Defra Contract No: SPMT09_011
Fire Retardant Technologies: safe products with optimised environmental hazard and risk performance
Annexe 4 Ecolabel Review and Awareness Study
For the attention of the Project Steering Group
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Fire Retardant Technologies: safe products with optimised environmental hazard and risk performance
Annexe 4 Ecolabel Review and Awareness Study
Authors:
Caroline Bartlett Oakdene Hollins Ian McGill Oakdene Hollins Nick Morley Oakdene Hollins Gary Stevens GnoSys UK
GnoSys Report No: GR223 GnoSys UK Ltd, University of Surrey, Guildford, Surrey, GU2 7XH Date: 26 November 2009 tel: (+) 1483 689599, fax: (+) 1483 9555, web: www.gnosysuk.com
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Summary
This annex compares the EU Ecolabel fire retardant criteria to other ecolabels; it reviews the overarching principles and criteria and incorporates industry comment about the EU Ecolabel, including awareness and effectiveness in comparison to similar European ecolabels.
The project focused on the following consumer products:
1. Products covered by the Furniture and Furnishings (Fire) (Safety) Regulations 1988: "items which contain upholstery: beds, headboards, mattresses, sofa-beds, nursery furniture, garden furniture which can be used indoors, furniture in new caravans, scatter cushions, seat pads and pillows and loose and stretch covers for furniture".
2. Clothing textiles – nightwear, personal protective equipment and any other relevant categories.
3. Electronic and electrical equipment: specifically including televisions and computers (both personal or office computers and portable computers including laptops and notebooks).
The study considered both consumer products and commercial products (for example, furnishings for public use areas which may be subject to more stringent fire protection standards). The use of fire retardants and the use and awareness of the EU Ecolabel and other ecolabels by business were then assessed by way of a market survey.
The annexe firstly focuses on current ecolabels in existence within Europe and reviews the specifications relating to flame retardant use. A brief overview is given to some of the most relevant national Type 1 ecolabel schemes with high levels of adoption and which have also carried out detailed consideration of the flame retardants issue. This highlighted:
- Approaches based on the use of risk phrases.
- The use of exclusions, such as of organohalogen compounds, often combined with specific exemptions.
- The exclusion of additive flame retardants.
The EU Ecolabel is then examined in greater detail, with comparison to other national labelling schemes. The flame retardant criteria for the EU Ecolabel are contrasted with other ecolabel specifications, with focus on use of additive and reactive retardants as an assessment tool, plus exclusion policies for specific compounds. The use of risk phrases was also evaluated, and suitability of flame retardant restrictions over various product groups awarded the EU Ecolabel.
The market survey demonstrates the widespread use of flame retardants in the electronics area, whereas the situation within textiles is much more complex, with use of flame retardants favoured with mattresses, work wear and foam, but less so in other textile applications and not at all in nightwear.
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Contents
SUMMARY ...... 3
1 INTRODUCTION ...... 6
2 METHODOLOGY ...... 6
3 ECOLABEL SCHEMES ...... 9
3.1 The EU Ecolabel ...... 9
3.2 The Blue Angel Ecolabel (Germany) ...... 12
3.3 The Nordic Swan (Norway, Sweden, Iceland, Finland, Denmark) ...... 15
3.4 Comparison and Conclusions ...... 15
4 OPTIONS FOR ECOLABEL CRITERIA ...... 22
4.1 Application of Alternative Options...... 22
4.2 Acceptability of Ecolabel Criteria and Chemical Risk Assessment ...... 28
4.3 Conclusions ...... 35
5 BUSINESS STAKEHOLDER SURVEY ...... 35
5.1 Selection of Interviewees ...... 35
5.2 Industrial Stakeholder Comment ...... 37
APPENDIX 1 OTHER EUROPEAN ECOLABELS...... 45
The Hungarian Ecolabel...... 47
The Czech Republic Ecolabel ...... 48
The Dutch Ecolabel ...... 48
The French Ecolabel (NF Mark) ...... 49
APPENDIX 2 A NOTE ON RISK PHRASES...... 50
APPENDIX 3 COMPANIES INTERVIEWED ...... 51
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Glossary
BEUC European Consumers‟ Organisation CAS Chemical Abstracts Service Defra Department for Environment, Food, and Rural Affairs EEB European Environmental Bureau EFRA European Flame Retardants Association EU European Union FR Flame retardant GHS Global Harmonised System of Classification and Labelling of Chemicals GPP Green Public Procurement NMN (Nordic Ecolabelling Board) PC Polycarbonate OR Personal computer PCB Printed circuit board PE Polyethylene PET Polyethylene terephthalate PPE Polyphenylene ether OR Personal protective equipment PU Polyurethane PVC Polyvinyl chloride PWB Printed wire board R-phrase risk phrase RAL (German Ecolabelling Board) REACH Registration, Evaluation, Authorisation and Restriction of Chemicals RoHS Restriction of Hazardous Substances TBBPA Tetrabromobisphenol A
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1 Introduction
Flame retardants (FRs) are used in a variety of applications throughout the UK and Europe and their exact chemical formulations differ according to use. Products containing these compounds include textiles (including nightwear, mattresses, soft furnishings and protective workwear) and electronics (such as TVs, laptops, and personal computers), which are the focus of this study.
The purpose of this study is to critically review the approach within the EU Ecolabel criteria for flame retardancy, to propose possible options with initial industry comment. The outputs are a series of conclusions that, together with the risk assessment analysis, will form the recommendations for the EU Ecolabel FR criteria. The EU Ecolabel criteria are important because:
- The EU Ecolabel is meant to be applicable to the top 10-15% of environmentally-benign products. It therefore, to an extent, „sets the standard‟ for better environmental performance in the relevant product groups. It also means that competitive pricing with existing products is not necessarily a reason for excluding that approach.
- The criteria are used in Green Public Procurement (GPP) buying standards. The UK has Government Buying Standards criteria in place for purchasing certain textiles and electronics, but greater harmonisation with GPP criteria is under consideration. Competitive pricing is of greater significance within GPP than it is within EU Ecolabel.
The study compares the current EU Ecolabel criteria with those of other national ecolabels to draw out some of major areas of concern. For example, the current EU Ecolabel criteria for mattresses and textiles specify reactive FRs only. These are defined as being chemically bound to the fibre or fibre surface or cross-linked within the fibrous nano- and microfibrillar structure. Additional risk phrase restrictions apply to the residual flame retardants if they are present in more than trace (>0.1% unreacted) quantities. The criteria for TVs exclude certain risk phrases and certain specific FRs (PBBs and PBDEs). The risk phrase exclusions do not apply to reactive FRs, so long as only trace unreacted quantities remain. For laptops and TVs, short chain chlorinated paraffin FRs are also prohibited.
Different approaches to flame retardancy, such as the use of design and of inherently flame retardant materials, are compared to the existing EU Ecolabel criteria for the different product groups. Conclusions over what is possible (and, for GPP, has cost implications) enable recommendations for the EU Ecolabel criteria to be made. These are tested with a small group of industrial stakeholders, and informed by a wider market survey. The market survey sets out which flame retardants are used in products available to UK markets, across all sectors. The analysis includes: which chemicals are used, how many companies are handling products containing FRs, what level of these are additive, and industrial stakeholder opinion on effects of restricting these sort of flame retardants for GPP policy, on supply chains and on market structure. It also evaluates levels of awareness of the EU Ecolabel (the Flower) across relevant sectors, and industry perception of suitability of these criteria.
2 Methodology
An initial web-based search and literature review was carried out to highlight the most prominent national ecolabels that addressed the issue of FR use across Europe. National competent bodies responsible for assessment of products and allocation of certification were contacted to determine the specific details in
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regards to these specifications. Based on this, a more comprehensive analysis was carried out for the most important ecolabels in regard to FR use.
It is assumed that the efficacy of the flame retardant in use is dealt with via national legislation or by EU legislation. Therefore this study does not consider, for example, arguments around the different modes of action of FRs, or the toxicity of products generated during a fire. The basis for selecting or preferring ecolabel criteria for FRs is based upon:
- Assessment of risk, which is made operational in ecolabels through hazard assessment of ingredients.
- Environmental impacts over the life cycle of the product.
- Technical ability to meet the required legislative standards.
Information on risk (more precisely, hazard) assessments is presented in Annex 2, and technical ability of different technologies is presented in Annex 3. Analysis and comparison of whole life cycle impacts of FRs lie outside of the scope of the project. However, we may use certain principles to guide the comparison, such as the Principles of Green Chemistry. These include waste prevention, use of substances that possess little or no toxicity to human health and the environment, and minimisation of toxicity of chemicals1. From this we can derive the following preferences, which may be subject to individual life cycle assessments but do give a hierarchy of approaches to evaluate the suitability of the varying specifications across the different product groups. This approach is based on the premise that the avoidance of FR chemicals is to be preferred either through use of alternative materials or through design. If FR chemicals are used, then a number of approaches are adopted to minimise their environmental impact. Thus the hierarchy is:
Use of low flammability materials.
Design of products.
Use of flame retardants.
The environmental impact of flame retardants can be minimised by:
Use of risk phrases Prohibited and allowable chemical classes Exemptions
The choice of options was determined by the review of the ecolabel schemes, the review of the risk assessment data available and the technical options for substitution.
There is a final option of using a „White List‟ i.e. prohibiting all flame retardants except for specified chemicals that have been incontrovertibly shown to be of very low hazard. The approaches can be used in isolation or in combination.
1 “Principles of Green Chemistry” Anastas P.T., Warner J.C. Oxford University Press 1998 p30
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These approaches are constrained by:
Meeting legislative requirements.
Maintaining a degree of commercial choice.
Cost.
Product groups are described that are subsets of EU Ecolabel definitions that are impacted by different FR legislation. For each group, the ability of the different FR approaches to meet the constraints put upon them is described.
The framework was validated and commented upon using a number of interviews with knowledgeable individuals who had expertise in the particular product group areas to record their views on the different options. These individuals were selected from the market survey and covered end users, EU Ecolabel licencees and FR manufacturers and representatives. The selection criteria were that they had to:
- be reasonably knowledgeable about FR issues;
- represent a range of views about FRs; and
- represent different points of the supply chain.
Given the different legislative concerns and different material and design options, some product groups within the same EU Ecolabel categories were considered separately (e.g. PPE, sleepwear and interior fabrics, which all reside within the Textiles EU Ecolabel product category).
