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October 2000

Response to DTI Questions Regarding the European Commission Proposal on Restrictions On Substances in Electrical and Electronic Equipment (ROHS)


Answers to Question 15a:

EBFRIP has gone on record on several occasions to make clear its opposition - and that of the European Chemical Industry Council - CEFIC - to the phase-out proposal as regards all three PBDE flame retardants.

One of the three PBDE flame retardants - penta-BDE - is scheduled to be the subject of a phase-out proposal from the Commission at the end of this year under Directive 76/769/EEC on marketing and use following risk assessment provisional conclusions indicating a need for risk reduction measures. EBFRIP fully accepts that this is a necessary outcome from the risk assessment of penta-BDE.

The other two PBDE flame retardants - octa-BDE and deca-BDE - are subject to provisional risk assessment conclusions indicating no need for risk reduction measures. Final tests are taking place on these two PBDEs which are due for completion early in 2001. It would be a disturbing precedent for future EU policy were the Council to confirm the Commission's proposal on octa-BDE and deca-BDE even though each Member State has signed up to the Existing Substances Regulation and its risk assessment process.

We urge EU governments to postpone any decision on octa-BDE and deca-BDE until the completion of the risk assessments. We also view Directive 76/769/EEC to be the only logical way in which the environment and worker health can be protected from substances whose risks need to be managed or avoided. In this respect, it seems illogical for the Commission to propose a ban on penta-BDE in electrical and electronic equipment with one hand and to propose a complete ban with the other.

In summary, we would suggest that, as regards the PBDE flame retardants, the Commission's proposal on ROHS should be subjected to the science of the EU's own risk assessment process and to the Commission's own drafting of new legislative proposals under Directive 76/769/EEC.

Finally, the industry can confirm that the one remaining PBB has already ceased production, in May 2000 of this year.