Alternatives

• Author: Clemm, Christan; Löw, Clara; Baron, Yifaat; Moch, Katja; Möller, Martin; Köhler, Andreas R; Gensch, Carl-Otto; Deubzer, Otmar
• Pages: 49-62

RoHS Annex II Dossier, final

Diantimony trioxide (flame retardant)

49

8 ALTERNATIVES

ATO acts as a synergist for halogenated flame retardants. As the scope of this assessment

addresses ATO on its own and in combination with the halogenated flame retardants included in this

current review, this section on alternatives will cover the following possibilities for substituting ATO:

• Substituting ATO as a synergist, also referred to as mono-substitution;

• Substituting the halogenated flame retardant together with ATO as synergist ATO – hereafter

referred to as co-substitution;

• Alternative technologies.

Alternatively, it was proposed by stakeholders during the 2nd consultation114 to evaluate substitutes

in relation to individual applications instead of a general assessment for EEE covered under RoHS.

“There is no way of performing a general assessment of alternatives, but rather this should be done

for each application separately.115” Such an assessment could take into account life cycle impact of

alternatives, technical or cost impacts of substitution and substance-specific FR performance,

recycling potential, recycled contents applicable in the polymers, environmental and human health

“at the same level” as demanded in the contribution of i2a (2020) and Campine (2020). However,

according to the methodology for substance assessment under RoHS, the assessment of possible

substitutes and other alternatives should go as far as necessary to “allow understanding, in which

applications substitutes or alternative technologies are already applied and subsequently to what

degree the substance (or substance group) has been phased-out. Where differences occur related

to substitute or alternative technology implementation, such as between manufacturers of certain

regions, product or component categories, etc., this should be specified. It should also be specified

whether substitutes or alternative technologies can be considered to have less negative impacts

(interpreted in comparison with the impacts of the substance in relation to the Article 6(1)(a-c)

criteria).” A detailed case-by-case examination (as requested by some stakeholders) of concrete

applications that use substances restricted under RoHS not feasible here.

Various information sources have been used to gather information on alternatives and to compen-

sate for missing information from stakeholders during the consultation. Besides information by manu-

facturers of alternatives, voluntary industry approaches have been reviewed. Furthermore, other

studies have been investigated. Regarding costs, it should be noted that, generally speaking, data

are hardly explorable in desktop research, and information on costs are vague.

Availability of substitutes / alternative technologies

8.1.1 Alternatives to ATO as synergist for flame retardants

Other substances acting as synergist can be used alternatively to ATO., However, even in the

absence of “halogenated flame-retardants” ATO plays an important role in the flame retardancy of

PVC cables. Alternatives for both cases are based on zinc, tin or other metal salts:

Tin compounds, so-called stannates: There are several stannate compounds on the market under

the trade name “Flamtard”116; they are used as polymer additive providing the smoke supressing

114 Op. cit. ZVEI (2020), Campine (2020), and i2a (2020)

115 Op. cit. i2a (2020)

116 https://www.williamblythe.com/markets/polymer-additives/ last viewed 20.11.2019)