Update on EU regulatory action on FRs

Information update for pinfa members on implementation of the ECHA Flame Retardant Strategy and implications for industry. The ECHA report on Aromatic Brominated Flame Retardants (ABFRs) (see pinfa Newsletter n°166) and its annexes were analysed in detail by pinfa member company regulatory experts Adrian Beard, Clariant, Thoralf Küchler, Lanxess and Sander Kroon, ICL. The ECHA report identifies 60 ABFRs, used mainly in electrical and electronic (E&E) and automobile applications. Although only 5/60 are today formally identified as SVHC, PBT or vPvB, ECHA considers that most of the others are likely to also be problematic (based on modelling). Polymeric and reactive ABFRs are not themselves considered problematic, but there is concern about their breakdown products. Alternative FRs are identified, some of which are considered to not be problematic, but many of which do not yet have adequate data. A problem is waste disposal. Only around half of EU E&E waste is collected, so much goes to unknown disposal routes. Losses of ABFRs during waste shredding can be significant and there are concerns about possible breakdown products of ABFRs in the environment. 16 out of 50 brominated FRs indicated as found in the environment are ‘not identified’, so are either breakdown products of other BFRs or are being imported into Europe (including in articles) without REACH registration. Phosphorus flame retardants are also being found in the environment. pinfa is working on projects to improve information on release of PIN FRs. An important conclusion is the problem of brominated FRs which are not REACH registered coming into Europe in imported articles (finished products or parts): 35 of the 60 ABFRs identified by ECHA are not REACH registered (those which are classed as polymers do not require registration). This reflects the problem that REACH largely fails to address chemicals in imported articles.

* SVHC = Substance of Very High Concern. PBT= Persistent Bioaccumulative Toxic. vPvB = very Persistent very Bioaccumulative.

Recording of this online information meeting available on demand for pinfa members only.

See also ECHA presentation to CARACAL on the ABFR report here.