministry of
Not yet
There is a
None
89/542/EEC
detergents
Ecology and
adopted Regulation on
Natural
obligatory product
Resources
declaration and
labelling
Regulation
On detergents Ministry of
Not yet
There are no legal None
648/2004/EC
(degradability Ecology and
adopted acts and regulations
and labelling)1 Natural
regarding special
Resources
features of
detergent quality
Recommendation Good
Ministry of
Not yet
Not yet adopted
There is no
98/480/EC
environmental Ecology and
adopted
experience in
practice for
Natural
Moldova of
household
Resources
developing
detergents
"codes of good
environmental
practices" of the
sort envisaged
by the Directive
Directive
Urban Waste
Ministry of
Not yet
There is no similar See note 3
91/271/EEC
Water
Ecology and
adopted normative act within
Treatment
Natural
the Moldovan
Directive
Resources
legislative corpus.
The provisions of
the Directive are
spread in several
Moldovan legal acts
Directive
Water
Ministry of
Not yet
There was
There is no made
2000/60/EC
Framework
Ecology and
adopted developed a set of an obvious
Directive
Natural
recommendations
progress towards
Resources
towards
approximation so
approximation of
far
Moldovan Water
quality legislation
to the EU legislation
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)
Note 3: General provisions for municipal wastewater discharges were identified as follows:
·
The level of treatment should take into account local conditions, e.g. the use of the
treated effluent, possibly blended with surface water run-off, for industrial and
agricultural supply.
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 84
·
In order to achieve the required ambient water quality in relation to individual
substances. For example, the treatment level for raw municipal wastewater should be
calculated from the size of the population and the assumptions of emission rate per
person (in grams per day) as: phosphates P2O5 (3.3 g/day, including 1.6 g/day from
detergents); detergents (2.5 g/day). For a population served by a non-canalised
system, each of these values should be reduced by 33%.

Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Is a Additional information
review planned?
/ comments
Water Pollution Manages water in
In force

Control Plan
accordance with the principle
integrity of the river system
and principle of sustainable
development
The Water Code Provides framework for new In force since 1993;
Defines obligation of
regulations in water
modified and added -
water management
pollution control, and water 2003
quality control
Environmental
Protection of natural sources In force

Protection Act

Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1 Details
of
Is the agreement Overview of its
agreement2
existing or
success/failure
planned? Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 85
Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
No voluntary agreements
If no voluntary agreement has been made ­ What has prevented this?
The main reasons are lack of relevant laws/ regulations and other legal acts, and
insufficient understanding and knowledge on the issue; Socio-economic barriers;
What do you think is needed in your country for an effective voluntary agreement to
be established?
Introducing a system of P-control for the time being should be made on an ad hoc
basis, with the donor countries starting negotiations with governments on conditions
about P-removal for the financing of industrial plants in the most sensitive areas, if
applicable.
Needed:
-
Improvement in the legal system dealing with environmental issues
-
Improvement of environmental education
-
Assistance from ICPDR

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 86
Romania
Status of EU Legislation
Ref. Nr.
Title
Body responsible for
Status in
Present status Comments
implementation
20002
Directive
Biodegradability Ministry of Economy and In force since In force

73/404/EEC as of detergents
Commerce ­ National
November
amended
Authority for Consumer 2001
Protection; Ministry of (Governmental
Environment and Water Decision
Management ­ Local
527/2001)
Recommendatio Labelling of
Environment Authorities In force since In force

n 89/542/EEC
detergents
March 2000
(Governmental
Decision
745/1999)
Regulation
On detergents




648/2004/EC
(degradability
and labelling)1
Recommendatio Good




n 98/480/EC
environmental
practice for
household
detergents
Directive
Urban Waste
Ministry of Environment Not in force in In force (new
See note 3
91/271/EEC
Water Treatment and Water Management 2000;
Governmental
Directive
­ National
Transposed in Decision
Administration "Apele
March 2002
352/2005 which
Romane"; Ministry of
(Governmental amends the GD
Public Administration
Decision
188/2002)
188/2002)
Directive
Water
Ministry of Environment Not in force in In force since
Progress in
2000/60/EC
Framework
and Water Management 2000; Law
July 2004
line with
Directive
­ National
310/2004 for
the EU
Administration "Apele
modification
countries
Romane"
and
amendment of
the Water Law
107/1996
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)
Note 3: For the protection of the Black Sea and the Danube Delta against eutrophication,
Romania has committed to designate all territory as being sensitive area.
Romania has obtained transition period:
- sewage network
31 December 2013 for agglomerations with more than 10 000 p.e.
31 December 2018 for agglomerations between 2000 ­ 10000 p.e.
- urban waste waters treatment stations;
31 December 2015 for agglomerations with more than 10 000 p.e. ­ nutrient removal (tertiary
treatment);
31 December 2018 for agglomerations between 2000 ­ 10000 p.e. ­ biological treatment.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 87

Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Is Additional information
a review planned?
/ comments
Environmental
Environmental management Law 137/1995 ­ in

Protection Law
force since 1995 -
which was reviewed by
the Government
Ordinance 90/2003
Water Law
It provides principles,
In force since 1996 ­ Actually, the Romanian
objectives and policies for
Water Law 107/1996 Water Law is in line
integrated water resources
which was amended by with the requirements
management and their
the Law 310/2004
of the Water
sustainable use. It includes
Framework Directive
protection of water against
pollution
Discharge norms The Governmental Decision
In force
The 2 standards, NTPA
352/2005 which amends the
001 and 002, have
GD 188/2002 contains 2
been in force since
discharge standards:
1997.
NTPA 001 includes limit
values for the main pollutants
discharged into water
resources. Also, the
parameters "Anion-active
surfactants" and
"Phosphates" have thresholds
in this standard.
NTPA 002 provides thresholds
for some pollutants
discharged into the urban
sewage network, including for
detergents and phosphates.
Ecolabelling
The Governmental Decision
In force

1530/2004 concerning the
setting up the criteria for
assigning of ecologic label for
dishwasher detergents

Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 88
Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1 Details
of
Is the agreement Overview of its
agreement2
existing or
success/failure
planned? Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
No voluntary agreement
If no voluntary agreement has been made ­ What has prevented this?
Socio-economic barriers
Lack of legislative measures or other incentives
Lack of support for establishing agreements
Insufficient understanding and knowledge on the issue
What do you think is needed in your country for an effective voluntary agreement to
be established?