Finally the overall views of the industrial stakeholders are presented in the market survey, both in aggregate form and also with individual comments. The purpose of this is to indicate the level of awareness and the range of views of the EU Ecolabel and the FR criteria among the business stakeholders consulted. They included:
- Major UK retailer of sleepwear (Marks and Spencer) - Two international electronic goods manufacturers (Philips and HP) - PPE textiles manufacturer and EU Ecolabel licencee (Klopman) - Brominated FR manufacturer (Albermarle) - FR manufacturer (Rhodia) - FR formulator for the textile industry (Avocet) - Chemical blender for PU foam manufacture (Elastogran) - Representative of the Flexible Foams Group of the British Plastics Federation - Research and Technology Organisation (RTO) developing FRs (ITRI) - Textile consultant (Peter Wragg) - Supplier of natural materials to the mattress industry (Enkev) - Mattress manufacturers (Abaca Organic and Harrison).
Information from business stakeholders that could not be sufficiently validated, but may still be useful in setting ecolabel and GPP criteria, is presented as stakeholder opinion in the business stakeholder survey that is described later in the Annexe.
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3 Ecolabel Schemes
The following ecolabel schemes were examined:
- Czech Republic Ecolabel
- Dutch Ecolabel
- French Ecolabel (NF Mark)
- German Blue Angel
- Hungarian Ecolabel
- Nordic Swan
- Spanish Ecolabel (Aenor)
- Swedish TCO Ecolabel
Following the review, it was concluded that the most important ecolabel schemes with respect to FRs were the German Blue Angel and the Nordic Swan schemes. This selection was based on the criteria:
- Type 1 ecolabel (i.e. specification by an external organisation – the most stringent form of labelling).
- Specific FR requirements within the label.
- Use of the schemes as references within EU Ecolabel discussions on FRs .
The reviews of the lower priority ecolabelling schemes can be found in Appendix 1.
3.1 The EU Ecolabel
All of the consumer products being considered in this review are eligible for application to obtain the European Ecolabel2. The EU Ecolabel scheme is voluntary and was established in 1992 to encourage businesses to market products that use sustainable and environmentally friendly technologies throughout the supply chain. It forms part of a broader environmental plan on sustainable consumption and production and sustainable industrial policy that was adopted by the EU Commission on the 16th July
2 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2000:237:0001:0012:EN:PDF Regulation (EC) No 1980/2000 of the European Parliament and of the Council of 17 July 2000 on a Revised Community Eco-label Award Scheme. GR256/Defra/2010 9 of 53 November 2010
20083. At the beginning of 2010 there were more than 1,000 companies that had obtained the stringent EU Ecolabel requirements for their products. Italy, France, Spain and Germany hold the greatest number of licenses (~645) for products.
Figure 4-1-No of EU Ecolabel licences issued since 1992
Source: http://ec.europa.eu/environment/ecolabel/about_ecolabel/facts_and_figures_en.htm
For the consumer products considered here there are currently 88 licenses for textile products, 14 for bed mattresses, 5 for televisions, 2 for desktop computers and 2 for portable computers. In particular, all these products have to satisfy specific FR criteria that are different dependent upon the product group.
EU Ecolabel products groups relevant to this study are shown in Table 4-1 with the flame retardant restrictions that have been imposed.
3 http://ec.europa.eu/environment/eussd/pdf/com_2008_397.pdf Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the regions on the Sustainable Consumption and Production and Sustainable Industrial Policy Action, Com (2008) 397 Final, 16-07-2008.
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Table 4-1: Flame retardant restrictions for different product groups
EU Ecolabel Valid Product Sub-Group Restrictions on Flame Retardants Until Group Textile clothing & Accessories. 10th July Only reactive FRs are allowed plus restriction on certain Clothing4 Interior Textiles, 2013 R-Phrases Fibres Yarn & Fabric Plastic parts shall not contain poly-brominated biphenyl Personal (PBB) or poly-brominated diphenyl ether (PBDE) FRs as Computers5 listed in Article 4 to Directive 2002/95/EC of the 31st May European Parliament and of the Council. Also Plastic 2010 Portable parts shall not contain chloroparaffin FRs with chain Computers6 length 10-17 carbon atom Also restriction of FRs in Electronic plastic parts >25g that contain certain R-Phrases. Equipment Plastic parts shall not contain poly-brominated biphenyl (PBB) or poly-brominated diphenyl ether (PBDE) FRs as 31st listed in Article 4 to Directive 2002/95/EC of the TV7 October European Parliament and of the Council. Also restriction 2013 of FRs in plastic parts >25g that contain certain R- Phrases. Bed mattresses, 10th July Only reactive FRs are allowed plus restriction on certain Mattresses8 fillings for bed 2013 R-Phrases. Alternative hazard statements are used. mattresses
It is important to note that there are many environmental labelling schemes in operation throughout the world. Each scheme covers many different products and services and they are all voluntary.
Within Europe there are 10 recognized environmental labelling schemes, but not all of them cover the products being considered here. The EU Ecolabel Regulation does require that Member States and the European Commission coordinate activities with respect to product categories and the development of criteria and the revision of criteria.
The EU Ecolabelling Board (EUEB) is comprised of all Member States‟ competent bodies that have the responsibility for drafting and revising product criteria, implementing the EU Ecolabel scheme on a national level, assessing applications and awarding the label. In developing the various criteria, the EUEB works in consultation with stakeholders and other interested parties.
4 EU Ecolabel criteria for textile products 5 EU Ecolabel for personal computer products 6 EU Ecolabel criteria for portable computer products 7 EU Ecolabel criteria for TV products 8 EU Ecolabel criteria for bed mattresses GR256/Defra/2010 11 of 53 November 2010
3.2 The Blue Angel Ecolabel (Germany)
The Blue Angel label is the oldest environment-related label for products and services in the world. It was created in 1978 on the initiative of the then Federal Minister of the Interior and approved by the Ministers of the Environment of the federal government and the federal states. It considers itself as a market-conform instrument of environmental policy designed to distinguish the positive environmental features of products and services on a voluntary basis.
The first Basic Award Criteria were adopted by the Environmental Label Jury9 in 1978. In 2009 about 10,000 products and services in 80 product categories carried the Blue Angel eco-label. The Environmental Label Jury is an independent decision-making body composed of representatives from environmental and consumer associations and others. In April 2009 the Environmental Label Jury adopted the first new Blue Angel ecolabel for small portable computers.
The Jury decides on the products and services to be Blue Angel-ecolabelled as well as on the underlying Basic Award Criteria and the respective compliance verifications. These are elaborated on a scientific basis by the Federal Environmental Agency with the collaboration of the German ecolabelling board (RAL) and the groups involved. When establishing the criteria, the Federal Environmental Agency takes into account that about 30% of the best available products on the market are likely to be successful in achieving the Ecolabel requirements.
The Federal Ministry for the Environment Nature Conservation and Nuclear Safety10 is the owner of the label. It has the responsibility to regularly inform the public about the decisions of the Environmental Label Jury and bears substantial responsibility for the use of the label as reliable product information. In addition, the Federal Ministry for the Environment acts in an advisory capacity (without a vote) to the bodies of the Environmental label Jury. The Federal Environmental Agency11 with its „Eco-labelling, Eco-declaration and Eco-procurement department acts as office of the Environmental Label Jury and develops the technical criteria of the Basic Award Criteria for the Blue Angel.
The Blue Angel product groups relevant to the study include the following:
1. Low Emission Upholstered Furniture RAL-UZ 11712
The requirement under section 3.3 - Recycling and Disposal includes the statement that neither material protection agents including FRs, nor halogenated organic compounds i.e. chloro- organic carriers in textiles, may be added to upholstered furniture, including the materials used for its manufacture (leather, textiles, foams, wood-based materials, adhesives etc).
The exemptions are:
- flame retardants using inorganic ammonium phosphates (diammonium phosphate, ammonium polyphosphate etc.)
9 http://www.blauer-engel.de/en/blauer_engel/who_is_behind_it/environmental_label_jury.php (Accessed 1st October 2009) 10 http://www.bmu.de/english/aktuell/4152.php (Accessed 1st October 2009) 11 http://www.blauer-engel.de/en/index.php (Accessed 1st October 2009) 12 http://www.blauer-engel.de/en/products_brands/vergabegrundlage.php?id=128 GR256/Defra/2010 12 of 53 November 2010
- boron compounds (boric acid, borates) or
- other dehydrating minerals (aluminium trihydrate or the like).
Flame retardants used in plastic parts with a mass greater than 25 grams shall be indicated and identified by their CAS number.
2. Mattresses RAL-UZ 11913
The requirement under section 3.3 - Recycling and Disposal includes the statement that neither material protection agents including FRs, nor halogenated organic compounds i.e. chloro- organic carriers in textiles, may be added to mattresses including the materials used for their manufacture. There are no exemptions for FRs.
3. Computers (Workstation Computers and Portable Computers) RAL-UZ 7814
The requirement under section 3.1.2.1 - Material Requirements for Plastics of Casings, Casing Parts, Chassis and Keyboards includes the statement that halogenated polymers shall not be permissible. Organic halogenated compounds as FRs shall not be permissible and may not be added to the plastic parts.
The exemptions are:
- Fluoro-organic additives (for example as anti-dripping agents) used to improve the physical properties of plastics, provided that they do not exceed 0.5 weight percent.
- Fluoroplastics such as, for example, PTFEs.
- Plastic parts weighing less than 25 grams. However, they may not contain polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs) or chlorinated paraffins.
4. Netbooks (Small Portable Computers) RAL-UZ 13515
The requirement under section 3.3.2 – Material Requirements for Plastics in Cases and Case Parts includes the statement that halogenated organic compounds may not be added as FRs. Moreover, additions of FRs labelled with the Risk Phrase R 50/53 pursuant to Table 3.2 of Annex VI to EC Regulation 1272/200816 shall not be permitted. There are no exemptions for FRs. Electronic and electrical products are regulated in Germany by the same standards as in Denmark.
