Vietnam Ecolabel Criteria for Biodegradable and Recycled Plastic Packaging
On November 7, 2023, Vietnam's Ministry of Natural Resources and Environment (MONRE) introduced an Ecolabel criterion, NSTVN - 01:2023 Environmentally Friendly Plastic Packaging, aimed at promoting sustainable production and consumption practices. This criterion focuses on environmentally friendly plastic packaging, including biodegradable and recycled plastic packaging.
Key Requirements of NSTVN - 01:2023
The criterion outlines specific requirements for biodegradable and recycled plastic packaging, emphasising the use of polyethylene (PE) or polypropylene (PP) plastic as the main raw material.
Below are the key requirements summarized in Table 1:
Biodegradable Plastic Packaging
Basic Requirements
- Products shall be manufactured at facilities complying with the Law on Environmental Protection and other relevant laws.
Technical Characteristics
- Biodegradation rate of at least 90% within 2 years in a natural environment, compost, or solid waste landfills.
Recycled Plastic Packaging
Basic Requirements
- (Raw) materials used during packaging production
- Forbidden to use additives containing substances on Vietnam’s prohibited list.
- Forbidden to use non-compliant inks, dyes, colourants, and additives per environmental and health safety regulations.
- Materials derived from cleaned recycled PE and PP plastic.
Technical Characteristics
- At least 20% of packaging materials come from recycled plastic, with a thickness of 50 µm or more, and a minimum size of 50 cm or more in each direction.
What is Ecolabel
Vietnam’s Ecolabel, as defined by the Law on Environmental Protection 2020, is a certification for environmentally friendly products and services. Circular No. 02/2022/TT-BTNMT further elaborates that Ecolabel criteria assess the entire life cycle of products and services, from raw material use to disposal. The Ecolabel indicates products causing less harm to the environment.
Difference between Ecolabel and Green Label
Companies familiar with Vietnam’s market may be familiar with Vietnam Green Label through Circular 41/2013/TT-BTNMT. Circular 19/2023/TT-BTNMT renders Circular 41/2013/TT-BTNMT invalid after December 30, 2023. Companies seeking Ecolabel certification for biodegradable plastic packaging can follow NSTVN-01:2023. Existing Green Label certifications remain valid until their expiry date.
Rights and Obligations of Ecolabel Certification
Obtaining Vietnam’s Ecolabel is voluntary, and certified organisations receive preferential policies. However, certification may be revoked if the product or service no longer meets Ecolabel criteria or if the organisation fails to fulfil specified commitments.
Vietnam’s Roadmap to Control Plastic Production and Import
In alignment with sustainability goals, Vietnam aims to phase out single-use plastic products and difficult-to-biodegrade plastic packaging in various establishments by 2030. Ecolabel certification aligns with these goals, enhancing product competitiveness and appealing to environmentally conscious consumers.
How to Apply for Ecolabel
Procedures and required materials for Ecolabel application are outlined in Decree No. 08/2022/ND-CP. Once approved, the Ecolabel certification remains valid for three years.
Taiwan's Proposed Regulations on Hydrofluorocarbons (HFCs)
On November 21, 2023, Taiwan's Ministry of Environment (MOENV) released draft regulations, "Regulations on Hydrofluorocarbons Management" and "High Global Warming Potential Greenhouse Gas Hydrofluorocarbons Regulated Under the Montreal Protocol," aiming to control the production and consumption of hydrofluorocarbons (HFCs). These drafts are open for public comments until December 12, 2023.
Background on HFCs
HFCs, widely used in various products like air conditioners, refrigerators, and aerosols, are greenhouse gases with high global warming potentials (GWPs). The Kigali Amendment, adopted on October 15, 2016, under the Montreal Protocol, aims to phase down HFCs globally.
18 Types of HFCs in Focus
The drafts propose regulating 18 types of HFCs, listed in Annex F of the Kigali Amendment. The production of these regulated HFCs will be strictly prohibited from January 1, 2024.
Proposed Restrictions on HFCs
Production Prohibition: The production of regulated HFCs is strictly prohibited from January 1, 2024.
Import/Export Approval: Companies must apply to MOENV for approval before importing or exporting regulated HFCs.