Improvement in the legal system dealing with environmental issues
Better internal (i.e. ministry) communication

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 89
Serbia-Montenegro
Status of EU Legislation
Ref. Nr.
Title
Body
Status in
Present
Comments
responsible 20002
status
for
implementa
tion
Directive
Biodegradability


No such Regulation or
73/404/EEC as
of detergents
legal act
amended
Recommendation Labelling of



There is a Regulation on
89/542/EEC
detergents
obligatory product
declaration
Regulation
On detergents


See note 3
648/2004/EC
(degradability
and labelling)1
Recommendation Good



No such act or regulation
98/480/EC
environmental
or recommendation. The
practice for
only existing standards
household
are concerning analytical
detergents
methods for quality
examination and
detergent efficiency
Directive
Urban Waste


No such All measures and long-
91/271/EEC
Water
legal act term plans on building
Treatment
UWWT plants are stated
Directive
in the Water Master Plan
for Serbia (2002);
National Program with
Action Plans according to
the Law on
environmental protection
is yet to be drafted
Directive
Water


Transition Planned schedule for
2000/60/EC
Framework
al
approximation 2005
Directive
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)
Note 3: It is stated by the Law on environmental protection " ..the production is not acceptable
unless it fulfils the environmental quality standards and product quality standards..." but there
are no specific legal acts or regulations concerning the product ­ detergent quality or the BAT in
detergent industry.

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 90
Existing legislation and policies
Name Main
aims/issues
Is this still in
Additional information /
addressed
force? Is a review comments
planned?
Environmental
Environmental

A new law, adopted in December
Protection Law
management - general
2004, in accordance with
European legislation. By-laws and
other legal acts are still needed in
order to make the law effective.
IPPC Law
It is in accordance with
Adopted in Dec. 2004, permits
IPPC Directive
are to be issued at the latest by
2015 (there is a Program and
time schedule for harmonizing
industrial sectors with this law)
EIA Law
Concerning

Adopted in Dec. 2004
environmental impact
assessment
Law on Water
Generally concerning
A new Law on
According to the existing Law,
water protection,
Water (in
water protection is generally
protection against
accordance with based on emission monitoring;
devastating effects of
WFD) is prepared there are no emission standards
water and water
and in the
management (from1996) process of
adoption

Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 91
Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
No voluntary agreement
If no voluntary agreement has been made ­ What has prevented this?
· Lack of appropriate lows and regulations
· Lack of appropriate instruments to put in force the existing regulations
· Poor economic status of the country
· Many companies are undergoing the privatization process
· Among the detergent producers there is a good general knowledge on the issues like
detergent biodegradability and phosphate caused problem to the environment, as well
as on new technologies and BAT
What do you think is needed in your country for an effective voluntary agreement to
be established?

· improvement in the legal system
· better internal communication
· capacity building

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 92
Slovak Republic
Status of EU Legislation
Ref. Nr.
Title
Body responsible Status in
Present
Comments
for
20002
status
implementation
Directive
Biodegradability of



73/404/EEC as detergents
amended
Recommendation Labelling of




89/542/EEC
detergents
Regulation
On detergents




648/2004/EC
(degradability and
labelling)1
Recommendation Good




98/480/EC
environmental
practice for
household
detergents
Directive
Urban Waste Water



91/271/EEC
Treatment
Directive
Directive
Water Framework



2000/60/EC
Directive
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)

Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Is a Additional information
review planned?
/ comments





Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 93
Other Voluntary Commitments
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
If no voluntary agreement has been made ­ What has prevented this?
What do you think is needed in your country for an effective voluntary agreement to
be established?

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 94
Slovenia
Status of EU Legislation
Ref. Nr.
Title
Body
Status in
Present status Comments
responsible for 20002
implementation
Directive
Biodegradability



73/404/EEC as of detergents
amended
Recommendation Labelling of




89/542/EEC
detergents
Regulation
On detergents



648/2004/EC
(degradability
and labelling)1
Recommendation Good




98/480/EC
environmental
practice for
household
detergents
Directive
Urban Waste




91/271/EEC
Water
Treatment
Directive
Directive
Water




2000/60/EC
Framework
Directive
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)

Existing legislation and policies
Name
Main aims/issues addressed Is this still in force? Is a Additional information
review planned?
/ comments





Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 95
Other Voluntary Commitments
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
If no voluntary agreement has been made ­ What has prevented this?
What do you think is needed in your country for an effective voluntary agreement to
be established?