13 http://www.blauer-engel.de/en/products_brands/vergabegrundlage.php?id=140 14 http://www.blauer-engel.de/en/products_brands/vergabegrundlage.php?id=148 15 http://www.blauer-engel.de/en/products_brands/vergabegrundlage.php?id=184 16 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:353:0001:1355:en:PDF GR256/Defra/2010 13 of 53 November 2010
Table 4-2: Product Group Flame Retardant Criteria for German Blue Angel
Product Part (a) Part (b) Part (c) Proprietary Performance Recommendations for Environmentally Legal Description Friendly Procurements Stipulations
Note: Products awarded with the Blue Angel ecolabel (basic criteria document version December 2007) are certified to fulfil all criteria listed here beginning January 2009.
Desktop Reference 17 Reference19 (Desktop PCs) Reference PCs Reference20 (Notebooks) 21
Section 4.1 – Exclusion of certain halogen compounds Notebooks Reference18 Plastic enclosure substances are not to be made of polymers with halogen content (e.g. PVC). Furthermore, no flame retarding agents containing chlorine or bromine are to be added to plastic enclosure parts > 25 g.
Section 4.2 –Exclusion of certain substances
Substances classified by Appendix 4 of EU Guideline 67/548/EWG as having the following hazardous properties may not be added to plastic materials in computer enclosures (parts > 25 g): Carcinogens in EU categories 1, 2 or 3 R 40 suspicion of carcinogenic effect R 45 can cause cancer Mutagens in EU categories 1, 2 or 3 R 46 can cause inheritable damage R 68 irreversible damage possible Reproduction endangering substances per EU categories 1, 2 or 3 R 60 can impair fertility R 61 can harm the foetus R 62 can potentially impair fertility R 63 can potentially harm the foetus
17 Non-proprietary performance description for desktop PCs - Guideline Version 2 18 Non-proprietary performance description for notebooks - Guideline Version 1.0 19 Recommendations for the environmentally friendly procurement of desktop PCs - Guideline Version 1.1 20 Recommendations for the environmentally friendly procurement of notebooks - Guideline Version 1.0 21 Legal requirements on PCs and Notebooks - Guideline Version 2 GR256/Defra/2010 14 of 53 November 2010
3.3 The Nordic Swan22 (Norway, Sweden, Iceland, Finland, Denmark)
The Nordic Swan Ecolabel was initiated by the Nordic Council of Ministers (NCM) for Consumer Affairs almost 20 years ago. From 2006 the Nordic Swan is formally under the Council of Ministers for Environmental Affairs.
The Nordic countries work together using the Swan ecolabel. This work is coordinated by the Nordic Ecolabelling Board (NMN) which has produced a set of regulations. NMN determines which products can be covered by the Swan and the criteria they must meet. Decisions taken by NMN must always be unanimous. Groups of experts from the Nordic countries develop proposals for criteria. The group representatives come from government, environmental organisations, trade and industry.
The Nordic Ecolabelling Board is supplemented by national accreditation bodies. In October 2008, the Council of Ministers for Environmental Affairs unanimously expressed their countries‟ support for further development of the Swan as a first follow-up of the last evaluation of the scheme.
In a recent evaluation of the scheme23 the relationship between the Nordic Swan and the EU Ecolabel was examined to compare the two systems and examine the prospects for co-ordination and harmonization of the two schemes. The two ecolabelling schemes have published criteria for 18 overlapping product groups. The number of product groups with EU Ecolabel criteria (26) is still less than half that of the products included in the Nordic Swan (67).
3.4 Comparison and Conclusions
Table 4-3 shows a comparison of the product group FR criteria across the key ecolabelling schemes in Europe (as discussed at the start of the section). The US EPEAT (Electronic Products Environmental Assessment Tool) falls outside of the scope, but is highlighted here as it has substantial uptake for electronic products in the USA, and acts as a useful comparison for practical and environmental cohesion. The Oeko-Tex scheme for textiles has also been included due to the many references by business stakeholders during the market survey.
Points to note are:
- Ecolabels use hazard assessments of ingredients as a proxy for risk assessment.
- Restrictions are usually based around general restrictions on classes of compound (sometimes supplemented by exemptions) and the use of risk phrases.
- The main general restrictions are on the use of PBB, PBDE, chlorinated paraffins and organic halogenated FRs. These are applied to different extents across the ecolabels.
- The main exemptions refer to fluorinated organic compounds, or plastic parts <25g.
- Typical risk phrase restrictions are R45, R46, R50-R53, R60, R61.
22 http://www.svanen.nu/Default.aspx?tabName=StartPage 23 Report TemaNord 2008:529 ISBN 978-92-893-1680-4 GR256/Defra/2010 15 of 53 November 2010
- There is one attempt only to harmonise with REACH (German Blue Angel RAL-UZ 135 on netbooks).
- Discussions with business stakeholders indicated that the specialist textile label Oeko-Tex, which combines concerns for human and environmental exposure to chemicals, was of particular relevance. This has been included in the summary. It prohibits all FRs except for those on a „white list‟ of approved chemicals.
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Table 4-3 Comparison of Ecolabelling Schemes
Ecolabel Hazard Risk Phrase Restrictionsi and Product Statement General Restrictions Exemptions Conditions (Criterion) Restrictionsii,iii
Exempted from the requirement on halogenated organic compounds are:
Printed circuit boards; Plastic parts lighter than 25g; Casing parts that are demonstrably reused and marked in accordance with requirement R19.
Nordic Swan The above 3 exemptions must not Personal Plastic parts must not contain R45, R46, R60, R61 Prohibited None contain any PBB, PBDE, decaBDE Computers halogenated flame retardants; (R20) or chlorinated paraffins
Fluoro-organic additives which are used to improve the physical properties of plastic, provided they are not present in concentrations greater then 0.5 weight-%.
Fluorinated plastics like for example PTFE.
iv Personal Plastic parts shall not contain Computers EU Ecolabel Plastic parts heavier than 25 grams shall not contain FR substances or polybrominated biphenyl (PBB) or (6g and 6h) preparations that are assigned at the No hazard polybrominated diphenyl ether (PBDE) FRs as listed in Article 4 of time of applying for the eco-label any of statements vi the risk phrases: specified Directive 2002/95/EC or contain chloro-paraffin FRs with chain length 10 to 17 carbon atoms and
Commission chlorine content greater than 50 % decision of by weight (CAS No 85535-84-8
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11/iv/05 R45, R46, R60, R61, R50/53, R51/53 and CAS No 85535-85-9)
(6g and 6h)
This requirement does not apply to FRs that on application change their chemical nature to no longer warrant classification under any of the R- vPortable phrases listed above, and where less Computers than 0.1% of the FR in the treated part remains in the form as before application.
Fluoro-organic additives
German Blue Workstation Angel computers and Organic halogenated flame Fluoro-plastics such as PTFE
portable RAL-UZ 78 retardants
computers (3.1.2.1) Plastic parts <25g, but no PBBs, PBDEs or chlorinated paraffins
Organic halogenated flame No carcinogenic, retardants mutagenic or German Blue reprotoxic Angel RAL- substances in Netbooks UZ 135 R50/53 categories 1 or 2 Not included in „list of candidates‟ Fluoro-organic additives according to from REACH; or persistent, bio- (3.3.2) Table 3.2. of accumulative and toxic according to Annex VI to EC REACH; or very persistent and Regulation ref (2) very bio-accumulative according to REACH
Desktops, EPEAT R45, R46, R50-51-52, R60, R61 not Must comply with RoHS laptops, GR256/Defra/2010 18 of 53 November 2010
workstations, (4.1.1.1) permitted in large plastic parts restrictions on FRs monitors (4.1.6.1) (optional criterion) Short chain chlorinated paraffins not permitted (4.1.6.2)
Plastic parts heavier than 25 grams shall not contain FR substances or preparations that are assigned at the time of applying for the eco-label any of the risk phrases:
EU Ecolabel Plastic parts shall not contain R40, R45, R46, R50, R51, R52, R53, No hazard polybrominated biphenyl (PBB) or R60, R61, R62, R63 viiTVs statements polybrominated diphenyl ether 12/iii/05 specified (PBDE) flame retardants as listed in Article 4 of Directive 2002/95/EC (5) This requirement does not apply to reactive FRs i.e. those which upon use change their properties (i.e. are actually not contained in the final product in a concentration > 0.1 %) such that the identified R-phrases above no longer apply.
PBB, PBDE, decaBDE or Cables Plastic parts, printed wire boards chlorinated paraffins not permitted, included, must not, at the time of appli- taking account the thresholds cation, contain FRs which are assigned specified in Commission Decisions Nordic Swan or may be assigned any of the following 2005/618/EC, 2005/717/EC and Audiovisual risk phrases: 2005/747/EC amending Directive Reactive flame retardants in printed equipment wiring boards (R9) 2002/95/EC
R45 R46 R60, R61 Organohalogen compounds Plastic parts <25g, but PBB, PBDE, decaBDE and chlorinated paraffins
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not permitted
EU Ecolabel (28) 09/vii/09 R40, R45, R46, R49 R50, R51, R52, R53, R60, R61, R62, R63, R68 (1d: Foam) H351, H350, viiiTextiles H340, H350i, H400, H410, Only flame retardants that are If the FRs used have any of the R- H411, H412, chemically bound into the polymer (2d: phrases listed above, these reactive FRs H413, H360F, fibre or onto the fibre surface Polyurethane should, on application, change their H360D, H361f, (reactive FRs) may be used in the Foam) chemical nature to no longer warrant H361d H360FD, product. classification under any of these R- ixBed mattresses H361fd, H360Fd, phrases. (Less than 0.1% of the FR on H360Df, H341 the treated yarn or fabric may remain in 6: Textiles the form as before application.) (Fibres and Fabric))
Textiles Nordic Swan As EU Ecolabel As EU Ecolabel As EU Ecolabel
Furniture and Nordic Swan Padding must not contain
fitments (R32) halogenated flame retardants
R45, R49, R40, R60, R61, R62, R63, R46, R68,R23-28 Not permitted
Chlorinated/brominated paraffins, Nordic Swan Floor coverings halogenated flame retardants, None (R15) The total sum of chemical substances organic tin compounds, phthalates classified as R50, R50/R53, R51/53, and fluorinated compounds R52/R53, R52, R53, R54, R55, R56, R58, R59 must not exceed 2% by weight of the floor covering. The quantity of each individual substance must not exceed 1% by weight of the
GR256/Defra/2010 20 of 53 November 2010
floor covering German Blue Inorganic ammonium phosphates; Low emission Angel boron compounds; other upholstered RAL-UZ No flame retardants or halogenated dehydrating minerals e.g. furniture 117 organic compounds aluminium trihydrate (3.3) German Blue Angel No flame retardants or halogenated Mattresses RAL-UZ None 119 organic compounds (3.3)
AFLAMMIT KWB, AFLAMMIT SAP, FLAMMENTIN MSG (Thor GmbH); APYROL CEP-ECO (CHT R. Beitlich GmbH); Avora Polymer 2370, Avora Polymer 2630, Avora Polymer 2750 (Invista Resins & Fibers GmbH & Co. KG); No flame retardants allowed outside Textiles Oeko-Tex Flavacon ARP, Flavacon WP (Schill of given exceptions. & Seilacher); FLOVAN CGN, PYROVATEX CP new, PYROVATEX CP-LF (Huntsman Textile Effects); PROBAN POLYMER (Rhodia UK Ltd); RUCO-FLAM PCE (Rudolf GmbH & Co KG)
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4 Options for Ecolabel Criteria
4.1 Application of Alternative Options
The options of inherently FR materials, of using product design approaches to eliminate FR chemicals, or of maintaining or amending FR chemical criteria according to approaches commonly found in ecolabels have been extracted from the research on alternative approaches and on risk assessments. Since Section 3 has demonstrated that ecolabels generally approach FR requirements in terms of risk phrases and in the exclusion or allowance of certain classes of chemical compounds, this is taken as the starting point of this analysis.
