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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

6 Additive use of tetrabromo bisphenol A (TBBPA)

• 6.1 Main concern
• 6.2 Characterisation of the substance
• 6.3 Applications in EEE
• 6.4 Quantities of the substance used
• 6.5 Available alternatives
• 6.6 Socioeconomic impacts
  • 6.6.1 Substitution costs for enclosures
  • 6.6.2 Impacts on supply chain
  • 6.6.3 Impacts on waste management
  • 6.6.4 Administrative costs
• 6.7 Impacts on health and environment
• 6.8 Conclusions for TBBPA

6.1 Main concern

The main concern regarding additive use of TBBPA is its toxicity in the aquatic environment and possible effect of breakdown products in the environment.

TBBPA is currently (Sep 2009) not on ECHA's candidate list of substances for authorisation.

TBBPA has recently been included in Annex I to Regulation No 1272/2008 (CLP) with the classification N; R50-53: Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment.

The EU Risk Assessment Report (RAR) of TBBPA on human health concludes that no health effects of concern have been identified for TBBPA and that risks to workers, consumers and humans exposed via the environment are not expected by the use of TBBPA as additive or reactive flame retardant (ECB, 2006). The RAR concludes that there is a need for measures for reducing the emission from compounding and conversion sites where TBBPA is used as an additive flame retardants (EC, 2008a)

The risk assessment for the environment concludes that TBBPA is a vP (very persistent) substance in the marine environment. The substance cannot be considered a PBT (ECB, 2007) as it does not meet the bioaccumulation and toxicity criteria, a conclusion agreed upon by the Scientific Committee on Health and Environmental Risks (SCHER, 2008).

Regarding breakdown products the RAR mention that TBBPA has been shown to break down in estuarine sediments to another substance (bisphenol-A) that is known to be toxic and shows effects on the endocrine system. Thus this indicates that tetrabromobisphenol-A may have the potential to cause long-term adverse effects on marine ecosystems if sufficient exposure occurs, but the RAR states that it is not clear how this finding fits in with the current Marine Risk Assessment Technical Guidance. In addition, another potential metabolite/degradation product (tetrabromobisphenol-A bis(methyl ether) that may be formed by O-methylation of tetrabromobisphenol-A, can be considered to meet the screening criteria for a vPvB substance (ECB, 2007).

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 TBBPA as a potential candidate. The recommendation is based on the uncertainties about breakdown products, possible formation of dioxins and furans by uncontrolled combustion processes and concerns regarding the findings of TBBPA in species at the top of the food chain with unknown long-term effects.

6.2 Characterisation of the substance

Tetrabromo bisphenol A (TBBPA) is a brominated flame retardant (BFR) widely used in electrical and electronic equipment. TBBPA is the BRF manufactured in the largest quantities (BSEF, 2009a). The substance is both used as a reactive and an additive flame retardant.

In additive usage of TBBPA, the substance 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. In reactive usage of the substance, the flame retardant is bound chemically into the polymer and does not exist anymore as the monomer substance (except for possible unreacted trace concentrations).

The current description focuses on the additive use of TBBPA.

Besides the pure TBBPA, a number of derivatives of TBBPA are used as additive flame retardants. Some are used for the same applications as TBBBA whereas others are mainly used for flame retarding other polymers (see Table 6.1. The TBBPA derivatives are not included in the present assessment, but a few notes on their application are added for the framing of the description of the use of TBBPA.

TBBPA is not produced in the EU. Globally TBBPA is produced in USA, Japan, Jordan and Israel.

Table 6.1
Structural formula and TBBPA and derivatives (based on lassen et al., 2006)

Click here to see table 6.1

6.3 Applications in EEE

The primary use of TBBPA as an additive flame retardant is in enclosures of acrylonitrile butadiene styrene (ABS) (BSEF, 2009b). ABS is widely used for enclosures and structural parts of many types of electronic and electrical equipment.

CEFIC (presentation without date on manufacturer’s website) inform that ABS with TBBPA is used for personal computers, monitors, notebooks, photocopiers, scanners, cellular phones, industrial and life safety applications, battery housings, smoke alarms and safety lighting.

An American survey found that ABS with TBBPA was used in 34% of the computer monitors and in 2% of TV back casings (Kingsbury, 2002 as cited by Pure Strategies, 2005).

