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Copyright 2000 EBFRIP
24 February 2000
Proposal on WEEE Recent Scientific Evidence Calls into Question Draft Restrictions
on Flame Retardants
Elements on the use of
certain flame retardants in the draft DG Environment proposal on Waste Electrical and
Electronic Equipment (WEEE) contradict the EUs own risk assessments, go against
recent life-cycle environmental evidence and would actually impede the recycling efforts
of those E&E manufacturers with the most ambitious plans for mechanical recycling.
- By focusing solely on environmental impact
at end-of-life, the draft proposal for an EU Directive on WEEE contradicts the EU policy
trend towards an Integrated Product Policy aimed at reducing environmental impact across a
products life-cycle. The DG Environment has not taken account of the environmental
benefits which flame retardants provide in reducing fires and their significant
environmental impact. For example, a recent study by the Swedish National Testing and
Research Institute (SP) demonstrated that, over their life-cycle, TV sets with the
brominated flame retardant decaBDE emit less polyaromatic hydrocarbons (PAHs) and less
dioxins and furans than those TV sets without flame retardants altogether1.
- Annex III of DG
Environments draft proposal would mandate the separate treatment and disposal of a
wide range of E&E equipment plastics protected from fire by halogenated flame
retardants. This is based on a false assumption that these flame retardants prevent such
plastics from being recycled:
- In fact, some leading-edge Japanese
E&E copier manufacturers which stipulate 30% recycled plastics content in their new
models, specify plastics with halogenated flame retardants partly in view of their
stability during recycling2.
- EBFRIP is supporting projects to
facilitate material recycling of plastics containing brominated flame retardants and is
promoting the development of a project to make possible feedstock recycling of E&E
plastics, while recovering the bromine for re-use3.
- The proposed
phase-out of the PBDE flame retardants in E&E Equipment plastics (Article 4(4)) is
also based on a false assumption that these flame retardants are not recyclable and are
going to result in increased dioxin emissions. This also contradicts the preliminary
conclusions of EU risk assessments:
- The EU Risk Assessments on the two PBDEs
used in E&E equipment do not identify a need for any risk reduction measures.
- Tests from the leading analytical
laboratory GfA in Münster, Germany4, demonstrate that
recycling the major PBDE flame retardant decaBDE is not only feasible from a health &
safety perspective, but also that the recycled end-product meets the strictest limit
values for dioxins and furans under German law.
- At the same time, tests carried out at the
Tamara incinerator in Germany5 show that, providing the
combustion is carried out properly, the presence or absence of plastics containing
brominated flame retardants does not affect full compliance of the recovery plant with
emission limits for dioxins and furans.
- In fact, the German Environment Ministry
has clearly stated its opposition to substance bans as preventing innovation in recycling
by removing materials from the market which are suited to the recycling age.
- If there are environmental concerns, these
should be handed separately by dangerous substances legislation and in the context of the
EU risk assessments6.
- By not including
energy recovery in the draft proposals targets, DG Environment would in effect
remove control of decision-making from local waste managers, excluding a recovery route
which under certain circumstances makes the best sense from an environmental and
economical (i.e. sustainable) point of view.
EBFRIP therefore calls on
the Commission services to reconsider the draft proposal and in particular to:
- remove the requirement on halogenated
flame retardants to be separately collected and disposed of (Annex III);
- withdraw the ban on PBDEs and PBB (Article
incorporate energy recovery within the
recycling targets (Article 7(2)).
LCA Study of Flame Retardants in TV Enclosures, Presented to Flame Retardants 2000
Conference, Margaret Simonson, SP, P.O. Box 857, S-501, 15 Börås, Sweden and Håkan
Stripple, SP P.O. Box 47086, S-402 58, Gothenberg, Sweden, February 2000.
Resin Reclaiming Process Learned from Office Automation (OA) Equipment", Nikkei
Mechanical, no. 542, November 1999.
3 Recovery of
Bromine and Energy from Waste Electrical & Electronic Equipment Containing Bromine in
the European Union, PB Kennedy & Donkin, May 1999,
on the recycling of High Impact Polystyrene (HIPS) flame retarded with
Decabromodiphenylether (DecaBDE)", Dr Stephan Hamm, November 1999 (http://22.214.171.124/bsef/confe.htm).
and electronic plastic waste co-combustion with Municipal Solid Waste for energy recovery,
Jürgen Vehlow, Forschungszentrum Karlsruhe, and Frank E. Mark, Dow Europe, APME, February
Government opposes EU ban on brominated flame retardants", High Performance Plastics,
1 February, 2000.