The EU Ecolabel criteria options are presented after they have been appropriately validated by a number of industrial stakeholders who expressed expertise in the particular product group areas. These were either found through the survey respondents or through consultation with known experts.
The conclusions are tabulated for each product group below, and the general conclusions are summarized in the Technical Report:
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Table 4-4: Matrix of Flame Retardant use in Sleepwear
Comments Technical feasibility of compliance SLEEPWEAR Hazard Assessment Degree of Choice Cost Implications and with UK /EU Legislation Exemptions Inherently FR Relatively few UK legislation can be met using certain perhaps 30% more inherently FR non-FR treated polyesters or specialist expensive material, Generally assessed as low grades in each fibre Low flammability materials FR viscose, polyester or acrylic. but can be blended. hazard type. Cannot use cotton for children‟s wear Non-FR treated Wide choice of without FR treatment polyester – no cost non-FR polyester implications Plasma finishing to graft FRs onto Likely to be considered of Not known but likely Design to eliminate FRs Not known surface (lab scale only) low hazard to be more expensive Oeko-Tex standard FRs are available to meet UK legislation for e.g. polycotton blends Cheapest option is Use of risk phrases, exclusions Phosphorus and nitrogen based FRs are Additive compounds use of non-FR Significant choice of classes of compounds and available, but some reduction in choice currently excluded, and risk polyester, unaffected still likely to be exemptions to control FR if chlorinated FRs are not permitted. phrases R40, R45, R46, by r-phrase changes, available chemical selection R49, R50-53,R60-63, R68 which will meet UK Current focus is on reducing legislation formaldehyde release, which significantly affects use of reactive FRs, and reducing thermoplasticity Oeko-Tex list 7 manufacturers of relates to White list of allowable FR Oeko-Tex has 14 allowable Oeko-Tex human health compounds only compounds allowable products and environment
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Table 4-5: Matrix of Flame Retardant Use in PPE
Comments Technical feasibility of compliance PPE Hazard Assessment Degree of Choice Cost Implications and with UK /EU Legislation Exemptions Inherently FR Some Usually depends on materials more Inherently FR materials commonly restrictions on Generally assessed as low technical expensive, Low flammability materials used, particularly in more sophisticated inherently FR hazard performance, but sometimes PPE materials e.g. widely available substantially so (e.g. UV stability Kevlar) Use of inherently FR Likely to be considered of Design to eliminate FRs materials increases low hazard cost A major issue is keeping the Reactive FRs already in use in PPE. Additive compounds Use of risk phrases, exclusions formaldehyde currently excluded, and Range of well of classes of compounds and level below Some organo-chlorinated FR products risk phrases R40, R45, known products exemptions to control FR allowable used R46, R49, R50-53,R60-63, available chemical selection Ecolabel limits R68 for certain FR chemicals Review Oeko- 7 manufacturers of Tex list in the White list of allowable FR Oeko-Tex has about 14 allowable Oeko-tex allowable light of solely compounds only compounds products environmental criteria
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Table 4-6 Matrix of Flame Retardant Use in Interior Furnishings
Comments TEXTILES FOR INTERIOR Technical feasibility of compliance Hazard Assessment Degree of Choice Cost Implications and FURNISHINGS with UK /EU Legislation Exemptions Foam containing furniture usually uses Ecolabelled polypropylene, wool, polyester or Inherently FR wool products Generally assessed as low Low flammability materials cotton/polyester, all of which require materials up to 2-3x are currently hazard FR treatment. Inherently FR materials more expensive. supplied are available for polyester. without FR Use of interliner increases costs. Usual types (cotton) Use of inherent FR interliners between Likely to be considered of Wide variety of are cheaper than Design to eliminate FRs the foam and face fabric can reduce the low hazard interliners available inherently FR need for FRs. materials – but have FR treatments themselves
Some halogen-free Generally more Phosphorus and nitrogen based Additive compounds FR chemicals are expensive than alternatives available. Some currently excluded, and risk available suitable brominated Use of risk phrases, exclusions chlorinated phosphorus compounds phrases R40, R45, R46, for cotton, polyester alternatives of classes of compounds and used with polyester. R49, R50-53,R60-63, R68 etc
exemptions to control FR Higher cost of chemical selection Alternatives to organobromine Some chlorinated Exclusion of processing due to compounds exist, but more specific to phosphates do not have additive FRs fibre specificity fibre types these risk phrases, so substantially allowable. decreases choice
Review Oeko- 7 manufacturers of Tex list in the White list of allowable FR Oeko-Tex has about 14 allowable Oeko-Tex light of solely compounds only compounds allowable products environmental criteria
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Table 4-7: Matrix of Flame Retardant Use in Mattresses
Technical feasibility of compliance Comments and MATTRESSES Hazard Assessment Degree of Choice Cost Implications with UK /EU Legislation Exemptions Only possible to Conventional design of mattresses Inherently FR have non-FR requires these or FRs. Generally assessed as low Low flammability materials materials up to 2-3x materials if Not possible for PU foams, but hazard more expensive combined with possible for other mattress components design changes. Side seaming rather than tape edging combined with high wool content Redesign of some paddings can meet BS 7177 for Greater use of elements of domestic mattresses without use of Likely to be considered of wool or other less Not possible to Design to eliminate FRs production required. FRs. Also can use interliners from low hazard flammable use PU foams More expensive inherently FR materials or >70% materials required materials natural materials e.g. wool/viscose will meet more demanding standards Depends on the risk phrases of chlorinated phosphorus compounds. Some halogen-free Chlorophosphates are widely used in FR chemicals are combustion modified PU foam. Additive compounds Additive nature available suitable Therefore this would exclude most PU currently excluded, and risk Non-brominated FR of most FR Use of risk phrases, exclusions for cotton, foam mattresses. However FR of phrases R40, R45, R46, chemicals generally chemicals of classes of compounds and polyester etc polyester and polypropylene could be R49, R50-53,R60-63, R68 more expensive than exclude PU- exemptions to control FR achieved with non-halogenated brominated foam mattresses chemical selection Exclusion of products alternatives from ecolabel additive FRs consideration substantially Bromine-based materials less specific decreases choice to fibre types
Review Oeko- 7 manufacturers of Tex list in the White list of allowable FR Oeko-Tex has about 14 allowable Oeko-Tex light of solely compounds only compounds allowable products environmental criteria
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Table 4-8: Matrix of Flame Retardant Use in Electronic Products
ELECTRONIC / Technical feasibility of compliance Comments and ELECTRICAL Hazard Assessment Degree of Choice Cost Implications with UK /EU Legislation Exemptions (TVs/PC/Laptops) Use of inherently FR materials in 3 plastics identified Specific casings, although performance may to be inherently FR requirements for Likely to be more not be comparable. Some use of Generally assessed as low – polysulphone, PCBs. Low flammability materials expensive than usual metals as alternatives hazard polyether sulphone Requirement for high volume plastics New laminate materials for PCBs and polyarylether RoHS (developed for lead-free soldering) ketone compliance Reduction in use of FRs Use of internal metal Likely to be considered of Likely to be more Design to eliminate FRs would assist partitions/casings low hazard expensive recycling of these plastics
PBBs and PBDEs excluded.
Alternatives exist to brominated FRs Risk phrases R40, R45, R46, in PCBs based on phosphorus. R50, R51, R52, R53, R60, Reactive FRs would likely meet R61, R62, R63 all excluded Exemptions in tighter risk phrase requirements. unless reactive and hence other ecolabels Use of risk phrases, exclusions lose r-phrase. The R40, A wide range of FR for fluorinated of classes of compounds and A number of non-halogenated FR R52, R62 exclusions do not chemicals available, More expensive that compounds. exemptions to control FR chemicals exist, but impact on apply to PCs but with cost BFR alternatives chemical selection performance of plastic and cost. penalties
Certain manufacturers already Chlorparaffins excluded (for eliminating halogenated FR PCs). chemicals. Not included in Annex 1 to Directive 67/548/EEC (for PCs)
Several lists of non-halogenated or White list of allowable FR non-brominated compounds have
compounds only been produced by e.g. the Lowell Centre
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4.2 Acceptability of Ecolabel Criteria and Chemical Risk Assessment
The impact of the current EU Ecolabel criteria on typical FR chemicals is shown in the Tables below. Compounds highlighted in RED are acceptable in all relevant EU Ecolabel product groups:
Table 4-9: FRs Subject to European Risk Assessment
#
Acceptability in EU Ecolabel Name Comments
Latest Latest Mattresses and Assessment
EU EU Number Televisions PCs and Laptops
CAS number CAS Abbreviation Risk Phrases Risk Textiles
Banned.