In flame retarded ABS for enclosures the TBBPA is typically applied in concentrations of 14-30% with about 4% antimony trioxide (ATO – CAS. No 1309-64-4) as synergist (Lassen et al., 2006). A typical loading for V0 grade ABS is 22% (Lassen et al., 2006). Traditionally octa-BDE has been the flame retardant of choice for ABS plastic, but after the phase out of octa-BDE, TBBPA has been one of the main flame retardant for this plastic type.

Some of the TBBPA derivatives may as well be used in enclosures of ABS, PP and HIPS, but besides the TBBPA derivatives are widely used in engineering plastics; first of all the thermoplastic polyesters poly(butylene terephthalate) (PBT) and poly(ethylene terephthalate) (PET). These plastics are used for more demanding applications in connectors, circuit breakers and similar parts. According to Munro et al. (2004) brominated carbonate oligomers (probably tetrabromobisphenol-A carbonate oligomer) accounted for 44% of the global flame retardant use in thermoplastic polyesters. There are currently no commercially mature non-brominated alternatives for the thermoplastic polyesters, but new alternatives have been introduced recently.

The possible applications of TBBPA in flame retarded parts of EEE are indicated in Table 6.2 below. Flame retarded ABS enclosures or structural parts may in principle be found in products within all categories, but the major part is probably used in Category 2 “IT and telecommunication equipment”.

Table 6.2
Possible uses of TBBPA in EEE

6.4 Quantities of the substance used

The annual global production in 2004 was estimated at more than 170.000 tonnes. (Posner, 2006). About 70% of TBBPA is used as a reactive flame retardant in EEE and 20% is used as an additive to plastics (BSEF, 2009a).

The total European consumption of TBBPA from the demand for EEE is estimated by Gross et al. (2008) at around 40,000 tonnes/year (figures are based on data for 2003/2005).Thereof Gross et al. (2008) estimate that 13,800 tonnes/year were imported into the EU as the substance itself, 6,000 tonnes/year were imported in partly finished products (e.g. masterbatch, epoxy resins) and 20,200 tonnes/y were imported in finished products and components. Assuming that 20% of the 40,000 tonnes/year are used additively, the additive use of TBBPA (= total content of marketed EE products) can be estimated at 8,000 tonnes/year.

No new data on the consumption of the TBBPA derivatives have been available. The European market volume for carbonate oligomer of TBBPA in 1998 was 2,150 tonnes while the market for TBBPA bis (2,3-dibromopropyl ether) was 1,500 tonnes (IAL Market Report as cited by Lassen et al. 1999).

6.5 Available alternatives

A number of brominated flame retardants exist that can substitute for the additive use of TBBPA in ABS, but at the moment no non-brominated alternatives are available for this polymer. Manufactures of EEE, who are going for a non-brominated flame retardant, have typically changed to another polymer/flame retardant system.

Polymer/FR systems marketed for manufacturing of enclosures of EEE is shown in Table 6.3. All the BFRs are applied together with antimony trioxide (ATO) as a synergist.

Table 6.3
TBBPA and derivatives and selected alternative flame retardants for relevant V-0 grade plastics in enclosures of EEE (derived from Lassen et al., 2006)

Note: ATO= Antimony trioxide added as synergist

In the USA (around 2002) the main system applied for computer monitor enclosures was PC/ABS with resorcinol bis (diphenylphosphate). Other polymers such as PC or PPO/HIPS with resorcinol bis (diphenylphosphate) took up less than 1% of the monitors market, while the US TV enclosure market was totally dominated by HIPS with deca-BDE. The European market has been quite different from the market in USA and Pure Strategies (2005) note that PPO/HIPS with resorcinol bis (diphenylphosphate) was used throughout Europe and roughly 20,000 metric tons was used in the EU TV enclosure market.

Polymers used by important European producers of TV-sets are shown in Table 6.4. Al the produces are mostly using polymer blends with –non-halogenated flame retardants, but the actual flame retardants are not reported.

Table 6.4
Polymers and flame retardants used by five important producers of TV-sets for the European market (based on Lassen et al., 2006)

Much of the available information on alternatives to the additive use of TBBPA and derivatives in EEE originate from assessments of substitutes for octa-BDE and deca-BDE. In these assessments TBBPA is assessed together with other alternatives.

