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Inclusion of HBCDD, DEHP, BBP, DBP and additive use of TBBPA in annex IV of the Commission's recast proposal of the RoHS Directive

2 Hexabromocyclododecane (HBCDD)

• 2.1 Main concern
• 2.2 Characterisation of the substance
• 2.3 Applications in EEE
• 2.4 Quantities of the substance used
• 2.5 Available alternatives
• 2.6 Socioeconomic impacts
  • 2.6.1 Substitution costs
  • 2.6.2 Impacts on supply chain
  • 2.6.3 Impacts on waste management
  • 2.6.4 Administrative costs
• 2.7 Impacts on health and environment
  • 2.7.1 Impact profile of substance and alternatives
• 2.8 Conclusions for HBCDD

2.1 Main concern

The main concern regarding HBCDD is its persistence and toxicity in the environment as well as possible development neurotoxicity effects.

HBCDD is (November 2009) included in the draft list of substances recommended by ECHA for inclusion in the list of substances subject to authorisation in Annex XIV of REACH.

The Annex XV report and the Member State Committee Support Document conclude, mainly on the basis of the EU Risk Assessment, that HBCDD is a PBT substance according to Article 57 of the REACH Regulation (ECHA, 2009). The substance fullfills the PBT criteria as the substance is persistent (P), biocaccumulative (B) and toxic to organisms in the environment (T).

Classification of HBCDD with N; R50/53 was agreed at a Technical Committee for Classification & Labelling (TC C&L)-meeting on 11-12 June, 2003 but the substance is still not included in Annex I to Regulation No 1272/2008)(ECHA, 2009). Classification for health effects has not yet been discussed (ECHA, 2009).

As consequence of its persistence and the potential for long-range environmental transport HBCDD has been proposed by Norway for inclusion as a persistent organic pollutant under the global Stockholm Convention on persistent organic pollutants (POP's).

An EU Risk Assessment has been finalised for HBCDD (ECB, 2008a). Regarding human toxicity the Risk Assessment concludes that no measures beyond those, which are being applied already, are needed for consumers and human exposure via the environment. The main effect of concern is development neurotoxicity where the Risk Assessment concludes that there is a need for further information as there are indications of developmental neurotoxicity in adult mice exposed to HBCDD as pups, but the study is not performed according to current guideline and good laboratory practice and therefore this potential developmental neurotoxicity needs to be examined further.

The review undertaken for the European Commission by Öko-institut e.V. as background for selection of candidate substances for a potential inclusion into the RoHS Directive (Gross et al., 2008) recommend HBCDD as a potential candidate.

2.2 Characterisation of the substance

Hexabromocyclododecane (HBCDD) is a brominated flame retardant (BFR) primarily used in the polystyrene foam types expanded polystyrene (EPS) and extruded polystyrene (XPS), but also to a lesser extend in high impact polystyrene (HIPS) enclosures of consumer electronics and in flame retarding back coating for certain textiles (IOM, 2009). HBCDD is the sole flame retardant used for flame retarded EPS and XPS (KemI, 2006). Flame retarded HIPS is also produced without HBCDD, yet with other flame retardants. Textiles are primarily produced without flame retarders, or with other flame retardants. The flame retarded qualities of textiles are mainly used for furniture in public places, in furniture for private homes in the UK and a few other countries, and in textiles for automobile seats.

The use of flame retardants is driven by fire regulations specifying certain threshold for resistance to ignition and burning in different product types. The fire regulations vary somewhat between countries, and there are different grades of flame resistance required depending on the application and its inherent fire risks.

HBCDD is used as an additive flame retardant only i.e. the flame retardant is not bound chemically in the polymer material, and therefore continues to exist as the original substance, and has the potential for migrating or evaporating out of the polymer.

The structural formulas for HBCDD (CAS. No 25637-99-4 or 3194-55-6) are shown below. HBCDD exists in three isomers with identical composition but slightly different structure, depending on which side of the molecule's main plane the brome atoms are bonded on, so to speak. The bromine content of HBCDD is about 74%.

Different grades of the technical mixture are produced by industry, each containing different percentages of the three isomers: low melt, medium range, high melt and thermally stabilized (Greeg et al., 2004). The selection of HBCDD grade used depends on the usage of the end-product.