9
2 -
- Xn; Possible risk to Excluded as a
Excluded on basis of 81
PENTABROMO- - Penta R48/21/22 babies through polybrominated 084 2000 risk phrases R50-53 Excluded as a PBDE DIPHENYL ETHER - BDE R64 human breast milk. diphenyl ether and as an additive FR
251 N; R50-53 Possible secondary (PBDE) 32534 poisoning. Banned.
Respiratory and
0
9 -
- Repr. Cat. 2; female fertility
Excluded on basis of 52
OCTABROMO- - Octa R61 effects. Possible 087 2003 risk phrases R61, R62 Excluded as a PBDE Excluded as a PBDE DIPHENYL ETHER - BDE Repr. Cat. 3; risk of secondary and as an additive FR
251 R62 poisoning and more 32536 toxic degradation products Originally excluded as a PBDE, then
Originally excluded as
Possible risk of included by
5 9 - - a PBDE, then included 2003 secondary Excluded on basis of amendment to
BIS (PENTABROMO- 19 Deca by amendment to - 604 2004 N; R50-53 poisoning and more risk phrases and as an Directive DI PHENYL) ETHER - BDE Directive 2002/95/EC,
2007 toxic degradation additive FR 2002/95/EC, this 214 1163 this being annulled by products being annulled by ECJ. Hence excluded ECJ. Hence excluded
GR256/Defra/2010 28 of 53 November 2010
#
Acceptability in EU Ecolabel Name Comments
Latest Latest Mattresses and Assessment
EU EU Number Televisions PCs and Laptops
CAS number CAS Abbreviation Risk Phrases Risk Textiles Acceptable as a Acceptable as a Acceptable as a reactive FR provided reactive FR provided reactive FR provided that residual
that residual unreacted that residual unreacted
9
- unreacted FR is less 7
- TBBPA FR is less than 0.1% FR is less than 0.1%
TETRABROMO-BIS Very toxic to than 0.1% and 236
94 or 2006 N; R50-53 and provided that the and provided that the - PHENOL-A - aquatic organism provided that the
79 TBBA reacted compound is reacted compound is
201 reacted compound is no longer classified no longer classified no longer classified with excluded risk with excluded risk with excluded risk phrases phrases
phrases
-
4 -
99 HBCDD N; R50-53 Excluded on basis of Excluded on basis of -
HEXABROMO- Possible neuro- Excluded on basis of 148 4 or 2008 R62/63, R64 risk phrases R50-53, risk phrases R50-53, CYCLO DODECANE - toxicity risk phrases R50-53
HBCD proposed R62/63 R62/63
25637 247
4 0 - - R40 Excluded since named
DIANTIMONY 64 R38 Possible skin Excluded as an Excluded on basis of in Annex 1 of CPL - 175 ATO 2008
TRIOXIDE - proposed by irritation additive FR risk phrase R40 Directive 215
1309 rejected (67/548/EEC)
-
7 -
TRIS (2-CHLORO-1- 84 Possible fertility -
R22 Excluded as an Acceptable on risk Acceptable on risk 158 METHYLETHYL) 5 TCPP 2008 and developmental - proposed additive FR phrases phrases
PHOSPHATE toxicity
13674 237
- 2
- N;
TRIS [2-CHLORO-1- 87 Excluded as an Excluded on risk -
R51-53 Possible female Excluded on risk 159 (CHLOROMETHYL) 8 TDCP 2008 additive FR and on risk phrase R51-53 for - R22 fertility effects phrase R51-53
ETHYL] PHOSPHATE phrase R51-53 parts >25g 237 13674 proposed
GR256/Defra/2010 29 of 53 November 2010
#
Acceptability in EU Ecolabel Name Comments
Latest Latest Mattresses and Assessment
EU EU Number Televisions PCs and Laptops
CAS number CAS Abbreviation Risk Phrases Risk Textiles
2,2-BIS
4
2 -
(CHLOROMETHYL) -
Possible Excluded as an 10
TRIMETHYLENE BIS - Excluded on risk Excluded on risk 760 V6 2008 R60 due to No risks identified additive FR and as R60 [BIS (2- - phrase R60 if present phrase R60 if present impurity if present
CHLOROETHYL) 253 38051 PHOSPHATE]
Carc. Cat. 3;
5 8 - R40 Possible Excluded as an TRIS (2- - Excluded on risk Excluded on risk
Repr. Cat. 2; carcinogenicity additive FR and on risk
96 118 CHLOROETHYL) - TCEP 2009 phrases R40, R60, phrases R60, R51-53 - R60 unless phrases R40, R60,
PHOSPHATE R51-53 for parts >25g 115
204 Xn; R22 contaminated R51-53
N; R51-53
-
0 -
85 R64 Excluded as an -
Medium chain Excluded on risk Excluded specifically 477 9 MCCP 2007 R66 additive FR and on risk chlorinated paraffins - phrase R50-53 by CAS number
N; R50-53 phrase R50-53
85535 287
-
5 -
84 Carc. Cat. 3; Excluded as an -
Short chain chlorinated Excluded on risk Excluded specifically 476 8 SCCP 2008 R40, R66 additive FR and on risk paraffins - phrase R50-53 by CAS number
N; R50-53 phrase R50-53
85535 287
# Risk phrases from Table 3.2 of CLP Annex VI Hazard phrases from Table 3.1 of CLP Annex VI
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Table 4-10: Examples of Chemical Classification of Commercial Flame Retardants Chemicals from the FR Technology Survey (and not included in Table above).
Chemical Name from Survey CAS number EC Number Classification Acceptability in EU Ecolabel (formal name in italics) Mattresses and Televisions PCs and Laptops Textiles R22, R36/38 X, N; R20/21/22 Excluded as R36/37/38, R51/53, R20/22, R39/23/24/25, Excluded on risk Excluded on risk additive and on 2,4,6 Tribromophenol24 118-79-6 204-278-6 R23/24/25, R11, R63, R43-45 phrases R51/53, phrase R51/53 for risk phrases R63 plastic parts >25g Xi,N,Xn,T,F; R51/53, R63 R36/37/38, R51/53, R20/22, R39/23/24/25, R23/24/25, R11, R63, R43-45 R20/22, R36/37/38, R51/53 “Insufficient data” Excluded as Acceptable on risk Acceptable on risk ammonium polyphosphate 68333-79-9 269-789-9 No significant [health] hazards additive FR phrases phrases Excluded as Acceptable on risk Acceptable on risk bisphenol A diphosphate 181028-79-5 “None listed” additive FR phrases phrases Excluded as an bisphenol A bis (diphenyl Excluded on risk Acceptable on risk 5945-33-5 R53 additive FR and phosphate) phrase R53 phrases on risk phase bis(Tribromophenoxy)ethane Excluded as Excluded on risk 1,1'-[ethane-1,2- additive FR and Excluded on risk 37853-59-1 253-692-3 R20/22; R36/37/38; R51/53 phrase R51/53 for diylbisoxy]bis[2,4,6- on risk phrase phrase R51/53 plastic parts >25g tribromobenzene] R51/53 N; R36/37/38, R51/53 Excluded as Excluded on risk Excluded on risk cresyl Diphenyl Phosphate 26444-49-5 247-693-8 Xn; R48, cat 2 reprotoxin R60 additive FR and phrases R51/53, phrases R51/53, diphenyl tolyl phosphate R 50 / 53 on risk phrases R50/53, R60 R50/53, R60 for
24 https://www.who.int/ipcs/publications/cicad/cicad_66_web_version.pdf GR256/Defra/2010 31 of 53 November 2010
R50/53, R51/53, plastic parts >25g R60 Decabromodiphenylethane or Ethane-1,2-bis Excluded as Acceptable on risk Acceptable on risk (pentabromophenyl) 84852-53-9 284-366-9 R22 additive FR phrases phrases 1,1'-(ethane-1,2-diyl) bis[pentabromobenzene R40 No Tested for this endpoint R42 No R43 No Tested for this endpoint diethylphosphinic acid, Excluded as Acceptable on risk Acceptable on risk 225789-38-8 R45 No aluminium salt additive FR phrases phrases R49 No R50 No Tested for this endpoint R53 No Tested for this endpoint XI, Xn; R20/21, R43-44 Acceptable on risk Melamine Excluded as Acceptable on risk 108-78-1 203-615-4 phrases 1,3,5-Triazine-2,4,6-triamine R20/21; R44 additive FR phrases
Melamine Cyanurates Excluded as Acceptable on risk Acceptable on risk 504-19-8 Xn; R22 1,3,5-triazinane-2,4,6-trione additive FR phrases phrases Excluded as Acceptable on risk Acceptable on risk Melamine polyphosphate 20208-95-1 243-601-5 additive FR phrases phrases Acceptable as a reactive FR provided that residual unreacted FR is less than Acceptable on risk Acceptable on risk Phosphorus polyols N/A None found 0.1% and phrases and as a phrases and as a provided that the reactive FR reactive FR reacted compound is not classified with excluded risk phrases
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Acceptable as a reactive FR provided that residual unreacted None found FR is less than Acceptable on risk Acceptable on risk Poly(dibromostyrene) 148993-99-1 0.1% and phrases and as a phrases and as a provided that the reactive FR reactive FR reacted compound is not classified with excluded risk phrases Resorcinol Bis-(diphenyl Acceptable on risk Phosphate) Excluded as Acceptable on risk 57583-54-7 260-830-6 None found phrases tetraphenyl m-phenylene additive FR phrases
bis(phosphate) Acceptable as a reactive FR provided that residual unreacted FR is less than Acceptable on risk Acceptable on risk Tetrabromobenzoate ester N/A None found 0.1% and phrases and as a phrases and as a provided that the reactive FR reactive FR reacted compound is not classified with excluded risk phrases Acceptable as a reactive FR provided that residual unreacted Tetrabromophthalic anhydride FR is less than Acceptable on risk Acceptable on risk 4,5,6,7-tetrabromo-2- 72625-95-7 Xi; R36/37/38 0.1% and phrases and as a phrases and as a benzofuran-1,3-dione provided that the reactive FR reactive FR reacted compound is not classified with excluded risk phrases Tetrabromophthalate ester Acceptable as a Acceptable on risk Acceptable on risk 26040-51-7 247-426-5 None found bis(2-ethylhexyl) reactive FR phrases and as a phrases and as a GR256/Defra/2010 33 of 53 November 2010
tetrabromophthalate provided that reactive FR reactive FR residual unreacted FR is less than 0.1% and provided that the reacted compound is not classified with excluded risk phrases Excluded on risk Triarylphosphates isopropylated Excluded as Excluded on risk phrases R62, R63 Phenol, isopropylated, 68937-41-7 273-066-3 Rep 3; R62,R63. additive FR and phrases R62, R63 for plastic parts phosphate (3:1) on risk phrases >25g Triarylphosphates isopropylated Acceptable on risk Excluded as Acceptable on risk 7% phosphorus 26967-76-0 248-147-1 None found phrases additive FR phrases tris(isopropylphenyl) phosphate Tribromophenyl allyl ether Excluded as Acceptable on risk Acceptable on risk 2-(allyloxy)-1,3,5- 3278-89-5 221-913-2 R10, R25, R27, R38, R41 additive FR phrases phrases tribromobenzene Xn,N,T; Excluded as Excluded on risk Tricresyl Phosphate R21/22, R51/53, R39/23/24/25 additive FR and Excluded on risk 1330-78-5 215-548-8 phrase R51/53 for tris(methylphenyl) phosphate R51/53, R39/23/24/25 on risk phrase phrase R51/53 plastic parts >25g Rep 2 Xn; R48 R51/53 Excluded as N; R51/53 Excluded on risk additive FR and Excluded on risk Trixylyl phosphate 68952-33-0 273-166-7 phrase R51/53 for on risk phrase phrase R51/53 Rep.2; R60 plastic parts >25g R51/53
# MSDNs without R-phrase classifications tend to be American and not for sale in Europe, or Chinese, or invite the user to enquire through a web form for further information. Our experience has been that it can be difficult to get the company to recognise chemical name or CAS number (they generally require their own product name) and that response times can be in excess of 7 days.
