BSEF Position Paper Grouping of Brominated Flame Retardants

Brominated Flame Retardants are essential to protect lives and property, by inhibiting ignition of combustible materials, and by slowing the rate at which a fire propagates increasing escape time and time for emergency services to act.

A wide variety of Brominated Flame Retardants are needed to satisfy the diversity of engineered materials used today, thereby protecting people, property and important societal innovation aimed at reducing carbon footprint in housing and transportation.

Individual Brominated Flame Retardants are designed to work in a polymer system. They are widely different in structure and functionality. They are not one single group of similar chemicals. Substituting one brominated flame retardant with another or with a non-halogen flame retardant is not readily possible in all circumstances.

REACH dossiers can be used to assess chemical similarities however more robust analysis should include detailed information on the working mechanism, uses and end use applications of chemicals under review.

When identifying the essential use of a chemical or its alternatives, technical performance, durability of the final article, matrix compatibility, decomposition products are also important flame retardant characteristics for sound regulatory decision making.

BSEF, the International Bromine Council, hereby shares its views on a possible grouping of brominated flame retardants (BFRs) as announced in the recently adopted REACH Restriction Roadmap by the European Commission on 25 April1 .