Consumption Phase-down: The drafts outline a phased reduction in HFCs consumption, starting from 100% of the baseline on January 1, 2024, and reaching 20% of the baseline by January 1, 2045.
Time Points HFCs Consumption
Since January 1, 2024 100% of the baseline
Since January 1, 2029 90% of the baseline
Since January 1, 2035 70% of the baseline
Since January 1, 2040 50% of the baseline
Since January 1, 2045 20% of the baseline
DfT Guidance - Placing Transportable Pressure Equipment in Great Britain
The UK's Department for Transport (DfT) has published guidance on placing transportable pressure equipment on the market in Great Britain, effective from January 1, 2023. The guidance outlines rules and procedures for market placement and can be accessed on the gov.uk website.
India's Ecomark Certification Rules
India's Ministry of Environment, Forest, and Climate Change (MOEFCC) notified the Ecomark Certification Rules, 2023, on October 11, 2023. This certification aims to promote environmentally friendly products, encourage manufacturers to produce Ecomark certified products, and prevent deceptive use of the Ecomark label.
Criteria for Ecomark
To receive the Ecomark, products must meet specified environmental criteria set by the Central Government. Certification from a Standards Body for quality and safety is a prerequisite. Primary criteria include aspects such as production processes, use of natural resources, environmental impact, emissions/waste, product disposal, compliance with Extended Producer Responsibility regulations, utilisation of waste and recycled materials, and substitution of hazardous substances.
Ecomark Portal
The Central Pollution Control Board (CPCB) will develop an Ecomark web portal within six months. The portal will track entities submitting applications, sales of Ecomark certified products, and registrations for producers/exporters/importers, designated Ecomark verifiers, and other entities. Registered entities must file annual implementation reports.
Compliance Verification
CPCB and Designated Ecomark Verifiers (DEVs) are eligible to verify compliance with Ecomark criteria. DEVs will conduct conformity assessments, including factory visits, sample drawing, factory audits, and recommendations for award/renewal of certification.
EU Consultation on Octocrilene
Call for Comments Deadline: January 10, 2024
The European Chemicals Agency (ECHA) has issued a call for comments and evidence on Octocrilene (EC 228-250-8, CAS 6197-30-4). The call aims to collect information on the manufacture, import, use, and market placement of octocrilene, particularly in plastisol and cosmetic products, including sunscreens.
Key Points:
- Substance Focus: Octocrilene (EC 228-250-8, CAS 6197-30-4).
- Areas of Interest: Manufacturing, import, use, and market placement of octocrilene in plastisol and cosmetic products (including sunscreens).
- Additional Information: Life cycle, environmental risks, and socio-economic impacts of a potential restriction for the specified uses are of interest.
- Deadline for Comments: January 10, 2024.
EU Biocidal Products Regulation (EU BPR) Update for Northern Ireland (NI)
Please note that the EU Biocidal Products Regulation (EU BPR) operates independently from the GB Biocidal Products Regulation (GB BPR), which applies in Great Britain.
Active Substance Approval Dates
Application Deadline: 1 February 2024
Ensure your products stay compliant on the NI market by applying for product authorization by the upcoming EU BPR active substance approval dates:
- Chrysanthemum cinerariaefolium, extract from open and mature flowers of Tanacetum cinerariifolium obtained with hydrocarbon solvents (CAS 89997-63-7 EC 289-699-3) in product type 19.
- Chrysanthemum cinerariaefolium, extract from open and mature flowers of Tanacetum cinerariifolium obtained with supercritical CO (CAS 89997-63-7 EC 289-699-3) in product type 19.
- N,N-Didecyl-N,N-dimethylammonium chloride (DDAC) (CAS 7173-51-5 EC 230-525-2) in product types 01 and 02.
If your biocidal products contain these active substances in the specified product types, ensure timely application for EU BPR product authorization to maintain their presence on the NI market.
Active Substance Renewal Submission Deadlines
Application Deadline: 28 February 2024 and 29 May 2025
Under the EU BPR, active substance approvals are subject to renewal. The 550-day deadlines for renewal applications are approaching for various active substance/product type combinations in NI. Take note of the dates for the following substances:
- 3-phenoxybenzyl(1R,3R)-2,2-dimethyl-3-(2-methylprop-1-enyl)cyclopropanecarboxylate (1R-trans-Phenothrin) in product type 18.
