Environmental Requirements

3.1 Fitness for Purpose
Certified products should be good performers in their intended application. It is implied that certain standards of product performance are implicit in the label.

Brilliance Australia produces a cleaning cloth which is non-toxic, and approved for use in food areas. The product was approved by the New Zealand Food Safety Authority to 31.10.04, holds NSF registration from 19.07.07, and is registered with BFA

3.2 Formulation Requirements
The phosphorous load shall not exceed 25 mg/litre.
General purpose cleaners shall not be formulated or manufactured with:
- EDTA; 
- NTA;
- APEO’s;
- reactive chlorine compounds such as hypochlorite or organic chlorine carriers; 
- substances classified as carcinogenic according to the approved criteria for the classification of hazardous substances by the National Industry Chemical Notification and Assessment Scheme;
- greater than 0.1% of any ingredient that is classified or may be classified as mutagenic or tetragenic according to the approved criteria for the classification of hazardous substances by the National Industry Chemical Notification and Assessment Scheme;
- greater than 1% of any ingredient that is classified as a contact sensitiser or as a possible mutagen according to the approved criteria for the classification of hazardous substances by the National Industry Chemical Notification and Assessment Scheme

GECS have reviewed a detailed MSDS for the chemical impregnated into the cloth, and all ingredients are in compliance to the requirements of this criterion.

3.3 Solvents
General purpose cleaners must not contain:
a) Halogenated organic solvents or butoxy-ethanol;
b) volatile organic compounds in excess of 10% by weight as measured by EPA Method 24-24A, 40 C.F.R., Part 60, Appendix A (1991), or Method 18,48 Federal Register 48, no. 202, October 18, 1983 or Method 1400 NIOSH Manual of Analytical Methods, Volume 1, February 1984, or EPA Method 8240 GC/MS Method for Volatile Organics, September 1986 or as demonstrated through calculation from records of the amounts of constituents used to make the product. For product for which the label specifies dilution with water prior to use, the VOC limit shall apply only after the minimum specified dilution has taken place. The minimum specified dilution shall not include recommendations for the incidental use of a concentrated product to deal with limited special applications, such as hard to remove soils and stains.

There are no solvents used in the Brilliance Cleaning Cloth. This has been confirmed by a review of the MSDS for all ingredients used.

3.4 Fragrance
Fragrance must be produced and used in accordance with the “Code of Practice” compiled by the International Fragrance Association (IFRA).
Fragrance containing mitromusk compounds must not be used because of their cancer risk.

No fragrance is added to the Brilliance Cleaning Cloth.

3.5 Colours
Colourants used must be included on the “List of Colouring Agents Allowed for use in Cosmetic Products” in Annex IV of European Commission Directorate 76/768/EEC, 27 July 1976 on the Approximation of the Laws of the Member States relating to Cosmetic Products (OJ L 262, 7.9.1976, p 169). A copy of the Directive is available in the document “The rules governing cosmetic products in the European Union”, Volume 1 Cosmetics legislation, 1999 Edition.

There are no colourants used in the Brilliance Cleaning Cloth. This is evident from a review of the MSDS.

3.6 Consumer Information
a) The detergents must be accompanied by instructions for proper use so as to maximise product performance and minimise waste.
b) All detergents must display on the container a list of product ingredients which complies with the requirements of the EEC Commission Recommendation for Labelling of Detergents and Cleaning Products.

GECS have reviewed information available on the website, which includes instructions on how to maximise the product’s performance, as well as samples of the product, which are labelled with concise instructions. The Brilliance Australia product subject of this report meets the requirements of this criterion.

3.7 Packaging Requirements
All plastic containers and plastic components must be made of plastic that are recycled in Australia (or the country to which the product is exported and sold). 
Packaging must not be impregnated, labelled, coated or otherwise treated in a manner, which would prevent recycling (i.e. PVC sleeves, metallic labels).
All plastic packaging (i.e. container, cap, measuring devise) must have a plastic resin identification code clearly visible on each item. 
Packaging (including labels) must not contain PVC or any type of chlorinated materials.
The cardboard packaging shall consist of 70% recycled material.

The package is appropriately labelled with the recycling code, also there is a film bag and a cardboard box. GECS have reviewed a letter which states that all product packaging will be labelled with the appropriate recycling codes.