Description of socio-economic impacts

• Author: Clemm, Christan; Löw, Clara; Baron, Yifaat; Moch, Katja; Möller, Martin; Köhler, Andreas R; Gensch, Carl-Otto; Deubzer, Otmar
• Pages: 60-68

RoHS Annex II Dossier, final

TBBP-A (flame retardant)

60

9. DESCRIPTION OF SOCIO-ECONOMIC IMPACTS

9.1. Approach and assumptions

In this section, possible socio-economic impacts of a scenario in which TBBP-A is to be restricted

are compared with the current situation (business as usual) in which TBBP-A is not restricted. In this

respect, the section shall address the differences between two scenarios:

• a restriction scenario; and

• the current non-restriction scenario.

The essence of this analysis is based on the understanding as to which applications shall be affected

by a restriction scenario. In principal, as presented in the above sections as well as in section 10,

TBBP-A is applied in two application areas which could be affected from a restriction; reactively in

epoxy resins of PWBs and additively in plastic housings and enclosures of EEE.

In reactive applications, TBBP-A undergoes a chemical reaction and is generally not present in the

final component in its original form. On the condition of good practice, existing evidence suggests

that the concentration of TBBP-A remaining in cases of its application in epoxy resins in PWBs is

well below the proposed restriction threshold (see section 10). In such cases impacts are not

expected and shall not be addressed in the sub-sections below. Cases of bad practice, where TBBP-

A may remain at higher levels in the final component, may be affected if they exist. Since in such

cases substitution of this substance may be avoided through the application of good practice, this

sub-case shall also not be looked into separately: As in most cases, standard manufacture practices

do not result in residual TBBP-A in concentrations above the proposed threshold, it must be assumed

that the costs of improvements in production practices are acceptable and would be justified with the

benefit of reducing the amount of residual TBBP-A and preventing possible emissions.

In the case of additive uses, it has been shown that these remain in the final product and may emit

through use or at end-of-life, resulting in possible impacts on consumers and or on workers of waste

management facilities. Emissions have shown up in the environment, suggesting that TBBP-A is a

persistent substance and its increasing presence could result in an impact on the environment

(aquatic toxicity). Thus, other impacts related to a restriction are to be weighed against the benefits

of removing TBBP-A from the plastic material cycle and thus to preventing (or decreasing) possible

impacts on the environment and on health with which its presence and emissions are related.

9.2. Impact on chemicals industry

Manufacturers of flame retardants

In terms of the manufacture of TBBP-A, BSEF specify that it is produced mainly in Israel, Jordan,

the United States, Japan and the PR of China.159 These countries are understood to be the main

countries where bromine is sourced and bromine-based chemicals are manufactured.

To understand how these industries shall be affected, it is necessary to know how the restriction

shall affect the use of TBBP-A in articles placed on the EU market as well as in the global production

of EEE. Generally, in a restriction scenario, it can be expected that the production of TBBP-A is to

decrease, as it shall no longer be permitted in EEE to be placed on the EU market. It is, however,

also possible that the EU restriction will affect EEE to be placed on other markets:

159 BSEF, Fact sheet TBBP-A: Tetrabromobisphenol A for Printed Circuit Boardsand ABS plastics (2007): Brussels,

Belgium