HBCDD

(Diagrams from Astrup and Bergman, 2009)

According to IOM (2009), HBCDD is manufactured at one facility in the EU. Imported volumes are similar to the volume manufactured in the EU. The annual consumption in the EU in 2007 is estimated at 11,000 tonnes, of which less than 10% (less than 1,100 t/y) is used in HIPS and an estimated 2% (220 t/y) is used for back coating of flame retarded textiles. The remainder is used for EPS and XPS insulation boards primarily used in construction. The consumption has increased slightly between 2003 and 2007, but the trend is not expected to have continued.

2.3 Applications in EEE

HBCDD is used in EEE in plastics parts made of HIPS. Flame retarded HIPS is used mainly for the production of housings of equipments such as television sets, audio-videos and personal computers but it has also been mentioned as used for electrical boxes and wiring fittings, electrical appliance parts, business machines, and interior parts of refrigerators. On the European market enclosures of computer monitors seem generally not to be made of HIPS, but of acrylonitrile-butadiene-styrene (ABS) or co-polymer of polycarbonate (PC)/ABS due to their higher impacts strength and resistance to cracking (Lowell, 2005).

KemI (2006) quote the European Brominated Flame Retardants Industry panel (EBFRIP) for the information that about 5 percent of all HIPS in the EU is flame retarded with HBCDD.

HBCDD is generally used for UL 94 V-2 grade HIPS, which is the flammability grade used for housing and similar parts not in direct contact with electricity bearing parts. For V-0 grade HIPS, used for parts in closer contact with electricity bearing parts, aromatic BFRs are generally used. HBCDD is an aliphatic BFR, which is usually used together with antimony trioxide as shown in Table 2.1. As shown in the table, the aliphatic BFRs are more efficient for V-2 grade HIPS.

Slightly lower loading are indicated elsewhere e.g. for the FR-1206 with HBCDD V-2 grade is obtained by 2 to 3 % of the flame retardants and circa 1% of antimony trioxide as a synergist (ICL, 2009a).

Table 2.1
Guidance for FR HIPS class V-0 and V-2 (ICL, 2009b)

HBCDD used without antimony trioxide has been introduced on the market. The flame retardant SaFRon-5261 is marketed as a heat stabilized HBCDD designed for specific and high demanding properties at high cost efficiency (less than 4% bromine is enough to reach V-2) (ICL, 2009b). The SaFRon-5261 can be used without antimony trioxide and is mentioned to have better colour thermal stability than alternatives, good corrosion resistance and high UV stability.

Refrigerators and freezers, etc., are generally insulated with polyurethane foam, which is not flame retarded, but in rare instances of non-consumer products EPS or XPS may be used (Vestfrost, 2009). EPS or XPS with HBCDD is therefore not expected to be used in EEE, but it cannot be ruled out.

HBCDD may be used in flame retarding back coating of textiles (furniture, etc. for certain markets). This application could be relevant for EEE, if furniture with EEE components, e.g. elevation chairs, is included in the scope of the RoHS Directive.

The possible applications of HBCDD in flame retarded parts of EEE are indicated in Table 2.2 below.

Table 2.2
Possible uses of HBCDD in EEE

2.4 Quantities of the substance used

As mentioned above, an estimated less than 1,100 t/y of HBCDD were used in 2007 for production of HIPS enclosures in the EU. A part of the HBCDD in European produced EEE will be exported with articles to countries outside the EU.

Likewise, HBCDD may be present in imported EEE and imported EEE parts

2.5 Available alternatives

HIPS
As mentioned above HBCDD is mainly used in V-2 grade flame retarded HIPS where aliphatic BFRs are more efficient than aromatic BFRs (i.e. can provide the flame retardancy at lover loadings.

A number of both aliphatic and aromatic brominated flame retardants are marketed for use in HIPS (Table 2.3). All are used in conjunction with antimony trioxide.

For the use of non-halogenated flame retardants it is necessary to replace the HIPS with copolymers like PPE/HIPS or PC/ABS.

Selected alternatives to HIPS/HBCDD systems are listed in Table 2.3.

Table 2.3
Selected alternative flame retardant systems to HBCDD in V-2 grade HIPS (based on KemI, 2006b; Lassen et al.,2006;ICL, 2009a)

Note:: /ATO: With antimony trioxide (4-6% concentration) used as synergist.

Major European manufacturers of TV sets seemed to be using copolymers like PC/ABS, PS/PPE or PPE/HIPS either without flame retardants, or with non-halogenated flame retardants (Lassen et al, 2006). Such copolymers have a higher inherent resistance to burning and spreading a fire, because they form an insulating char foam surface when heated. Further they have higher impact strength.