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4.3 Conclusions
Alternative non-FR approaches: there are successful „inherent FR‟ or „FR by design‟ approaches in almost all of the product categories. These do lead to restriction of choice of material, most noticeably the restriction in cellulosic textiles and in the use of certain common plastics in electronics. Costs would increase and the degree of choice decrease in many cases. No firm estimates have been made of the impact on final pricing of the FR-containing product, but it is believed that these would be modest, therefore within the scope of EU Ecolabel, but possibly more problematic with GPP. However elimination of FRs would also bring other advantages such as greater ease of recycling of plastics in the electronics sector.
Hence, although there is probably insufficient evidence that FR chemicals can be excluded from EU Ecolabelled products, sufficient evidence exists to insist upon continued high levels of environmental performance from FR chemicals, since substitution by non-FR approaches is possible in many cases.
Restriction of choice of additive FRs: Tables in Section 4.2 illustrate the impact of the exclusion of additive FR chemicals from the textile EU Ecolabel, with several chemicals with acceptable risk phrases excluded and just a small number of reactive FR chemicals acceptable. Subject to consideration of impacts elsewhere in the product lifecycle, the exclusion of additive FRs appears to create substantial restrictions not justified on hazard assessment grounds.
Exclusion of classes of compounds: brominated compounds can be excluded from all product categories, since alternatives do exist. Similarly for chlorinated compounds, with the current exception of polyurethane foams, however brominated and chlorinated FRs do exist with acceptable risk phrases for the current EU Ecolabel criteria.
5 Business Stakeholder Survey
5.1 Selection of Interviewees
A total of 116 companies were approached, the majority being manufacturers, but input was taken from suppliers, retailers and trade associations. 47 responses were given, though these were not equally distributed across all sectors, with PPE representing the largest responding group (Figure 4-1).
Of those organisations which responded to the initial survey, 60% use FRs somewhere in their products (or products they represent) – though often not applied by themselves directly (Figure 4-2). Due to uneven representation, however, this should not be viewed as typical across the sectors; for example, all electronics manufacturers used FRs, though fewer respondents in this sector replied than in textiles.
It is worth noting, that the majority of „textile other‟ were active in more than one product group – for example fabric manufacturers who produced fabrics for nightwear and PPE, or mattress covers and upholstery. In some areas of the report, the respondents may be stated as slightly higher than shown here, due to the inclusion of the additional „textile other‟ stakeholders who may have commented.
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Figure 4-1: Respondent Product Groups
Figure 4-2: Respondents Using Flame Retardants
Overall, companies were largely poorly informed or did not have a good understanding of how to find out information or who was responsible for the flame retardant use. In particular, those further along the supply chain seemed to have little awareness of what chemicals were used and many believed that, providing flammability regulations were met, and certificates supplied, they had no further responsibility.
Several organisations were hesitant to discuss details of exact chemicals used due to commercial sensitivity. Those that did discuss the issue in more depth were frequently strongly viewed. It is important to highlight the differing responses from various sectors, which is discussed later in the section.
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Figure 4-3: Types of Flame Retardant Used by Respondent Companies
Companies using additive FRs were typically using a range of both additive and reactive – often with inherently flame retardant fabrics used as a first option. Several applications required the use of both, acting in combination with each other.
5.2 Industrial Stakeholder Comment
5.2.1 Awareness
Figure 4-3: Awareness of EU Ecolabel by Product Group
Of the companies questioned, 58% were aware of the EU Ecolabel specifically, with the electronics industry showing the greatest awareness. The use of the EU Ecolabel was theoretically applauded, but
GR256/Defra/2010 37 of 53 November 2010
many companies felt the profile is not yet strong enough for any real influence on consumer behaviour, and therefore on company behaviour. It was noted that the use of the EU Ecolabel in GPP would quite probably change this, and therefore it is important that the exact decisive factors used for criteria are made most effective now.
Textiles/Mattresses
Members of the textile industry were the only group who declined to give response on behalf of their company on the awareness of the EU Ecolabel, and this was typically because the individual questioned was concerned about misrepresenting the organisation as a whole. However, those questioned generally had a good awareness of the EU Ecolabel, with 78% of those who responded personally recognising the certification (see Figure 4-3). The general concept was well received, and a „single – stand alone‟ label that considered whole life was regarded as most beneficial. However, managing the often large and complex supply chain and customer/public awareness was a concern of many.
Electronics
All electronics companies interviewed were aware of the EU Ecolabel, and this could be extended to a further few companies who had answered basic questions but were unable to provide FR details within the time given for response. While awareness was 100%, the overall opinion of the EU Ecolabel was fairly weak. It was considered that more emphasis in the electronics industry is placed on energy labels, and consumers within the UK were not familiar with it as a purchasing incentive. One organisation opined:
“Until the profile of the Flower (i.e. the EU Ecolabel) is raised, it will have no influence on company practices.”
Another organisation, who manufactures several EU Ecolabel products, was uncertain about the effectiveness of any label for this subcategory of products:
“Customers in the UK are driven by touch, and look of products such as televisions and computers. Ecolabelling is more effective for less aesthetic product categories, such as white goods.”
5.2.1 Ecolabel Suitability
The issue of additive FRs being subject to risk phrases, whilst reactive are not, caused some mixed opinions, with one chemical company suggesting that the same restrictions should be placed on both.
Of those organisations which would respond, over half (55%) responded positively, saying they would consider applying for the EU Ecolabel. However, only three respondents were definite about this, with others approving of the concept, but citing specific conditions before they could be certain. The majority of uncertainty was due to lack of detailed information – several stated it would not be a priority, so they would consider if the paperwork or associated costs were not excessive.
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Figure 4-4 – Consideration of EU Ecolabel Application
Textiles/Mattresses
Whilst fairly strongly recognised, no textile company questioned considered the Flower the optimal ecolabel to use, with Oeko-Tex® (Standard 100) mentioned on several occasions. In particular, PPE manufacturers were well aware of the Flower (82% recognition from those who responded), but rated Oeko-Tex® highly, with 50% of PPE manufacturers suggesting they used it - or were more likely to use it, without prompting. This was typically due to customer drive, and therefore marketing for future sales. The EU Ecolabel was not perceived to be a well recognised tool for sales to the general public, yet was considered to be one of the more difficult to obtain. Oeko-Tex® was considered a sufficient environmental standard, which created challenges to obtain, but was achievable.
The furniture industry was hesitant regarding the use of reactive FRs only. This was felt to have been a barrier to application to the EU Ecolabel previously, though this was not seen to be particularly worrisome as it has not been a strong marketing tool and customers were not known to request it. However, should this become a selection criteria for GPP, it was felt strong resistance would be received to the policy.
Foam industry members were strongly against the reactive only criteria for EU Ecolabel, and suggested it would act as an absolute barrier to their application for certification. It was suggested by one industry member that this stipulation created inequality for different products, stating:
“The Ecolabel restriction of additives in foam does not bring about fair levels of „sustainability‟ across different CMR (carcinogenic, mutagenic and toxic to reproduction) substances being Ecolabelled - e.g. carcinogens in hardwood.”
Both respondents also stressed that the method of using reactive versus additive was not a scientifically sound method of testing sustainability.
The general feel by FR manufacturers interviewed was that, whilst the general notion of the EU Ecolabel was a valuable one, the exact details of exclusion were perhaps not as well defined as they could be. One manufacturer producing both reactive and additive FRs felt the products they produced were GR256/Defra/2010 39 of 53 November 2010
environmentally sound, and the emphasis should be taken away from additive automatically being unsustainable in textiles. Individual chemicals should be excluded, or groups such as those containing bromine, heavy metals or antimony. This was an issue iterated by several other stakeholders also, with several EU Ecolabel-restricted chemicals (for textiles/foam) considered „non-harmful to environment or people‟.
Electronics
It was felt by one FR manufacturer that the current EU Ecolabel criteria had about the maximum number of risk phrases that would be practicable with electronic goods. An end user commented on the lack of reasoning behind the selection of the risk phrases by the EU Ecolabel. Halogenated systems were usually required, but chlorophosphorus-based systems were available to replace brominated FRs.
There were two comments by electronic industry members in favour of a „white list‟ approach, which contrasted with the views expressed from the textiles sector. One of the problems foreseen was the criteria for inclusion and the large amount of activity that would be generated from various plastics and FR manufacturers that might make this process difficult to manage. A flow chart was submitted by one consultee as a possible approach that would assist this.
In the more detailed interviews with industrial stakeholders in the electronics sector there emerged greater dissatisfaction with the risk phrase approach, and a greater preference for a white list or one based around systematic risk assessment and REACH requirements. This was not however constraining current applications for EU Ecolabel licences. Removal of halogenated compounds appears technically possible, at the expense of greater cost, a reduction in choice and moving away from the principle of purely a risk phrase based approach.
