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Mapping of decabromodiphenylether (decaBDE) in other products than electrical and electronical products 5 Mapping of decaBDE in Denmark
5.1 Import of decaBDE as a chemicalFrom Statistics Denmark 2006 it appears that under customs tariff 2909.30.38 covering imports of bromine derivates of aromatic esters, including decaBDE, 2 tons were imported in 2005. As earlier mentioned, it is likely that these imports were imports of decaBDE. Furthermore, it appears from statistics that the materials were imported from Sweden. It has not been possible to track the importing company, for which reason it is not possible to determine whether the material was used for products covered by the RoHS Directive or was re-exported. It is therefore assumed that the 2 tons are in fact products covered by this mapping and that consumption of the products has taken place in Denmark. Through a contact in the plastics industry the project group got in touch with a company that imported 3 tons of decaBDE from the Netherlands in 2005. This material was used for the production of a master batch. After production, the master batch was re-exported to Germany where it has not been possible to trace the use. This amount is not included in the calculation of the total Danish consumption, as the entire amount was re-exported. Furthermore, the company informs that the import in question and the following re-export of the master batch with decaBDE was an isolated order in 2005 based on some special competitive circumstances abroad. The company has not been met with any demand for master batch with decaBDE in Denmark. The same answer is given by a number of other Danish suppliers of raw materials for the plastics industry. 5.2 Import as content in semi-finished productsFrom the SPIN database it appears that 300 kg of decaBDE was imported in 2004 via products that are subject to a duty of notification. No amounts are stated for 2005. Neither products nor importers appear from the part of the SPIN database that is open to the public. Through the Danish EPA, however, contacts were established with such companies. The two companies responsible for the above-mentioned notification have informed that:
5.3 Import as content in finished products5.3.1 The plastics industry etc.5.3.1.1 Plastic raw materialsThe group of suppliers of plastic raw materials was identified by reference to www.krak.dk. Table 5.1: Result of the questionnaire survey for the product group Plastic Raw Materials
As it appears from the above, none of the respondents has used decaBDE the last year. This confirms the general information from the plastics industry that there is no demand in Denmark for master batch with decaBDE content. Note, however, that the supplier of plastic raw materials mentioned earlier who made the import of the 3 tons of decaBDE for the master batch did not respond to the questionnaire. Two businesses inform that they use flame-retardants in their products, but not decaBDE. Alternatives include aluminium hydroxide and tris(1-chloro-2-propyl)phosphate. 5.3.1.2 Stadium seatsInternet search has revealed that decaBDE can be used for fire protection of seats for sports centres and stadiums. Therefore, two Danish importers of this type of products were contacted by telephone. These two importers cover more than 50% of the market in Denmark. Both inform that fire protected seats are not produced in Denmark and that, so far, none of the two companies have supplied fire protected seats to Danish stadiums. One of the suppliers informed that the latest tenders for projects on public stadiums include requirements for use of fire protected seats and that; consequently, this type of seats will presumably be installed in future. More concise information on the nature of fire protection of such future seats was not available. 5.3.2 Means of transportThis group consists of importers and manufacturers of cars, trucks, buses, and trains. The NACE codes for this group are 15.10.10., 60.21.00 and 51.47.30. At the request of several of the respondents, the questionnaire used for this group was also sent in an English version with a view to obtaining information from the foreign manufacturer. Table 5.2: Result of the questionnaire survey for the product group Means of Transport