Flat panel TV sets are taking over from cathode ray tubes (CRT's) and for 2005, General Electric (2006) calculated the global plastic consumption for flat panel TV sets at approximately 42% PC/ABS, 33% HIPS (without flame retardants), 14% HIPS with flame retardants, 10% modified PPE and 1% other.

According to Lassen et al (2006), the PPE/HIPS copolymer blends have very similar flow properties to HIPS, meaning that the copolymer gives similar design opportunities for parts with fine structural details, and fewer changes to the expensive moulds and tooling used in the moulding process.

IOM (2009) states that: "Given that HBCDD is not widely used in HIPS, it is perhaps reasonable to assume that technically and economically feasible alternatives are already on the market".

EPS or XPS
The use of flame retarded EPS or XPS in electrical and electronic products has not been confirmed, but cannot be ruled out. Polyurethane foam seems to be the dominating insulation material for electric cooling appliances.

Only two flame retardants are currently available for use in EPS or XPS, namely HBCDD and the TBBPA-bis(allyl ether)(CAS No 25327-89-3) (KemI, 2006). According to IOM (2009), only HBCDD is used for this purpose.

IOM (2009) lists the following alternative insulation materials that may also be relevant for EEE: Polyurethane and polyisocyanurate foams.

2.6 Socioeconomic impacts

2.6.1 Substitution costs

Besides the single HBCDD producer in the EU, the substitution costs will mainly fall at the formulators and converters of HIPS (and EPS or XPS), which likely in some cases will include the EEE manufacturers, especially with regard to HIPS enclosures. The major technical costs are the costs for more expensive flame retardants, higher loadings of flame retardants and costs for new moulds. In cases where the total polymer system is changed, more process steps may need to be changed implying higher costs (but also higher impact strength as described under available alternatives). Costs for mould changes can be reduced significantly with sufficiently long transition periods, as moulds have to be replaced regularly in any case (Lassen et al., 2006).

The alternative plasticisers, polymer systems and production set-ups are already developed and on the market.

The most affected EEE manufacturers will be manufacturers of equipment in which HBCDD is present in casings and other structural part designed specifically for the equipment in question. Further, manufacturers of equipment for the low price market segment, with a strong competition on the price, may be impacted by the higher price of plastic parts with HBCDD alternatives.

Price estimates for substitution of HBCDD have not been identified, but substitution price examples for phasing out Deca-BDE in TV-sets may give an idea of the cost levels. Lassen et al. (2006) indicate the order of magnitude of price differences between compounds with Deca-BDE and alternatives on the basis of the experience of one major compounder (formulator). The extra raw material costs of replacing HIPS/Deca-BDE with the alternative materials PPE/HIPS or PC/ABS with halogen-free flame retardants would be about 5-6 € for the full enclosure of an average 27.5-inch TV-set (front and rear enclosure). The extra cost of using other BFRs would be 0.8-1.9 €, depending on the flammability grade. Note that these estimated costs are for the raw materials only. The total production cost of a 27.5-inch TV-set is roughly 300 € (Lassen et al., 2006), and the extra material cost of these alternatives can consequently be estimated at 0.5-2% of the production cost, with the higher end of that range representing the halogen-free HIPS/PPE.

In accordance with this, Lowel (2005)estimated the extra raw materials costs of replacing HIPS/deca-BDE in TV-sets, at 1.5-2.5% of the total price of the TV-set.

As shown for TV-sets above, for most EEE the parts which may contain HBCDD comprise only a minor fraction of the total production price of the product. Also, considerable fractions of the EEE parts that could be produced with HBCDD flame retarded polymers seem already to be made from other materials or with other flame retardants.

The substitution cost example above is based on HIPS/deca-BDE compound priced at 1.50-1.80 €/kg, HIPS/other BFR compound prices at 1.70-2.10 €/kg (at V1/V0), and HIPS/PPE/halogen-free flame retardants compound prices at 2.30-2.90 €/kg. As mentioned above, HBCDD and other aliphatic brominated flame retardants are more efficient in V-2 grade HIPS than the aromatic flame retardants (like deca-BDE) in V-1 grade.. There is no indication that the price of HIPS with other aliphatic brominated flame retardants should be higher than the HIPS/HBCDD whereas the price of the copolymers with non-halogenated flame retardants will likely be 0.5-0.8 €/kg higher.