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5.2.2 Technical Feasibility
Textiles/Mattresses
Several textile companies contacted, particularly those in nightwear, responded that they used inherently flame retardant materials in preference to chemical flame retardants. A number of reasons were given for this, with environmental concerns typically given fairly low importance. For children‟s nightwear in particular, two companies highlighted customers concerns for children‟s health, and problems with allergies/rashes being caused (whether realistically or perceived to be is uncertain) by proximity to material treated with flame retardant chemicals. Similar reasons were given by one mattress manufacturer and a fabric supplier. In all such cases, a specific FR could not be named, and evidence appeared to be very anecdotal.
A large department store has restricted the use of FRs in children‟s nightwear, with the simple explanation of „toxicity‟, and a second, large supermarket has also restricted FR use in similar products, due to concerns of skin irritations should the finishes be incorrectly applied. Whether these stances are based on real, or even current, issues could not be determined. In a separate interview, an expert in FR use in textiles iterated frustrations at emotive media portrayals of dangerous chemical use, citing articles that are several years out of date, referring to substances that are banned still being circulated, and causing unnecessary apprehension in retailers who are not necessarily informed of recent information.
In a follow up interview with a more knowledgeable sleepwear manufacturer, modified acrylic/cotton mixes (i.e. partially inherent FR) were criticised in sleepwear because of hydrogen cyanide emissions; however there are apparently some garments that use this approach.
Most textile sectors did seem to have alternatives to chemical flame retardants available, with examples found in mattresses, upholstery and nightwear. The personal protective equipment (PPE) sector does produce garments composed of inherently flame retarded materials, such as Kevlar, but these were felt to be unsuitable for all applications. Kevlar, for example, was said to have little UV stability, and textiles used for webbing and narrow fibres would not be reliable being produced from this style of fabric. They were rather seen as complementary approaches for different applications and markets.
Reactive FRs are suitable for several PPE applications, with Proban the most commonly used in this sector. However, highly specific PPE applications, for example aluminium smelting, can be more difficult. Due to the characteristics of this work, only specific FRs can be used.
One manufacturer of PPE found the concept of changing to reactive FRs only, particularly concerning:
“There are too many industries to supply, with too wide a range of needs. Additive may be more suitable for certain applications - product A won‟t fit product B, which won‟t fit product C, just to meet sustainability criteria.”
For nightwear, the alternative options are numerous and easily available: simply replacing cotton with polyester, for example, will meet many flammability regulations. Other applications, however, have a far greater likelihood of meeting with flames or flammable substances, and as such need more protection against such events occurring. There are also additional characteristics – such as tensile strength and durability – which need to be taken into consideration. PPE gives several choices of both inherently flame retardant materials such as Kevlar and Nomex, as well as reactive FRs. However, not all PPE requires the same level of protection, or even has the same suitability, and therefore several niche applications may require further investigation for alternatives. GR256/Defra/2010 41 of 53 November 2010
A graded system for textile FR use was suggested by one consultee, with more stringent requirements for free formaldehyde content for children‟s sleepwear, less stringent requirements for garments in contact with adult skin, and less so again for garments not in contact with the skin. This is consistent with the existing EU Ecolabel approach. In the view of this consultee, the formaldehyde issue made Oeko-Tex a more attractive label than EU Ecolabel since it was simply a case of the FR chemical being on the Oeko- Tex white list without further assurances required on free formaldehyde.
PU foam is the single textile application where there appear to be no alternative options to additive FRs, available on the current market. A foam industry stakeholder stated:
“While a few chemically reactive flame retardants are available (to the foam industry) they are in themselves inadequate for levels of fire safety such as those the UK has in place. Chemically reactive substances are used on a very limited basis in combination with additive flame retardants which remain pivotal to UK Statutory Instruments.”
It was also noted that, whilst research in this area is ongoing, there is no technology that has passed, or is near to passing, the stringent testing processes and likely to come onto the market in a commercially viable manner in the near future.
It is also worth acknowledging, however, that foam is not the only available filling method, and two manufacturers were interviewed who supply mattresses that do not require the use of flame retardants at all, through the use of improved design and inherently flame retardant materials. In one example, changes in design (side seaming rather than tape edging) negated the need for FRs, otherwise FRs would be required in covers and/or fillings. Another manufacturer was producing mattresses that only had FRs in the ticking, but was investigating methods of removing these also (for example using denser wool blends).
Alternatives to flame retardant treatment were also available to the soft furnishings industry, with similar options to mattress fillings, using wool - in one case treated with borax. A key issue to development of these pieces was the ability to get testing carried out on each material, not composites only, as it was suggested is widely believed. If that were the situation, cost was considered to be a bigger hindrance, particularly to small organisations and designers. Again, getting materials was initially difficult, but possible. One company sourced coarse wool, which is typically used for wall insulation. However, whilst several needed untreated wools passed the BS5852 standards, an interliner was still required for the top layer in interior furnishings.
Use of interliners as a design alternative to eliminate FR use was felt to be of limited use by other interviewees, however, since it was believed that most interliners in the UK were of cotton, which would require treatment with FRs. An inherently FR material might be used, but there was a difference of opinion whether thermoplastic liners such as polyester would be allowable.
As regards foam fillings, there was a general consensus from consultees that although chlorinated phosphorus compounds were the main FR chemical, non-chlorinated compounds were starting to become commercially available. These were for example being introduced into office furniture by one foam manufacturer, with an eventual ambition of introduction into interior furnishings. There was some drive from customers to replace chlorinated FRs, but concerns were not as great about these compounds, as say brominated FRs. For example, some of the chlorinated phosphorus FRs do not have risk phrases - TCCP was mentioned as an example.
Electronics
FRs used in electronic products are more numerous than in textiles, with different chemicals needed for the different components. Only one company was uncertain if additive FRs were used in its products, with two reactive chemicals used for PWBs and cables, but others used for components whose GR256/Defra/2010 42 of 53 November 2010
categorisation was unclear. Typically most products used both additive and reactive FRs, though televisions were seen to require higher levels of additive (and FRs in general) than laptops.
The use of risk phrases was generally an accepted method of determining environmental safety issues, though it was highlighted by two companies that the specific chemicals (and specific FR groups, e.g. brominated) should be targeted more than additive FRs. It was felt highly probably that significant difficulties would ensue if additive retardants were to be restricted in the same way as they are in textiles.
One manufacturer, which currently produces EU Ecolabel certified products, stated that they tried to use non-halogenated or -chlorinated flame retardants as general practice across their products, hence showing that taking the sustainability aspect a little further was not too arduous.
The electronics sector seemed to have less understanding of alternative FRs than the textile industry, although this is largely due to the wider range of chemicals used and more complex component composition within the product. Textile products, in particular, garments (PPE or nightwear) are relatively straightforward to treat in comparison.
One end user had removed brominated and chlorinated FRs from their products. However some of the phosphate esters used as replacements had the same risk phrases as the products that they were replacing. Another end user had problems of replacing brominated compounds with lesser known products, which had later presented problems when the risk assessments had been carried out. However another end user stated that the choice of non-brominated FRs for the plastics in their products was sometimes very limited.
5.2.3 Cost
Textiles/Mattresses
For much of the textile industry, there appeared to be some concern over the cost of moving towards inherently flame retardant materials or reactive FRs only – with the exception of the sleepwear sector. For nightwear, FRs are not in such wide use as other areas, due to other concerns discussed above. The alternative fabric choice and availability reflects in the cost, and no financial concerns were highlighted for sleepwear.
Several members of the PPE industry indicated concerns of cost increase for „everyday‟ PPE (i.e. not including those niche applications, or the very heavy protective wear). Additives were felt to be a cost effective way of meeting flammability regulations, though reactive FRs were available to most. Views varied however, and several PPE manufacturers used only reactive FRs already. However, even one industry member unofficially emphasised the worry that restriction of additive FRs may result in competitive disadvantage against non-EU manufacturers.
In niche PPE applications, one manufacturer expressed a concern over reliance on inherently retardant materials, which are significantly more expensive. This was felt to potentially encourage companies to “duck the issue”, or in the case of GPP, simply cause purchasers to disregard policy in place of financial aspects.
Use of inherently FR materials for soft furnishings, such as aramid would be possible, but it is claimed would cost approximately ten times more. One manufacturer was using densely woven wool with relatively expensive Kevlar as an interliner. However, finding an initial supplier had, it was claimed, been difficult, with most upholstery associations approached not even aware of options.
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Generally, in the opinion of the industrial stakeholders surveyed, the non-chlorinated FRs will be more expensive and there is greater uncertainty about their effectiveness across different polymer types, with their risk assessments being more uncertain.
Electronics
For electronic products, the brominated FRs were said to be generally cheaper than alternatives and require lower loadings to achieve the same fire retardancy performance while not compromising key physical properties and processability. However, additional cost of compliance with EU Ecolabel criteria was not felt to be significant over the whole product cost. One company stated the additional costs of adherence were low enough for absorption by themselves, with no additional cost to customer. However, the company noted that this might not be possible for smaller manufacturers or those with very tight profit margins.
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Appendix 1 Other European Ecolabels
The Swedish TCO Label25
The Swedish TCO label specifically deals with IT equipment. Product groups that fall within the labelling scheme are Displays26, Desktops27, Headsets28, Notebooks29, Projectors30, Printers31 and Mobile Phones (presently under revision). Specific restrictions on the use of FRs are as follows:
ICT Flame Retardant Restrictions Product Halogenated FRs Non-Halogenated FRs
- Plastic parts weighing more than 25 grams shall not contain FRs or plasticizers that contain organically - Flame retardants used in bound bromine or chlorine. The plastic parts weighing more requirement applies to plastic parts in all than 25 grams shall not have assemblies and sub-assemblies. been assigned one or more of the following risk phrases at - Exempted are printed wiring board the time of application Displays laminates, electronic components and all (according to EU Directive kinds of cable insulation. 67/548/EEG (/EU Directive 1272/2008)): - Shall not contain PBB and PBDE. The requirements apply to components, parts R40(/H351), R45(/H350), and raw materials in all assemblies and R46(/H340), R48(/H372), sub-assemblies of the product e.g. R50/53(/H400 and H410), batteries, paint, surface treatment, R60(/H360F), R61(/H360D) plastics and electronic components.