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 96
Ukraine
Status of EU Legislation
Ref. Nr.
Title
Body
Status in
Present Comments
responsible for 20002
status
implementation
Directive
Biodegradability


The Law of Ukraine On
73/404/EEC as of detergents
the State Program of
amended
Adaptation of the
Recommendation Labelling of



Legislation of Ukraine to
89/542/EEC
detergents
EU Legislation (N 1629-IV
Regulation
On detergents


of 18.03.2004):
648/2004/EC
(degradability
environmental sector was
and labelling)1
determined as one of
Recommendation Good



priority sectors for
98/480/EC
environmental
approximation of national
practice for
legislation to the EU
household
legislation. National legal
detergents
acts in this area will be
harmonised with EU by
2008. No specific
measures undertaken
Directive
Urban Waste



See note 3
91/271/EEC
Water
Treatment
Directive
Directive
Water
Ministry for


The Directive is translated
2000/60/EC
Framework
Environmental
in Ukrainian; the
Directive
Protection of
provisions of the Directive
Ukraine
are taking into account
during development of
new legal acts and
regulation
Note 1: Brings together and replaces 73/404/EEC as amended, and 89/542/EEC - enters into
force 8. October 2005
Note 2: As stated in Annex 8.2 Transposal or adoption (year)
Note 3: There are few national regulations in this area, which are not harmonised with Directive
91/271/EEC, including:
·
Resolution of the Cabinet of Ministers "On the approval of the Rules of the protection of
surface waters against pollution by return waters" (25.03.1999 N 465-99);
·
Rules of taking-up the waste waters of enterprises into communal and sectoral
sewerage systems of settlements of Ukraine (approved by the State Committee on
Housing and Communal Service of Ukraine, 19.02.2002 N 37; registered by the
Ministry of Justice 26.04.2002 N 403/6691);
·
Resolution of the Cabinet of Ministers "On the procedure of development and approval
of norms maximum allowable discharge of polluting substances and list of substances
to be regulated during discharge" (11.09.1996 N 1100-96);
·
Resolution of the Cabinet of Ministers "On the approval of the Rules for the
determination of normative fees for pollution of the natural environment and collection
of these fees" (01.03.1999, No 347)

WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 97
Existing legislation and policies
Name
Main aims/issues addressed
Is this still in force? Additional
Is a review planned? information /
comments
Law on Environmental
Framework law , which
The Law is in force.
Protection (1991)
determines, among others:
Its provisions were
-Objectives and principles of
detailed in many
environmental protection
other laws and sub-
-Competencies of central, regional legal acts.
and local governmental authorities
-Mechanisms of prognostication,
monitoring and information in the
field of environmental protection;
-Obligatory requirement of
environmental expertise for any
activities influencing the
environment;
-Ecological standards and norms;
-Control and supervision of
environmental protection;
-Regulation of nature resources
usage;
-Economic mechanism of
environmental protection incl
pollution control);
-Mechanisms of environmental
emergency response;
-Liability for violation of
environmental legislation and
regulation;
Water Code of Ukraine
The Code constitutes legal
Some Articles of the Related EU
(1995)
framework for
Water Code
Directive:
- management of water protection correspond to the EU Principles of the
- rational use of water for the
regulation (e.g., The EC Water Policy
population and economic activities Code introduces the (draft, 4/12/96)
- restoration of water resources
Basin principle of
- protection of waters from
water management.)
pollution, littering and depletion
but in general the
- prevention of accidental water
Code is not
pollution and floods and
harmonised
elimination of their consequences Amendments to the
- improving the condition of water Code have been
bodies
approver by number
- protection of rights of
of laws during
enterprises, institutions,
1996-2004
organisations and citizens.
Law on Drinking Water
The Law is to provide legislative,

Related EU
and Drinking Water
economic and organisational
Directive: On
Supply (2002)
framework for the sustainable
water Quality for
operation of the drinking water
Human
supply system aimed at ensuring
Consumption
that the population is supplied with
(80/778/EEC)
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 98
Name
Main aims/issues addressed
Is this still in force? Additional
Is a review planned? information /
comments
needed quantity and quality of
safe drinking water. Centralised
water supply system and its
components are not available for
privatisation.
The Law on the State
The Program determines set of
Recently approved

Program "Drinking Water provisions aimed at the
National Program,
of Ukraine" for 2006-
improvement of water supply for which complemented
2020, (03.03.2005)
population in terms of adequate
and to some extend
quality and quantity;
replaced relevant
reconstruction and development of parts of other
the water supply / sewage
national programs
network; rehabilitation, protection approved in the
and sustainable use of the water
past.
sources.
The Program of
The Program is aimed at the

Related EU
Development of Water
rehabilitation and improvement of
Directives:
Supply and Sewerage
an effectiveness of water supply /
Pollution Caused
Sector (Resolution of the sewerage system.
by Certain
Cabinet of Ministers
Dangerous
1269 of 17.11.1997)
Substances,
Discharged into
Water Bodies
(76/464/EEC);
Urban
Wastewater
Treatment
(91/271/EEC)
Main Directions of State Defines key priorities of
As a policy

Policy on the
Environmental Policy and Practical document, it is still
Environmental Protection, Actions, includes obligations to
valid but some
Utilization of Natural
nutrient pollution reduction
provisions are
Resource and
outdated and require
Environmental Safety
revisions
(1998)
On the State Program of The Program is aimed at the
The Program

the Development of
implementation of national policy envisages practical
Water Economy
concerning the improvement of
implementation of
(17.01.2002)
qualitative water supply to
the basin principle of
population and national economy, water management.
resolution of environmental and
water-resources problems,
establishments of the conditions
for sustainable functioning of
water economy complex.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 99
Name
Main aims/issues addressed
Is this still in force? Additional
Is a review planned? information /
comments
Law on sanitary and
The Law: determines the rights
Not harmonised with
epidemiological Security and duties of governmental
EU regulations
of the Populations (1994) authorities, enterprises,
organisations and citizens in the
field of sanitary-epidemiological
regulations;
- establishes the procedures and
state surveillance of sanitary-
epidemiological services;
-Introduces the licensing of all
activities with potential impact of
human health (including those in
water sector).
On the approval of State The Program (adopted by Law) is ICZM and pollution
Program of Protection
aimed at the development of the
control of coastal
and Rehabilitation of the policy, strategy and action plan to and marine
Environment of the Black prevent anthropogenic damage of environment are
and Azov Seas (2001)
the Black and Azov Seas
among key
environment, rehabilitate the
components of the
Biodiversity and natural resources, programs
and promote sustainable
development of the region.

