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To: MEPs
Re: Call for restriction of BFRs and PVC in electrical and electronic equipment in the RoHS revision

The RoHS Directive must, in accordance with its stated objectives, consider the impact of chemical substances and their transformation products in the production, use and waste phase. It should therefore promote the substitution of hazardous substances in Electrical and Electronic Equipment (EEE) to protect the environment and human health and enhance the possibilities for recycling, based on swift uptake of new scientific evidence, and the precautionary principle.

We, the undersigned public interest organisations, accordingly urge the European Parliament to strengthen the European Commission proposal for a revised RoHS Directive, and in particular:

  • Restrict by 2015 at the latest halogenated organic substances in EEE, to a maximum of 0,1% (w/w) such as Brominated Flame Retardants (BFRs) and Polyvinyl Chloride (PVC) that cause serious concern throughout their lifecycle (production, use, disposal) and hamper recyclability

Background

The objective of the RoHS Directive is to protect human health and the environment and, more specifically, to contribute to environmentally sound recovery and disposal of electrical and electronic equipment1. Many substances with undesirable properties such as being Persistent, Bio-accumulative and Toxic (PBTs) or Carcinogenic, Mutagenic or Toxic for Reproduction (CMRs), endocrine disrupting or otherwise hazardous because of their nanoscale, are used in many Electrical and Electronic Equipment (EEE).

In order to eliminate the adverse effects of hazardous substances and highly toxic transformation products in the life cycle of EEE, a number of prominent actors, equipment manufacturers and component suppliers have invested in substitution of hazardous substances in EEE including a general phase-out of halogenated organic substances.

Their efforts have led to the transformation of the electronics supply-chain globally. This is not only due to the global nature of the supply chains in the EEE industry but also due to the fact that the EU RoHS legislation has been taken over by many other political entities outside the EU. In the case of RoHS, and contrary to what is commonly assumed, globalization has not led to a race to the bottom in environment and health protection policy. RoHS has triggered the introduction of similar regulations in California, China, Japan and South Korea. Australia, New Zealand, Malaysia, Taiwan and Thailand are currently considering the introduction of a similar policy. Setting a new high environment and health protection standard through the current RoHS revision in the EU will improve the environment and health both inside and beyond the EU.

EU regulators now have a unique possibility support and uphold the momentum gained in parts of the industry by strengthening the RoHS Directive. We, the undersigned public interest organisations, consequently urge you to strengthen the European Commission proposal for a revised RoHS Directive.

Some supporting arguments:

Some phthalates which are used as plasticizers in PVC are classified in the EU as toxic to reproduction, recognised as Substances of Very High Concern under REACH2, and are also Endocrine Disrupting Chemicals (EDCs)3. The endocrine disrupting effects of halogenated flame retardants like TBBP-A are also demonstrated in the scientific literature4,5. TBBP-A is widely used in EEE - about 40.000 tonnes per year in the EU alone - and has been found in human blood-samples and human breast milk as well as in remote regions including the Arctic and in all kinds of animals (in wide variety of marine organisms, predatory birds, etc). Although there remain scientific gaps in order to determine the official classification of TBBP-A, existing evidence indicates that TBBP-A is very toxic to aquatic organisms; is persistent and potentially very persistent, and there are potential endocrine disruption effects.

Another reason for banning halogenated organic substances and materials in EEE is because they have the potential to form dioxins and furans when incinerated under suboptimal conditions or otherwise subjected to thermal stress like extrusion, moulding, shredding or sunlight exposure. Dioxins are classified as very toxic and very persistent substances, and are recognized as priority contaminants in the Stockholm Convention for the elimination of Persistent Organic Pollutants (POPs). Thus their formation is both a local and global problem and damages health and environment at a global scale, irrespective of where they are formed.

The restriction of halogenated organic substances will:

  • increase the reusability and recyclability of EEE and, at the same time,
  • protect humans and especially vulnerable groups like babies and children and highly exposed populations such as workers in the electronics recycling industry from cumulative exposure to chemicals that are demonstrated to pose severe health hazards
  • confirm progress and support the momentum gained in parts of the industry by strengthening their voluntary substitution commitments
  • improve the environment and public health both inside and beyond the EU

For more information on alternatives to BFRs please consult “Alternatives to Brominated Flame retardants “ presented on 23rd March 2010 by the Phosphorus, Inorganic, Nitrogen Flame Retardants Association http://www.chemsec.org/images/stori... European_Parliament_RoHS_20100323_Final.pdf

Please also see Industry Position Papers supporting the proposals for PVC and BFR substance bans in the RoHS revision by:
- ACER http://www.chemsec.org/images/stori... Cl_Br-free_of_RoHS_Revision.pdf),
- Hewlett Packard http://www.chemsec.org/images/stori...
- and Dell http://i.dell.com/sites/content/cor.... pdf

1 Article 1, 2002/95/EC, RoHS Directive.

2 REACH Regulation No 1907/2006, OJEU 29.05.2007. Substances of Very High Concern list: http://echa.europa.eu/chem_data/aut...

3 See the ‘Priority List’ and studies commissioned for European Commission’s DG Environment, where ‘Category 1’ EDCs are listed: http://ec.europa.eu/environment/end...

4 Lilienthal, H., Verwer, C.M., Van der Ven, L.T.M., Piersma, A.H., Vos, J.G., 2008. Neurobehavioral effects of tetrabromobisphenol A (TBBPA) in rats after pre- and postnatal exposure. Toxicology

5 Van der Ven LT, Van de Kuil T, Verhoef A, Verwer CM, Lilienthal H, Leonards PE, Schauer UM, Cantón RF, Litens S, De Jong FH, Visser TJ, Dekant W, Stern N, Håkansson H, Slob W, Van den Berg M, Vos JG, Piersma AH., 2008. Endocrine effects of tetrabromobisphenol-A (TBBPA) in Wistar rats as tested in a one-generation reproduction study and a subacute toxicity study. Toxicology

Last updated on 13 June 2011

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