One importer of cars from the East says that decaBDE is used in wire lugs for the electric system in the marque of cars that he imports. The amount used for one individual car is of the order of 1-5 gram. The car marque in question is a common marque on the Danish market. The marque covers many types of cars for private as well as business purposes and is therefore representative of the Danish fleet of cars. Information was received from a supplier of one make of cars (Western European) that with certainty their cars do not contain decaBDE. Thus, the same content in all makes of cars marketed in Denmark cannot be presupposed. In 1999 the Danish EPA stated that Northern European car manufacturers are supposed to have completely substituted poly brominated diphenyl ethers, including decaBDE, while cars with decaBDE are still imported from the East and the USA to Europe. On the assumption that at present this conclusion is correct for all cars manufactured in Europe and that the average amount of decaBDE in cars from other countries (primarily the East and USA) is 3 gram per car analogous to the details in this survey, this gives an average annual import of 240 kilos (table 5.3). In this table an estimate of the uncertainty of this number is stated in brackets. The uncertainty is estimated on the basis of the concentration interval stated (1-5 gram per car), the number of imported cars of the make in question and the total import of cars to Denmark from the East and the USA (2005), respectively. Table 5.3: Annual import of decaBDE in cars
Several of the respondents are not sure, though, whether there is decaBDE in the cars they market. The Danish EPA (1999) states that a number of manufacturers use decaBDE for fire protection in parts of the car cabins. Verification of this has not been possible in this survey. In the affirmative case, however, the amounts in one car will be considerably larger than 1-5 gram and, as a consequence, the above-mentioned figures for consumption in Denmark are underestimated, if cars with decaBDE in cabin parts are still being imported. A number of the responds received mention that since, at present, the use of decaBDE is not subject to any restrictions, suppliers make no demands on their sub-suppliers as regards the use of decaBDE. One car manufacturer states that they primarily seek to use materials that already possess natural fire retardant qualities rather than add fire retardant materials. 5.3.3 The furniture industry5.3.3.1 Upholstered furnitureUpholstered furniture is one of the product groups most often referred to, when it comes to the use of decaBDE in other than electronic products. The reason is that among others England and Ireland have specific rules laying down procedures for fire protection of this type of furniture. Table 5.4 shows the result of an enquiry made among potential Danish manufacturers and suppliers of upholstered furniture. The NACE code system does not have a specific category for upholstered furniture alone, so the questionnaire was sent to a number of manufacturers and importers of furniture that do not include upholstered furniture in their assortment. The NACE codes for the businesses in this group are 36.11.00., 36.11.20., 36.15.00., 51.47.05. and 51.47.10. Table 5.4 Result of the questionnaire survey for the product group Upholstered Furniture
The response rate is very low, which of course affects the validity of data negatively. In order to obtain supplementary information three Danish manufacturers of upholstered furniture were contacted by telephone. One has the furniture manufactured in Denmark, whereas the other two have the furniture manufactured in Eastern Europe and Asia. Two of the three companies state that they definitely do not market FR treated (FR; Flame Retardant) upholsteries in Denmark. Both businesses produce FR treated upholstered furniture for sale in England. In one case the furniture is shipped directly from the foreign manufacturer to England without passing through Denmark. The other case is a special product not for sale in Denmark. The third manufacturer informs that the production takes place in Eastern Europe and that FR treated furniture is imported to Denmark. E.g. Belgian companies carry out the FR treatment of textiles and cushions. In spite of repeated reminders it was not possible to obtain information on the type of FR treatment or on amounts imported. Presumably, decaBDE is still used for fire protection in furniture textiles in a number of countries, and therefore Danish imports of decaBDE in upholstered furniture cannot be ruled out. A calculation of amounts, however, is not possible. One consultant, who has a long and detailed knowledge of the Danish furniture industry, claims that he is not aware of any cases of use of decaBDE in Danish furniture. EUROPUR, the European trade association of foam manufacturers, has been contacted. EUROPUR has no knowledge of any use of decaBDE in PU (polyurethane) foam in Europe. 5.3.4 Cables and electronic accessories5.3.4.1 Power cablesCables used for alternating current of more than 1000 volts and direct current of more than 1500 volts are excepted from the regulations of the RoHS Directive and thereby covered by this survey. Danish manufacturers and suppliers of cables were identified by means of contacts within the industry, references to guides and references to wholesale catalogues. A total of 1 manufacturer and 8 importers of cables were contacted. Sources within the industry have stated that the 9 businesses contacted cover more than 90% of the Danish market. Table 5.5: Result of the questionnaire survey for the product group Cables
