THE SUBSTITUTION OF REGULATED BROMINATED FLAME RETARDANTS IN PLASTIC PRODUCTS AND WASTE AND THE DECLARED PROPERTIES OF THE SUBSTITUTES IN REACH

Plastics containing brominated flame retardants (BFR) currently contain both “legacy” regulated and non-regulated BFR (R-BFRs and NR-BFRs), as evidenced by the increasingly lower correspondence over time between total bromine and R-BFRs content. The portion of substitutive NR-BFR present in the plastics and their toxicity and ecotoxicity properties are documented. Data relating to plastics and foam present in electrical and electronic equipment (EEE), waste EEE, vehicles, textiles and upholstery, toys, leisure and sports equipment show how 88% of plastic waste contains bromine from NR-BFRs. BFR substances mentioned in the catalogs of the three main producers (Albemarle, ICL, Lanxess) and BFR on the official used list of 418 plastic additives in the EU were gathered and the toxic and ecotoxic properties of these compounds as listed in their ECHA registration dossier were compiled. Fifty-five preparations using 34 NR-BFRs substances, including polymers and blends, were found. Seventeen of these substances featured an incomplete dossier, 12 were equipped with a complete dossier, whilst 11 substances (including 2 ill-defined blends) should be reassessed. Eight substances have been notified for assessment by the ECHA as persistent, bioaccumulative and toxic, or as endocrine disruptors, including decabromodiphenylethane; 3 substances display functional concentrations (the concentration of additives that retards flame) exceeding the concentration limits classifying a waste as hazardous but are “reactive” (they bind to the polymer). The technical limit of 2 000 mg total Br/kg indicated for further recycling (EN 50625-3-1) relates to all brominated substances and is relevant in the sorting of all poorly classified new substances.