Experience with substituting octa-BDE in ABS indicated that averaged over a five-years period the higher material price accounted for more than 85% of the total incremental costs while R&D and replacing moulds accounted for only 15% (Corden and Postle, 2002). Assuming that something similar would be the case for substituting HBCDD in HIPS it is roughly estimated that the incremental cost of replacing the HIPS with copolymers with halogen-free flame retardants would be in the range of 0.6-0.9 €/kg whereas the costs of replacing with other BRFs are more likely in the range of 0.1-0.3 €/kg

All substitution costs are expected to ultimately be furthered to the end customers. The total incremental costs to the consumers of replacing the HIPS/HBCDD can be roughly estimated using the following assumptions:

• Total volume of additively used TBBPA in EEE: 1,100 tonnes/year.
   
• Total volume of flame retardant HIPS assuming an average HBCDD load of 5% (3-4% Br): 22,000 tonnes/year.
   
• Total incremental costs assuming that the HBCDD is replaced by other brominated flame retardants: 2-7 million €/year.
   
• Total incremental costs assuming that the HIPS/HBCDD is replaced by copolymers with non-halogenated FRs: 13-20 million €/year.

Adding the additional uncertainty for the assumptions, at EU level the total incremental costs at the production level of replacing the HBCDD in HIPS are likely in the range of 1-10 million €/year if HBCDD is replaced with other brominated flame retardants and 5-25 million €/year the HIPS/HBCDD is replaced by copolymers with non-halogenated flame retardants. The costs may decrease over the years as result of a larger market for the alternatives.

2.6.2 Impacts on supply chain

SMEs
Plastic resins are produced and formulated by relatively few large companies in Europe. The resins are mixed with additives (in so-called “masterbatches”) to form compounds, which are the raw materials for further processing. Compounding may take place by the resin manufacturer, by specialised compounders or by the company manufacturing the plastic parts.

Whereas the market for compounds is dominated by relatively few large actors, the market for plastic parts is characterized by many small and medium sized enterprises (SMEs). The UK Risk Reduction Strategy and Analysis of Advantages and Drawbacks of Octa-BDE (Corden and Postle, 2002) provided details of plastics manufacturers in the UK according to a number of size categories (defined by number of employees), as well as the average turnover of the companies within those categories. Of the total 14,540 plastics manufacturers in the UK, 5,260 companies fell within the category of small companies (those with fewer than 50 employees), of which the majority (3,365) were micro-enterprises (0-9 employees). With regard to the situation for the EU as a whole, the study stated that there are 55,000 companies manufacturing rubber and plastics in the EU. Of these companies, the average enterprise size was given as 25 employees. No data have been found on how many of these actually supply EEE parts.

Previous studies have clearly indicated that SMEs are affected to a greater degree by compliance with the RoHS legislation compared to their larger competitors. The relatively larger burden for SMEs holds for total costs to comply with RoHS in general as well as more specifically the administrative burden (Bogaert et al., 2008). As most of the SMEs involved in the manufacturing of flame retarded plastics for EEE already have procedures in place for ROHS compliance, the differences between the SMEs and larger companies is probably not as large as seen by the initial implementation of the RoHS Directive. The companies offering the alternative flame retardants are large companies, and they serve as general customer advisers when it comes to adjusting polymer formulations and production setup, however, the burden of identification of suitable alternatives and R&D by introduction of new substances must still be expected to place a larger burden on SMEs than on larger companies.

EU production
Three large companies with headquarters in the USA and Israel, but production facilities in Europe (among other places), dominate bromine production globally and produce a range of brominated compounds. They also manufacture different halogen-free flame retardants like organo-phosphorous compounds and magnesium hydroxide. These three companies jointly formed the European Brominated Flame Retardant Industry Panel (EBFRIP) representing these three main members, as well as a number of major polymer producers as associate members. These companies are vulnerable to changes in the demand for BFRs (Lassen et al., 2006), however the same companies also manufacture some of the alternatives. If HBCDD in EEE is restricted the first step will likely be a shift to other brominated flame retardants and the impact on the manufacturers will be very limited.

The manufacturers of alternative flame retardants would benefit from a restriction of HBCDD in EEE, although the impact in the short term may be moderate. The phosphate esters are manufactured by the same companies that also provide the brominated flame retardants, but besides the phosphorous flame retardants are manufactured by at least two European companies (Lassen et al., 2006).

Production of EEE is substantial in the EU, however a large part of the total end-user consumption of EEE is imported as finished goods from outside the EU. This is notably the case for small household appliances, consumer electronics, IT equipment, and toys etc., but also for other EEE groups.