One Danish manufacturer of cables of this type was contacted by telephone. This manufacturer informed that brominated flame-retardants are used in no cables produced in Denmark, at all. 5.3.4.2 Heat shrinkable materialInformation was found on the Internet that decaBDE can be used for fire protection of heat shrinkable material (flexible polymer material shrinkable by means of heat - used for e.g. insulation of live joints). A few multinational companies produce most heat shrinkable materials. Heat shrinkable material is covered by the RoHS Directive, in so far as it is used for/mounted in connection with electric installations, but not if it is sold separately e.g. for other electrical purposes. Therefore it was chosen to include heat shrinkable material in this survey. Such products are sold in all small and large electronics stores and in many hobby shops. As there are numerous retail shops in Denmark that sell heat shrinkable materials, and as the number of manufacturers worldwide is limited, enquiries about sale of decaBDE-containing products were made to the manufacturers instead of the retailers. Thus the three largest suppliers to the Danish market were approached. Table 5.6 below summarizes the result. Table 5.6: Result of the questionnaire survey for the product group Heat Shrinkable Material
Import of decaBDE was identified through the one manufacturer that responded. The material in question was a special product; of which the total annual amount sold was barely 200 m heat shrinkable material. The content of decaBDE was stated to be barely 10 percent by weight. On this basis, the annual amount of decaBDE imported by this manufacturer can be calculated to be less than 1 kg. If we assume that the other manufacturers of heat shrinkable materials use the same amount of decaBDE, this implies a total annual import of less than 5 kg. Table 5.7: Annual import of decaBDE in heat shrinkable products
*: the estimate results from an assumption of the same relative share of decaBDE in imported products. 5.3.5 Furnishing fabricsFlame retardants can be used in a number of furnishing fabrics, such as carpets and curtains. The group covers wholesale and manufacturing of all textiles for the home, except clothing. Fixed and movable carpets, curtains, cushions, tablecloths, bed linen etc. are all included under this group. The NACE codes for the group are 17.40.20., 17.51.00., and 17.40.90. Table 5.8: Result of the questionnaire survey for the product group Furnishing Fabrics
The completed questionnaires and telephone contact to selected companies in the group of respondents gave the following information on the product group: There are no general requirements regarding fireproofing of furnishing fabrics in Denmark apart from mattress covers. None of the manufacturers or dealers mentions use of decaBDE. One respondent describes use of another brominated flame-retardant, and others use inorganic flame-retardants. According to the questionnaires we have received, a number of manufacturers/dealers use materials with inherent flame retardant qualities, such as the polyester fabric Trevira CS with integrated metal compounds. Brominated flame-retardants are not used in carpets manufactured in Denmark. 5.3.6 Wholesale textilesFurnishing fabrics are also available through dealers registered as “wholesale textiles”. This group also covers textiles sold for later use in clothing, upholstery etc. However, the group cannot be split up further under the NACE code 51.41.00. Thus, the products include textiles sold directly as well as textiles sold for further manufacture. Table 5.9: Result of the questionnaire survey for the product group Wholesale Textiles
The completed questionnaires together with telephone contacts to selected businesses in the group gave a good deal of information about the product group. As was the case with the previous product group, there are no general European requirements regarding fire applying to this product group. However, a few countries, e.g. England, have specific rules regarding fire protection. One answer indicates the use of halogenated flame-retardants, but not decaBDE. This manufacturer, though, works at phasing out this type of flame-retardants. Several manufacturers report using materials such as Trevira CS, Duraflam, and Duracote. The fire retardant qualities of the two last-mentioned products are based on organic and inorganic phosphorus compounds, including ammonium phosphates. Dealers of large textiles for sports centres, such as nets, room dividers etc., were contacted by telephone. This product group is not subject to any fire requirements, but one type of material frequently used for room dividers is a material with inherent flame-retardant qualities. None of the respondents acknowledge having used decaBDE. 