TAGS: Flame Retardants
BSEF, the International Bromine Council, has significant concerns over the proposed ban on halogenated flame retardants (HFRs) in the enclosures and stands of electronic displays contained within an EU Commission draft regulation on electronic displays.
Proposed Ban Contrasts Other Eco-design Regulations
The ban inserted the EU Regulatory Committee for Ecodesign after the finalisation of formal WTO TBT notification on the 6th of December 2018, is completely unjustified according to BSEF. “
The EU has appropriate and well-known tools and processes for restriction of substances namely RoHS and REACH. Eco-design should not subordinate these. Doing so sets a dangerous precedent.” Said Dr Kevin Bradley. Secretary General of BSEF.
“Along with colleagues in the wider chemical and electronics industries, we are extremely disappointed that the Commission did not act to prevent Member States inserting such a blanket ban. It goes beyond the scope of the Eco-design Directive and is not consistent with article 1 of that Directive”, he noted.
BSEF points out that this proposed ban is in sharp contrast to the way hazardous substances have been treated in other Eco-Design regulations for light sources and separate gear controls where RoHS governs the use of hazardous substances and no eco-design requirements have been set in the implementing measure.
Appropriate Legal Instruments to Restrict Substances Supported
BSEF supports the use of appropriate legal instruments to restrict substances in products or articles. This proposed ban disregards the principle of regulatory coherence, Better regulation and prejudices ongoing evaluations and assessments of some brominated flame retardants under RoHS and REACH. “
Brominated and other halogenated flame retardants are being denied due process by this proposal”, Dr Bradley noted.
BSEF is also concerned that the ban will be impossible to enforce as no thresholds have been set. From a trade point of view, this will be difficult for third country manufacturers of displays to comply with. “
The EU is proposing a ban with ramifications outside the EU but has not consulted trade partners on the ban” noted Dr Bradley.
Addressing Issue of Small Number of Legacy BFRs
A supposed justification for the “ban” is that HFRs impede WEEE plastics recycling. No empirical evidence has been produced to substantiate this by the European Commission, according to BSEF. According to the European electronics Recyclers Association, EERA, 92% of all BFRs used in electronics and electrical equipment are not restricted.
BSEF members, the plastics industry and recyclers have worked together and are working together to address the issue of the small number of legacy BFRs and new technologies are emerging all the time. “
Well established CEN standards for WEEE waste treatment are ensuring that the 8% of WEEE plastics containing brominated FRs are effectively managed and recycled or otherwise treated in accordance with current EU legislation”
Source: BSEF