Planned Legislation and Policies
Name
Main aims/issues addressed Expected date to come Additional information
into force
/ comments





Voluntary Commitments relating to P reduction in detergents
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

Other Voluntary Commitments
Name Type1
Details of agreement2 Is the agreement
Overview of its
existing or planned? success/failure
Dates





Note 1: e.g. voluntary agreement, eco-labelling, incentive scheme
Note 2: Who is the agreement between, what does it address etc

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 100
Barriers to the Implementation of Voluntary Agreements
If a voluntary agreement has been made in the past ­ Has it been successful? What
have the benefits been?
No voluntary agreement
If no voluntary agreement has been made ­ What has prevented this?
Environmental Voluntary agreements as a tool of co-regulation, which is
complementary to the traditional command-and-control approach, are not used in
Ukraine. Possible reasons are:
- Environmental issues in reality are not on the top of governmental priorities due to
domination of the goals of economic recovery and growth;
- Current legislation and regulation (first of all, economic mechanisms) do not promote
voluntary commitments (implementation of such commitments requires additional
financial implications);
- Institutional constrains (no association of producers of laundry detergents
established in Ukraine, lack of co-operative relations with corresponding governmental
bodies)
- Lack of knowledge and understanding on such instruments among producers and
governmental bodies ;
- Lack of encouraging incentives from the Ministry for Environmental Protection and
other relevant governmental institutions
What do you think is needed in your country for an effective voluntary agreement to
be established?
To introduce Voluntary agreements practice in Ukraine the following measures would
be helpful:
- Improving communication and establishing mutually beneficial (or at least working)
relations between producers and relevant ministries (first of all, with the Ministry for
Environmental Protection)
- Appropriate informational campaign to raise awareness, share knowledge and
increasing the understanding of the benefits from such instruments for both sides
(including producers and governmental regulating institutions); in this regard, any
assistance from experienced institutions of EU countries (in form of training,
workshops etc.) would be helpful;
- Revision of appropriate legal and regulation acts in order to provide legal support of
voluntary incentives
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 101
Laundry detergents produced by Association in Czech Republic in 2000, 2001, 2002 , 2003







Product
universal color compact special content of phosphate








Colon/Dosia (bio,citrus)
X



phosphate

Colon/Dosia color

X


phosphate








Colon/Dosia bio
X



Phosphate-free

Colon/Dosia gel
X

X

Phosphate-free








Lanza bílá
X



phosphate

Lanza color

X


phosphate

Lanza rucka prásek



X
phosphate








Lanza gel
X

X

Phosphate-free








Lanza tabs
X

X

Phosphate-free

Lanza rucka tekutá



X
Phosphate-free








Lovela/Woolite prásek



X
phosphate

Lovela/Woolite Balsam liquid


X
X
Phosphate-free








Lip tekutý


X
X
phosphate

Lip prásek



X
Phosphate-free








Woolite-porst. na praní jemn.prádla



X
Phosphate-free








Clarax plus
X



Phosphate-free

Titan
X



phosphate

Titan
X



Phosphate-free








Product
universal color compact special content of phosphate








Merkur
X



phosphate








Mýdlové Toto



X
phosphate

Mýdlová Hanka



X
Phosphate-free








Namo



X
Phosphate-free








Persil
X



Phosphate-free

Persil color

X


Phosphate-free

Persil gel
X

X

Phosphate-free

Persil color gel

X
X

Phosphate-free

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 1: INDIVIDUAL COUNTRY DETERGENT POLICY
page 102
Laundry detergents produced by Association in Czech Republic in 2000, 2001, 2002 , 2003







Product
universal color compact special content of phosphate















Palmex
X



Phosphate-free

Palmex color

X


Phosphate-free

Palmex gel
X

X

Phosphate-free

Palmex color gel

X
X

Phosphate-free








Rex
X



Phosphate-free

Rex color

X


Phosphate-free








Perwoll



X
Phosphate-free

Perwol tekutý


X
X
Phosphate-free








Ariel tekutý
X
X
X

Phosphate-free

Ariel pwd
X
X


phosphate








Tide/ Tix
X
X


phosphate








Bold 2 v 1
X
X


phosphate








Product
universal color compact special content of phosphate








Bonux
X
X


phosphate


WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 103

ANNEX 2

TEMPLATE FOR INDIVIDUAL COUNTRY DETERGENT POLICY AND
USE QUESTIONNAIRE

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 2: Template for individual country detergent policy
page 104
Detergent Use in Danube River Basin (DRB) Countries -
Template for Individual Country Detergent Policy and Use

This template is in 2 sections. Section 1 deals with information relating to existing and
planned policies, legislation and voluntary commitments. Existing information has been
extracted from Annex 8.2 of the DRP Project Brief (Phase 2) ­ entitled "Existing and
planned Policies and Legislation Relation to Pollution Control and Nutrient Reduction"
(2000). Please update the existing information (which is based on information collected in
or before 2000) and provide additional information where requested.

Section 2 deals with information regarding the usage, import and export of phosphorus
containing and phosphorus free detergents. The Annex suggests further questions to
detergent manufacturers; it would be helpful if answers to these could also be obtained.

