Industry Response to Öko-Institut Recommendations Wednesday, June 18, 2008 Crowne Plaza Europa Hotel Brussels Brussels, Belgium Dr. Manfred Cygon Isola GmbH Düren Düren, Germany June 2008 - Dr. M. Cygon TBBA-Brussels

Impact of the Öko-Institut, recommendations on the Laminate Manufacturer, in particular TBBA. June 2008 - Dr. M. Cygon TBBA-Brussels

Tetrabromo-Bisphenol-A What is TBBA? -C- CH3 -OH HO- Br Tetrabromo-Bisphenol-A The largest volume brominated flame retardent in production world-wide today.1)‏ 1) EBFRIB, 2006 June 2008 - Dr. M. Cygon TBBA-Brussels

How is it used in Epoxy resins for Base Materials? TBBA is a reactive chemical. After processing TBBA does not exist as a free chemical in the polymer matrix but as part of the polymer chain to be cured in the final product, e.g. FR-4. -C- CH3 -O- Br CH2-CH-CH2-O- OH -O-CH2-CH-CH2 O June 2008 - Dr. M. Cygon TBBA-Brussels

Electronic equipment can be the root of fire if it is not Why do we need TBBA? Electronic equipment can be the root of fire if it is not flame retarded. The most effective flame retarder is TBBA and we achieve easily the highest FR-class V-0 according to UL 94 spec. which is required world-wide. June 2008 - Dr. M. Cygon TBBA-Brussels

Do we have Risk Assessments? Several Risk Assessments have been carried out. None showed a risk for reactive TBBA: - „Erarbeitung von Bewertungsgrundlagen zur Substitution umweltrelevanter Flammschutz- mittel“, December 2000, Environmental Ministry of Germany (carried out by Öko-Institut)‏ - EU Human Health Risk Assessment, Feb. 2005 - EU Environmental Risk Assessment, June 2007 No risk! June 2008 - Dr. M. Cygon TBBA-Brussels

Do we have Risk Assessments? - European Commission‘s Scientific Committee SCHER, January 2008 - REACH - Over 200 studies have been produced in the context of the Risk Assessment Agrees with the conclusions of RAR (EU Risk Assess- ment Report)‏ TBBA does not meet any of the criteria for REACH substances of concern! No risk! June 2008 - Dr. M. Cygon TBBA-Brussels

Report by Prof. Korte, University Munich Report by Italian Authorities Do we get Dioxins or Dibenzofurans in case of the thermal decomposition of TBBA-modified Epoxy? All tests show that critical dioxins and dibenzofurans are not formed, even in the worst case of a reactor blow up. Report by Prof. Korte, University Munich Report by Italian Authorities June 2008 - Dr. M. Cygon TBBA-Brussels

Do we have alternatives? Some halogen free base material grades are available. The FR-system is mainly phosphorous modified epoxy in combination with Al (OH)3. Risk assessments of the phosphorous components have not been carried out sufficiently. Al (OH)3 is critical regarding thermal resistance. Not all TBBA-modified epoxy resins can be substituted by halogen free components from a technical point of view. June 2008 - Dr. M. Cygon TBBA-Brussels

A not well-founded ban of TBBA as reactive component to Impacts A not well-founded ban of TBBA as reactive component to produce flame retarded epoxy systems will have a tremendous impact on the electronic industry in Europe. For many companies it will become a matter of survival. Here are some facts to underline this statement: The substitution of TBBA-modified epoxy systems with the more expensive halogen free systems will result in approx. 150 Mio € p.a. additional costs for base material only! The approval of alternative materials at PCB shops and OEM’s will take 2-5 years and will cost approx. 12-15 Mio €. June 2008 - Dr. M. Cygon TBBA-Brussels

Impacts Since some electrical and dielectrical properties of halogen free materials are different, compared to TBBA modified, there will be a necessity for a re-design of many PCB’s. The expenditure therefor cannot be predicted. Halogen free alternatives have not been developed for all cases. It will take at least 5 years to develop such resins, but resin experts doubt that it is possible to find drop in solutions. Anyhow, a two-digit million € sum will be requested. The production capacity for halogen free resins is by far too small to cover the full demand. June 2008 - Dr. M. Cygon TBBA-Brussels

Conclusion A ban of TBBA is absolutely not justified from a technical point of view, in particular for reactive TBBA! We have long year experience with TBBA in applications where a high reliability is required, e.g. automotive, aircraft, military. We should not take a needless risk with substitutes. Laminators are always prepared to support environmental friendly technologies if there are proven facts. We do not accept that further activities on TBBA are discussed without the participation of the affected industry (Öko-Institut). June 2008 - Dr. M. Cygon TBBA-Brussels

Conclusion We do not accept that political organisations have more influence on EU regulations than the well experienced industry (Greenpeace). We do not accept that TBBA is put on the priority list of the EU because of political reasons as they do not have scientific reasons. This is prejudgement! (Laperrouze-Report)2)‏ A lot of money has been spent for several risk assessments. Why don’t we trust the results? 2) ZVEI, Stellungnahme des Verbandes der Leiterplattenindustrie und des Fachverbandes “Electronic Components and Systems” im ZVEI Zentralverband Elektrotechnik- und Elektronikindustrie e.V. June 2008 - Dr. M. Cygon TBBA-Brussels

Conclusion It will weaken the electronic industry significantly if a new regulation of the EU forces us to spend a lot of money for a groundless substitution process instead to invest the money into innovations which help to keep or strengthen our position in this key technology. Regulations like WEEE, RoHS and REACH have always been accepted by the electronic industry because of justified facts. We supported the implementation actively and on time. The EU should take this into consideration prior they continue to extend the RoHS on base of rumours and political games. The electronic industry will always be a fair partner for open minded, well justified discussions as in the past! June 2008 - Dr. M. Cygon TBBA-Brussels