15 Sept 2016
Denmark Assesses Chlorinated Phosphorous-based Flame Retardants in Articles Intended for Children
Hong Kong traders selling children’s articles such as children’s car seats, baby slings and prams may want to know that the Danish Environmental Protection Agency has produced an assessment of chlorinated phosphorous-based flame retardants in children’s articles containing foam. The report, published in Denmark earlier this year, provides a comprehensive review of the market distribution of three flame retardants in children’s articles and of possible alternatives thereto.
The project is part of the Danish Environmental Protection Agency's efforts to evaluate the need to prepare a proposal for the regulation of these substances at EU level. The overall objective of the project was, indeed, to establish the scientific justification for a possible proposal for an EU-wide regulation, so as to manage the risk from phosphorous-based chlorinated flame retardants in children’s articles containing foam.
Hong Kong traders selling toys may be relieved to learn that toys were not included in the scope of the study. This is because they are already regulated at the EU level.
The report concerns three phosphorous-based chlorinated flame retardants, named below, in children’s articles that contain flexible polyurethane (PUR) foam:
- TCPP, which is the least-costly and most-used of the concerned flame retardants; it is believed to be an all-round flame retardant.
- TDCP, which is more expensive and used mainly for automotive applications due to lower fogging potential.
- TCEP, which is currently not used in the EU but may be present at low levels in certain flame retardants (V6 or V66) and hence be present in articles.
Hong Kong’s suppliers should be informed that, according to the report, all three substances were found in various children’s articles, e.g. car seats, baby slings, prams, carrycots, baby strollers, as well as in a few earphones and baby changing mats.
The report highlights that TCPP and TDCP are typically present together, even though TCPP is cheaper and would be expected to be found on a stand-alone basis in most articles. EU manufacturers who participated in the survey indicated that they usually did not use those flame retardants in combination; most tested articles were produced in Asia. This could explain the results obtained by the survey, but no information on the typical use pattern of the flame retardants in Asia is yet available.
According to the report, EU manufacturers prefer to avoid the use of these substances because of their potential health risks and consumer concerns. Moreover, PUR foams containing flame retardants would also have inferior technical performances, particularly regarding durability, comfort and smell.
The report found that the main driver for manufacturers to use these substances after all, stems from UK and Irish fire safety regulations. However, the results obtained show that the concentration of flame retardants found in many products was far below the concentration expected to comply with UK and Irish regulations. This indicates that they are present either as an impurity in substances not tested for this purpose, or are present as contaminants (e.g. from the manufacture of the foam). Moreover, most surveys analysed composite samples consisting of both PUR foams and textile which may explain to some extent such low levels. The use of rebounded foams from production scarp is a plausible explanation since the survey shows that it is common to mix scraps of flame retardant and non-flame retardant foams.
Finally, Hong Kong traders selling children’s articles containing foam may be interested in knowing that the report seems to indicate that there is no simple substitute for the use of chlorinated phosphorus flame retardants for all applications. Different alternatives may be needed depending on the nature of the foam. Reactive flame retardants and polymeric flame retardant alternatives have a better environmental and health profile than chlorinated phosphorous flame retardants, but have been developed for use in automotive applications because of their properties, which are particularly suited to the requirements of this sector. Melamine is another suitable alternative but it is only applicable for a limited range of foams (dense foams).
Moreover, these alternatives have been used mainly for furniture complying with U.S. regulations and limited experience of their use for furniture complying with UK regulations has been identified. The report highlights that finding alternatives suitable for the UK market requires substantial research and development (R&D). The time needed for R&D is indicated to be in the range of 3 months to one year for each application. A full transition would require the build-up of additional capacities, which would take between 3 and 5 years. Additionally, manufacturers indicated that these alternatives were more expensive by 20 to 200%.
One of the conclusions reached in the report is that if a limit value of 5 mg/kg (0.0005%) were to be applied, manufacturers and importers of children's articles would need to apply more extensive controls with respect to their consignments being sold in the EU. For the Member States’ authorities, such a low limit-value would lead to extra inspection and control costs, as the likelihood of articles not in compliance with the restriction would be much higher as compared with the situation if a limit value of 0.1% were to be applied. Indeed, according to the European trade association EUROPUR, it may be challenging to meet a limit value of 5 mg/kg, which is said to be the limit value applied in the Toy Safety Directive for the targeted substances. EUROPUR prefers a more realistic tolerance level, namely, a limit value of 0.1%, if Denmark chooses to go ahead with the preparation of a restriction proposal for eventual application in all EU Member States.
Please click on the following link to view the Danish Environmental Protection Agency report.