The polymer/flame retardant systems used in computer monitors and TV back casings are assumed to be applicable to all applications of structural parts of EEE made of flame retarded ABS or HIPS with TBBPA or derivatives.

6.6 Socioeconomic impacts

6.6.1 Substitution costs for enclosures

The cost considerations for replacing TBBPA in ABS are quite comparable to earlier considerations regarding the replacement of octa-BDE in ABS. A Risk Reduction Strategy for octa-BDE from (Corden and Postle, 2002) included a detailed assessment of the cost of substituting octa-BDE in ABS. The price of ABS with TBBPA is mentioned to be slightly lower than the price of ABS with octa-BDE. Total costs of substitution of the octa-BDE was nearly the same whether ABS with an alternative BFR, 1,2-bis(pentabromophenyl) ethane, or an alternative polymer with halogen-free flame retardant were used. The total polymer/flame retardant cost increase was estimated at 10%. Compared to an ABS/TBBPA system the price increase would be slightly higher. Furthermore, the cost estimate included an estimate for R&D by companies using octa-BDE. The total R&D costs for UK manufacturers were estimated at 0.5 m€, while the cost due to the increased price of flame retardants was estimated at 1.2 m€/year. To this was added the costs of replacing moulds.

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 15%. At the time of the study (2002) the price of ABS with octa-BDE was about 1.4 €/kg and the price of alternatives about 1.6 €/kg.

The study concluded that if the increased costs were passed on to the consumer, the percentage increase in the average price of products would be between 0.19% and 0.30%, taking into account an estimated 3 million products on the market per year (Corden and Postle, 2002).

In a newer study (Lassen et al. 2006) report on the basis of information from a major market actor that the price of HIPS/PPE + halogen-free flame retardant was in the range of 2.30 – 2.90 €/kg whereas the price of PC/ABS is indicated at 2.60 – 2.80 €/kg (European prices). The prices of these co-polymer systems were about 150% the price of HIPS with other BFRs than deca-BDE. No data on ABS with TBBPA is indicated but it is certainly higher than the price of the HIPS with other BFRs.

The total price increase of changing ABS with TBBPA by copolymers with halogenfree flame retardants can based on the information above roughly be estimated at 0.3-0.7 €/kg ABS including R&D costs distributed over 5 years. The price increase is based on European prices - as much of the TBBPA is imported with EEE from Asia the actual price difference may be lower, but European prices are used here for indication of the incremental costs.

The total incremental costs to the consumers can be roughly estimated using the following assumptions:

• Total volume of additively used TBBPA in EEE: 8,000 tonnes year.
• Total volume of ABS polymer assuming an average TBBPA load of 22%: 36,000 tonnes/year.
• Total incremental costs assuming that all TBBPA is used in ABS and replaced by copolymers with non-halogenated flame retardants: 11-25 million €/year.

Considering the uncertainties related to the assumptions the total incremental costs are roughly estimated to be in the range of 5-30 million €/year. The costs may decrease over the years as result of a larger market for the alternatives.

All TBBPA is certainly not used in ABS, but the incremental costs for other additive uses of TBBPA are assumed to be close to the same range and would have a small influence on the estimated total.

6.6.2 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).

The manufacturers of alternative flame retardants would benefit from a restriction of additive use of TBBPA in EEE, although the impact in the short term may be moderate. Halogen-free alternative flame retardants that may serve as alternatives to TBBPA in EEE are manufactured primarily by 6 European companies, of which 5 have headquarters within the EU (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, TBBPA containing parts may be produced by themselves or by subcontracting 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.

6.6.3 Impacts on waste management

The considerations regarding waste management are identical to the considerations for HBCDD in section 2.6.3.

6.6.4 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. TBPPA is typically used additively in parts where deca-BDE or octa-BDE have traditionally also been used and compliance documentation would usually be required for such parts. This cost element is therefore not included further in the assessment made here.

The main extra costs are estimated to be related to control; both by the manufacturers, importers and the authorities. The presence of TBBPA cannot be determined by simple XRF screening (only the presence of Br and Sb), therefore sampling, extraction and laboratory analysis is required. As the parts that may contain TBBPA typically also may contain other RoHS substances (e.g. octa-BDE or deca-BDE) 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 the PBDEs 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 extra costs of an analysis for TBBPA in ABS in Denmark, if the sample is already analysed for PBDE, is reported to be about 40€ (excl. VAT). The extra costs of analysis of TBBPA and HBCDD in HIPS, if the sample is already analysed for deca-BDE is about 60€ (excl. VAT). All prices are per sample when more than 20 samples are analysed.