5.3.7 CampingTo investigate the product group Camping, wholesale businesses selling sports items and/or camping equipment were contacted. The NACE code of this group is 51.40.10 and this covers manufacturers/importers of sunblinds, other types of sunscreens, Venetian blinds, tents etc. Excepted are businesses that could be immediately identified as irrelevant in this connection, such as sail makers, rope makers and flag factories. Table 5.10: Result of the questionnaire survey for the product group Camping
The completed questionnaires together with telephone calls to selected companies from the group gave the following information on the product group: Large party tents within this group are subject to requirements for fire safety, but no one uses decaBDE for the purpose. Many of the products within this group use PVC canvas that is inherently fire retardant due to the large content of chlorine. The content of plasticizers in plasticized PVC may necessitate extra fire protection. A large Danish manufacturer/importer informs that treatment with flame-retardants have become more common in camping tents. This manufacturer uses decaBDE as flame-retardant, thereby accounting for the only confirmative answer in the group. Production takes place in China. The majority of the imported tents are re-exported. Part of the import goes to England. The business has provided information on expected sales for 2007 as data for the investigation. Table 5.11 shows the actual figures that are based on information on the consumption of decaBDE. The figures in brackets show the estimate range for the consumption of decaBDE in tents in Denmark. The estimate is based on the information received from the one importer about the average content of decaBDE in tents and from Statistics Denmark: Im- and exports January-December 2005. To convert imports of synthetic tents from tons to number of tents, the project group has based their calculation on an assumption that an average tent weighs 15 kg. Based on this assumption, annual imports will amount to 160.000 tents. This seen in combination with the actual data leaves a maximum import of 190 kg to Denmark via tents. According to market information and data from Statistics Denmark a large part is being re-exported, leaving the share of decaBDE for use in Denmark at less than 190 kg, as seen in table 5.11 below. Table 5.11: Annual imports of decaBDE in tents
Regardless of the uncertainties of this estimation, the amounts accessing Denmark through imports of tents are still limited. 5.3.8 Outdoor lifeTo include all tents, the group Outdoor Life is also covered. The NACE code for this group is 51.47.35. and it includes tarpaulins and camping and sports equipment. Excepted from the group are businesses manufacturing or dealing in equipment for golf, riding, horse racing, and yachting Table 5.12: Result of the questionnaire survey for the product group Outdoor Life
Together with the questionnaire responses, a few businesses in the group were contacted. No respondents had stated a use of decaBDE or other flame-retardants. Awnings were stated as containing no fire retardants, and tarpaulins, in general, were made of PVC, which has natural fire retardant qualities. 5.3.9 GluesA source (Kemikalieinspektionen 2004) has stated that hot melt glues may contain decaBDE. The NACE code for this group is 24.62.00 and comprises glue factories. Table 5.13: Result of the questionnaire survey for the product group Glues
Subsequent contact to Kemikalieinspektionen confirms that decaBDE is no longer used in hot melt glues. Thus, the project group considers glues to be completely decaBDE free. 5.3.10 Nursing requisitesRequisites to be used by sick, weak or disabled consumers need more safety in case of fire. Products such as cushion seats/wheelchair cushions, mattresses, duvets/pillows and bed linen are available with flame-retardants for this particular consumer group. The products constitute a grey zone when it comes to legislation on medical equipment. The products are only subject to the Order (BEK no 1268 of 12/12/2005) when marketed directly as equipment for disabled persons. The buyers on the market, however, demand fire protection of these products. Countries like England, France, the Netherlands, and Belgium also step up their focus on fire safety in order to satisfy more players on the market. No information was found regarding any use of decaBDE in this type of products. One supplier states that duvets/pillows are fire protected by means of Trevira CS, cotton/linen fire protected by means of Pyrovatex, and that smoking aprons are made of glassfibre material. Pyrovatex is based on inorganic phosphorous compounds (Environmental guidance for work clothing). Other actors inform that they use Fyrol FR2 (tris-(1,3-dichloro-2-propyl)phosphate) for fire protection of textiles. 