Context and scope of the substance assessment

• Author: Clemm, Christan; Löw, Clara; Baron, Yifaat; Moch, Katja; Möller, Martin; Köhler, Andreas R; Gensch, Carl-Otto; Deubzer, Otmar
• Pages: 7-8

RoHS Annex II Dossier, final

TBBP-A (flame retardant)

7

CONTEXT and SCOPE of the Substance Assessment

The substance assessment of 2,2',6,6'-tetrabromo-4,4'-isopropylidenediphenol or tetrabromobis-

phenol A (TBBP-A, flame retardant), respectively, is being performed as part of the “Study on the

review of the list of restricted substances and to assess a new exemption request under RoHS 2 –

Pack 15”. With contract No. 07.0201/2017/772070/ENV.B.3 implementing Framework Contract

No. ENV.A.2/FRA/ 2015/0008, a consortium led by Oeko-Institut for Applied Ecology has been as-

signed by DG Environment of the European Commission to provide technical and scientific support

for the review of the list of restricted substances and to assess a new exemption request under RoHS

2. This study includes an assessment of seven substances with a view to the review and amendment

of the RoHS Annex II list of restricted substances. The seven substances have been pre-determined

by the Commission for this task. The detailed assessment is being carried out for each of the seven

substances in line with a uniform methodology.1

In the course of the substance assessment, the 1st stakeholder consultation was held from 20 April

2018 to 15 June 2018 to collect information and data for the seven substances under assessment.

Information on this consultation can be found at Oeko-Institut’s project webpage at:

http://rohs.exemptions.oeko.info/index.php?id=289.

For TBBP-A, a total of 11 contributions were submitted by different stakeholders. An overview of the

contributions submitted during this consultation is provided in Appendix I. The contributions can be

viewed at http://rohs.exemptions.oeko.info/index.php?id=295.

Among these contributions, a study from the Fraunhofer Institutes ITEM and IPA has been submit-

ted, which is an assessment of TBBP-A performed according to the “Methodology for Identification

and Assessment of Substances for Inclusion in the List of Restricted Substances (Annex III) under

the RoHS 2 Directive, thus in the format of a RoHS dossier which was mandated and funded by

BSEF, the Bromine Science and Environmental Forum.2 Though no date on when the study was

conducted is indicated, it is understood as a very recent data compilation. In August 2018, after the

stakeholder consultation was closed, the BSEF provided an updated version of this assessment. It

is understood that the update overall covers the DNELs retrieved from the ECHA Registered Sub-

stance Database that has been lowered in the last years. In the following, this updated assessment

is referred to as Fraunhofer ITEM IPA, Wibbertmann and Hahn (2018).3

Nine different stakeholder contributions were received during the 2nd stakeholder consultation which

was held from 05th December 2019 to 13th February 2020. The contributions can be viewed at

http://rohs.exemptions.oeko.info/index.php?id=333.

1 This methodology includes a dossier template for substance assessment which had been prepared by the Austrian

Umweltbundesamt GmbH in the course of a previous study. The methodology for substance assessment has been

revised based on various proposals from and discussions with stakeholders. Among others, revisions have been made

to clarify when the Article 6(1) criteria are considered to be fulfilled and how the precautionary principle is to be applied.

The methodology has also been updated in relation to coherence to REACH and other legislation and publicly available

sources of relevance for the collection of information on substances have been updated and added. The methodology

is available at https://rohs.exemptions.oeko.info/index.php?id=341

2 Frauenhofer ITEM & IPA, Hesse, Susanne; Wibbertmann, Axel; Hahn, Stefan; Miehe, Robert; Müller, Sebastian (no

year): Assessment of TBBP-A (tetrabromopisphenol-A) according to the “Methodology for Identification and

Assessment of Substances for Inclusion in the List of Restricted Substances (Annex III) under the RoHS2 Directive”.

Update August 2018. Fraunhofer ITEM, Fraunhofer IPA, Stuttgart; submitted as part of the contribution submitted by

BSEF, aisbl – The International Bromine Council during the TBBP-A stakeholder consultation conducted from 20 April

2018 to 15 June 2018

3 Fraunhofer ITEM IPA, Wibbertmann and Hahn (2018): Assessment of TBBP-A (tetrabromopisphenol-A) according to

the “Methodology for Identification and Assessment of Substances for Inclusion in the List of Restricted Substances

(Annex III) under the RoHS2 Directive”. Update August 2018. Fraunhofer ITEM, Fraunhofer IPA, Stuttgart.