6.7 Impacts on health and environment

Antimony trioxide
TBBPA used additively is in general used together with antimony trioxide, Sb₂O₃ (same as diantimony trioxide). According to the EU Risk Assessment for antimony trioxide, critical endpoints with respect to human health are skin irritation, local pulmonary toxicity and carcinogenicity. Antimony trioxide is considered to be a carcinogenic substance and is classified for carcinogenicity, Carc. 2. The risk assessment concludes that there is a need for limiting the risks to workers working with the substance e.g. in the use as flame retardant in plastics.

Assessment of alternatives
No comparative assessments focusing on alternatives to TBBPA have been identified, but a number of assessments of alternatives to octa-BDE, deca-BDE, and HBCDD have been undertaken in the recent year. TBBPA has been included in several of the assessment together with other possible alternatives, and a summary of the results of the following recent assessments is provided below:

• Assessment of alternatives to deca-BDE by Washington State Department of Health (2006)
• Assessment of alternatives to deca-BDE for the Danish EPA (2006)
• Assessment of alternatives to deca-BDE by Illinois Environmental Protection Agency (2007)
• Assessment of alternatives to HBCDD for European Chemicals Agency (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 TBBPA. The data for some of the substances relevant for the current study is shown in Table 6.5. 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. TBBPA is considered to meet the PBT criteria of WSDH, which is in contrast to the PBT evaluation in the EU Risk Assessment. 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 rescorcinol bis(biphenylphosphate (RDP) and bisphenol A diphosphate (BAPP or BDP) are each described as “one of the more promising alternatives”, but it is noted that information on toxicity is limited.

Table 6.5
Summary of persistence, bioaccumulation potential and toxicity information for selected potential alternatives (Based on Washington State, 2006)

Click here to see Table 6.5

As to human health no major differences in rating were found between TBBPA and TPP, whereas the TPP rated better than TBBPA with respect to persistence in the environment.

Contrary to the assessment from WSDH, but in accordance with the EU Risk Assessment, Stuer-Lauridsen et al. found that there was no evidence of bioaccumulation of TBBPA.

Table 6.6
Key toxicological and environmental properties of TBBPA and some potential alternatives. (original data from Stuer-Lauridsen et al., 2006 – the table is here based on a revised table in Lassen et. al, 2007)

Parameters: carcinogenicity (C), mutagenicity (M), reproductive toxicity (R), endocrine disrupting effects (E), sensibilisation (S), persistence (P), bioaccumulation(B) and aquatic toxicity (T). The symbol + indicate a potential hazard, - indicates no potential hazard identified and 0 indicates that no data are available.
* A As a worst case polymers are assessed by their monomer, in this case TBBPA

Assessment of alternatives to deca-BDE by Illinois Environmental Protection Agency (2007)
Illinois Environmental Protection Agency (IEPA, 2007) summarised toxicity data on non-halogenated alternatives to deca-BDE. They applied in their assessment a rating system based on a number of endpoints: Cancer, reproductive/developmental toxicity, systemic toxicity, local effects, acute environmental effects, chronic environmental effects and persistence, bioaccumulation and toxicity. TBBPA was not assessed and therefore the data cannot be used for comparison of TBBPA and possible alternatives. Based on the rating the agency grouped the potential alternatives into four groups : a) Potentially unproblematic, 2) Potentially problematic, 3) Insufficient data and 4) Not recommended.

Among the potentially unproblematic substances are some of the main alternatives to TBBPA in enclosures, which are reviewed as follows (IEPA, 2007):

• BAPP: Low Concern for most endpoints based on existing data and professional judgment; key data deficiencies include cancer, two-generation reproductive/developmental effects, and chronic aquatic toxicity studies; some concern due to generation of Bisphenol A, a chemical identified by the Agency as a probable endocrine disruptor, as a breakdown product, although no data on potential amounts were found.
   
