CONSUMER PRODUCTS AND RETAIL E-SSENTIALS

EU: Lowers HBCDD limit under POPs

SEPTEMBER 2024 - ELECTRICAL AND ELECTRONICS, HARDLINES, SOFTLINES, TOYS AND CHILDREN'S PRODUCTS

The amendment¹ of EU Persistent Organic Pollutants (POPs) Regulation² was published on 27 September 2024. This reduces the limit value of Hexabromocyclododecane (HBCDD), listed in Annex I of Regulation (EU) 2019/1021 as an unintentional trace contaminant (UTC) in substances, mixtures and articles. The amendment will apply from 17 October 2024.

HBCDD, a restricted brominated flame retardant, has raised concerns due to its occurrence in recycled materials. It has long been the most important flame retardant used in polystyrene insulation materials (expanded polystyrene (EPS) and extruded polystyrene (XPS)). Moreover, this substance has been used in textiles, packaging materials or high-impact polystyrene (HIPS) for electrical and electronic applications.

The use of HBCDD has been largely phased out in the EU market. The European Commission further evaluated the UTC limit of HBCDD as stated in the POPs Regulation and decided to lower the limit value. However, the limit value of recycled polystyrene in the production of EPS and XPS insulation material for use in buildings or civil engineering works remains the same as further improvements to the recycling process and more concrete evidence are required to decide the limit value. A further review will be carried out by 1 January 2026.

Table A: Comparison of HBCDD updates

[1] Regulation (EU) 2024/2555, amending HBCDD’s limit

[2] EU Persistent Organic Pollutants (POPs) Regulation (consolidated version on 28 August 2023)

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