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    Currently the EU regulations that restrict certain halogenated flame retardants are RoHS and REACH.



    RoHS currently restricts PBB and PBDE with no exemptions.


    The proposed recast will not include restrictions on any other halogenated flame retardants but will introduce a comitology procedure (i.e. carried out by the EC) for restricting additional substances which will include these types of compounds and, as a result, HBCDD is likely to be considered at an early stage. The procedure is likely to be risk based and similar to the restrictions procedure used by REACH, but will have an emphasis on risks at the end of life phase.


    The EP proposal to include all halogenated flame retardants in Annex III of the recast appears to have been dropped as Annex III will probably not be included. Member States will however propose specific substances for restriction by RoHS once the comitology procedure is in place.



    REACH also restricts a few specific halogenated flame retardants including penta-BDE and octa-BDE. In addition, there are so far three that are SVHCs; HBCDD, SCCP and Tris(2-chloroethyl)phosphate, the first two of which  have been proposed to require authorisation for use. In the future, more specific halogenated flame retardants that meet the Article 57 criteria will be proposed to be SVHCs.



    Outside of the EU, only certain US States have so far imposed restrictions on penta-BDE, octa-BDE and a few also on Deca-BDE. China RoHS, Korea RoHS and Japan (J-MOSS) have information requirements for PBB and PBDE but no restrictions, although China will restrict PBB and PBDE (but possibly not Deca-BDE) in its catalogue listed products when this is adopted and enters force.



    Green Groups are still actively targeting halogenated flame retardants and are putting pressure on manufacturers and retailers to avoid these substances irrespective of legislation or the potential risk from substitutes.



    With thanks to Dr. Paul Goodman of Cobham Technical Services (ERA Technology)





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