• RDP: No Concern for reproductive/developmental effects; no chronic aquatic toxicity data; Low Concern for other effects based on existing data and professional judgment; key data deficiencies include cancer, chronic systemic effects, and chronic aquatic toxicity studies.

Aluminum trihydroxide and magnesium hydroxide are listed in the group of potentially unproblematic, but these substances cannot be considered immediate alternatives to the main additive uses of TBBPA.

The triphenyl phosphate and antimony trioxide were together with a number of other potential alternatives to deca-BDE included in the group of “Potentially problematic” with the following review (IEPA, 2007):

• Triphenyl phosphate: High Concern for acute and chronic aquatic toxicity (very wide range of fish lethality levels); Low Concern for other effects based on existing data and professional judgment; key data deficiencies include cancer and two-generation reproductive/developmental studies.
   
• Antimony trioxide: High Concern for blood effects; Moderate Concern for cancer and lung irritation effects; no data for reproductive/developmental and neurological effects; Low Concern for other effects; key data deficiencies include additional cancer studies, and reproductive/developmental and neurological effects studies.

Whereas Lauridsen et al. (2006) ranked the aquatic toxicity of triphenyl phosphate to be low, both the assessment from Illinois and Washington find that there is enough data for concluding that there is basis for a concern about acute and chronic aquatic toxicity.

Assessment of alternatives to HBCDD for Europan Chemicals Agency
In an assessment for the European Chemicals Agency of alternatives to HBCDD, IOM (2008) assessed a number of alternatives to HBCDD in HIPS which may also be considered alternatives to additive use of TBBPA (Table 6.7).

Table 6.7
Summary for Human health and environmental properties of selected alternatives to HBCDD used in HIPS

Summary on health and environmental assessment
A number of alternatives to TBBPA exist which may potentially be less problematic than TBBPA, but data are missing for critical endpoints (e.g. carcinogenity). Phosphate esters have been mentioned as promising alternatives to deca-BDE, but considering that TBBPA, according to the EU Risk Assessment neither a CMR nor a PBT substance, the same conclusion cannot be drawn for TBBPA without more comprehensive data on the phosphate esters.

As TBBPA in general is used in conjunction with antimony trioxide (ATO) the comparison should in principle be done between the TBBPA/ATO flame retardant system and the alternatives. The fact that antimony trioxide is a carcinogen may influence the assessment of the TBBPA/ATO system, but none of the studies have included a common assessment of the two substances.

6.8 Conclusions for TBBPA

The main concern regarding TBBPA is its toxicity in the aquatic environment and possible effect on the endocrine system of breakdown products in the environment.

According to the EU Risk Assessment, TBBPA does not meet the criteria for being a CMR, a vPvB or a PBT substance. TBBPA is not on the Candidate List of SVHC substances currently proposed for inclusion in Annex XIV of REACH. When used additively TBBPA is used in conjunction with antimony trioxide (ATO) which is classified for carcinogenicity.

The main application of TBBPA used additively in EEE is in ABS plastic used for closures and structural parts of different types of EEE. The total content of additively used TBBPA in EEE marketed in the EU is estimated at some 8,000 tonnes/year assuming that 20% of the 40,000 tonnes/year in marketed EEE is used additively.

The additive use of TBBPA is not deemed essential as technically suitable alternative substances and materials are available and already used extensively today. The main alternatives for ABS/TBBPA/ATO systems are ABS with other brominated flame retardants and ATO or co-polymers (e.g. PC/ABS, PS/PPE, HIPS/PPO) with phosphate esters.

Costs - The prices of alternatives are typically 10-50% higher than ABS/TBBPA/ATO systems and it is estimated that the total incremental costs at the production level of replacing additively used TBBPA in all EEE may likely be some 5-30 million €/year depending on the actual alternatives being introduced (European prices). The costs may decrease over the years as result of a larger market for the alternatives.

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

Benefits - A number of alternatives to TBBPA exist which may potentially be less problematic than TBBPA, but data on the alternatives are missing for critical endpoints (e.g. carcinogenicity). Phosphate esters have been evaluated as promising alternatives to deca-BDE, but considering that TBBPA is neither a CMR, a vPvB nor a PBT substance, it may be considered necessary to have a more robust basis for decision on its inclusion in the RoHS directive.

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Version 1.0 March 2010, © Danish Environmental Protection Agency