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Waste Electrical and Electronic Equipment Directive

You may be aware that the European Commission’s DG XI has recently distributed the 2nd draft of the "Proposal for a Directive on Waste from Electrical and Electronic Equipment" (WEEE).  In this draft, a proposal is made to phase out Halogenated Flame Retardants (HFRs) by 1 January 2004 if alternative flame retardants can meet minimum fire safety standards. EBFRIP would wish to highlight the following concerns with this element of the draft proposal:

1. A phase-out of HFRs will result in diminished fire safety. Most original equipment manufacturers (OEMs) have traditionally exceeded the minimum levels of fire safety required by European standards. Enactment of the draft WEEE Directive will seriously diminish, if not eliminate, the ability of OEMs to continue to provide the level of protection which European consumers have come to expect.

2. No attempt has apparently been made to assess the relative environmental impact of halogenated and non-halogenated flame retardants. It is imperative that DG XI establishes a transparent, and scientifically-based, set of human health and environmental objectives upon which to base the draft WEEE Directive. Only then can objective comparisons be made and meaningful conclusions be reached regarding the selection of flame retardants for use in E&E products.

3. If the concern is that HFRs in some way adversely affect the recyclability of plastics, then this is not reflected by the "on-the-ground" reality of E&E recycling. In fact, the copiers industry convinced the German Environment Agency to delay eco-label criteria discriminating against brominated flame retardants precisely because HFR plastics were preferable from the point of view of recyclability.

4. Furthermore, the presence of HFRs does not affect recyclability any differently than other additives. E&E recyclers agree the presence of any additives (and not just HFRs) makes plastics less pure and hence more complicated to market.

5.  It is important to recognise that halogens in themselves can be recycled from E & E plastics. Brominated flame retardant producers, with the support of E & E recyclers, are studying processes to accomplish this on a commercial scale.

6. Finally, the proposed phase-out of HFRs would unjustifiably prevent the recycling of materials from equipment currently in use, and would preclude the development of products and processes that may provide the best solutions for future recycling goals.

EBFRIP also supports calls for energy recovery to be included in the draft proposal’s recovery targets.  Such targets need to be realistic in terms of market demand for secondary raw materials while ambitious in terms of optimising levels of recycling.  Only by including energy recovery within the recovery targets can this balance hope to be achieved.

In short, the DG XI should clarify the following points:

• What are the concerns with regard to halogenated flame retardants;
• What is the basis for these concerns;
• What is the relative environmental impact of alternative flame retardants; and
• What effect will a move away from HFRs in the EU have on E&E equipment fire safety.

Bent Jensen
EBFRIP Secretariat
3 September 1998