For EU based EEE producers, HBCDD containing parts may be produced by themselves or by subcontracting polyvinylchloride (PVC) processing or non-polymer formulator companies in the EU as well as on the world market.

Differences in restriction of the use of the substance via the RoHS Directive or via REACH are discussed in section 1.3.

2.6.3 Impacts on waste management

According to the WEEE Directive, plastics containing BFRs have to be removed from any separately collected WEEE. It is by the use of simple screening methods (e.g. X-ray fluorescence screening, XRF) not possible to distinguish plastics with HBCDD from plastics with PBDEs or PBBs already restricted by the RoHS Directive. In practice plastics with HBCDD consequently cannot be recycled, even though the use of recycled plastics with HBCDD is not restricted in the current RoHS Directive. If the HBCDD is replaced by non-BFRs, it will be possible to distinguish the flame retarded plastic parts from plastic parts with restricted BFRs by the use of XRF screening, and the plastic parts may be recycled. The enclosure parts are typically of a size that makes recycling practicable.

2.6.4 Administrative costs

Extra compliance costs related to the addition of one new substance under RoHS are expected to be minimal for companies which have already implemented RoHS, that is, most relevant companies. HBCDD is typically used in parts where deca-BDE have traditionally also been used and compliance documentation would usually be required for such parts.

The main extra costs are estimated to be related to control; both by the manufacturers, importers and the authorities. The presence of HBCDD cannot be determined by simple XRF screening (only the presence of Br), therefore sampling, extraction and laboratory analysis is required. As the parts that may contain HBCDD typically may also contain other RoHS substances the extra costs would mainly comprise the costs of analysis as the sampling and sample preparation would in any case be undertaken for control of other RoHS substances in the parts.

Brominated flame retardants and phthalates can be extracted by the same organic solvents and analysed using the same GC-MS analysis (Gas chromatography followed by mass spectroscopy), however, usually the materials containing the brominated flame retardants are different from the materials containing phthalates. The costs of an analysis of HBCDD in HIPS is in Denmark is reported to be about 250 € (excl. VAT) while the total price of analysing HBCDD, deca-BDE and TBBPA is about 310 € (excl. VAT).The extra costs of analysing for two extra flame retardants is thus about 60€ (excl. VAT). All prices are per sample when more than 20 samples are analysed.

2.7 Impacts on health and environment

2.7.1 Impact profile of substance and alternatives

Antimony trioxide
Antimony trioxide, traditionally used in conjunction with the HBCDD, is classified Carc. Cat 3; R40 (Limited evidence of carcinogenic effect).

Assessment of alternatives
Alternatives to HBCDD have recently been assessed for the European Chemicals Agency. In addition many of the alternatives to HBCDD in HIPS have been assessed in their capacity of being alternatives to the use of deca-BDE in HIPS e.g. by the Washington State Department of Health.

Unfortunately, some of the alternatives, specifically marketed as flame retardants for V-2 grade HIPS, have not been included in any of the assessments: tris(tribromoneopentyl)phosphate (TTBP) and 2,4,6-tris(2,4,6-tribromophenoxy)-1,3,5 triazine. These substances are among the substances manufacturers would most likely change to if HBCDD is prohibited for use in electrical and electronic equipment. It has been beyond the limits of this study to make a full environmental and health assessment of these substances.

Assessment of alternatives to HBCDD for the Europan Chemicals Agency (ECHA)
In a study for the European Chemicals Agency IOM (2008) assessed a number of alternatives to HBCDD. The study did not directly compare the environmental and health properties of the alternatives with the properties of HBCDD.

The summary results are shown Table 2.4. Note, that antimony trioxide is listed as an alternative, but has traditionally been used together with both HBCDD and alternative BFRs.

Regarding alternatives to HBCDD in HIPS they conclude: “Given that HBCDD is not widely used in HIPS, it is perhaps reasonable to assume that some technically and economically feasible alternatives are already on the market, although it is uncertain whether the human health and environmental impacts of these alternatives are any less than those associated with HBCDD products.” (IOM, 2008).

Regarding alternative insulation materials for replacement of EPS or XPS with HBCDD they conclude: “There are however a number of alternative forms of insulation that can be used in place of XPS or EPS. These alternative insulation systems have different characteristics to XPS and EPS and may be less appropriate for some specific use scenarios or may incorporate different environmental issues such as increased energy costs during transportation.”