- bis(N-cyclohexyl-diazenium-dioxy)-copper (Cu-HDO) in product type 08.
- Iodine in product types 01, 03, 04, and 22.
- Isopropyl-(2E,4E,7S)-11-methoxy-3,7,11-trimethyl-2,4-dodeca-dienoate (S-methoprene) in product type 18.
- n-Decanoic acid (Decanoic acid) in product types 04, 18, and 19.
- n-Octanoic acid (Octanoic acid) in product types 04 and 18.
- Polyvinylpyrrolidone iodine in product types 01, 03, 04, and 22.
- 1-[[2-(2,4-dichlorophenyl)-4-propyl-1,3-dioxolan-2-yl]methyl]-1H-1,2,4-triazole (Propiconazole) in product type 07.
- 3-iodo-2-propynylbutylcarbamate (IPBC) in product type 13.
- 5-chloro-2-(4-chlorophenoxy)phenol (DCPP) in product types 01, 02, and 04.
- Potassium (E,E)-hexa-2,4-dienoate (Potassium sorbate) in product type 08.
For further details and to ensure the continuous compliance of your products, reach out to your suppliers and be informed about the renewal status of the substances crucial for your formulations.
China NIFDC Consults on Testing Methods for Toothpaste, Cosmetic Ingredients, and Toxicological Tests
On November 24, 2023, China's National Institutes for Food and Drug Control (NIFDC) initiated a public consultation on 20 draft testing methods. Stakeholders can submit comments until December 15, 2023, via hzpbwh@nifdc.org.cn.
The draft testing methods for toothpastes are as follows:
- Determination of pH in Toothpastes: Suitable for determining the pH value of toothpaste.
- Determination of Free Formaldehyde in Toothpaste: Specifies the post-column derivatization-high-performance liquid chromatography method for free formaldehyde content.
- Determination of Methanol in Toothpaste: Specifies the determination of methanol content by gas chromatography.
- Determination of Dioxane in Toothpaste: Specifies the determination of dioxane content by gas chromatography-mass spectrometry.
- Determination of Mercury in Toothpaste: Specifies two methods for determining total mercury content.
- Determination of Lead in Toothpaste: Specifies two methods for determining lead content.
- Determination of Arsenic in Toothpaste: Specifies the determination of total arsenic content.
- Determination of Cadmium in Toothpaste: Specifies the determination of total cadmium content.
- Determination of Li and 36 Kinds of Elements in Toothpaste: Specifies the determination of the content of 37 elements by inductively coupled plasma mass spectrometry.
- Oral Mucous Irritation Test: Suitable for evaluating the potential irritating effect of toothpaste on oral mucus.
- General Guidelines: Specifies basic requirements for microbiological tests.
- Aerobic Plate Count: Specifies the testing method for aerobic plate count.
- Thermotolerant Coliform Bacteria Test: Specifies the testing method for thermotolerant coliform bacteria.
- Pseudomonas Aeruginosa Test: Specifies the testing method for Pseudomonas aeruginosa.
- Staphylococcus Aureus Test: Specifies the testing method for Staphylococcus aureus.
- Molds and Yeasts Count: Specifies the testing method for molds and yeasts count.
The draft testing methods for cosmetic ingredients are as follows:
- Determination of Dioxane in Cosmetics: Specifies the gas chromatography-mass spectrometry method for determining dioxane content.
- Determination of Dimetridazole and Other 119 Kinds of Components in Cosmetics: Specifies the liquid chromatography-mass spectrometry method for Dimetridazole and 119 other components in cosmetics.
The draft testing methods for toxicological tests are as follows:
- The Safety and Technical Standards for Cosmetics (STSC) currently lack a dedicated chapter on the pretreatment of toxicological test samples for cosmetic ingredients and products, including acute inhalation toxicity tests. The introduction of the following two standards aims to complement and improve the current STSC.
- Technical Requirements for Pretreatment of Cosmetic Materials and Products in Toxicological Experiments: Specifies basic principles, requirements, and methods for the pretreatment of cosmetic materials and products in toxicological experiments.
- Technical Requirements for Pretreatment of Cosmetic Ingredients in Toxicological Experiments: Specifies basic principles, requirements, and methods for the pretreatment of cosmetic ingredients in toxicological experiments.
