Rwanda, Cook Islands and Norway have proposed to the United Nations to “avoid and minimise” many plastics chemicals. The three countries proposed to UNEP INC-4 to ban ten chemicals or families of chemicals which are today identified as CMR (carcinogenic, mutagenic or reprotoxic), including the halogenated flame retardant TCEP. They also propose to list to “avoid and minimise” further families of chemicals because “structurally similar chemicals can have” CMR properties. These proposed families are very wide including plasticisers, UV protection additives, antimony and several other metal compounds, and brominated, chlorinated and organophosphorus flame retardants.
pinfa supports the regulatory grouping of flame retardant chemicals into families with similar properties (see pinfa/Fisk study on grouping of organophosphorus PIN FRs (see pinfa Newsletter n°142). However, grouping all organophosphorus PIN FRs together makes no sense: this would conclude that all the organophosphorus chemicals widely present in our bodies (e.g. DNA/RNA, …) and in food (e.g. phytate) are CMR (these natural organophosphorus chemicals can be extracted from food wastes and used as PIN flame retardants).
The UNEP INC-4 website continues to refer to the criteria* proposed for prohibition or regulation of chemicals put forward by the UNEP secretariat in 2023. These proposed criteria target chemicals which are CMR, endocrine disruptors, PBT, vPvB**, PMT, vPvM**, ozone depleting or are impede recycling**, polymers “of high concern” and “potential migration/release from plastic”.
* UNEP/PP/INC.4/3 (part II – 2), 23rd December 2023, “Revised draft text of the international legally binding instrument on plastic pollution, including in the marine environment” and UNEP/PP/INC.2/INF/4 (Annex II – B – i), 23rd May 2023, “Additional information linked to potential options for elements towards an international legally binding instrument”.
** brominated flame retardants are cited for these criteria.
“Conference Room Paper. Chemicals of concern in plastics: Proposal by Norway, Cook Islands and Rwanda for an approach to criteria and lists, including initial lists”, submitted to United Nations fourth Intergovernmental Negotiating Committee to develop an international legally binding instrument on plastic pollution, Ottawa, Canada, from 23-29 April 2024 https://resolutions.unep.org/incres/uploads/chemicals_of_concern_in_plastics_proposal_by_cook_islands_rwanda_and_norway.pdf