25 The Swedish TCO labelling scheme 26 TCO Criteria for Display Products v 5 2-Mar-2009 27 TCO Criteria for Desktop Computers Version 1.0 29-Jun-05 28 TCO Criteria for Headset Products Rev 1.1 15-Oct-07 29 TCO Criteria for Notebook Products 3 July 2009 30TCO Criteria for Projector Products Version 1 25-Sep-09 31 TCO Criteria for Printers Version 2.1 15-Nov-06
ICT Flame Retardant Restrictions Product Halogenated FRs Non-Halogenated FRs
As above +
- Flame retardant substances that are being used in plastic parts and printing wiring board laminates that weigh more than 25 g shall be tested for bioaccumulation, toxicity in a water - As above but limited to the Desktop environment, and persistence. The following Risk Phrases: Computers requirement applies to all FR substance levels exceeding 1 percent by weight of R45, R46, R60, R61 the plastic parts and in the printed wiring board laminates.
- Exempted are electronic components and cables.
Notebooks As for Displays As for Displays
Projectors As for Displays As for Displays
- Plastic parts weighing more than 25 grams shall not contain FRs or plasticizers that contain organically bound chloride or bromide.
- The product and peripheral equipment shall not contain PBB and PBDE.
Printers - The limit value for FRs is 0.1 % by weight in homogeneous materials.
- Exemptions are special plastic parts located close to the heating and fusing facilities. These parts must not contain any PBB, PBDE or chlorinated paraffins.
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The Catalonian Ecolabel
The Emblem of Guarantee of Environmental Quality (El Distintiu)32 is the Ecolabelling system of the region of Catalonia (Spain). This system was developed in 1994 by the Ministry of Environment and Housing under the Catalan Government‟s Decree 316/199433. At the beginning, the Catalan Emblem was only for products, and in 1998 by further Decree34, the system was extended to services. The Emblem is a Type I Ecolabel (ISO 14024:1999).
This ecolabelling system is complementary to other ecolabelling systems, especially to the EU Ecolabel; it means that if the same product group exists in the EU Ecolabel system the criteria are compatible. There is also an exemption for paying the renovation fee for the products/services that also are awarded with the EU Ecolabel. On the other hand, the General Directorate for Environmental Qualification is in charge of the Catalan Emblem and it is also the Catalan Competent Body of the EU Ecolabel.
The Catalonian Ecolabel has 28 existing products groups with three under development. Many are about recycled products or materials. There are no product groups that have criteria related to FRs.
The Spanish Ecolabel - AENOR - Spanish Association for Standardization and Certification 35
AENOR was designated to carry out these activities by Order of the Ministry of Industry and Energy, on 26 February 1986. It is an organization dedicated to the development of standardization and certification in all industrial and service sectors. Its aim is to contribute to the improvement in quality and competitiveness of companies, and to environmental protection.
There are no product groups that fit with the scope of this survey and there are no product groups that have criteria related to FRs.
The Hungarian Ecolabel36
In Hungary, the government passed a resolution on September 9th, 1993 establishing an “Environmentally Friendly” product differentiation and certification system. In accordance with the government‟s resolution, the Environmental Protection and Regional Development Ministry founded the „Hungarian Eco-Labelling Organisation‟ Public HELO (hereafter
32 http://mediambient.gencat.net/eng//empreses/ecoproductes_i_ecoserveis/distintiu.jsp 33 Catalonian Government Decree 316/1994, Diari Oficial de la Generalitat du Catalunya, No.1985, 14- 12-1994 34 Catalonian Government Decree 296/1998, Diari Oficial de la Generalitat du Catalunya, No.2772, 23- 11-1998 35 AENOR - Spanish Ecolabelling Organisation 36 http://okocimke.kvvm.hu/public_eng/ GR223 47 of 53 June 2010
referred to as HELO), which is tasked with the coordination and operation of the label certification system. In doing so, Hungary became the first among economically and politically similar countries to introduce such a system.
In general, the Hungarian ecolabel criteria for products and services covered by the EU Ecolabel are identical.
The Czech Republic Ecolabel
The National Programme for Labelling Environmentally Friendly Products was declared on 14 April 1994. The system was initiated by the Minister of the Environment and the Minister of the Economy.
The ecolabel of the Czech Republic and the National Programme for Labelling Environmentally Friendly Products37 are subject to the international technical standard ISO 14024 Environmental Labels and Declarations – Type I Environmental Labelling – the Principles and Procedures and, therefore, they serve as an internationally recognised confirmation of the quality of a product.
In general, the Czech ecolabel criteria for products and services covered by the EU Ecolabel are identical.
The Dutch Ecolabel38
None of the products and services that are covered by the Dutch ecolabel requires the use of FRs.
37 Eco-Labelling in the Czech Republic 2003
38 The Dutch Eco-label Web Site (Milieukeur)
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The French Ecolabel (NF Mark)39
The NF Environmental Mark is one of the voluntary national standardization marks granted by the Association Française de Normalisation (AFNOR), provided for by amended French Decree No.84-74 of January 26th, 1984. Furthermore, the NF Environmental Mark materialises the certification of a product within the meaning of Article L 115-27 of the French Consumer code40 and must meet ecological and fitness for purpose criteria. The various NF Marks which are associated with the product groups within this project scope are as follows:
NF Environmental Mark for Ecological Products
NF217 – which relates to domestic furniture, office furniture, professional furniture.
NF Mark for Relevant Industrial and Consumer Products
NF022 - Domestic furniture which relates to seats, kitchen furniture and bathroom furniture. NF089 - Household appliances which relates to electrical appliances. NF208 - Electrical equipment which relates to electrical. NF226 - Medical Mattress which relates to mattress foam helps prevent pressure sores, mattresses and mattress with water helps prevent bedsores, mattress and air mattress to aid in the prevention of bedsores and gel mattress pad helps prevent pressure sores. NF372 - Contract furniture (contract, education, health, technical) which relates to furniture.
39 Official site of the NF Mark Eco-Label
40 French Consumer Code http://195.83.177.9/upl/pdf/code_29.pdf
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Appendix 2 A Note on Risk Phrases
Risk phrases (regulatory hazard labelling phrases) have been used in many national and international ecolabelling schemes. The EU Ecolabel scheme was established in 1992 and followed the convention of other schemes, particularly the German Blue Angel and the Nordic Swan. In reality, the statements which are assigned to the risk phrases are in fact hazard statements which are a formal part of European chemical safety classification.
However, it is important to note that chemical classification (see Annexe 2) should always be supported by adequate toxicity data. It is possible for potential users of a chemical FR technology to confuse the absence of a classification with it being acceptable for use. For ecolabels this should not be acceptable and any FR that has no classification and appears to meet ecolabel requirements should have adequate toxicity data to support this position.
Risk phrases have continued to be used when defining chemical criteria for additives used in a variety of products. R-phrases are defined in EU Directive 67/548 relative to classification, packaging and labelling of dangerous substances and are applicable to all chemicals which represent a risk for health or for the environment. R-phrases take no account of exposure and thus risk to human health or the environment.
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Appendix 3 Companies Interviewed
Product group Company name Chemical/coatings Bollom Group Chemical/coatings Indestructible Paint Chemical/coatings Morrells Woodfinishes Chemical/coatings Name withheld Chemical/coatings Name withheld Chemical/coatings Thor Chemicals UK Ltd PC/laptop/TV Panasonic PC/laptop/TV Philips PC/laptop/TV HP PC/laptop/TV Sharp PC/laptop/TV Hitachi Foam Flexible Foam Group Foam Vitafoam Mattresses Abaca Organic Ltd Mattresses Beds4zzz Mattresses Enkev Mattresses Silentnight Mattresses Sutcliffe Ltd Nightwear Akroyd & Sons Ltd Nightwear M&S41 Nightwear Name withheld Other (textile) Alan Ross Consulting (via ASBCI) Other (textile) Camira Fabrics Other (textile) Name withheld Other (textile) Name withheld Other (textile) Nylatex Other (textile) Offtree Other (textile) Palmhive
41 Whilst M&S do sell products other than nightwear that may contain flame retardants, this was the only area commented on by the interviewee, due to area of expertise.
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Product group Company name Other (textile) Peter Wragg (textile consultant) Other (textile) Specialist Garment Braids Soft furnishings Fabric Select Soft furnishings Glendale Textiles Soft furnishings Wood Bros Furniture Workwear Allen & Douglas Workwear Arco Workwear Bristol Oilskins Workwear Bristol Uniforms Workwear CCW Workwear Faithful Workwear Workwear FE Engel Workwear Fristads Workwear Incorporatewear Workwear Lantex Workwear M.Wright & Sons Workwear Name withheld Workwear Orbit International Plc Workwear Turner Virr & Co
i Commission Directive 2000/32/EC, 19th May 2000, adapting to technical progress for the 26th time Council Directive 67/548/EEC on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances. ii Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008, on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006, OJ:L:2008:353/1, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:353:0001:1355: en:PDF iii Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008, Annex III, List of Hazard Statements, Supplemental Hazard Information and Supplemental Label Elements, OJ:L:2008:353/146, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008: 353:0001:1355:en:PDF iv Commission Decision 11th April 2005, establishing ecological criteria and the related assessment and verification requirements for the award of the Community eco-label to personal computers, (2005/341/EC), OJ:L:2005:115/1 http://ec.europa.eu/environment/ecolabel/ecolabelled_products/ categories/portable_computers_en.htm v Commission Decision 11th April 2005, establishing ecological criteria and the related assessment and verification requirements for the award of the Community eco-label to portable computers, GR223 52 of 53 June 2010
(2005/343/EC), OJ:L:2005:115/35 http://ec.europa.eu/environment/ecolabel/ecolabelled_products/ categories/portable_computers_en.htm vi Directive 2002/95/EC 27th January 2003, on the restriction of the use of certain hazardous substances in electrical and electronic equipment, OJ:L:2003:37/19, http://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=CELEX:32002L0095:EN:HTML vii Decision 12th March 2009, establishing ecological criteria and the related assessment and verification requirements for the award of the Community eco-label to televisions, (2009/300/EC), OJ:L:2009:82/3, http://ec.europa.eu/environment/ecolabel/ecolabelled_products/categories/televisions _en.htm viii Commission Decision 9th July 2009, establishing ecological criteria for the award of the Community eco-label for textile products, (2009/567/EC), OJ:L:2009:197/70, http://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=OJ:L:2009:197:0070:0086:EN:PDF ix Commission Decision 9th July 2009, establishing ecological criteria for the award of the Community eco-label for bed mattresses, (2009/589/EC), OJ:L:2009:203/65, http://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=OJ:L:2009:203:0065:0080:EN:PDF
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