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TBBPA as a flame retardant

Stakeholder Consultation: Analysis of alternatives for the use of TBBPA as a flame retardant

Overview and survey links

Overview presentation

Please view our short (7 minute) presentation on the TBBPA analysis of alternatives and stakeholder consultation. The presentation includes:

  • An overview of the regulatory context of the study
  • A summary of the purpose of both the analysis of alternatives and stakeholder consultation exercise, highlighting how you can participate and why your input is critical
  • An overview of the confidentiality provisions in place surrounding the consultation exercise.

Survey links are available directly below the presentation and are proceeded by a more detailed written overview of the study.

 

Survey links

Using the following links, please download and complete the survey which best describes your role concerning TBBPA (all surveys have been prepared in Microsoft Excel format and contain further instructions):

 

Response deadline *UPDATE: DEADLINE EXTENDED UNTIL FRIDAY 31 MAY 2024*

Please send your completed survey to Apeiron-Team’s dedicated inbox: TBBPA@apeiron-team.eu by Friday 31 May 2024.

In case of any questions or clarifications, please reach out via the same email address or call +32 (0)3 808 20 67.

We look forward to your support and contribution.

 


 

Full details

Regulatory background

In March 2023, the European Chemicals Agency (ECHA) published its ‘regulatory strategy for flame retardants’. Amongst several conclusions, the strategy recommended that ‘aromatic brominated flame retardants’ (those containing a benzene ring in their structure), are investigated to understand whether their use should be subject to a restriction under REACH. 

Following on from the publication of the regulatory strategy, in December 2023, the European Commission sent a request to ECHA to prepare an investigation report to gather further information on flame retardants. Amongst several aspects, the information report should “outline as far as possible which alternative substances or technologies are available that provide flame retardancy in the materials or for the uses in which currently aromatic brominated flame retardants are used”.

As a result of the investigation report request, ECHA confirmed that several calls for evidence would be carried out to gather information from interested parties.

One call for evidence on uses, volumes and end-of-life considerations ended on 5 April 2024 and another (with a focus on alternatives) is anticipated to be launched at the end of April 2024.

ECHA’s investigation report must be completed by the end of 2024 and will support the European Commission in a decision on whether a mandate to ECHA for the preparation of a restriction dossier is required.

As indicated by the following figure, a REACH restriction could be formally proposed as soon as 2025.

Within the background note to the first call for evidence, ECHA published a non-exhaustive list of 50 aromatic brominated flame retardants within scope of the investigation report. These substances have been categorised within the following groups: ‘brominated diphenyl ethers’, ‘brominated phthalates’, ‘TBBPA and its derivatives’, ‘bromophenols’ and ‘other’.

Purpose of the analysis of alternatives

Considering the above regulatory environment Apeiron-Team NV has been contracted by ICL under the umbrella of a work programme developed by BSEF (the International Bromine Council) to prepare an analysis of alternatives (AoA) for Tetrabromobisphenol A (TBBPA) – CAS No: 79-94-7; EC No: 201-236-9.

ICL is the lead registrant for TBBPA and is making efforts to engage TBBPA co-registrants in this activity.

Whilst ECHA’s investigation report is focused on a wider pool of substances, this AoA is specifically focusing on TBBPA because: 

  • It is one of the core substances in focus within ECHA’s Flame Retardants Strategy
  • It is one of the most commonly used brominated flame retardants
  • It has both additive and reactive uses

 

The AoA is considering whether there is a means to replace the functions performed by TBBPA. Alternatives may be chemical substances or non-chemical alternatives (e.g. materials or technologies), and the AoA is also considering aspects including technical feasibility, economic feasibility, availability and suitability.

The overall purpose of preparing the AoA is to ensure that accurate and robust information can be provided to the authorities (e.g. ECHA and the European Commission) on the substitution potential for TBBPA across relevant uses and sectors. Considering the potential for a future restriction proposal, development of a robust AoA for TBBPA early in the regulatory process will encourage the adoption of proportionate regulatory measures and ensure that stakeholder voices are heard.

Request for stakeholder participation

In order to provide a strong AoA with robust and credible conclusions, a significant amount of data from industry and other actors is required. Apeiron-Team is therefore launching a consultation with stakeholders to gather information on the uses and functions of TBBPA, as well as the availability and suitability of potential alternatives (including those that may have already been deemed as unsuccessful or unsuitable).

As noted above, the study team is aware of calls for evidence that have been (and will continue to be) launched by ECHA in order to assist in the development of their investigation report on flame retardants. Whilst stakeholders are encouraged to participate in ECHA’s information requests, participation in this parallel industry led exercise will also be critical for all actors in the TBBPA supply chain.

Using the links at the top of the page, please download and complete the survey which best describes your role concerning TBBPA (all surveys have been prepared in Microsoft Excel format and contain further instructions).

Confidentiality

Please note that all information collected via the stakeholder survey will be visible only to Apeiron-Team and treated confidentially. Apeiron-Team will not share survey responses with ICL, BSEF or any other organisation.

The collected information will only be used for the TBBPA AoA project. Survey responses will be anonymised meaning that information will be reported without any individual attribution. Furthermore, any quantitative data received will be suitably aggregated with that of other respondents.

Apeiron-Team is very well versed in the handling of confidential information via stakeholder surveys and we encourage you to reach out if you require any further assurances.

Survey submission and deadline *UPDATE: DEADLINE EXTENDED UNTIL FRIDAY 31 May 2024*

Please send your completed survey to Apeiron-Team’s dedicated inbox: TBBPA@apeiron-team.eu by Friday 31 May 2024.

In case of any questions or clarifications, please reach out via the same email address or call +32 (0)3 808 20 67.

We look forward to your support and contribution

Privacy note

Personal data (i.e. name, email address, telephone number) collected as part of this consultation exercise will not be shared outside of the Apeiron-Team project team or used outside the context of the project. A privacy note for Apeiron-Team surveys can be viewed here.

 

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