5.3.11 Commodities for babies and childrenConsumer products intended for children and babies were investigated, particularly car seats, bicycle trailers, prams, and push chairs. The largest actors on the market within the four product groups were contacted by telephone. The calls revealed that no flame-retardants are added to neither bicycle trailers, prams, pushchairs, nor car seats in Denmark. 5.3.12 Paints and joint sealing compoundsAs earlier paints have been said to contain PBDE (Table 3.2), three actors on the market were contacted, two of who practically cover the market for fire protecting paints and joint sealing compounds. Both state that flame retardant substances are not added to their products. Instead, their products swell or expand when exposed to heat (structural fire protection). 5.4 Total statement of decaBDEAll facts demonstrated in this investigation are gathered and shown in table 5.14. Table 5.14: Summary of the findings with regard to annual imports of decaBDE (2005)
1 Covers a group of chemicals including decaBDE; most likely it is decaBDE. Use of the chemical is unknown 2 Stated as an isolated export order 3 Stated as an isolated export order 4 Annual imports to Denmark can be estimated at < 5 kg When decaBDE is imported as a chemical or as semi-finished products we often speak of single, isolated orders. Nothing indicates a regular use of decaBDE in Denmark. Isolated cases, however, will most likely happen every year in an amount estimated at less than 5 tons. Apparently, most of the material is being re-exported, leaving only a small amount for consumption in Denmark. Imports of cars constitute the major uncertainty, as only two car manufacturers have submitted detailed answers, one of which uses decaBDE. Other car manufacturers could perhaps be using decaBDE in man-made materials or fabrics for the cabin, as indicated in other investigations. As the total potential amount from such materials by far exceeds the other amounts, cars constitute a field that should be studied more closely in order to throw light on the actual present use of decaBDE. Three large actors, of whom only one has submitted information for this project, dominate the market for heat shrinkable material. If their use of decaBDE is representative of the other manufacturers, the total consumption of decaBDE in Denmark within this product group will amount to less than 5 kg. One tent importer and dealer using flame-retardants as surface treatment of the tents have been identified. This does not exclude the possibility that other importers use flame-retardants, but the contact to the other large importers on the market has shown that they do not use fire retardant additives. I any case, within this product group the total import is therefore limited and will hardly exceed 50 kg as net consumption (imports minus exports) for Denmark. No use of decaBDE has been demonstrated within the product group Upholstery Furniture. The investigation has shown that furniture with fire retardants are still being imported to Denmark to a certain degree, but knowledge about decaBDE as a flame retardant component is very insufficient. There is reason to assume that furniture with content decaBDE is being imported to Denmark, because the component is still being used worldwide for the purpose, and because hardly any special products are being made only for the Danish market. Foreign laboratory analyses have demonstrated use of decaBDE in polystyrene boards. Insulation boards of polystyrene produced in Denmark do not contain decaBDE, and nothing indicates any import of decaBDE through these materials. 5.4.1 Comparison with EUAs mentioned earlier, the total import through finished products to EU has been calculated to be 1300 tons corresponding to 17 tons for Denmark when distributed proportionally by number of inhabitants. As it appears from the previous sections, it has not been possible by this survey to demonstrate imports of this volume. However, it is doubtful whether the European data can be applied proportionally within the individual countries, the reason being, partly, national regulations as known from England and Ireland and, partly, national differences in the use of fire protective products. That national differences can be considerable appears from the fact that is has not been possible for this investigation to demonstrate the same consumption of decaBDE for cellular rubber as was demonstrated in a Norwegian investigation (SFT 2003).
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