1. 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

2. 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

3. 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

4. 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

5. 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

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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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