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3 August 1999


While EBFRIP welcomes the DG XI’s decision to exclude most brominated flame retardants from the substance bans maintained under the latest draft proposal for a Directive, the continued inclusion of PBDEs and PBBs:

  • contradicts the EU’s own risk assessments for which there are already preliminary conclusions; and

  • undermines the flexibility in choice of materials which the E&E industry needs in order to maximise recyclability without reducing levels of fire safety.

Moreover, continued discrimination against energy recovery is likely to make it impossible for some materials (notably printed circuit board resins) to participate fully in optimising end-of-life waste management.

No risk assessment has been carried out for DBB, the one PBB in use. Without a specific risk assessment it is difficult to see how the proposed restriction on trade can be justified under WTO rules. Even when risk assessments are well under way, as is the case with the three commercial PBDEs, the DG XI ignores the risk assessment process altogether. A statement from the EU Environment Commissioner published in May in the EC Official Journal made clear that, for the PBDEs relevant in E&E equipment – i.e. deca- and octa-BDPE – the preliminary risk assessment conclusion is that no risk reduction measures are required. An outright ban on the use of PBDEs in E&E equipment, as is being proposed by the DG XI’s waste unit, is diametrically opposed to these risk assessment conclusions.

At the same time, there has been no assessment, with regard to the proposed phase-out of PBDEs and PBBs, of the actual impact on the recyclability and fire safety of E&E plastics. Some E&E manufacturers have found certain brominated flame retardant/polymer combinations to be the most suited to recycling, while others specify brominated polymers in order to meet the highest levels of fire safety. A ban on PBDE use in E&E plastics would send the wrong signal to the market that reduced levels of fire safety is acceptable.

By contrast to the DG XI approach of ignoring the need to take into account risk assessments, the bromine industry has commissioned the leading German analytical institute GfA and the University of Erlangen to carry out a series of tests on the recyclability of plastics with PBDEs. Issues being analysed and on which conclusions will be published in 1999 include:

  • whether, as DG XI alleges, dioxins are formed in the process of plastics recycling;

  • whether emissions of dioxins and furans occur during the plastics recycling process;

  • whether lower brominated compounds are formed in the process of plastics recycling.

EBFRIP will ensure that all those that have a stake in the WEEE debate are informed of the results of these studies.

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