Table 2.4
Summary for Human health and environmental properties of selected alternatives to HBCDD used in HIPS, EPS or XPS (based on IOM, 2008)

Alternatives to deca-BDE by Washington State Department of Health (2006)
Washington State Department of Health (WSDH) has as part of the development of a PBDE action plan reviewed human health and environmental data on potential alternatives to deca-BDE, among these HBCDD. The data for some of the substances relevant for the current study is shown in Table 2.5. WSDH concludes that based on the review of available information, there did not appear to be any obvious alternatives to Deca-BDE that are less toxic, persistent and bioaccumulative and have enough data available for making a robust assessment. They note that two of the alternatives with a moderate amount of data, HBCDD and TBBPA, are on the Department of Ecology’s PBT list, indicating that they present a hazard to the environment and human health. HBCDD is considered to meet the PBT criteria of WSDH. Other alternatives do not appear to meet the department’s PBT criteria, indicating that they are less of a concern, but WSDH states that is difficult to draw definitive conclusions based on incomplete data sets for these chemicals. The organo-phosphates RDP and BAPP (or BDP) are each described as “one of the more promising alternatives”, but it is noted that information on toxicity is limited.

Table 2.5
Summary of persistence, bioaccumulation potential and toxicity information for HBCDD and selected potential alternatives (Based on Washington State, 2006)

Click here to see Table 2.5

Summary of the assessment of alternatives
Both assessments, referred to above, emphasise that data on alternatives are not sufficient for making a robust conclusion.

The available data indicates that a number of alternatives exists which do not meet the PBT criteria, and in this respect would be more environmentally friendly than HBCDD.

The major uncertainly related to data on human toxicity. HBCDD is not a demonstrated CMR substance although some concern on possible development neurotoxicity exists. Antimony trioxide, which traditionally has been used in conjunction with the HBCDD is classified as carcinogen.

Many of the alternatives have some demonstrated potential health effects. The available data indicate that most of the alternatives should not be more problematic than the HBCDD as regards human health, but data are missing for critical endpoints.

The overall assessment is therefore a trade off between less environmental effects vs. uncertainty about human toxicity.

2.8 Conclusions for HBCDD

The main concern regarding HBCDD is its persistence and toxicity in the environment as well as possible developmental neurotoxicity effects.

As regards human toxicity the main effect of concern is developmental neurotoxicity from exposure of the newborn child (neonatal exposure) and the EU Risk Assessment Report concludes that there is a need for further information. The substance is currently not included in the list of classified substances. HBCDD is persistent in the environment and meets the PBT criteria

The main application of HBCDD in EEE is as flame retardant in HIPS used for closures and structural parts of different types of EEE. Total volume used for manufacturing processes within the EU is about 1,100 tonnes; no data are available on import/export with articles. HBCDD may as well be used in EPS or XPS foam in some EEE, but no actual use in such equipment has been identified. The HBCDD has traditionally been used together with antimony trioxide (ATO), but some HBCDD grades have been introduced that can be used without ATO.

The use of HBCDD in EEE is not deemed essential as technically suitable alternative substances and materials are available and already used extensively today. The main alternatives are either HIPS with other brominated flame retardants or copolymers with phosphor esters. If productions of EEE with flame retarded EPS or XPS foam do occur these may need to be replaced by other insulating materials such as for example polyurethane foam. The main alternatives are either HIPS with other brominated flame retardants or copolymers with phosphor esters.

Costs - At EU level the total incremental costs at the production level of replacing the HBCDD in HIPS are likely in the range of 1-10 million €/year if HBCDD is replaced with other brominated flame retardants and 5-25 million €/year if the HIPS/HBCDD is replaced by copolymers with non-halogenated flame retardants in all EEE. The actual costs depend on the share of the total EEE which is within the scope of the Directive or exempted.

HBCDD is typically used in plastic components where other RoHS substances have traditionally been used as well (e.g. deca-BDE). The main extra administrative costs is estimated to be related to compliance control, where the extra costs would mainly comprise the costs of chemical analysis as sampling and sample preparation will be done in any case for control of deca-BDE substances in the parts.

Benefits -The available data indicates that a number of alternatives exists which do not meet the PBT criteria, and in this respect would be more environmentally friendly than HBCDD.

The major uncertainly with respect to the alternatives relates to data on human toxicity. Many of the alternatives have some demonstrated potential health effects. However, for most of the substances the available data do not indicate that the alternatives should be more problematic than the HBCDD as regards human health, but data are missing for critical endpoints.

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