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24 February 2000

Draft Proposal on WEEE – Recent Scientific Evidence Calls into Question Draft Restrictions on Flame Retardants

Elements on the use of certain flame retardants in the draft DG Environment proposal on Waste Electrical and Electronic Equipment (WEEE) contradict the EU’s own risk assessments, go against recent life-cycle environmental evidence and would actually impede the recycling efforts of those E&E manufacturers with the most ambitious plans for mechanical recycling.

1. By focusing solely on environmental impact at end-of-life, the draft proposal for an EU Directive on WEEE contradicts the EU policy trend towards an Integrated Product Policy aimed at reducing environmental impact across a product’s life-cycle. The DG Environment has not taken account of the environmental benefits which flame retardants provide in reducing fires and their significant environmental impact. For example, a recent study by the Swedish National Testing and Research Institute (SP) demonstrated that, over their life-cycle, TV sets with the brominated flame retardant decaBDE emit less polyaromatic hydrocarbons (PAHs) and less dioxins and furans than those TV sets without flame retardants altogether¹.

2. Annex III of DG Environment’s draft proposal would mandate the separate treatment and disposal of a wide range of E&E equipment plastics protected from fire by halogenated flame retardants. This is based on a false assumption that these flame retardants prevent such plastics from being recycled:

• In fact, some leading-edge Japanese E&E copier manufacturers which stipulate 30% recycled plastics content in their new models, specify plastics with halogenated flame retardants partly in view of their stability during recycling².
• EBFRIP is supporting projects to facilitate material recycling of plastics containing brominated flame retardants and is promoting the development of a project to make possible feedstock recycling of E&E plastics, while recovering the bromine for re-use³.

3. The proposed phase-out of the PBDE flame retardants in E&E Equipment plastics (Article 4(4)) is also based on a false assumption that these flame retardants are not recyclable and are going to result in increased dioxin emissions. This also contradicts the preliminary conclusions of EU risk assessments:

• The EU Risk Assessments on the two PBDEs used in E&E equipment do not identify a need for any risk reduction measures.
• Tests from the leading analytical laboratory GfA in Münster, Germany⁴, demonstrate that recycling the major PBDE flame retardant decaBDE is not only feasible from a health & safety perspective, but also that the recycled end-product meets the strictest limit values for dioxins and furans under German law.
• At the same time, tests carried out at the Tamara incinerator in Germany⁵ show that, providing the combustion is carried out properly, the presence or absence of plastics containing brominated flame retardants does not affect full compliance of the recovery plant with emission limits for dioxins and furans.
• In fact, the German Environment Ministry has clearly stated its opposition to substance bans as preventing innovation in recycling by removing materials from the market which are suited to the recycling age.
• If there are environmental concerns, these should be handed separately by dangerous substances legislation and in the context of the EU risk assessments⁶.

4. By not including energy recovery in the draft proposal’s targets, DG Environment would in effect remove control of decision-making from local waste managers, excluding a recovery route which under certain circumstances makes the best sense from an environmental and economical (i.e. sustainable) point of view.

incorporate energy recovery within the recycling targets (Article 7(2)).