Country name

Consultant responsible for the

questionnaire
Contact details

Completion date



Summary

To be completed by the Consultant once all information has been obtained














WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 105
1
EXISTING AND PLANNED POLICIES, LEGISLATION AND VOLUNTARY
COMMITMENTS

1.1 STATUS OF EU LEGISLATION

Please identify progress with transposal into national legislation of the following Directives and Regulations, and adoption of
the Recommendations:
Directive/ Regulation/
Title
Ministry or national Status in 2000 (as
Present status
Comments
Recommendation No.
body responsible
stated in Annex 8.2)


for implementation

Non-EU countries:
Transposal or
Proposed progress towards
adoption (year)
approximation
Directive 73/404/EEC
Biodegradability of detergents



as amended
Recommendation
Labelling of detergents




89/542/EEC
Regulation
On detergents (degradability




648/2004/EC
and labelling) - brings
together and replaces
73/404/EEC as amended, and
89/542/EEC - enters into force
8. October 2005)
Recommendation
Good environmental practice




98/480/EC
for household detergents
Directive 91/271/EEC
Urban Waste Water Treatment



Directive
Directive 2000/60/EC
Water Framework Directive





UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 2: Template for individual country detergent policy
page 106
1.2 OVERVIEW OF NATIONAL LEGISLATION AND POLICIES

Please complete and update this information with details of the measures ­ existing and planned - specifically addressing the reduction
of phosphate in laundry detergents (focus on domestic laundry detergents)

Existing legislation and policies
Name

Main aims/issues addressed by
Is this still in force? Is a review
Additional
policy/legislation (with
planned? Provide details
information/comments
particular reference to
phosphate in detergents)

















Planned legislation or policies
Name
Main aims/issues addressed by
Proposed dates for
Additional
policy/legislation (with
implementation
information/comments
particular reference to
phosphate in detergents)

















WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 107
1.3 VOLUNTARY
COMMITMENTS

Please provide details of any existing or planned voluntary commitments, incentives or other initiatives dealing with
the reduction of phosphate in laundry detergents. Please also provide details of any other voluntary commitments
dealing with general environmental issues, if available.

Name Type
(e.g.
Details of
Is the agreement If an existing agreement, please
voluntary
agreement (i.e.
existing or
provide a brief overview of its
agreement,
who is the
planned. Please
success/failure, with reasons.
ecolabelling,
agreement
give dates (note
incentive
between, what
2)
scheme)
does it address
etc). See note 1.

1. Relating to P reduction in detergents











2. Relating to any other environmental issues










Note 1. If possible, please provide a copy of the agreement, or a link to where a copy can be found.
Note 2. If existing ­ when was the agreement made, if proposed, when will it be agreed?
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 2: Template for individual country detergent policy
page 108

1.4 BARRIERS ON THE IMPLEMENTATION OF VOLUNTARY
AGREEMENTS

Please provide your views on what the current or future barriers are to establishing
voluntary agreements and how you think these can be overcome in order to
implement a successful agreement for the reduction of phosphate in detergents.

Please indicate whose views these are.

Question
Response

If a voluntary agreement has been made in

the past ­ Has it been successful? What
have the benefits been?








If no voluntary agreement has been made ­
What has prevented this? For example:
·
Institutional barriers?
·
Socio-economic barriers?
·
Have relied on legislative measures or
other initiatives (such as incentives)?
·
You do not feel that voluntary
agreements are effective?
·
Lack of support for establishing
agreements?
·
Insufficient understanding and
knowledge on the issue?
·
Other reasons (please state).
What do you think is needed in your country
for an effective voluntary agreement to be
established? For example:
·
Capacity building of the institutions?
·
Improvement in the legal system
dealing with environmental issues?
·
Better internal (i.e. ministry)
communication?
·
Ministerial reform?
·
Assistance from ICPDR?
·
Training workshop?
·
Other? Please state


WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 109
2 DETERGENT
USE
Please state the source of information for each reply (or table), e.g.
(1) National government statistics
(2) Detergent industry / association statistics
(3) Independent market research organisation statistics

2.1 OVERALL
DETERGENT
USE

Year to which data applies

Laundry detergents
(domestic and in launderettes)

Total laundry detergent usage (tonnes/year)

% of detergent that is phosphate-free

(<0.2% phosphate)
Total population (million)

Total number of households (million)

Average use of laundry detergent (g/person/day)

Average use of laundry detergent (g/household/day)
% of households with washing machines

% of washing machines of the top loading design

Is there a difference between top and front loaded machines, in terms of the
type of detergent used or the amount? Please describe.









Industrial detergents
Total industrial detergent usage (tonnes/year)

% of industrial detergent that is phosphate-free

(<0.2% phosphate)


Dishwasher detergents

Total dishwasher detergent usage (tonnes/year)

% of dishwasher detergent that is phosphate-free

(<0.2% phosphate)
% of households with dishwashers



UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 2: Template for individual country detergent policy
page 110
2.2 MANUFACTURERS AND SUPPLIERS OF LAUNDRY DETERGENTS

Note: if the information is more easily available in terms of percentage market share
(for the whole country), this information and the total use can be used instead to
estimate the amount of each brand.

Year to which data applies

Used in the country
Name of
Country of
Phosphate free
Phosphate-based
manufacturer/
manufacture
(<0.2%
supplier
phosphate)
Brand
Amount
Brand
Amount
Phos-
name
used
name
used
phate
(t/year)
(t/year) content
(%)


























































Made in the country and exported to non-Danube countries
Name of
% of total
Phosphate free
Phosphate-based
manufacturer/
production
(<0.2% phosphate)
supplier
Brand
Amount
Brand
Amount
Phos-
name
exported
name
exported
phate
(t/year)
(t/year)
content
(%)

























































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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 111
2.3 BRAND DESCRIPTIONS AND PRICES

Year to which data applies

Please provide the following information for the leading phosphate-based and
phosphate-free (<0.2% phosphate) brands

Brand
Phosphate- Phosphate-
Type / purpose1 Price
range2
name
free
based
Euro/kg
(<0.2%
(%
phosphate) phosphate)
yes/no








































Note 1. For example 90oC wash, coloured wash, hand wash
Note 2. Typical shop prices

Exchange rate local currency to Euros

How were the price ranges estimated?











UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 2: Template for individual country detergent policy
page 112
Annex: Additional questions for the detergent manufacturers:


1. What is the percentage difference between the production costs for
phosphate-free (<0.2% phosphate) and phosphate containing detergents?
2. What are the reasons for any difference in costs (e.g. raw material costs,
processing costs, production volume ­ please specify which and the
significance of each in %)?
3. Would the unit cost decrease to that of phosphate containing detergents if the
production volume increases to the current production of phosphate
containing detergent?
4. Is there a difference in selling price for the phosphate-free (<0.2% phosphate)
and phosphate containing detergent for the same application and if yes what
are the reasons for any difference in price between phosphate-free (<0.2%
phosphate) and phosphate containing detergents?
5. Have you discovered a difference in washing performance of domestic
laundry between the use of front loaded and top loaded machines for
phosphate containing and phosphate-free (<0.2% phosphate) detergents? If
yes, what are the differences?
6. Are any investment costs required to move from phosphate containing
detergents to alternative builders, e.g. zeolite? If yes what is the approximate
cost per tonne of detergent produced?

Please summarise any information below:





















WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 113
ANNEX 3

EXAMPLES OF VOLUNTARY AGREEMENTS ­ CZECH REPUBLIC
AND REPUBLIC OF IRELAND

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 3: Examples of voluntary agreements ­ Czech Republic and Republic of Ireland
page 114
CZECH AGREEMENT ON DETERGENTS
Full text of the voluntary agreement closed between
CSDPA and the Ministry of the Environment on 22 March 1995:
Agreement
closed in the sense of § 51 of the Civil Code as amended between
Czech Soap and Detergent Products Association, with seat in Prague 10, V Olsinách 75,
represented by RNDr. Ing. Miloslav Handl, Chairman of the Czech Soap and Detergent
Products Association /hereinafter "Association"/
and
Ministry of the Environment of the Czech Republic, with seat in Prague 10, Vrsovická 65,
represented by Ing. Vladimír Novotný, the First Deputy Minister /hereinafter "ME CR"/
have decided to enter into the Agreement on gradual reduction of impact of laundry
detergents on the environment.
I.
Subject of Agreement
1. The subject of the Agreement is a reduction of undesirable influence of used laundry
detergents on the environment, particularly on a quality of surface water, determination of
limits of contents of ingredients in these detergents, and further, determination of
recommended procedures for the lowering of these limits.
2. This Agreement relates to laundry detergents for small-scale consumers, i.e. to laundry
detergents supplied by domestic manufacturers or importers, the members of the Association,
into retail network.
II.
Members of Association
The Association was entrusted by its members, all being main producers or importers of
laundry detergents who perform their business activity in the territory of the Czech Republic,
with execution of this Agreement. List of the Association´s members bound by this Agreement
is attached.
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 115
III.
Limits of Detergent Ingredients
The members of the Association voluntarily undertake to maintain maximum level content of
ingredients in their laundry detergent products supplied into retail network as stated below:
a) Phosphate detergents
EDTA max. 0,1 % (w/w)
NTA max. 4,0 % (w/w)
Polycarboxylates max. 6,0 % (w/w)
Phosphorus in total max. 5,5 % (w/w)
b) Phosphate-free detergents
EDTA max. 0,1 % (w/w)
NTA max. 4,0 % (w/w)
Polycarboxylates max. 6,0 % (w/w)
Inorganic Phosphorus max. 0,1 % (w/w)
Alkylphosphonates as phosphorus max. 1,0 % (w/w)
IV.
Compact Detergents
1. The Association and ME CR /hereinafter "contracting parties"/ are in agreement in stating
that compact detergents can make a significant contribution to a decrease in the pollution of
the environment, as they are distinguished by a decreased filler content, a decreased
consumption of chemicals during laundering and decreased packaging and transport
requirements.
2. The contracting parties therefore, for the sake of environmental protection, shall make their
further effort to promote the compact detergents in the consumer market of the Czech
Republic.
3. The Association shall support a promotion of the compact detergents in order to increase
their part in total consumption in the Czech Republic.
V.
Surfactant Biodegradability
The members of the Association undertake to ensure that anionic and non-ionic surfactants
used in laundry detergents comply with the requirements for biodegradability according to the
EC directives, valid at the time of execution of this Agreement.
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 3: Examples of voluntary agreements ­ Czech Republic and Republic of Ireland
page 116
VI.
Consumers´ Information
The Association underlines its readiness and willingness to closely co-operate in activities
aimed at improving the environmental consciousness of the consumers, for example by
participation in the National Programme for Ecolabelling.
The attention shall be particularly paid to proper information of consumers about all the
aspects of the use of laundry detergents. The Association shall ensure its activities by
distributing information materials for consumers, organizing of special seminars and
supporting educational events organized by ME CR.
VII.
Joint Evaluation of Agreement´s Fulfilment
The contracting parties agreed to organize annual meetings in order to evaluate Agreement´s
fulfilment. Both parties shall prepare respective documents for such meetings. The first
evaluation shall be completed by the end of November, 1995.
VIII.
Observance of Agreement´s Principles
1. The Association professes to the principle of self-control. To minimise the chances of
distribution of products which are not in compliance with the principles mentioned herein the
Association shall call upon its members to install appropriate monitoring system of
consumer´s market in the Czech Republic.
2. After evaluation of information pursuant to the Section 1 of this Article, the contracting
parties shall take necessary steps to support aims of this Agreement or, as the case may be,
they will propose corrections to this Agreement for the purpose of the further limitation of the
undesirable influences of phosphate-containing laundry detergents on the environment.
IX.
Further Provisions
1. The contracting parties are aware of the fact that all laundry detergent products for retail
network manufactured or imported by the members of the Association prior to the effective
date can be marketed without any limitation set forth by this Agreement.
2. This Agreement in no way authorizes the Association to co-ordinate the competitive
behaviour of its members on the market.
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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 117
X.
Termination of Agreement
In case of a material breach of this Agreement by the Association, ME CR can terminate this
Agreement. The withdrawal notice period is one month, and must be sent in writing to the
address of the Association. The notice period begins on the first day of the month following
the month in which the notice was delivered.
XI.
Final Provisions
All changes or amendments of this Agreement must be made in written form based on
agreement of both contracting parties.
This Agreement is executed in two copies and each party shall receive one copy.
This Agreement comes into effect 3 month after the execution day.


