Proposed restriction of organo-halogen compounds and its possible impact on the electronics sector 18 June 2008 Resources Exercise 1 OHP and paper pens Exercise sheet 1 x 1 per group Exercise sheet 2 x 2 per group

Öko Institut’s proposal Restriction of all organo-bromine and organo-chlorine compounds. Organo-fluorine based materials would be affected if “organo-halogens” are restricted Restriction proposed only to prevent harm from “backyard” recycling

Organo-halogen compounds Brominated flame retardants – most are not hazardous materials Chlorinated polymers such as PVC – not hazardous materials Epoxy resins (epichlorohydrin-bisphenol A) Adhesives, coatings, resins Fluxes – small amounts used Fluorinated polymers – wire insulation, bearings

Backyard processes & organo-halogens No risk from modern recycling technology WEEE is exported from EU and USA to Asia for recycling Equipment is shipped to Africa for re-use and subsequently is recycled “Back-yard” recycling is quite common in Asia and Africa Low efficiency, aimed mainly at recovering metals - copper, silver and gold Plastics are burnt on fires – this emits toxic gases

Uncontrolled recycling Uncontrolled combustion products include: Brominated flame retardants – bromo-dioxins and furans Organo-chlorine – chloro-dioxins and furans Non-halogenated polymers – PAH, benzene, etc. Dioxins and furans are very toxic and are carcinogens. PAH are also carcinogens so replacing organochlorine and organobromine by halogen-free plastics does not eliminate risk

Uncontrolled recycling Benefit from this ban would not be realised until 2018 at least 2012 – ban introduced 2008 2018 6 years – typical product life

Uncontrolled recycling Workers and locals also affected by process chemicals and heavy metal pollution Cyanide, acids, mercury, etc usedto recover gold, copper, silver Blood lead (and other metals) levels found at high, harmful levels These problems can only be eliminated by stopping these processes

Brominated flame retardants Flame retardants used to stop fires but also delay fires to allow time to escape – this saves lives If flame retardancy is reduced, time for escape will be shorter and there would be more fire deaths and injuries Not always easy to identify halogen-free alternatives with equivalent flame retardancy Impossible in some cases – exemptions would be needed The only effective direct alternatives are phosphorous-based Limited and inadequate testing, some are not harmless Impact of most on health and environment not fully known World-wide capacity far too small to replace all brominated flame retardants Another alternative is by eco-design – metal enclosures, etc. This limits design options and has other environmental impacts

Chlorinated polymers PVC and other chlorinated polymers Neoprene and other synthetic rubbers Substitutes are different polymers (different properties) Plasticised PVC for wire and cable fluoropolymers, - high temperature resistance, better flexibility, longer life but more expensive PE (ATH flame retardant), fairly commonly used and low cost. Used in vehicles, tunnels, etc, as low smoke in fires - but is less flexible than PVC

Epoxy resins Bisphenol A – Epichlorohydrin is most common type Uses - Adhesive, conformal coatings, potting, paints Difficult to find alternatives for some applications More exemption requests

Organofluorine compounds Inherently flame resistant Produces toxic gases when burned – HF, etc. Used for wire insulation, oil-free bearings, non-stick surfaces No alternatives for most applications

Impact on the electronics industry Manufacturers will need to identify where these substances are used Experience with RoHS when adopted that this is very difficult – could take >2 years + time to develop substitutes Most manufacturers do not know which flame retardants are used, neither do most suppliers due to long supply chains Standard procedure is to buy plastics based on flame retardancy specification - chemical constituents are rarely specified Many different organobromine and organochlorine materials are used for many applications Substitutes are rarely drop-in substitutes Each requires research and extensive testing

Impact on electronics industry - Small and medium size producers Small and medium size manufacturers will have much greater difficulty due to lack of resources - staff available to identify, design and test possible alternatives technical skills – knowledge of materials and possible alternatives Little influence over suppliers – to identify where the substances occur and to ensure that compliant parts are supplied Have to use what is available – buying power too small to customise materials

Control of supply chain by SMEs Experience is that this is very difficult for plastics Lead, cadmium, PBDE frequently found in imported plastic parts Only very large multinationals can audit and approve all suppliers in supply chain. SMEs can sometimes audit only their direct suppliers Analysis of every batch is very expensive and may not guarantee compliance if several batches of plastic are used for one batch of parts 60% of world’s electronics made in China Most components are made in Asia Products and components from Asia contain Asian plastics from unknown sources

Supply chain example Many links in supply chain, importer cannot identify material supplier or whether they are reliable Material supplier 1 Component manufacturers Component distributor Material supplier 2 Material supplier 3 Asian product manufacturer Asian exporter EU based equipment importer

Conclusions Proposals are for: Replacement of low/zero risk substances by substitutes that are not fully tested In the past, what were thought to be safe substances were eventually shown to be dangerous E.g. DDT toxic to humans and birds of prey Banning organochlorine and organobromine compounds will not prevent illness and deaths due to uncontrolled recycling – a different solution is needed Introduction of substance bans is very difficult for smaller importers and manufacturers