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Mapping of decabromodiphenylether (decaBDE) in other products than electrical and electronical products

4 Method description

• 4.1 Introduction
• 4.2 Strategy
  • 4.2.1 Import as chemical
  • 4.2.2 Import as part of semi-finished produtcs
  • 4.2.3 Import as part of finished goods
  • 4.2.4 Other sources

4.1 Introduction

The mapping of the consumption decaBDE in Denmark has been completed in accordance to the Danish EPA’s paradigm for mass flow analyses (the Danish EPA 2000).  The mapping covers according to the project description only the 2 initial parts of the paradigm (1.1– 2.3) and 4.1. The volume of waste products will thus not be included in the analysis.

The newest possible data has been searched for in connection with this survey. This means that the contacted manufacturers and suppliers have delivered data from 2005. The public registers have delivered data from 2004 and 2005 respectively depending on the latest update.

The mapping is based on the mapping work that is available from e.g. the other Nordic countries. The result is moreover, compared with data from the Danish EPA’s mass flow analyses for brominated flame retardants from 1997 (the Danish EPA 1999).

The used sources are described in details in the following sections.

4.2 Strategy

DecaBDE is not manufactured in Denmark and thus the substance may enter the Danish market in three different ways. The figure below illustrates that correspondingly there may be export of decaBDE abroad.

Figur 4.1.: DecaBDE import and export to and from Denmark

The three import ways where treated separately in the survey and are described one by one in the following.

4.2.1 Import as chemical

Import of pure chemicals, including brominated flame-retardants must be reported to the Denmark's Statistics Office (Foreign Trade). The reporting is performed through the 2 following channels:

1. Via Intrastat that describes Denmark’s trade flow with the EU. Companies with an annual EU-import above 1.6 million DKK are obligated to report their import to Intrastat (EU 2004).
   
2. Via the Danish Customs and Tax Authorities. If the import takes place from a country outside the EU the reporting will be automatic through the imported goods’ customs clearance documents contrary to Intrastat. There is no lower threshold limit for when the goods are included (LBK 2005).

Information from the two mentioned sources is gathered at the Denmark's Statistics Office (Foreign Trade) to one specification titled: Foreign Trade Distributed on Goods and Countries.

Import and export of goods distributed on KN-product number are listed on this specification (Customs tariff). The specification also specifies import and export countries. The customs tariff is used to map the import of decaBDE as chemical. DecaBDE is listen on the specification under customs tariff no 2909.30.38: Bromine derivates of aromatic ethers, except pentabrominediphenylether (penta-BDE), tetrabromine(pentabrominephenoxy)-benzene, and tribrominephenoxy.

In this mapping it is assumed that the imported amounts under the mentioned customs tariff are comprised of decaBDE. Another alternative could be octaBDE, however, as octaBDE together with pentaBDE have been banned since 2004, it is most likely that the reported amounts are comprised of decaBDE and no other substance.

4.2.2 Import as part of semi-finished produtcs

DecaBDE may also enter the country as a component in semi-finished products (plastic raw material), if so it will be evident from the import register. This opportunity is thus been investigated partly through contacts to the trade association for plastic manufacturers partly at contact to the Danish Product Register.

Labelling obligatory substances and materials must be reported to the Product Register at import. DecaBDE is not included of this labelling obligation duty, however, nevertheless it may still be reported if the substance is included in a labelling obligated product or material. Reporting of decaBDE to the product register was mapped through the SPIN-database (SPIN 2006).

4.2.3 Import as part of finished goods

4.2.3.1 Gross list of product types

The information collection was initiated with examination of potential applications of decaBDE in products that are not included in the RoHS directive.

The following sources are primarily used for disclosing potential products with decaBDE content.

• Internet
• Published reports
• Search in product register (SPIN database)
• Common knowledge to chemical/technical products

The Internet was used to search information on potential application of decaBDE. The information was searched through websites for decaBDE manufacturers and for the European trade association from manufacturers of brominated flame-retardants (EBFRIP).

A number of published reports (including recent year’s Nordic reports), the Danish EPA’s own mapping projects and chemical-technical reference were reviewed for information on product types that may contain decaBDE.

Based on the above-mentioned sources a gross list of product types that potentially might contain decaBDE were identified. Table 4.1 shows the product groups that the test identified as interesting.

Table 4.1: Product types with potential decaBDE presence

4.2.3.2 Collection of information

The gross list was used by means of the NACE code system to select Danish companies within the identified product areas. The selection was performed through a database that is published by the Danish Grocery Industry’s information agency (KOB).

In order to limit the amount of companies all one-man businesses were discarded.

The table below shows the number of companies in the selected product groups (table 4.2.).

Table 4.2: Number of companies that have received a questionnaire in connection with the investigation

Moreover, 2 Danish suppliers/manufacturers of paints and joint fillers were contacted.

A questionnaire was sent to all companies in June 2006 containing questions on potential content of decaBDE in the goods that the companies market. The questionnaire is enclosed in appendix B. The auto industry was given customized questionnaire that is enclosed as appendices C and D (English version).

After the response deadline’s expiry in July 2006 all non-respondents were contacted by phone. In that connection the response deadline was extended with further 3 weeks.

The average response rate for all categories was 18.5% after the initial deadline. The telephone contact and extended response deadline resulted in further 1.5% response.

Appendix A contains a list of the single companies that were contacted in connection with this investigation.

With the responses of the additional questions in mind and the clarification of conditions in the industry a number of companies within the selected product areas were contacted directly.

4.2.4 Other sources

The analytical laboratory Eurofins Gfa GmBH in Hamburg was contacted in connection with the testing. This laboratory has offered analyses for brominated flame-retardants for many years. The analyses are primarily carried out in environmental samples (sludge, sediment etc.), however, during recent years the analyses have been performed on consumer products.

The laboratory was asked about:

• Number of analyses for decaBDE in consumer products over the past 2 years
• Number and result of analyses of products outside the RoHS directive’s area

During the last 2 years the laboratory has analysed to the extent of 50 consumer products for decaBDE content. The major part has been electronical products.

Several non-electronical products contained traces of decaBDE. The content presumably originates from other applied flame-retardants (impurities).

The laboratory database only contains one non-electronical product with a content of decaBDE above 1%. The actual example was seating foam for chairs with a content of 7.4 in percentage.

During the completion of this report Eurofins GfA GmbH analysed a sample of a polystyrene isolation plate from the German market. The analysis indicated a decaBDE content of 11 weight percentage. The contact to the Danish manufacture of polystyrene isolation plates indicated that this type of material formerly was added flame-retardant agents, however, Danish manufactured polystyrene isolation plates are not added flame retardant agents anymore. The manufacturer cannot dismiss that German construction companies takes flame-retardant polystyrene plates with them to Denmark in connection with concrete construction assignments, but this was considered to be of an insignificant extent.

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Version 1.0 August 2007, © Danish Environmental Protection Agency