Prague, 22 March 1995
Ing. Vladimír Novotný
RNDr. Ing. Miloslav Handl
The First Deputy Minister
Chairman of the Czech Soap and
Ministry of the Environment of the Czech
Detergent Products Association
Republic


UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 3: Examples of voluntary agreements ­ Czech Republic and Republic of Ireland
page 118
Attachment to the voluntary agreement:
The list of founding members of the Czech Soap and
Detergent Products Association

Name of the Company
Seat of the Company
Represented by
SETUZA a.s.
Zukovova 100
Ústí nad Labem
Ing. RNDr. M. Handl
UNILEVER CR, spol. s r.o. V Olsinách 75
Praha 10
Dr. A. Steinbrecher
PROCTER and GAMBLE,
Karlovo nám. 7
v.o.s.
Praha 2
William D. Harter
HENKEL CR, spol. s r.o.
Stpánská 33
Praha 1
Ch. Poschik
BENCKISER, spol. s r.o.
Vorsilská 8
Praha 1
Milan K. De Millan
(Note : current list of the Association´s members - see separate page)



WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 119
Full text of the Supplements to the voluntary agreement signed by the
contracting parties on 23 June 1998:

SUPPLEMENT No. 1
to the Agreement on gradual reduction of impact of laundry detergents on the environment
of 22 March 1995
closed on the date set below between
Czech Soap and Detergent Products Association,
with seat in Prague 1, Snmovní 9,
represented by Riccardo Cincotta,
Member of the Board of Directors of the Czech Soap and Detergent Products Association
(hereinafter "Association")
and
Ministry of the Environment,
with seat in Prague 10, Vrsovická 65,
represented by Ing. Michael Barchánek,
Deputy Minister of the Environment
(hereinafter "ME CR")


The Agreement on gradual reduction of impact of laundry detergents on the environment
closed on 22 March 1995 between the Czech Soap and Detergent Products Association and
the Ministry of the Environment of the Czech Republic is amended and supplemented as
follows:
1.) Following the existing Article III., a new Article IIIa. is inserted, and reads as follows:
IIIa.
Renunciation of the use of surfactants
based on adducts of alkylphenols with ethylene oxide
The members of the Association voluntarily undertake not to use surfactants based on
adducts of alkylphenols with ethylene oxide in their laundry detergents for retail network.
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 3: Examples of voluntary agreements ­ Czech Republic and Republic of Ireland
page 120
2.) The contracting parties are aware of the fact that all laundry detergents for retail network
manufactured or imported by the members of the Association prior to the date on which this
supplement becomes effective can be marketed without any limitations stipulated in this
supplement.
3.) This supplement is executed in two copies and each party shall receive one copy.
4.) This supplement comes into effect 3 month after the date of its signing by both contracting
parties.
5.) The contracting parties have read through this supplement and are in agreement with its
content, in evidence whereof they affix their signatures hereto.

Prague, 23 June 1998
Riccardo Cincotta
Ing. Michael Barchánek
Member of Board of Directors of the
Deputy Minister of the Environment
Czech Soap and Detergent Products
Association


SUPPLEMENT no. 2

To the Agreement on gradual reduction of the impact of detergents on environment
dated March 22nd, 1995
Formed on the day, month and year shown bellow between
The Czech Association of Detergent Producers,
With the registered office in Prague 1, Snmovní 9,
Represented by Ing. Ladislav Tochácek
Vice-chairman of the board of directors of The Czech Association of Detergent Producers
(hereafter the "Association")
and
The Ministry of Environment,
With the registered office in Prague 10, Vrsovická 65,
Represented by RNDr. Milos Kuzvart,
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 121
The Minister of Environment
(hereafter the "MoE")
The Agreement on gradual reduction of the impact of detergents on environment
Formed on March 22nd, 1995 between The Czech Association of Detergent Producers and
The Ministry of Environment in wording in force is being amended and supplemented in the
following way:
1.) The current article III is being supplemented by the following provision:
The members of the Association undertake with effect from 2005 for all its products the
Agreement relates to maintain the limits for the non-phosphate detergents. The limits
presented in art. III par. a) "The detergents containing phosphates" are valid until the end of
2004.
The contractual parties will discuss the gradual balance limit throughout the year 2001.
The statement about adherence to particular limits will be a part of the documents prepared
by the Association to annual assessment of performance of the Agreement.
2.) A new article III b. with the following wording is being inserted instead of the current article
III a:
III b.
Labelling the non-phosphate detergents
The members of the Association undertake new detergents introduced firstly into the market
after six month from the signing of Supplement 2 of Voluntary Agreement and complying with
the limits for the non-phosphate detergents to label e.g. "does not contain phosphate",
"phosphate-free". The same label will be after this date on the new labels all other washing
products, which fulfil the limits.

3.) The current article IV. Compact detergents is being supplemented with par.4
IV. 4. The members of the Association undertake to ensure constant presence of compact
detergents in the offer for the consumer market in the CR.
4.) The current article V. is being supplemented in this way:
In case of amendment of the EU legislation the contractual parties will within 1 year after its
approval agree on another advance in this field.
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 3: Examples of voluntary agreements ­ Czech Republic and Republic of Ireland
page 122
5.) A new article V a of the following wording is being inserted instead of the article V.
V a.
The Association will support availability of measures and aids for dosage of detergents
directly into the drum of a washing machine during purchase of detergents.
6.) The article VII is being supplemented in the following way:
As a groundwork for annual assessment the Association shall submit a list of produced or
imported detergents stating the following features:
The product contains / does not contain phosphate
The product is / is not compact
The product is aimed for colour washing / is universal
Besides the contractual parties the agreement will be assessed also by the organisations of
the non government environmental association, pertinently by other independent
oraganisations and independent experts interested in participation in the assessment. Both
contractual parties shall prepare documents for assessment which shall be submitted to all
participants of the assessment for comments at least two months prior the pursuance of the
assessment. Discussion of the comments will be part of the assessment. The result of the
assessment will be published by both contractual parties.
7.) A new article IX a of the following wording is being inserted instead of the current article
IX:
IX a.
Every subject that introduces detergents into the market of the CR or is interested in
participation in solution of the impact of detergents on environment may join the agreement in
a way agreed upon by the contractual parties.
8.) A new article XIa of the following wording is being inserted instead of the current article XI:
XIa.
Sanctions
The MoE is authorised to require the Association to pay a conventional fine in the amount of
up to CZK 1 000 000 in case of breach of the provision of art. III, IIIa. Any amount of the
potential conventional fine will be aimed and used for promotion of environmental projects
upon mutual agreement.
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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 123
9.) The contractual parties are aware of the fact that detergents aimed for retail, produced or
imported by the members of the Association prior the date this Supplement comes to force,
may be enforced in the market without restrictions determined in this Supplement.
10.) This Supplement has been formed in two copies, each of the party shall obtain one copy.
11.) This Supplement comes to force by expiration of 3 months after the date of its signing by
both of the contractual parties.
12.) The contractual parties have read this Supplement, approve of its contents and as a
proof thereof enclose their signatures.
In Prague on 23.7.2001

Ing. Ladislav Tochácek
RNDr. Milos Kuzvart
The Vice-chairman of the board of
Minister of Environment
directors of the Czech Association of
Detergent Producers

UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 3: Examples of voluntary agreements ­ Czech Republic and Republic of Ireland
page 124
IRISH AGREEMENT ON DETERGENTS

AGREEMENT
between
THE IRISH DETERGENT AND ALLIED PRODUCTS ASSOCIATION (IDAPA)
and
THE MINISTER FOR THE ENVIRONMENT AND LOCAL GOVERNMENT
concerning
THE PHASING-OUT OF THE MARKETING OF PHOSPHATE-BASED DOMESTIC
LAUNDRY DETERGENT PRODUCTS IN IRELAND
WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 125









UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 3: Examples of voluntary agreements ­ Czech Republic and Republic of Ireland
page 126


WRc plc / CESEP

Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 127
ANNEX 4

AISE MEMBER ASSOCIATIONS IN DANUBE COUNTRIES


AUSTRIA
Fachverband der Chemischen Industrie Österreichs - F.C.I.O.
Mr Christian Gründling
Wiedner Hauptstrasse 63
A-1045 Wien
Tel: +43 1 501 05 3348
Fax: +43 1 501 05 280
E-mail: gruendling@fcio.wko.at
Website: http://fcio.at
CZECH REPUBLIC
Czech Soap and Detergent Association - C.S.D.P.A.
Mr Robert Klos
U Pruhonu 10
CZ-17000 Praha 7
Tel: +420 2 201 01 172
Fax: +420 2 201 01 190
E-mail: Robert.Klos@cz.henkel.com
Website: http://www.csdpa.cz
UNDP/GEF DANUBE REGIONAL PROJECT

ANNEX 4: AISE members associations in the Danube Countries
page 128
GERMANY
Industrieverband Hygiene und Oberflächenschutz Für Industrielle und Institutionelle
Anwendung e.V. - I.H.O. -
Mr Walter Gekeler
Karlstr. 21
D-60329 Frankfurt/M
Tel: +49 69 2556 1246
Fax: +49 69 2556 1254
E-mail: iho@iho.de
Website: http://www.iho.de

Industrieverband Körperpflege- und Waschmittel e.V. (IKW)
Mr Bernd Stroemer
Karlstraße 21
D-60329 Frankfurt/Main
Tel: +49 69 25 56 13 21
Fax: +49 69 23 76 31
E-mail: bstroemer@ikw.org
Website: http://www.ikw.org
HUNGARY
Magyar Kozmetikai és Háztartás-vegyipari Szövetség - KOZMOS
Mr István Murányi
Harangvirág u. 5.
H-1026 Budapest
Tel: +36 1 363 75 59
Fax: +36 1 460 94 44
E-mail: imuranyi@axelero.hu
Website:
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Final Report ­ Recommendations for Reduction of Phosphorus in Detergents
page 129
ROMANIA
Romanian Union of Cosmetics and Detergent Manufacturers - RUCODEM -
Mrs Mihaela Rabu
Str. Mihai Eminescu, 105-107, Apt.6
RO-020073 Bucuresti S2
Tel: +40 21 210 88 85
Fax: +40 21 210 88 85
E-mail: mihaela.rabu@rucodem.ro
Website:
SLOVENIA
Association of Cosmetics and Detergents Producers of Slovenia - K.P.C. -
Mr Borut Zule
Dimiceva 13
SI-1504 Ljubljana
Tel: +386 1 58 98 262
Fax: +386 1 58 98 100
E-mail: borut.zule@gzs.si
Website:
SLOVAK REPUBLIC
Slovenské zdruzenie pre znackové výrobky (SZZV)
Dusan Plesko
Obchodná 30
811 06 Bratislava 1
Tel: +421 2 5273 1113
Fax: +421 2 5263 4234
E-mail: szzv@nextra.sk
Website:


Source: http://www.aise-net.org/downloads/members2006.pdf
UNDP/GEF DANUBE REGIONAL PROJECT